EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 8.3.2011 
SEC(2011) 278 final 
  
COMMISSION STAFF WORKING DOCUMENT 
  
IMPACT ASSESSMENT  
 
ANNEX I  
 
Accompanying document to the 
  
COMMUNICATION FROM THE CO MMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMI TTEE OF THE REGIONS 
COMMISSION STAFF WORKING DOCUMENT 
  
Energy Efficiency Plan 2011 
    
COM(2011) 109 final 
SEC(2011) 277 final 
 
 
EN 2   EN ANNEX I   
 
     
 
 
REPORT ON THE PUBLIC CONSULTATION  
 
ON 
 
EVALUATION AND REVISION OF THE ACTION PLAN FOR 
ENERGY EFFICIENCY 
  
  
 
              
In line with the Commission's commitment to transparent and interactive policy-
making, this documents aims at providing an overview and general impression of 
the feedback provided to the Commission in  the context of a public consultation. 
The statements and opinions expressed in the document do therefore in no way 
necessaril y reflect those of the Commissi on or the Commission services. 
 
EN 3   EN  
Table of contents  
 
1. Context and Process ..................................................................................................... 6 1.1. Context and purpose..................................................................................................... 6 1.2. Process and timing ....................................................................................................... 6  
2. Background information about the respondents .......................................................... 7 2.1. Individual respondents ................................................................................................. 8 2.2. Number of participants for each type of organisation responding............................... 8 
2.3. Type of private sector/association responding............................................................. 9 3. General opinion about the current Energy E fficiency Action Plan and its revision .... 9 
4. Specific questions....................................................................................................... 10 4.1. Introduction.............................................................................................................. .. 10 
4.2. The promotion of energy efficient buildings ............................................................. 11 4.3. Transport ................................................................................................................. ... 13 
4.4. Product policy ............................................................................................................ 14 
4.5. Financing................................................................................................................. ... 16 
4.6. Fiscal incentives......................................................................................................... 18 
4.7. Education and Training.............................................................................................. 19 4.8. Awareness of consumers and SMEs .......................................................................... 20 4.9. SMEs...................................................................................................................... .... 21 
4.10. Public sector............................................................................................................ ... 22 
4.11. Energy utilities ......................................................................................................... .. 23 
4.12. Incentives for SMEs to enter the energy efficiency market....................................... 25 4.13. White certification scheme......................................................................................... 25 4.14. Binding targets .......................................................................................................... . 27 
4.15. Measurement and verification.................................................................................... 28 4.16. International cooperation ........................................................................................... 29 5. Final remarks.............................................................................................................. 2 9 
 
 
EN 4   EN  
Executive Summary 
 
At the Spring Council 2007, the EU Heads of Stat es and Governments stressed the need to 
increase energy efficiency in the EU so as to  achieve the objective of saving 20 % of the EU's 
energy consumption compared  to projections for 20201. However, evaluations suggest that the 
energy saving potential is not be ing realised fast enough and the measures adopted so far can 
only achieve energy savings of about 11% by 2020, if prope rly implemented by Member 
States.   On 19 October 2006, the Commission adopted the Action Plan for Energy Efficiency: 
Realising the Potential (EEAP)
2. As announced in the Plan, the Commission is to prepare in 
2009 a revised Action Plan, as requested by the European Council. In this regard a Public 
Consultation on the Evaluation an d Revision of the Energy Effici ency Action Plan was launched 
on 8 June 2009 with a dead line on 3 August 2009. 
 This report presents the results of the public consultation on the Evaluation and Revision of the 
Energy Efficiency Action Plan. This public consultation was also held in order to receive input for the New Energy Efficiency Action Plan planne d to be adopted by the end of this year.   
 There were 203 submissions to the on-line p ublic consultation, 173 organisations and 30 
individuals. In addition, 6 submissions vi a email were sent to the Commission by 
organisations which did not make use of the web- based interface to reply to the questionnaire.  
 Overall, 173 organisations, the 30 individuals and the additiona l submissions have generally 
acknowledged that the measures in the current Energy Efficiency  Action Plan should continue 
to be implemented. However, the majority of th e stakeholders argued that the time had come 
for a more focused and targeted approach in order to promote energy efficiency further.  
 The topics highlighted to be targeted were ener gy efficiency of buildings, access to financing, 
energy efficiency both on the supply and dema nd side for SMEs and a better use of the 
Structural and Cohesion funds with rega rd to energy efficiency projects.  
 It was also pointed out that the new Energy Ef ficiency Action Plan should recognise the role 
of the local politicians in the delivery of energy efficiency in Europe. The Covenant of Mayors was mentioned to be a successful policy instrument to bring energy efficiency policy 
to local level. Several stakeholders were also  of the opinion that co generation and district 
heating planning had to be furt her promoted since the existing legislation had not given the 
correct incentives to develop these policy areas satisfactorily. White certificates were mentioned as an instrument that could give th e correct incentives in this regard. However, 
there seemed to be a general reluctance for a unified EU wide Certification Scheme to be 
introduced.   The majority of stakeholders welcomed bindi ng targets on energy efficiency, however, there 
were some divergent views on which paramete rs to use as a base for the methodology and 
verification for measuring energy efficiency.  
                                                
 
1 7224/1/07 REV 1. 
2 COM(2006) 545. 
 
EN 5   EN  
Energy efficiency was also argued to be a gl obal issue and not only a policy for Europe. A 
reference was made to that several countries  like United States and Japan had already 
launched efficiency programmes. Several stak eholders pointed out that it was therefore 
crucial that Europe from a competitiveness asp ect did not miss opportunities in the timing of 
developing an energy efficient economy.   Finally, it was also emphasised by numerous stak eholders that the different legal instruments 
should not overlap or be conflicting. The Comm ission should endeavour to synchronise the 
different frameworks on energy e fficiency for optimal effect on th e market with due regard to 
avoiding any distortion of  the internal market. 
 A broad range of ideas for possible actions were put forward by respondents. This report 
explores the feedback in more details. Th e policy conclusions drawn by the Commission will 
be set out in an official  communication and not addre ssed in the present report. 
 
EN 6   EN 1. CONTEXT  AND PROCESS  
1.1. Context and purpose  
 
At the Spring Council 2007, the EU Heads of Stat es and Governments stressed the need to 
increase energy efficiency in the EU so as to  achieve the objective of saving 20 % of the EU's 
energy consumption compared  to projections for 20203. However, evaluations suggest that the 
energy saving potential is not bein g realised fast enough and th e measures adopted can only 
achieve energy savings of about 11% by 20204, if properly implemented by Member States5. 
This progress is very unsatisfactory and more acti ons need to be taken in order to address the 
remaining challenges and r eap the potential savings. 
 On 19 October 2006, the Commission adopted the Action Plan for Energy Efficiency: 
Realising the Potential (EEAP)
6. It gave an outline for a coherent framework of legislation, 
policies and measures with a view to save a substantial part of the 20% of EU annual primary energy consumption by 2020. It proposed a sele ction of cost-effectiv e energy efficiency 
improvement initiatives to be put in place and implemented until 2012. As announced in the 
Plan, the Commission is to prepare in 2009 a revised Action Plan, as requested by the 
European Council.  
 To explore possible policy options, several meeti ngs were held with stakeholders. However in 
order to obtain an even wider input for th e New Energy Efficiency Action Plan, a public 
consultation on the current Action Plan was launched on 8 June 2009 with a deadline on 3 
August 2009. Public authorities, businesses, non-governmental organi sations, citizens and 
other interested parties were asked several qu estions with regard to the current Energy 
Efficiency Action Plan and whether there were to be suggested additional measures at EU 
level in order to further promote energy efficienc y. A list of all contributions is to be found in 
Annex I to this report.  
1.2. Process and timing 
 
The consultation consisted of a questionnair e in English with structured questions, 
supplemented by open "free text" questions wher e participants could provide feedback not 
captured in the structured part. The on-lin e questionnaire and the background document can 
be found in Annex II and III to this report.  Moreover, the Commission will publish the 
submissions that answered affirma tively to be published on-line.  
 The public consultation complied with the Co mmission's minimum consultation standards, 
including the 8 week minimum duration. The standard Commission internet tool for 
Interactive Policy Making
7 was used. As participation was voluntary and based on self-
selection, the views expressed by respondents are not necessarily representative of the views 
held by all stakeholders or citizens.  
                                                 
3 7224/1/07 REV 1. 
4 The latest estimates, forthcoming Impact Assessme nt Report on the new Energy Efficiency Action Plan.  
5 COM(2008) 772. 
6 COM(2006) 545. 
7 http://ec.europa.eu/yourvoice/ipm/index_en.htm   
 
EN 7   EN 2. BACKGROUND INFORMATION ABOUT THE RESPONDENTS  
 
In all, 203 responses from individuals and orga nisational participants were received through 
the IPM tool (the on-line questionnaire).    
 Number of requested reco rds Requested records (203) 
Representative of an 
organisation 173 85.2% 
Individual citizen 30 14.8% 
Total number 203 100% 
Tab. 1 Total number of respondents 
 A few other responses, 6 submissions, were submitted by organisations which did not make 
use of the web-based interface to reply to the questionnaire. The st atistical data in this report 
refer only to responses made by the 203 respons es submitted through the IPM tool. However, 
the views in all the submitted responses, incl uding those submitted without using the IPM 
tool, have been considered  by the Commission services.  
 
2.1 Organisations responding 
 
Organisation Participants
48
30
16
11
99887
55444322222111111000
05101520253035404550
 
Fig. 1: Number of organisations res ponding per country of residence 
 
Most responses were received from organisati on representing EU as a whole, followed by 
Germany, France, Netherlands and Austria. Mo reover, there were two contributions from 
Switzerland. 
 
EN 8   EN 2.1. Individual respondents 
 
In all, 30 responses from indi viduals were received. The replies came from citizens from 
Austria, Belgium, Czech Republic, Denmark, France, Germany, Ireland, Italy, Lithuania, 
Malta, Netherlands, Romania, Slovakia, Spain,  Sweden and UK (in alphabetical order). The 
number cannot be seen as representative for th e citizens of EU, but the Commission services 
welcome these submissions since energy effici ency is a policy highly concerned with the 
citizens of the EU.  
2.2. Number of participants for each ty pe of organisation responding 
 
Number of requested records
82
24
171615
13
32100
0102030405060708090
Industry and private
sector, incl. their
associations, excl.
SMEsNon-governmental
organizationOTHER Member States or public
body
(national/regional/local),
incl. RegulatorsEnergy utility Small and Medium Size
Enterprises (SMEs)Consumer organization University/
education/research
instituteFinancing organization European institution or
bodyEnergy Efficiency
Agency (national,
regional, local)
 
 
Fig. 2: Number of participants for each category of organisations 
 
The largest single fraction of responses was from private sector companies or industry 
associations. The second largest fraction of  the submissions was from non-governmental 
organizations.   
 
EN 9   EN 2.3. Type of private sector/association responding 
 
  
Number of requested records
94
85
72
68
61
44
31
0102030405060708090100
Energy Efficiency
services in the
residential sectorEnergy Efficiency
services in the
tertiary and industry
sectorsEnergy-using
products and
appliancesEnergy production,
supply,
transmission or
distributionConstruction Transport sector Other
 
 
Fig. 3: Type of private sector companie s or industry associations that responded 
 
Within the fraction of private sector companie s or industry associations, the largest single 
group was from companies/organi sations dealing with energy e fficiency services in the 
residential sector, in the tertia ry and industry sector. However, also industry related to energy-
using products, energy utilities and construction were highly represented in the received submissions.   
3. G
ENERAL OPINION ABOUT THE CURRENT ENERGY EFFICIENCY ACTION PLAN AND 
ITS REVISION  
 
As a first and general question the public consultation asked whether the 6 key areas and 85 
actions in the current Energy Efficiency Ac tion Plan should be co ntinued, redefined, 
discontinued and if so the public consultati on enquired for the underlying reasons for the 
suggested modifications.   Several stakeholders made reference to the global economical crisis. Moreover, numerous 
stakeholders were concerned because of the climate change. Concern was also raised of the increasing import dependence of Europe and in th is regard the security  of supply of energy. 
Energy Efficiency was therefore concluded to be a good political response to the economical crises by creating job opportunities.  Energy Efficiency could also mitigate climate change and 
 
EN 10   EN security of supply by using the energy in Europe  smarter and more effi ciently. On the aspect 
of mitigating climate change and also secu rity of supply, it was emphasised by several 
stakeholders that it was of importance to find the optimal balance between energy efficiency 
and renewable energy policies.   On how to best promote energy efficiency, the overa ll majority stated that the measures in the 
current Energy Efficiency Action Plan should c ontinue to be implemented. However, several 
stakeholders argued that the time had come for a more focused and targeted approach in order 
to promote energy efficiency further. Some of th e topics that were high lighted in this regard 
were the energy efficiency of buildings and pa rticularly energy efficiency of the existing 
building stocks. Another topic ofte n referred to as significant was financing but also to create 
the awareness of the exis ting opportunities of access to finan ce for energy efficiency projects. 
Several stakeholders pointed to  the fact that the Structural  and Cohesion funds should be 
further used to promote energy efficiency in the different Member States. In this regard it was 
suggested that the new Energy Efficiency Action Plan should recognise the role of the local 
politicians in the delivery of energy efficien cy in Europe. The Covenant of Mayors was 
mentioned to be a successful policy instrument to  bring energy efficiency policy to local level 
and to "think globally but act locally". 
 A lot of the stakeholders were of the opinion that cogeneration and district he ating planning 
had to be further promoted. Th e existing legislation had not gi ven the correct incentives to 
develop these policy ar eas satisfactorily.  
 Energy efficiency was also argued to be a gl obal issue and not onl y a policy for Europe. 
Several countries like United States and Ja pan had already launched several efficiency 
programmes. It is therefore crucial that Europe  from a competitiveness aspect does not miss 
opportunities in the timing of devel oping an energy efficient economy.  
 It was also emphasised among several stakeholders  that the different legal instruments should 
not overlap or be conflicting. The Commission should endeavour to synchronise the different 
frameworks on energy efficiency for optimal eff ect on the market with due regard to avoiding 
any distortion of the internal market.  
4. S
PECIFIC QUESTIONS  
4.1. Introduction 
 
Following the general question, th e public consultation also put  forward several specific 
questions. The specific questions consisted of a questionnaire in English with structured 
questions, supplemented by open "free text" que stions where participants could provide 
feedback not captured in the structured part. This report will provide the statistical data 
regarding the structured questions. For the open "free text" questions the submissions will be 
generally described with certain direct refe rences to some of the suggestions in the 
submissions.    
 
