European Industrial Insulation Foundation
EiiF
Article 2 Purpose of the Foundation The Foundation engages itself, exclusively and irrevocably, on a non-profit basis for the deployment of sustainable insulation systems in industrial plants and in the industrial environment with the aim of saving energy, reducing CO2 emissions and realizing the best possible noise and fire control systems. The primary task of the Foundation is to publicize the potential of sustainable insulation solutions with policy makers from the economic and political field and, through consultation as well as education and further training, to initiate the implementation of concrete projects. Here, energy-saving potentials as well as health aspects and work safety should be considered.
ID: 658236415011-84
Lobbying Activity
Meeting with Andrea Wechsler (Member of the European Parliament) and Carbon Capture & Storage Association
3 Jul 2025 · EU Energy and industry policy
Meeting with Claudia Canevari (Head of Unit Energy) and European Alliance to Save Energy
9 Apr 2025 · A workshop and roundtable on possible modalities for the proratisation of the energy efficiency in industrial investments, focusing on practical solutions, standardisation and policy frameworks to drive decarbonisation and competitiveness
Response to EU rules on industrial emissions - revision
22 Jun 2022
European Industrial Insulation Foundation (EiiF) strongly supports the initiative to update EU rules on industrial emissions. We encourage this initiative in its aim to ensure industry uses techniques that create a more sustainable EU economy, and a cleaner environment that improves public health.
As stated in the Inception Impact Assessment, industry is likely to need to make significant investments in the future to support the move to climate neutrality. Our expertise lies in the very specific field of industrial insulation, a cross-cutting BAT delivering multiple benefits to industry: process and safety needs, cost reductions, energy savings and connected emissions reductions urgently needed for a transition to a low carbon industry and to make the EU less dependent on energy imports.
The EiiF Study 2021 analyses that 14 Mtoe of energy can be saved by improving insulation standards in industry, offering the potential to reduce EU’s CO₂ emissions by 40 Mt every year. This potential is equivalent to the emissions of more than 20 million cars and the energy consumption more than 10 million households.
TIPCHECK energy audits could quickly identify the savings. The payback times of technical insulation improvements like insulating bare surfaces and repairing damaged insulation systems, are often less than 2 years, as mentioned in the EED Evaluation, PDF page 255 of directive 2012/27/EU on energy efficiency which accompanies the Proposal for a Directive of the European Parliament and of the Council on energy efficiency (recast). With today’s rising energy and CO₂ prices, the payback times can even be less than one year.
We see a great opportunity in the enforcement of EU rules on industrial emissions. We therefore recommend the following measures:
GENERAL:
Mandatory horizontal Energy Efficiency BREF or integration of all cross-cutting energy-efficiency technologies to be used in specific vertical
BREFs
A more efficient BREF process aiming for a duration of no more than one year, with a revision every 4 years
INSULATION SPECIFIC:
Introduction of energy classes for industrial insulation to define the energy efficiency performance of industrial insulation systems
Introduction of mandatory minimum requirements for insulation defined by maximum heat loss rates like the existing building insulation
standards
Increased activity in the field of industrial insulation can contribute in a financially attractive way to support the decarbonisation of industry as well as providing and saving jobs in Europe. The installation of new and better performing insulation solutions as well as the repair work can be done right here in Europe by European insulation workers, and most insulation materials used in industry are produced in Europe.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
18 Nov 2021
EiiF welcomes the EED recast and supports in particular the following amendments:
• The energy efficiency first principle (cf. Page 3)
• A binding and increased energy savings target (cf. Page 34)
• Energy management obligation for energy-intensive companies (with an annual energy consumption higher than 100TJ) (cf. Page 96)
• Energy audit obligation for companies with an annual energy consumption higher than 10TJ (cf. Page 50 and Page 96)
• The requirement to implement the energy audit recommendations (cf. Page 96 and ETS amendment, Page 19)
EiiF’s vast TIPCHECK experience (about 2.500 audits in industrial plants and on technical building equipment (HVAC)) proves that the energy efficiency first principle today remains an overlooked opportunity in industry. It must be strengthened and strongly promoted and making the energy savings target binding is a good step towards the right direction but in our opinion not sufficient. We recommend to increase the ambition from 36% to at least 40% (PRIMES 2007), (Article 1 and 4) as a recent study ( Fraunhofer ISI & Stefan Scheuer (2021)) confirms that the EU cost-effective energy savings potential for 2030 stands at around 41% for final energy (PRIMES 2007).
