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Swedish Property Federation

SPF

The Swedish Property Federation is the voice of property in Sweden.

Lobbying Activity

Meeting with Jessika Roswall (Commissioner) and

20 Nov 2025 · Sustainability and circular economy

Response to Circular Economy Act

30 Oct 2025

Fastighetsägarna welcomes the European Commissions ambition to establish a Circular Economy Act as part of the Clean Industrial Deal. The property and construction sector supports this transition but stresses that circularity must be built on value creation, prevention and market functionality, not on new administrative layers or overlapping quota systems. The real estate and construction sector accounts for more than one third of Swedens total waste generation. A well-designed Circular Economy Act can therefore deliver substantial system benefits provided that it focuses on efficient use of existing buildings, smarter material cycles and proportionate regulation. 1. Prevention and preservation as top priorities The Act must recognise that the most resource-efficient measure is to use and maintain existing buildings. EU-driven renovation obligations under the EED and EPBD risk conflicting with resource-efficiency goals. Studies from Sweden show that forced renovations often generate more emissions and waste than the energy savings achieved. Member States must be given a clear mandate to balance different climate benefits under Fit for 55 and to prioritise preservation when it yields greater environmental value. 2. Market-driven reuse and harmonised rules Reuse of construction components is hindered by inconsistent end-of-waste definitions and complex taxation. The Act should ensure free movement of reused materials and harmonised criteria for testing, certification and digital product passports. The announced green VAT initiative should simplify VAT treatment of reused building products and recognise retained material value as an asset. 3. Avoid regulatory overlap Binding recycled-content quotas or additional reporting obligations would duplicate existing legislation (EPBD, CPR, CSRD) and risk distorting investment decisions. Circularity should be promoted through data transparency, procurement incentives and functioning markets, not through parallel compliance systems. 4. Waste hierarchy and energy recovery Incineration of waste should gradually decrease but remains necessary for non-recyclable fractions, particularly within district-heating systems. The Act should ensure coherence between incineration taxes and the EU ETS and allow stricter EU control of fossil-based plastics in waste streams. Emissions from plastic combustion should be allocated to plastic producers, not to district-heating customers or municipalities. Likewise, the EUs plastic-levy costs, currently borne by Swedish taxpayers, must be passed on to producers in accordance with the principle of producer responsibility. 5. Extended Producer Responsibility (EPR) for construction products EPR can play a constructive role for selected product groups with high turnover and feasible take-back systems. Any EU framework must remain proportionate, harmonised and avoid transferring producer costs to property owners. Further pilot schemes and EU coordination are needed before new binding obligations are introduced. Fastighetsägarna supports a European circular-economy framework that is coherent, predictable and economically viable. The Circular Economy Act should build on existing instruments such as the Sustainable Product Regulation, the Construction Products Regulation and the Strategy for a Sustainable Built Environment, ensuring consistency rather than new layers of regulation. Circularity succeeds when it strengthens competitiveness and makes better use of what already exists using buildings longer, using materials smarter, and directing responsibility to the right actors in the value chain.
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Response to Heating and cooling strategy