EN 11   EN 4.2. The promotion of energy efficient buildings  
 
The questionnaire contained a question regardin g whether more could be done on buildings 
besides the existing Energy Performance of Bu ildings Directive (2002/91/EC).  Out of the 
203 contributions, 154 (75.9 %) submissions were of  the opinion that more could be done in 
order to further promote energy efficiency in buildings. 24 (11.8 %) of the submissions stated 
that they were not in favour of additional measures and 25 (1 2.3 %) of the contributions did 
not have any opinion in this regard. Concerning  energy efficiency in buildings there were 3 
open "free text" questions. The first question wa s how to assess the need to move towards a 
requirement that all new buildings have low or zero energy consumption and carbon 
emissions after a certain date. The second questio n was addressing the need for introducing at 
EU level measures concerning training of ar chitects, builders and installers. The third 
question related to which other measures at EU level need to be undertaken.   
 Concerning the first question ther e was a majority in favour of developing buildings of low or 
zero energy consumption and carbon emissions afte r a certain date. Furthermore, the majority 
were of the opinion that the main challenge wa s to promote energy efficiency in existing 
buildings.  A holistic approach wa s argued to be the best way to  proceed with due regard to 
district heating and renewable en ergy. There were also different  views on how to define low 
or zero energy consumption and carbon emissions buildings. Some stakeholders argued that 
the CO2 aspect was the key issue, while others were proponents of only relating the 
definitions to primary energy consumption. Some stakeholders also referred to the different 
climate between the Northern and Southern part  of Europe which should also be accounted 
for when deciding on the devel opment of buildings of low or  zero energy consumption and 
carbon emissions.  Furthermore, there were divergent statements regarding setting the date for implementation of such a policy. There were also  voices for taking due re gard to and preserve 
the cultural heritage contained in some  of the existing build ings of Europe.  
 
Examples of stakeholder feedback on that  all new buildings will have low or zero 
energy consumption and carbon emissions after a certain date: 
 
• "The setting of such requirement is im portant for the launch of construction and 
reconstruction of buildings in the best availa ble standards in the short and medium term. 
Facing the need to tackle the climate change  and the rising energy prices, the savings 
potential in buildings ought to  be exploited". (A Ministry of Environment in one of the 
Member State of EU) 
• "In steps of about three years the standard s hould be developed: for example in Germany: 
EnEV 2009, EnEV 2012, EnEV 2015 (passi ve house standard), EnEV 2018 zero 
emission standard". (Organ isation for architects) 
• "Each year, new buildings represent about 1% of the buildings stock. This very small 
percentage should feature the latest technologies in term s of energy efficiency and 
renewable energies to ensure that new buildings make the EU less dependent on 
imported, expensive and scarce energy. Indee d, Plus-Energy Buildings and Net Zero 
Energy buildings are crucial for security of  supply reasons. Decisions taken now will 
have a crucial impact on the future landscape of the European building stock….  Existing 
buildings should not fall out of the scope of the EU scrutiny: the refurbishment rate of 
existing buildings is very low in the European  Union and furthermore, Europe has a large 
stock of historic buildings which are far away from being energy efficient. If the 
European Union takes the threat of climate ch ange seriously, it needs to address existing 
buildings. The recast of the Energy Performa nce of Buildings’ Dire ctive should provide 
 
EN 12   EN the first opportunity to set targets for existing buildings to become net zero energy 
buildings by 2018". (Organisation for promoting renewable energy) 
 
Concerning the second question, the majority we lcomed the idea of introducing measures 
concerning training of architects, builders and in stallers. However, several stakeholders were 
of the opinion that this was best  pursued by the Member States due  to the different structures 
of the sector across EU, and the range of inst itutions, professional bodies and educational 
bodies involved in the training in  the different Member States. Nevertheless, the stakeholders 
expressed that EU had a role to  play for facilitati ng action on training through for instance EU 
programmes such as the Intelligent Energy Eur ope. The EU could also assist concerning the 
exchange of best practises, but also facilita te for the mutual recognition of qualifications 
between Member States.  Some stakeholders ma de reference to Annex IV of the Directive 
2009/28/EC on the promotion of the use of energy from renewable sources and that a similar 
annex could be adopted for the Energy Perfor mance Directive on Build ings (2002/91/EC). 
Reference was also made to the American sy stem where architects must maintain their 
certification by earning a number of credit point s from mandatory courses. Such courses can 
be arranged by the government, institutional a nd private actors under th e approval of an 
authority.  
Examples of stakeholder responses on intr oducing at EU level measures concerning 
training of architects, builders and installers : 
• "While training activities are a largely national competence, the Commission does 
have a leadership role to play in spr eading best practice a nd providing finance to 
stimulate such activities. The EU should ensure mutual recognition of training 
programmes across Europe as well as ha rmonised accreditation of inspectors and 
assessors. European funds could also be used  to finance training activities at national 
level". (Industry organisation fo r energy efficiency services) 
• "The operatives on construction sites who actua lly install energy efficiency materials, 
products and components must be fully aware of the need for those items to be installed to a high level of workmanship and with a high  level of care. Bringing 
assistance to relevant institutions and associ ations that can quickly fill the training and 
education gaps is one tool that could si gnificantly assist in improving the energy 
efficiency of buildings in the medium term". (Organisation for architects)  
• "Optimal outcomes in the built environmen t will only be possi ble if builders, 
installation companies and architects are pr ovided with all the relevant training and 
information they need to make an optimal  decision about whic h solution is most 
suitable for the building in question. Unless  training is addresse d and offered in a 
timely fashion, it is widely feared that it wi ll be a key barrier". (Association for micro-
generation)  
 
On the third "free text" question on what other m easures at EU level should be adopted for the 
promotion on energy efficiency in buildings, several ideas for further measures were 
suggested. One suggestion that several stakehol ders referred to was the need for further 
promotion of cogeneration, district heating and cooling. It was stated that the existing legal 
instruments did not give the necessary incenti ves for these technologies to achieve their 
potential. Furthermore, smart metering should be rolled out in different Member States in 
order to help consumers to save energy. ICT was also argued by several stakeholders to be an 
important instrument for the promotion of energy  efficiency. It was also  argued that buildings 
 
EN 13   EN when sold should have to reach a certain st andard of energy efficiency. A Smart City 
Campaign for Buildings was also envisaged to be launched by the EU.  
Examples of stakeholder responses on in troducing further measures at EU level : 
• "Possible measures could introduce an oblig ation to upgrade the energy performance 
of a building whenever it is sold or rented  up to a certain standard (for example 
obligation to reach a higher energy class of  the energy performance certificate or to 
renovate according to very lo w energy standards), and an obligation on countries to at 
least double their renovation rates of existing buildings. To make this approach more 
flexible, it could be possible to set differe nt targets for different type of buildings 
(public buildings, commercial buildings, and residential buildings) or for buildings of 
different ages, for example by initially fo cusing only on buildings built after 1945. 
Adequate financing is crucial to ensure th e success of any policy intending to improve 
the energy performance of existing buildi ngs. Financing should not only come from 
national sources through fiscal and/or fina ncial incentives but the use of available 
funds from other sources should be optimi zed (EU structural and cohesion funds, use 
of auctioning revenues under the EU ETS ). In addition, an energy performance 
contracting model needs to be promoted in order to increase refurbishment rates in 
existing buildings". (NGO) 
• "The requirement that all new buildings  and major renovations be equipped with 
intelligent metering systems is rational and necessary. This, however, must be reconciled with the smart metering requi rements in the 3rd Energy Package". 
(Industry) 
• "ICT can play an important role in making buildings more  energy efficient, and its 
role should be recognised as such. Public pr ocurement (for public buildings) is a tool 
that may be used for encouraging i nnovative ICT solutions to reduce energy 
consumption of building". (Industry)  
• "The European Commission could launch an “Energy Smart Building” Campaign. 
This campaign would aim at stimulating the market for energy efficiency and 
renewable energies in buildings and woul d be implemented via national campaigns, 
for instance by national energy agencies and/ or ministries, in strong connection with 
cities. ……… It is estimated that at leas t 150 000 jobs will be ne wly created in the 
Energy Smart Buildings sector in the co ming years, which will become one of 
Europe’s job-motors. The proposed stimulus  would largely benef it SMEs involved in 
the energy efficiency and renewable ener gy sectors". (European Renewable Energy 
Industry Association) 
 
4.3. Transport 
 
The public consultation addresse d also energy efficiency in  transport. 93 (45.8%) of the 
submissions were in favour of additional measures on energy effi ciency at the EU level in the 
transport sector, while 22 (10.8%) were opposed  to further measures. 88 (43.3%) submissions 
did not have any opinion in this regard.   Most of the stakeholders in favour of add itional measures on energy efficiency in the 
transport sector welcomed the electrification of the transport sector for cars, buses, rail, motor 
cycles, scooters and mopeds. It was argued that the current Emission Trading Scheme is penalising the rail sector. Even though the aviation will  be included, stakeholders argued that 
 
EN 14   EN only 15% of the allowances in this regard will be  auctioned and the rest will be transferred to 
the aviation sector free of charge. As railw ays are affected by ETS , the other modes of 
transport that have higher emissions were argued to receive a competitive benefit. Another concern raised in the public consultation rega rding transport was a request for a more robust 
regulation on CO2 emission for vans. There were  also proponents who ar gued that legislation 
should not only be concerned with the concrete CO2 emissions, but also the efficiency of the 
car as such. A reference of importance in this regard was the weight of  vehicles. Eco-driving 
was another measure suggested to be launched at the EU level. The use of a bicycle, but also 
the city planning of faci litating increased number of cyclists, wa s also stated to be an efficient 
measure to reduce significantly CO2 emissions.   
Examples of stakeholder respo nses relating to transport: 
• "The current technology-based approach to reduce CO2 emissions from cars needs to be 
supplemented with infrastructure  and driver behaviour related measures, as is the case in 
other sectors. In this respect, eco-driving is a no-regret measure that can be implemented 
rather easily, leads to solid results rather quickly and can contribut e to fighting climate 
change". (NGO) 
• "The transportation sector plays a central role in the European economy and accounts for 
almost 20% of the total Europ ean consumption of primary ener gy. 98% of the energy that is 
used in this sector is fossil fuel. It is theref ore important that the energy consumption in the 
transportation sector is made efficient and th at new fuel sources are developed for this 
sector. The Electrification of th e transportation sector, includi ng promotion of electric cars, 
is an important element with regards to making the energy consumption in the 
transportation sector more e fficient". (Energy utility) 
• "The EU should provide different  options to encour age technical develo pment of hybrid and 
electrical cars, e.g. funding research and de monstration projects, contributing fiscal 
measures such as tax incentives, heightening of public awareness to environmental issues. 
Other measures would include mandatory targ ets, removal of administrative and planning 
barriers and sharing best practi ces on the promotion of clean ve hicles and intermodal shifts. 
Local authorities should be fully involved and engaged in making it attr active to utilize an 
electric car, free of charge batt eries stands, less taxes, free park ing spaces in the cities, etc. 
The EU should consider whether transport and the efficiency hereof should be regulated on equal terms as any other energy consumption an d become part of the Directive for Energy 
end-use Efficiency and Energy Services". (Associ ation of electricity industry in Europe)  
 
4.4. Product policy 
 
Stakeholders were also asked whether they were  in favour of further measures in order to 
increase the impact of the Eco-design Dir ective (2005/32/EC) and Energy Labelling Directive 
(92/75/EEC). 110 (54.2%) of the submissions were  in favour of further measures, 45 (22.2%) 
of the contributions were against additional measures, while 48 (23.6%) had no opinion in this regard.   The majority of the stakeholders expressed satisfaction with both th e Eco-design Directive 
(2005/32/EC) and Energy Labelling Directive (92/75/EEC). However, there was some 
concern raised regarding these two Directives. Several stakeholders argued that it was of 
significant importance that the la bels for consumers were clear  and not confusing. There had 
 
