Lobbying Activity
Response to Electrification Action Plan
9 Oct 2025
Marcogaz, the technical association of the European gas industry supports the EUs climate objectives and the decarbonisation of the heating sector. The current strategy focuses on electric heat pumps and district heating networks only. While these solutions are valid, the energy savings benefits, particularly attributed to electric heat pumps, are often overestimated and should be assessed carefully, considering local conditions and climate variability. Realistic and comprehensive cost-benefit analyses are essential, including direct costs to end users but also indirect system costs, such as investments in electricity grids updates, generation and storage capacity, and the construction and operation of district heating networks. This is crucial to avoid energy poverty resulting from overly costly or unsuitable choices. In many cases, the installation of electric heat pumps is not feasible due to space constraints, need for extensive renovations of the heat distribution systems, and the high insulation standards required. Decarbonising the gas supply while maintaining existing infrastructure and appliances is often more cost-effective, system-efficient and quicker to implement. A diversified and synergistic combination of technologies is more resilient and economically viable. Restricting this diversity risks excluding vulnerable households and slowing down the energy transition, due to affordability and energy transport system bottlenecks. Leveraging multiple energy networks and repurposing existing infrastructure can mitigate these challenges. Renewable gases -biomethane, hydrogen and blends with natural gas- offer immediate and scalable decarbonisation opportunities with minimal conversion requirements. Biomethane production in Europe reached 22 bcm in 2023, with projections of up to 40 bcm by 2030. Imports of green gases from outside the EU, using existing or new infrastructure, can further support supply. These gases can be injected into existing networks, enabling continued use of efficient gas appliances while reducing emissions. Mechanisms such as green gas contracts and blending obligations already support decarbonisation of heating in several Member States and are explicitly recognised in the EPBD Recast. Appropriate certification schemes for gases used in boilers should be enabled for this purpose. To fully unlock this potential, clear and binding targets for biomethane use in the heating sector should be established. A technology-neutral approach is essential to ensure all viable solutions are considered based on their actual carbon footprint and system impact. As public and private owners bear the cost of conversions, they must retain the freedom to choose the solution that best fits their needs. High-efficiency boilers already contribute to decarbonisation by replacing old inefficient appliances. They are affordable, widely available, compatible with existing infrastructure and now in large scale deployment. Hybrid heat pumps combining boiler and electric heat pump, offer flexibility and system efficiency, reduce peak electricity demand during cold spells, lowering the needs for electric grid reinforcement, they optimise transition costs for both consumers and the energy system. Gas heat pumps are growing popular particularly for high energy demand buildings combining heating and cooling needs, micro-cogeneration and fuel cells providing heat and local electricity production. Beyond buildings, renewable gases and hybrid systems offer decarbonisation potential, particularly for industrial heating processes that require high-temperature heat. Gas infrastructure plays a critical role in ensuring energy security, particularly during supply shortages, as a silent guard who constantly makes our energy supply stable and safe. The widespread transmission and distribution gas networks, operating alongside electricity networks, enable a faster and more costeffective decarbonisation of the heating and cooling sector.
Read full responseResponse to Heating and cooling strategy
8 Oct 2025
Marcogaz, the technical association of the European gas industry supports the EUs climate objectives and the decarbonisation of the heating sector. The current strategy focuses on electric heat pumps and district heating networks only. While these solutions are valid, the energy savings benefits, particularly attributed to electric heat pumps, are often overestimated and should be assessed carefully, considering local conditions and climate variability. Realistic and comprehensive cost-benefit analyses are essential, including direct costs to end users but also indirect system costs, such as investments in electricity grids updates, generation and storage capacity, and the construction and operation of district heating networks. This is crucial to avoid energy poverty resulting from overly costly or unsuitable choices. In many cases, the installation of electric heat pumps is not feasible due to space constraints, need for extensive renovations of the heat distribution systems, and the high insulation standards required. Decarbonising the gas supply while maintaining existing infrastructure and appliances is often more cost-effective, system-efficient and quicker to implement. A diversified and synergistic combination of technologies is more resilient and economically viable. Restricting this diversity risks excluding vulnerable households and slowing down the energy transition, due to affordability and energy transport system bottlenecks. Leveraging multiple energy networks and repurposing existing infrastructure can mitigate these challenges. Renewable gases -biomethane, hydrogen and blends with natural gas- offer immediate and scalable decarbonisation opportunities with minimal conversion requirements. Biomethane production in Europe reached 22 bcm in 2023, with projections of up to 40 bcm by 2030. Imports of green gases from outside the EU, using existing or new infrastructure, can further support supply. These gases can be injected into existing networks, enabling continued use of efficient gas appliances while reducing emissions. Mechanisms such as green gas contracts and blending obligations already support decarbonisation of heating in several Member States and are explicitly recognised in the EPBD Recast. Appropriate certification schemes for gases used in boilers should be enabled for this purpose. To fully unlock this potential, clear and binding targets for biomethane use in the heating sector should be established. A technology-neutral approach is essential to ensure all viable solutions are considered based on their actual carbon footprint and system impact. As public and private owners bear the cost of conversions, they must retain the freedom to choose the solution that best fits their needs. High-efficiency boilers already contribute to decarbonisation by replacing old inefficient appliances. They are affordable, widely available, compatible with existing infrastructure and now in large scale deployment. Hybrid heat pumps combining boiler and electric heat pump, offer flexibility and system efficiency, reduce peak electricity demand during cold spells, lowering the needs for electric grid reinforcement, they optimise transition costs for both consumers and the energy system. Gas heat pumps are growing popular particularly for high energy demand buildings combining heating and cooling needs, micro-cogeneration and fuel cells providing heat and local electricity production. Beyond buildings, renewable gases and hybrid systems offer decarbonisation potential, particularly for industrial heating processes that require high-temperature heat. Gas infrastructure plays a critical role in ensuring energy security, particularly during supply shortages, as a silent guard who constantly makes our energy supply stable and safe. The widespread transmission and distribution gas networks, operating alongside electricity networks, enable a faster and more costeffective decarbonisation of the heating and cooling sector.
Read full responseResponse to Revision of the Energy Performance of Buildings Directive 2010/31/EU
31 Mar 2022
MARCOGAZ, the Technical Association of the European Gas Industry, acknowledges the importance of having an adequate and updated legislation that promotes energy efficiency in buildings as it contributes to reach the European climate goals. Therefore, MARCOGAZ fully supports the revision of the Energy Performance of Buildings Directive and welcomes the opportunity given by the European Commission to provide its view on it through the attached position paper.
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