3 Oct 2025

Fastighetsägarna welcomes the Commissions initiative to develop a Heating and Cooling Strategy. We would like to highlight the following points: 1. Stronger consumer protection in district heating monopolies ensures affordability and competitiveness. District heating is a natural monopoly in most Member States. Consumers cannot change supplier, which requires stronger protection than currently in place. Without safeguards, tariff structures risk shifting costs unfairly onto customers. The Strategy should strengthen consumer rights, ensure tariff transparency and fairness, and establish clear rules for cost distribution. This is vital to guarantee that decarbonisation of district heating happens in a way that is affordable and socially acceptable. 2. Phasing out fossil plastics in waste incineration is essential for true decarbonisation. District heating in several Member States still relies on municipal waste incineration, where fossil plastics make up a significant share of the energy content. This locks in fossil emissions and undermines EU climate goals. Producers often argue that they cannot control the waste composition, but such reasoning cannot justify fossil-based production. District heating producers must remain accountable for their production processes regardless of input fuel. The Strategy should therefore establish a clear EU roadmap for phasing out fossil plastics in waste-to-energy, combined with producer responsibility, stronger recycling requirements and binding emission criteria. 3. Enforceable rights to integrate residual heat increase system efficiency and resilience. Residual heat from industry, commerce and data centres remains largely untapped. Property owners and industries should have a guaranteed right to feed surplus heat into district heating networks. At the same time, a localisation principle should apply, requiring facilities with major surplus heat flows to develop a plan for recovery. Removing administrative barriers is key here and the upcoming Omnibus Energy initiative should be used to simplify rules and facilitate surplus heat integration. This would prevent waste of valuable energy resources and directly support EU objectives of reducing fossil fuel imports and improving energy security. 4. Energy efficiency first delivers affordability and competitiveness if building owners have the right incentives. Reducing demand is the most cost-effective way to decarbonise. Yet property owners often face disincentives: rental rules that make it difficult to recover investments, building codes that undervalue reduced consumption, and tariff models where lower usage increases fixed costs. These barriers discourage investments in efficiency. The Strategy should therefore strengthen the economic incentives of building owners, ensuring that efficiency gains are rewarded rather than penalised. Here too, the Omnibus Energy initiative can help to streamline overlapping rules and reduce regulatory burden, making energy efficiency measures easier to implement. 5. Addressing cooling demand now prevents future system stress while recognising efficiency trade-offs. Cooling demand is growing rapidly due to climate change, urbanisation and data centres. If unmanaged, this risks creating new electricity peaks, higher system costs and reduced affordability. At the same time, there is a clear tension between expanding cooling supply and the EUs overarching goal of energy efficiency. Unless properly addressed, increased cooling could offset efficiency gains in buildings. The Strategy should therefore give cooling equal priority to heating, focusing on highly efficient equipment, passive cooling measures and the use of suplus cold from industrial processes, while explicitly acknowledging this trade-off and ensuring that efficiency targets are not undermined. 6. A future-oriented strategy must reflect the transition away from combustion towards surplus heat and heat pumps.
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Response to Electrification Action Plan

3 Oct 2025

Fastighetsägarna welcomes the Commissions initiative to develop an Electrification Action Plan. As property owners, we represent a key sector that both consumes and enables electrification through buildings. We fully share the objective of increasing cost-effective, system-friendly and competitive electrification. Against this background, we would like to highlight the following points: 1. Proportional EPBD requirements are essential to protect grid stability and affordability. The Action Plan aims to achieve system-friendly electrification. However, current EPBD rules risk undermining this objective. Article 14.1 EPBD obliges new and renovated office buildings with more than five parking spaces to equip at least 50% of them with charging points. In practice, this can mean hundreds of chargers per project, regardless of actual demand. Such obligations place an unrealistic and sudden burden on local electricity grids, where capacity can be exceeded many times over at peak hours. Instead of fostering efficient electrification, the rule risks driving costly grid reinforcements, higher tariffs and reduced security of supply. By adapting EPBD obligations to realistic demand, the Electrification Action Plan can avoid unnecessary grid strain, reduce costs for consumers, and ensure that electrification contributes positively to affordability and competitiveness. 2. Neutral and science-based weighting factors strengthen system efficiency. The Action Plans objective of cost-effective electrification requires that all fossil-free energy carriers can compete on equal terms. Today, Member States can set politically determined primary or weighting factors, which risk distorting the balance between electricity and district heating. Ensuring neutrality and transparency in weighting factors supports investment decisions, drives system efficiency and safeguards the competitiveness of electrification. 3. Enforceable rights to energy sharing empower consumers and increase flexibility. The goals of resilience, affordability and lower fossil imports cannot be achieved without active consumers. Yet several Member States treat the right to form energy communities and share electricity as optional. This holds back the development of local flexibility resources. Making these rights enforceable across the EU activates property owners and citizens as system participants, reducing peak demand and strengthening security of supply. 4. Smart grids are a prerequisite for system-friendly electrification. The EU promotes smart and flexible buildings, but most grids remain insufficiently digitalised to send price signals or reward demand-response. This mismatch creates inefficiencies and limits the system value of building investments. By prioritising grid digitalisation and flexibility markets in parallel with smart building policies, the Action Plan ensures that demand response becomes effective, lowering system costs and benefiting consumers. 5. The Omnibus Energy initiative is an opportunity to simplify and improve coherence. Cost-effective electrification also depends on reducing administrative burdens and avoiding overlapping or inconsistent obligations. The anticipated Omnibus Energy package provides an opportunity to simplify complex provisions in the EPBD and related energy legislation. By using omnibus measures to streamline requirements, remove redundancies and align building and energy market rules, the Electrification Action Plan can accelerate implementation, reduce compliance costs and foster investor confidence.
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Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