EN 15   EN been to many labels and marks discussed in recent times. Moreover, there were some 
resistance for including further product groups in the near future because of the argument that 
there is still a lack of expe rience of the adopted implementi ng measures of the Eco-design 
Directive (2005/32/EC). However, others were of the opinion that the Eco-design Directive 
(2005/32/EC) should set stricter requirements and a faster implementation. It was also 
necessary to enhance the market  surveillance in this regard since it was argued that this 
function was not adequa tely performed by some Member States. Moreover, there were 
divergent views on voluntary agreements. Some s ubmissions stated they were in favour while 
others argued that voluntary ag reements were inefficient.  
 It was also argued that the extended scope of the Eco-design Dir ective (2005/32/EC) and 
Energy Labelling Directive (92/75/EEC) should not  cover certain construction products. This 
should rather be included in the Energy Perfor mance of Buildings Di rective (2002/91/EC). 
The reason for this was stated to be that the performance of construc tion products can only be 
assessed at the level of the functional unit, whic h is the building. Neither of the two directives 
provides a methodology as to how this could be  achieved. The absence of such a methodology 
may distort competition, confuse markets and ha ve a negative effect on market transparency. 
Even worse, the indicators would not provide  a methodology to identify the most sustainable 
solution for a building over  its whole life cycle. 
 Several stakeholders expressed that  it was of importance that the different legal instruments in 
place should not overlap or be conflicting but  taken due account to when deciding on which 
legal instrument would be the most adequate to promote the energy efficiency aim in 
question.   
Examples of stakeholder responses relating Eco-design Directive (2005/32/EC) and 
Energy Labelling Directive (92/75/EEC): 
• "The energy and environmental performance of  construction products can only be assessed 
at the level of the functional unit, which is the building. Neither of the two directives 
provides a methodology as to how this coul d be achieved. The absence of such a 
methodology may distort competition, confuse markets and have a negative effect on 
market transparency. Even worse, the i ndicators would not pr ovide a methodology to 
identify the most sustainable solution for a building over its whole life cycle. All 
requirements regarding buildings and buildin g components should be addressed in the 
EPBD". (Association for insulation in  buildings and renewable energy) 
• "The impact of Eco-design directive could certainly be increase d by setting stricter 
requirements and a faster implementation. In ad dition, two crucial elements should also be 
reinforced: market surveillance  and a better coordina tion with existing legislation covering 
the same products (i.e. RoHS, WEEE and EPBD).  In order to safeguard competitiveness 
among manufacturers and ensure European consum ers’ rights, it is imperative that products 
subject to Eco-design requirement s are properly verified before entering the EU market. At 
present, market surveillance, organised at Member State level, is not performing this 
function adequately; ther efore, a more coordinated appro ach across Europe is necessary. 
Ensuring a better integration of  existing EU product-related re gulation is another essential 
issue when developing eco-design require ments. Although avoiding duplications is 
important, making sure that no gaps or grey ar eas are overlooked is even more critical. For 
this reason where technically possible Eco-design measures for specific products should set 
more ambitious requirements than allowed und er another regulation (i.e. lower mercury 
 
EN 16   EN levels than those allowed under RoHS could be applied for domestic lighting). When facing 
overlaps with existing legislation, implementi ng measures should be thoroughly designed to 
avoid gaps and ensure that th e combined potential of the relevant regulations is fully 
exploited. For example Eco-design measures on heating and cooling equipment should be 
fully coordinated and integrated with the re spective provisions in the Energy Performance 
of Buildings Directive, in part icular those dealing with building components and systems. A 
bold approach on heating equipment could help save more than 200 million tons of CO2 in 
the EU-27 by 2020, one of the larges t savings achievable". (NGO) 
 
4.5. Financing   
 
The public consultation also addressed the lack of access to appropriate financing which is an 
important bottleneck for further promoting ener gy efficiency. Various financing instruments 
are at present time being devel oped by different institutions such  as the European Investment 
Bank (EIB), the European Bank for Recons truction and Development (EBRD), national 
promotional banks and private banks in partic ular in association with the Covenant of 
Mayors. Demonstration projects of the applic ation of energy efficient technologies in a 
competitive manner, for example "smart cities" could also be considered. The question was therefore raised in the public consultation whet her stakeholders thought that other financing 
measures at EU level are needed.  135 (66.5%) of the stakeholders answered confirmatively, 18 (8.9%) responded negatively 
and 18 (24.6%) stakeholders had not any opini on in this regard. Several stakeholders 
expressed that Structur al Funds should be reformed with a strong focus on energy efficiency 
projects.  At the same time it was argued that th e EU should facilitate that the current funding 
opportunities under the Structural and Cohesion Funds were properly spent by encouraging 
Managing authorities to develop and promote energy efficiency pr ojects in their regions.  
 It was also stated by several stakeholders that  there were numerous funding opportunities in 
place, but that these funding possibilities se emed confusing and difficult to access which 
discouraged participation. The Commission was th erefore encouraged to facilitate a one-stop-
shop procedure to remove these barriers to funding. It was also sugge sted that many small 
scale investments should be linked together an d thereby apply for financing. Consequently, 
there would not only be access to fi nance for the large energy efficiency projects but also for 
smaller energy efficiency schemes.   Up-front financing was also highlighted to  be of significant importance by several 
stakeholders. It was suggested that the EIB s hould lend money to specia lised national energy 
efficiency funds which would pr ovide up-front financing solutions  to ESCOs and in particular 
SMEs. Alternatively, th ese funds could provide loan guarantees to faci litate lending from 
private banks.   Several stakeholders also made reference to  the importance of us ing energy performance 
contracts (EPCs). The experience of KfW in fi nancing EPC was referred to as a successful 
funding mechanism in this regard. However, ap art from raising the awareness in the public 
and private sector of EPC it was also pointed to the need of addressing accounting and 
budgeting rules. Accounting and budgeting rules in several Member States were stated to 
prevent or discourage EPCs.   
 
EN 17   EN Some stakeholders also stated that there was a particularly need for enhanced investments in 
CHP and district heating. Furthermore, invest ment in smart grids and smart metering were 
also emphasised.   There were also statements suggesting that the Member States should be strongly encouraged 
to use the auctioning revenues from ETS for energy efficiency projects. 
 It was also emphasised that due regard should be taken to fuel poverty. Finance for energy 
savings should not place a burden on consumers who already are facing the highest level of 
billing to their homes.  It was further suggested that not only "smart cities" projects should be launched but also 
"smart industries" should be developed.
 There is increasing interest in the potential of having 
industries, including power stati ons, working in co-ordination to  provide connected heat loads 
and use high efficiency cogeneration. Smart indus try zones could be created encouraging the 
linking of industries together and maximizing the e fficiency of electricity and heat delivery to 
the group, combined with distri bution of heat to th e local community a nd the commercial or 
agricultural zones. 
  
Examples of stakeholder respo nses relating to financing: 
• "The continued reinforcement of  the use of the European Cohe sion policy as a key tool in 
the leverage and promotion of investment ai med at reducing the environmental impact of 
the residential sector….. The revenues of the EU Emissions Trading Scheme should be used 
to promote energy efficiency and rene wable energy in existing housing stock". 
(Organisation for social housing)  
• "Tackling head-on the cost barriers which inhi bit energy efficiency actions will bring about 
dramatic progress. Lower interest loans, with long pay back periods, and “pay as you save” 
schemes from the EIB in conjunction with national banks will help incentivise business and consumers to install energy efficiency measures. This model is being trialled on public buildings through the C40 large ci ties climate leadership gro up (with a major project being 
undertaken in London). Measures to guarantee en ergy savings as a basis for loan pay back 
helps tackle the barriers  of upfront costs. SMEs  in particular should be targeted with low 
interest loans as they often require extra suppo rt in the short term to  overcome difficulties in 
accessing credit". (Industry organisation). 
• "One of the main barriers is the current frame of mind of average investor s in building 
energy efficiency measures. Indeed, large institutional investors are very much focused on large projects for which the a ssociated risks over the lifeti me of the project are easily 
identified/quantified. However, the energy revolu tion that is needed involves a plethora of 
small/medium projects to be promoted by a large number of actors or their agents (e.g. energy services companies). Thus  large budgets (that can  be equivalent to  that of a single 
large project) need to be committed towards a pool  of smaller projects so that it can finance 
smaller operation efficiently. Experience shows that investors are currently shying away 
from it. A limited number of financial products, including from the EIB,  are targeting this 
kind of operations but do not seem to be known enough by the market. The EU can play a role to promote and encourage the use of such financing products adapted to small projects". 
(Industrial organisation for  energy se rvices in the re sidential sector) 
• "The financing measure at EU level is corr ect and appropriate. The problem is the access 
to these financing instruments at country leve l. For small enterprise s it is not easy knowing 
 
EN 18   EN the rules of access and it is not always clear  who to contact". (ESCO operating in the 
lightning sector) 
• "Apart from raising the awareness in the pub lic and private sector of energy performance 
contracting (EPC), is to address accoun ting and budgeting rules that can prevent or 
discourage EPCs. Ideally, an ESCO contract sh ould be over multiple years (e.g. 10 years or 
more) with no upfront investme nt costs and aimed at the ex isting building stock where the 
biggest energy saving potential s are located. Operators in public sector (ministries, 
hospitals, schools, universities etc) need to r eceive assurances that they will retain the 
financial benefits of reduced energy costs and not just see their effort s translated into budget 
reductions; they also need to be able to engage  in long-term contracts.  Both these critical 
factors are often impossible to  realise due to budgetary a nd accounting rules; and Member 
States need to remove such administrative barriers so there is a real incentive for public sector operators to engage in  long-term partnerships with ESCOs". (Chamber of Commerce)
4.6. Fiscal incentives 
 
The stakeholders were also asked whether they were in favour of additional measures at the EU level for fiscal incentives. 147 (72.4%) of  the stakeholders responded confirmatively, 16 
(7.9%) of the submission answered negativel y, while 40 (19.7%) had no opinion in this 
regard.  
 The majority welcomed fiscal incentives for the promotion of energy efficiency. Several 
stakeholders from the industry expressed that the main problem of developing and promoting 
energy efficiency services was not the supply of  energy services but the lack of demand. In 
their view fiscal incentives could help to cr eate further demand of energy efficient products 
and energy efficiency services. One example men tioned in this regard was to examine income 
tax rebates for energy-saving measures for c onsumers which have been employed in the 
United States with some success.    Regarding VAT, some stakeholders  expressed that VAT reductions  should not be applied to 
all products and services. It was pointed ou t that reduced VAT rates should not to be 
permitted for certain energy construction saving products, such as insulation. The effectiveness of energy efficiency measures was stated not to be the su m of the products used, 
but how they were incorporat ed. Otherwise, it would enc ourage undeclared labour and 
increases the risk of bad workmanship which would be counter-produ ctive to the goal of 
increased energy efficiency.  Some stakeholders regretted th e recent withdrawal of the Co mmission's legislative plans on 
reduced rates of VAT for energy and environm ental policy purposes. Preferential rates on 
materials which enable savings on energy dema nd in buildings would have contributed to 
lowering the prices of low energy buildings and making them more attractive. Even though 
some of the stakeholders stated that they unde rstood that the issue of reduced VAT rates could 
be politically difficult at this point in time, they invited the Commission to encourage Member 
States to make use of other fiscal tools such as progressive property ta x in relation with a 
building’s energy certificate. Differentiated tax le vels would be instrument al in inciting future 
owners to opt for the most energy efficien t buildings. Another sugge stion instead of re- 
proposing VAT reductions at EU level, was the proposal that the EU should provide a 
framework of available options th at could be compatible with st ate aid rules as well as sharing 
of best practise between Member States.   
 
EN 19   EN Several stakeholders were also of the opinion that an efficient and timely roll out of smart grid 
and smart metering required fiscal incentives  to be adequately and timely developed.  
 A reference was also made to the landlord/ten ant dilemma regarding investment in buildings. 
A tenant is not interested to invest in energy efficiency in a building that is not owned by the 
tenant. Furthermore, a landlord has not so much interest to invest in energy efficiency since 
the landlord is usually not pa ying the bill of the energy cons umption. Financial incentives 
could trigger landlords to make investments in energy efficiency. Such measures could 
include tax-breaks on the refurbishment of houses  or revolving funds for the same purpose.  
  
Examples of stakeholder responses  relating to fiscal incentives: 
• "Landlord/tenant dilemma: in several EU countries over 50% of buildings are rented, and 
neither the tenants (as they do not own the hous es) nor the landlords (a s they do not pay the 
energy bills) have incentives to invest in such  measures as insulati on. Financial incentives 
should oblige landlords to make the right inve stments. Such measures could include tax-
breaks on the refurbishment of houses or revolving funds for the same purpose. The 
European Economic Recovery plan suggests ur gent tax measures to improve the energy 
efficiency of the housing stock and public buildings. Taxation ought to be one of the 
instruments that governments should apply to  promote energy efficiency investments". 
(Industry association for energy efficiency services)  
• "VAT reductions for energy-efficient products ar e not recommended. They bear the risk of 
high free-rider effects. Targeted financial in centives for the purchase of such products are 
better in this respect, since they are not given automatically and more easily adapted to the required level. On the other hand, targeted incen tives for investments in energy efficiency in 
buildings or production faciliti es can be given through fi scal incentives . A number of 
Member States have made good experiences w ith enhanced capital allowances or with 
rebates on energy taxes (often coupled to volunt ary agreements with industry). A Concerted 
Action is advisable to exchange experi ences and to devel op common conclusions. 
Following this, an EU Directive could require Me mber States to provide a certain level of 
funding through such fiscal incen tives, leaving them freedom on the concrete way how to 
do it". (University, institute) 
• "High up-front costs are often a psychological obstacle. Fiscal policies should therefore 
continue to be developed and c oordinated at the EU level. Such  policies could take the form 
of ecological tax reform, such as tax differe ntiation (e.g. reduced VAT for the most energy 
efficient products and services), enhanced us e of fiscal incentive s (e.g. tax rebates for 
consumers buying products labelled as the mo st energy efficient goods or if consumers 
insulate their homes) or more easily accessible financing schemes and subsidies for energy 
efficiency investments of priv ate households. This will make  consumer uptake of such 
products increase and ensure a leve l playing field in Europe. In th is context, we particularly 
call on the Commission to cons ider re-introducing the plan for an EU proposal to reduce 
minimum VAT rates for green products and services, which was recently dropped due to the current financial crisis"
. (Consumer organisation) 
4.7. Education and Training 
 
The public consultation also addr essed the vital need for furt her education and training in 
energy efficiency. The stakeholders were ther efore asked whether they wanted EU level 
actions to catalyse training at schools and universities. 
 
