COMMISSION STAFF WORKING DOCUMENT EVALUATION of Directive 2010/31/EU on the energy performance of buildings Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2010/31/EU on the energy performance of buildings
Date: 2016-11-30
Institutions: Directorate-General for Energy, European Commission
Subjects: building, building services, energy consumption, energy efficiency, energy saving, improvement of housing, innovation, reduction of gas emissions, technological change

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 30.11.2016  SWD(2016) 408 final   COMMISSION STAFF WORKING DOCUMENT EVALUATION of Directive 2010/31/EU on the energy performance of buildings  Accompanying the document Proposal for a Directive of the European Parliament and of the Council  amending Directive 2010/31/EU on the energy performance of buildings   {COM(2016) 765 final} {SWD(2016) 409 final}  
 
 
TABLE OF CONTENTS  

1. 

INTRODUCTION ........................................................................................................... 4  

1.1.  Purpose of the evaluation .................................................................................. 4  

1.2.  Scope of the evaluation ..................................................................................... 5  

2.  BACKGROUND ............................................................................................................. 5  

3.  EVALUATION QUESTIONS ............................................................................................ 9  

4.  METHOD .................................................................................................................... 10  

4.1.  Sources of information .................................................................................... 10  

4.2.  Regulatory scrutiny board ............................................................................... 11  

4.3.  Robustness ....................................................................................................... 12  

5.  CURRENT SITUATION ................................................................................................ 13  

5.1.  State of implementation ................................................................................... 13  

5.2.  Energy trends ................................................................................................... 14  

5.3.  Broader context interfering with the EPBD impact ........................................ 15  

5.4.  Technological development ............................................................................. 17  

6.  ANSWER TO THE EVALUATION QUESTIONS .............................................................. 17  

6.1.  Effectiveness .................................................................................................... 17  

6.2.  Efficiency ........................................................................................................ 19  

6.3.  Relevance ........................................................................................................ 23  

6.4.  Coherence ........................................................................................................ 24  

6.5.  EU added value ................................................................................................ 25  

7.  CONCLUSION ............................................................................................................. 25  

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TABLE OF ANNEXES  

ANNEX 1  ACRONYMS ..................................................................................................... 28  

ANNEX 2  DEFINITIONS ................................................................................................... 29  

ANNEX 3 

INTERVENTION LOGIC AND PRESENTATION OF THE INITIATIVE ................... 31  

ANNEX 4  PROCEDURAL INFORMATION ......................................................................... 38  

ANNEX 5  STATE OF IMPLEMENTATION ......................................................................... 49  

ANNEX 6  ECONOMIC CONTEXT ..................................................................................... 52  

ANNEX 7  COST-EFFECTIVE SAVING POTENTIALS FOR 2020 ......................................... 55  

ANNEX 8  TECHNOLOGICAL PROGRESS ......................................................................... 57  

ANNEX 9  EVALUATION OF THE EFFECTIVENESS ........................................................... 61  

ANNEX 10  EVALUATION OF THE EFFICIENCY ................................................................. 75  

ANNEX 11  EVALUATION OF THE RELEVANCE ................................................................. 95  

ANNEX 12  EVALUATION OF THE COHERENCE ................................................................ 99  

ANNEX 13  EVALUATION OF THE EU ADDED VALUE ..................................................... 105  

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1. 

INTRODUCTION  

1.1.  Purpose of the evaluation  

Pursuant to the Commission Better Regulation Framework1, the present evaluation aims 
at a thorough assessment of the Energy Performance of Buildings Directive ('the EPBD' 
or  'the  Directive')2  in  the  light  of  experience  gained  and  progress  made  during  its 
application,  against 
the  following  criteria:  effectiveness,  efficiency,  relevance, 
coherence, and EU added value.  

Energy efficiency, as a contribution to the moderation of energy demand, is one of the 
key  dimensions  to  achieve  a  resilient  Energy  Union,  based  on  a  forward-looking 
climate  policy.  In  this  context,  the  European  Commission  decided  to  pay  particular 
attention  to  sectors  with  an  important  potential  for  further  efficiency  increases,  in 
particular buildings.  

The  existing  EU  core  instruments  in  this  context,  the  EPBD,  the  Energy  Efficiency 
Directive3  (EED),  and  several  product  regulations  laying  down  minimum  energy 
performance  standards  and  putting  energy  performance  information  on  labels4  are 
delivering  tangible  results  and  have  proved  to  be  a  solid  basis  for  achieving  energy 
savings  in  the  buildings  sector5.  Amongst  them,  the  EPBD  is  the  main  legislative 
instrument at EU level addressing the energy used in buildings.  

The evaluation of the EPBD is a direct follow-up to the Communication on an Energy 
Union6, which asked for a review and possible revision of the Directive by the end of 
2016.  The  review  of  the  Directive,  including  the  'Smart  Finance  for  Smart  Buildings' 
initiative is one of the specific actions to improve the energy performance of buildings 
in  the  EU  included  in  the  Roadmap  for  the  Energy  Union7.  The  evaluation  equally 
delivers  on  the  legal  obligation  under  Article  19  of  the  Directive,  which  asks  for  an 
evaluation to be completed by 1 January 2017.  

Acronyms and definitions of specific terms in use in the present document are provided 
respectively in Annexes 1 and 2.  

1 

2 

3 

4 

5 

6 

7  

Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and  the  Committee  of  the  Regions  -  Better  regulation  for  better  results  -  An  EU  agenda; 
COM(2015) 215 final of 19 May 2015. 
Directive  2010/31/EU  of  the  European  Parliament  and  of  the  Council  of  19  May  2010  on  the  energy 
performance of buildings (recast); OJ L 153, 18.6.2010, p. 13-35.  
Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency, 
amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC; OJ L 
315, 14.11.2012, p. 1-56.  
Regulations adopted pursuing Directives 2010/30/EU on energy labelling and 2009/125/EU on ecodesign, for 
instance Regulations 811/2013 and 812/2013 on the energy labelling for heaters and combination heaters and 
on the energy labelling of water heaters and Regulations 813/2013 and 814/2013 on the ecodesign for heaters 
and combination heaters and on the ecodesign water heaters.  
Communication  from  the  commission  to  the  European  Parliament  and  the  council  Energy  Efficiency  and  its 
contribution to energy security and the 2030 Framework for climate and energy policy; COM(2014) 520 final 
of 23 July 2014.  
Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee, the Committee of the Regions and the European Investment Bank  - A framework strategy 
for a resilient energy union with a forward-looking climate change policy; COM(2015) 80 final of 25 February 
2015.  
Roadmap for the energy union; Annex 1 to COM(2015) 80 final of 25 February 2015.  

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1.2.  Scope of the evaluation  

The present evaluation aims at a thorough assessment of the EPBD in its entirety and 
for the whole European Union (EU).  

Complementing  the  EPBD,  the  EED  required  Member  States  to  establish,  by  April 
2014,  national  long-term  strategies  for  mobilising  investment  in  the  renovation  of  the 
national stock of residential and commercial buildings, both public and private. These 
strategies  bring  together  different  elements  of  the  EPBD  and  of  the  EED  and  their 
assessment8 is reflected in the current evaluation.  

As  it  will  be  further  explained  in  below  Section 2,  the  EPBD  recasts  Directive 
2002/91/EC9,  from  which  it  retained  the  objectives,  principles  and  several  provisions. 
The  application  deadlines  for  Directive  2002/91/EC  and  for  the  EPBD  were 
respectively 9 January 2006 and 9 January 2013. The transposition measures notified by 
Member  States  to  transpose  the  EPBD  were  adopted  from  2010  onwards10.  A  large 
number  of  legislative  measures  transposing  the  new  provisions  of  the  EPBD  were 
adopted  by  amending  or  recasting  pre-existing  national/regional  legislation  adopted 
pursuant  to  Directive  2002/91/EC.  At  EU  level,  the  application  of  transposition 
measures must therefore be seen as a progressive and continuous process, for which no 
precise  starting  point  after  2006  can  be  established.  For  these  reasons,  the  evaluation 
examines the impact of Directive 2002/91/EC and of the EPBD, looking in more detail 
at  the  changes  introduced  by  the  recast  that  created  specific  new  obligations  for 
Member States.  

In  order  to  detect  any  change  of  trends,  the  evaluation  looks  at  energy  consumptions 
and greenhouse gas (GHG) emissions during the period from 1990 until today, on the 
basis of the latest available data. The Impact Assessment of the EPBD11 referred to the 
2007  update  of  the  PRIMES  reference  scenario12,  2007  is  therefore  used  as  reference 
year.  

2.  BACKGROUND  

The EPBD aims at promoting the improvement of the energy performance of residential 
and  non-residential  buildings  within  the  Union,  taking  into  account  outdoor  climatic 
and local conditions, as well as indoor climate requirements and cost-effectiveness.  

The  EPBD  defines  the  energy  performance  of  a  building  as  the  amount  of  primary 
energy needed, in the use phase, to meet the energy demand associated with a typical 
use  of  the  building,  which  includes,  inter  alia,  energy  used  for  heating,  cooling, 
ventilation, hot water and built-in lighting (mainly in non-residential buildings).  

8  

Synthesis  Report  on  the  assessment  of  Member  States'  building  renovation  strategies,  2015,  European 
Commission (JRC) 

9   Directive  2002/91/EC  of  the  European  Parliament  and  of  the  Council  of  16  December  2002  on  the  energy 

performance of buildings; OJ L 1, 4.1.2003, p. 65–71.  

10   For example, the Danish Building Regulations were updated on 12 December 2010, the French RT2012 (new 

thermal regulation for new buildings) adopted on 26 October 2010, etc.  

11   Communication Staff Working Document of 13 November 2008 accompanying the proposal for a recast of the 

EPBD – Impact assessment SEC(2008)2864 

12   European energy and transport trends to 2030, update 2007, European Commission (written by E3M-Lab) 

5 

 
                                                 
The  intervention  can  be  outlined  as  a  three-pronged  approach,  as  summarised  by 
Figure 1:  
  Creating  a  demand-driven  market  for  energy  efficient  buildings,  with  the 

provision of information through certification and inspection. 
The  EPBD  does  not  mandate  any  investment  but  addresses  information  barriers. 
National  Energy  Performance  Certificates  schemes  must  be  in  operation  for  the 
issue,  hand-over  to  the  buyer  or  tenant  and  display  of  energy  performance 
certificates  (EPCs)  and  for  the  issue  and  hand-over  to  the  owner  or  tenant  of 
inspection  reports.  EPCs  and  inspection  reports  intend  to  provide  information  to 
building owners and tenants on the energy performance of their buildings, heating 
and  air-conditioning  systems,  and  on  effective  ways  to  improve  these  through 
building  renovation  works.  Qualification  schemes  for  experts,  quality  control  and 
enforcement  must  be  ensured,  in  particular  through  national  independent  control 
systems  that  Member  States  must  set  up  in  line  with  the  EPBD.  Providing  users 
with the relevant information help them to take the best decisions;  

  Preventing  that  sub-optimal  investments  are  made  with  minimum  energy 

performance requirements set at cost-optimal level. 
The EPBD requires Member States to set and ensure minimum energy performance 
requirements  for  all  building  works:  new  construction,  major  renovation  of 
buildings,  and  the  retrofit  of  building  elements  (e.g.  windows,  technical  building 
systems). These minimum requirements must be periodically reviewed by Member 
States.  A  delegated  act13,  accompanied  by  guidelines14,  establishes  a  harmonised 
comparative  methodology  framework  for the calculation of cost-optimal levels  of 
requirements for buildings and building elements. The reference to cost-optimality 
ensures  reasonably  ambitious  levels  of  requirements.  At  the  same  time,  Member 
States  must  ensure  that,  from  the  end  of  the  decade  onwards,  only  nearly  zero-
energy  buildings  (NZEB)  are  built.  Enforcement  mechanisms  and  rules  on 
penalties must be in place;  

  Further  catalysing  the  increase  in  energy  performance  of  buildings  and  the 
transition  to  nearly  zero-energy  buildings  with  measures,  including  of 
financial and fiscal nature. 
With  the  support  of  the  EU,  the  EPBD  requires  Member  States  to  establish 
measures and instruments, including those of financial and fiscal nature, to ensure 
the availability of capital needed to cover the costs associated with the upgrade of 
the  energy  performance  of  buildings.  Article  7  of  the  EED  acts  directly  on  the 
renovation rate, requiring actual energy savings and therefore encouraging building 
renovation to take place in practice. Article 4 of the EED on renovation roadmaps 
acts indirectly on the renovation rate and on enhancing access to finance. It requires 
Member States to map their building stock and define a roadmap for its renovation, 
without  actual  obligation 
those  measures.  These  measures 
complement  the  EPBD,  which  acts  on  the  depth  of  renovation  and  contains  no 
requirements on how many buildings to be renovated, or by when.  

implement 

to 

13  Commission  Delegated  Regulation  (EU)  No  244/2012  of  16  January  2012  establishing  a  comparative 
methodology framework for calculating cost-optimal levels of minimum energy performance requirements for 
buildings and building elements; OJ L 81, 21.3.2012, p. 18–36. 

14  Guidelines  accompanying  Commission  Delegated  Regulation  (EU)  No  244/2012  of  16  January  2012;  OJ  C 

115, 19.4.2012, p. 1–28. 

6 

 
 
 
 
                                                 
Figure 1: Outline of the intervention  

The EPBD recasts the previous Directive 2002/91/EC by introducing new aspects while 
keeping,  and  in  some  cases  reinforcing,  the  objectives,  scope,  principles  and  several 
provisions of the original Directive.  

The recast had the following specific objectives:  
  Provide  a  simple  and  unambiguous  legal  framework  that  will  provide  clear 
guidance and ease the transposition and implementation of Directive 2002/91/EC;  

  Ensure that the policy instruments used stimulate further energy savings;  
  Ensure  that  the  measures  have  a  wider  coverage  of  the  EU  buildings  stock  and 

relevant energy consumption but are at low additional cost;  

  Ensure that buyers/tenants/owners receive good quality information at a reasonable 
cost  on  the  energy  performance  of  buildings  and  about  the  performance  of  their 
heating and air-conditioning systems;  

  Establish  a base for cost-effective energy performance requirements for  buildings 

or for their comparison;  

  Stimulate the public sector to show good example in buildings' energy efficiency.  

The EPBD has continued a trend towards a more holistic approach for a more efficient 
energy use in the building sector. The integrated approach is crystallised in the common 
general  framework  for  the  calculation  of  energy  performance  of  buildings  annexed  to 
the  EPBD,  encompassing,  in  addition  to  the  quality  of  insulation  of  the  building, 
heating installations, cooling installations, energy for ventilation, lighting installations, 
position  and  orientation  of  the  building,  heat  recovery,  active  solar  gains  and  other 

7 

 
  
renewable energy sources.  The choice of an integrated approach was explained in  the 
explanatory  memorandum  of  the  original  Commission's  proposal15  in  2001,  which 
remains relevant today.  

As  regards  elements  reinforced  with  the  recast,  an  effort  was  made  to  ensure  the 
continued  implementation  of  Directive  2002/91/EC  by  keeping  its  main  provisions  as 
they were already delivering.  

More specifically, the recast introduced the following new provisions that did not exist 
in Directive 2002/91/EC:  
  Several  new  definitions,  including  the  concept  of  major  renovation,  multiple 
references  to  renewable  energy  sources  and  the  framework  definition  of  nearly 
zero-energy buildings;  

  Article 5 on the calculation of cost-optimal levels of minimum energy performance 

requirements;  

  Article 8 on technical buildings systems;  
  Article 9 on nearly zero-energy buildings (NZEB);  
  Article 10 on financial incentives and market barriers;  
  Article 16 on reports on inspection of heating and air-conditioning systems; and  
  Article  18  on  independent  control  systems  and  Article  27  on  penalties,  which  in 

combination provide for the establishment of enforcement mechanisms.  

In addition, the Directive reinforced significantly the following provisions:  
  Article  6,  by  requiring  that  the  assessment  of  technical,  environmental  and 
economic  feasibility  of  high-efficiency  alternative  systems  such  as  decentralised 
energy  supply  or  district  solutions  is  documented  and  available  for  verification 
purposes;  

  Article  7,  by  removing  the  1000  m²  threshold  for  minimum  requirements  in 

existing buildings when they undergo major renovation;  

  Articles  11  to  13  on  energy  performance  certification  systems,  in  particular  as 
regards  having  recommendations  adapted  to  the  specific  building  and  public 
buildings to lead by example through the display of energy performance certificates 
(EPC); and  

  Article 14 on inspections on heating systems by enlarging the scope of obligations 
to  regularly  inspect  boilers  to  the  inspection  of  all  accessible  parts  of  the  heating 
systems.  

The  intervention  logic  and  a  more  detailed  description  of  the  main  provision  of  the 
EPBD can be found in Annex 3.  

15   “With today's highly insulated new buildings and the trend towards low energy houses, these additional factors 
play an increasingly large role and should therefore be included in regulatory provisions. Such an integrated 
approach will give more flexibility to designers to meet energy reduction standards in the most cost-effective 
way.  […]  A  common  approach  on  this  basis  would  contribute  to  a  more  level  playing  field  as  regards  the 
efforts  made  by Member  States  to  achieve  energy  savings  in  the  buildings  sector.  It  would  also  facilitate  the 
comparison  of  buildings  throughout  the  EU  for  prospective  users  and  make  it  easier  for  designers  and 
constructors to apply standards in other Member States.”, COM(2001)0226 final of 15 May 2001, proposal for 
a Directive of the European Parliament and of the Council on the energy performance of buildings. 

8 

 
                                                 
By building on the structure and provisions of the Directive 2002/91/EC, as well as the 
implementing measures already undertaken by Member States, the transposition of the 
EPBD was expected to be eased, whilst at the same time tapping a larger share of the 
energy saving potential and other related benefits.  

The  recast  intended  to  facilitate  transposition  and  implementation.  The  Impact 
Assessment16 estimated the minimum total impacts as follows:  
 

60 – 80 Mtoe/year energy savings by 2020, i.e. a reduction of 5-6% of the EU final 
energy consumption in 2020;  
160 to 210Mt/year CO2 savings by 2020, i.e. 4-5% of EU total CO2 emissions in 
2020;  
280,000 (to 450,000) potential new jobs by 2020, mainly in the construction sector, 
energy certifiers, auditors and inspectors of heating and air-conditioning systems.  

 

 

During  the Impact Assessment preceding the EPBD, based on the 2007 update of  the 
PRIMES  reference  scenario17,  the  EU  wide  cost-effective  energy  efficiency  potential 
was estimated at 28% cost-efficient energy savings by 2020 for the sector (or 143 Mtoe 
final energy), which is equivalent to 11% of total EU final energy consumption in 2020.  

3.  EVALUATION QUESTIONS  

The evaluation addresses specifically the following questions.  

Effectiveness  
  To what extent has the Directive achieved its objectives, e.g. to improve the energy 
performance  of  buildings  within  the  Union,  taking  into  account  outdoor  climatic 
and local conditions, as well as indoor climate requirements and cost-effectiveness?  
  Which provisions have been most appropriate for improving energy performance of 
buildings? To what extent has the lack of fixed EU-wide levels (requiring instead 
that  Member  States  lay  down  the  mechanisms  for  implementing  its  provisions) 
been effective and why?  

  What  main  factors,  in  particular  related  to  national  implementation,  have 

influenced, or stood in the way of, achieving these objectives?  

  What results, if any, did the EPBD achieve beyond its main aim to promote energy 
performance,  for  example  towards  job  creation  or  retention,  incorporation  of 
renewable  energy  sources  in  buildings  or  driving  innovation  in  building-related 
technology?  

  Did the Directive cause any other unexpected or unintended changes?  

Efficiency  
  What are the costs and benefits associated with the implementation of the EPBD?  
  To what extent have the EPBD and the obligations included therein been efficient 

means of achieving a more energy efficient European building stock?  

  To what extent are the costs involved with implementing the EPBD justified given 

the benefits which have been achieved?  

16  Communication Staff Working Document of 13 November 2008 accompanying the proposal for a recast of the 

EPBD – Impact assessment SEC(2008)2864 
European energy and transport trends to 2030, update 2007, European Commission (written by E3M-Lab) 

17 

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 

Is  there  potential  to  simplify  and  deliver  the  objectives  of  the  Directive  more 
efficiently? How?  

  Have  there  been  technical  or  other  developments  since  the  elaboration  of  the 
Directive  that  could  contribute  to  achieving  the  objective  more  efficiently,  for 
example in the context of the recent EEFIG report18?  

  To  what  extent  does  the  Directive  allow  for  efficient  policy  monitoring  (e.g. 
reporting  mechanisms)?  How  far  do  the  reporting  processes  allow  for  efficient 
collection of all relevant information?  

Relevance  
  Do the EPBD objectives still correspond to the needs of the policy area concerned?  
  To what extent have the EPBD objectives proved relevant to the needs identified at 

the outset?  

  Which  other  approaches  than  those  set  currently  in  the  EPBD  became  more 
important  for  improving  energy  efficiency  in  buildings,  including  solutions  at 
district and city levels?  

  What are citizens' expectations for the role of the EU to ensure an efficient building 

stock?  

Coherence  
  To what extent are the EPBD provisions internally coherent? Do provisions overlap 

or contradict, do they co-act as intended?  

  Does the EPBD contradict other EU interventions with similar objectives?  
  To what extent can effects be linked to provisions in other EU legislation?  
  Which effects had the EPBD on areas targeted by other EU legislation?  
  To  what  extent  are  there  any  gaps  between  the  EPBD  and  other  relevant  EU 
legislation or initiatives that could prevent the objectives of the EPBD to be met?  

EU added value  
  What  has  been  the  EU  added  value  of  the  Directive,  and  do  the  issues  addressed 

continue to require action at EU level?  

  Why would the EPBD objectives be better achieved by EU action?  

4.  METHOD  

4.1.  Sources of information  

Following  the  Evaluation  Roadmap  published  in  July  201519,  the  evaluation  has  been 
carried out on the basis of information and data collected from different sources.  

Stakeholders were consulted through an open internet-based public consultation that ran 
from  30  June  2015  to  31  October  2015  and  thematic  technical  workshops  on  specific 
topics took place from June 2015 to January 2016.  

18   Energy Efficiency Financial Institutions Group, "Energy Efficiency – the first fuel for the EU Economy. How 

19 

to drive new finance for energy efficiency investments", February 2015, www.eefig.eu 
http://ec.europa.eu/smart-
regulation/roadmaps/docs/2016_ener_023_evaluation_energy_performance_of_buildings_directive_en.pdf  

10 

 
                                                 
Different studies supported the monitoring of the implementation of the Directive and 
provide relevant input to this evaluation. When the findings of these studies are used in 
the current evaluation, reports are explicitly referenced.  

A  specific  study  for the  evaluation of  the  application  of  the  EPBD  and  assessment  of 
policy  options  and  resulting  energy  related  impacts  in  the  framework  of  the  EPBD 
review delivered the summary report following the public consultation20 and informed 
the present evaluation.  

Information on the implementation of the EPBD is also available from the work of the 
EPBD  Concerted  Actions  and,  according  to  the terms  of  Article  19  of  the  EPBD,  the 
work of the Energy Performance of Buildings Committee.  

In  addition  to  the  consultation  activities  involving  the  European  Commission,  this 
evaluation  made  use  of  other  sources  of  information,  e.g.  research  papers,  identified 
through  literature  review.  When  such  sources  of  information  are  used  in  the  current 
evaluation, they are explicitly referenced.  

The Secretariat General (SG) has set up an ISG on the review of the EED, the EPBD 
and  the  'Smart  Financing  for  Smart  Buildings'  initiative.  The  group  met  in  total  nine 
times in support of the full review process, from 30 April 2015 to 28 June 2016.  

More information on the consultation with stakeholders and the external expertise used 
for the evaluation is provided in Annex 4.  

4.2.  Regulatory scrutiny board  

The draft evaluation was submitted to the scrutiny board on 2 March 2016.  

The  regulatory  scrutiny  board  met  on  the  6  April  2016  and  issued  an  opinion  which 
supported  further  improvement  of  the  evaluation  report  with  respect  to  the  following 
key aspects:  
(1)  The  assessment  of  coherence  should  be  improved  and  conclusions  supported 
with evidence. In doing so, the report should better explain the scope, the policy 
context  and  the  coherence  with  other  energy  efficiency  initiatives  and 
evaluations.  It  is  sensible  that  a  fitness  check  of  the  Directive  (together  with 
other related instruments) be undertaken in the next round of the policy cycle to 
explore better the coherence between different but related policy instruments;  

(2)  The report should clarify the effectiveness of the Directive in reaching its policy 
objectives, in particular those specified in the 2008 Impact Assessment. To what 
extent  can  the  available  evidence  be  used  to  attribute  energy  savings  in  the 
buildings  sector  to  this  directive  as  opposed  to  other  instruments  such  as 
financing  instruments,  the  energy  efficiency  directive  and  the  effort  sharing 
decision etc.;  

(3)  The  evidence  supporting  the  efficiency  assessment  of  the  Directive  should  be 
better  demonstrated,  in  particular  regarding  the  cost-effectiveness.  In  this 
context, the report should explain upfront any limitations and justify them;  

20   Public  Consultation  on  the  Evaluation  of  the  EPBD  –  Final  synthesis  report,  2015,  European  Commission 

(written by Ecofys) https://ec.europa.eu/energy/sites/ener/files/documents/MJ-02-15-954-EN-N.pdf 

11 

 
                                                 
(4) 

In  view  of  the  envisaged  impact  assessment,  the  reasons  behind  the  slow 
progress in the area of building renovations should be better elaborated as well 
as those aspects of implementation which have been found to be problematic;  

(5)  The lack of available data should be explained, including clarifications on how 
the problem will be dealt with in the future. The report should be shortened and 
streamlined, in order to fulfil the Better Regulation guidelines requirements.  