25 Jul 2025

Input from the Swedish Property Federation is contained in the attached file.
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Response to European Affordable Housing Plan

4 Jun 2025

See attached document.
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Response to Common templates for the transfer of the information in national databases to the EU Building Stock Observatory

2 May 2025

The Swedish Property Federation supports the EUs objective to improve the evidence base for policy through better data on the energy performance of the building stock. However, we wish to raise several concerns about the proposed implementing regulation, especially in terms of proportionality, legal clarity, and administrative implications for property owners. First, the draft regulation requires reporting of a broad and detailed set of indicators, including life-cycle greenhouse gas emissions, disaggregated energy use by energy class, smart readiness scores, and renovation scenarios with estimated costs and benefits. These data demands assume the existence of comprehensive, standardized, and validated national datasets, which is not the case in many Member States today. The risk is high that inconsistent or incomplete national data will produce misleading statistics at EU level, resulting in flawed policy conclusions. We urge the Commission to revise the list of required indicators with a focus on data reliability, policy relevance, and proportionality. Second, while Member States are formally responsible for transmitting the data, much of the underlying information must in practice be obtained or financed by private property owners. This includes energy performance certificates, renovation passports, and (in the future) smart readiness assessments. These instruments entail costs, especially for small-scale landlords or owner-occupiers. Furthermore, property owners are already subject to several overlapping reporting obligations, including those stemming from national energy statistics, the Energy Efficiency Directive, the EU Taxonomy Regulation, and the Corporate Sustainability Reporting Directive (CSRD). Any new obligations should be coordinated with existing frameworks to avoid duplication, and the administrative and financial burden on owners must be assessed and mitigated. Third, the draft regulation lacks legal clarity regarding optional elements of the Energy Performance of Buildings Directive. Two major reporting areas building renovation passports (BRP) and the Smart Readiness Indicator (SRI) are optional under Directive (EU) 2024/1275. Nevertheless, the regulation includes extensive reporting obligations on these instruments, using the label mandatory if applicable (Miap). This is insufficient. Member States that have not implemented BRP or SRI schemes should not be expected to report related indicators. The current formulation risks creating indirect pressure on Member States to adopt these instruments simply to comply with the reporting framework. We therefore strongly recommend that the regulation include an explicit legal provision, e.g. in Article 1 or 2, stating that reporting obligations apply only where the respective national schemes exist. Finally, while we welcome the requirement to anonymise personal data and aggregate information at national level, we are concerned about the possible downstream uses of the published data. Financial institutions, insurers, and other third parties may use publicly available building data (such as energy class or emissions intensity) to apply indirect market pressure on owners, effectively creating renovation obligations outside the scope of the directive. To protect ownership rights and market neutrality, the regulation should prohibit commercial reuse of the data by third parties and establish safeguards to monitor how the data is accessed and applied. In conclusion, we urge the Commission to align the implementing regulation more closely with the legal nature of the directive, existing administrative realities in Member States, and the legitimate interests of property owners.
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Meeting with Stefan Moser (Head of Unit Energy)

19 Feb 2025 · Exchange of views on housing policy, including coordinating role of the TFH in the Commission as well as cooperation with external partners

Meeting with Johan Danielsson (Member of the European Parliament) and Public Housing Sweden

18 Feb 2025 · Bostadspolitiska frågor i EU under mandatperioden

Meeting with Barbara Brandtner (Director Competition)