EN 20   EN  
145 (71.4%) of the stakeholders answered confirmatively, 11 (5.4%) responded negatively 
and 47 (23.2%) stakeholders had not any opinion in this regard.  
 It was stated by the majority in favour of additio nal measures that it was essential that energy 
efficiency becomes part of education and trai ning. It was further emphasised that the best 
long-term results are achieved when education starts early. In higher education the classes 
were suggested to become more practical.   
Examples of stakeholder responses relating to education and training: 
• "Schools and universities are pla ces where people are educated on a variety of topics that 
will benefit them for the remainder of there live. As such schools and universities are an 
excellent place for education and training on ener gy efficiency. It is especially important 
that the training will be continued during severa l years of the education so it can be ensured 
that energy efficient behaviour gets lock ed into people’s no rmal behaviour. To 
systematically include the topic of energy effici ency in education will surely help to meet 
the European Union’s long-term challenge of arriving at a energy-effi cient and low-carbon 
economy". (ICT company) 
• "An EU wide spread of best practice examples and case-studies to be used in further 
education courses and as part of the university courses. Th e business sector should be 
actively integrated in the development of such training elements. This could be done for 
example by introducing regular visits of energy advisors to schools". (Chamber of 
Commerce) 
• "There should also be opport unities not only for students but  professionals". (Industrial 
organisation for energy efficiency services  in the tertiary a nd industry sectors) 
 
 
4.8. Awareness of consumers and SMEs 
 
The stakeholders were also asked whether they were in favour of additional measures at the EU level for raising awareness on energy saving opportunities, particularly for consumers and 
SMEs. 141 (69.5%) of the stakeholders re sponded confirmatively, 24 (11.8%) of the 
submission answered negatively, while 38 ( 18.7%) had no opinion in this regard.  
 The majority of stakeholders in favour of add itional measures for awareness raising on how to 
save energy, welcomed information campaigns  but not at EU leve l. Communication was 
argued to be needed given at loca l level and close to the citizens .  There were several practical 
examples suggested such as the organisation of information days in citie s and regions. It was 
also suggested that local Energy Agencies or Chambers of Commerce c ould play a key role 
on awareness raising as they are close to c onsumers and SMEs. The Covenant of Mayors was 
also mentioned to be a good structure to be used for information campaigns.   Concerning consumers and SMEs and their energy bills, ICT solutions were suggested to be 
efficient. The consumers should be able to access a website or digital indicator to be aware at 
any time of their energy consumption allowing  them to take conscious decisions on energy 
saving. It was also suggested in this regard that the mere in formation was not sufficient for 
 
EN 21   EN significant energy saving, the information needed  to be accompanied by advice how to save 
energy.  
Examples of stakeholder responses relating to  awareness of energy saving for consumers 
and SMEs: 
• "Our answer is actually a no for EU-level Ca mpaigns: Communication need s to be closer to 
the citizens. Therefore, any EU  legislation and regulation should include requirements to the 
Member States to ensure co mmunication (including at lower government levels) that makes 
citizens and market actors aware of the benefits of the legisl ation and regulation and how to 
apply it. The contents of that decentralised communica tion could and should be co-
ordinated at EU level. This could be a new task for the EA CI". (University, Institute)  
• "Communication campaigns on energy efficiency and sustainable development are very 
important but are not sufficient.  It asks a strong involvement  from inhabitants to look for 
information and have the “good energy behaviou r”. All the European citizens don’t have the 
capacity and time to be well informed. European Union has to develop a new 
communication strategy based on lo cal level, with a direct di alogue with inhabitants. In 
France, to inform people on wastes mana gement, there is “wastes management 
ambassadors” in each neighbourhood, who are interm ediaries beside inhabitants. European 
Union could promote Energy ambassadors in each  member’s states, it means local actors 
who could inform, train and answer question, di rectly to citizen on energy saving. Covenant 
of Mayors could be a good way to implement it at the first step". (Association for social 
housing) 
• "When it comes to requirements of information about energy efficiency via the energy 
supply companies or the transmission or di stribution operators it is important, that 
information are given in a cost and climate prot ecting way (e.g. via internet if possible, just 
one time by the supplier and not additionally by the grid operator and the meter operator
)". 
(Energy utility) 
• "The easy access to consumpti on patterns, through a website or  a digital indicator in a 
central location, allows consumers and SMEs to  keep a constant eye on their consumption, 
allowing them to make conscious decisions. The indication should be kept in close relation 
to the cost savings made by energy users, as the price of energy has a large impact 
consumers and on a business’s bottom line prof its". (Producer of energy using products) 
 
4.9. SMEs 
 
The public consultation also a ddressed the significant need for further promoting energy 
efficiency for SMEs. The stakeholders were  asked whether they thought that specific 
measures targeted to SMEs are necessary. 121 (59.6%) of the stakeholders answered 
confirmatively, 20 (9.9%) responded negatively  and 62 (30.5%) stakeholders had not any 
opinion in this regard.   Looking at the demand side on energy savings for SMEs, the majority of the stakeholders in 
favour of further measures for promoting en ergy efficiency welcomed awareness raising 
rather than new incentives. Moreover, several st akeholders expressed th at subsidised or free 
energy audits would be an efficient tool to  facilitate real energy savings for SMEs. 
 
 
EN 22   EN Concerning the supply side, micro-credits for SMEs were stated to  be of significant 
importance in order to help ESCOs to be created.  On the decision- making process, some stakehol ders raised the concern that SMEs were not 
adequately involved, particularly with the pr oceedings regarding the Eco-design Directive 
(2005/32/EC) since the cost of sending represen tatives were too high. An on-line system 
aimed at collecting industry data allowing SMEs to take part in the process was suggested to 
facilitate further participa tion by SMEs in this regard. 
 
Examples of stakeholder responses relating to SMEs: 
• "Most traditional banks still see no return in  loans financing energy efficient improvements 
in SMEs and/or they are still not prepared for this. We are talking about micro credits of 
around 20.000 to 30.000 Euros required by SMEs directly or through ESCOs. This hampers improvement in energy efficiency in many SM Es due to their often precarious financial 
situation. The EU and its Member States coul d set up specific measures to change this 
attitude, for instance through awar eness campaigns addressed to the banks. At the same time 
the EU could explore new, alternative financi ng ways to ensure the conditions are laid for 
these micro credits to be pr ovided (for instance through vent ure capital, etc.)." (Industry 
organisation) 
• "SMEs will enter the energy efficiency market  so long as that mark et provides clear and 
profitable commercial opportunitie s. This would be achieved if  all the exis ting policies, 
legislation and financial instru ments in place at EU (and Memb er State) level operated fully 
and effectively. No particular new incentives for SMEs are needed; rather the emphasis 
should be placed on making all existing (a nd proposed) instruments work fully and 
effectively. This should be underpinned by adop ting binding targets fo r energy efficiency, 
which would send a clear signal to SMEs that energy efficiency is a market area worth 
investing in. For example, Energy Performa nce Contracting (EPC) generates jobs by 
employing local labour and local contracting co mpanies which tend to be SMEs. If EPC is 
supported, this will automatically provide fo r SME growth". (Construction Association ) 
• "The current eco-design standard setting proce dure suffers from a lack of SME participation 
in the process. Even though SM Es are generally considered th e source of innovation in the 
engineering sector, their high pe rforming products are not consider ed in the process, as their 
participation in the process is not ensured. Th e cost for an SME to send a representative to 
Ecodesign Consultation Forums is too high, re sulting in standard setting meetings being 
dominated by multinational corporations and broad associations. As associations can only participate based on the lowest common denominat or, their impact is limited. This results in 
a watering down of requirements. An online sy stem aimed at collecti ng industry data would 
allow SMEs to take part in the process at a fraction of the cost, allowing the EU to develop 
meaningful legislation". (Pr oducer of energy using products) 
4.10. Public sector 
 
The public sector should lead by providing th e best example on the promotion of energy 
efficiency. The stakeholders were therefore asked whether actions at  EU level should be 
adopted in order to further make the public sector to promote energy efficiency. 137 (67.5%) 
of the stakeholders responded confirmativ ely, 31 (15.3%) of the submission answered 
negatively, while 31 (15.3%) had no opinion in this regard.  
 
 
EN 23   EN The majority of stakeholders wanting additional  measures for the public sector stated that 
public buildings should be setti ng a leading example and should be  the first buildings to be 
zero net buildings. Moreover, green public procur ement was stated nearly by all stakeholders 
to be of significant importance.  Some of th e stakeholders wanted to make green public 
procurement mandatory.  Some concern was rais ed that green public procurement applied by 
the governments seems to favour larger companies and not SMEs.   
Examples of stakeholder responses relating to public sector: 
• "The public sector can help raise awareness of the benefits of energy e fficiency for business 
and consumers. For example Energy Performan ce Certificates (EPCs) and Display Energy 
certificates (DECs) provide details on the en ergy performance of buildings. The A-G rating 
of EPCs provides important information highlig hting improvements that can be made to the 
fabric of the building to make it more efficien t. By showing how efficiently energy is used 
in a building the DEC rating encourages inve stment in energy efficient equipment and 
promotes behavioural change. A further role out  of DECs from public buildings to all non–
domestic buildings could be a powerful tool in motivating businesses to monitor and manage their energy consumption. The role of  green public procurement is also highly 
significant in the switch to energy ef ficiency". (Industry organisation) 
• "The leading role of the aut horities cannot be underestimate d. Public procurement offers a 
route to increased efficiency of products. Public  authorities should also change their ways of 
working as far as possible towards a low-carb on one, fully utilizing the possibilities that 
ICT and broadband communications (mobile and fixed) can bring". (Company in the ICT 
sector) 
• "The public sector should lead by example and improve the energy efficiency of their 
buildings in the short term, through binding im plementation dates. The public sector should 
also be mandated to implement all recommen dations indicated in the energy performance 
certificate during the lifetime of that certifica te. The public sector in each Member State 
needs to make an overall and systematic plan to renovate the public sector building stock. If 
resources are pooled to renovate multiple buildi ngs at the same time, a higher cost-savings 
can be achieved. Scaling up in this way will not only bring the best economies of scale, but 
also of knowledge and best practice. The Natio nal Energy Efficiency Action Plans could be 
used as the tool to outline these plans. A ch ange in attitude is needed regarding public 
procurement practices for energy efficiency. It is about buying en ergy saving, not products 
or services. Public authorities need help in  changing mindsets to this way of thinking. The 
green public procurement policy advocated by th e EC can help Europe to move towards a 
more sustainable building stock. The EC needs to make sure that this policy is based on 
objective, scientific and well acce pted criteria. Financing shoul d also be available to the 
Public sector to allow implementation of th ese ambitious plans". (I ndustry association in 
energy efficiency services)  
 
4.11. Energy utilities 
 
The stakeholders were also as ked whether they thought that sp ecific measures targeted to 
energy utilities were required.  111 (54.7%) of the stakeholders answered confirmatively, 34 
(16.7%) responded negatively and 58 (28.6%) stakehol ders had not any opinion in this regard.  
 
 
EN 24   EN The majority of the stakeholders in favour of further measures for the energy utilities wanted 
stricter requirement on energy utilities to inve st and provide energy efficiency services. 
However, there were some stakeholders who favoured that the requirements should be of 
voluntary character, while others  were of the opinion that th e further obligations should be 
legally binding. On which segment the requirements  should be set, some  of the stakeholders 
expressed the distribution companies were the best segment since they are closest to the 
consumers.   There were also arguments that when energy uti lities were investing in energy services they 
should be able to pass the co st on to the end-consumers. This could also be done in 
coordination with the national regulatory auth orities by passing-through costs in the network 
rates or supply prices.    Energy utilities were also encouraged by certain  stakeholders to invest in Best Available 
Technique (BAT) in their own in stallations. Moreover, it was suggested that in the licence 
process for new plants, energy utilities shou ld demonstrate to the national regulatory 
authorities that their plants are of the most cost-effective option. 
 
Some of the stakeholders made reference to  the new codes to be developed by the Third 
Liberalisation Package. It was proposed in this  regard that the code on energy efficiency 
should be ambitiously set for concrete energy savings.   
Examples of stakeholder responses relating to energy utilities: 
• "There is a burning need to change the regulat ory framework in order for the energy utilities 
to play a much bigger role in the energy efficiency and to offer energy performance 
contracting. It is necessary to provide the en ergy utilities with an incentive to invest in 
energy efficiency – for example a possibili ty to make profit th rough energy savings. 
Moreover, it is necessary to further prom ote a fair and open market with energy"
. (Ministry 
of environment in one of the Member States of the EU) 
• "In particular Article 6 of the Energy End-us e and Energy Services Directive needs to be 
fully enforced, and then strengthened. Also it should be made a requirement for all energy 
companies, before any new generation plant is built, to demonstrate publicly to the regulator 
(or government) that a new plant would be a more cost-effective option than helping 
consumers to save energy. This is standard pr actice already in many US  States". (Industry 
association in energy efficiency services) 
• "The incentives for energy companies to pu rsue end-use energy e fficiency depend on the 
framework conditions. Articles 6 (2) and 10 of the EU Directive on energy end-use 
efficiency and energy services (ESDir) enable  Member States to create such a framework. 
However, they are not yet specific and c oncrete enough. Three components need to be 
regulated to remove disincentives and create  positive incentives for energy companies to 
pursue end-use energy efficiency, under the c ondition that the cost-effectiveness of the 
programmes for participating energy consumers and society can be made plausible: (1) 
There must be the possibility to recover prog ramme costs. If networ k operators or energy 
suppliers with regulated supply prices (as, e.g., still  in France) implement the programmes, 
the regulators must explicitly allow pass-through of programme co sts in the network rates or 
supply prices. Article 10 of the ESDir should be recast in order to requ ire national regulators 
to allow this. If unregulated suppliers are to implement programmes, giving all comparable suppliers the same level of obligations to save  energy will also enable them to pass on the 
 