The  Evaluation  was  redrafted  in  response  to  the  Board  recommendations,  which  are 
addressed by reducing the number of pages of the main report and further elaborating 
the following sections:  
(1) 
(2) 
(3) 
(4) 
(5) 

Section 6.4 and Annex 12;  
Section 6.1 and Annex 9;  
Section 6.2 and Annex 10;  
Sections 5.3 and 6.2;  
Section 5.2.  

The  Annexes  have  also  been  reformulated  to  contain  all  background  information  and 
supporting evidence to the findings presented.  

4.3.  Robustness  

Although the review of the EPBD comes arguably early in the life of the Directive, its 
scope,  objectives,  and  some  core  provisions  already  existed  in  Directive  2002/91/EC. 
There  is  therefore  more  experience  with  transposition  and  implementation  than  the 
transposition  date  of  July  2012  and  the  application  date  of  January  2013  seem  to 
suggest. Moreover, the EPBD Concerted Action has accumulated more than ten years 
of  practical  experience  on  national  implementation  of  the  Directives  and  compiled 
numerous best practices. As of 2016, the Concerted Action has produced two detailed 
reports on national and EU-wide lessons from the transposition and implementation of 
the EPBD.  

The present evaluation made use of the most recent sources of information. However, 
the  granularity  and  level  of  quantification  in  the  analysis  of  impacts  of  the  EPBD  is 
substantially constrained by the availability of quantitative data.  

Global  annual  energy  data  for  2014 were  published  by  Eurostat  only  very  recently  (9 
June 2016) and there is limited available data on disaggregated energy consumption in 
the  households  sector  and  in  the  services  sector.  It  is  therefore  not  possible,  for  the 
years  2014  and  after,  to  segregate  the  specific  effect  of  the  EPBD  on  energy 
consumption  from  other  influencing  factors  such  as  climate  variations,  economic 
activity, behaviour, etc.  

This lack of reliable and consistent data is seen as a major challenge and was already 
identified as a limitation when carrying out the Impact Assessment for the EPBD21.  

For  the  residential  sector,  the  final  energy  consumption  in  households  and  its 
disaggregation  per  fuel  are  currently  used  by  Eurostat  as  proxy  indicators  in  the  key 

21   Communication Staff Working Document of 13 November 2008 accompanying the proposal for a recast of the 

EPBD – Impact assessment SEC(2008)2864 

12 

 
                                                 
area 'Improving buildings' of the resource efficiency initiative22. More detailed data on 
energy consumption in households (e.g. energy for space heating, space cooling, water 
heating and cooking) will be collected in the future under the Commission Regulation 
(EU) No 431/2014  of 24 April 2014 amending Regulation (EC) No 1099/2008  of the 
European  Parliament  and  of  the  Council  on  energy  statistics,  as  regards  the 
implementation  of  annual  statistics  on  energy  consumption  in  households.  The  first 
reference  year  for  mandatory  reporting  under  this  Regulation  will  be  2015.  In  2014, 
only 12 Member States have voluntarily reported data.  

For  the  non-residential  sector,  most  available  data  cannot  be  considered  to  have  the 
same quality grade as official statistics23.  

Regarding  costs  and  benefits  of  the  measures  adopted  pursuant  to  the  EPBD, 
quantitative  analysis  was  constrained  by  the  available  scattered  information.  The 
following  evaluation  of  this  specific  aspect  is  therefore  chiefly  based  on  a  qualitative 
analysis,  cross-checking  information  from different sources and in  particular  from the 
public consultation and the specific consultation of Member States.  

Nevertheless,  the  cost-benefit  of  measures  is  expected  to  be  balanced  thanks  to  the 
strong  link  between  the  provisions  of  the  EPBD  and  cost-optimality,  while  leaving 
some flexibility in this respect:  
  Member States are not required to set minimum energy performance requirements 

which are not cost-effective over the estimated economic lifecycle,  

  Member  States  can  set  up  criteria  to  exempt  the  application  of  minimum  energy 
performance  requirements  for  buildings  and  building  elements,  when  this  is  not 
technically, functionally and economically feasible,  

  Member  States  can  opt  to  adopt  equivalent  measures  to  the  regular  inspection  of 

heating and air conditioning systems.  

Combined  with  the  additional  information  collected  under  the  above-mentioned 
Commission  Regulation  (EU)  No  431/2014,  the  EU  Building  Stock  Observatory, 
currently  under  development  by  the  European  Commission  should  significantly 
improve  the  situation  and  be  an  essential  tool  for  monitoring  and  steering  the 
improvement of energy efficiency in buildings and to support the implementation of the 
EPBD.  

5.  CURRENT SITUATION  

5.1.  State of implementation  

Full implementation and strict enforcement of existing energy and related legislation is 
the  first  priority  to  establish  the  Energy  Union.  As  highlighted  by  the  2016  Annual 
report on monitoring the European Union law24, the Commission  closely  monitors  the 
application of the acquis in the climate and energy policy areas. It undertook systematic 
checks on Member States' transposition of, and conformity with the EPBD.  

22   Eurostat  data  code  "t2020_rk200  -  Final  energy  consumption  in  households"  and  data  code  "t2020_rk210  - 

Final energy consumption in households by fuel" 

23   Robust building data: A driver for policy development, 2013, GBPN 
24  

33rd Annual Report on monitoring the application of EU law (2015); COM(2016) 463 final of 15 July 2016. 

13 

 
                                                 
EU  Pilot  dialogues  and  infringement  procedures  are  systematically  launched  for  non-
compliance  with  the  EPBD,  with  positive  outcomes.  Despite  these  efforts,  correct 
transposition  is  not  yet  ensured  for  all  provisions  and  countries.  Discussions  on 
conformity issues are still necessary and going on. These activities and their results are 
detailed in Annex 5.  

Beside these legal enforcement activities, the European Commission established a joint 
initiative  with  representatives  from  the  national  implementation  bodies  in  order  to 
enhance the sharing of information and exchange of experiences from national adoption 
and  implementation.  Since  2005,  the  Concerted  Action  EPBD  has  been  the  technical 
forum for national representatives working on the transposition and implementation of 
the EU directive into national measures and policies.  

Evidence  shows  that  the  Concerted  Action  has  substantially  contributed  to  a  better 
understanding  of  the  implementation  challenges  and  the  pro  and  cons  of  various 
strategies to implement the EPBD requirements in a cost effective way into the national 
context of Member States. The latest report of the EPBD Concerted Actions25 gives an 
overview  of 
the  status  of 
implementation in all 28 Member States plus Norway.  

thematic  and  describes 

the  achievement 

in  five 

5.2.  Energy trends  

The EU Reference scenario 2016 (REF2016)26 constitutes the latest projections for EU 
and  Member  States  energy,  transport  and  greenhouse  gas  (GHG)  emission-related 
developments  up  to  2050.  It  does  so  by  taking  into  account  global  and  EU  market 
trends and the energy and climate policies already adopted by the EU and its Member 
States, including the EPBD.  

According  to  REF2016,  total  2020  final  energy  consumption  in  the  residential  and 
tertiary sectors would be 485 Mtoe, instead of the 541 Mtoe projected by the baseline 
2007 update of the PRIMES reference scenario, i.e. a 56 Mtoe reduction of final energy 
consumptions for these two sectors, close to 60-80 Mtoe total impacts expected out of 
the recast.  

REF2016 indicates that the distribution of final energy consumption across sectors will 
remain broadly identical, keeping with around 40% of the final energy consumption for 
these two sectors.  

This  reference  scenario  confirms  that  electrification  is  a  persisting  trend,  due  to  a 
growing electricity demand, the electrification of heating (heat pumps) and, to a limited 
extent, the electrification of the transport sector.  

In  parallel,  the  share  of  electricity  generation  from  renewable  energy  in  total  gross 
electricity generation increased from 14.4 % in 2004 to 27.5 % in 201427. In the future, 
the  EU  power  generation  mix  is  expected to  keep  changing  considerably  in  favour of 
renewables.  

25 
26 

Implementing the Energy Performance of Buildings Directives, 2016, Concerted Action EPBD 
EU  Reference  Scenario  2016  –  Energy,  transport  and  GHG  emissions  –  Trends  to  2050,  2016,  European 
Commission. 

27   Eurostat, ref. indicator "nrg_ind_335a" 

14 

 
                                                 
For  2020,  the  reference  scenario  reports  a  total  primary  energy  decrease  by  18.4% 
(relative  to  the  2007  baseline),  still  falling  slightly  short  of  the  2020  indicative  EU 
energy efficiency target of 20%.  

5.3.  Broader context interfering with the EPBD impact  

It should be noted that these results are achieved with worse economic conditions than 
the  underlying  assumptions  of  the  2007  reference  scenario.  This  scenario,  used  as 
reference for the 2008 Impact Assessment proved to be overestimated:  
  The  2007  Primes  scenario  was  ‘pre-crisis’  and  assumed  a  2.5%  increase  of  GDP 

per year; and  

  The rate of renovation was equally overestimated as influenced by the ‘pre-crisis’ 

scenario.  

The  EPBD,  and  in  particular  energy  performance  certificates  and  inspection  reports, 
addresses informational barrier to create a demand-driven market. Under the EPBD, the 
decision to take action to upgrade the energy performance of buildings is entirely left to 
market  actors.  The  minimum  energy  performance  requirements  set  under  the  EPBD 
only apply when construction or renovation work is performed. The broader economic 
context plays a role in the magnitude of the impacts of the EPBD.  

As shown in Annex 6, the construction sector was strongly hit by the global crisis with 
a  decrease  of  economic  output  and  absolute  number  of  jobs.  It  has  not  yet  fully 
recovered from it. As of May 2015 it was still 35% points below pre-crisis levels.  

On  the  other  hand,  new  business  opportunities  generated  by  EU  energy  efficiency 
legislation is estimated at some €124 billion over the 2010-2014 period, corresponding 
to  about  5%  of  the  total  value  of  the  residential  building  market28.  This  constitutes  a 
meaningful contribution to sustain the level of activity during a difficult period for the 
construction industry, in particular towards SMEs. However, this was a period of low 
demolition rates (0.1-0.2% per year), limited new construction activities (0.4-1.1% per 
year) and very low refurbishment rates (0.4-1.2% per year).  

With construction rate significantly higher than the demolition rates, the building stock 
is naturally expanding in size. This means more space to heat, cool, ventilate, etc. The 
increasing size is bound to increase its energy consumption and hence to the increase in 
energy related carbon-dioxide emissions.  

At current construction and demolition rates around 70% of the buildings that will be 
in-use  in  2050  are  already  built.  This  confirms  that  buildings  are  assets  with  a  long 
lifetime, much longer than appliances, or cars.  

As presented in  Annex 7, at least  20-65 Mtoe of cost-effective saving potential in the 
residential and tertiary sectors remain untapped for 2020, 80-85% of which are within 
the  scope  of  intervention  of  the  EPBD.  The  tighter  minimum  energy  performance 
requirements and high compliance rates of new buildings (typically above 80%)29, mean 
that  the  large  saving  potentials  remains  mostly  in  the  existing  buildings  stock. 

28   Supporting  study  for  the  Fitness  Check  on  the  construction  sector:  EU  internal  market  and  energy  efficiency 
legislation, 2016, European Commission (Written by Economisti Associati, Milieu, CEPS, BPIE, DBRI) 
29   Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 

by ICF international) 

15 

 
                                                 
Increasing  the  rate,  quality  and  effectiveness  of  building  renovation  is  certainly  the 
biggest challenge for the coming decades.  

The reason for the lack of uptake of cost-effective renovation can be found in the split 
incentives  associated  with  tenure  status,  the  general  lack  of  understanding  among 
households  of  their  energy  use,  and  potential  savings  related  to  different  energy 
efficiency measures30,31 as well as insufficient knowledge on financial and other benefits 
related to building renovation.  

In this context, present investment flows in energy efficiency and renewable energy in 
buildings  are  below  half  of  the  investments  needed32.  Deep  renovation  of  buildings 
requires significant up-front cost for building  owner-occupiers,  who represent 70% of 
the EU building stock. The capacity of households to pay for this up-front cost depends 
on their level of savings, income, debt capacity, credit worthiness, their access to public 
support schemes or other financing instruments and availability of attractive financing 
products on the market.  

Such attractive financing products are missing, usually because financial institutions do 
not  incorporate  all  the  benefits  of  energy  efficiency  investments  (higher  asset  value, 
better  liquidity  position  of  borrowers,  lower  credit  default  rate  of  renovation  loans 
compared to standard loans) into their commercial offering.  

Split incentives also play an important role. 30% of the EU population live as tenants, 
according  to  Eurostat.  Landlords  may  have  little  incentives  to  invest  in housing  stock 
improvements as return on capital employed can be limited.  

The  above  is  also  valid  for  the  non-residential  sector  and  in  particular  for  SMEs. 
Financing  mechanisms  such  as  third  party  financing  where  repayments  are  partly 
funded by the energy savings over a long period are not affordable and practical for all. 
Split  incentives  are  also  present  in  office  buildings  and  other  rented  space  such  as 
shopping malls. Split incentives are indirectly addressed by Article 7 of the EED, acting 
on  the  renovation  rate  (there  are  no  specific  provisions  in  the  EPBD  to  address  this 
issue).  

In the public buildings segment, the level of investment financed through commercial 
finance (outside public finance grants) is influenced by Eurostat accounting rules and of 
Stability and Growth Pact rules on flexibility. Further, lack of capacity of public sector 
to  aggregate  small  scale  measures  into  larger  scale  investments  across  their  buildings 
stock leads to suboptimal solutions, far below cost-effective potential.  

On the use of private funding, the EEFIG identified the lack of aggregation of smaller 
building  renovation  investments  (to  decrease  the  transaction  costs),  and  the  perceived 
high risk as important barriers for building renovation.  

30 

Public perceptions of energy consumption and savings. Procedings of the National Academy of Science of the 
USA. 2010 

31  Domestic energy use and householders' energy behaviour. Energy Policy. 2012 
32  DIW.  (2013).  Financing  of  Energy  Efficiency:  Influences  on  European  Public  Banks’  Actions  and  Ways 

Forward. Retrieved from: 
 http://hayek.diw.de/documents/publikationen/73/diw_01.c.422405.de/hudson_financing.pdf  

16 

 
                                                 
 
5.4.  Technological development  

Combined with increasing energy prices, cost reduction of energy efficient solutions are 
key enablers to stimulate further the demand for energy efficient buildings. As shown in 
Annex 8,  new  technology  developments  and  cost  reduction  of  efficient  technologies 
were observed since the adoption of the EPBD in 2010.  

There is still a lot to be done to ensure the transformation of the EU building stock in a 
sustainable way, making buildings more energy efficient, in a value-chain and lifecycle 
perspective,  improving  the  indoor  environment  and  making  an  efficient  use  of 
resources33. The challenge is not limited to renovation, however. Barriers such as cost, 
quality of the works delivered34, integration of renewable energy sources, and required 
construction skills35 also hamper the development of new nearly zero-energy buildings. 
In  addition,  increasingly  sophisticated  building  control,  automation  and  monitoring 
systems require better interoperability and effective integration within the building and 
the surroundings (e.g. energy grids, district infrastructure).  

Technological progress towards ‘smarter’ building systems creates enabling conditions 
to provide information to consumers on operational energy consumption36; to adjust to 
the needs of the user; to run the efficient and comfortable operation of the buildings; its 
readiness to connect to electric vehicle charging, to host energy storage and to support 
demand response in an modernised electricity market.  

6.  ANSWER TO THE EVALUATION QUESTIONS  

This section summarises the answer to the evaluation questions presented in Section 3. 
Detailed  analysis  for  each  of  the  below  Sections 6.1  to  6.5  can  be  found  in  their 
respective Annexes 9 to 13.  

6.1.  Effectiveness  

Although  saving  potential  remains  high  (Annex 7),  positive  effects  of  the  EPBD  are 
observed as follow (Annex 9).  

Up to 2014, 48.9 Mtoe energy savings have been achieved in total:  
 
 

41.4 Mtoe in the residential sector (of which 36.6 Mtoe for space heating only),  
7.5 Mtoe in the service sector.  

33   Energy-Efficient  Buildings  –  Multi-annual  roadmap  for  the  contractual  PPP  under  horizon  2020,  2013, 

34  

European Commission (E2B/ECTP) 
IEE project QUALICHECK is investigating issues affecting quality of the building works with regard to energy 
performance  and  is  developing  appropriate  guidance,  with  a  focus  on  four  key  technologies  (Transmission 
characteristics,  Ventilation  and  airtightness,  Sustainable  summer  comfort  technologies,  Renewables  in  multi-
energy systems). See: QUALICHeCK ‘Quality of the Works’ report: 
 http://qualicheck-platform.eu/2015/02/report-quality-of-the-works/  

35   The BUILD UP Skills initiative under IEE aims to increase the number of qualified workers across Europe to 
deliver  renovations  offering  a  high  energy  performance  as  well  as  new,  nearly  zero-energy  buildings.  See: 
http://www.buildupskills.eu/  

36  Building  energy  management  systems  allow  savings  in  existing  buildings  arising  from  a  more  efficient 
operation of space heating in the range of 2-30% and for cooling 37-73% depending on the climate and building 
type (Improving energy efficiency via smart building energy management systems: A comparison with policy 
measures. Energy and Buildings. Volume 88, 1 February 2015, Pages 203–213) 

17 

 
                                                 
 
These  figures  seem  to  be  in  line  with  the  2008  Impact  Assessment  supporting  the 
adoption  of the EPBD and indicate that the Directive is likely to deliver the  expected 
60–80 Mtoe energy savings by 2020.  

On  average,  the  final  energy  consumption  per  square  meter  is  still  very  high  (final 
energy  consumptions  of  175kWh/(m².year)  for  residential  buildings  and  around 
300kWh/(m².year)  for  non-residential  buildings)  and  decreasing  very  slowly,  by 
3.8kWh/(m².year) in the household sector, 5.2kWh/(m².year) in the service sector.  

After  2006,  application  date  of  the  Directive  2002/91/EC,  a  clear  positive  change  of 
trends in the energy performance of buildings (primary energy consumption per square 
meter)  is  observed.  This  observation  varies  across  Europe.  The  few  Member  States 
where  an  opposite  change  is  observed  had  already  a  quick  improving  energy 
performance before 2006.  

Furthermore, the EPBD was the main responsible agent for important improvements in 
energy performance of buildings in the EU:  
  Directive  2002/91/EC  and  the  EPBD  resulted  in  major  modernisation  of  national 
building  codes  through  the  introduction  of  minimum  requirements  for  existing 
buildings and the cost optimality concept, followed by the adoption of nearly zero 
energy standards;  

  Prior to the EPBD, few Member States fixed their levels of minimum performance 
requirements  based  on  cost-optimal  solutions  and,  as  a  result  of  the  EPBD,  a 
strengthening  of  minimum  energy  performance  requirements  in  building  codes  is 
observed37.  

The share of renewable energy in final energy consumption is steadily increasing, with 
a  significant  contribution  of  small  scale  on-building  installations.  The  2014  share  of 
renewables in final energy consumption in residential and service sectors is estimated at 
20.3% (9.3% is renewable electricity plus 11.0% from other renewable sources).  

Over the same 2007-2013 period of time, direct GHG emissions were reduced by 63 Mt 
CO2 (i.e. 8% of the 1990 emissions of household and service sector).  

720,000  direct  and  indirect  jobs,  mainly  in  SMEs,  can  be  associated  with  the  energy 
renovation  of  the  EU  building  stock,  including  148,800  jobs  created  or  maintained 
thanks to new business opportunities generated by EU energy efficiency policies.  

With the available data it is not yet possible to conclude on the additional effect of the 
recast. However, there are still potential improvements to be expected with a continued 
and proper implementation of the EPBD:  
 

should  the  national/regional  calculation  methodology  for  the  energy  performance 
of building be unbiased and considering fairly all technologies that can contribute 
to the improvement of the energy performance of buildings, in particular emerging 
efficient technologies, including technologies using renewable sources;  
should  minimum  requirements  be  periodically  reviewed  and  the  calculated  cost-
optimal  level  be  swiftly  implemented  in  the  national/regional  legislation.  The 

 

37   Assessment of cost-optimal calculations in the context of the EPBD, 2015, European Commission (written by 

Ecofys) 

18 

 
                                                 
EPBD leaves 5 years ("by the next review") to reduce any significant gap between 
the regulatory and the cost-optimal levels38;  
should  Member  States  take  the  relevant  actions  to  ensure  that  by  2019  (public 
buildings)  and  2021  (privately-owned  buildings)  all  new  buildings  placed  on  the 
market will effectively be nearly zero-energy buildings (NZEB)39;  
should  enforcement  and  compliance  of  the  EPBD  be  stronger.  Levels  of 
compliance  with  national  transposition  measures  hamper  reaping  a  potential  of 
around 40% additional energy savings, mainly because of lack of compliance with 
minimum requirements in existing buildings40;  
should the measures adopted to further catalyse the increase in energy performance 
of buildings prevent lock-in effects or other negative effects.  

 

 

 

It is impossible to precisely segregate and quantify a specific contribution of the EPBD 
to the above achievements:  
  As  developed  in  Section 5.3  above,  the  EPBD  and  the  broader  economic  context 
and the action taken by the EU and by Member States to improve this context have 
intermingled effects;  

  Other  EU  policies  working  in  synergy  with  the  EPBD  may  have  influenced  the 
observed trends, e.g. national measures including those adopted pursuant Directive 
2006/32/EC  on  energy end-use  efficiency and energy  services.  On  the other  side, 
by  requiring  the  setting  of  minimum  standards,  the  EPBD  is  also  having  an 
influence on the effectiveness of these other measures.  

This last observation is equally valid for the specific parts of the EPBD. Section 6.2 on 
efficiency will show the value to consider the EPBD as a whole rather than as a set of 
interventions.  

6.2.  Efficiency  

For the public sector, the Concerted Action estimated the administrative costs supported 
by  Member  States  to  transpose  and  implement  the  EPBD  in  the  2011-2015  period 
(staff,  studies,  communication  campaigns)  at  160.8  M€  in  total,  reasonable  in 
comparison with the benefits associated with the achievements of the EPBD.  

For the private sector, the consultation with stakeholders41 indicates that the processes 
created  by  the  EPBD  are  necessary,  in  the  light  of  the  energy  saving  potential  in  the 
buildings sector.  

38   Report  from  the  Commission  to  the  European  Parliament  and  the  Council  –  Progress  by  Member  States  in 
reaching  cost-optimal  levels  of  minimum  energy  performance  requirements;  COM(2016)464  final  of  29  July 
2016. 

39   Commission Recommendation (EU) 2016/1318 of 29 July 2016 on guidelines for the promotion of nearly zero-
energy buildings and best practices to ensure that, by 2020, all new buildings are nearly zero-energy buildings; 
OJ L 208, 2.8.2016, p. 46–57.  

40   Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 

by ICF international) 

41   Public  Consultation  on  the  Evaluation  of  the  EPBD  –  Final  synthesis  report,  2015,  European  Commission 

(written by Ecofys) https://ec.europa.eu/energy/sites/ener/files/documents/MJ-02-15-954-EN-N.pdf  

19 

 
                                                 
The EPBD creates the conditions for the better information of decision makers. This is 
generally done through three main instruments, which efficiency can be summarised as 
follow:  
  The  energy  performance  certification  of  buildings  have  a  relatively  limited 
additional  transaction  cost  (in  the  range  of  85-140€  for  an  apartment  or  single 
family  house  EPC42,  i.e.  around  1€/m²,  valid  for  10  years).  EPCs  have  positively 
influenced  property  valuation,  both  for  the  sale  and  rental  market43,  hence 
effectively  contributing  to  the  creation  of  a  demand  driven  market  for  energy 
efficiency in buildings;  

  The regular inspection of heating and air-conditioning systems are reported to have 

a relatively low cost, 200€ on average for both types of inspections;  

  Little information could be gathered on the cost of the technical, environmental and 
economic feasibility of high-efficiency alternative systems,  mandatory  before any 
new  construction  starts.  It  is  however  estimated  around  the  cost  of  an  EPC,  i.e. 
1€/m²;  

No  regulatory  cost  can  be  associated  to  minimum  energy  performance  requirements. 
The EPBD does not mandate any construction or renovation activity. When the decision 
to build or renovate a building is taken, the EPBD prevents sub-optimal investments by 
prescribing minimum requirements based on cost-optimality.  