18 Feb 2025 · The housing market in Sweden and State aid rules on housing

Response to Evaluation of the EU Lifts Directive

12 Feb 2025

1. Scope Should Be Limited to New Lifts We emphasize the importance of ensuring that the scope of the Lifts Directive remains limited to new lifts and does not introduce requirements that could be retroactively applied to existing installations. Sweden has a long-standing issue where requirements intended for new lifts have been extended to existing lifts, creating significant financial and administrative burdens for property owners. To ensure legal certainty and proportionality, the revised directive should explicitly state that new requirements apply only to lifts placed on the market after its entry into force, preventing member states from introducing retroactive obligations. 2. Ensuring Interoperability in Control Systems to Avoid Market Lock-In A major concern for property owners is the proprietary nature of lift control systems, which effectively locks them into long-term, costly service agreements with the original manufacturer. Many lift manufacturers design their systems in a way that restricts third-party access to servicing and maintenance, limiting competition and increasing costs. How Proprietary Systems Create Market Lock-In Many lift manufacturers use proprietary software, diagnostic tools, and control systems that make it impossible for independent maintenance providers to service the lifts. This results in: - Restricted access to maintenance: Only the original manufacturer can perform maintenance or repairs, even for routine issues. - Artificial spare part shortages: Manufacturers limit spare part availability or significantly inflate prices, sometimes forcing full lift replacements instead of repairs. - Software and diagnostic tools are locked: Third-party technicians cannot troubleshoot or repair lifts without access to proprietary tools. - No alternative service providers: Property owners must accept whatever service terms and costs the manufacturer dictates, leading to higher-than-market prices. Economic and Operational Impacts on Property Owners - **Increased maintenance costs**: Lack of competition results in significantly **higher service fees**. - Reduced flexibility: If a service provider underperforms, property owners cannot switch to a competitor. - Forced full replacements: Some manufacturers declare lifts obsolete and refuse to supply parts, pushing for expensive full replacements. - Longer downtime: Limited access to maintenance tools and spare parts leads to delays in service and repairs, affecting residents and businesses. The Need for EU-Level Regulation on Interoperability To address these issues, the revised Lifts Directive should introduce clear interoperability requirements to ensure that: - Lift control systems are designed to allow third-party maintenance providers to access and service the lifts. - Software, diagnostic tools, and spare parts must be made available to independent technicians to promote fair competition. - Manufacturers cannot use software updates or security measures to artificially restrict service access, ensuring that property owners have a real choice in service providers. By mandating interoperability, the directive would enhance competition, reduce costs, and improve service availability for property owners across the EU. This approach has already been introduced in other industries, such as automotive repair, and should be extended to the lift sector to prevent monopolistic service agreements. 3. It is crucial that the Lifts Directive aligns with the EUs broader regulatory framework on repairability and circular economy. Manufacturers should be required to provide spare parts for a reasonable period after a lift has been placed on the market. This would prevent situations where property owners are forced into full lift replacements due to artificial spare part shortages. This issue is particularly relevant given the ongoing legislative discussion in France, where lift manufacturers argue that spare parts are no longer available, making repairs impossible.
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Response to Initiative on EU taxonomy - environmental objective

2 May 2023

We welcome the recognition of Construction and real estate activities as eligible for the purpose of transitioning to a circular economy (CE) under the Taxonomy Environmental Delegated Act. Our comments are limited to this topic. We highlight the need to consider differences within the construction sector (i.e., contractors as service providers) and the property sector (i.e., investment decision makers) to ensure the motivation to change/advance on transitioning to a circular economy is well placed to where decisions are being made. According to the Swedish National Board of Housing the material recycling rate is currently at 52% for construction and demolition materials. Some key materials are lacking fully functioning material recycling processes. Due to this, to meet the proposed TSC of at least 90 % (by weight) of the non-hazardous construction and demolition waste generated on the construction site is prepared for re-use or recycling seems, unfortunately, unattainable. We call for a feasibility check regarding 90 %. We also express a deep concern regarding data availability in existing Environmental Product Declarations regarding GWP fossil, GWP biogenic, GWP land for Level(s) indicator 1.2 reporting format (as expressed in footnote 78). We estimate that over 80% of available EPDs does not have this information. By setting to high requirements over 80% of the existing EPDs will not be useful for the Taxonomy. We therefore strongly request the Taxonomy to allow for a gradual introduction of the proposed criteria until there is sufficient EPDs produced containing the necessary information. If not, the criteria will not be possible to align with. When setting TSC for "retaining" when renovating building we see the need to revise the calculation method. Using gross floor area is not practical. We propose to specify building components, e.g., building frame, façade etc, when determining level of retaining.
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Response to Asbestos screening, registering and monitoring

8 Feb 2023

Se enclosed file for comments from the Swedish Propert Federation.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

25 Mar 2022

Allmänna synpunkter Fastighetsägarna anser att rätt utformade och incitamentsbaserade styrmedel för energieffektivisering av byggnadsbeståndet är en grundläggande förutsättning för att fastighetsbranschen fortsatt ska kunna bidra till uppsatta energi- och klimatmål. Fastighetsägarna välkomnar de ambitiösa målen, men anser att förslaget inom vissa områden är alltför detaljstyrande och oproportionerligt vilket riskerar att medföra mycket stora kostnader för både fastighetsägare, boende och ekonomin i stort. Fastighetsägarna anser att förslaget är kontraproduktivt då vissa av kraven skulle onödigt försvåra, fördyra och i värsta fall undantränga kostnadseffektiva satsningar på energieffektivisering och förnybar energi i Sverige. Fastighetsägarna anser det nödvändigt att legala styrmedel som Energiprestandadirektivet (EPBD) beaktar de olika förutsättningar som råder inom EU. Energisystem, klimat och byggnadstekniska lösningar mm skiljer väsentligt mellan EU:s medlemsstater. Det är naivt att tro att EU kan detaljreglera energieffektiviseringsåtgärder och -krav under dessa vitt skilda förutsättningar. Fastighetsägarna anser att krav på nollutsläppsbyggnader är beroende av att energisektorn blir en nollutsläppssektor. Rådighetsfrågan är här avgörande, byggnadsägare har inte rådighet över bränsle- och energimix inom energisektorn. Fastighetsägarna anser att förslaget har en orealistisk tidsram och otillräcklig motivering för de föreslagna ”Minimum Energy Performance Standards” (MEPS). Fastighetsägarna anser att bruk av delegerade akter för fundamentala kostnadsdrivande aspekter utgör en oacceptabel risknivå för bygg- och fastighetssektorn. Fastighetsägarna anser att kommissionen som huvudregel inte ska ges mandat att ta fram delegerade akter. Fastighetsägarna saknar förnybar el från nätet. Fastighetsägarna anser att ”environmental and health externalities” ska strykas då det medför en icke kalkylerbar faktor för kostnadsoptimal beräkning. Fastighetsägarna anser det vara motsägelsefullt kring vilka energikrav som ska gälla för nya byggnader. ”Minimum energy performansce reqirements (NZEB)” ska sättas utifrån kostnadsoptimalitet. För ”Zero emission buildings” framgår inte vilka antaganden kommissionen gjort. Kommissionen föreslår att detta ska läggas fast av Kommissionen själva i en delegerad akt. Det kan inte accepteras. Fastighetsägarna anser att det är omvänd ordning att ställa krav på att beräkna GWP innan erforderligt underlag finns framme. Kraven på GWP bör träda i kraft under förutsättning att en reviderad CPR har trätt i kraft. Fastighetsägarna anser att medlemsländerna ska få större flexibilitet att uppfylla energieffektiviseringsmålen. Kommissionen har inte hörsammat kritiken från Regulatory Scrutiny Board. Subsidiaritets- och proportionalitetsprinciper har inte efterlevts. Fastighetsägarna anser kravet på att Technical Building Systems (TBS) ska kunna ”monitor and regulate of indoor air quality” (11.3) ska strykas. Inomhusmiljö är ett brett och viktigt ämne som består av många olika parametrar som till exempel NOx, radon, PM10-halt mm. Det är inte rimligt att TBS ska kunna reglera dessa parametrar. Fastighetsägarna anser att nationell bostadspolitik och specifikt hyressättningsfrågor inte är ”EU Competence”. Texter om eventuella ”rent support” eller ”rent cap” (15.13) hör inte hemma i EU Direktiv. Hyressättningsregler är nationell angelägenhet. Fastighetsägarna avstyrker att inspektioner ska ske så pass ofta som vartannat år (20.3). Det är inte rimligt eller proportionellt mot nyttan.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