Our TIPCHECK experience confirms that the technical potential for energy efficiency is there. If all processes, equipment, and related infrastructure are upgraded with technically feasible energy efficient solutions like in our case better insulation systems, the potential will most likely exceed the 40% by 2030. In addition the binding EU target must be complemented by binding national contributions (Article 1 and 4). National action plans must be set according to a linear pathway and include binding milestones to enable the Commission to activate the gap-filler mechanism if needed (Article 4.3).
Our TIPCHECK experience confirms that companies with energy management like ISO 50001 continuously improve their energy efficiency and are more open for energy audit services like TIPCHECK. They have and use energy management budgets to invest in production efficiency. The energy management obligation for energy-intensive companies (> 100TJ) (cf. Page 96) will deliver significant energy savings and emissions reductions.
For smaller energy consumers (10TJ - 100 TJ) the energy audit obligation (cf. EED recast, Page 50 and Page 96) is a tailored approach to motivate them to improve their energy performance.
To assure that energy saving potentials will be tapped we think the requirement to implement the audit recommendations (cf. EED recast, Page 96 and ETS amendment, Page 19) should be extended. We propose to make it obligatory to implement all measures offering payback periods of less than 3 years until the next energy audit (“every four years...“ EED recast, Page 95).
The European Commission staff working document evaluation of directive 2012/27/EU highlights the short payback times offered by TIPCHECK projects (cf. EED Evaluation, Page 255) https://www.eiif.org/tipcheck/
EiiF experience until today shows that the potential of industrial insulation remains largely untapped, despite its being financially attractive to implement, its offering multiple benefits to industry and the environment and its being urgently needed to help the EU become carbon neutral in 2050 and in short term reduce emissions by 55%. In our EiiF Study 2021 we calculated an annual energy savings potential of industrial insulation of 14 Mtoe and an emissions reduction potential of 40 Mt CO2eq. if all equipment in industry was insulated with an Energy Class C (VDI 4610) quality. More information can be found in the attached White Paper (10 min. read) or online on our website: www.eiif.org/publications.
We are convinced that the proposed amendments of the EED (recast) and our additional recommendations will accelerate the uptake of the energy efficiency potential in industry and immediately contribute to reach the 55% emissions reduction target by 2030.
Read full responseMeeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and
27 Oct 2020 · Business and investor support for higher ambition and the just transition
Response to Review of Directive 2012/27/EU on energy efficiency
18 Sept 2020
EiiF strongly supports the initiative to revise the EED with the aim to achieve a higher level of greenhouse gas reduction by 2030 and to assure its most effective contribution to other European Green Deal initiatives.
Our expertise lies in the very specific field of industrial insulation, a cross-cutting BAT delivering multiple benefits to technical building equipment and industry and in particular to thermal energy auditing. In 2010 EiiF established its TIPCHECK (Technical Insulation Performance Check) programme, training engineers in certified thermal energy auditing according to EN 16247.
EiiF Comments on Article 8, EED
• We are convinced that energy audits and especially energy management schemes that include high quality energy audits under Article 8 are useful and very effective tools to identify energy savings and CO2 reduction potential in European industry.
• This is backed up by our TIPCHECK experience: Our certified engineers have carried out more than 2.500 thermal energy audits in buildings (mainly HVAC) and larger industry. 95% of TIPCHECK inspections find economically attractive insulation energy and CO2 saving potential. Inspections have included HVAC systems of hotels, hospitals or office buildings as well as technical equipment in industry from energy intensive companies (e.g. refineries and power plants) to small and medium sized plants (e.g. specialised chemical plants or breweries).
• The TIPCHECK triggered insulation investments prove the effectiveness of thermal energy audits: 75% of TIPCHECK audits lead to investments to stop the identified energy losses.
• We therefore think that Article 8 is a very important article and a decisive part of the EED, with clear links to Article 7 and Annex V, as well as to Article 20, respectively, where energy audits and improved incentive structures are key elements.
