European Association for the Consumption-based billing of Energy Costs

E.V.V.E.

E.V.V.E.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

WE Data Europe welcomes the opportunity to provide feedback on the Climate Delegated Act and recommends updating the technical screening criteria of Activity 3.5 to reflect recent technological and regulatory developments. We propose broadening the scope to include the manufacturing of cold-metering equipment to ensure alignment with EU legislation and coherence with related Taxonomy activities, and explicitly recognising the essential role of software and digital platforms that enable submetering, consumption-based billing, data-driven optimisation and energy savings in buildings. These enhancements would improve consistency across the Taxonomy, support efficient heating and cooling solutions, and more accurately capture the contribution of digital technologies to climate mitigation. Detailed feedback is provided in the attached document.
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Response to Roadmap for artificial intelligence and digitalisation for energy (RAID-E)

5 Nov 2025

WE Data Europe welcomes the opportunity to contribute to this Call for Evidence. Please find attached our feedback. We look forward to further collaborating with the European Commission and all interested stakeholders on this essential initiative.
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Meeting with Pierre Schellekens (Director Energy)

24 Oct 2025 · The way forward for the energy efficiency framework

Response to New European Bauhaus

16 Oct 2025

WE Data Europe welcomes the opportunity to contribute to this Call for Evidence. Please find attached our feedback, which contains our new Smart Water Metering Study. The study, conducted by the Flemish Institute for Technological Research (VITO), analysed water consumption and regulatory frameworks across six EU Member States, complemented by expert interviews and an extensive literature review. This is the first analysis of its kind at the European level, providing the strongest evidence to date of how smart metering can deliver real, measurable, and lasting water savings. Its key findings include: Metering works: Installing individual water meters in buildings where none previously existed can reduce water use by up to 25%. Digital meters deliver more: Upgrading from analogue to digital meters results in an additional 58% reduction, while also enabling leak detection and real-time consumption feedback. Leak detection is impactful: Buildings equipped with leak detection systems consumed 714% less water. Behavioural change matters: Real-time consumption information encourages households to use water more efficiently and helps prevent waste. A comprehensive rollout of smart water metering represents a major opportunity to reduce buildings water consumption by up to 25%. As evidenced by the Water Resilience Strategy, the New European Bauhaus provides significant opportunities to boost efforts towards water resilience across the built environment. In this context, we recommend that the New European Bauhaus encourage all new buildings, as well as those undergoing major renovation, to be designed and prepared for the installation of individual smart water meters, at apartment level. We look forward to further collaborating with the European Commission and all interested stakeholders on this initiative.
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Response to Evaluation of the Measuring Instruments Directive

9 Oct 2025

WE Data Europe welcomes the opportunity to contribute to this Call for Evidence. Please find attached our feedback. We look forward to further collaborating with the European Commission on this initiative.
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Response to Heating and cooling strategy

8 Oct 2025

WE Data Europe welcomes the opportunity to contribute to this Call for Evidence. Please find attached our feedback. We look forward to further collaborating with the European Commission and all interested stakeholders on this essential initiative.
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Meeting with Hildegard Bentele (Member of the European Parliament) and ista SE

30 Sept 2025 · Water Metering

Response to Citizens energy package – protecting and empowering consumers in the just transition

10 Sept 2025

WE Data Europe welcomes the opportunity to contribute to this Call for Evidence. Please find attached our position paper below. We look forward to further collaborating with the European Commission and all interested stakeholders on the development and implementation of the Citizens Energy Package.
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Response to European Affordable Housing Plan

4 Jun 2025

EVVE welcomes the opportunity to contribute to this Call for Evidence. Please find attached our feedback. We look forward to further collaborating with the European Commission and all interested stakeholders on this essential initiative.
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Response to Common templates for the transfer of the information in national databases to the EU Building Stock Observatory

5 May 2025

EVVE appreciates the opportunity to provide feedback on the Commission Implementing Regulation establishing common templates for the transfer of information from national energy performance databases to the EU Building Stock Observatory. Please find our full answer attached below.
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Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