Please find the comments from Swedish Property Federation in attached file.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Ensuring carbon neutrality and fostering the energy transition is a key societal challenge. Property owners, be they owner-occupiers or individual/professional landlords, are not only key stakeholders in the housing and real estate sectors, they also are consumers, as well as potentially producers of renewable energies helping households and businesses to reduce their energy costs and their environmental footprint. The Commission’s proposal is a valuable attempt to increase the importance of renewables in the energy mix. To contribute positively and fairly to boosting the installation of renewable energy sources in the building sector, we consider nonetheless that some adjustments of the policy framework proposed are needed. We welcome that: • local planning is still considered a central aspect for the integration and deployment of renewable energy (Art. 15.3). We believe it is important that this further push towards integration of suppliers continues at local level, through the involvement of local and regional administrative bodies, together with network operators. • a more interconnected local infrastructure open to third party suppliers and a better use of waste heat, is to be integrated in a circular energy system (new paragraph 4a of Art. 24). We consider it necessary for the local infrastructure of heating and cooling to adapt and allow suppliers of energy from renewable sources and from waste heat and cold to connect. This is crucial to guarantee consumers communities’ and property owners’ choice. We consider it is a suitable approach to: • set targets for increasing the use of renewables in the building sector at national level as it gives Member States the necessary flexibility to reach them, as long as these targets remain realistically achievable. As the requirement to use minimum levels of energy from renewable sources is no longer limited to new buildings and existing buildings that are subject to major renovation (previous Art. 15.4), we consider that at the very least technical, functional and economic feasibility should remain the cornerstone of national policy measures in this regard (as it was in RED II)
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Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

We welcome the opportunity to express our views on the Draft Delegated Regulation on Sustainable Finance (Ares (2020)6979284) – EU classification system for green investments. The property sector has an important role to play in the race towards a decarbonised European economy by 2050. As an association, we are committed to improve the sustainability of our built environment on EU and national level, and likewise we acknowledge the importance of the European Commission’s efforts to direct more investments into environmentally sustainable activities that substantially contribute to the EU’s environmental objectives. We wish to bring to your attention that the Taxonomy is failing to deliver on its promise. In fact, it is almost contradicting the important objectives of the EU Green Deal and the Renovation Wave Strategy. We believe this for the following reasons: 1) The Technical screening criteria are prominently supportive of construction and/or acquisition of new buildings, while fully disregarding the most meaningful real estate activity to substantially support climate change mitigation, i.e. ownership and/or acquisition of existing buildings with the aim of improving their sustainability performance. 2) The proposed changes to Existing Buildings (EPC A) would significantly decrease the amount of assets available to i. Real Estate companies, ii. Municipalities iii. Regions and iv. Financial Institutions. 3) The suggested change regarding Existing Buildings would not achieve coherency across EU member states. Energy Performance Certificates are an EU-wide classification but implemented differently in each member state. Consequently, EPC A will vary across member states in terms of the climate efficiency it delivers and how tough it is to achieve. In that context, and in relation to the Acquisition and Ownership, we fully support the proposal put forward by the Technical Expert Group (TEG) underlying that the TSC should be set at a level reflecting the top 15 % in terms of energy demand, rather than on solely the EPC Class A, as we explain thoroughly under section 4 in our attached pdf We would like to take this opportunity to share our specific comments on the Technical Screening Criteria (TSC) and DNSH with respect to 7.1 Construction of new Buildings, 7.2 Renovation of existing buildings and, in particular 7.7 Acquisition and ownership of buildings. We also have comments regarding Energy production.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

As key stakeholders in the housing and real estate sectors, we welcome the opportunity to express our views on the Roadmap on “A Renovation Wave initiative for public and private buildings”. Property owners have a crucial role to play in the energy transition, and we thus value the possibility of having their position considered and their concerns reflected in the upcoming Renovation Wave and its action plan. Improving the sustainability of our built environment is a matter of great importance for our association. In line with the views expressed in the Green Deal Communication and the Renovation Wave Roadmap, we are convinced that better performing buildings can ensure healthier and safer environments for all citizens. The development of renewables, greener heating and cooling solutions, as well as the need to factor in climate resilience, circularity and digitalisation aspects should also contribute to this task. However, renovation does not come without a cost, and this inevitably entails a critical challenge for European citizens and real estate companies, even more so in light of the disruption brought by the recent pandemic. If it is true that energy efficient buildings with integrated renewable systems lower energy bills, it is also true that renovating one own’s dwelling require high upfront investments and considerable costs that many simply cannot afford. Promoting renovation – not to mention imposing it – can fall short of its social objectives unless coupled with the appropriate incentives and the necessary support. To this end, in our view, the Renovation Wave and its action plan should focus on FACILITATING and ENABLING renovation to GET IT RIGHT, as no “wave” can take place across Europe without making sure that it does not translate into a mere economic burden but rather truly empowers citizens and companies to live in a more sustainable environment. See also attached file.
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