EN 25   EN costs in their supply prices. (2) In the energy network business, regulators must take care 
that the level of net profits of the network company is not compromised if they or anybody 
else save energy at the final energy consumers connected to the network. Article 10 of the 
ESDir should be recast in  order to require national regulator s to allow this". (University, 
Institute) 
• "New market models in liber alized markets, combined with unbundling measures, can lead 
to confusion on roles and responsibilities of th e different market players : DSO – which is 
the only player with a neutra l and long term relationship with  the energy consumer - should 
(continue to) play a central ro le in energy saving actions and contribute to the (further) 
development of energy services. - consid er the specific requirements (high-level 
bureaucratic und regulatory complexity) to lo cal energy companies in the EU member 
states. To integrate suppliers successfully in  energy efficiency programs, specific and new 
incentives will have to be developed. A central  role for the DSO - with his neutral and long 
term relationship with the energy consumer – is most logic in the field of energy efficiency. 
The possible conflict between th e regulator that strives for maximum cost cutting, and the 
DSO that is ambitiously stimulating energy e fficiency actions must be avoided and should 
explicitly be addressed. EU-level measures should be restricted to  a general framework, 
leaving the practical elaboration to the Member States. In general it s hould be avoided that 
existing successful measures (possibly in conf lict with a new EU-lev el general framework) 
are being stopped". (Ener gy utility organisation) 
• "The role of energy utilities has been fundame ntal until now to deve lop energy efficiency 
services in some countries; probably their ro le might evolve towards a cooperation with 
Regulators to promote structural investments in energy efficiency. Energy utilities could 
contribute not as “obliged subj ect” but as “intermediate” betw een the State and the obliged 
subject. In this scheme energy utilities might commit themselves on the results with the possibility to share benefits of energy savings  and therefore maybe r eady to share or support 
costs when the client cannot afford or does not  want to divert inve stments from its core 
business. This would have the effect to pr oduce results for the State in terms of energy 
savings and CO2 reductions, and would at th e meantime launch projects resulting in a 
stimulus for the competitiveness of th e industrial system." (Energy utility) 
 
  
4.12. Incentives for SMEs to enter th e energy efficiency market  
 
Energy efficiency offers signifi cant market opportunities. The stakeholders were therefore 
asked whether actions at EU level should be adop ted in order to further provide incentives for 
companies to enter these markets and partic ularly SMEs. 86 (42.4%) of the stakeholders 
responded confirmatively, 56 (27.6 %) of the submissi on answered negatively, while 61 (30%) 
had no opinion in this regard.   The stakeholders responding confirmatively to this  question stated in general that the creation 
of ESCOs was important in this regard. It wa s also mentioned that United States and Japan 
had already launched several effi ciency programmes. It was ther efore argued that it is crucial 
that Europe from a competitiveness aspect does not miss opportunities in the timing of 
developing an energy efficient economy.  
4.13. White certification scheme 
 
 
EN 26   EN The public consultation also addr essed the question whether an EU wide White Certification 
scheme should be introduced. 60 (29.6%) of th e stakeholders answered confirmatively, 65 
(32%) responded negatively and 78 (38.4%) stakehol ders had not any opinion in this regard.  
 On this issue there was rather diverging opinions. Furthermore, there were several 
stakeholders who had answered yes to the ques tion, but qualified the an swer by stating that 
they would only welcome white certificate scheme s to be introduced at the national level. The 
majority of stakeholders were not in favour of the introduction of a unified EU wide White 
Certificate Market. The reasons given were am ongst others that it could distort the already 
existing schemes introduced in some of the Me mber States, and it could overlap with other 
instruments such as ETS and green certificates . However, there were several proponents for 
national white certificate scheme s to be introduced under the condition that these schemes 
should be market driven and car efully designed in order not to overlap with other schemes 
and create further administrative burden for th e Member States. Some stakeholders suggested 
that white certificates should be targeted towa rds energy utilities in or der to encourage energy 
efficiency services to be provided.  
Examples of stakeholder responses re garding White Certification Scheme: 
• "We have some reservations about the intr oduction of an EU wide white certificate 
scheme. Whilst the CERT in the UK, and pr eviously the EEC, is helping to improve 
energy efficiency (and can help drive energy effici ency skills at a local level) an EU wide 
scheme could be cumbersome, unwieldy, ove rlap with other schemes (national and 
European) and not be appropriate to the need s of individual member states. If such a 
scheme was set up at EU level, given the di fferences in market liberalisation in the 
member states, a white certificate could enha nce the market position of incumbents and 
hinder access for SMEs". (Chamber of Commerce) 
• "Article 6 of the ESD alrea dy requires Member States to place obligations on their 
utilities, including the po ssibility of White Certification sc hemes. It should be possible to 
facilitate even further at EU level the cont inued use of such White  Certification schemes 
where utilities are involved, by the use of a nd, if necessary, the strengthening, of Article 
6(2) in the ESD, placing additional obligations on utilities. Creating an EU-wide or regional trading system may, however, prove difficult at this stage where different 
national schemes already exist, and where an EU –wide might generate too much 
administrative burden and render the na tional systems less effective". (Industry 
organisation) 
• "White certificate schemes can be, and are already, an effective policy measure for 
promoting implementation of energy efficiency  improvement measures. This is reflected 
in the fact that a number of  countries have already adop ted such schemes or similar 
supplier obligations and more are actively doing  so in the context of implementation of 
the Energy Services Directive. We believe therefore that a proposal for an EU-wide 
scheme is neither necessary or timely as it has the potential to both cast uncertainty over, 
compromise, or actively conflict with the operation of existing successful national 
schemes. The current Energy Services Directive Concerted Action provides an 
opportunity for Member States to learn form each other's national schemes". (Ministry of 
a Member State) 
 
• "In general terms we support measures that give appropriate and cost-reflective price 
signals that improve energy efficiency an d we often believe that market based 
mechanisms constitute the most economical approach compatible with a liberalised 
 
EN 27   EN market. However, this implies a liquid, well  designed, transparent and harmonised market, 
particularly concerning the methodology for calculation, reporting and verification. In 
addition, a homogeneous product to  be traded. This is not th e case for energy efficiency. 
On the question of a European white certificat e scheme, we believe that existing national 
experiences should be analyzed and compared before any extension. The same applies for 
the impacts of white certificate schemes to common European energy markets, energy end 
prices and the EU emissions trading scheme. Today, few Member States have opted for a 
white certificate scheme and their schemes are not compatible (i.e. white certificates are 
not tradable across their borders ). Moreover, such schemes have yet failed to demonstrate 
their effectiveness (both in te rms of additionality and of real reductions in energy 
consumption) and their driver in investments with medium-to-long term payback time. We would also like to stress that implications  of interactions betw een different trading 
schemes (ETS, Green Certificates, White Certifi cates) should be carefully assessed. In this 
respect, we believe the conclusions of the 2005 NERA report “Interactions of the EU ETS 
with Green and White Certificate Schemes” ar e still valid and should be taken in serious 
considerations. Furthermore, the introduction of cer tificates should be consistent with 
existing measures, bring an added value, and be  cost effective – i.e. the least bureaucratic 
possible. Multiple overlapping steering mechanisms should generally be avoided and EU-
wide regulation should be as limited as possibl e. Any discussion on white certificates shall 
not neglect that calculations  of savings shall include the whole energy chain from 
production to end-point use in order to make  sure no point of the energy process is 
neglected. In addition, it should specifically address issues like the risk of free riders and 
increased cost, and the effectiv eness in driving investments in  the industrial sector, where 
the highest potentials at the lowest cost can be found". (Association of  electricity industry 
in Europe) 
 
4.14. Binding targets  
 
The Directive on energy en-use efficiency an d energy services (2006/ 32/EC) set indicative 
targets for energy savings. Since energy efficiency is becoming increasingly important both as regards security of supply and climate mitigatio n, the public consultation raised the question 
of the need for binding target s. 108 (53.2%) of the stakeholders responded confirmatively, 50 
(24.6%) of the submission answered nega tively, while 45 (22.2%) had no opinion.  
 The majority that answered confirmatively, favour ed a binding overall ta rget but supported by 
secondary level targets, amongst others for CHP. However, th e condition for adopting binding 
targets was to find a common meas urement and verification method. 
 
Examples of stakeholder responses relating to binding targets: 
• "There is a need for an overall target for ener gy efficiency to be made mandatory, such as 
the 20% by 2020 compared to 1990.  This should be underpinned by an understood and clear 
definition of “energy efficiency” and the develo pment of an objective method for measuring 
and quantifying energy efficiency. 2. The bindi ng overall target needs to be supplemented 
by secondary level targets in specific sectors. 3. An overall  mandatory target for 2050 
should also be set for the bu ildings sector. There are legi timate concerns regarding the 
reliability of existing data in all member states  for establishing baselines to measure precise 
energy intensity. Therefore, there is a need for more practical sector specific targets to be 
 
EN 28   EN set. For buildings, for example, a target could be set that would see x% of existing buildings 
renovated to a high standard in each Me mber State every year until 2020/2030/2050". 
 (Industry association in en ergy efficiency services) 
• "There is a need for an overall binding targ et for energy efficiency. The level of ambition 
should be set at least the 20% savings target  already espoused by th e Heads of State and 
government for 2020. There is additionally a need to define clearly what the baseline for the 
calculation at Member State and EU level will  be. The binding overall target needs to be 
supplemented by secondary level targets in sp ecific sectors, including a target for the 
penetration of cogeneration in the electricity provision of a member state". (Association of 
cogeneration)  
4.15. Measurement and verification  
 
Measurement and verification of energy savings is an essential aspect for monitoring the 
results of any measure introduced at national and EU level. The public consultation raised 
therefore the questions whether it was necessary that a systema tic and harmonised approach at 
EU level should be adopted. 143 (70.4%) of th e stakeholders responded confirmatively, 22 
(10.8%) of the submission answered negatively, while 38 (18.7%) had no opinion in this regard.   The majority opting for a systematic and harm onised approach at EU level to be adopted 
stated that measurement and verification methods  are a prerequisite for binding targets.  The 
stakeholders had however some divergent vi ews on which parameters to base such a 
methodology for measuring energy efficiency.   
Examples of stakeholder responses relat ing to measurement and verification: 
• "Systematic and precise measurement of Prim ary Energy used should be emphasised in any 
overall energy use management/monitoring at EU le vel. This is the most effective parameter 
and ensures parity between all energy sources". (NGO) 
•    "The indicative ESD savings target of 9% by 2016 and the 20% 2020 savings goals are not 
directly comparable since the ESD is an end- use (final energy) targ et and the 2020 target 
relates to primary energy use. However, the MS should be required to put their national 
ESD target into the context of the 2020 target to  identify the gap. It should also be requested 
from the MS to indicate how they consider  dealing with the iden tified gap. To improve 
methodology and comparability of  energy savings between Member States, EU wide and 
mandatory templates should be proposed for th e next round of National Energy Efficiency 
Action plans. The templates should be sector specific and highlight how the obligation to 
the Public sector should be implemented. A temp late should also be us ed to request the MS 
to clearly state which measures are new and wh ich ones already exist, as well as how they 
plan to validate the impact of the measures  to be implemented. Several sector templates 
were developed for the first NEEAPs, which is a good starting point for developing mandatory EU templates covering all end-use sector s. The results of the in-depth analysis of 
the NEEAPs currently undertaken by JRC, as well as th e analysis done by Wuppertal and 
Ecofys as part of the EEW project, should also be taken into account when developing 
templates. To provide consistency in ap proach and confidence for organisations 
implementing energy saving measures, a sta ndard protocol should be supported and 
implemented for the measurement and veri fication of energy sa vings from Energy 
Performance Contracting such as IPMVP which is  used in North America and is being used 
 
EN 29   EN by all the major ESCOs in Europe". (Industry association in energy efficiency services) 
•    "Energy efficiency is the largest, quickes t, and most cost-effective resource to improve 
security of supply and mitigate climate change. Binding targets as for renewable energies or 
greenhouse gas emissions should th erefore also be set in th e energy efficiency area. 
However, energy savings can always only be m easured against what would have been the 
energy consumption in the absence of energy ef ficiency measures (a counterfactual). Given 
the measurement problems associated with the de finition of this counter factual, it may be 
better to set binding requirements for the abso lute energy consumption in a Member States 
than for energy savings from energy efficienc y. These requirements for the absolute energy 
consumption can easily be measured and are t hus able to prove thei r fulfilment with the 
precision required. However, they should sti ll be accompanied by indicative targets for 
energy savings against baseline projections. The level of energy savings achieved through 
policy and energy services should also be calcul ated in order to measure the Member States’ 
effort". (University, Institute) 
•    "This is a difficult question as savings of ener gy is not the same thing as energy efficiency, 
it seems attractive to work with energy units sa ved, but to monitor this is difficult. Our own 
work within this field is based on additionality on the sales of electricity, and then this funds 
energy efficiency activities. We argue that ther e are important gains al so in those projects 
that are not necessarily resulti ng in the largest net gain per invested euro as activities can 
boost and support indirect effects". (NGO) 
4.16. International cooperation  
 
The public consultation asked the stakeholders whet her they agreed to that energy efficiency 
should become a vector of international coopera tion and a subject of in ternational financing 
programmes, in particularly regarding EU neighbouring countries. 142 (70%) of the 
stakeholders responded confirmatively, 5 (2.5 %) of the submission an swered negatively, 
while 56 (27.6%) had no opi nion in this regard.  
 The stakeholders expressed that energy efficiency is a global issue as the climate change is an 
issue that concerns the planet. Moreover,  energy efficiency gives several market 
opportunities. As several countries like United St ates and Japan have already launched several 
energy efficiency programmes which will create new products and energy services, energy efficiency is also linked to the competitiveness of Europe.   Several stakeholders also expresse d that they want Eur ope to be a leader in energy efficiency 
policy and that ambitious EU level decision sh ould be brought to th e negotiation table in 
Copenhagen by the end of this year.   
5. F
INAL REMARKS  
 
As a last open free question, the public consultation invited the stak eholders to give their final 
comments on energy efficiency. Some stakeholde rs expressed that the on-line consultation 
should have had an open-free text also related to the No options for the different questions. 
The Commission takes due notice of these rema rks and will endeavour to take this into 
consideration for future on-line questionnaires. Nevertheless, section 5 asked for additional 
comments and was intended for statements that would not directly fit in under the specific 
questions. Several stakeholders used this optio n to elaborate their negative replies for the 
 
EN 30   EN specific questions and these comments have been included in this  report on the public 
consultation on the Evaluation and Revision of the Energy Efficiency Action Plan. 
 