22 Apr 2025 · Water Resilience Strategy

Meeting with Hildegard Bentele (Member of the European Parliament)

21 Apr 2025 · Water resilience

Meeting with Veronica Manfredi (Director Environment)

15 Apr 2025 · Water efficiency in buildings

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen)

15 Apr 2025 · energy efficiency

Meeting with Niels Ladefoged (null Energy)

28 Mar 2025 · Energy Efficiency in upcoming EU Policy implementation.

Response to European Water Resilience Strategy

4 Mar 2025

EVVE welcomes the opportunity to contribute to this Call for Evidence. Please find attached our position paper, including: 1) EVVEs Feedback to the Call for Evidence on the European Water Resilience Strategy 2) A Study on Smart Water Metering and Water Leakage Detection, performed by ista FR (2023 and 2024) 3) An Analysis of cold and hot water consumption and Costs in the German Multi-Family Housing Stock, performed by the Techem Research Institute on Sustainability (TRIOS, 2025) 4) The Report of the Danish Working Group on Mandatory Individual Use of Water Meters (2010) Please find below some key elements: As Europe increasingly faces water-related challenges such as droughts, floods, and water stress, addressing inefficiencies in water use has become a top priority. The buildings sector represents 28% of the water abstracted in the EU, and 13% of the water consumption (State of Water 2024), highlighting a critical yet untapped potential for water savings. By adopting smart water submetering technologies, the EU can significantly enhance water efficiency, reduce water wastage, empower consumers and bolster resilience against future water crises. Indeed, If all residential flats in the EU were equipped with individual water meters and billed based on actual water consumption, annual water savings could reach 1,356M m3. This is equivalent to an entire year of the gross freshwater abstraction of Czechia, or about 3 days of total water abstraction across the EU. (Eurostat,2024) EVVE's Main Policy Recommendations: 1. Buildings as core part of the Water Resilience Strategy The built environment remains an underutilised sector for achieving water efficiency gains, yet it plays a critical role in addressing water stress in urban areas, where water demand is concentrated. 2. Mandate harmonised water submetering in buildings Introducing a harmonised submetering mandate across the EU would equip consumers with the data they need to monitor and optimise their water use. This approach mirrors the success of similar provisions in the energy sector under the Energy Efficiency Directive and would unlock significant water-saving potential. 3. Establish Sector-Specific Water Efficiency Targets To enhance water resilience, all sectors should be required to meet tailored water efficiency targets. These targets would drive the adoption water-saving technologies at large and, e.g. water submetering, especially in urban areas where water scarcity is most acute. For instance, the UK has taken a proactive step in this direction with the 2021 Environment Act, which sets a target to reduce public water supply consumption by 20% per capita by 2037-38, based on 2019-20 usage levels. This goal will be supported by the progressive roll-out of smart water meters, which are expected to save the equivalent of 1/3 of the UK water supply deficit by 2040. 4. Adopt a Water Efficiency First Principle The EU should enshrine a Water Efficiency First Principle into its water resilience framework. EVVE looks forward to further collaborating with the European Commission and all interested stakeholders on this essential initiative.
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Response to Targeted technical update of EU rules on measuring instruments

3 Mar 2025

EVVE welcomes the proposal to amend the Measuring Instruments Directive to better reflect the technological evolution of measuring instruments essential for achieving the objectives of the European Green Deal. In particular, we support the proposed technical adjustments to Annex IV. The updated definition of thermal energy meters is a significant improvement, as it now aligns with real-world applications by formally recognising both heating and cooling functions of these devices, paving the way for MID-compliant cooling and combination meters without country-specific restrictions. Furthermore, we view positively the proposed amendment of point 1.1 of Annex IV, as the new formulation enhances the flexibility and adaptability of thermal energy meters, expanding their operational temperature range while ensuring greater accuracy in measuring small temperature differences, remaining coherent with the effective integration of cooling applications.
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Response to Report on the application of the General Data Protection Regulation

8 Feb 2024

EVVE welcomes the opportunity to provide its feedback concerning the report on the General Data Protection Regulation. Please find our contribution in the attached document.
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards