11.^.88 Official]ournal of the European Communities NoC955ul5 
Opinion on the proposal foraCouncil Directive on information on the energy efficiency of 
buildings^ 
^88^C95^0^ 
On ^5 September 198B^,the Council decided to consult the Economic and Social Committee, 
under Article 198 of thelreaty establishing theEuropean Economic Community,onthe 
abovementioned proposal 
The Section for Energy,Nuclear Questions and Research, which was responsible forpreparing 
the Committee'swork on the subject, adopted its opinion on 15 January 1988.Phe rapporteur 
was Air Salmon. 
At its ^5^rd plenary session ^meeting of ^5 February 1988^, the Economic and Social 
Committee adopted the following Opinion by 8^ votes to^with seven abstentions. 
1. Since 19^ the energy conservation policies of the 
CommunityandtheAiemberStateshaveproduceda 
^^improvement in energy efficiency. 
^ Thesepolicies must bepursued resolutely since 
they offer enormous scope for saving energy in the 
Community—as the Council recognised in its resol 
utionofl^ September 198^ on new Community energy 
policy objectives for 1995 ^OJNoC^l,^5,9.198^, 
whichincludeafurther^O^ improvement inenergy 
efficiency. 
^. The building sector consumes the most energy— 
more than ^8^ of final energy consumption in the 
Community ^0 million toe in 1985^The Commission 
estimates that55 million toeByear ^5 million in old 
buildings and^million in new buildings^ could be 
saved in this sector in the wholeof the Community 
e^cludingSpainand Portugal If Spain andPortugal 
are included and if allowance is made for the likely 
improvement in behaviour patterns and the improved 
energyefficiencyofelectrical household appliances,a 
total saving of 80 million toe^year can be expected. 
^. Numerous provisions, mainly in the form of direct 
tives and recommendations, have already been brought 
into force with regard to such matters as thermal insu 
lation, heating facilities in existing buildings and large 
scale financial aid forthe renovation ofbuildings.fhese 
provisions will provideageneral basis foraCommunity 
policy on the rational use of energy in the building 
sector. 
5. The implementation of suchapolicy has received 
the support of the Economic and Social Committee on 
several occasions, not only because it will further the 
objectives laid down inthe field of energy policy but 
also because of its positive effect on employment. l^roD 
moting investment in the rational use of energy is likely, 
above all, to boost growth and employment in the 
building sector. ^. The Commission rightly feels that lack of infor 
mation is anobstacletoinvestment in improving the 
energy efficiency of buildings. 
^. The Council has on several occasions underlined 
the importance of publicising the need for greater 
energy efficiency and for providing full information and 
advice on how to achieve this. 
8 lnaresolutionofl5Aiarchl985^0JNoCB8, 
^.^.1985^ the Council noted that the Commission 
would famine questions relating to the placarding of 
the energy consumptionofbuildingsby aprocessof 
certification, in order to improve the flow of inform 
mation to the parties concerned on the state of the real 
estate market and to give credit to the efforts made by 
the buildersBownerseThis process would allowevery 
prospective tenant or owner to discover the energy 
efficiency of the property in question. 
9. This proposal embodies one of the pledges made 
by the Commission in its Communication to the 
Council of ^November 198^entitled 5AEuropean 
policy for the rational use of energy in the building 
sectorMdoc.COAi^^l^finaip 
10. The Economic and SocialCommittee'ssupport 
foramore rational use of energy and the improvement 
of energy efficiency in thebuildingsector should be 
reiterated. Eurther efforts must be made toconserve 
energy by increasingpublic awareness and changing 
patterns of behaviour, and by installing more efficient 
appliances and lighting. Statistics indicating the savings 
made must also be given wide publicity in order to 
prompt new incentives in support of this policy. 
^oj^DC^^^mom^^D^ 11. however, it is in the planning and design of 
buildings that there is the greatest potential for saving 
energy. Cenerallyspeaking,energy spending accounts 
No C 95/26 Official Journal of the European Communities 11. 4. 88 
for a high proportion of buildings' running costs. This 
spending could be reduced by suitable investment. 
12. The lack of information on the energy efficiency 
of individual buildings is without a doubt a very serious 
obstacle to such investment. A certification procedure 
for the energy consumption of buildings would provide 
this information and could have a major influence 
on economic operators; economically viable work on 
improving the thermal insulation of buildings would be 
encouraged and could in turn create a wealth of jobs 
in the building sector (designers, architects, engineers, 
energy auditors, building contractors, tradesmen and 
their respective workforces). 
According to the Commission, the investment required 
to save 1 million toe/year in the building sector is bound 
to create at least 5 000 jobs/year. 
13. The openings available to third parties for 
financing energy-saving investments should be the sub­
ject of further detailed studies. 
14. Even though the idea of energy audits in the 
building sector should be supported, there is no escap­
ing the fact that the proposal is likely to affect the 
property market and radically change the value of 
existing property in time. 
15. The criteria applicable to different types of build­
ings (new, recent or old, public or private, multi- or 
single-occupant) are not precise enough and may elicit 
negative reactions from interested parties. Greater clari­
fication and precision is required here. 
16. The proposal allows the partial or total exclusion 
of certain public and private buildings used for agricul­
tural or industrial purposes, i.e. the Commission wishes 
to grant the Member States some latitude with regard 
to the proposal's field of application. It is regrettable 
that not all buildings (including public, industrial and 
agricultural buildings) are covered by the proposal, 
because of both the example this would set and the 
energy saving potential. In addition, such a situation is 
certainly not likely to further the effective application 
of the proposed Directive on 1 January 1993. 
17. It can be seen from the above comments that the 
proposal reflects a certain uncertainty and hesitancy; 
this uncertainty and hesitancy should be eliminated in 
order to make the Directive as precise and effective as 
possible. 18. For the benefit of a balance and trouble-free 
application of the Directive and in order to allay the 
concerns which have led to provision for exemptions, 
the Directive should apply to all buildings but its entry 
into force should be staggered according to the different 
types of buildings. Thus, the Directive should not 
include any exemptions and should be widely circulated 
among ministries, local and national authorities, mem­
bers of the building trade, private and public property 
owners' associations, property owners' representatives, 
property management services and consumer organiz­
ations. The aim would be to persuade all parties, 
whether natural or legal persons, to ensure that more 
information is provided about property on the market. 
19. The methodology for the energy audits, as advo­
cated in Annex C to the Commission's Communication 
of 13 November 1984 (cf. point 9 above), should be 
widely circulated along with the Directive among mem­
bers of the relevant trades. 
20. The involvement of the two sides of industry in 
these measures' implementation is particularly desir­
able. 
21. It is not only the parties concerned with energy 
policy which should be called on to define and 
implement a clear, objective and coherent common 
policy for the rational use of energy in the building 
sector and to draw up an information scheme based on 
energy audits. All the parties affected in the building 
sector, as high up as national ministries, should be 
closely involved. 
The twelve Member States' housing ministers should 
meet for the first time at the earliest opportunity in 
order to define a joint policy. 
22. The Commission estimates one that the jobs 
created by making energy-saving investments which 
reduce energy consumption by one million toe/year will 
cut the social costs of unemployment by 50 million 
ECU each year. This will release vast sums of money 
which, during the initial years of application, should 
be earmarked for the rational use of energy in the 
building sector, in the form of either aid for property 
owners and investors or loans/advances for members 
of the relevant trades whishing to adapt to the new 
markets (training of designers and energy auditors, 
equipment for contractors and tradesmen). 
23. Stock will also have to be taken of current meas­
ures which are calculated to improve energy efficiency 
11. 4. 88 Official Journal of the European Communities No C 95/27 
in the building and construction sectors (construction designed to improve the 'common technical language' 
products proposal, public contracts) or which are (e.g. Eurocodes). 
Done at Brussels, 25 February 1988. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
APPENDIX I 
The following amendments were rejected during the discussions: 
1. Point 12, second line 
Add the word 'voluntary' before 'certification procedure'. 
Reasons 
Although support should be given to every measure designed te reduce energy consumption and the public 
should be made aware of the need to improve the energy efficiency of buildings, the measures proposed by 
the Commission should be voluntary, and not mandatory. 
Thus the public should be encouraged more to save energy, by means of information and education campaigns, 
rather than being burdened with new obligations whose costs give cause for concern and whose effects are 
questionable. 
Voting 
For: 42, against: 68, abstentions: 3. 
