Turboden

Turboden is an Italian firm and a global leader in the design, manufacture and maintenance of Organic Rankine Cycle (ORC) systems, highly suitable for distributed generation, that generate electric and thermal power exploiting multiple sources, such as renewables (biomass, geothermal energy, solar energy), traditional fuels and waste heat from industrial processes, waste incinerators, engines or gas turbines.

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ID: 111151414941-72

Lobbying Activity

Meeting with Martin Hojsík (Member of the European Parliament) and ENEL SpA and

26 Nov 2025 · Geothermal energy breakfast

Meeting with Jan Farský (Member of the European Parliament) and European Geothermal Energy Council and

26 Nov 2025 · Support to geothermal energy

Response to Heating and cooling strategy

9 Oct 2025

Turboden welcomes the opportunity to contribute to the EU Heating and Cooling Strategy consultation. The focus is on industrial waste heat recovery, geothermal energy, district heating, and efficiencyadvancing a holistic, cross-sectoral approach that links thermal needs to industrial competitiveness, system integration, and decarbonisation. Europe faces a decisive challenge: strengthening energy resilience and upgrading strategic infrastructure is urgent to achieve Green Deal goals. Scaling up local manufacturing and leveraging European technologyparticularly large heat pumps, geothermal, and ORC systemswill secure employment and technological leadership across the clean energy transition. The move to fully renewable and waste-heat powered district heating by 2045 is a timely chance to modernize and reinforce energy infrastructure. Waste heat recovery from industry and data centers must be recognized as a strategic assetcrucial for heating networks and, where feasible, for onsite electricity generation with ORC, delivering both energy security and emissions cuts. Turbodens core technologiesgeothermal, industrial-scale waste heat recovery, and large heat pumpsare included among the 19 net zero strategic technologies designated by the NZIA. As underlined by the KCORC report, up to 150 TWh/year of power could be produced in Europe from presently wasted heat, vastly improving industrial efficiency and emissions. Achieving this potential requires coordinated EU action: integrating new and existing resources, supporting investment, harmonizing regulation, and accelerating future-proof infrastructure deployment.

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Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

We support efforts to simplify and harmonise the Taxonomy, since it does not drive investment in heating and cooling (H&C), despite the sector consuming half of the EUs energy, with 75% using imported fossil fuels. Several district heating and cooling (DHC) activities are eligible, yet outdated and complex criteria hinder alignment. DHC expansion is essential for competitive decarbonisation, but the Taxonomy has not supported the necessary investments. Future revisions must align criteria with existing legislation and support less efficient systems. PwC 20222024 data highlights low Taxonomy alignment for H&C. Energy and utility companies had the highest turnover alignment (25%), mainly in manufacturing (3.1, 3.5, 3.6). CAPEX alignment averaged 12%, with energy and utilities leading at 33%. Solar PV (4.1) was the only highly reported energy activity1. Another 2023 analysis of 1,300 companies found low energy sector alignment (18% CAPEX, 5% revenue, 10% OPEX), while utilities, mainly electricity and transport-related, had the highest alignment. Only one company reported taxonomy alignment for natural gas2. A report on green bonds (2022Sept 2024) showed the energy sector received just 7%, and > 1% Taxonomy-aligned, while utilities received 52%, with 79% alignment, mostly from companies already exceeding 80% renewable capacity3. The lack of alignment for H&C suggests the Taxonomy is failing to guide sustainable investments across all sectors, despite its aim to do so regardless of their starting point disadvantaging smaller DHC systems. Geothermal activities face unnecessary burdens, hindering investments in a proven renewable technology crucial for decarbonizing district heating and cooling in Europe. For activities under sections 4.18 and 4.22 the required life cycle assessment (LCA) disadvantages them compared to other renewables even if studies show existing plants stay below the 100 gCO2e/kWh threshold. TSC for activity 4.15 must align with the EED 2023 definition of efficient DHC. The updated definition provides a clear trajectory towards climate neutrality, ensures coherence across legislation and removes the need to further amend DHC criteria. A recent study finds that outdated and complex TSC for DHC activities render taxonomy impacts on DHC investments minimal. Nonetheless, in some markets, DHC remains a recognised sustainable investment for decarbonisation because of the wider energy framework like the EED or ETS, but Taxonomy has little impact4. For effectiveness, DHC criteria should be simplified and harmonised across legislation. Finally, even if we support the effort to push for a major simplification and harmonization of the Taxonomy, we must highlight that while the Production of heat/cool using waste heat is properly reported in the first Delegated Act of Taxonomy (Annex I and II, point 4.25) and already recognised as a climate mitigation and green investment measure (so including large heat pump, biomass or geothermal applications) the production of power using waste heat (Waste heat to Power solution) is currently missing, despite being a carbon-neutral solution. Therefore, we recommend adding waste heat to power (utilisation of waste heat from industrial and tertiary sources to produce electricity for internal or external usage) to the list of energy measures that should be considered under the EU Taxonomy regulation.