EN 31   EN  
Annex 1: List of organisations submitting responses 
Country Organisation Website 
Austria  Organisation Alpsolar Klimadesign 
Austria  Organisation Association of Austrian Electricity Companies 
Austria  Organisation Enamo GmbH 
Austria  Organisation Energie AG Oberösterreich 
Austria  Organisation EVN Aktiengesellschaft 
Austria  Organisation IG Passivhaus Österreich 
Austria  Organisation Österreichische Elektrizitätswirtschafts-AG 
Austria  Organisation Sonnenplatz Großschoenau GmbH 
Austria  Citizen   
Belgium  Organisation Cefic - European chemical  Industry Association 
Belgium  Organisation DIGITALEUROPE 
Belgium  Citizen   
Belgium  Citizen   
Belgium  Citizen   
Cyprus  Organisation  
Czech Republic  Organisation CEZ Group 
Czech Republic  Organisation Ministry of the environment  
Czech Republic  Organisation Saint-Gobain Orsil 
Czech Republic  Citizen   
Denmark  Organisation Danish Energy Association 
Denmark  Citizen   
 
EN 32   EN EU as a whole (for 
organisations only) Organisation A.I.S.E. (detergents industry association) 
EU as a whole (for 
organisations only) Organisation AEGPL - European LPG Association 
EU as a whole (for 
organisations only) Organisation American Chamber of Commerce to the European 
Union 
EU as a whole (for 
organisations only) Organisation ANEC 
EU as a whole (for 
organisations only) Organisation Architects' Council of Europe (ACE) 
EU as a whole (for 
organisations only) Organisation BEUC - the European Consumers' Organisation 
EU as a whole (for 
organisations only) Organisation BING European polyurethane insulation association 
EU as a whole (for 
organisations only) Organisation Bosch Thermotechnik GmbH 
EU as a whole (for 
organisations only) Organisation CECED - Household Applianc e Industry Association 
EU as a whole (for 
organisations only) Organisation CECODHAS - European Social Housing Network 
EU as a whole (for 
organisations only) Organisation COGEN Europe 
EU as a whole (for 
organisations only) Organisation Danfoss A/S 
EU as a whole (for 
organisations only) Organisation EFIEES – Europ. Feder. Energy Efficiency Services 
EU as a whole (for 
organisations only) Organisation Emerson Electric 
EU as a whole (for 
organisations only) Organisation EON AG 
EU as a whole (for 
organisations only) Organisation EPIA, European Photovoltaic Industry Association 
EU as a whole (for 
organisations only) Organisation ETRMA- European Tyre & Rubber Manufacturers' Ass 
EU as a whole (for 
organisations only) Organisation eu.bac - european building automation & controls  
EU as a whole (for 
organisations only) Organisation EURELECTRIC 
EU as a whole (for 
organisations only) Organisation EURIMA, European Insulati on Manufacturers Assoc 
EU as a whole (for 
organisations only) Organisation EuroACE 
EU as a whole (for 
organisations only) Organisation EUROCHAMBRES 
EU as a whole (for 
organisations only) Organisation EuroCommerce 
 
EN 33   EN EU as a whole (for 
organisations only) Organisation EUROGYPSUM 
EU as a whole (for 
organisations only) Organisation Euroheat & Power 
EU as a whole (for 
organisations only) Organisation European Aluminium Association 
EU as a whole (for 
organisations only) Organisation European Autoclaved Aerated Concrete Association 
EU as a whole (for 
organisations only) Organisation European Calcium Silicate Producers Association 
EU as a whole (for 
organisations only) Organisation European Construction Indu stry Federation (FIEC) 
EU as a whole (for 
organisations only) Organisation European Copper Institute 
EU as a whole (for 
organisations only) Organisation European Cyclists' Federation (ECF) 
EU as a whole (for 
organisations only) Organisation European Environemental Bureau (EEB) 
EU as a whole (for 
organisations only) Organisation European Federation for Construction Chemicals 
EU as a whole (for 
organisations only) Organisation European Lamp Companies Federation 
EU as a whole (for 
organisations only) Organisation European Petroleum Indust ry Association, EUROPIA 
EU as a whole (for 
organisations only) Organisation European Renewable Energy Council 
EU as a whole (for 
organisations only) Organisation FIA European Bureau 
EU as a whole (for 
organisations only) Organisation GEODE 
EU as a whole (for 
organisations only) Organisation Glass for Europe 
EU as a whole (for 
organisations only) Organisation International Network for Sust. Energy - Europe 
EU as a whole (for 
organisations only) Organisation Kingspan Group - mark.harris@kingspanpanels.com 
EU as a whole (for 
organisations only) Organisation Micropower Europe 
EU as a whole (for 
organisations only) Organisation NGVA Europe 
EU as a whole (for 
organisations only) Organisation Surfrider Foundation Europe 
EU as a whole (for 
organisations only) Organisation Surfrider Foundation Europe 
EU as a whole (for 
organisations only) Organisation UEAPME 
 
EN 34   EN EU as a whole (for 
organisations only) Organisation WWF European Policy Office 
EU as a whole (for 
organisations only) Citizen   
Finland  Organisation Finnish Energy Industries 
Finland  Organisation National Board of Antiquities 
France  Organisation ACFCI - French Chambers of  Commerce and Industry 
France  Organisation Assemblée permanente des chambres de métiers 
(APCM 
France  Organisation Banque Populaire 
France  Organisation Bosch Thermotechnology 
France  Organisation ELM Leblanc (groupe BOSCH) 
France  Organisation ERDF -  Electricité Réseau Distribution France 
France  Organisation Fédération Française du Bâtiment 
France  Organisation Fédération Nationale des Travaux Publics (FNTP) 
France  Organisation GIMELEC 
France  Organisation L'Union sociale pour l'Habitat 
France  Organisation MEDEF 
France  Organisation Ministère en charge du développement durable 
France  Organisation Regional Chamber of Commerce and Industry Lorraine 
France  Organisation  EDF 
France Organisation  
France  Organisation   
France  Citizen   
Germany  Organisation B.A.U.M. e.V. 
Germany  Organisation Bayerisches Staatsministerium für Umwelt 
 
EN 35   EN Germany  Organisation BDEW German Association of  Energy and Water Indust 
Germany  Organisation Bundesarchitektenkammer 
Germany  Organisation Bundesverband Großhandel, Außenhandel, Dienstleist 
Germany  Organisation Deutscher Industrie- und Handelskammertag DIHK e.V 
Germany  Organisation DGUF - Reg.-Nr. 82277911427-06 
Germany  Organisation erdgas mobil GmbH 
Germany  Organisation Federation of German Industries (BDI) 
Germany  Organisation FMI Fachverband Mineralwoleindustrie e.V. 
Germany  Organisation German Association of the Automotive Industry 
Germany  Organisation German Engineering Federation (VDMA) 
Germany  Organisation IHK Halle-Dessau 
 Germany Organisation Landis+Gyr Ag 
Germany  Organisation Industrieverband Polyurethan-Hartschaum e. V: 
Germany  Organisation Max Weishaupt GmbH, D-88475 Schwendi 
Germany  Organisation RWE AG 
Germany  Organisation Schulze Darup & Partner architects 
Germany  Organisation Stadtwerke München GmbH 
Germany  Organisation Verbraucherzentrale Bundesverband 
 Germany Organisation Wienerberger AG 
Germany  Organisation Vereinigung der Landesdenkmalpfleger in Deutschlan 
Germany  Organisation Viessmann Werke GmbG & Co. KG 
Germany  Organisation Viessmann Werke GmbH & Co. KG 
Germany  Organisation VKU e.V. und ASEW GbR  
 
EN 36   EN Germany  Organisation Wuppertal Institute 
Germany  Organisation Zentralverband des Deutschen Handwerks 
Germany  Citizen   
Germany  Organisation   
Germany  Organisation   
Germany  Citizen   
Germany  Citizen   
Greece  Organisation test 
Hungary  Organisation Hungarian Real Estate Association Management HAREM 
Hungary  Organisation National Office of Cultural Heritage 
Hungary  Organisation   
Ireland  Citizen   
Italy  Organisation 3Effegi S.r.l. 
Italy  Organisation Centro Studi Galileo 
Italy  Organisation Confcommercio - Imprese per l'Italia 
Italy  Organisation Edison spa 
 Italy Organisation ENI SpA 
Italy  Organisation Municipality of Bologna 
Italy  Organisation PIRELLI REAL ESTATE 
Italy  Citizen   
Italy  Organisation   
Lithuania  Citizen   
Luxembourg  Organisation   
 
EN 37   EN Malta  Citizen   
Netherlands  Organisation Bouwend Nederland 
Netherlands  Organisation   
Netherlands  Organisation   
Netherlands  Organisation   
Netherlands  Citizen   
Netherlands  Organisation   
Netherlands  Organisation   
Netherlands  Organisation   
Netherlands  Organisation   
Netherlands  Organisation   
Netherlands  Citizen   
Poland  Organisation Verband für Wärmelieferung e.V. 
Poland  Organisation   
Portugal  Organisation EFRIARC - Assoc.Port.Eng.Frio Ind. Ar Condicionado 
Portugal  Organisation Portuguese Natural Gas Vehicle Association 
Romania  Citizen   
Romania  Citizen   
Romania  Citizen   
Romania  Citizen   
Romania  Citizen   
Slovakia  Organisation Association of Service Users 
Slovakia  Citizen   
 
EN 38   EN Slovenia  Organisation Elektro Ljubljana d.d. 
Slovenia  Organisation Focus Association for Sustainable Development 
Slovenia  Organisation Lokalni pospeševalni center Pivka 
Slovenia  Organisation ZOJA 
Some EU Member 
States (for 
organisations only) Organisation CEDEC  
Some EU Member 
States (for 
organisations only) Organisation CELMA 
Some EU Member 
States (for 
organisations only) Organisation EnBW Energie Baden-Württemberg AG 
Some EU Member 
States (for 
organisations only) Organisation Eurofuel (The European Heating Oil Association) 
Some EU Member 
States (for 
organisations only) Organisation EUROGAS 
Some EU Member 
States (for 
organisations only) Organisation Lubrizol  
Some EU Member 
States (for 
organisations only) Organisation UPEI (Union of European Petroleum Independents) 
Spain  Organisation Cantabria Trade Federation 
Spain  Organisation FENIE 
 Spain Organisation IBERDROLA 
Spain  Organisation Minsiterio de Industria, Turismo y Comercio 
Spain  Organisation Saint-Gobain Cristalería S.A. 
Spain  Organisation UNION FENOSA comercial 
Spain  Organisation   
Spain  Citizen   
Spain  Citizen   
 Sweden Organisation Telefonaktiebolaget LM Ericsson 
Sweden  Organisation 5665831886-97 (Svensk Energi, Swedenergy AB) 
 
EN 39   EN Sweden  Organisation Stadskansliet, City Hall 
Sweden  Organisation Swedish Society for Nature Conservation 
Sweden  Citizen   
United Kingdom Organisation Confederation of British Industry (CBI) 
United Kingdom Organisation Department of Energy and Climate Change (UK) 
United Kingdom Organisation Energy Action Scotland (EAS) 
United Kingdom Organisation Kingspan Insulation Limited 
United Kingdom Organisation Local Govt Assn (for England and Wales) 
United Kingdom Citizen   
United Kingdom Citizen   
United Kingdom Citizen   
United Kingdom Citizen   
  Organisation ACEA 
  Organisation AGFW e.V. 
  Organisation Alstom Power 
  Organisation Greenpeace 
  Organisation HELIO International 
  Organisation International Union of Tenants (IUT) www.iut.nu 
  Organisation Royal Institution of Char tered Surveyors (RICS) 
  Organisation shecco 
  Organisation SHV GAS 
 Organisation AREA 
 Organisation Applied Materials 
 
EN 40   EN  Organisation Better Place 
 Organisation Energy Efficiency Industrial Forum 
 Organisation Eurocities 
  Organisation   
  Organisation   
 
 
EN 41   EN Annex 2: On-line public consultation  
Public Consultation on the Evaluation and Revision of the 
Action Plan for Energy Efficiency [COM(2006) 545] 
 
 
Useful links  - Background documents   
 
The Heads of States and Governments have endors ed an ambitious European Energy policy which 
seeks to enable the European Union to reduce green house gases by at least 20 %, to reduce energy 
consumption by 20 % and increase to 20 % the shar e of renewable energies in energy consumption 
by 2020.  
 
The Action Plan for Energy Efficiency (EEAP) of  2006 was prepared and adopted with a view to 
intensify the process of realising the substantia l cost-effective energy savings potential and the 
above-mentioned target on energy consumption redu ction. The Plan's running time is until 2012. A 
major mid-term review to evaluate its effectiven ess and results was scheduled to take place in 
2009.  
 
This internet consultation will suppo rt this evaluation and revision. It aims to collect views from 
interested parties on the effectiveness and results of the Action Plan so far, and on how best the 
EU may identify and initiate improved policy actions and measures which contribute to a 
maximum extent to the EU's energy saving targets.  
 
The Commission will publish the results, which may also contain some of the individual replies (if 
no specific request for confidentiality is made) at 
http://ec.europa.eu/energy/efficiency/consultations/2009_08_03_eeap_en.htm  
 
The public consultation will last 8 week s. The closing date is 3 August 2009. 
 
