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European Building Automation and Controls Association

eu.bac

eu.bac is the European Building Automation and Controls Association.

Lobbying Activity

Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

25 Sept 2025 · Twin Transition – role played by digital techs and AI to ensure resource efficiency

Response to Revision of the Cost-Optimal Methodology framework for calculating minimum energy performance requirements for buildings

7 May 2025

Please find attached the contribution from the European Building Automation and Controls Association (eu.bac).
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Response to Reporting scheme for data centres in Europe

15 Jan 2024

Dear Sir or Madam, You will find our feedback attached as a pdf document. Thank you in advance for taking the time to review it. Kind regards, The eu.bac team.
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Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur) and Siemens Energy AG and The Regulatory Assistance Project

21 Jun 2023 · Energy Performance of Buildings Directive: opportunity for countries to unleash the potential for smart and cost-effective solutions (Staff level)

Meeting with Alessandra Basso (Member of the European Parliament, Shadow rapporteur)

7 Mar 2023 · Construction Products Regulation

Meeting with Iskra Mihaylova (Member of the European Parliament)

5 Oct 2022 · EPBD

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)

20 Sept 2022 · EPBD

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Google and

30 Jun 2022 · US-EU Task Force Convening: Energy efficiency and Energy Savings. The American Council for an Energy-Efficient Economy (ACEEE), the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) and Tado also participated.

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur) and Schneider Electric and Finance Denmark

22 Jun 2022 · Energy Performance of Buildings Directive

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Google and

25 Apr 2022 · US-EU Task Force Convening: Clean Energy Technologies. Carrier, Tado and the European Council for an Energy Efficient Economy (ECEEE) also participated.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

eu.bac welcomes the Commission’s proposal for the recast of the Energy Performance of Buildings Directive with a view to achieving a zero-emission building stock by 2050. We however believe the use of existing, smart and cost-effective technologies could be incentivised further in order to foster the twin green and digital transitions. The attached document outlines suggestions to achieve this. We are committed to continuing to support the institutions by providing our expertise in the next steps to improve and successfully adopt the review.
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Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur) and European Alliance to Save Energy and

31 Mar 2022 · The Energy Performance of Buildings Directive - Stakeholder Event

Response to Review of ecodesign requirements for standby and off mode electric power consumption

4 Feb 2022

1) DEFINITIONS NEED MORE CLARITY Certain definitions are not clear at the moment and need further explanations in order to avoid misunderstandings about which products will fall in scope of the regulation. We appreciate the availability and openness of DG ENER on this topic, we are responsibly providing our resources and expertise for reaching this goal and we hope these clarifications will be included in the draft regulation as soon as possible. If these clarifications were to be postponed, there would be serious consequences on the ability of the industry to cope with the current deadlines. One clear example is a system made up of multiple “motor-operated building elements”, where every "motor-operated building element" contributes to the consistent operation of the system so that the system itself can provide a standby mode. At the moment there’s no clarity on what would be the maximum system’s consumption allowed in standby mode. 2) IMPACT ON THE INDUSTRY AND ENTRY INTO FORCE OF THE REGULATION At the moment the industry is facing several challenges related to the COVID19 crisis. In addition to all the consequences that are affecting all the industries horizontally, our industry has to face the consequences of deep shortages of electronical components and different kind of materials. Following the COVID outbreak all the efforts of the industry are focused on how to modify the products in light of these shortages. With this situation, most of all the other developments that were already planned before COVID had to be postponed, there was simply no alternative. These measures were discussed for the last time in 2017. Since then, the world has changed. While the process followed by the Commission is formally complying with the “Better regulation” principles, insufficient time has been allocated to exchange views with stakeholders on such important measures that would have a considerable impact on the industry. We surely understand that the impact of the COVID crisis has been burdening other industries as well and we fully support the goals the Commission is trying to achieve with the Ecodesign measures but the industry needs a reasonable amount of time to comply with these rules in a sustainable manner. With the current measures entering into force only two years after the publication in the official journal, we fear that the impact of the industry would be strongly detrimental and that these implementing measures could have a “significant impact on the industry’s competitiveness” (Art. 15, par. 5 d, Directive 2009/125/EC) While all the measures could enter into force after 2 years, the new measures on “motor-operated building elements” could enter into force after a longer transitional period. The need to differentiate between the entry into force of different requirements was already recognized by the Commission in the last draft from 2017 (Art. 9, par.3, “Points 5 and 6 of Annex I shall apply as from 30 months after the date referred to in the first paragraph”). While 30 months were considered to be a good compromise before the COVID outbreak and the shortage of the components, we would now suggest that these measures could enter into force at least 40 months after its publication. 3) INFORMATION STATUS DISPLAY CONSUMPTION In the previous 2017 draft, the standby consumption in case of information status display was 1W, in the new proposal it has been reduce to 0.8W. Even with the uncertainty generated by postponements and lack of clarity about the timing (since 2017 to 2022), the figure the industry was referring to when discussing development projects was 1W and not 0.8W. Even if the industry was able to re-start the product development based on a draft, the requirement is now changed and this means that the product development would need to start from scratch. For these reasons and the ones mentioned in the above-mentioned point 2) we therefore call for this requirement to be changed in line with the previous draft.
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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