The  choice  of  a  cost-optimal  benchmarking  methodology  to  steer  existing  national 
energy  performance  requirements  towards  cost-efficient  levels  has  proved  to  be  an 
efficient  and  results-oriented  approach.  The  cost-optimal  calculations  allowed  the 
identification  of  cases  where  there  is  still  a  significant  potential  for  cost-effective 
energy  savings.  On  the  other  hand,  the  analysis  of  the  first  cost-optimal  calculations44 
showed  that  some  Member  States  took  the  political  decision  of  setting  minimum 
requirements more stringent than the cost-optimal levels, possibly because of the non-
economic benefits of improved building energy performance, which are not integrated 
in the framework calculation methodology45.  

In this respect, the provisions of the EPBD leave flexibility to avoid overly burdensome 
situations:  
  Member States are not required to set minimum energy performance requirements 

which are not cost-effective over the estimated economic lifecycle,  

  Member  States  can  set  up  criteria  to  not  apply  minimum  energy  performance 
requirements on a case-by-case basis, when this is not technically, functionally and 
economically feasible.  

42  

http://www.viadiagnostic.fr/tarif-diagnostic-immobilier.html. Lower prices below 50€ are also observed on the 
market. It is however considered that such prices hardly leave the time to provide tailor made recommendation 
that could be trusted and taken up by building owners. 

43   Energy  performance  certificates  in  buildings  and  their  impact  on  transaction  prices  and  rents  in  selected  EU 

countries, 2013, European Commission (written by Bio Intelligence Service) 

44   Report  from  the  Commission  to  the  European  Parliament  and  the  Council  –  Progress  by  Member  States  in 
reaching  cost-optimal  levels  of  minimum  energy  performance  requirements;  COM(2016)464  final  of  29  July 
2016. 

45   Commission Delegated Regulation (EU) 244/2012 of 16 January 2012 supplementing Directive 2010/31/EU by 
establishing  a  comparative  methodology  framework  for  calculating  cost-optimal  levels  of  minimum  energy 
performance requirements for buildings and building elements 

20 

 
                                                 
There is evidence46 showing that renovation decisions are made to meet the demands of 
domestic life and triggered by exogenous factors (e.g. a boiler breaking down, humidity 
in  a  wall),  which  precipitate  an  immediate  response  on  the  affected  building  element. 
Such  patchy  intervention  could  be  seen  as  a  factor  that  limits  the  effectiveness  of  the 
Directive.  Nevertheless,  lowering  the  major  renovation  threshold  would  not  be  an 
appropriate answer as it would be burdensome and not easy to enforce. The Directive 
has proved to take a balanced approach to the issue. The evaluation identified a need to 
ensure that step by step upgrades follow consistent intervention logics over time. This 
need  was  highlighted  by  many  respondents  to  the  public  consultation47  but  could  be 
addressed  by  high  quality  recommendations  on  the  EPCs  and  a  reference  to  these 
recommendations when financial support is granted.  

It has been found that national implementation of the Directive could be more efficient 
in several cases:  
 

35  different  national/regional  calculation  methods  for  the  energy  performance  of 
buildings,  lacking  of  transparency,  contribute  to  market  fragmentation,  limiting 
cost  reduction  potential  for  existing  technologies  and  development  of  new  ones 
(e.g.  integration  of  renewable  energy  technologies  in  buildings)48.  In  total,  half  of 
the  Member  States  have  a  different  calculation  method  for  setting  and  ensuring 
minimum energy requirements, on the one hand, and for certifying buildings on the 
other  hand49.  Such  implementation  choices  create  complexity  and  limit  the 
readability of the policy for end users;  

  The  provisions  related  to  nearly  zero-energy  buildings  will  fully  operate  as  from 
January  2021  (January  2019  for  public  buildings).  However,  this  perspective  is 
perceived  by  the  respondents  to  the  public  consultation  as  an  important  signal. 
Mobilising stakeholders towards a common path is expected to make NZEB levels 
correspond  to  the  cost-optimum  level  for  2020.  To  ensure  that  this  actually 
happened, the Commission recently issued a Recommendation50;  

  The calculated cost-optimal levels can be implemented by Member States within 5 
years  after  the  calculations  were  carried  out.  When  minimum  requirements  are 
implemented,  these  are  generally  enforced  at  building  permit  stage,  which  means 
that buildings can be built with the standards into force at the time of granting the 
permit. This time lapse, compliance and enforcement gaps51 are contributing to not 
reaching cost-optimal levels are leaving room for sub-optimal investments;  

  Even if EPCs have positively influenced property valuation, EPC recommendations 
could  have  had  a  higher  impact  on  informing  and  stimulating  higher  renovation 
rates. For certification to go beyond its main objective of giving a market signal for 
efficient buildings and equally stimulate more building renovation, EPCs should be 

46  Applied  behaviour  research  on  households'  attitudes  towards  building  renovation  (C.  Wilson  et  al.  /  Energy 

47 

48 

49 

Research & Social Science 7 (2015)) 
Public  Consultation  on  the  Evaluation  of  the  EPBD  –  Final  summary  report,  2015,  European  Commission 
(written by Ecofys).  
Technical assessment of national/regional calculation methodologies for the energy performance of buildings, 
2015, European Commission (written by CSTB/TSUS) 
Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 
by ICF international) 

50  Commission  Recommendation  2016/1318  of  29  July  2016  on  guidelines  for  the  promotion  of  nearly  zero-
energy buildings and best practises to ensure that, by 2020, all new buildings are nearly zero-energy buildings; 
O.J. L208, 2.8.2016, P46-57. 
Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 
by ICF international) 

51 

21 

 
                                                 
better  integrated  within  a  framework  of  supporting  measures  including  EPC 
databases52,  and  stronger  links  to  financing  schemes  and  to  compliance  checking. 
For instance, the study on compliance53 indicates that EPCs can be a valuable tool 
for  assessing  the  level  of  compliance  with  building  codes  and  enable  efficient 
compliance check by providing information to central bodies;  

  The  public  consultation  indicated  that,  in  their  current  form,  inspection  reports 
could be poorly suited to the needs of non-expert building owners, with a high risk 
for the recommendation therein of being ignored. Under the EPBD, Member States 
can  make  many  different  choices  when  deciding  how  to  implement  regular 
inspections  and  have  taken  advantage  of  this  flexibility.  Thirteen  of  them  have 
chosen  alternative  measures  in  place  of  inspection  of  heating  systems.  Seven  of 
them  have  chosen  alternatives  to  air-conditioning  inspection,  this  being  a  new 
option available with the recast. According to the Concerted Action, alternatives to 
inspection  are  chosen  by  Member  States  who  consider  that  physical  inspection  is 
too  expensive  relative  to  the  likely  benefits,  or  is  unworkable  for  other  reasons. 
Moreover,  technology  developments  related  to  building  automation,  electronic 
monitoring  and  smart  metering  have  the  potential  to  find  energy  saving 
opportunities  more  cheaply  and  effectively  than  regular  inspection54.  These  could 
also prepare buildings' full interaction with the energy system.  

Enhanced  efficiency  is  achievable  through  more  holistic  ways  to  implement  the 
Directive,  giving  more  clarity  to  the  overall  system  and  reducing  the  administrative 
burden to ensure compliance, in particular for existing buildings. Such approaches are 
already in application in some Member States, for example:  
  The setting of minimum requirements according to EPC energy classes that enable 
the  use  of  EPCs  to  ensure  compliance  and  a  monitoring  of  the  building  stock 
through a central EPC database;  

  The  involvement  of  other  actors  in  the  checking  process  (e.g.  notaries  for  the 
handover  of  EPCs  including  for  the  rental  agreement  which  practically  ensures 
100%  compliance,  installers  for  the  declaration  of  performance  of  the  retrofitted 
building elements);  

  Appropriate accompanying measures such as a more systematic link between EPCs 
and financial support, e.g. with an ex-ante and ex-post energy performance rating 
to set and check the appropriate level of financial support, or linking cost effective 
recommendations in EPCs to mortgage options.  

This  can  only  be  the  case  with  robust  energy  performance  certification  schemes. 
Although reinforced by the EPBD, limited progress as regards the independent quality 
control of EPCs and inspections can be observed55. After surveying the Member States 
in  March  2014,  the  Commission  services  observed  that  too  small  samples  were 
randomly  checked  in  most  Member  States  to  derive  any  conclusion  on  the  quality  of 
EPCs and inspection reports.  

52 

53 

In 2014, 24 Member States had an operational regional of national EPC database (plus Norway). In addition, 
Poland, Latvia, Luxembourg and the Czech Republic are lining up to launch their own databases. 
Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 
by ICF international) 

54   Electronic monitoring systems can deliver on the same objectives, in real time (e.g. iServCMB project) 
55 

Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 
by ICF international) 

22 

 
                                                 
The  need  for  a  holistic  implementation  is  equally  valid  for  the  national  long-term 
renovation  strategies  developed  under  Article  4  of  the  EED.  The  assessment  of  the 
strategies56 revealed that in most cases Member States merely reported a reference to the 
cost-optimal methodologies but did not integrate the results within the strategy. The use 
of national EPC databases to link EPCs with financing schemes and contribute to better 
enforcement of building provisions was generally lacking.  

6.3.  Relevance  

The EPBD is needed to achieve EU ambition and its general objective, framework and 
boundary conditions remain relevant.  

The  European  building  stock  is  responsible  for  approximately  30%  of  the  EU 
greenhouse  emissions57  and  40%  of  the  final  energy  consumption58.  The  sector  is 
expanding, which is bound to increase its energy consumption. Therefore, reduction of 
energy  consumption  and  the  use  of  energy  from  renewable  sources  in  the  buildings 
sector constitute important measures needed to reduce the Union’s energy dependency 
and greenhouse gas emissions. Energy trends indicate that final energy consumption for 
the households and service sector will remain around 40% in the coming decades.  

According  to  the  Communication  on  the  state  of  the  Energy  Union59,  there  are  still 
numerous barriers to reaping the full potential of energy efficiency, such as information 
failures  and  a  shortage  of  dedicated  financial  tools.  This  leads  to  a  limited  uptake  of 
energy efficiency opportunities, products and technologies.  

For buildings, saving potentials mostly lays within the current EPBD scope (space and 
water  heating,  space  cooling,  ventilation  and  their  auxiliary,  and  lighting  in  the  non-
residential sector), to a very large extent in the existing building stock.  

The general mechanisms of the EPBD are relevant to address saving potentials  

The transposition of the EPBD into ambitious building codes in the Member States is 
and will continue to help Member States to reach their GHG reduction targets for the 
non-ETS sector under the Effort Sharing Decision (ESD).  

Better  energy  performance  of  buildings  can  deliver  social  co-benefits  as  a  result  of 
enhanced usability of the building, more efficient use of resources, enhanced health and 
quality  of  life,  stimulating  economic  recovery  and  promoting  growth  and  the  creation 
and retention of jobs60.  

The  district-scale  is  an  attractive  option  due  to  the  higher  leverage  factor  of  any 
intervention  at  this  scale.  But  challenges  and  barriers  are  aggravated  when  scaling  up 

56 

57 

58 

Synthesis  Report  on  the  assessment  of  Member  States'  building  renovation  strategies,  2015,  European 
Commission (JRC) 
In  2014,  the  share  of  inland  GHG emissions  for  Commercial/Institutional/Residential  sectors  and  60%  of  the 
Public  Electricity  and  Heat  Production  sector  (without  LULUCF  and  without  international  aviation  and 
international maritime transport) was 31.7%. Source: EEA/UNFCC.  
In  2014,  households  and  services  were  accounting  for  38.1%  of  the  final  energy  consumptions.  Source: 
Eurostat.  

59  Communication  from  the  Commission  -  State  of  the  Energy  Union  2015,  COM(2015)  572  final  of  18 

November 2015. 

60   Multiple benefits of EE renovations in buildings, 2012, Copenhagen Economics 

23 

 
                                                 
from building to district. If there is space for the consideration of energy in the urban 
planning, there is no strong argument to change the current intervention.  

There  are  however  three  aspects  where  the  EPBD  is  not  yet  fully  delivering  on  the 
identified needs: (i) better informing the financial institutions to improve the efficiency 
of  the  financial  support;  (ii)  making  more  explicit  that  high  energy  performance  in 
buildings  requires  both  energy  efficiency  and  renewable  energy  measures;  and  (iii) 
taking  better  advantage  of  the  technological  progress  for  the  decarbonisation  of  the 
economy.  

Options to address these three aspects should be analysed in the Impact Assessment.  

6.4.  Coherence  

The EPBD is coherent internally and with other EU objectives and interventions.  

6.4.1.  Internal coherence  

No  internal  contradiction  could  be  identified  during  the  evaluation.  The  provisions 
related  to  the  setting  of  minimum  requirements  for  new  and  existing  buildings,  the 
provisions for EPCs and inspections, and on more general measures to address market 
barriers, are focusing on different and complementary aspects. These provisions support 
each  other.  However,  as  indicated  in  the  section  on  efficiency,  related  national 
implementation measures are not always co-acting as expected.  

6.4.2.  External coherence  

The EPBD and other relevant EU legislation are found work in synergy:  
  The objective of the EPBD to support the increase of building renovation depth and 
rates  is  supported  by  other  EU  legislation;  inter  alia,  by  the  EED  and  by  the 
European Structural Investment Funds (ESIF);  

  The  obligations  arising  from  the  EPBD  to  set  and  ensure  minimum  energy 
performance  requirements  for  building  elements,  on  the  one  hand,  and  the  EU 
legislation on ecodesign and energy labelling energy efficiency of products, on the 
other hand, were found coherent;  

  The provisions of the EPBD naturally drive the use of renewable energy sources, 

consistently with Directive 2009/28/EC;  

  To  achieve  the  40%  reduction  target  for  greenhouse  gas  emissions  in  2030, 
established  in  line  with  the  cost-effective  pathway  described  in  the  2050 
Roadmaps61, the non-ETS sectors (buildings, transport and agriculture) need to cut 
emissions  by  30%  (compared  to  2005).  The  improvement  of  the  energy 
performance  of  buildings  is  key  to  achieve  the  2050  target  of  at  least  80-95% 
reduction requires that the residential and tertiary sectors together reduce their CO2 
reductions by 88 to 91% (compared to 1990 levels)62;  

  To  mutually  reinforce  other  EU  policies.  E.g.  the  EPBD  and  Directive 
2014/61/EU63 (in particular Article 8 "In-building physical infrastructure") can be 

61  COM(2011) 112, COM(2011) 144 final, and COM(2011) 885 final 
62  A Roadmap for moving to a competitive low-carbon economy in 2050 (COM(2011) 112 final) 
63  Directive 2014/61/EU of the European Parliament and of the Council of 15 May 2014 concerning measures to 

reduce the cost of deploying high-speed electronic communication networks 

24 

 
                                                 
mutually  supportive  by  creating  respectively  the  demand  and  the  offer  for  high-
speed electronic communication networks.  

6.5.  EU added value  

The principles of subsidiarity and proportionality were considered by the co-legislators 
and are explicitly mentioned in the recitals of the EPBD and were carefully respected. 
Article  194  of  the  Treaty  on  the  Functioning  of  the  European  Union  remains  an 
appropriate legal basis of the EPBD.  

Climate change, security of energy supply and environmental protection are challenges 
that cannot be sufficiently addressed at national level only. Energy efficiency and on-
site  renewables  in  buildings  provide  part  of  the  solution  of  these  problems  and  the 
instruments that have already been adopted at EU level reflect this need for EU action.  

The  EU  level  of  intervention  is  crucial  to  address  the  challenge  to  transform  the 
building stock and a proportionate level of harmonisation is justified and necessary:  
  The impact assessment underpinning the non-ETS proposal demonstrated that in a 
cost-effective  GHG  reduction  scenario  for  the  EU,  all  Member  States  need  to 
improve  energy  efficiency  in  a  similar  way  and  without  an  EU  legislative 
instrument for buildings not all Member States would act (e.g. some can meet their 
Effort Sharing target without additional action). One or several Member States not 
acting in the area of buildings would imply overall higher GHG abatement costs for 
the EU as a whole;  

  The  Directive  2002/91/EC  and  EPBD  played  an  important  role  to  ensure  that  all 
Member  States  have  energy  efficiency  requirements  related  to  new  and  existing 
buildings  in  their  building  codes,  based  on  cost-optimality.  These  minimum 
requirements are used in reference for the use of EU Funding under the Cohesion 
Policy  and  play  an  important  role  to  ensure  that  EU  funding  is  focused  on  the 
effective delivery of Europe 2020 objectives and targets;  

  The setting of a pan-European ambition for all new buildings to be of nearly zero-
energy by 2020 has proved to set a 'future-proof' vision for the sector and mobilise 
stakeholders accordingly. Similar market signals were found to be missing for the 
existing building stock, with the largest cost-effective potential.  

Additional  EU  added  value  is  brought  through  the  support  to  national  regulators; 
stimulating  research  and  innovation  at  a  higher  scale;  support  to  the  single  market 
integration  for  building  products  and  services,  including  financial  services  to  energy 
efficiency; and international leadership in the field of energy performance of buildings. 
In these areas, action at EU level offers a better leverage in mobilising the sector around 
a common ambition and offer higher expected market outcomes  than in  a fragmented 
market.  

7.  CONCLUSION  

7.1.  Key findings  

The evaluation shows that the Directive is effective and is delivering on its general and 
specific  objectives.  Implementation  to  date  shows  broadly  good  performance  on  the 
other four analysed criteria: efficiency, relevance, coherence, and EU added value.  

25 

 
There  is  evidence  of  around  48.9  Mtoe  of  additional  final  energy  savings  in  2014  in 
buildings  compared  to  the  2007  baseline  of  the  EPBD.  These  savings  occur  mainly 
within the scope of the EPBD – space heating, cooling and domestic hot water – and a 
significant part can be attributed to factors influenced by policy interventions.   

This figure of 48.9 Mtoe in 2014 is in line with the 2008 Impact Assessment supporting 
the  EPBD,  which  estimated  that  the  Directive  would  deliver  60  to  80  Mtoe  of  final 
energy savings by 2020.  

The  evaluation  shows  that  the  overall  architecture  of  the  Directive,  combining 
minimum requirements and certification, is working, in particular for new buildings.  

Targets for all new buildings to be of nearly zero-energy by 2020 have proved to set a 
'future-proof' vision for the sector and mobilise stakeholders accordingly. 

Moreover,  for  both  new  and  existing  buildings,  the  choice  of  a  cost-optimal 
methodology to steer existing national energy performance requirements towards cost-
efficient  levels  has  proved  to  be  an  efficient  approach.  Analysis  of  national  reports 
shows  that  it  is  ensuring  reasonably  ambitious  levels  of  requirements64.  A  large  cost 
effective  energy  saving  potential  remains  in  the  building  sector  (see  Annex  7). 
Increasing the rate, quality and effectiveness of the renovation of existing buildings is 
the  biggest  challenge  for  the  coming  decades.  The  long  term  renovation  strategies 
developed  by  Member  States  under  Article  4  of  the  EED  should  result  in  increased 
renovation rates through mobilising finance and investments. These strategies should be 
combined in a clear forward looking vision with 2030 and 2050 perspectives, creating 
market signals for households, building owners/managers, businesses and investors.  

The  evaluation  shows  that  certification  of  the  energy  performance  of  buildings  is 
delivering  a  demand-driven  market  signal  for  energy  efficient  buildings  and  is 
achieving  its  aim  to  encourage  consumers  to  buy  or  rent  more  energy  efficient 
buildings. However, national certification schemes and independent control systems are 
yet at early stages in several Member States and their usefulness could be enhanced.  

Due to the diversity and disaggregation of the buildings sector, it remains challenging 
to acquire good data on building characteristics, energy use, and financial implications 
of  renovation  in  terms  of  cost  savings  or  asset  values.  This  lack  of  data  has  negative 
consequences on the market perception of the cost-effective energy saving potential of 
the  EU  building  stock,  on  enforcement  tracking,  on  monitoring  and  evaluation.  EPC 
registers/databases  can  be  a  key  instrument  for  reinforced  compliance,  improve  the 
knowledge  on  the  building  stock  and  better  inform  policy  makers  and  support  the 
decisions of market players.  

7.2.  Scope for improvements  

The evaluation identified ways in which national transposition and implementation can 
be  further  developed  through  better  enforcement,  compliance  monitoring  and 
evaluation.  

64   Report  from  the  Commission  to  the  European  Parliament  and  the  Council  –  Progress  by  Member  States  in 
reaching cost-optimal levels of minimum energy performance requirements; COM(2016) 464 final of 29 July 
2016. 

26 

 
                                                 
At  EU  level,  opportunities  for  simplification  or  modernisation  of  outdated  provisions 
and  streamlining  existing  provisions  in  the  light  of  technological  progress  were 
detected, in particular:  

  The 

technical,  environmental  and  economic  feasibility  of  high-efficiency 
alternative  systems,  under  Article  6(1))  of  the  EPBD.  With  the  obligation  for  all 
new buildings to be nearly zero-energy buildings, the use of locally available high-
efficiency  alternative  systems  becomes  an  implicit  obligation  and  this  provision 
becomes an unnecessary burden;  

  The regular inspection of heating  and air  conditioning systems, under Articles  14 
and 15 of the EPBD, for which many Member States have opted out for alternative 
measures as allowed by the Directive.  

towards 

Technological  progress 
‘smarter’  building  systems  offers  not  only 
opportunities to support a more efficient implementation of the EPBD and in addition 
creates  enabling  conditions:  to  provide  information  to  consumers  and  investors  on 
operational energy consumption; to adjust to the needs of the user; to run the efficient 
and comfortable operation of the buildings; to ensure buildings' readiness to connect to 
electric vehicle charging; to host energy storage; and to support demand response in a 
modernised electricity market.  

In  conclusion,  the  evaluation  reveals  relatively  limited  regulatory  failures.  There  is 
however scope for simplifying and streamlining outdated measures, and for enhancing 
compliance  through  fine  tuning  of  existing  provisions  and  better  linking  them  with 
financial support. Additionally the evaluation points to the scope for modernisation of 
the Directive in light of technological developments and the need to increase building 
renovation rates while supporting the decarbonisation of buildings in the long-term.  

The  results  of  this  evaluation  provide  the  basis  for  the  Impact  Assessment  of  policy 
options performed in the framework of the EPBD review.  

27 

 
Annex 1 

ACRONYMS  

CPR -  

Construction Product Regulation  

EED - 

Energy Efficiency Directive  

EPBD - 

Directive  2010/31/EU  Energy  Performance  of  Buildings  Directive 
(recast), inclusive of the provisions kept from the Directive 2002/91/EC it 
recast.  

EPC - 

Energy Performance Certificate  

EnPC - 

Energy Performance Contracting  

ESCOs - 

Energy Service Companies  

NZEB - 

Nearly-Zero Energy Buildings  

MS -  

Member States  

TBS - 

Technical Building Systems  

28 

 
Annex 2 

DEFINITIONS  

Building: Buildings are roofed constructions that can be used separately and built for 
permanent purposes, which can be entered by persons and are suitable or intended for 
protecting  persons,  animals or  objects (Eurostat, CC1998).  The EPBD  applies only to 
buildings with walls for which energy is used to condition the indoor climate (EPBD, 
Article 2(1)).  

Building stock: All buildings from residential and services sectors (i.e. residential, and 
non-residential buildings).  

Residential buildings: Buildings at least half of which is used for housing purposes. If 
less than half of the overall useful floor area is used for housing purposes, the building 
is  classified  under  non-residential  buildings  in  accordance  with  its  purpose-oriented 
design.  (Eurostat,  CC1998).  The  residential  building  category  can  be  further  divided, 
e.g. depending on the ownership and the tenure status.  

Non-residential buildings: Buildings which are mainly used or intended for purposes 
other  than housing. If at least half of the overall useful floor area  is  used for housing 
purposes,  the  building  is  classified  as  a  residential  building.  (Eurostat,  CC1998).  The 
non-residential  building  category  can  be  further  subdivided  depending,  e.g.  on  the 
nature  of  the  occupant  (public  or  private),  the  nature  of  the  occupation  (retail  shops, 
etc.), the frequentation (visited by the public or not).  

Building unit: Section within a building designed or altered to be used separately (e.g. 
an  apartment  in  a  multi-apartment  block,  a  retail  shop  at  the  ground  floor  of  a 
residential building).  

Building  product:  Any  product  which  is  produced  and  placed  on  the  market  for 
incorporation  in  a  permanent  manner  in  building  works  or  parts  thereof  and  the 
performance  of  which  has  an  effect  on  the  performance  of  the  building  works  with 
respect to the basic requirements for building works (Derived from CPR, Article 2(1)).  

Building code: Set of rules regulating the basic requirements for building works in both 
new  and  existing  building.  Basic  requirements  may  include  requirements  on:  1. 
Mechanical resistance and stability; 2. Safety in case of fire; 3. Hygiene, health and the 
environment;  4. Safety and accessibility in  use; 5. Protection against  noise; 6. Energy 
economy and heat retention; 7. Sustainable use of natural resources (Framework from 
CPR Annex 1).  

Building envelope:  Integrated elements of a building which separate its  interior  from 
the outdoor environment (EPBD, Article 2(7)). The elements that are part of buildings' 
envelope  (wall,  roof,  glazed  parts,  etc.)  generally  consist  of  a  system  of  building 
products separating the interior from the outdoor environment.  

Building  element:  Either  a  technical  building  system  or  an  element  of  the  building 
envelope (Adapted from EPBD, Article 2(9))  

Construction work: Buildings and civil engineering works (CPR, Article 2(3)).  

29 

 
Embodied energy: Total of all energy consumed in the processes associated with the 
production  (and  transport)  of  the  materials  and  components  that  go  into  a  building  or 
structure.  

Energy performance of a building: Amount of net primary energy needed to meet the 
different needs associated with its typical use and shall reflect the heating energy needs 
and  cooling  energy  needs  (energy  needed  to  avoid  overheating)  to  maintain  the 
envisaged temperature conditions of the building, domestic hot water needs and built-in 
lighting.  The  energy  performance  of  a  building  must  be  expressed  in  a  transparent 
manner  with  an  energy  performance  indicator  and  a  numeric  indicator  of  primary 
energy use (Adapted from EPBD Article 2(4) and Annex I).  

Nearly zero-energy building: Building that has a very high energy performance. The 
nearly  zero  or  very  low  amount  of  energy  required  should  be  covered  to  a  very 
significant extent by energy from renewable sources.  

Major renovation: Building works of a certain cost (cost higher than 25% of the value 
of the building) or magnitude (affecting more than 25% of the surface of the building 
envelope) that provide a special opportunity to take cost-effective measures to enhance 
energy performance, beyond the simple retrofit of building elements.  

Specific  (primary/final)  energy  use:  (Primary/final)  energy  use  within  the  EPBD 
scope, space and water heating, space cooling, ventilation and lighting.  

Energy  performance  of  a  building  element:  Performance  related  to  energy  for  the 
integrated building element, expressed by level or class, or in a description  

Technical building systems: Technical equipment for the heating, cooling, ventilation, 
hot water, lighting or for a combination thereof (EPBD, Article 2(3)).  

Cost-optimal  level:  Energy  performance  level  which  leads  to  the  lowest  global  cost 
during  the  estimated  economic  lifecycle.  The  cost-optimal  level  shall  lie  within  the 
range  of  performance  levels  where  the  cost  benefit  analysis  calculated  over  the 
estimated economic lifecycle is positive.  

30 

 
Annex 3 

INTERVENTION LOGIC AND PRESENTATION OF THE INITIATIVE  

1. Situation prior to Directive 2002/91/EC  

Already  in  the  70's  the  first  European  energy  policies  intended  to  reduce  the  rate  of 
growth of internal consumption65 gave a prominent role to the building sector.  

The  building  sector  was  one  of 
recommendations:  
  The  first66,  recommending  minimum  harmonized  standards  for  the  thermal 
insulation of new buildings, information  campaigns  and call  for proposals  to  find 
cost-effective solutions to address existing residential buildings;  

the  first  sectors  covered  by 

two  Council 

  The  second67,  recommending  the  installation  of  temperature  control  devices  for 
space  and  water  heating  systems  in  existing  buildings,  periodic  maintenance  and 
inspections, and heat metering.  

These initiatives were regularly complemented but did not reach the expected level of 
implementation68. For example, in 1992, the recommendations and resolutions adopted 
by the Council on the billing of heating and hot-water costs had  been applied in only 
two Member States69.  

In  1993,  the  SAVE  Directive70  aimed  at  stabilizing  or  reducing  greenhouse  gas 
emissions  in  2000  at  the  1990  level  by  requiring  Member  States  to  draw  up  and 
implement energy saving programmes, almost all related to buildings:  
 
 

energy certification of buildings,  
the  billing  of  heating,  air-conditioning  and  hot  water  costs  on  the  basis  of  actual 
consumption,  
third-party financing for energy efficiency investments in the public sector,  
thermal insulation of new buildings,  
regular inspection of boilers,  
energy audits of undertakings with high energy consumption.  

 
 
 
 

The "SAVE Directive" is reported to have had limited impact on energy efficiency due 
to  its  unusually  large  degree  of  flexibility  and  subsidiarity71.  A  complementary  legal 
framework on energy efficiency, including specifically on buildings, was needed to lay 
down more concrete actions with a view to achieving the great unrealised potential for 

65  Community  action  programme  on  the  rational  utilization  of  energy  of  27  November  1974  and  Council 

Resolution of 17 December 1974 

66   Council recommendation 76/492/EEC of 4 May 1976 on the rational use of energy by promoting the thermal 

insulation of buildings 

67  Council recommendation 76/493/EEC of 4 May 1976 on the rational use of energy in the heating systems of 

existing buildings 

68   COM(84)614  final  of  13  November  1984,  Towards  a  European  Policy  for  the  rational  use  of  energy  in  the 

building sector. 

69   COM(92)182  final  of  20  May  1992,  Proposal  for  a  Council  Directive  to  limit  carbon  dioxide  emissions  by 

improving energy efficiency (SAVE programme) 

70   Council  Directive  93/76/EEC  of  13  September  1993  to  limit  carbon  dioxide  emissions  by  improving  energy 

efficiency (SAVE), OJ L 237, 22.09.1993, p 28 – 30. 

71   Report on the European Climate Change Program, June 2001, European Commission (JRC). 

31 

 
                                                 
energy  savings  and  reducing  the  large  differences  between  Member  States'  results  in 
this sector.  

2. Directive 2002/91/EC on the energy performance of buildings  

Directive 2002/91/EC was the first major policy initiative addressing energy efficiency 
in buildings. Its main purposes were to achieve the great unrealised potential for energy 
savings  and  reduce  large  differences  between  Member  States'  achievements  in  this 
sector.  

The  main  objective  of  Directive  2002/91/EC  was 
to  promote  cost-effective 
improvement  of  the  overall  energy  performance  of  buildings  within  the  Union,  while 
taking  into  account  outdoor  climatic  and  local  conditions,  as  well  as  indoor  climate 
requirements  and  cost-effectiveness.  The  scope  of  the  Directive  encompassed  energy 
needs for space and hot water heating, cooling, and lighting.  

Directive 2002/91/EC covered energy used in residential and non-residential buildings 
for  space  heating,  space  cooling,  ventilation,  domestic  hot  water  and  built-in  lighting 
(mainly  in  non-residential  buildings).  It  therefore  mainly  targets  the  households  and 
service sector. Other building categories (e.g. industrial buildings) or energy needs (e.g. 
electrical uses for appliances) are not covered.  

Directive  2002/91/EC  was  a  major  step  forward  through  which  Member  States 
introduced requirements based on a “whole building” approach. Directive 2002/91/EC 
defined, for the first time, the integrated energy performance of buildings. Accordingly, 
the indicator on building energy performance encompasses, in addition to the quality of 
insulation  of  the  building,  heating  installations,  cooling  installations,  energy  for 
ventilation, lighting installations, position and orientation of the building, heat recovery, 
active solar gains and other renewable energy sources72. Directive 2002/91/EC also set 
up  a  general  framework  for  a  common  methodology  for  national  energy  performance 
standards.  

In  the  explanatory  memorandum  the  Commission  justified  this  approach  as  follows 
“With today's highly insulated new buildings and the trend towards low energy houses, 
these  additional  factors  play  an  increasingly  large  role  and  should  therefore  be 
included  in  regulatory  provisions.  Such  an  integrated  approach  will  give  more 
flexibility  to  designers  to  meet  energy  reduction  standards  in  the  most  cost-effective 
way. […] A common approach on this basis would contribute to a more level playing 
field  as  regards  the  efforts  made  by  Member  States  to  achieve  energy  savings  in  the 
buildings sector. It would also facilitate the comparison of buildings throughout the EU 
for  prospective  users  and  make  it  easier  for  designers  and  constructors  to  apply 
standards in other Member States.”.  

Directive 2002/91/EC covered these through four main elements:  
  Establishment  of  a  general  framework  of  a  common  methodology  for  calculating 

the integrated energy performance of buildings;  

  Member  States  obligation  to  set  nationally  or  regionally  determined  minimum 
standards on energy performance and apply them to new buildings and to existing 
buildings of more than 1000 m² when they are renovated;  

72   COM(2001)0226 final of 15 May 2001, proposal for a Directive of the European Parliament and of the Council 

on the energy performance of buildings 

32 

 
                                                 
  Establishment of national certification schemes for new and existing buildings on 
the  basis  of  the  above  standards  and  public  display  of  energy  performance 
certificates  and  recommended  indoor  temperatures  and  other  relevant  climatic 
factors in public buildings and buildings frequented by the public;  
Introduction  of  national  inspection  requirements,  so  that  heating  and  air-
conditioning systems above certain thresholds should be regularly checked for their 
efficiency.  

 

3. The EPBD, Directive 2010/31/EU on the energy performance of buildings (recast)  

The  EPBD  did  not  change  the  scope  of  Directive  2002/91/EC  and  retained  its  main 
objectives  and  principles.  The  revision  aimed  at  clarifying  and  simplifying  certain 
provisions, extending the scope of the Directive to all existing buildings, strengthening 
some  of  its  provisions  so  that  their  impact  was  more  effective,  setting  enabling 
conditions  for  a  common  level  of  ambition,  and  providing  for  the  leading  role  of  the 
public  sector.  In  doing  so,  the  transposition  and  implementation  was  expected  to  be 
facilitated  and  a  significant  portion  of  the  remaining  cost-efficient  potential  in  the 
buildings sector reaped.  

Accordingly, the revised Directive had the following specific objectives:  
  Provide  a  simple  and  unambiguous  legal  framework  that  will  provide  clear 

guidance and ease the transposition and implementation;  

  Ensure that the policy instruments used stimulate further energy savings;  
  Ensure  that  the  measures  have  a  wider  coverage  of  the  EU  buildings  stock  and 

relevant energy consumption but are at low additional cost;  

  Ensure that buyers/tenants/owners receive good quality information at a reasonable 
cost  on  the  energy  performance  of  buildings  and  about  the  performance  of  their 
heating and air-conditioning systems;  

  Establish  a base for cost-effective energy performance requirements for  buildings 

or for their comparison;  

  Stimulate the public sector to show good example in buildings' energy efficiency.  

The EPBD was designed to result in a major modernisation of national building codes 
through  the  introduction  of  the  cost  optimality  concept,  leading  up  to  the  adoption  of 
nearly  zero  energy  standards.  The  latter  reflected  the  fact  that  renewable  energy  and 
efficiency measures work together to improve energy performance of buildings.  

More specifically, the EPBD introduced the following new provisions that did not exist 
in Directive 2002/91/EC:  
  Several  new  definitions,  including  the  concept  of  major  renovation,  multiple 
references  to  renewable  energy  sources  and  the  framework  definition  of  nearly 
zero-energy buildings;  

  Article 5 on the calculation of cost-optimal levels of minimum energy performance 

requirements;  

  Article 8 on technical buildings systems;  
  Article 9 on nearly zero-energy buildings (NZEB);  
  Article 10 on financial incentives and market barriers;  
  Article 16 on reports on inspection of heating and air-conditioning systems; and  

33 

 
  Article  18  on  independent  control  systems  and  Article  27  on  penalties,  which  in 

combination provide for the establishment of enforcement mechanisms.  

In addition, the Directive reinforced significantly the following provisions:  
  Article  6,  by  requiring  that  the  assessment  of  technical,  environmental  and 
economic  feasibility  of  high-efficiency  alternative  systems  such  as  decentralised 
energy  supply  or  district  solutions  is  documented  and  available  for  verification 
purposes;  

  Article  7,  by  removing  the  1000  m2  threshold  for  minimum  requirements  in 

existing buildings when they undergo major renovation;  

  Articles 11 to 13 on Energy Performance Certification (EPC) systems, in particular 
as  regards  having  recommendations  adapted  to  the  specific  building  and  public 
buildings to lead by example through the display of EPCs; and  

  Article 14 on inspections on heating systems by enlarging the scope of obligations 
to  regularly  inspect  boilers  to  the  inspection  of  all  accessible  parts  of  the  heating 
systems.  

As a result of the new and reinforced provisions, the main elements of the EPBD can be 
outlined in four blocks.  

3.1. Determination of the energy performance of buildings (EPBD Articles 2(4) and 
3, Annex I)  

Setting  minimum  energy  performance  standards  (Article  4)  and  certifying  the  energy 
performance of buildings (Articles 11 and 12) require a method to determine the annual 
energy that is consumed in order to meet the different needs associated with its typical 
use.  Minimum  requirements  need  to  reflect  the  heating  energy  needs  and  cooling 
energy  needs  (energy  needed  to  avoid  overheating)  to  maintain  the  envisaged 
temperature  conditions  of  the  building,  and  domestic  hot  water  needs.  The  related 
provisions  of  the  EPBD  are  designed  to  ensure  that  Member  States  apply  a 
methodology  for  calculating  the  integrated  energy  performance  of  buildings  and 
building units (Article 3).  

The  methodology  must  be  in  accordance  with  the  common  general  framework  of 
Annex  I  aiming  at  including,  in  addition  to  thermal  characteristics,  other  factors  that 
play  an  increasingly  important  role  such  as  heating  and  air-conditioning  installations, 
application  of  energy  from  renewable  sources,  passive  heating  and  cooling  elements, 
shading,  indoor  air-quality,  adequate  natural  light  and  design  of  the  building.  The 
methodology  for  calculating  energy  performance  should  be  based  not  only  on  the 
season in which heating is required, but should cover the annual energy performance of 
a building. That methodology should take into account existing European standards.  

3.2. Minimum energy performance requirements (EPBD Articles 4, 5, 6, 7, 8 and 9)  

Building  energy  codes  are  generally  recognised  as  the  key  policy  instrument  used  by 
governments  to  limit  buildings’  pressure  on  the  energy  sector  and  the  environment 
while providing occupants with comfort and modern living conditions.  

The related provisions of the EPBD are designed to ensure:  
  The  application  of  minimum  requirements  to  the  energy  performance  of  new 

buildings and new building units (Articles 4 and 6);  

34 

 
  The application of minimum requirements to the energy performance of:  
 

existing  buildings  that  are  subject  to  major  renovation  (Article  7,  first  two 
subparagraphs);  
building  elements  that  form  part  of  the  building  envelope  and  that  have  a 
significant impact on the energy performance of the building envelope when they 
are retrofitted or replaced (Article 7, third and fourth subparagraphs); and  
technical  building  systems  whenever  they  are  installed,  replaced  or  upgraded 
(Article 8).  

 

 

Minimum  requirements  related  to  building  and  to  building  elements  that  form  part  of 
the building envelope must aim at achieving a cost-optimal level (Article 5), determined 
by using a common comparative methodology framework for calculating cost-optimal 
levels of minimum energy performance requirements as set out in Delegated Regulation 
No 244/2012 of 16 January 2012.  

Member  States  must  use  this  framework  to  compare  the  resulting  cost-optimal  levels 
with  the  national  minimum  energy  performance  requirements,  which  they  have 
adopted. Should significant gap, i.e. exceeding 15%, exist between the calculated cost-
optimal levels of minimum energy performance requirements and the minimum energy 
performance requirements in force, Member States should justify the difference or plan 
appropriate steps to reduce the gap.  

Minimum requirements must be reviewed at regular intervals, which shall not be longer 
than five years and, if necessary, must be updated in order to reflect technical progress 
in the building sector.  

The  EPBD  also  gave  a  push  to  increasing  the  number  of  highly  efficient  buildings, 
obliging  Member  States  to  make  sure  that  by  the  end  of  2020  (2018  for  public 
buildings)  all  new  buildings  are  nearly  zero-energy  buildings  (NZEB)  and,  for  this 
purpose, requiring Member States to draw up plans for increasing the number of NZEB 
(Article 9).  

3.3.  Provision  of  information  through  certification  and  inspection  (EPBD  Articles 
11, 12, 13, 14, 15, 16, 17, 18 and annex 2)  

Certification and inspection are designed as a information-based instrument to inform in 
particular  prospective  owners  and  tenants,  about  the  performance  of  specific 
buildings/system and  about ways to improve the energy performance through specific 
recommendations.  

The  EPBD  defined  a  common  approach  to  the  energy  performance  certification  of 
buildings and to the inspection of heating and air-conditioning systems, carried out by 
qualified  and/or  accredited  experts,  whose  independence  is  to  be  guaranteed  on  the 
basis  of  objective  criteria.  The  intention  was  to  ensure  transparency  for  prospective 
owners  or  users  with  regard  to  energy  performance  in  the  Union  property  market.  In 
order to ensure the quality of energy performance certificates and of the inspection of 
heating  and  air-conditioning  systems  throughout  the  Union,  an  independent  control 
mechanism must be established in each Member State.  

The related provisions of the EPBD are designed to ensure:  
 
energy certification of buildings or building units;  

35 

 
 
 

regular inspection of heating and air-conditioning systems in buildings; and  
qualification  of  experts  and  independent  control  systems  for  energy  performance 
certificates and inspection reports.  

3.4  Financial  and  fiscal  incentives  and  information  campaigns  (EPBD  Articles  10 
and 20)  

The  EPBD  recognises  the  role  that  financial  initiatives  can  play  in  giving  practical 
effect  to  the  objectives  of  this  Directive,  without  however  substituting  national 
measures.  As  a  concrete  measure  to  provide  the  Commission  with  adequate 
information,  the  Directive  (Article  10)  requires  Member  States  to  draw  up  lists  of 
existing and proposed measures, including those of a financial nature, other than those 
required by this Directive, which promote the objectives of this Directive.  

The  EPBD  (Article  20)  requires  Member  States  to  inform  owners  or  tenants  of 
buildings  or  building  units  of  the  different  methods  and  practices  to  enhance  energy 
performance,  providing  information  to  owners  or  tenants  of  buildings  on  energy 
performance  certificates  and  inspection  reports,  their  purpose  and  objectives,  on  cost-
effective  ways  to  improve  the  energy  performance  of  the  building  and,  where 
appropriate,  on  financial  instruments  available  to  improve  the  energy  performance  of 
the building.  

4. Type of obligation and target groups  

The  different  provisions  of  the  EPBD  take  effect  at  different  times  of  a  building's 
lifetime:  
  After any construction activity: Minimum energy performance requirements are to 
be met when buildings are built, when they undergo major renovation (i.e. typically 
every 25 to 40 years) or when a building element is replaced or retrofitted.  

  During  a  real  estate  transaction:  The  energy  performance  certificate  is  required 
only  when  buildings  are  newly  constructed,  sold  or  rented  out  and  is  valid  for  a 
maximum of 10 years:  

  Periodically: Inspections of heating and cooling systems are independent of the sale 
or rent of a building. EPBD inspections should consist of an assessment of system 
efficiency  with  recommendations  for  improvement,  documented  by  an  inspection 
report,  and  therefore  come  on  top  of  annual  maintenance  for  boilers  as  the 
inspection.  Their  regularity  is  a  function  of  the  size,  fuel  source  and  average 
lifetime of the system.  

The Directive's  main instruments address different actors:  certificates are to  be issued 
by qualified expert, under the responsibility of home or building owners and advertised 
in commercial media. Minimum energy performance requirements are to be ensured by 
promoters, designers building constructors, and renovation companies such as ESCOs. 
Inspections are primarily the responsibility of the building owner.  

36 

 
5. Intervention logic of the EPBD  

Objectives EPBD:  
to promote the improvement of the energy 
performance of buildings within the Union, 
taking into account outdoor climatic and local 
conditions, as well as indoor climate 
requirements and cost-effectiveness.  

Actions for Member States:  
Setting of minimum energy performance 
requirements for new buildings, existing 
buildings that undergo major renovation and 
retrofit of building elements in existing 
buildings;  
Ensuring that from the end of the decade only 
nearly zero-energy buildings (NZEB) are built;  
Ensuring the issue and display of energy 
performance certificates (EPCs);  
Ensuring regular inspection of heating and air 
conditioning systems (or equivalent measures);  
Establishment of supporting measures and 
instruments (including financial).  

Consequences:  
Minimum energy performance requirements 
for new buildings and for renovating 
buildings and parts of buildings set at the 
right level (lowest cost during the estimated 
life cycle), and kept under regular review;  
Relevant quality information for consumers 
on the energy performance of their homes 
and on how to improve it;  
Minimum energy performance requirements 
for new buildings and for renovating 
buildings and parts of buildings set at the 
right level (lowest cost during the estimated 
life cycle), and kept under regular review;  
Only NZEB constructed from the end of 
2020;  
Enhanced level of ambition of national and 
regional building codes, diminishing 
differences across Member States;  
Technological, financial and organisational 
innovation in the building sector;  
Relevant quality information available to 
regional and local authorities, Member States 
and the Commission.  

37 

External Factors:  
Characteristics of each national buildings 
stock (starting point);  
National and regional transposition and 
implementation measures;  
Activity rates in the construction sector;  
Economic and financial context;  
Local climatic conditions;  
National enforcement systems;  
Cost-effectiveness;  
Indoor climate requirements;  
Technological development and 
innovation;  
Maturity of national energy services 
sectors;  
Availability of national public and private 
financing;  
Availability of skilled workers;  
Other legislation touching on buildings 
(Mainly Energy Efficiency Directive and 
products legislation).  

Expected Results/Impacts:  
Reduced energy use in buildings;  
Better energy performance and energy 
savings;  
Reduced energy bills for EU citizens, 
Consumers can compare the energy 
performance of houses and apartments;  
More jobs (creation and retention) in the 
renovation, construction and energy 
services sectors;  
Increased use of renewable energy 
sources in buildings and reduced use of 
fossil fuels;  
Reduced GHG emissions;  
Reduced air, noise, water and soil 
pollution;  
Co-benefits on human health and state of 
the ecosystems;  
Consumers can compare the energy 
performance of houses and apartments 
before renting or buying.  

 
  
 
 
 
 
 
Annex 4 

PROCEDURAL INFORMATION  

1. Lead DG  

DG ENER  

2. Associated Commission Services  

(COMP),  Economic  and  Financial  Affairs 

SG, Legal Service (SJ), Agriculture and Rural Development (AGRI), Budget (BUDG), 
Climate  Action  (CLIMA),  Communications  Networks,  Content  and  Technology 
(CNECT),  Competition 
(ECFIN), 
Employment,  Social  Affairs  and  Inclusion  (EMPL),  Environment  (ENV),  Eurostat 
(ESTAT), Financial Stability, Financial Services and Capital Markets Union (FISMA), 
Health  and  Food  Safety  (SANTE),  Internal  Market,  Industry,  Entrepreneurship  and 
SMEs (GROW), Joint Research Centre (JRC), Justice and Consumers (JUST), Mobility 
and Transport (MOVE), Regional and Urban Policy (REGIO), Research and Innovation 
(RTD),  Taxation  and  Customs  Union  (TAXUD),  Trade  (TRADE),  Executive  Agency 
for Small and Medium-sized Enterprises (EASME).  

3. Agenda planning/WP references: 2015/ENER/023  

The  preparatory  work  to  assess  the  application  of  the  EPBD,  financing  of  energy 
efficiency  and  knowledge  about  the  building  stock  started  in  2014  to  ensure  that  the 
information  would  be  ready  for  the  Impact  Assesment  in  2016.  Additional  studies  in 
support  of  the  ex-post  evaluation  of  the  EPBD,  ex-ante  analysis  of  policy  options 
including of 'Smart Financing for Smart Buildings' and modelling were launched in the 
first quarter of 2015.  

The  Secretariat  General  (SG)  has  set  up  an  Inter-Service  Group  on  the  review  of  the 
EED,  the  EPBD  and  the  'Smart  Financing  for  Smart  Buildings'-  initiative.  The  group 
met in total nine times in support of the full review process, from 30 April 2015 to 28 
June 2016.  

4. Consultation  

4.1. On-line public consultation  

The communication on the general principles and minimum standards for consultation 
of  interested  parties  by  the  Commission  requires  that,  without  excluding  other 
communication tools, open public consultations should be published on the Internet and 
announced at the “single access point”. In line with this purpose, an open internet-based 
consultation  on  the  evaluation  of  the  Energy  Performance  of  Buildings  Directive  was 
carried  out  from  30  June  to  31  October  2015  (longer  period  than  the  mandatory  12 
weeks  consultation).  The  target  groups  of  this  consultation  were  Public  authorities, 
Member  States  authorities,  private  organisations, 
industry  associations,  SMEs, 
Consultancies,  other  relevant  stakeholders  and  Citizens  (inside  and  outside  of  the 
European Union).  

The  questions  were  elaborated  in  a  way  that  the  consultation  feeds  well  into  the 
evaluation and at the same time provides a basis for the identification of policy options 
that  will  be  part  of  the  Impact  Assessment  in  the  framework  of  the  EPBD  review. 
Position papers were received through a dedicated functional mailbox.  

38 

 
The open internet consultation closed on 31 October 2015. Summarised results of this 
consultation are available on line73. 308 stakeholders sent inputs within the timeframe. 
More  than  half  (58  %)  of  respondents  were  organisations,  mainly  representing  the 
construction sector industry, followed by companies (20 %) operating in Member States 
of  the  European  Union.  Individuals,  Public  Authorities  and  others  represent  7-8  %  of 
the respondents.  

Results 
https://ec.europa.eu/energy/sites/ener/files/documents/MJ-02-15-954-EN-N.pdf  

available 

link 

the 

are 

in 

below: 

The contributions cover all EU Member States, the top 6 in coverage being Germany, 
Belgium,  the  United  Kingdom,  France,  Spain  and  the  Netherlands.  Respondents 
generally  understood  the  possibility  offered  to  reply  only  to  the  section(s)  of  their 
interest. 94% of respondents answered to the "Section A: Overall assessment" while, at 
the  other  end  of  the  scale,  46%  of  respondents  covered  "Section  I:  Sustainability, 
competitiveness and skills in the construction sector".  

The results can be summarised as follows:  
 

In  general,  the  additional  administrative  and  regulatory  processes  created  by  the 
EPBD  are  considered  necessary  by  most  of  the  respondents  to  the  public 
consultation, in the light of the energy saving potential in the buildings sector.  
  The vast majority of the respondents to  the open public consultation have  clearly 
stated  that  the  EPBD  respects  the  principles  of  subsidiarity,  mainly  because  the 
Directive  allows  for  a  lot  of  flexibility  for  Member  States  to  take  into  account 
different  climate  conditions,  building  types,  and  accordingly  define  minimum 
requirements, NZEB levels, certification schemes, etc. However, some respondents 
point  out  that  this  flexibility  has  led  to  the  impossibility  of  establishing  direct 
comparisons  of  building  performance,  NZEB  levels,  and  certificates  across 
Member  States.  Consequently,  within  the  replies  to  the  question  on  subsidiarity 
(question  13  of  the  open  public  consultation),  many  stakeholders  call  for  more 
harmonisation  in  the  calculation  of  energy  performance  and  the  use  of  CEN 
standards,  while  taking  advantage  of  the  flexibility  that  these  (and  the  Directive) 
allow.  

  Several  respondents  highlighted  poor  compliance  and  enforcement  of  national 
measures while others recognised that the economic crisis in the construction sector 
has slowed improvements.  

  Regarding  new  buildings,  the  pathway  towards  nearly  zero-energy  buildings  by 
2020 is perceived as an important signal. Stakeholders call for a similar vision for 
existing buildings.  

  A  vast  majority  of  stakeholders  believes  that  the  EPBD  is  contributing  to  cost-
effective improvements in energy performance of buildings (question 5 of the open 
public  consultation).  The  setting  up  of  minimum  energy  and  maintenance 
requirements  is  now  based  on  cost  optimality,  which  is  technology  neutral, 
performance  based  and  cost-effective.  This  mechanism  is  a  major  driver  for 
continuing  the  efforts  on  improving  energy  performance  of  buildings  in  a  realist 
way.  Some  stakeholders  also  suggested  that  cost-optimality  should  be  taken  to  a 
next  step  and  include  other  benefits,  e.g.  positive  asset  value,  as  increased  work 

73 

Public  Consultation  on  the  Evaluation  of  the  EPBD  –  Final  synthesis  report,  2015,  European  Commission 
(written by Ecofys) https://ec.europa.eu/energy/sites/ener/files/documents/MJ-02-15-954-EN-N.pdf  

39 

 
                                                 
productivity, less employees on sick leave, lower healthcare costs, healthier indoor 
environment, or levels of minimum requirements that go beyond cost-optimality at 
a certain point in time.  

  Respondents  to  the  public  consultation  mentioned  that  renovations  are  usually 
made  ‘step  by  step’,  and  that  those  single  steps  should  not  trigger  the  major 
renovation  threshold  (this  is  also  acknowledged  in  the  EPBD  recast  2008  Impact 
Assessment).  However,  the  current  Directive  does  not  ensure  that  step-by-step 
renovations  (which  do  not  qualify  as  major  renovations)  are  to  be  carried  out 
following  a  cost-optimal  pathway  over  the  long  run  (e.g.  in  line  with  an  energy 
audit or a building passport, linked to financial support).  

  The  views  of  stakeholders  on  the  impact  of  energy  performance  certificates 
(question  10  of  the  open  public  consultation)  vary.  In  some  countries  EPCs  are 
perceived  positively,  and  used  as  an  information  tool  to  inform  buy/rent  decision 
making.  A  common  point  mentioned  by  several  stakeholders  is  the  fact  that  the 
certificate presents estimated energy consumption (asset rating) which frequently is 
different from the actual energy use (operational rating). This is caused by the fact 
that  for  the  estimated  energy  use  a  typical  consumption  profile  is  used,  which  is 
makes  the  result  behaviour  independent.  However,  the  discrepancies  are  also 
caused  by  lack  of  quality  of  the  national  energy  performance  calculation 
methodologies in some cases.  

  Stakeholders  see  a  lack  of  demand  for  building  renovation,  which  seems  to  be 
linked to the absence of long term regulatory goals, e.g. building owners are not yet 
convinced that all existing buildings will have to be renovated, at a certain moment, 
to  a  certain  level.  Another  issue  is  the  lack  of  trust  towards  the  future  financial 
benefits.  

  Many  respondents  to  the  public  consultation  suggested  better  linkages  between 
NZEB and EPCs, by making NZEB a specific certification class. Stakeholders also 
suggest  reinforcing  the  link  between  EPCs  and  financial  support  schemes  for 
building renovation.  

  The  consultation  of  Member  states,  organised  in  the  context  of  the  Concerted 
Action,  indicated  that  the  mandatory  setting  of  overall  technical  building  system 
requirements in existing buildings is complex, difficult to define and expensive to 
enforce.  
It  is  acknowledged  by  industry  stakeholders,  including  the  Energy  Efficiency 
Financial  Institutions  Group  (EEFIG)  that  further  EU-level  harmonisation  and 
guidance  concerning  methods  for  data  collection,  data  analysis  and  protocols  for 
data  sharing  is  important  (e.g.  an  indispensable  prerequisite  for  aggregation  of 
small scale projects and development of attractive financial products).  

 

4.2. Consultation with the Member States  

12  contributions  from  national  authorities  were  received  through  the  on-line  public 
consultation, within or after the timeline, and were analysed separately.  

To  complement  the  on-line  public  consultation  on  the  review  of  the  EPBD  that  took 
place  from  30  June  2015  to  31  October  2015,  the  Commission  hosted  a  dedicated 
consultation of Member States in the framework of the Concerted Action on 26 and 27 
November  2015.  Member  States  and  experts  were  split  into  three  parallel  sessions, 
focusing  on  different  parts  of  the  Directive.  All  Member  States  sent  several 
representatives from different ministries and national energy agencies.  

40 

 
Regarding  minimum  energy  requirements  for  new  and  existing  buildings,  majority  of 
the participants agreed that renovation works are usually made ‘step by step’, and that 
those  single  steps  do  not  necessarily  trigger  the  major  renovation  threshold.  Several 
Member  States  supported  voluntary  individual  building  roadmaps  linked  with 
government funding to complement the "major renovation" approach.  

Most of the Member States' experts agreed that Energy Performance Certificates (EPC) 
are  important  tools  both  for  linking  the  energy  efficiency  investments  with  housing 
prices  and  for  checking  compliance.  However,  experts  agreed  on  the  need  for 
the  product 
improving  EPC  reliability.  Experts  agreed 
technologies  can  also  further  facilitate  compliance.  Importance  of  tax  incentives  in 
increase compliance was also mentioned.  

that  developments 

in 

Regarding  nearly  zero-energy  buildings  (NZEB),  a  majority  of  experts  agreed  on  the 
need to avoid EU mandatory interim requirements for use of renewables in buildings, 
which  hamper  cost  effectiveness  and  limit  national  flexibility  to  set  the  right  set  of 
provisions.  Experts  agreed  that  provisions  to  support  off-site  or  nearby  use  of 
renewables  do  not  belong  in  the  Buildings  Directive  but  rather  to  the  overall  market 
design and grids modernisation.  

Experts agreed on that District Heating Cooling (DHC) cannot be promoted everywhere 
and  they  not  see  any  added  value  for  the  EPBD  to  emphasise  DHC.  Instead, the heat 
roadmap of the EED is mentioned as a useful exercise to actually sort out this question 
of opportunity.  

Regarding  technical  building  systems,  experts  consider  the  mandatory  overall  system 
energy performance requirements in existing buildings as a challenge to implement due 
to  the  lack  of  technical  standards.  A  further  challenge  is  the  level  of  investment  to 
assess  the  system  in  place,  and  to  enforce  the  requirements  while  the  authorities  are 
generally  not  informed  when  technical  building  systems  are  replaced  or  put  in  place. 
Most of the participants reminded that some parts of these systems are regulated by the 
Ecodesign  and  energy  labelling  directives  and  that  the  overall  efficiency  of  technical 
systems  is  reflected  and  covered  by  overall  building  performance  and  minimum 
requirements.  

Moreover, mandatory regular inspections are considered by experts as an archaic way, 
while continuous electronic monitoring is a more efficient way. However, most of the 
experts agreed that a one-off inspection after installation/upgrade  of a key component 
of the systems would be necessary for ensuring proper installation.  

Lastly, regarding information and finance, Member States reported a lack of awareness 
and willingness to invest. Experts emphasized the need for a one-stop-shop and a step-
by-step  guide  for  renovation.  Moreover,  split  incentives  challenge  seems  to  remain in 
the  market,  while  on  the  other  hand  lack  of  trust  in  the  EPC  providers  and  lack  of 
effective links with financing is being reported.  

The Committee set up under Article 26 of the EPBD met on 1 February 2016 as part of 
the consultation process. The Commission services presented the consultation activities 
and briefly summarised their outcome. The opportunity to receive additional input from 
Member States was left, in particular on the cost and cost/benefits associated with the 
national/regional implementation of the EPBD. No additional information was received 
upon this opening.  

41 

 
4.3. Specific Workshops  

Further  stakeholders  opinions  have  been  collected  throughout  the  full  review  process. 
Thematic expert workshops were organized targeting, depending on the theme, relevant 
stakeholders in public authorities, industry and other groups. These workshops can be 
listed as:  
 
 

11 November 2015: Workshop on "Territorial Impact Assessment",  
7 December 2015: Workshop on "Smart buildings, building automation, intelligent 
metering and demand response",  
8 December 2015: Workshop on "On-buildings renewable energy",  
9  December  2015:  "Workshop  on  "Practical  Approaches  to  the  Building 
Renovation Challenge",  
15 December 2015: Workshop on "Healthy and Energy-Efficient Buildings in the 
EU",  
20  January  2015:  Workshop  on  "Unlocking  the  energy  efficiency  potential  in  the 
rental & multifamily sectors",  
21  January  2015:  Workshop  on  "Provision  of  consumption  information  to  final 
customers".  

 
 

 

 

 

4.3.1. Workshop on "Territorial Impact Assessment"  

The  Better  Regulation  guidelines,  approved  in  May  2015,  describe  that  all  potential 
impacts  should  be  mapped  out  according  to  their  expected  magnitude  and  likelihood 
and  to  the  specific  parties  that  would  be  affected,  including  different  territories  and 
regions.  

In June 2015 the Directorate-General for Regional and Urban Policy started a test phase 
to  see  which  methodologies  can  best  be  used  to  quantify  these  territorial  impacts.  As 
part  of  the  revision  process  of  the  EPBD  DG  REGIO  conducted  a  pilot  test  on  the 
Territorial Impact Assessment (TIA) of the Directive testing two methodologies:  
  Sub-national  LUISA  modelling  and  data  collection  performed  by  the  JRC,  with 

early results for two case-studies, one in Italy and one in the Netherlands.  

  Workshop with 10 European cities using the ESPON TIA Quickscan methodology.  

The results of this first test phase were presented in a report drafted by DG REGIO and 
JRC  in  close  cooperation  with  the  European  Committee  of  the  Regions  and  the 
European  Territorial  Observation  Network.  EUROCITIES  and  CEMR  supported  the 
work and provided the contacts to most of the city experts. The report presents also a 
short  reflection  on  the  added  value  and  limitations  of  the  used  methodologies  (JRC-
LUISA,  ESPON  Quickscan)  and  main  reflections  collected  during  the  workshop  with 
urban experts.  

Experts agreed on the potential of the EPBD to contribute to the increase in GDP and to 
increase entrepreneurship in metro regions. Moreover, experts emphasized the need for 
further exploration for local economic opportunities in order to increase employment in 
the construction sector and household disposable income. Regarding the employment in 
the  energy  sector,  according  to  experts,  while  some  jobs  might  indeed  be  lost  in  the 
industry linked to fossil fuels, other highly qualified jobs might be created (as energy 
experts needed).  

42 

 
Experts from city administrations agreed on the need for further compliance among the 
Member  States.  Some  experts  reported  negative  impacts  of  taxing  on  the  energy 
efficiency investments; which should also be taken into account. Experts argued that as 
the energy costs of a building are marginal in many cities, compared to house or rental 
prices, which appears to be a disincentive for EPCs. The significance of addressing the 
ownership  issues  (split  incentives  challenge)  in  building  sector  is  emphasized, 
particularly when carrying out renovations.  

In  conclusion  some  policy  recommendations  were  discussed  in  the  final  part  of  the 
meeting. These are; (1) the need for a life-cycle approach for building renovations, (2) 
provision of more flexibility in conservation and social housing areas, (3) inclusion of 
behavioural  aspects  in  the  directive  and  (4)  improvement  of  Energy  Performance 
Certificates in terms of their scope and content.  

4.3.2. Workshop on "Smart buildings, building automation, intelligent metering and 
demand response"  

Workshop on Smart Buildings, Building Automation, Intelligent Metering and Demand 
Response  was  held  on  7  December  2015  with  the  participation  of  relevant  market 
participants and representatives of research institutes.  

The  participants  of  the  workshop  stressed  the  lack  of  a  shared  understanding  of  what 
'smart  building'  means  and  the  need  for  differentiation  of  sectors  due  to  the  different 
dynamics. Referring to the recent technological developments, most of the participants 
argued that technical barriers for energy efficiency investments are almost over, while 
improvements  are  needed  to  remove  regulatory  and  financial  barriers.  The  need  for 
regulatory  incentives  for  smartness  in  buildings  (towards  the  occupant  and  better 
comfort,  and  towards  the  grid  integration)  is  stressed.  Moreover,  some  participants 
recommended the introduction of a label for smart readiness (i.e. smartness indicator). 
It is acknowledged that this may require an implementing power in the EPBD for the 
Commission to develop such a label, possibly following an approach similar to the one 
used  for  smart  appliances,  including  the  preparatory  study  and  stakeholder  process. 
Other  possible  incentives  were  also  discussed,  such  as  establishing  links  between 
building automation and energy performance contracting.  

4.3.3. Workshop on "On-buildings renewable energy"  

Workshop  on  Renewable  Energy  was  organised  on  8  December  2015.  Main 
conclusions of the workshop are as listed below:  
  On-building  renewables  moving  in  the  right  direction,  but  at  a  slow  pace. 
Recognition  that  energy  efficiency  and  renewable  energy  sources  work  better 
together  

  Main  barriers  relate  to  market  design  issues,  e.g.  national  provisions  preventing 

self-consumption  

  Question  mark  on  the  adaptability  of  the  cost-optimal  tool,  and  in  particular  its 
financial  perspective  aspects,  to  changes  in  framework  conditions  over  time  or 
whether  there  is  inertia  to  stick  to  the  initial  set  up  i.e.  mature  and  cost-effective 
technologies at the time of performing the calculations for the first time  

  Need to clarify the NZEB provisions  
  Lack of an harmonised calculation methodology perceived as a problem  

43 

 
4.3.4. Workshop on Practical Approaches to the Building Renovation Challenge:  

The  workshop  was  organized  by  EASME  and  it  involved  experts  from  about  40  EU-
funded  projects  (H2020,  FP7,  IEE,  and  regional  and  cross-border  programmes) 
representing  a  cross-section  of  the  buildings  sector  (researchers,  engineers,  architects 
and  other  practitioners).  It  focused  on  4  different  aspects  of  EE  policy  particularly  in 
buildings.  

Regarding the construction sector, a room for improvement is reported, particularly in 
offering  holistic  solutions  for  deep  renovation  at  acceptable  cost  and  quality.  The 
building  process  usually  involves  multiple  separated  disciplines,  which  leads  to 
additional costs and risk of failure. The renovation market is principally supply driven 
which  can  lead  to  a  mismatch  between  the  offered  products  and  the  end-user's  needs. 
Many  customers  see  high  operating  costs  and  poor  environment  as  an  acceptable 
alternative to the time-consuming, disruptive and risky renovation process. Participants 
indicated  the  need  for  practical  trainings  and  other  soft  measures  related  to  energy 
efficient construction, e.g. air tightness.  

Moreover,  the  participants  emphasized  the  need  for  district-scale  planning  when 
integrating renewable energy sources, whereas design and certification of Nearly Zero 
Energy  Buildings  is  usually  done  at  the  level  of  an  individual  building.  Moving  the 
emphasis  from  building  to  districts  escalates  from  a  single-stakeholder  decision  to  a 
multi-stakeholder  decision.  Participants  recommended  the  introduction  of  low-
regulatory zones  where some of the regulatory barriers to renewables installations are 
relaxed.  

In addition, a "district level EPC" concept is also recommended, which is already being 
investigated  in  Austria  and  Switzerland.  Participants  indicated  a  lack  of  trust  in  the 
EPCs,  which  shows  that  there  is  a  need  for  improved  monitoring  to  assess  the 
correctness of EPC predictions.  

The participants also indicated that challenges and barriers are aggravated when scaling 
up  from  building  to  district.  In  general,  there  is  a  lack  of  interaction  between 
stakeholders (silos in authorities, dispersion of decision making) at all levels. In certain 
contexts, the age structure is a strong barrier ("old owners, old houses"), as well as the 
"hassle factor" or intrusiveness of building renovation measures.  

The final paper from the workshop is available for download on www.buildup.eu  

4.3.5. Workshop on "Healthy and Energy-Efficient Buildings in the EU":  

The Workshop on “Healthy and Energy Efficient Buildings in the EU” was organized 
by  JRC  and  DG  ENER  on  15  December  2015  in  Brussels  with  the  aim  to  directly 
inform the review process of the EU energy efficiency legislation in 2016. The outcome 
of the workshop served as an input for the preparation of the JRC report: "Promoting 
healthy and energy efficient buildings in the European Union"74.  

Three main issues were addressed in the consultation process regarding the indoor air 
quality (IAQ), comfort and health conditions related to buildings in EU MS. These are: 

74 

"Promoting healthy and energy efficient buildings in the European Union: National implementation of related 
requirements  of  the  Energy  Performance  Buildings  Directive  (2010/31/EU)",  European  Commission’s  JRC, 
2016 (EUR 27665 EN) 

44 

 
                                                 
(1) reviewing the implementation status in the EU MS of the EPBD recast provisions 
relating  to  ventilation,  indoor  air  quality  and  energy  efficiency  criteria  and 
requirements; (2) assessing the impact of tightening energy efficiency requirements on 
IAQ, comfort and health conditions of the buildings’ occupants in EU; (3) formulating 
policy and technical related recommendations to enable the effective implementation of 
healthy and energy efficient buildings in the EU.  

The EPBD laid down new concepts such as nearly zero energy buildings (NZEB) and 
minimum requirements in new and existing buildings in EU. The progression towards 
meeting  the  targets  for  NZEB  by  2020  resulted  in  a  stepwise  tightening  of  minimum 
energy performance requirements in EU MS. This poses a risk of deterioration of IAQ, 
comfort  and  health  conditions  in  the  European  building  stock.  In  order  to  avoid  or 
mitigate such risks, stakeholders indicate that increased emphasis should be put on the 
integration  of  energy  sufficiency,  energy  efficiency  and  renewable  energy  supply 
measures with appropriate strategies dealing with indoor and outdoor pollution sources, 
ventilation,  thermal  comfort,  acoustics  and  lighting.  Moreover,  adoption  of  a 
perspective which also takes IAQ, comfort and health conditions properly into account 
is strongly argued by the participants.  

Secondly, it is indicated that although there are national standards regulations regarding 
ventilation,  they  are  missing  a  health-based  approach  and  perspective  among  the  EU 
MS.  Considerable  discrepancies  exist  in  EU  MS  between  measured  ventilation  rates 
and ventilation rates required by national regulations and European standards. The same 
applies  also  for  other  parameters  of  the  indoor  environment  quality  (IEQ)  such  as 
thermal  comfort,  lighting  (including  daylighting)  and  noise.  Stakeholders  report  the 
need  for  EU-wide  common  health-based  ventilation  guidance  that  will  reinforce  the 
definition  and  setting  of  ventilation  requirements  and  metrics  based  on  health  criteria 
after  all  possible  control  strategies  of  indoor  and  outdoor  pollution  sources  are 
exploited.  Moreover,  inclusion  of  IAQ  and  health-based  related  requirements  and 
measures  in  energy  efficiency  inspections  of  buildings  is  recommended  in  the  review 
process of EPBD in line with other building and product related product legislations.  

Thirdly, experts argue that compliance and monitoring procedures are mainly focusing 
on structural, and energy performance aspects during the buildings’ design stage having 
and give much less emphasis on the operational and occupation phases of buildings. To 
address  this  problem,  stakeholders  recommend  a  common,  flexible  and  comparative 
methodology  in  EU  including  guidelines  for  compliance  checks,  ensuring  the 
assessment  of  energy  efficiency,  IAQ  and  comfort  related  measures  to  avoid  health 
risks  of  the  buildings’  occupants  while  optimising  energy  expenditures.  Moreover, 
extension of EPCs to include ventilation systems and IEQ performance of buildings is 
also recommended.  

Last  but  not  least,  it  is  recommended  to  expand  the  existing  EPBD  Comparative 
Methodology  Framework  by  establishing  key  performance  indicators  for  energy  use, 
health,  comfort  and  IEQ  in  buildings.  These  should  be  integrated  with  a  proper  cost 
indicator  for  estimating  the  co-benefits  of  measures  for  energy-efficiency  health  and 
comfort in indoor environments, in the context of calculations for cost-optimisation  at 
macroeconomic  level,  particularly  in  the  case  of  renovation  measures  related  to  the 
existing EU building stock (i.e. gains from energy savings, less health care costs, less 
absenteeism  rates  from  work,  increased  productivity).  Furthermore,  clear  provisions 
and  criteria  should  be  introduced  in  the  calculation  methodology  of  the  energy 
performance of buildings (including cost-effectiveness and cost-optimality calculations) 

45 

 
so  that  simulated  scenarios  and  subsequent  energy  efficiency  measures  (while 
optimising on energy savings and costs) shall also guarantee good indoor air quality and 
comfort  conditions  for  the  buildings’  occupants  at  the  design  and  operation  phases  of 
new and renovated buildings during their entire lifespan.  

4.3.7. Workshop on "Unlocking the energy efficiency potential in the rental & 
multifamily sectors"  

Asymmetric information and split incentives are typically regarded as major barriers to 
fostering  energy  efficiency  upgrades  in  rented  and  multi-unit  properties  both  in  the 
private and public as well as residential and commercial sectors. The EED (Article 19) 
calls  for  Member  States  to  take  measures  addressing  these  barriers.  Current  solutions 
vary in nature, ranging from revised rent acts, green leases, on-bill finance mechanisms, 
minimum energy performance standards, use of inclusive rents and others.  

A workshop was organised by Commission Services on 20 January 2016, with the aim 
of receiving stakeholders' reflections on these possible solutions. Within the current EU 
regulatory framework, there are no obligations for landlords to renovate their buildings. 
A  key  aspect  to  encourage  energy  efficiency  renovations  is  having  a  stable  rental 
framework.  The  legal  background  is  reported  to  be  fairly  complex  at  EU  level. 
Experience shows that although energy efficiency renovations are recognised as drivers 
to increase the property value, landlords are reluctant to invest unless there is a subsidy 
scheme in place. An additional element that creates some uncertainties is that baselines 
to  compare the percentage of renovation are considered quite unclear  among Member 
States.  

4.3.8. Workshop on "Provision of consumption information to final customers"  

This  workshop  was  organised  by  Commission  Services  in  order  to  support  to  the 
Implementation  of  EED  Article  10  in  relation  to  billing  information  on  21  January 
2016.  

As  historical  data  on  actual  energy  consumption  is  considered  a  powerful  tool  in 
encouraging  the  customers  to  better  manage  their  energy  consumption  through  self-
checks,  the  issue  is  addressed  by  the  Article  10  of  the  Energy  Efficiency  Directive 
(EED). The article makes a number of requirements on billing information and the cost 
of access to metering and billing information.  

This stakeholder workshop aimed at exchanging information on effective ways to tackle 
issues related to the provision of information on historical consumption, to collect/share 
information on good practices and principles for the provision of historical information 
to  final  customers  and  to  provide  main  principles  as  well  as  practical  hints  on  how 
historical  information  should  be  provided  to  final  customers  in  an  effective  and  cost-
efficient way.  

4.4. Conclusion on the consultation process  

In conclusion, the benefits of being open to outside input from external stakeholders are 
already  recognised  during  the  review  process  of  EPBD.  An  internet-based  public 
consultation (which is far longer than the mandatory 12-week consultation) was carried 
out,  reaching  Public  authorities,  Member  States  authorities,  private  organisations, 
industry  associations,  SMEs,  Consultancies,  other  relevant  stakeholders  and  Citizens 
(inside and outside of the European Union). Additional comments and position papers 

46 

 
of  the  respondents  were  received  via  a  dedicated  functional  mailbox.  A  separate 
platform  of  consultation  for  the  Member  States  is  established  under  the  Concerted 
Action  EPBD.  Moreover,  workshops  were  organized  on  specific  sub-topics,  targeting 
different  stakeholder  groups  in  various  subsectors  relevant  to  the  implementation  of 
EPBD. The consultation processes of other Commission services are also utilized with 
the purpose of an effective consultation process.  

5. External Expertise  

5.1. Studies  

Different studies supported the monitoring of the implementation of the Directive and 
provide relevant input to this Evaluation, as follows:  
  Progress towards Nearly Zero-Energy Buildings75  
 
  Assessment of the national/regional methodologies for the calculation of the energy 

Impact of Energy Performance Certificates on property valuation76  

performance of buildings77  

  National implementation of the cost-optimal methodology78,  
  Compliance with the national regulatory frameworks79.  

A  specific  study  for the  evaluation of  the  application  of  the  EPBD  and  assessment  of 
policy  options  and  resulting  energy  related  impacts  in  the  framework  of  the  EPBD 
review kicked off on 25 June 2015. The study delivered the summary report following 
the public consultation80.  

5.2. Other sources  

Outcomes of projects funded under the 'Energy efficiency' chapter of 'Secure, clean and 
efficient  energy'  under  H2020  and  its  predecessor  the  Intelligent  Energy  for  Europe 
(IEE) programme were analysed and referenced where relevant.  

In  addition  to  the  consultation  activities  involving  the  European  Commission,  this 
evaluation  made  use  of  other  sources  of  information,  e.g.  research  papers,  identified 
through  literature  review.  When  such  sources  of  information  are  used  in  the  current 
evaluation, they are explicitly referenced.  

6. Overall opinion of the scrutiny board on the draft dated on 2 March 2016  

A draft evaluation dated on 2 March 2016 was submitted to the scrutiny board.  

75   Overview of MS information on NZEBs - Background paper and progress report, 2014, European Commission 

(written by ECOFYS) 

76   Energy  performance  certificates  in  buildings  and  their  impact  on  transaction  prices  and  rents  in  selected  EU 

countries, 2013, European Commission (written by Bio Intelligence Service) 

77   Technical assessment of national/regional calculation methodologies for the energy performance of buildings, 

2015, European Commission (written by CSTB/TSUS) 

78   Assessment of cost-optimal calculations in the context of the EPBD, 2015, European Commission (written by 

Ecofys) 

79   Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 

by ICF international) 

80   Public  Consultation  on  the  Evaluation  of  the  EPBD  –  Final  synthesis  report,  2015,  European  Commission 

(written by Ecofys) https://ec.europa.eu/energy/sites/ener/files/documents/MJ-02-15-954-EN-N.pdf 

47 

 
                                                 
The regulatory scrutiny board met on the 6 April 2016 and, in its opinion, found scope 
for further improving the evaluation report with respect to the following key aspects:  
(1)  The  assessment  of  coherence  should  be  improved  and  conclusions  supported 
with evidence. In doing so, the report should better explain the scope, the policy 
context  and  the  coherence  with  other  energy  efficiency  initiatives  and 
evaluations.  It  is  sensible  that  a  fitness  check  of  the  directive  (together  with 
other related instruments) be undertaken in the next round of the policy cycle to 
explore better the coherence between different but related policy instruments;  

(2)  The report should clarify the effectiveness of the Directive in reaching its policy 
objectives, in particular those specified in the 2008 Impact Assessment. To what 
extent  can  the  available  evidence  be  used  to  attribute  energy  savings  in  the 
buildings  sector  to  this  directive  as  opposed  to  other  instruments  such  as 
financing  instruments,  the  energy  efficiency  directive  and  the  effort  sharing 
decision etc.;  

(3)  The  evidence  supporting  the  efficiency  assessment  of  the  Directive  should  be 
better  demonstrated,  in  particular  regarding  the  cost-effectiveness.  In  this 
context, the report should explain upfront any limitations and justify them;  
In  view  of  the  envisaged  impact  assessment,  the  reasons  behind  the  slow 
progress in the area of building renovations should be better elaborated as well 
as those aspects of implementation which have been found to be problematic;  

(4) 

(5)  The lack of available data should be explained, including clarifications on how 
the problem will be dealt with in the future. The report should be shortened and 
streamlined, in order to fulfil the Better Regulation guidelines requirements.  

The Evaluation was completely redrafted in response to need for shortening (Point 5). 
In  addition,  comments  were  addressed  in  further  elaborating  the  respective  following 
sections of the present document:  
(1) 
Section 6.4 and Annex 12;  
(2) 
Section 6.1 and Annex 9;  
(3) 
Section 6.2 and Annex 10;  
(4) 
Sections 5.3 and 6.2;  
(5) 
Section 5.2.  

48 

 
Annex 5 

STATE OF IMPLEMENTATION  

The  Commission  services  have  monitored  the  EPBD  in  terms  of  its  transposition, 
conformity and correct application through direct contact with the national authorities, 
visits to Member States, meetings, dialogues through the EU Pilot tool81, and ultimately 
infringement procedures.  

As  the  transposition  depends  on  Member  States'  constitutional  rules  and  internal 
allocation  of  competences,  the  level  of  existing  legislation,  and  the  strategy  for  the 
transposition, differences in results occur. Communication and dialogue in the context 
of infringement procedures help Member States to align their legislation with what the 
EPBD requires.  

1. Full transposition  

Infringement  procedures  for  not  having  fully  transposed  the  EPBD  (so-called  non-
communication  cases  or  cases  of  failure  of  Member  States  to  communicate  all  the 
necessary  transposition  measures)  were  launched  against  all  Member  States,  as  the 
assessment  of  the  Commission  revealed  the  existence  of  transposition  gaps.  The 
transposition verification consists in evaluating whether each obligation of the Directive 
is reflected in the national law.  

Among these 28 Infringement procedures:  
 
 
 

5 closed at the stage of letters of formal notice,  
15 closed at the stage at the stage of reasoned opinion,  
8 closed at the stage of additional reasoned opinion.  

The  non-transposition  exercise  ensured  that  transposition  was  complete  in  all  28 
Member  States.  This  however  did  not  necessarily  imply  that  all  provisions  of  the 
directive  were  correctly  transposed  and  enforced.  This  further  assessment  was 
performed through more in-depth investigations with the concerned Member States.  

2. Correct transposition  

The Commission investigated the conformity of national law with the Directive in the 
framework of EU Pilot information requests. The EU Pilot tool allows the Commission 
services  to  engage  a  constructive  dialogue  with  Member  States  authorities  in  order to 
assess  whether  all  of  the  EU  legal  requirements  are  complied  with.  On  that  basis,  the 
requests 
Commission  services  progressively 
investigating compliance with different requirements of the EPBD.  

launched  EU  Pilots 

information 

Within this process:  
 
 

4 non-conformity EU Pilots request were closed at this dialogue level,  
8 of the dialogues are still on-going,  

81  

"EU  Pilot"  is  a  scheme  designed  to  resolve  compliance  problems  without  having  to  resort  to  infringement 
proceedings. It is based on a website which the Commission and national governments use to share information 
on  the  detail  of  particular  cases,  and  give  governments  a  chance  to  remedy  any  breaches  through  voluntary 
compliance. 

49 

 
                                                 
 

16 EU Pilot requests were closed, 14 with the subsequent opening of infringement 
procedures, 9 of which are at the stage of a letters of formal notice and 3 is at the 
stage of a reasoned opinion. 2 letters of formal notice were closed.  

3. Correct application  

From  2011  to  date,  42  complaints  for  violation  of  the  EPBD  requirements  were 
registered leading to 4 dialogues with Member States within the Eu-Pilot system. The 
majority of complaints concerned the energy performance certificates system as well as 
certain energy efficiency measures introduced by Member States.  

4. Specific proceedings for reporting obligations  

In addition to the general proceedings:  
 

23 EU Pilots were launched for failure to submit the Cost-optimal report satisfying 
the obligations of Delegated regulation 244/2012, and 19 information requests were 
sent for submitting incomplete cost-optimal reports,  
11  EU  Pilots  were  launched  for  failing  to  communicate  the  consolidated 
information on increasing the number of nearly zero-energy buildings.  

 

In addition, the Commission services had specific discussions with the Member States 
that opted, as an alternative to regular inspection schemes,  for measures to ensure the 
provision of advice to users on the replacement of boilers or air-conditioning systems or 
on  other  modifications  to  the  heating  and  air-conditioning  systems.  The  13  Member 
States that choose to alternative measures to the regular inspection of heating systems 
and  the  7  Member  States  that  choose  to  do  so  for  air-conditioning  systems  had  to 
submit to the Commission a report on the equivalence of those measures to the regular 
inspections.  

5. Conclusions  

From  these  proceedings  it  can  be  seen  that  the  most  difficult  part  to  implement  were 
related to:  
  Article  5  related  to  the  calculation  of  the  cost-optimal  levels  of  the  minimum 
energy  performance  requirements,  in  particular  for  existing  buildings:  A  large 
number  of  reports  were  delayed  and/or  incomplete.  But  proceedings considerably 
improved the situation. A progress report was recently issued82;  

  Article  7  related  to  minimum  requirements  for  existing  buildings  and  building 
elements:  The  obligation  to  ensure  cost-optimal  level  requirements  for  buildings 
that undergo a major renovation and for building elements with significant impact 
on the energy consumption was unclear for some Member States. The matter was 
discussed with Member States within the Committee;  

  Article 8 related to system requirements for technical building systems: The setting 
of overall system requirements for technical building systems is seen as a challenge 
to implement due to the lack of technical standards. A further challenge is the need 
of investment to assess the system in place, and to enforce the requirements while 
the  authorities  are  generally  not  informed  when  technical  building  systems  are 

82  Report  from  the  Commission  to  the  European  Parliament  and  the  Council  –  Progress  by  Member  States  in 
reaching  cost-optimal  levels  of  minimum  energy  performance  requirements;  COM(2016)464  final  of  29  July 
2016. 

50 

 
                                                 
replaced or put in place. The matter was discussed with Member States within the 
Committee;  

  Article  9  related  to  nearly-zero  energy  buildings:  The  first  Commission  progress 
report  on  nearly  zero-energy  buildings83  revealed  a  certain  lack  of  preparation  of 
some Member States and the need for further guidance. The Commission recently 
issued a Recommendation84.  

83   Communication on Progress by Member States towards Nearly Zero-Energy Buildings, COM(2013)483/2 final 

of 17 October 2013. 

84   Commission  Recommendation  2016/1318  of  29  July  2016  on  guidelines  for  the  promotion  of  nearly  zero-
energy buildings and best practises to ensure that, by 2020, all new buildings are nearly zero-energy buildings; 
O.J. L208, 2.8.2016, P46-57. 

51 

 
                                                 
Annex 6 

ECONOMIC CONTEXT  

The downturn in construction activity within the EU-28 lasted longer than for industry. 
In  May  2015  (latest  recorded  data) the level  of the  construction activity  index  for  the 
EU-28 was still 35 %-points below the pre-crisis high (Figure 2). The construction of 
buildings  accounts  for  around  78  %  of  total  construction  in  the  EU-28  and, 
unsurprisingly,  the  output  for  building  works  shows  a  similar  development  to  the 
overall  indicator  for  construction.  The  crisis  in  the  building  sector  hit  all  EU-28 
countries  albeit  to  different  extents.  All  countries  experienced  a  decline  in  building 
production ranging from an extreme reduction of 54.5 % in Lithuania in 2009 to almost 
stable activity levels in Germany and Austria. In several countries (e.g. Estonia, Ireland, 
Latvia) growth rates had already begun to move considerably downwards before 2009 
while  in  several  other  countries  the  drop  in  building  activities  happened  in  a  more 
sudden way and was shorter.  

Figure  2:  EU-28  Total  construction,  buildings  and  civil  engineering  activity  index,  2000-2015, 
monthly  data,  seasonally  and  working  day  adjusted  (2010=100),  (Source:  Eurostat,  data  table 
"sts_copr_a")  

The  building  permits  index  of  useful  floor  area85,  although  most  relevant  for 
construction  of  new  buildings  (about  30-40%  of  the  total  production  value  of 
contractors),  gives  an  indication  of  the  future  development  of  construction  activity  in 
terms  of  volume.  During  the  2010-2015  period,  the  index  level  remained  quite  stable 
but still far below the pre-crisis levels (Figure 3).  

85   The  building  permits  index  of  useful  floor  area  is  compiled  from  the  square  metre  of  useful  floor  area  of 
buildings  for  which  permits  have  been  granted  (Source:  Commission  Regulation  (EC)  No  1503/2006  of  28 
September 2006). 

52 

 
  
                                                 
Figure  3:  EU-28,  Building  permits  index  (number  and  floor  area)  2000-2015,  quarterly  data, 
seasonally and calendar adjusted, (2010=100), (Source: Eurostat, data table "sts_cobp_q")  

It  should  be  noted  that,  the  same  2010-2015  period,  the  reduced  activity  had  limited 
impact  on  construction  costs  that  generally  kept  increasing  steadily,  although  at  a 
relative  slower  pace  than  general  prices,  housing  prices,  and  even  energy  prices. 
Therefore, despite the recent decrease of trend for energy prices and compared to 2010, 
overall the situation remains favourable to energy renovation, with still a higher relative 
increase of energy costs compared to construction costs and housing prices (Figure 4).  

Figure 4: EU-28, 2000-2015 construction cost and consumer prices development (Source: Eurostat, 
data tables "sts_copi_m" and "prc_hicp_mmor")  

53 

 
  
  
As  a  result,  low  demolition  rates  (0.1–  0.2%  per  year),  limited  new  construction 
activities (0.4-1.1%  per year86)  and very low refurbishment rates (0.4-1.2%  per year87) 
were observed since the proposal for the EPBD in November 2008.  

With construction rate significantly higher than the demolition rates, the building stock 
that  is  naturally  expanding  in  size.  With  more  space  to  heat,  cool,  ventilate,  etc.  the 
increasing  size is bound to  increase its energy consumption and hence also  its carbon 
dioxide emissions.  

With these construction and demolition rates88, around 70% of the buildings that we will 
occupy in 2050 are already built. This confirms, if needed, that buildings are assets with 
a  long  lifetime,  much  longer  than  appliances,  or  cars,  meaning  that  buildings  have  a 
natural trend to low replacement and refurbishment rates.  

The  supporting  study  for  the  on-going  Fitness  Check  on  the  construction  sector89 
estimates that new business opportunities generated by EU energy efficiency legislation 
at some €124 billion over the 2010-2014 period, corresponding to about 5% of the total 
value  of  the  residential  building  market.  This  definitely  constitutes  a  meaningful 
contribution to sustain the level of activity during a difficult period for the construction 
industry and also had positive effects across the whole supply chain, with an increase in 
the demand for energy efficient construction products and for energy efficiency-related 
professional  services.  In  addition,  considering  the  small  scale  of  the  majority  of 
building  renovation  interventions  (whose  average  values  typically  range  between 
€4,000  and  €10,000),  EU  legislation  on  energy  efficiency  in  buildings  contributed  to 
enhance opportunities for small and medium companies.  

86   GLOBUS model prognosis based on prediction of the gross domestic product and on the population. 
87   An EU Strategy on Heating and Cooling, COM(2016) 51 final 
88   Taking constant 0.1% demolition rate and 1% average construction rate results in having 96% of 2016 existing 

buildings still standing in 2050 and a net stock increase of 40%.  

89   Supporting  study  for  the  Fitness  Check  on  the  construction  sector:  EU  internal  market  and  energy  efficiency 
legislation, 2016, European Commission (Written by Economisti Associati, Milieu, CEPS, BPIE, DBRI) 

54 

 
                                                 
Annex 7 

COST-EFFECTIVE SAVING POTENTIALS FOR 2020  

In  2014,  Fraunhofer  ISI  conducted  a  study90  to  report  on  the  evaluation  of  the 
achievement  of  the  2020  energy  efficiency  target  of  20%  and  to  discuss  energy 
efficiency potentials in two different time horizons (2020, 2030).  

Regarding the residential and tertiary sector, the modelling analysis done for this study 
was carried out with the following models:  
  The INVERT/EE-Lab model (run by TU Wien);  
  The FORECAST platform (run by Fraunhofer ISI);  

These  bottom-up  models  enabled  a  very  detailed  level  of  decomposition,  which, 
contrary to other sources of information, gave an insight of the trends within the scope 
of the EPBD (space heating, space cooling, ventilation, domestic hot water, and lighting 
in  non-residential  buildings)  and  outside  the  scope  of  the  EPBD  (other  uses,  e.g. 
appliances, elevators, cooking, etc.).  

The  following  scenarios  are  relevant  for  the  purpose  of  identifying  the  cost-effective 
saving potentials:  
  The baseline with measures, which contains measures which are already accepted 
or close to being accepted in 2014 and the near future. This scenario includes the 
EPBD;  

  The potential with low policy intensity (LPI), meaning with high discount rates and 
barriers persisting. The discount rates applied for the study are sector and partially 
country specific;  

  The potential with high policy intensity (HPI), with low discount rates and barriers 

(partially or totally) removed;  

  The near economic (NE) potential that includes potential which are not economic 
(the  Net  Present  Value  is  negative  given  the  discount  rates  used  in  the  HPI 
scenario) but the scenario induces costs not much higher than present level energy 
consumption  entails.  This  differentiates  the  near  economic  potential  from  a  pure 
“technical” potential which may include also higher cost.  

  The results for 2020 are summarised in Table 1.  

90   Study evaluating the current energy efficiency policy framework in the EU and providing orientation on policy 
options  for  realising  the  cost-effective  energy  efficiency/saving  potential  until  2020  and  beyond,  2014, 
Fraunhofer ISI. 

55 

 
                                                 
Table 1: Projected 2020 energy consumptions and saving potentials ( Mtoe) within and outside of 
the scope of the EPBD in different scenarios. 

Baseline with 
measures 

Potential 
LPI 

Potential 
HPI 

NE potential 

Residential 
Within EPBD 
Out of EPBD 
Tertiary 
Within EPBD 
Out of EPBD 
Residential & tertiary 
Within EPBD 
Out of EPBD 
Total potential 
Within EPBD 
Out of EPBD 

299.7 
234.3 
65.4 
151.4 
113.8 
37.6 
451.1 
348.1 
103.0 

292.2 
228.1 
64.0 
125.1 
90.0 
35.0 
417.2 
318.2 
99.1 
33.9 
29.9 
4.0 

261.3 
199.5 
61.8 
114.3 
80.1 
34.2 
375.6 
279.6 
96.0 
75.5 
68.5 
7.0 

259.1 
199.5 
59.7 
114.3 
80.1 
34.2 
373.4 
279.6 
93.9 
77.7 
68.5 
9.1 

The following conclusions can be drawn upon these results:  
 

77% of the 2020 energy consumptions would occur within the scope of the EPBD 
(348.1 out of 451.1 Mtoe in the baseline scenario);  
33.9-77.7  Mtoe  cost-effective  potential91  would  remain  in  total  for  2020,  88% 
within the EPBD scope.  

 

The same study projects remaining cost-effective potential of 29.1-86.5 Mtoe within the 
EPBD  scope  for  2030.  Only  1.2-5.2  Mtoe  of  cost-effective  potential  in  new 
constructions are expected by 2030, which means that the saving potentials mostly lay 
in the existing building stock.  

91   The  2020  projections  for  the  above  baseline  scenario  is  30  Mtoe  lower  than  with  the  latest  updated  EU 
Reference Scenario 2016 projections for 2020. This means that, taking the later as reference would lead to an 
additional 2020 saving potential of 50 – 95 Mtoe. 

56 

 
 
  
  
  
                                                 
Annex 8 

TECHNOLOGICAL PROGRESS  

Technological progress and availability of cost-effective energy efficient solutions are 
key enablers to stimulate the demand for energy efficient buildings. Since the adoption 
of  the  EPBD  in  2010,  new  technology  developments  and  cost  reduction  of  efficient 
technologies were observed.  

For  example,  in  Germany,  a  general  trend  of  building  envelope  technology  costs 
declining  from  1994  to  2014  is  evident,  with  the  cost  of  windows  falling  most 
dramatically.  Roof  insulation,  commonly  the  lowest-cost  building  envelope  measure, 
has not shown any significant cost changes; as a result, when indexed it shows the only 
increasing cost trend (Figure 5).  

Figure 5: Cost of building envelope measures in Germany, 1994-2014 (Source: IEA92)  

The European Union, with Canada, and the United States have made most progress in 
deploying  energy  efficient  building  envelopes93.  Highly  efficient  building  envelope 
components  are  available  on  the  EU  market,  and  most  are  considered  to  be  mature 
(more  than  50%  of  sales)  or  established  (between  5  and  50%  of  sales)  markets.  For 
instance, the majority of windows sold in the European Union are double-glazed94 and 
Austria,  Germany  and  Switzerland  have  the  highest  market  share  for  triple  glazing 
usually with two low-e surfaces, at 54 % of total window sales.  

Even the market for advanced insulation (e.g. aerogel, vacuum insulation products) and 
building  integrated  photovoltaic  (BIPV)95,  although  at  initial  stage  (less  than  5  %  of 
sales),  is  more  advanced  than  in  other  parts  of  the  world.  Also  technologies  that 
industrialise the retrofitting of buildings (e.g. through off-site pre-fabrication of larger 

92   Energy Efficiency Market report, 2015, IEA 
93   Technology roadmap – Energy efficient building envelopes, 2013, IEA 
94  

Interconnection  (2013),  “Euro  Crisis  Strains  the  Western  European  Window  Industry,  No  Recovery  Before 
2014”, May, www.interconnectionconsulting.com. 

95   While  conventional  photovoltaic  panels  are  installed  on  rack  mount  systems  placed  on  buildings,  BIPV 
integrate the electricity generation function to another product and replace conventional building materials in 
parts of the building envelope such as the roof, skylights, or facades. 

57 

 
  
                                                 
façade and roof elements) and thus make retrofitting faster, more resource-efficient and 
more user-friendly start to appear on the market96.  

Cost  reduction  is  also  observed  for efficient  technical  building  systems  (such  as  solar 
technologies  or  geothermal  heat  pumps),  which  are  getting  cheaper  and  more 
performing every day (Figure 6, Figure 7, and Figure 8).  

Figure  6:  Collector  production  costs  development  for  high-efficient  flat  plate  solar  thermal 
collector panel of about 2.2 to 2.5 m² gross collector area manufactured in Europe (Source: solrico 
& trenkner consulting). Based on a learning factor of 23%, derived from these historical data, cost 
reduction  projections  are  calculated  up  to  2020  based  on  market  expectations  of  the  National 
Renewable Energy Action Plans (NREAPs).  

96   Cf. for example the results of the e2rebuild project (http://www.e2rebuild.eu/), which developed industrialised 

energy efficient retrofitting of residential buildings in cold climates 

58 

 
  
                                                 
Figure  7:  Development  of  geothermal  heat  pump  system  first  cost,  heat  full  cost,  and  electricity 
consumption  of  geothermal  heat  pump  systems  in  the  residential  sector  in  Central  Europe 
(Germany,  Austria,  Switzerland,  Luxembourg)  (Source:  European  Technology  Platform  on 
Renewable  Heating  and  Cooling,  "Strategic  Research  and  Innovation  Agenda  for  Renewable 
Heating & Cooling")  

Figure  8:  Price  Learning  Curve,  including  all  commercially  available  photovoltaic  technologies 
(Source: Fraunhofer Institute for Solar Energy, 2015 Photovoltaics report).  

59 

40608010012014019851990199520002005201020152020year%System first costHeat full costElectricity consumption 
  
  
The impact of metering provisions in the electricity97 and gas98 Directives fostered cost-
benefit  analysis  and  supported  the  development  of,  inter  alia,  building  automation 
systems, smart meters, demand forecasting software and smart grids. The development 
of key enabling technologies for “smart buildings” is no longer a technical barrier. The 
technology is well established:  
 
 
  Building Energy Management Systems (BEMS) are increasingly used.  
  Data  communication  (internal  and  external)  and  user-friendly  displays  can  be 
integrated  with  BEMS  or  smart  meters,  although  a  standard  protocol  for  data 
exchange may have to be developed.  

sub-metering has been available for many years;  
sensors have become cheaper and more reliable;  

Standard  data  formats  and  transmission  protocols  still  have  to  be  agreed  to  ensure 
interoperability  between  devices  and  equipment  from  different  manufacturers  and  the 
networks infrastructure, further work has to be done to agree standard data formats and 
transmission protocols.  

Such  developments  could  be  pursued  at  EU  level  as  technical  projects  or  in 
standardisation committees.  

These developments offer an opportunity to reconsider the design of energy efficiency 
measures  for  buildings  by  means  of  new  technologies,  improving  comfort  for  the 
their  more  active 
occupant  and  better  preparing 
integration/participation  in  the  energy  system  (e.g.  through  demand  response, 
renewable energy production and storage in buildings).  

individual  buildings 

to 

These  issues  are  also  addressed  in  parallel  freestanding  evaluations  of  the  impact  of 
energy  legislation  in  the  areas  of  (a)  metering  and  billing  and  (b)  demand  response, 
framed in the broader discussion of the Market Design Initiative.  

97   Directive  2009/72/EU  of  13  July  2009  concerning  common  rules  for  the  internal  market  in  electricity  and 

repealing Directive 2003/54/EC 

98   Directive  2009/73/EU  of  13  July  2009  concerning  common  rules  for  the  internal  market  in  natural  gas  and 

repealing Directive 2003/55/EC 

60 

 
                                                 
Annex 9 

EVALUATION OF THE EFFECTIVENESS  

The effectiveness of the EPBD for the households and services sector was approached 
through two different means:  
  Using  the  Odyssee-Mure  decomposition  tool99,  retained  as  the  main  reference  to 

estimate the additional savings observed since the 2007 baseline. ;  

  Observing  the  final  energy  consumption  and  GHG  emission  trends  in  order  to 

detect the effects of the EPBD.  

Methodological  limitations  are  acknowledged  and  both  approaches  do  not  permit  to 
fully segregate and precisely quantify the specific contribution of the EPBD:  
  As developed in Section 5.3, the EPBD and the broader economic context and the 
action  taken  by  the  EU  and  by  Member  States  to  improve  this  context  have 
intermingled effects;  

  Other  EU  policies  working  in  synergy  with  the  EPBD  may  have  influenced  the 
observed trends, e.g. national measures including those adopted pursuant Directive 
2006/32/EC  on  energy end-use  efficiency and energy  services.  On  the other  side, 
by  requiring  the  setting  of  minimum  standards,  the  EPBD  is  also  having  an 
influence on the effectiveness of these other measures.  

1. Estimation of energy savings with the Odyssee-Mure decomposition tool  

48.9 Mtoe energy savings resulting of EU policies have been achieved in total:  
 
 

41.4 Mtoe in the residential sector (of which 36.6 Mtoe for space heating only),  
7.5 Mtoe in the service sector.  

These  figures  seem  to  be  in  line  with  the  2008  Impact  Assessment  supporting  the 
adoption  of the EPBD and indicate that the Directive is likely to deliver the expected 
60–80 Mtoe energy savings by 2020.  

1.1. Households/residential sector  

Apart  from  climatic  conditions,  energy  consumption  developments  in  households  are 
influenced by various factors:  
  Change in number of occupied dwelling ("more dwellings");  
  More appliances per dwelling" (electrical appliances, central heating);  
  Change in floor area of dwelling for space heating ("larger homes");  
  Other effects (mainly change in heating behaviour);  
  Finally, energy savings;  

After  neutralising  the  effects  of  the  other  factors,  as  shown  in  Figures  9  and  10,  the 
energy savings resulting of EU policies in the household sector over the period 2007-
2014 are estimated at 41.4 Mtoe (of which 36.6 Mtoe for space heating only).  

This efficiency progress encompasses:  
  Heating: unit consumption per square meter at normal climate (koe/m²),  

99  

http://www.indicators.odyssee-mure.eu/decomposition.html 

61 

 
                                                 
  Water heating: unit consumption per dwelling with water heating,  
  Cooking: unit consumption per dwelling,  
  Large 

appliances: 

electricity 

electrical 

specific 

consumption, 

in 

kWh/year/appliance.  

Figure  9:  Decomposition  of  the  variation  of  Households'  consumption  -  European  Union  -  Mtoe 
(2007-2014) (Source: Odyssee database, http://www.odyssee-mure.eu/)  

62 

 
  
Figure 10: Decomposition of the variation of Households' space heating consumption - European 
Union - Mtoe (2007-2014) (Source: Odyssee database, http://www.odyssee-mure.eu/)  

1.2. Tertiary/non-residential sector  

Apart  from  climate,  energy  consumption  developments  in  services  are  influenced  by 
three factors.  
  Change in economic activity, measured with the value added (“activity effect”);  
  Energy savings, measured from changes in energy use per employee;  
  Changes in labour productivity, i.e. changes in the ratio value added per employee ;  
  Other effects, mainly behavioural effects.  

After  neutralising  the  effects  of  the  other  factors  as  shown  in  Figure  11,  the  energy 
savings  resulting  of  EU  policies  in  the  service  sector  over  the  period  2007-2014  are 
estimated at 7.5 Mtoe.  

63 

 
  
Figure 11: Decomposition of the variation of service sector consumption - European Union - Mtoe 
(2007-2014) (Source: Odyssee database, http://www.odyssee-mure.eu/)  

2. Analysis of final energy consumption trends  

As  detailed  below,  on  average,  the  final  energy  consumption  per  square  meter  is  still 
very high (final energy consumptions of 175kWh/(m².year) for residential buildings and 
around 300kWh/(m².year) for non-residential buildings) and decreasing very slowly, by 
3.8kWh/(m².year) in the household sector, 5.2kWh/(m².year) in the service sector.  

The  final  energy  consumption  per  square  meter  is  mainly  driven  by  improvement  of 
final  energy  consumption  for  space  heating,  around  125kWh/(m².y),  which  follows  a 
similar trend at around 72% of the total final energy consumption (82% for space and 
water heating). For comparison:  
  Nearly  zero-energy  buildings  will  typically  have  energy  needs  for  space  heating 

around 15-30kWh/(m².y),  

  Major  renovation  of  existing  buildings  can  typically  reduce  the  energy  needs  for 

space heating down to 50-70kWh/(m².y), at cost-optimal level.  

A  clear  inflexion  in  final  energy  consumption  can  be  observed  from  2007  onwards 
compared to the observed trend pre-2006, application date of the Directive 2002/91EC. 
This  suggests  correlation  between  the  EU  intervention  and  the  realised  savings  and 
emissions reduction.  

Despite  the  fact  that  final  energy  consumption  occur  mainly  within  the  EPBD  scope 
(space heating and cooling and domestic hot water) and that the change of trend seems 
to coincide in terms of timing with the application of Directive 2002/91/EC, other EU 
policies working in synergy with the EPBD may have influenced the observed trends, 
e.g.  national  measures  including  those  adopted  pursuant  Directive  2006/32/EC  on 
energy  end-use  efficiency  and  energy  services.  On  the  other  side,  by  requiring  the 
setting  of  minimum  standards,  the  EPBD  is  also  having  an  influence  on  the 

64 

 
  
effectiveness of these other measures. This makes it impossible to precisely segregate 
and quantify a specific contribution of the EPBD to these savings.  

The positive influence of the EPBD on this additional improvement cannot be denied 
either.  Moreover,  with  its  proposal  for  revision  of  the  2002  Directive  in  November 
2008, the Commission gave a clear message of continuity and reinforcement. The main 
principles, objectives and most provisions were maintained, facilitating the continuation 
of  national 
implementation  efforts.  Therefore,  although  not 
observable yet, a continuation of the trend in final energy consumption is the least that 
would be expected post-2013 as a result of the approach taken with the recast of 2010.  

transposition  and 

2.1. Households/residential sector  

From  1990  to  2013,  the  climate  corrected  annual  final  energy  consumptions  in  the 
residential sector, remains stable around 300 Mtoe, despite different factors (Cf. above 
decomposition) pushing for an increase of consumption (Figure 12).  

Figure  12:  Annual 
(Source: Odyssee database, http://www.odyssee-mure.eu/)  

final  consumption 

for 

the  residential  sector 

(climate  corrected) 

The observation of the trends of annual final energy consumption per square meter in 
residential building before 2006 and after 2007 can be used to approach the effect of the 
EPBD.  At  EU  level,  it  can  be  observed  that  up  to  2006,  after  climate  correction,  the 
average  final  energy  consumption  in  the  residential  sector  was  decreasing  on  average 
by 2.1kWh/(m².y) each year. From 2007 to 2013, inclusive, this decrease was quicker, 
on average by 3.8kWh/(m².y) and appears to be maintained overtime (Figure 13). This 
can be materialised a net delta of -1.7kWh/(m².y). The negative sign indicates a quicker 
decreasing slope after 2007 compared to before 2006.  

65 

 
  
Figure  13:  Annual  final  consumption  per  m²  and  per  year  in  residential  buildings,  total  and  for 
space  heating  (climate  corrected)  (European  Commission,  based  on data  from  Odyssee  database, 
http://www.odyssee-mure.eu/)  

A similar analysis was done at national level. In most Member States, the trend changed 
towards delivering more energy savings per square meter per year (Figure 14), meaning 
that the observed decrease is quicker after 2007 compared to the pre 2006 general trend, 
sometimes much more significantly than the EU average change of trend.  

66 

 
  
Figure 14: Difference in the change of the evolution trend of the annual final energy consumption 
per  square  meter  in  the  residential  sector  between  the  trend  observed  after  2007  and  the  trend 
observed before 2006)  

The  few  Member  States  with  an  opposite  change  are  also  Member  States  that  had  a 
quick  decreasing  trend  before  2006  (Figure  15).  However,  these  Member  States  also 
have a relatively higher consumption than the EU average but also compared to some of 
their neighbouring countries with similar climate intensity.  

67 

 
  
Figure  15:  Evolution  trend  of  the  annual  final  energy  consumption  per  square  meter  in  the 
residential sector between the trend observed after 2007 and the trend observed before 2006.  

Figure 16 shows the latest known annual final energy consumption per square meter in 
the  residential  sector  for  EU28  Member  States  with  two  different  layout:  in  the  same 
order as in Figure 14 and Figure 15; and in ascending order.  

68 

 
  
Figure  16:  Latest  known  annual  final  energy  consumption  per  square  meter  in  the  residential 
sector (2013 value for all Member States, except (*) 2012 and (**) 2011)  

2.2. Tertiary/non-residential sector  

From  1990  to  2013  (latest  available  data),  the  climate  corrected  annual  final  energy 
consumptions  in  the  non-residential  sector,  remains  stable  around  160  Mtoe,  despite 

69 

 
  
  
different  factors  (Cf.  above  decomposition)  pushing  for  an  increase  of  consumption 
(Figure 17).  

Figure 17: Final consumption for the service sector (climate corrected) (Source: Odyssee database, 
http://www.odyssee-mure.eu/)  

The observation of the trends of annual final energy consumption per square meter in 
residential building before 2006 and after 2007 can be used to approach the effect of the 
EPBD.  This  can  be  materialised  a  net  delta  of  -7.7833kWh/(m².y).  The  negative  sign 
indicates  a  quicker  decreasing  slope  after  2007  compared  to  before  2006.  (Cf.  Figure 
18).  

Figure  18:  Total  annual  final  consumption  per  m²  and  per  year  in  non-residential  buildings 
(climate  corrected) 
from  Odyssee  database, 
http://www.odyssee-mure.eu/)  

(European  Commission,  based  on  data 

Due to lack of disaggregated data (energy use by end use), the fraction of these energy 
efficiency  gains  within  the  EPBD  scope  (i.e.  for  space  and  water  heating,  cooling, 
ventilation  and  lighting)  cannot  be  established  independently  from  other  energy 
efficiency  gains,  e.g.  from  electric  appliances,  or  other  factors  such  as  building 

70 

 
  
  
occupancy rates. In particular, the climbing slope from 1990 to 2006 is clearly driven 
by an increase  of electricity  use in  tertiary  buildings.  At least  two factors can  explain 
this  increase  of  electricity  use:  the  development  of  air-conditioning,  to  avoid 
overheating  or  provide  additional  comfort,  and  the  increase  of  computer  usage  in  the 
service sector. In addition to the effect of the EPBD, the decrease after 2007 is certainly 
also a result of national and other EU policies, e.g. on energy efficiency of products and 
in particular light bulbs, ventilation units, and air-conditioning systems.  

The absence of data on floor areas of the national non-residential building stocks does 
not allow the derivation of the national trends in the non-residential sector.  

3. Renewable energy  

At EU level, the 2014 share of renewables in final energy consumption in households 
and  services  is  estimated  at  20.3%,  of  which  9.3%-points  is  renewable  electricity and 
11.0%-points  for  other  renewable  sources  (Figure  19).  The  share  of  renewable 
electricity  in  households  and  services  assumes  that  the  overall  electricity  mix  can  be 
applied to individual sectors.  

Figure 19: Cumulated share of renewables in the total final energy use for households and services 
(Source: Eurostat, ref. indicator "nrg_ind_335a")  

25,0%

20,0%

15,0%

10,0%

5,0%

0,0%

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Share of renewable energy from other sources (%)

Share of renewable in the electrical final energy use (%)

An additional 1.3%-point could be added on top of the 20.3%, assuming that the 17.7% 
share of renewables in the energy use from derived heat in 2014 could be used for the 
household and service sectors only.  

Supported  by  policies,  a  peak  in  annual  solar  photovoltaic,  for  the  generation  of 
electricity,  installed  capacity  was  observed  in  2014,  with  a  total  installed  capacity  of 
86,636  MW,  of  which  around  50  %  consists  of  residential  and  commercial  scale 
installations100.  

100   "Global market Outlook", 2015, Solar Power Europe 

71 

 
  
                                                 
Solar thermal collectors are another typical example of renewable technologies installed 
on buildings. As Figure 20 shows, the installed capacity is steadily increasing and the 
regulatory framework for buildings is not used to explain the contraction of sales post-
2008 but rather low gas prices, difficult access to finance for consumers, slow-moving 
construction sector, less public support schemes for solar thermal and competition from 
other energy sources, namely those with more attractive market incentives101.  

Figure  20:  Solar  Thermal  Market  in  EU28  and  Switzerland  MWth  Total  and  Newly  Installed 
Capacity  (glazed  collectors)  (Source:  "Solar  thermal  markets  in  Europe  -  Trends  and  Market 
Statistics 2014", June 2015, ESTIF)  

The  contribution  of  the  Directive  2002/91/EC  and  of  the  EPBD  to  these  increases 
cannot  be  exactly  determined.  Directive  2009/28/EC  more  specifically  promote  the 
increase  of  renewable  energy  in  general  where  the  EPBD,  with  the  tightening  of 
minimum  requirement  implies  a  technology  neutral  approach,  based  on  cost 
effectiveness.  However, 
tightened  minimum  energy 
performance  requirements  naturally  stimulate  the  cost-effective  introduction  of 
renewable  energies  in  buildings  and  that  the  construction  of  nearly  zero-energy 
buildings will naturally require the introduction of on-site renewable energy sources.  

it  was  established102 

that 

4. Greenhouse gas emissions and air pollution  

A  similar  analysis  to  the  analysis  performed  on  final  energy  consumptions  shows,  a 
clear  change  of  trends  in  the  residential  sector  appears  post-2007  whereas  the  trend 
remains continuous for the service sector, before and after 2007 (Figure 21). Between 
2007 and 2013, climate corrected energy consumption per dwelling dropped by around 
5% (from 1.50 toe/dwelling to 1.42 toe/dwelling) and climate corrected CO2 emissions 
by 10% (2.22 tCO2/dwelling to 1.98 tCO2/dwelling)103. From this change of trend, and 
compared  to  the  2007  baseline  of  the  EPBD,  additional  greenhouse  gas  emission  for 
2013 can be estimated at 63MtCO2, for the residential sector only (i.e. 8% of the 1990 
total emissions of household and service sector).  

101   Solar thermal markets in Europe - Trends and Market Statistics 2014, June 2015, ESTIF 
102   Towards  nearly 
zero-energy  buildings-  Definition  on 

the  EPBD 
(http://ec.europa.eu/energy/sites/ener/files/documents/nzeb_full_report.pdf), European Commission (written by 
Ecofys). 

common  principles  under 

103   Source: Odyssee database, http://www.odyssee-mure.eu/  

72 

 
  
                                                 
Figure 21: Total greenhouse gas emissions in the residential and service sectors (climate corrected) 
(European Commission, based on data from Odyssee database, http://www.odyssee-mure.eu/)  

5. Investments and job creation  

In 2014, the total costs associated with energy related upgrade (e.g. insulation, heating 
system  upgrade,  etc.)  are  estimated  around  €120  bn.  Based  on  the  assumption  of 
approximately  6  jobs  created  and  maintained  for  every  €1  million  constant  yearly 
investment  in  the  existing  building  stock  in  the  form  of  energy  renovation  work,  this 
leads to 720,000 direct and indirect jobs104 associated with the energy renovation of the 
EU building stock.  

104   This figure is estimated with a conservative assumption of around 6 direct and indirect jobs per million euro 
invested.  More  details  can  be  found  in:  Assessing  the  Employment  and  Social  Impact  if  Energy  Efficiency, 
2015,  Cambridge  Econometrics,  Warwick  Institute  for  Employment  Research  and  ICF  International.  For 

73 

 
  
                                                 
The  supporting  study  for  the  on-going  Fitness  Check  on  the  construction  sector105 
estimates that new business opportunities generated by EU energy efficiency legislation 
at some € 124 billion over the 2010-2014 period, i.e. on average € 24.8 billion per year, 
equivalent to 148,800 created or maintained jobs in the construction sector.  

example, Janssen and Staniaszek in "How many jobs? A survey of the Employment Effects of Investment in 
Energy Efficiency of Buildings" derive an average 19 direct and indirect jobs per million euro invested. 

105   Supporting  study  for  the  Fitness  Check  on  the  construction  sector:  EU  internal  market  and  energy  efficiency 
legislation, 2016, European Commission (Written by Economisti Associati, Milieu, CEPS, BPIE, DBRI) 

74 

 
                                                                                                                                               
Annex 10  EVALUATION OF THE EFFICIENCY  

1. Evaluation of the administrative costs for implementing bodies.  

The  recast  used  Directive  2002/91/EC  as  the  starting  point  and  'backbone'  for  the 
revision.  The  costs associated with the new measures of the recast were analysed and 
found  to  be  relatively  low  compared  to  the  benefits  and  returns.  For  example, 
abolishing  the  1000  m²  threshold  on  an  EU  scale  would  lead  to  €8  billion  per  year 
additional  investments  but  would  trigger  €25  billion  per  year  energy  cost  savings  by 
2020.  The  impact  on  administrative  burden  was  considered  limited  for  this  specific 
provision.  

The  2010  revision  chose  to  ensure  continuity  of  national  efforts  to  transpose  and 
implement  Directive  2002/91/EC.  The  main  provisions,  scope  and  structure  were 
therefore kept in a conscious effort to ease transposition of the 2010 Directive and limit 
related administrative burden.  

The  following  costs,  leading  to  a  total  cost  of  160.8M€  for  the  2011-2015  period 
(including Norway) were reported by the Member States in the context of the Concerted 
Action.  This  cost  is  considered  reasonable  in  comparison  with  the  benefits  associated 
with the achievements of the EPBD  

Table 2: Estimate the administrative costs linked to the EPBD transposition and implementation in 
the 2011-2015 period (e.g. prepare relevant legislation, EPCs, Q&A, campaigns, etc.)  

75 

 
  
2. Evaluation of the efficiency of the different provisions of the EPBD  

The evaluation of efficiency was further conducted for its four main pillars described in 
Annex 3.  

2.1.  Efficiency  in  adopting  a  method  to  determine  the  energy  performance  of 
buildings  

35  different  national/regional  calculation  methodologies  for  the  determination  of  the 
energy  performance  of  buildings  were  identified  at  national/regional  level.  These 
calculation methodologies are adopted in different manners and can hardly be grasped 
by  experts  outside  of  the  country  where  it  was  adopted.  To  perform  their  technical 
analysis,  a  consortium  of  28  European  experts  was  necessary106.  Furthermore,  due  to 
these  different  underpinning  calculation  methodologies,  absolute  levels  of  minimum 
energy  performance  values  in  building  codes  cannot  be  directly  compared  across 
Member States.  

These  different  methods  lead  to  different  energy  performance  ratings,  beyond  the 
justifiable specific local conditions. Only 15 of the 35 methodologies are considered to 
be fully reliable for the calculation of the primary energy demand and compliant  with 
Annex I of the Directive. Non-compliance was often due to national methodologies not 
taking  the  positive  influence  of  highly  efficient  technical  solutions,  such  as  efficient 
district or block cooling systems or on site cogeneration, into account. In addition to the 
subsequent barrier to their emergence107, missing technical systems cannot be evaluated 
in cost-optimal calculations, which are no longer technology neutral.  

Even  when  calculation  methods  cover  highly  efficient  systems,  Member  States  may 
have  different  approaches.  For  instance,  electricity  production  from  photovoltaic 
systems  (PV)  is  generally  accepted  in  most  Member  States,  but  the  way  electricity  is 
accounted for in the national calculation procedures varies. From a sample, 17 out of 20 
Member States allow inclusion of electricity from PV, while 12 allow electricity from 
local  wind-turbines  and  combined  heat  and  power  (CHP)  to  be  included  in  the 
calculated energy performance of buildings. 9 of these 20 Member States also allow the 
inclusion  of  electricity  from  hydropower.  More  or  less  the  same  differences  and 
approaches apply for RES-based heating and cooling production108.  

These  differences  result  in  market  fragmentation  and  possible  barriers  to  certain 
technologies,  limiting  the  cost  reduction  potential  for  existing  technologies  and 
increasing costs of development of new efficient technologies.  

The  conclusion  must  be  made  that  the  common  general  framework  set  out  in  the 
Directive  is  insufficiently  detailed  to  achieve  the  initial  ambition  to  facilitate  the 
comparison  of  various  buildings'  investments  throughout  the  EU  for  prospective 
investors and make it easier for designers and constructors to apply similar standards in 
other Member States (as presented in the proposal for Directive 2002/91/EC109).  

106   Technical assessment of national/regional calculation methodologies for the energy performance of buildings, 

2015, European Commission (written by CSTB/TSUS) 
ibid. 
Implementing the Energy Performance of Buildings Directives, 2015, Concerted Action EPBD 

107 
108 
109   COM(2001)0226 final of 15 May 2001, proposal for a Directive of the European Parliament and of the Council 

on the energy performance of buildings 

76 

 
                                                 
The rationale behind addressing the integrated energy performance of buildings remains 
relevant.  The  integrated  energy  performance  considers,  in  addition  to  the  quality  of 
insulation  of  the  building,  heating  installations,  cooling  installations,  energy  for 
ventilation, lighting installations, position and orientation of the building, heat recovery, 
active  solar  gains  and  other  renewable  energy  sources.  The  emerging  market  for 
building integrated renewable generation technologies adds to the initial motivations for 
this choice.  

The current determination of the energy performance, in typical use conditions, is also 
relevant to provide appropriate market information for property valuation110 and enables 
the  engagement  of  owners  and  investors  (responsible  for  energy  performance  of 
buildings), to ensure compliance with legal requirements, or constructors and financial 
institutions, to establish more stringent contractual requirements.  

Different stakeholder groups, e.g. financial institutions, require information that makes 
sense to them and that can support informed decisions. In this context, information on 
actual  energy  consumption  complementary  to  information  on  the  asset  value  of 
buildings,  could  certainly  benefit  from  technical  progress  on  better  ICT,  e.g.  through 
the use of central databases to collect information and redistribute statistical data111.  

2.2.  Efficiency  in  the  setting,  application  and  enforcement  of  minimum  energy 
performance requirements  

Decisions  made  during  a  buildings'  design  stage  will  structurally  determine  energy 
consumption  over  much  of  their  lifetime.  Some  energy  efficiency  improvements  are 
possible  only  during  construction  or  by  major  refurbishment,  likely  to  happen  after 
several  decades.  The  setting  of  energy  efficiency  requirements  in  building  codes  is 
therefore one of the most important single measures for energy efficiency in buildings.  

The  provisions  of  the  2002  and  EPBD  had  a  direct  influence  on  minimum  standards 
applied to new buildings and to existing buildings undergoing renovation. As a result of 
these  directives,  a  strengthening  of  minimum  energy  performance  requirements  in 
building  codes  is  clearly  observed112.  Due  to  different  underpinning  national/regional 
calculation  methodologies,  absolute  levels  of  minimum  values  cannot  be  directly 
compared  between  countries.  However  in  relative  terms,  the  observed  tightening 
between 2005 and 2013 was for example 66% for new buildings in France, and 60% for 
new and existing residential buildings in Ireland.  

The EPBD aimed at ensuring a similar minimum level of ambition of minimum energy 
performance  requirements  across  Member  States.  For  this  purpose,  the  European 
Commission  established  a  comparative  methodology  framework  for  calculating  cost-
optimal  levels  of  energy  performance  requirements  for  buildings  and  building 
elements113. Although demanding, the cost-optimal calculation framework is positively 

110   e.g.  IEE  project  RenoValue  is  developing  a  training  toolkit  on  building  energy  performance  for  property 

valuation professionals, building upon EPCs in particular. See http://renovalue.eu/ 

111   Under  the  H2020  Energy  Efficiency  calls  in  2014  and  2015,  the  EE11  topic  looked  at  using  ICT  tools  to 
promote energy conscious consumer behaviour. In some of the selected ongoing projects such as the Greensoul 
project  and  the Orbeet  project, enhanced  displays and  information  through  mobile  apps  and  serious games  is 
provided to the consumer and user of the building in order to influence its behaviour towards energy use. 
Implementing the Energy Performance of Buildings Directives, 2016, Concerted Action EPBD 

112  
113  Commission  Delegated  Regulation  (EU)  No  244/2012  of  16  January  2012  supplementing  Directive 
2010/31/EU  of  the  European  Parliament  and  of  the  Council  on  the  energy  performance  of  buildings  by 

77 

 
                                                 
considered by stakeholders, including by national authorities, as an efficient instrument 
in ensuring the right balance between self-benchmarking of requirements in place and 
flexibility to consider different national contexts.  