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Response to Delegated act on primarily used components under the Net-Zero Industry Act

19 Feb 2025

Turboden, an Italian company part of the Mitsubishi Heavy Industries group, is a world leader in the design, production and maintenance of ORC (Organic Rankine Cycle) systems and large industrial heat pumps (IHP), technologies that play a crucial role in the decarbonization of industrial processes and in pursuing the European Union's climate objectives. In particular, ORC systems can generate electrical and thermal energy by exploiting multiple sources, such as biomass, geothermal energy (including the production of electrical energy and heat, but also the extraction of critical materials such as lithium) or waste heat recovery from industrial processes. Industrial Heat Pumps (IHP) represent another key technology in Turbodens portfolio, enabling the efficient upgrading of waste heat to higher temperature levels for reuse in industrial processes or district heating networks. By leveraging renewable and residual heat sources, IHPs contribute to reducing primary energy consumption and carbon emissions, aligning with sustainability goals and Energy Efficiency Directive (EED). Founded in 1980 in Milan, Turboden has experienced significant growth in recent years, thanks to the acquisition of strategic projects in Europe and the United States; today the company is present in 52 countries, with over 463 plants. Delegated act on primarily used components under the Net-Zero Industry Act We welcome the European Commissions efforts to enhance the regulatory framework for net-zero technologies, particularly through the classification of final products and key components. However, we believe that some areas need a more comprehensive approach, with further refinement required to ensure that both geothermal technologies, heat pumps, solid biomass and waste heat recovery to power are adequately supported in the same way as wind, solar, hydrogen, and battery storage.

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Response to List of net-zero technology final products and their main specific components

19 Feb 2025

Turboden, an Italian company part of the Mitsubishi Heavy Industries group, is a world leader in the design, production and maintenance of ORC (Organic Rankine Cycle) systems and large industrial heat pumps (IHP), technologies that play a crucial role in the decarbonization of industrial processes and in pursuing the European Union's climate objectives. In particular, ORC systems can generate electrical and thermal energy by exploiting multiple sources, such as biomass, geothermal energy (including the production of electrical energy and heat, but also the extraction of critical materials such as lithium) or waste heat recovery from industrial processes. Industrial Heat Pumps (IHP) represent another key technology in Turbodens portfolio, enabling the efficient upgrading of waste heat to higher temperature levels for reuse in industrial processes or district heating networks. By leveraging renewable and residual heat sources, IHPs contribute to reducing primary energy consumption and carbon emissions, aligning with sustainability goals and Energy Efficiency Directive (EED). Founded in 1980 in Milan, Turboden has experienced significant growth in recent years, thanks to the acquisition of strategic projects in Europe and in the United States; today the company is present in 52 countries, with over 463 plants. Delegated act on primarily used components under the Net-Zero Industry Act We welcome the European Commissions efforts to enhance the regulatory framework for net-zero technologies, particularly through the classification of final products and key components. However, we believe that some areas need a more comprehensive approach, with further refinement required to ensure that both geothermal technologies, heat pumps, solid biomass and waste heat recovery to power are adequately supported in the same way as wind, solar, hydrogen, and battery storage

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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

Turboden, a Mitsubishi Heavy Industries group company, is an Italian firm and a global leader in the design, manufacture and maintenance of Organic Rankine Cycle (ORC) turbines - highly suitable for distributed generation -, Gas Expander (GEX) and Large Heat Pumps (LHP) for industrial applications. Turboden has been a leading manufacturer of made-in-EU technologies and solution provider of energy efficiency solutions in industrial processes and in the world of renewables for over 40 years and an active member of several European working groups related to the topic of industrial transition. The excellence of European manufacturing in the field of energy efficiency, recently promoted also by the Net Zero industry Act plan is another key building block for the development and strengthening of the industrial competitiveness of the entire European manufacturing and an opportunity to boost the competitive advantage of the industries of the contains within the wider global markets. For this reason, we welcome the Commission effort to provide guidance to Member States and market actors on how to unlock private investment in energy efficiency. We consider this as a key factor for further development of the sector and its environmental and social benefits, for the development of the manufacturing of these technologies in Europe as well as for the increase in competitiveness of small and large enterprises. Attached an overview on specific sectors.

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Response to Action plan on accelerating Heat Pump market and deployment

26 May 2023

Turboden S.p.A, an Italian company of MHI group, welcomes the opportunity to provide inputs on the European Commissions Action Plan to accelerate heat pumps roll-out across the EU. As a technology provider, Turboden contributes to the debate on Industrial Heat Pumps for Low-temperature applications in District Heating Networks as well as High-Temperature applications to decarbonize industrial processes. Large Heat Pumps (LHP) are utility-scale heating plants that allow transferring large quantities of heat from a colder source - like environmental heat or industrial waste heat - to a higher temperature heat user, like a district heating network or an industrial process. At the state of the art, LHP development can be summarized as follows, based on the temperature required by the heat user: District Heating applications (up to 100 °C). Traditional commercial products are available up to 90-100°C. The first Turboden plant recovering waste heat from a steel industry to feed a District Heating network reaching up to 120°C is now in operation https://heatleap-project.eu/ HIGH Temperature for industrial heat (up to 200 °C). Several players are offering solutions but only a few projects are ongoing. The first Turboden plant that will generate high-temperature heat (steam) without CO2 emissions in a Pulp&Paper Industry has been signed. https://www.turboden.com/company/media/press/press-releases/4436/what-could-not-be-done-before-is-now-possible-turboden-large-heat-pump-decarbonizes-industrial-steam-demand Following, are some suggested focuses: 1) Policy initiatives and finance. Develop specific measures to reduce CAPEX and OPEX (electricity bill) eg. tax credit and/or funding program, promotion of RES PPA for Industrial Heat Pump users, more valorization the role of waste heat and geothermal heat We recommend also to include a clear mandate to design an EU risk insurance scheme The recent Net-Zero Industry Act (NZIA) presented by the European Commission reports boosting European production capacities for renewable energy technologies. Geothermal and Heat Pumps are among the 8 key net-zero technologies. This legislation will help scale up net-zero technology manufacturing in the EU to provide at least 40% of the EUs annual deployment needs for strategic net-zero technologies by 2030. We recommend the present call for evidence on Heat pumps and further development will take into serious consideration the role and support to the EU manufacturers 2) Communication and skills. Many industrial processes do not consider HP due to a lack of awareness. Needs of intensive communication through eg. Energy agency, Esco, Technical University, Research center, engineering company). Keywords must be No interference with core industrial processes 3) Research & Innovation + Training. to improve efficiency and new components, and materials and to boost cluster of installations. Needs of a learning curve to reduce costs and integration of components and optimization This is a brief overview of the Turboden position, please find more detailed feedback in the papers reported from the association we cooperate with, particularly: EGEC European geothermal energy council Euroheat & Power EHPA - European Heat Pump Association

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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

Turboden S.p.A. welcomes the initiative of the European Commission on the Energy Efficiency Directive Recast. We strongly support the policy recommendations aiming at the promotion of energy efficiency and the efficient use of the sources. By the next decade, the EU must halve its greenhouse gas emissions and slash its fossil fuel dependency. Turboden positively receives the introduction of the energy efficiency first principle (EE1st principle) that, together with resources efficiency, is an important enabler for the EU long-term decarbonisation strategy. For that reason, the most resource and cost-efficient solutions need to be valorised creating a favourable policy framework. Turboden suggests six changes to the European Commission’s proposal in order to guarantee its successful operationalisation and outcome. 1. In order to emphasise the role of energy efficiency and increase its ambitious target, the energy efficiency first principle needs to be extent to all investment decision and not confine only to large-scale investments. Energy efficiency measure should be considered in the context as wider as possible! 2. Introducing a lower tariff for electricity feeding energy efficiency equipment, such as industrial heat pumps, has a great priority from the investor and industrial end-user perspective. Cost-efficiency is the centre of the EE1st principle and, considering the latest electricity price increases, energy efficiency solutions need to receive adequate electricity tariff not subject to market changes. 3. Gas distribution companies that invest in energy efficiency systems, are not entitle to produce and sell the produced electricity. This is detrimental to the overall efficiency of the gas infrastructure. 4. Energy efficiency investments, resulting from energy audit, should be put in place as mandatory measures. This measure should be applied especially in hard-to-abate sectors that receive benefits and tax relief in their energy bill. It is key to link any kind of mitigation costs of gas and electricity (or discount on surcharge costs) with mandatory investments in energy efficiency leveraging money from the EC. 5. Local heating and cooling plans will have an extreme importance and should be implemented by local authorities of all sizes. 6. In order to increase the share of renewables in district heating and cooling networks, waste-based fuels need to be valorised and their use should increase in the existing heat sources.

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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Nov 2021

Turboden S.p.A. welcomes the initiative of the European Commission on the Renewable Energy Directive Recast. We strongly support the policy recommendations aiming at the promotion of renewable sources and the efficient use of them. By the next decade, the EU must halve its greenhouse gas emissions and slash its fossil fuel dependency. Biomass has an essential role to play in this transition, for that reason, sus-tainable and predictable renewables such as biomass, geothermal, waste heat, renewable hydrogen need to be valorised creating a favourable policy framework. Turboden considers that there are six changes that should be made to the European Commission’s pro-posal to guarantee its successful operationalisation and outcome. 1. When drafting their support schemes Member States should strive to avoid any undue raw mate-rial market distortions. While an EU determined regulation on cascading would not be the right policy tool to prevent such distortions from happening (as recognised in 2018), Member States could benefit from an updated cascading guidance document. 2. There should be no retroactive application of measures, including on the GHG savings criteria, to protect legal certainty and ensure businesses trust in the energy transition. For it to be success-ful, the EU needs a sustainable growth of bioenergy. Regulatory uncertainty will not contribute to this objective. Retroactive introduction of GHG savings criteria will lead to the closure of existing plants and the slowing down or even the possible t reversal in the energy transition. 3. The exemption threshold for biomass should not be lowered from 20 to 5 MW. Although a threshold lower than 20 MW would certify the sustainability of a larger portion of biomass, it would place regulatory burdens and disproportionate cost compliance on the smallest actors with scarce administrative capacity. Time and digitalisation will be necessary before cost compliance can be brought down. 4. Support for installations producing electricity-only from forest biomass to 2030 should be maintained. Aid stemming from support schemes established after that date should still be grant-ed in cases where there is no commercial demand for heating, where it is necessary for the securi-ty of the energy supply, the stability of the grid, to prevent the risk of re-carbonisation, in Just Tran-sition territories. 5. In order to valorise all renewable non-fossil sources, “waste heat” needs to be explicit included in “renewable energy” definition. It represents a cost-effective, clean and reliable source of both, thermal and electric generation, such as other renewables: it is essential for the industrial decar-bonisation. 6. Considering future developments and the increasing relevance of hydrogen, a first and clear defi-nition of “Renewable Hydrogen” needs to be defined in the Renewable Energy Directive.

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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

Turboden S.p.A. welcomes the revision of guidelines of Trans-European energy infrastructure providing for the selection process of projects of common interest, which can facilitate their implementation and which represents and reflects a technological improvement for the gas and electricity networks being part of a Euro-pean Energy System Integration Strategy. Aiming at enable to the energy transition and to the decarbonisation of the EU energy system, TEN-E is a central instrument allowing to infrastructures (that are long-lived assets) to reach climate neutrality tar-gets and environmental objectives. The overall principles of the revisited TEN-E Regulation should avoid the distortive effects of uncoordinat-ed, fragmented policy initiatives, such as Energy Efficiency Directive, Taxonomy Regulation, Gas Network regulation and Strategy for Energy System Integration. In particular, here below are listed proposals for the revision of TEN-E Regulation: a) Include in “smart gas grid” definition (TEN-E Regulation Proposal, Art. 2, par. 9 ) waste heat to power so-lutions in gas compressor station in order to increase energy efficiency in gas distribution network. In particular: ‘smart gas grid’ means a gas network that makes use of innovative digital solutions to integrate in a cost efficient manner a plurality of low-carbon, renewable gas sources and waste heat to power solutions, in accordance with consumers’ needs and gas quality requirements in order to reduce the carbon footprint of the related gas consumption, enable an increased share of renewable and low-carbon gases, and create links with other energy carriers and sectors; b) In order to modernize all infrastructures especially in gas distribution ones, it should be included as mandatory both sustainability criteria and energy efficiency projects (e.g. waste heat recovery from gas compressor station and gas expanders).

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Response to Revision of EU rules on Gas

26 Feb 2021

Turboden S.p.A. welcomes the publication of combined evaluation roadmap/inception impact assessment-Hydrogen and Gas markets Decarbonisation Package, which represents an improvement of this sector in the European Energy System. Aiming at avoiding the distortive effects of uncoordinated, fragmented policy initiatives (such as Energy Effi-ciency Directive, Renewable Energy Directive, TEN-E regulation and Strategy for Energy System Integration) and in order to facilitate the production of renewable gases, here below are listed proposals for the revision of Gas Directive and Regulation: a) consent transportation and distribution companies to produce/sell electricity when it derives from en-ergy efficiency projects within their facilities (according to the EED 2012/27/EU and amended 2018/2002 - art. 15 par. 4); b) include sustainability criteria in order to decarbonized gas network (according to Proposal for TEN-E reg-ulation); c) Include as mandatory the energy efficiency projects in gas distribution tenders (e.g. waste heat recovery from gas compressor station or industrial processes and gas expanders), according to Energy Efficiency first principle.

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Response to Review of Directive 2012/27/EU on energy efficiency

18 Sept 2020

Turboden welcomes the European Commission initiative evaluating the possible revision of the Energy Efficiency Directive. The revision of the Directive is an important opportunity to further expand the energy efficiency benefits, as well as to support and create a common framework, also in accordance with the Energy System Integration Strategy. Further energy efficiency will allow to reduce reliance on fossil fuels and increase the share of renewable over the total energy mix. Among the policy options presented by the inception impact assessment, Turboden supports Option 3 (revision of the EED) combined with Option 2 (non-regulatory measures). 1. Energy efficiency target should be adjusted to be in line with the carbon neutrality target. Considering the potential of higher energy efficiency for renewable heating, the target for renewable heating and cooling must be increased to achieve at least 50% of the final heat to be renewable by 2030. In particular, check both the formal transposition and actual implementation of the EED Article 14 and Article 15 provisions related to CHP in national legislation. 2. Awaiting the European Commission assessment, preliminary analysis suggests that the final NECPs might still have the potential to further increase energy efficiency. The potential gap between the nationally set targets and the common target of 32.5% by 2030 must be filled to achieve carbon neutrality by 2050. 3. As proposed in the Energy System Integration Strategy, a review of the primary energy factor for electricity (ANNEX IV EED – footnote 3) should lead to a better recognition of these energy efficiency savings. The current factor of 2.1 should be revised to reflect the increasing share of renewable energy in electricity generation. Its application in EU product regulation should happen at a pace compatible with technical and commercial processes of the EU industry. 4. Proposals: Energy-intensive industries are important emitters of greenhouse gases in Europe, with the cement, chemical and steel sectors dominating industrial emissions. Finding solutions to drive down energy consumption and emissions is a top priority. Exploiting waste heat fosters a circular economy and lower fossil fuel-derived-energy consumption and emissions represent a key priority in the recent smart sector integration strategy. A specific effort to support waste heat recovery technology targeting primarily energy-intensive industrial applications is strongly recommended, representing an opportunity to boost energy efficiency development. This can be achieved: - by creating a common framework in order to incentivise waste heat to power introducing a feed in tariff dedicated to energy produced by waste heat recovery; - adjusting incentive scheme such as White Certificate mechanism focused on waste heat recovery