However, to ensure Article 8 delivers its full potential, practical experience shows that Article 8 should be improved by:
1. Combining the energy audit obligation with a mandatory requirement and incentives to implement recommended improvements which are possible through existing technologies that offer short payback periods of less than 3 years. Incentives could be linked to an ambitious timeframe of 1-2 years in which the identified energy saving potential shall be realised in connection with planned maintenance.
Why? An energy audit without consequences does not always lead to energy savings (see TIPCHECK experience: 25% of the clients do not take action after the audit). But a mandatory requirement to take action within an ambitious timeframe with the support of incentives will make energy performance improvements a high priority leading to improved energy productivity and increased competitiveness of Europe’s industry. In addition, the number of energy audits carried out today is too low and far away from identifying the huge potential.
2. Furthermore we recommend that EU and Member States continue to develop national programmes, including funds, soft loans, fiscal and other State Aid rule compliant incentives, to assist SMEs with an intensive energy use above a defined level to regularly (Article 8 = every 4 years) undergo energy audits and to consequently implement the recommendations at their next available opportunity.
Summary
Without mandatory requirements for companies above a defined energy consumption (no matter the size – it is the energy consumption that counts) combined with the obligation to take action to tap the audited energy efficiency potential, the 55% CO2 reduction target in 2030 and the target to reach net zero in 2050 will not be met.
The possible insulation contribution:
Just improving industrial insulation systems to the VDI 4610 Energy Class C will already and cost-effectively deliver annual CO2 reductions of 45 Mt, equivalent to 3% of reductions needed to reach 55% in 2030 (EiiF 2020).
Read full responseResponse to EU rules on industrial emissions - revision
20 Apr 2020
The EiiF strongly supports the initiative to update EU rules on industrial emissions. We encourage this initiative in its aim to ensure industry uses techniques that create a more sustainable EU economy, and a cleaner environment that improves public health.
Our expertise lies in the very specific field of industrial insulation, a cross-cutting BAT delivering multiple benefits to industry: process and safety needs, cost reductions, energy savings and connected emission reductions urgently needed for a transition to a low carbon industry.
However, contrary to the building sector, the energy efficiency and emission reduction potential of insulation in industry is not used today.
The consequences are largely untapped energy and emission reduction potentials. According to an Ecofys study, specifically on the industrial insulation potential (Climate protection with rapid payback, 2012), and latest figures investigated by EiiF (based on the 2017 emission data provided by the EEA), the annual reduction potential of industrial insulation sums up to 50 Mt CO2 and an energy saving potential of 600 PJ.
These potentials are equivalent to the emissions of at least 15 million cars and the energy consumption of about 10 million households.
In fact, industrial insulation could annually reduce about 1% of Europe’s CO2 emissions (or about 5% of EU industry emissions), thus offering a cleaner environment to European citizens. Furthermore, investments in industrial insulation give rapid payback (see EE-BREF page 153).
Against this background we see a great opportunity in the enforcement of EU rules on industrial emissions. We therefore recommend the following suggestions for the IED’s revision:
1. The horizontal Energy Efficiency BREF must become mandatory (including SMEs). If not, industry will continue to consider it irrelevant and the EU goals will not be met.
2. The Energy Efficiency BREF must be updated and improved:
a. Insulation specific:
Mandatory minimum requirements for insulation defined by maximum heat loss rates similar to the existing building insulation standards must be introduced: With the lately released VDI 4610 energy classes for industrial insulation an effective tool is now available (see attachment).
Today the EE-BREF is too vague and in particular misses out the huge energy efficiency potential of insulating equipment at temperature levels below 200 °C:
i. “As a baseline, all piping operating at temperatures above 200 °C and diameters of more than 200 mm should be insulated and good condition of this insulation should be checked on a periodic basis […].” (Page 153, Chapter 3, Steam pipes)
ii. “ensuring insulation is optimized” (Page vi/Executive Summary) – No guidance at all.
iii. “An optimum insulation thickness which relates energy consumption with economics should be found in every particular case” (Page 132, Chapter 3, Combustion) – No guidance at all.
b. General:
The structure and formatting must be corrected to transfer the BREF into a motivating, user-friendly document. (See attachment)
3. The duration of the general process for developing and reviewing BREFs is too long and too complex.
For the EE-BREF the process took almost 6 years and the revision every 8 years has not happened.