Please note that:   
• Replies in free text questions are limited, in most cases, to maximum 4000 characters (spaces 
included).  
• The session time is limited to 1 hour 30 min, which means that you should submit your reply 
within this allotted time. If you exceed th is timeframe, your replies will be lost.  
• If your replies need to be co-ordinated in ternally, we suggest that you print the blank 
questionnaire and draft your reply off-line (e.g. in a word processor of your choice) and then 
enter the answers online (you can of course simply "copy/paste" text already prepared).  
• After you have clicked on "submit", you should see a confirmation page stating that your reply 
has been recorded. If this is not the case, and if  the survey page is re-loaded instead, please 
check that you have filled in all compulsory qu estions correctly and you have not exceeded the 
maximum number of characters for free text questions. In this case, an error message appears 
next to the question for which something is wrong or missing.  
• The answers to the questions can be provided in  any of the official languages of the European 
Union; where possible, answers in a commonly known language are encouraged in order to 
simplify the processing of replies, if possible in  the Commission working languages (i. e. English, 
French or German).  
• The respondents are strongly encouraged, if poss ible, to support their answers with quantitative 
and qualitative arguments and reference to other information sources.  
 
   
 
EN 42   EN Profile of the respondent 
 
   
Your profile (compulsory )  
Citizen 
 Organisation 
 
Region (compulsory )  
European Union 
 Europe outside European Union 
 International 
 Other 
 
 
Austria  
 Greece  
 Portugal  
Belgium  
 Hungary  
 Romania  
Bulgaria  
 Ireland  
 Slovakia  
Cyprus  
 Italy  
 Slovenia  
Czech Republic  
 Latvia  
 Spain  
Denmark  
 Lithuania  
 Sweden  
Estonia  
 Luxembourg  
 United Kingdom 
Finland  
 Malta  
 EU as a whole (for organisations only) 
France  
 Netherlands  
 Some EU Member States (for organisations only) 
Germany  
 Poland    
Albania 
 Georgia 
 San Marino 
Andorra 
 Iceland 
 Serbia 
Armenia 
 Liechtenstein 
 Switzerland 
Azerbaijan 
 Moldova 
 Turkey 
Belarus 
 Monaco 
 Ukraine 
Bosnia and Herzegovina 
 Montenegro 
 Vatican City State 
Croatia 
 Norway   
Former Yugoslav Republic of Macedonia 
 Russia   
 
EN 43   EN  
Would you like your reply to be published online? (compulsory )  
Yes 
 No 
 
 Organisation name (optional )  
 
 
 Organization type (compulsory )  
Member States or public body  (national/regional/local), 
incl. Regulators 
European institution or body 
Industry and private sector, in cl. their associations, excl. 
SMEs 
Small and Medium Size Enterprises 
(SMEs) 
Consumer organization 
 Financing organization 
Non-governmental organization 
 Energy utility 
University/ education/ research institute 
 Energy Efficiency Agency (national, 
regional, local) 
OTHER   
 
 
 What type of activities are addressed by your organization (multiple choice 
question) (compulsory )  
Energy Efficiency services in the residential 
sector 
Energy Efficiency services in the tertiary and industry 
sectors 
Construction 
 Energy-using products and appliances 
Transport sector 
 Energy production, supply, transmission or distribution 
Other   
 
 
EN 44   EN  
 Briefly describe the nature of your  involvement in energy efficiency (optional )  
 
 
   
1. General questions 
In the context of this evaluation and the prep aration of the envisaged new Energy Efficiency 
Action Plan, the Commission is open to re-evaluate  its present legislation and policy portfolio. 
 
   
1.1. The Action Plan for Energy Efficiency of 20 06 identified 6 key areas and proposed 10 priority 
actions (out of a total of 85 actions and measures). Which of the actions and measures of the 2006 
EEAP should be continued / redefined / disc ontinued, and why ? (M ax. 4000 characters) (optional )  
 
 
1.2. Which new challenges have em erged since 2006 and should be addressed in the new Action Plan 
for Energy Efficiency? (Max. 4000 characters) (optional )  
 
 
   
2. Specific questions 
Please provide an answer to each of the following questions and, if possible, justify it by 
quantifying the environmental, social and economic impacts. 
 
   
2.1. The existing Energy Performance of Buildings Directive (2002/91/EC) and its recast, as well as 
other relevant legal acts, go a long way for introd ucing ambitious but realizable energy performance 
 
EN 45   EN requirements for buildings and increase consum ers' awareness. Howeve r, much more can be 
done. (compulsory )  
Yes 
 No 
 No opinion     
 
 How do you assess the need fo r moving towards a requirement th at all new buildings have low 
or zero energy consumption and carbon emissions after certain date? (Max. 4000 
characters) (optional )  
 
 
 How do you assess the need for introducing an  EU level measures co ncerning training of 
architects, builders and inst allers? (Max. 4000 characters) (optional )  
 
 
 What other measures at EU level need to be undertaken? (Max. 4000 characters) (optional )  
 
 
2.2. Sustainable transport and energy consumption of cars is currently addressed in the Greening 
transport package (COM(2008)433), the Regulation on Emission performance standards for new 
passenger cars (COM(2007)0856), the proposed Dire ctive on labelling of tyres (COM(2008)0779), the 
proposal on greening car taxation (COM(2005)261) an d the 'Green Cars' initiative. The Commission is 
also working on a proposal on light commercial vehi cles and a revision of CO 2/cars labelling. Do you 
consider that additional measures at  EU level need to be undertaken? (compulsory )  
Yes 
 No 
 No opinion     
 
 In your view what should these measures be? (Max. 4000 characters) (optional )  
 
EN 46   EN  
 
2.3. The Eco-Design (2005/32/EC) and Energy Labelling (92/75/EEC) framework Directives are 
significant steps as regard to product policy. A number of implementing measures have been already 
or are soon to be adopted and the ongoing amendments of the two Directives provide for their more 
ambitious and wider application. Do you consider th at additional measures can be taken forward in 
order to increase the impact of these instruments? (compulsory )  
Yes 
 No 
 No opinion     
 
 In your view what should these measures be? (Max. 4000 characters) (optional )  
 
 
2.4. Lack of access to appropriate financing is an important bottleneck for making a real step 
forward in our ambitions on energy saving. Innovative financing instruments are now being 
developed by institutions such as EIB, EBRD, national promotional banks and private banks in 
particular in association with the Covenant of Majors initiative. Demonstration projects of the 
application of energy efficient tec hnologies in a competitive manner, e.g. 'smart cities', could also 
be considered. Do you think other financ ing measures at EU level are needed? (compulsory )  
Yes 
 No 
 No opinion     
 
 What best mechanisms and ways forward wher e the EU value added can be substantial would 
you recommend? (Max . 4000 characters) (optional )  
 
 
2.5. Well targeted fiscal incentives could be a driver for energy efficiency investments and 
innovation. The EU has already take n measures to make it easy for Member States to allow for more 
advantageous VAT rates for some labour-intensive services, such as renovation and repairing of 
 
EN 47   EN private dwellings. Do you consider that additional  measures at EU level need to be undertaken to 
shape consumer choices? (compulsory )  
Yes 
 No 
 No opinion     
 
 In your view what these measures  should be? (Max. 4000 characters) (optional )  
 
 
2.6. Education and training on energy efficien cy are vital ingredient of a successful energy 
efficiency policy. These were already mentioned above regarding building s but the challenge is 
much broader. Do you consider that measures/actions at EU level to catalyze training at school and 
university level should be undertaken? (compulsory )  
Yes 
 No 
 No opinion     
 
 In your view what should th ese measures be as regards different target groups? (Max. 4000 
characters) (optional )  
 
 
2.7. Awareness of final co nsumers on energy savings possibilities and their benefits is still low. This 
in particular concerns domestic consumers and SMEs. Some actions to target different groups are 
already undertaken at national and EU level. For example, the Sustainable Energy Europe Campaign 
is focusing on grouping social stakeholders and market actors to undert ake joint action. Do you 
think that further communication action at EU level is needed? (compulsory )  
Yes 
 No 
 No opinion     
 
 Which would be the content of such a communica tion strategy as regard s each of the target 
groups concerned? (M ax. 4000 characters) (optional )  
 
EN 48   EN  
 
2.8. Furthermore, small and medium size companies (SMEs) are the backbone of EU's economy as 
they make up more than 99% of all firms and employ 67% of the EU's workforce but may need more 
support for implementing energy saving measures. Do  you consider that specif ic measures to target 
SMEs are necessary? (compulsory )  
Yes 
 No 
 No opinion     
 
 In your view what should these measures be? (Max. 4000 characters) (optional )  
 
 
2.9. Public sector should lead by providing best  practice examples. Positi ve progresses have been 
made under the voluntary Green public procurem ent policy and the proposals for mandatory 
procurement of energy efficient products in the framework of the recast of the Energy Labelling 
Directive. The leading role of public authorities has also been emphasized under the recast of 
Energy Performance of Buildings Directive proposal. Do you consider that further actions at EU level 
should be undertaken? (compulsory )  
Yes 
 No 
 No opinion     
 
 What further actions would you suggest at EU level? (Max. 4000 characters) (optional )  
 
 
2.10. The role of energy utilities can be substa ntial but at present they have insufficiently 
developed a market for energy efficiency services . Ways to create adequa te framework conditions 
for this market to take-up in liberalized electr icity and natural gas markets should be sought, 
possibly in cooperation with the Regulators. Do yo u consider that actions at EU level should be 
undertaken? (compulsory )  
 
EN 49   EN 
Yes 
 No 
 No opinion     
 
 In your view what should these measures be? (Max. 4000 characters) (optional )  
 
 
2.11. Energy efficiency offers significant market opportunities. Do you consider that specific 
measures at EU level should be adopted to provide incentives for companies to enter these markets, 
in particularly as regards SMEs? (compulsory )  
Yes 
 No 
 No opinion 
 
 In your view what should these measures be? (Max. 4000 characters) (optional )  
 
 
2.12. In relation to the above question do you consider that there is a need for the introduction of a 
EU-wide White Certificate scheme? (optional )  
Yes 
 No 
 No opinion     
 
 How do you think this EU-wide scheme should be  designed and what should the role of energy 
utilities be? (Max. 4000 characters) (optional )  
 
 
2.13. The Directive on energy end-use efficiency and energy services (2006/32/EC) already provides 
for national indicative energy savings target which differs from the ones for renewables and for the 
greenhouse gas emissions. Giving the increasing priority for ensuring that investment in energy 
consumption reduction are made in all Member Stat es do you consider that a move towards binding 
targets is needed? (compulsory )  
 
EN 50   EN 
Yes 
 No 
 No opinion     
 
 How should these binding targets be set up and at what level? (Max. 4000 characters) (optional )  
 
 
2.14. Measurement and verification of energy saving s is essential aspect fo r monitoring the results 
of any measures introduced at national and EU le vel. Although some targeted measures are being 
implemented, do you consider that more systematic and harmonized approach at EU level is 
needed? (compulsory )  
Yes 
 No 
 No opinion     
 
 In your view what should these measures be? (Max. 4000 characters) (optional )  
 
 
2.15. Energy efficiency should become a vector of international co-operation and a subject of 
international financing programmes, in particular re garding EU neighbouring countries. Do you agree 
with statement? (compulsory )  
Yes 
 No 
 No opinion     
 
 In your view what should these measures be? (Max. 4000 characters) (optional )  
 
 
   
3. Other remarks 
 
 
EN 51   EN    
3.1. Please add your additional remarks in  the section below. (M ax. 5000 characters) (optional )  
 
 
 
 
 SUBMIT  
 
 
 
 
EN 52   EN Annex 3: Background document on the on-line public 
consultation 
 
 EUROPEAN COMMISSION 
DIRECTORATE-GENERAL FOR ENERGY AND TRANSPORT 
 
DIRECTORATE D - New and Renewable Energy Sources, Energy Efficiency & Innovation 
Energy Efficiency  
 
 
 
 
Background Informat ion Paper for the 
Public Consultation on the  
Evaluation and Revision of the  
Action Plan for Energy Ef ficiency (COM (2006) 545) 
 
 
Note: 
 
This background paper is being circulated for consultation to all parties concerned by 
the Action Plan for Energy Efficiency (EEAP). 
 
 
The sole purpose of the consultation is to  contribute to the debate, collect relevant 
information and help the Commission develop its thinking in this area. 
 
 
This document does not necessarily reflect the views of the Commiss ion of the European 
Communities, and should not be interpreted as a commitment by the Commission to any 
official initiative in this area. 
 