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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

Dear Sir/Madam Turboden S.p.A. views on the TEN-E Inception Impact Assessment consultation Turboden, a Mitsubishi Heavy Industries group company, is an Italian firm and a global leader in the design, manufacture and maintenance of Organic Rankine Cycle (ORC) systems, highly suitable for distributed generation. ORC systems can generate electric and thermal power exploiting multiple sources, such as renewables (biomass, geothermal energy, solar energy), traditional fuels and wastWe welcome the opportunity to respond to the consultation on the TEN-E Inception Impact Assessment. Our observations and recommendations are: TEN-E Regulation, should focus more on infrastructure modernization, energy efficiency (EE) and sustainability through funding infrastructure of the future. Indeed, not only needs the EU infrastructure to be developed and interconnected. It needs to be deployed in the most efficient and modern way in order to ensure that public funding is spent in the best way. Efficient and low-carbon technologies are essential to promote decarbonisation, energy security, growth, jobs and competitiveness. Smart sector integration between the power and gas systems, offers additional opportunities to decarbonise the gas grid and manage the power system more efficiently. For instance gas compressor stations are open-cycle, realising pollutant emissions in the atmosphere. State of the art is not the best one must be improved through the adoption of best practice and technologies (e.g. waste heat recovery technologies for power generation, enabling for the decarbonisation). These efficient and low-carbon technologies for this are increasingly available but not yet cost-competitive for deployment at scale. Gas industry is still essential to influence energy transition and to meet global energy needs. In this field EE can make a major contribution in order to foster EU industrial competitiveness, sustainability as well as energy security. In this respect, the recovery of waste heat in gas compressor stations for the generation of electricity represents a solution allowing the EU energy infrastructures not only to be integrated but also to be conceived and built in the most cost-efficient way, therefore meeting international and EU commitments. Gas is an energy-intensive sector. In many applications in the Gas sector, gas turbines are used as prime movers: e.g. in gas compressor stations to make natural gas flow from extraction points to end users, natural gas liquefaction, gas storage, etc. Gas turbine that run gas compressor stations are open cycle and waste a considerable amount of sensible heat in the form of exhaust gas at temperatures above 400°C with consequent inefficiency and negative impact on the environment. The development of EE solutions – such as heat recovery for power generation – can be an interesting opportunity to increase competitiveness, whilst reducing dependency from fluctuating energy prices, reducing avoidable waste heat, optimizing and improving production processes. As EE contributes to both environmental protection and energy security in the most cost-effective way, waste heat recover to power generation in the gas sector represents a key solution to achieve strategic targets: - enhance EE of Gas production processes, reducing budget for electricity; - reduce fuel dependency and grid dependency thanks to EE; - improve the “green” image of fossil fuels; - exploit energy streams currently wasted in the atmosphere mitigating the adverse environmental impact and further improving economic returns; - improve transportation efficiency replacing gas turbines driven compressor with ORC-driven units or gas expander technology. EE measures will strongly contribute to the most cost-efficient infrastructure development, especially in gas sector, thus helping achieve international and EU commitments. Not only control emissions but make the best from them through recovering for re-use (e.g. electricity generation)!

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