The current BREF process makes it furthermore impossible to introduce innovations and younger best practices in due time. A more efficient process would enable the IED to ensure that industry uses more and new innovative techniques creating a more sustainable EU economy.
We propose to change the BREF process to enable a duration of not more than one year, and a revision every 4 years.
We strongly encourage DG Environment on the revision of the Industrial Emissions Directive and offer any support we can give to ensure industry uses the insulation BAT in its best way to create a more sustainable EU economy, and a cleaner environment that improves public health.
Read full responseResponse to Climate Law
6 Feb 2020
EiiF (European Industrial Insulation Foundation) strongly supports the initiative.
EiiF sees great opportunities in the “Energy Efficiency First” principle. It offers a powerful contribution to make the energy transition fair, fast and attractive. The cleanest energy is the one not used. Besides, energy efficiency offers well known multiple benefits of which competitiveness is just one.
We recommend that the new climate law shows how to deliver on the target and promotes the Energy Efficiency First principle. Our Energy auditing experience (TIPCHECK) shows that large cost-effective energy savings potentials are not tapped today. Studies like the Fraunhofer ISI (Jan 2019) predict that tapping cost-effective potentials would lead to halving energy demand by 2050 compared to business as usual, and deliver 40% energy savings by 2030, well above the 32.5% EU target. Against this background we recommend making a 40% energy efficiency target binding for 2030.
In addition, we ask for a consistency in the law asking the same contribution from all sectors and stakeholders. For the building sector minimum efficiency limits exist: The EPBD foresees that Member States “shall take the necessary measures to ensure that minimum energy performance requirements for buildings or building units are set with a view to achieving cost-optimal levels”. This leads to an average maximum heat loss of 4 W/m2 (for walls). In industry nothing comparable and concrete exists today.
A standard (AGI Q 101) for power plants asks for an insulation performance of only 150 W/m2 but companies are free to decide whether they use it or not. About 10% of equipment in industry is not insulated at all and the existing insulation levels correspond to the energy efficiency class F or below according to the German Insulation Standard VDI 4610. In fact, industry wastes about 620 PJ energy and therefore emits needlessly almost 50 Mt of CO2 every year - equivalent to the annual energy consumption of 10 million households or the emissions of 18 million cars (Climate Protection with Rapid Payback, Ecofys 2012).
This insulation experience supports IEA’s 2019 Energy Efficiency Report and what Dr Fatih Birol (IEA Executive Director) claims: “The historic slowdown in energy efficiency in 2018 – the lowest rate of improvement since the start of the decade – calls for bold action by policy makers and investors. We can improve energy efficiency by 3% per year simply through the use of existing technologies and cost-effective investments. There is no excuse for inaction: ambitious policies need to be put in place to spur investment and put the necessary technologies to work on a global scale.”
This statement is further backed up by our experience: Insulation improvements in industry usually come with payback times of only two years, 95% of the plants bear cost-effective potentials and finally 3 out of 4 TIPCHECK clients react and invest (TIPCHECK Report, EiiF 2016). EiiF estimates that by improving industrial insulation performance to cost-effective levels, EU emissions could be cut by at least 1% and 49 Mt CO2 (EEA: 2016, total GHG = 4.293 Mt). But tapping the existing potentials in industry will take too long if not an ambitious climate law will effectively accelerate this process. With the VDI 4610 standard the insulation industry has developed a tool which corresponds to the EPBD and the Ecodesign methodology. We strongly recommend integrating this regulatory tool in the climate law at least like the EPBD regulation.
We are convinced that many other BATs are also ready to deliver. We therefore recommend an enforced EED Article 8 making any measure with a payback time of five years and less obligatory. In addition, SMEs should as well fall under the Article 8 but connected to motivating support. And finally, CO2 emissions and energy efficiency must become part of the IED/all BREFs, as this will also help to tap the efficiency and emission reduction potential in industry.
Read full responseMeeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)
2 Dec 2014 · Energy savings