 
 
 
 
Parties concerned are invited to subm it their comments no later than  
3 August 2009 by means of an online questionnaire, available at: 
 
http://ec.europa.eu/energy/efficien cy/consultations/2009_08_03_eeap_en.htm 
 
 
 
EN 53   EN 1. INTRODUCTION 
The European Community aims to promote energy efficiency and energy saving as it is the 
most cost-effective way of reducing energy co nsumption while maintaining an equivalent 
level of economic activity. This supports broa der Community objectives in the areas of 
security of supply, climate change m itigation and improving competitiveness.  
On 19 October 2006 the Commission adopted the Action Plan for Energy Efficiency: 
Realising the Potential (EEAP)8. It gave an outline for a cohe rent framework of legislation, 
policies and measures with a view  to save a substantial part of  the 20% of EU annual primary 
energy consumption by 2020. It proposed a selec tion of cost-effective energy efficiency 
improvement initiatives to be put in place and implemented until 2012. 
As announced in the Plan, the Commission will evaluate it in 2009 a nd prepare a revised 
Action Plan, as requested by the European Council.  
This document initiates the Publ ic Consultation that precedes the preparation of the revised 
Plan and allows stakeholders and interested parties to express their views and opinions on 
issues they believe should be covered by the new Action Plan for  Energy Efficiency . 
2. THE ACTION PLAN FOR ENERGY  EFFICIENCY AND EU POLICY 
OBJECTIVES 
The full implementation of the EEAP can offer significant reductions in energy consumption 
and is therefore an important tool towards achieving the ambitious 20/20/20% targets for 
energy consumption and greenhouse gas emissi on reductions, and an increased share of 
renewables by 2020, as endorsed by the Heads of State and Governments during the spring 
2007 European Council9. 
The EEAP will lead to achieving the above objectiv es in a cost-effective manner as it will:  
(i) increase independence from energy impor ts which will contribute to the EU 
security of supply objectives; 
(ii) contribute to EU economi c growth and job creation;  
(iii) contribute to the redu ction of greenhouse gas emissions  and of the harmful impact 
of energy generation on the environment; and 
(iv) improve living conditions  and comfort for citizens. 
The implementation of actions and measures of the Action Plan sector is therefore of prime 
importance for realizing the strategic obj ectives of the European Energy Policy. 
 Moreover, on the basis of Di rective 2006/32/EC on energy e nd-use efficiency and energy 
services, each EU Member Stat e has prepared its National Energy Efficiency Action Plan 
which describes the energy efficiency improveme nt measures planned at national level to 
achieve the energy savings target of the directiv e, to be reached by way of energy services and 
other energy efficiency improvement measures . The Commission is currently assessing these 
plans. A Commission staff working document is to be published in mid-2009 and will present 
                                                
 
8 COM(2006) 545. 
9 7224/1/07, REV 1. 
 
EN 54   EN the results of this assessment. The national Plans are expected to also contribute significantly 
to the EU's energy saving targets and are complementary to the EEAP.  The EEAP and the National Plans are two of the five pillars to the EU's specific energy 
efficiency policy.  The other three pillars are i) the legal framework notably for the building 
sector and energy consuming products, ii) fla nking policy instruments such as targeted 
financing and the provision of information and networks, and iii) international collaboration. 
The Commission stresses that the full implemen tation and enforcement of the existing and 
future regulatory frameworks is essential and the Commission will continue to pursue - 
through legal means - proper transposition a nd application of Community law affecting 
energy efficiency. 
3. THE MAIN ELEMENTS OF THE ACTION PLAN FOR ENERGY EFFICIENCY 
The Action Plan outlines a framework of policies and measures with a view to intensify the 
process of realising the over 20% estimated savings potential in EU annual primary energy 
consumption by 2020. The Plan lists a range of cost-effective measures proposing priority 
actions to be initiated immediatel y, and others to be initiate d over the Plan's implementation 
period. 
The Action Plan intends to mobilise the genera l public and policy-makers  at all levels of 
government, together with market actors, and to  provide EU citizens with the globally most 
energy-efficient infrastructure, buildings, applia nces, processes, transp ort means and energy 
systems. Given the importance of the human f actor in reducing energy consumption, the Plan 
also encourages consumers to use energy in  the most rational manner possible as energy 
efficiency is also about informed choice by individuals. 
The current EEAP identifies six key areas wi th the highest potentia l for energy saving: 
• energy performance requirements for products, buildings and services 
• energy transformation 
• transport 
• financing and pricing 
• energy behaviour 
• international partnerships 
The current Plan also proposes 85 actions and meas ures to be taken at EU and national level. 
Among them, ten priority acti ons have been identified: 
• appliance and equipment labelling and minimum energy performance standards 
• adoption of building performance require ments and very low energy buildings 
• making power generation and distribution more efficient 
 
EN 55   EN • achieving fuel efficiency of cars  
• facilitating appropriate financing of ener gy efficiency investments for SME's and 
Energy Services Companies 
• coherent use of taxation 
• energy efficiency in built-up areas 
• raising energy efficiency awareness 
• fostering energy efficiency worldwide 
• spurring energy efficiency in the new Member States 
4. CURRENT IMPLEMENTATION OF THE ACTION PLAN FOR ENERGY 
EFFICIENCY 
The implementation of the Action Plan is ongoi ng and will continue till 2012. The measures 
set forth in the Action Plan and its annex ar e expected to produce e ffects between 2006 and 
2012 and many of them already between 2006 a nd 2009. That is why the mid-term review 
takes place this year, during the impl ementation period of the Action Plan. 
One third of the actions of the Action Plan have been completed. The remainder are ongoing 
and still need active commitment both at EU and national level. 
5. WHY THE ACTION PLAN FOR ENERGY  EFFICIENCY NEEDS EVALUATION 
AND REVISION? 
There are strong indications that  with on-going actions the EU w ill not be able to reach its 
saving objective for 2020. In it s Communication 'Energy effici ency: delivering the 20% 
target' (COM(2008) 772 final) , the Commission provi ded a quantitative evaluation of the 
expected impact of specific energy efficien cy legislation and measures when fully 
implemented. First hand information on the involvement and the implementation as well as other indicators suggested that the energy saving  potential is not being realised fast enough: 
they would achieve energy savings of a bout 13% by 2020 if properly implemented by 
Member States. Even if this represents a major achievement, it falls short of what is needed. For this reason, all pillars of th e EU's energy efficiency policy - including the EEAP - need to 
be reinforced.  Recent studies indicate that the opportunities for energy savings are significant: the estimated 
energy consumption reduction po tential in 2020 is 19% for i ndustry, 20% for transport and 
30% for the households and services sector.
10 
 There are a number of reasons why our energy saving potential is not exploited to the full: 
                                                
 
10 Study on Energy Savings Potentials in EU Memb er States, Candidate Coun tries and EEA Countries. 
Fraunhofer ISI et al; preliminary results.  
 
EN 56   EN   
• Energy saving and efficiency is by its nature a result from numerous small actions at the 
final consumption level.  
• The Member States are formally implementi ng the current EU legislation.  However, 
more needs to be done to reap all benefits available. 
• The diversity of the 27 Member States is  even more evident on energy efficiency 
policies than in other energy policy issu es. The climatic conditions, consumers' 
possibilities to act, economic circumstances vary from one corner of Europe to another.  
• Energy saving actions are needed  at all levels of government  including, but not only, the 
EU level.  
• Consumers, companies and households are the final decision makers. Consumer 
awareness on the benefits of energy saving, th ough on the increase, is still too low. In 
parallel, the political decision makers ar e not eager to touch upon delicate behaviour-
related issues. 
• The financing of the energy saving investments is complex because of the small scale of 
the individual actions. Unlik e other areas, such as renewable energy generation and 
transport, financial incentives for households  have been rather limited. Further, even if 
funding is available, the missi ng organisational and administra tive structures have been 
preventing its use.  
• Energy prices and the environmental benefits have so far been the main drivers for 
energy saving. However, price do not yet fully internalise the environmental, social and 
economic benefits of higher energy efficien cy (esp. there are be nefits from energy 
security not valued on markets).  
• Job creation benefits are e qually important to justify new activities in the deepening 
economic downturn in Europe. Concerns about security of supply add to the urgency of 
action. 
• A specific problem in energy saving is target  setting. A concrete, verified target has 
proved to be successful in many sector pol icies. In energy saving, the results are 
difficult to measure. 
• Energy efficiency in energy production a nd supply: a dynamic market for energy 
services has not yet fully developed, despite  incentives created by the energy services 
directive for utilities to invest in energy e fficiency and to promote an energy efficient 
behaviour of their customers 
• In many Member States architects, builders an d installers have not received training or 
have not certified their skills in order to implement energy efficiency practices.  
The above list is not exhaustive but provides indications and avenues on how more energy can 
be saved and the actions to be taken to make that happen. Of course, additional challenges and 
avenues can be identified and proposed.  In its Energy Efficiency Package of Nove mber 2008, the Commission presented the over-all 
policy lines and first rough estimations on th e expected impacts of the current policy 
 
EN 57   EN portfolio. In this context, the Commission also  made a number of proposals to strengthen the 
legal framework for energy efficiency.11 The impact assessments that accompany these 
proposals show the significant potential impact thereof and will serve as an important source of information for the evaluation of the EEAP. 
6. ISSUES FOR CONSIDERATION IN TH E CONTEXT OF THE PREPARATION OF 
A NEW ENERGY EFFICIENCY ACTION PLAN   
A brief but not exhaustive overv iew of some of the challenges arising out of implementation 
of the present Action Plan is set out in the pr evious sections. The new EEAP will start from 
analysis of the successes and failures of the current one. The Commission will carry out this 
evaluation in particular on the basis of the obs ervations and comments made by third parties 
under this Public Consultation. 
The list of priority issues that will be discussed in the new Action Plan for Energy Efficiency 
are the following: 
(1) The existing Energy Performance of Buildi ngs Directive (2002/91/EC) and its recast, 
as well as other relevant  legal acts, go a long way for introducing ambitious but 
realizable energy performance requirements  for buildings and increase consumers' 
awareness. However, much more can be  done. For example, measures on how to 
stimulate rapid uptake of trai ning of architects, builders a nd installers need to be 
considered. Further discussion is also n eeded on whether EU should move towards 
fixing agreed date for all new build to be  very low or zero energy and carbon and 
adopt a roadmap towards this. 
(2) Sustainable transport and energy consumpti on of cars is currently addressed in the 
Greening transport package12, the Regulation on Emission performance standards for 
new passenger cars13, the proposed Directive on labelling of tyres14, the proposal on 
greening car taxation15 and the 'Green Cars' initiative. The Commission is also 
working on a proposal on li ght commercial vehicles16 and a revision of CO2/cars 
labelling. Comments are needed as to whether additional measures need to be undertaken.  
(3) The Eco-Design (2005/32/EC) and Energy  Labelling (92/75/EEC) framework 
Directives are significan t steps with regard to product policy. A number of 
implementing measures have been already or are soon to be adopted and the ongoing 
amendments of the two Directives provide for their more ambitious and wider application. Suggestions should be made as to how these can  be taken forward in order 
to increase their impact.  
(4) Lack of access to appropriate financing is  an important bottlen eck for making a real 
step forward in our ambitions on energy saving. Innovative financ ing instruments are 
now being developed by institutions such as EIB, EBRD, national promotional banks 
                                                
 
11 See the European Commission's website for details. 
12 COM(2008) 433. 
13 COM(2007) 856. 
14 COM(2008) 779. 
15 COM(2005) 261. 
16 http://ec.europa.eu/environment/air/transport/co2/co2_home.htm 
 
EN 58   EN and private banks in particular in associati on with the Covenant of Majors initiative. 
Demonstration projects of the application of energy efficient technologies in a 
competitive manner, e.g. 'smart cities', coul d also be considered. Comments on the 
best mechanisms and ways forward are needed.  
(5) Furthermore, well targeted fiscal incentives could be important drivers for energy 
efficiency investments and innovation. The EU has already taken measures to make it 
easy for Member States to allow for more  advantageous VAT rates for some labour-
intensive services, such as renovation and repairing of private dwellings and is 
considering further how energy taxation and other taxes can play a role in synergy 
with the EU ETS to achieve EU climate and energy objectives steps on products and 
other services. Comments on whether additiona l measures need to be undertaken to 
change consumption patterns are needed. 
(6) Education and training on energy efficiency  are vital ingredients of a successful 
energy efficiency policy. These were already mentioned above regarding buildings but the challenge is much broade r. Measures on ways to ca talyze training at school and 
university level need to be  identified and discussed. 
(7) Awareness of final consumers on energy savings possibilities and their benefits is still 
low. This in particular concerns domestic consumers and SMEs. Some actions to 
target different groups are already undertaken  at national and EU level. For example, 
the Sustainable Energy Europe Campaign is focusing on grouping social stakeholders 
and market actors to undertak e joint action. Further consid eration of the appropriate 
level and means to better enga ge these groups is needed. 
(8) Furthermore, small and medium size comp anies (SMEs) are the backbone of EU's 
economy as they make up more than 99% of all firms and employ 67% of the EU's workforce. Consideration should be given as to the best means to provide them with 
more support for implementing energy saving measures. 
(9) Public sector should lead by providing be st practice examples. Positive progresses 
have been made under the voluntary Gr een public procurem ent policy and the 
proposals for mandatory procurement of energy efficient products in the framework of 
the recast of the Energy Labell ing Directive. The leading ro le of public authorities has 
also been emphasized under the recast of Energy Performance of Buildings Directive 
proposal but further measures should be envisaged. 
(10) The role of energy utilities can  be substantial but at present they have insufficiently 
developed a market for energy efficiency se rvices. Ways to create adequate framework 
conditions for this market to take-up in a lib eralized electricity and natural gas markets 
should be sought, possibly in cooperation w ith the Regulators. Further questions on 
how these framework conditions can best be created, for example through possible 
EU-wide white certificate scheme, would also need to be considered. 
(11) Energy efficiency offers significant ma rket opportunities. Measures to provide 
incentives for companies to enter these market s need to be considered, in particularly 
as regards SMEs.  
(12) The Directive on energy end-use efficiency and energy services (2006/32/EC) already 
provides for national indicative energy savings  target which differs from the ones for 
 
EN 59   EN renewables and for greenhouse gas emissi ons. Giving the increas ing priority for 
ensuring that investment in energy consum ption reduction are made in all Member 
States the question arises as to whether it is the time now to move towards binding 
"energy efficiency" targets. 
(13) Measurement and verification of energy savi ngs is a challenging but very important 
aspect for monitoring the results of any meas ures introduced at national and EU level. 
Some targeted measures are being impleme nted but whether a more systematic and 
harmonized approach is need ed should be considered. 
(14) Energy efficiency should become a vector of  international co-operation and a subject 
of international financing programmes, in particular regarding EU neighbouring 
countries.  Measures to this effect need to be identified and discussed. 
Specific questions highlighting these issues are included in the online qu estionnaire, available 
at: http://ec.europa.eu/ yourvoice/index_en.htm