2. Paragraph 17 
Replace the following text: 
'It can be seen from the above comments that the proposal reflects a certain uncertainty and hesitancy in 
going for a mandatory procedure which is applicable across the board. There is therefore some justification 
for casting doubt on the likely effects of the proposed Directive.' 
Paragraph 18 
Replace by the following: 
'For these reasons it would be better, at least at this stage, for the Commission proposal to take the form of 
strong Council recommendation to the Member States rather than a Council Directive. This recommendation, 
which should apply to all buildings, should be widely circulated among ministeries, local and national 
authorities, members of the building trade, private and public property owners' associations, property owners' 
representatives, property management services and consumer organizations. The aim would be to persuade 
all parties, whether legal or natural persons, to ensure that more information is provided about property on 
the market.' 
No C 95/28 Official Journal of the European Communities 11. 4. 88 
Paragraph 19, first line 
Replace 'Directive' by 'Recommendation'. 
Reasons 
The Opinion already suggests that the scope of the proposal be considerably broadened, e.g. to include public 
buildings. Furthermore there seems to be little awareness in most of the Member States of the importance of 
the energy efficiency of buildings. 
For both practical reasons and for reasons of principle it is therefore highly inadvisable to make the proposed 
arrangements binding at this stage. 
The proposed amendments restore the rapporteur's original text. 
Voting 
For: 60, against: 79, abstentions: 6. 
3. Paragraph 19 
Replace by the following text: 
'The methodology for the energy audits, as advocated in Annex C to the Commission communication of 13 
November 1984 {cf. point 9 above), is considered to be too complex and should be limited to those features 
of the structure which could incorporate cost effective solutions and have a pay back on the investment of 
five years or less.' 
Reasons 
None given. 
Voting 
For: 39, against: 69, abstentions: 2. 
APPENDIX 11 
The following Committee members, present or represented, voted for the Opinion: 
Mr, Mrs, Miss Amato, Arena, Ataide-Ferreira, Bazianas, Beltrami, Bento-Goncalves, Beretta, Bleser, Boddy, 
Lobo-Brandao R. Cal., Bredima-Savopoulou, Burnel, Calvet-Chambon, Carroll, Cavazzuti, Ceballo-Herrero, 
Christie, Gavel, Cortois, Curlis, Dassis, Delhomenie, Delia Croce, Dos Santos, Drilleaud, van Eeckert, 
Elstner, Etty, Eulen, Flum, Frandi, Fresi, Geuenich, Glesener, Gomez-Martinez, Gredal, Green, Hagen, 
Hammond, Hilkens, Horsken, Houthuys, Jenkins, Kelly, Larsen, Laur, Machado von Tschusi, Maddocks, 
Mourgues, Muhr, Muniz-Guardado, Miiller, Murphy, Nielsen B., Nielsen P., Nierhaus, Nieuwenhuize, 
Nugeyre, Orsi, Petropoulos, Proenca, Pronk, Raftopoulos, Rangoni-Machiavelli, Romoli, Roseingrave, Rou-
zier, Saiu, Salmon, Salomone, Santillan-Cabeza, Schmitz, Schopges, Silva, Smith A.R., Smith L.J., Solari, 
Spijkers, Stadelin, Velasco-Mancebo, Yverneau, Zufiaur-Narvaiza. 
The following Committee members, present or represented, voted against the Opinion: 
Mr, Mrs, Miss Arets, Aspinall, Broicher, Campbell, Cashman, Ceyrac, Collas, Alves-Conde, Coyle, van Dam, 
De Tavernier, Dodd, Donck, Flather, Gardner, Giacomelli, Hancock, Hovgaard-Jakobsen, Jaschick, Kaaris, 
Kenna, Low, Masprone, Meyer-Horn, Moreland, Neto da Silva, Noordwal, de Nermann, Pardon, Pearson, 
Pelletier, Perrin-Pelletier, Petersen, Polyzos, Proumens, Ribiere, Riera-Marsa, Robinson, Schade-Poulsen, 
Schnieders, Storie-Pugh, Tamlin, Tukker, Wagner, Whitworth, Williams. 
The following Committee members, present or represented, abstained: 
Mr, Mrs, Miss Corell Ayora, Drago, Dunet, Poeton, Termes-Carrero, Tiemann, Tixier.