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

eu.bac welcomes the 2021 revision of the Energy Performance of Buildings Directive, which has become necessary in light of the increased ambition agreed in the Renovation Wave. To meet EU climate targets and fully decarbonise the building stock by 2050, stronger measures must be put in place at the European level. The initial eu.bac suggestions are structured in 6 chapters, each containing specific policy recommendations on: 1. Implementation of the revised EPBD first 2. Digitalization as the driving force of the renovation wave 3. Decarbonisation and energy efficiency: defining the indicators for successful building policies 4. Filling the gaps on the basics: dynamic hydronic balancing, self-regulating devices and solar shading 5. Harmonization and synergies between different legislation at the EU and national level 6. Indoor environmental quality The eu.bac suggestions are available attached and at the following link: https://www.eubac.org/cms/upload/20210322_EPBD_2021_initial_eubac_suggestions.pdf
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

eu.bac, European Building Automation and Controls Association, welcomes the creation of a classification system for green investments to meet it’s 2030 energy and climate targets. It will provide the necessary dictionary for stakeholders to evaluate green technology in a uniform manner. We embrace the inclusion of production of building automation and control systems, installation, maintenance and repair of building automation and control systems and building energy management systems (BMS) and the acquisition and ownership of buildings which are efficiently operated through energy performance monitoring and assessment as contributing substantially to climate change mitigation in Annex I. Furthermore we are pleased to find the production of building automation and control systems, installation, maintenance and repair of building automation and control systems and building energy management systems (BMS) recognised in Annex II as contributing substantially to climate change adaptation. However, we encourage the inclusion in Section 7.7 of Annex II the acquisition and ownership of buildings which are efficiently operated through energy performance monitoring and assessment as contributing substantially to climate change adaptation. Alongside the energy efficiency benefits provided by demand-optimized energy usage and permanent energy monitoring, building automation and control systems optimize air quality, thermal comfort and human-centric lighting while helping to reduce the spread of infections. These facets will become increasingly more relevant in adapting to climate change. The building automation and control industry confirms its commitment to work together with policymakers to unleash the full potential of cost-effective technologies which would help businesses and citizens make major energy savings, improve health and comfort while, at the same time, tackling energy poverty and driving digitalization, jobs and growth.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

eu.bac fully supports a revision of the EED, in combination with additional non-regulatory policy measures. New economic and financial measures should be put in place, supporting the transition to energy efficient, smart buildings. The sector was particularly affected by the crisis that followed the Covid-19 outbreak:the new EU co-funded energy efficiency investments will be key to strengthen the European economy’s resilience and sustainability. The allocation of dedicated EU funds should therefore be conditioned to:1)the deployment of building automation and control solutions and 2)energy audits, able to properly assess and prove the real cost-effectiveness of the measures applied. Also, the funds must be strongly linked to the compliance with the implementation of the mandatory requirements set in the EU Directives. One of the major changes set at EU level in the revised EPBD in order to make the building stock energy-efficient, future-proof and decarbonized was the introduction of mandatory requirements to optimize technical building systems (TBS), install individual room temperature controls and equip large non-residential buildings with building automation and control functionalities. Six months after the deadline for the transposition, there’s still a widespread lack of ambition of the Member States in transposing these measures. Funds linked to the implementation of these measures would contribute to achieving savings corresponding to 14% of total building primary energy consumption (64 Mt CO2 annual savings and €36 billion energy bill savings triggered – WSE study, 2018). On the Renovation Wave: in addition to the inputs already provided (eu.bac 3-pager attached), public buildings should be at the forefront when it comes to energy efficiency, indoor environment quality, smartness and sustainability. Today, this is not the case. There should be higher ambition on public buildings, covering all the existing ones (exceptions only for the new buildings able to demonstrate state-of-the-art equipment) at all levels (central, regional, local). The legislator should also not miss the opportunity to require the installation of BACS in all public buildings across the EU. Their deployment, continuously ensuring optimal performance of all TBS installed, can deliver savings (52% in offices, according to EN15232) and optimal indoor environmental quality even in historic buildings (as often the case for public buildings in EU), fully preserving their heritage value, unlike other solutions. Even basic measures, such as installing individual room temperature controls or hydronic balancing quickly lead to significant energy savings with a short payback time, and should be rolled-out at large scale in public buildings. Programs for staged deep renovation should be prioritized and the potential of EPCs and ESCOs should be unleashed, with further improvements to the existing EED Article 18. On public procurement rules, the EED shall be more prescriptive on the criteria that should be used such as: • Make BIM standards mandatory when setting minimum requirements for tenders (as in Denmark, where BIM is mandatory at all levels) • Best certification practices from the private sector and building environmental certification (LEED, HQE, BREAM) shall be encouraged • Strong incentives in pushing Energy Performance Contracting practices across Europe • Strong incentives for commissioning and maintenance of TBS On trainings, we fully support the establishment of provisions to incentivize up- and re-skilling, technical education programs and apprenticeships. Skilled professionals are essential in order to effectively deploy (and assess) the technologies needed to achieve a fully decarbonized building stock (such as BACS). Measures on “information dissemination and awareness-raising campaigns” would be beneficial: one of the most relevant barriers is related to the little knowledge of owners and occupants of the multiple benefits of EE solutions.
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Meeting with Dominique Ristori (Director-General Energy)

14 Dec 2017 · Energy efficiency policy development

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

6 Dec 2016 · enrgy efficiency, construction initiative

Meeting with Gints Freimanis (Cabinet of Vice-President Valdis Dombrovskis)

17 Oct 2016 · Discussion on energy efficiency measures in the context of new Energy policy package

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

6 Oct 2016 · Energy Efficiency Package

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

21 Sept 2016 · Energy efficiency in buildings

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

12 May 2015 · Energy Efficiency in buildings

Meeting with Dominique Ristori (Director-General Energy)

27 Mar 2015 · Energy Efficiency