The analysis of the first round of cost-optimal calculations revealed significant gaps114 
between  the  current  level  of  requirements  and  the  cost-optimal  level  for  half  of  the 
Member  states115.  As  described  in  Article  4  §1,  last  subparagraph,  these  gaps  must  be 
reduced "by the next review" that should take place within 5 years after the 31 March 
2013  deadline116,  i.e.  at  the  latest  on  31  March  2018.  This  process  (cost-optimal 
calculations – review of minimum requirements) is an iterative process that will further 
result in a periodic tightening of minimum requirements, including beyond 2020. As an 
example,  in  Slovakia  the  2013  minimum  energy  performance  requirements  for 
apartment blocks will be cut by half in 2016 due to the results of the calculation of the 
cost-optimal levels.  

Progress by individual Member States towards setting cost-optimal levels of minimum 
energy performance requirements is presented in a recent progress report117.  

From the comparison of reported cost-optimal levels and minimum energy performance 
requirements,  it  can  be  concluded  that  roughly  half  of  the  Member  States  have  set 
minimum performance requirements which are below the 15% threshold. For example, 
in  Denmark,  Finland  and  Spain  the  average  gaps  between  cost-optimal  levels  and 
minimum requirements for all building categories (i.e. new building, major renovations, 
and  building  elements)  and  types  (i.e.  single  family  houses,  apartment  buildings  and 
non-residential buildings) are below that threshold.  

This  flexibility  may  be  challenging  as  the  technical  ability  to  respond  to  some  of  the 
requirements  of  the  Directive  significantly  varies  from  one  Member  State  to  another. 
This concerns in particular the setting of minimum requirements for technical building 
systems  and  the  development  and  adoption  of  a  calculation  methodology  compliant 
with  the  general  framework  of  Annex  I  of  the  Directive.  These  national  and  regional 
calculation  methodologies  are  the  corner  stone  of  both  minimum  energy  performance 
requirements and certification of buildings.  

Specifically  for  new  buildings,  the  pathway  towards  nearly  zero-energy  buildings  by 
2020 is perceived as an important signal by the respondents to the public consultation 
that call for a similar vision for existing buildings.  

The NZEB concept mobilised stakeholders towards a common path. The first progress 
report  on  nearly  zero-energy  buildings  showed  little  progress  made  by  the  Member 
States  in  their  preparations  towards  NZEBs  by  2020118.  At  that  time  only  9  Member 

establishing  a  comparative  methodology  framework  for  calculating  cost-optimal  levels  of  minimum  energy 
performance requirements for buildings and building elements 

114   Gaps are considered significant when the minimum requirement is more than 15% higher than the cost-optimal 
level. If this gap cannot be justified, Member States have to plan the reduction of the gap within 5 years. 

115   Assessment of cost-optimal calculations in the context of the EPBD, Ecofys, 19 November 2015 
116   The  Commission  extended  the  original  deadline  of  30  June  2012  till  31  March  2013  to  account  for  the  time 

needed to develop and adopt the Commission Delegated Regulation. 

117   Report  from  the  Commission  to  the  European  Parliament  and  the  Council  –  Progress  by  Member  States  in 
reaching  cost-optimal  levels  of  minimum  energy  performance  requirements;  COM(2016)464  final  of  29  July 
2016. 

118   COM(2013) 483 final/2  

78 

 
                                                                                                                                               
States had submitted national plans. Despite the fact that an updated progress report in 
2014119 and information collected in 2015120 showed clear improvement compared to the 
Commission  progress  report  of  28  June  2013,  it  cannot  be  guaranteed  that  all  new 
buildings will be NZEB by 2020, all over Europe121. This could delay the realisation of 
related benefits.  

New  buildings  are  not  yet  built  at  cost-optimal  levels  across  the  EU  as  the  calculated 
optimal  levels  can  be  implemented  by  Member  States  within  5  years  after  the 
calculations were carried out. Minimum requirements are generally enforced at building 
permit stage, which  means that  buildings  can  be built  with the standards into force at 
the time of granting the permit. This time lapse may be problematic for the achievement 
of the NZEB targets. In addition, compliance and enforcement gaps are contributing to 
not reaching cost-optimal levels and this is equally true when it comes to NZEB.  

Evidence shows that Member States are falling short in their preparations to meet the 
NZEB target, mainly due to the need to adapt current practices well in time to ensure 
that  all new buildings  by the end of 2020 are NZEB. Such adaptation would mean in 
particular  the  swift  adoption  of  detailed  national  definitions  of  NZEB  where  not  yet 
available,  or  their  reinforcement  when  needed,  and  assessing  the  need  for  adapting 
current permit practices to make sure that all new buildings by 2020 are constructed in 
accordance with NZEB standards.  

Numerical  indicators  for  NZEB  standards  are  not  fully  comparable  across  Member 
States because different energy performance calculation methodologies are used. With 
this  caveat,  the  available  evidence  shows  that  for  residential  buildings,  most  Member 
States  aim  to  have  a  primary  energy  use  not  higher  than  50kWh/m²/yr.  The  maximal 
primary  energy  consumption  ranges  between  33kWh/m²/y  in  Croatia  (Littoral)  and 
95kWh/m²/y in Latvia with several countries (BE (Brussels), EE, FR, IE) aiming at 45 
or 50kWh/m²/y.  

The NZEB provisions naturally drive the use of renewable energy sources, notably on-
site as the energy produced on-building reduces the primary energy associated with the 
delivered energy. While several Member States require a renewable energy share of the 
primary  energy  used  or  a  minimum  renewable  energy  contribution  in  kWh/m²/year, 
others  use  indirect  requirement  such  as  a  low  non-renewable  primary  energy  use  that 
can only be met if renewable energy is part of the building concept122. This flexibility 
allows  adaptation  to  national  circumstances  and  local  conditions  (building  type, 
climate,  costs  for  comparable  renewable  technologies  and  accessibility,  optimal 
combination  with  demand  side  measures,  building  density,  etc).  The  most  frequently 
applied  renewable  energy  systems  in  NZEB  are  on-building  solar  thermal  and  PV 
systems. Other renewable energy sources used in these buildings are geothermal (from 
ground source heat pumps) and biomass.  

119   https://ec.europa.eu/energy/sites/ener/files/documents/Updated%20progress%20report%20NZEB.pdf  
120   Synthesis report on the national plans for NZEBs, 2015, JRC 
121   Communication  COM(2013)483/2  of  17  October  2013  on  Progress  by  Member  States  towards  Nearly  Zero-

Energy Buildings 
122   Towards  nearly 

the  EPBD 
(http://ec.europa.eu/energy/sites/ener/files/documents/nzeb_full_report.pdf), European Commission (written by 
Ecofys). 

zero-energy  buildings-  Definition  on 

common  principles  under 

79 

 
                                                 
The ZEBRA 2020123 project is collecting data on the gradual deployment  of NZEB in 
Europe. Figures on share of new dwellings built according to NZEB definitions ranged 
from few percentage points in several Member States to 28.1% in France, according to 
2012  figures.  However,  data  are  only  available  for  few  Member  States  (8  Member 
States  in  2012  and  only  2  Member  States  in  2015).  Additional  information  should 
become available through the development of the EU Building Stock Observatory.  

Experience  by  Member  States  with  practical  examples  of  existing  buildings  that  have 
an  energy  performance  level  in  the  expected  range  of  NZEB124,  indicates  an 
improvement  of  energy  performance  compared  to  current  national  requirements 
between  21%  and  202%,  with  an  average  74%  improvement.  The  average  additional 
costs compared to current national requirements is 208 €/m² or 11% of the total costs. 
However  there  are  also  buildings  with  zero  additional  costs  and  buildings  with  up  to 
473 €/m² or 25% of the total construction and technology costs. It must be noted though 
that some of these buildings are special demonstration projects or prototypes, and they 
may  not  be  representative  of  future  typical  costs  of  NZEBs  when  these  technologies 
become  standard.  Besides  these  averages  across  building  types,  NZEB  apartment 
buildings reported that costs that were affordable or financially attractive to the tenants. 
Additional  costs  compared  to  conventional  buildings  were  as  low  as  0  €/m²  for  one 
Croatian  and  one  Finnish  example,  20  €/m²  for  the  Danish  example,  27  €/m²  for  the 
Spanish example and 25 €/m² for a second Finnish example.  

The analysis of cost-optimal calculations indicates that a smooth transition between cost 
optimality and NZEB is achievable. Furthermore, the feasibility of the NZEB standard 
is  demonstrated by pioneer regions such as  Brussels, where NZEB is the standard for 
new  buildings  and  deep  renovations  since  2015.  Further  options  for  increasing  the 
effectiveness  of  the  measure  are  discussed  by  many  respondents  to  the  public 
consultation,  i.e.  better  linking  NZEBs  with  EPCs,  making  NZEB  a  specific 
certification class, and with finance, referring to NZEB in financial support schemes.  

For existing buildings, an important modification introduced by the recast of the EPBD 
was  the  deletion  of  the  1000m²  threshold  for  meeting  national  and regional  minimum 
requirements when buildings undergo a major renovation and the inclusion of minimum 
energy performance requirements for simple retrofits of building elements, both as part 
of the building envelope (e.g. windows) and of technical building systems.  

The effectiveness of measures on existing buildings and building renovation is strongly 
affected  by  lack  of  enforcement.  Smaller  renovations  do  often  not  require  a  building 
permit,  rendering  enforcement  of  minimum  requirements  practically  impossible.  Over 
three  quarters  of  Member  States  are  unable  to  report  compliance  rates  for  retrofitted 
building  elements  and  when  this  is  done,  compliance  rates  are  typically  very  low. 
Overall,  annual  energy  savings  achieved  so  far  by  Member  States  are  approximately 
42% lower than they would have been at 100% compliance with all minimum energy 
performance requirements125.  

123   http://www.zebra-monitoring.enerdata.eu/overall-building-activities/share-of-new-dwellings-built-according-

to-national-nzeb-definition-or-better-than-nzeb.html 

124   http://www.epbd-ca.eu/outcomes/2011-2015/CA3-BOOK-2016-A-web.pdf  
125   Energy Performance of Buildings Directive (EPBD) Compliance Study, 2015, European Commission (written 

by ICF International) 

80 

 
                                                 
The case of requirements for existing buildings requires deeper analysis given that most 
of the cost-efficient potential that remains concerns building renovation. The Directive 
distinguishes:  
 

the case of major renovations for which energy performance requirements must be 
ensured and met for the building,  
the  case  of  simple  retrofits  of  building  elements  (below  the  major  renovation 
threshold)  for  which  minimum  energy  performance  requirements  of 
the 
replaced/retrofitted element only must be ensured.  

 

Higher  ambition  on  major  renovations  of  existing  buildings,  regardless  of  their  size, 
was  justified  by  the  specific  opportunity  to  take  cost-effective  measures  to  enhance 
energy  performance  at  the  same  time  as  other  major  refurbishments.  It  is  generally 
accepted that the best moment for the introduction of more ambitious energy efficiency 
measures is when a building undergoes major renovation (of aspects other than energy), 
which is approximately every 25 years. At that stage, the relative additional investment 
needed is not high.  

There is no consensus regarding a single best approach to regulate the renovation work. 
A  holistic  major  renovation  approach  provides  the  greatest  increases  in  energy 
efficiency, by matching all components with each other126 but requires more investments 
to  design  the  most  cost-effective  solution.  On  the  other  hand,  requirements  linked  to 
building  elements  limit the burden, but  are also  more difficult to  trace and enforce as 
they are often not linked to an obligation for building permit.  

The Impact Assessment for the EPBD acknowledged that renovations are usually made 
‘step  by  step’,  and  that  those  single  steps  should  not  trigger  the  major  renovation 
threshold. However, the Directive does not provide tools to ensure that such elemental 
upgrades follow a consistent intervention logic over time. This gap was highlighted by 
the  respondents  to  the  public  consultation  and  requires  further  analysis  in  the  Impact 
Assessment.  

The  assessment  of  the  first  building  long-term  renovation  strategies,  submitted  under 
Article 4 of the Energy Efficiency Directive (EED), showed that Member States need 
further  guidance  and  support  for  quantification  (setting  of  targets,  expected  energy 
savings  and  benefits)  and  forward  looking  aspects  required  to  guide  investments  into 
building renovation. At individual level, building owners and occupants face a lack of 
information  on  how  to  plan  and  implement  improvements  in  energy  efficiency  in 
buildings  over  time  (e.g.  optimal  route  for  step  by  step  energy  renovation,  timeline, 
costs,  benefits  and  solutions  to  overcome  the  ‘hassle  factor’  and/or  intrusiveness  of 
renovations).  

For technical building systems (TBS), confusion has arisen about the interpretation of 
‘existing  buildings’,  which  is  sometimes  taken  to  mean  only  buildings  that  are 
undergoing renovation. The EPBD makes clear that regulations are needed for all TBS 
installations, whether or not the building is undergoing renovation. The EPBD requires 
that  the  regulations  cover  energy  performance,  proper  installation,  dimensioning, 
adjustment, and control.  

126   Energy efficiency in heating systems in industry and production, 2011, Deutsche Energie Agentur (DENA) 

81 

 
                                                 
TBS  must  be  considered  at  system  level,  which  is  distinct  from  whole  building 
performance (as measured for EPCs) and individual product performance (as measured 
for  minimum  standards  and  energy  labelling  under  products  legislation).  To  analyse 
systems,  building  data  are  needed  as  the  services  demand  from  the  building  affects 
dimensioning  and  performance.  Calculations  are  usually  required  and  designers  and 
installers  need  established  procedures  to  follow,  which  are  technology  and  site 
dependent, introducing complexity to the whole process.  

At  least  13  Member  States  have  set  minimum  standards  for  the  overall  energy 
performance  of  TBS  installed/retrofitted  in  existing  buildings  but  only  5  have 
developed practical methods for this purpose. In addition, coverage of all technologies 
and their installation, dimensioning, adjustment, and control, is a significant challenge, 
even  more  important  for  combinations  of  systems  (explicitly  mentioned  in  the 
EPBD)127. This confirms the qualitative feedback provided by Member States and some 
respondents  to  the  public  consultation,  raising  that  practical  implementation  was 
challenging. Regulations for TBS are not obligatory in new buildings. Nevertheless, at 
least 18 Member States apply TBS regulations to new as well as existing buildings, and 
in 12 cases the same regulations apply to both.  

Under Article 8(2), the EPBD requires MSs to encourage the introduction of intelligent 
metering  systems  whenever  a  building  is  constructed  or  undergoes  major  renovation 
and to encourage, where appropriate, the installation of active control systems such as 
automation, control and monitoring systems that aim to save energy. Monitoring is not 
yet  implemented  by  any  Member  State;  there  is  low  awareness  of  its  potential. 
Concerns remain about privacy, security, safety and cost-effectiveness. There might be 
some  scope  for  integration  at  technical  level  of  interoperability  and  arrangements  for 
data  collection,  transmission  and  display  between  different  meters  at  building  and/or 
system levels that could ease the practical implementation and enforcement of Article 8 
on TBS throughout the EU.  

The consultation  of Member  states, organised in the  context  of the Concerted Action, 
indicated that the mandatory setting of overall technical building system requirements 
in  existing  buildings  is  complex,  difficult  to  define  and  expensive  to  enforce.  The 
setting of overall technical building system requirements is generally considered as not 
economically justified by Member States.  

Regarding  operation  of  buildings,  stakeholders  pointed  out  that  more  could  be  done. 
Buildings managers and occupants have limited tools to optimise building performance 
during operation. Potentials remain untapped for benefiting from new technologies such 
as  building  automation,  intelligent  metering  and  maintenance  of  technical  systems. 
Smart  building  energy management  systems  can  produce  savings  for  space  heating  in 
the range of 2-30% and for cooling 37-73% depending on the climate and building type. 
Services  buildings  consume  most  of  Europe’s  space  cooling128.  Building  operation 
needs  to  be  improved  through  better  benchmarking,  using  smart  information 
technologies, sub-metering, real time information, and other innovative technologies.  

The  limited  provisions  of  the  EPBD  aiming  at  incentivising  the  use  of  electronic 
monitoring  and  control  of  technical  building  systems,  and  more  generally,  the 
installation  of  building  automation  and  control,  had  limited  uptake  so  far.  The  EPBD 

Implementing the Energy Performance of Buildings Directives, 2015, Concerted Action EPBD 

127  
128   An EU Strategy on Heating and Cooling, COM(2016) 51 final 

82 

 
                                                 
include  two  provisions  which  could  be  considered  to  introduce  building  smartness  in 
the landscape:  

An  encouragement  to  the  installation  of  active  control  systems  such  as  automation, 
control and monitoring systems that aim to save energy,  

The possibility offered to Member States to reduce the frequency of regular inspections 
of  heating  and  air-conditioning  systems  or  lighten  such  inspections,  as  appropriate, 
where an electronic monitoring and control system is in place.  

In this area, projects like iSERVcmb129 demonstrated the potential benefits of electronic 
monitoring  of  energy  efficiency  of  technical  building  systems.  These  potentials  have 
been insufficiently used so far. No Member State made use of the possibility offered by 
the  Directive  to  reduce  the  inspection  frequency  where  electronic  monitoring  and 
control system is in place. At present, only one Member State is preparing regulations 
that will recognise monitoring as a partial substitute for inspection.  

Moreover,  a  new  European  standard  for  smart  appliances,  SAREF  (Smart  Appliances 
REFerence ontology) was developed by the European Commission in close cooperation 
with industry and the European Telecommunication Standards Institute (ETSI) to create 
a new reference "language" for energy-related data130. This new language will be used 
by home devices, allowing them to exchange information with any energy management 
system. SAREF has the potential to enable the smart grid demand-response mechanism, 
to  bring  energy  and  cost  savings,  and  to  open  new  markets.  To  fully  achieve  these 
goals,  efforts  are  already  planned  to  align  SAREF  with  existing  standards  for  smart 
meters and external services, to fill in potential gaps and extend SAREF where needed.  

The  EPBD  review  represents  an  opportunity  to  better  define  the  smartness  concept, 
reinforce conditions applicable to BEMS, further promote building automation and use 
of  website  platforms  and  apps,  and  foresee  the  introduction  of  standards  to  ensure 
interoperability.  These  aspects  require  further  analysis  in  the  subsequent  Impact 
Assessment phase.  

The  specific  obligation  to  ensure  that,  before  construction  starts,  the  technical, 
environmental  and  economic  feasibility  of  high-efficiency  alternative  systems  is 
considered  and  taken  into  account  was  several  times  quoted  as  an  example  of 
unnecessary burden, in particular by Member States.  

2.3. Efficiency in providing information through certification and inspection  

The  provisions  on  EPCs  have  proved  to  be  effective  in  creating  a  demand-driven 
market for energy efficient buildings by providing information to building owners and 
tenants  on  the  energy  performance  of  their  buildings,  heating  and  air-conditioning 
systems, and on effective ways to improve these through building renovation works It 
was statistically established that the improvement in energy performance, as calculated, 
is  associated  with  reduction  in  household  energy  expenditure131.  In  various  recent 

129  http://www.iservcmb.info/  
130   https://ec.europa.eu/digital-agenda/en/blog/new-standard-smart-appliances-smart-home  
131   E.g. Household fuel expenditure and residential building energy efficiency rating in Ireland, 2015, Curtis J. & 

al. 

83 

 
                                                 
studies132,  the  EPC  is  seen  as  an  effective  tool  with  strong  impact  on  sales  and  rental 
prices  in  the  real  estate  market.  The  EPBD  recast  further  reinforced  this  aspect  by 
requiring  the  inclusion  of  the  EPC  indicator  in  advertisement  and  commercial  media. 
Based  on  an  analysis  of  residential  markets  in  Europe,  findings  indicate  that  a  better 
performing building resulted in up to 5-10% higher sale or rental prices per energy class 
on average133.  

Despite  the  fact  that  tenants  and  buyers  are  increasingly  interested  in  their  domestic 
energy bills with a significant influence on their choice of home, this positive effect is 
limited  in  certain  Member  States  due  to,  importantly,  the  absence  of  accompanying 
measures,  as  well  as  a  lack  of  trust  and  understanding  in  EPCs134  in  some  Member 
States.  Examples  of  effective  accompanying  measures135  are  linking  cost-effective 
recommendations  in  EPCs  to  mortgage  options  or  creating  synergies  between  EPC 
schemes and financial support for building renovation. The lack of trust is in particular 
related to the discrepancy between the energy rating and actual energy consumption by 
owners/renters.  Partly  due  to  lack  of  understanding  about  the  label  among  the  public 
about  what  the  rating  means  and  partly  lack  of  trust  in  the  assessment  method  and 
quality  of  assessments  and  the  fairness  of  the  calculation methodology  used.  Member 
States  are  aware  of  these  concerns  and  are  addressing  them  in  different  ways  for 
instance with focus on improving quality assurance of assessors and EPCs and quality 
control of EPCs via EPC databases.  

At  its  introduction  in  2002  EPCs  were  considered  a  pioneering  instrument,  one  that 
would  help  overcome  an  information  deficit  hindering  consumer  interest  in  energy 
efficient  buildings.  At  present,  all  EPCs  include  a recommendation  section  to  provide 
tailor-made  advice  on  how  to  improve  the  energy  performance  of  buildings.  After 
several years of implementation, the contribution of the EPC recommendations towards 
stimulating  renovation  is  limited.  The  global  economic  context  is  certainly  a  limiting 
factor but some respondents to the public consultation challenge any causality between 
the recommendations that are provided in EPCs and action taken to upgrade the energy 
efficiency  of  buildings.  This  is  backed-up  by  studies136  bringing  evidence  that  EPC 
recommendations had a weak influence, especially pre-purchase. While it is required by 
Article  11  that  EPCs  must  include  recommendations  for  the  cost-optimal  or  cost-
effective  improvement  of  the  energy  performance  of  a  building  or  building  unit,  and 
although  most  Member  States  have  this  in  place  in  legislation,  little  evidence  exist 
today of whether these recommendations actually lead to increased renovation rates as 
intended.  This  could  be  due  to  lack  of  requirements  for  reporting  potential  measures 
that  has  been  done  due  to  the  recommendations,  or  it  could  be  due  to  the  absence  of 
appropriate  accompanying  measures  and  limited  trust  in  the  certificates  in  some 
Member  States,  which  leads  to  little  attention  being  paid  to  the  recommendations 
included in the certificates.  

132  For  example:  Institute  for  European  Environmental  Policy  (IEEP);  Directorate-General  for  Energy  (DG 
Energy), 2013; The impact of Energy Performance Certificates on the rental and capital values of commercial 
property assets, 2011, F. Fuerst and P. McAllister 

133   Energy  performance  certificates  in  buildings  and  their  impact  on  transaction  prices  and  rents  in  selected  EU 

countries, 2013, Bio Intelligence Service 

134  Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 

by ICF international) 

135   For example "The influence of the Energy Performance Certificate: the Dutch case", Energy Policy volume 67, 

April 2914, pages 664-672. 

136   e.g. "The influence of the energy Performance Certificate: The Dutch case", 2014, Murphy L. 

84 

 
                                                 
Finally,  the  provisions  for  the  EPCs  do  not  require  an  harmonised  methodology  for 
calculating  the  energy  performance  of  buildings.  As  EPCs  are  not  based  on  the  same 
methodology, EPCs have not yet succeeded in supporting a comparable pan-European 
market  for  buildings  energy  efficiency  investments137,  nor  led  to  reduction  of  related 
transaction  costs.  The  primary  underlying  reason  is  to  be  found  in  the  lack  of 
transparency of the national calculation methodologies that determine the energy rating 
that  is  included  in  the  EPC  (C  class,  for  instance).  When  the  methodology  for 
calculating energy performance and the scaling and labelling differs from Member State 
to  Member  State,  and  sometimes  from  region  to  region,  the  same  building  placed  in 
different  Member  States,  e.g.  two  different  sides  of  a  national/regional  border  could 
differ in rating, with the same climate conditions. This is equally true for investments 
into  non-residential  buildings  or  for  the  bundling  of  smaller  scales  investments  in  the 
residential  sector,  which  need  underlying  standards  to  rate  the  quality  of  the  bundle 
based on the quality of its parts.  

A  similar  picture  can  be  drawn  regarding  the  regular  inspection  of  heating  and  air-
to  recommend 
conditioning  systems.  The  essential  purpose  of 
improvements  to  energy  performance  that  are  cost-effective.  When  issued,  inspection 
reports  tend  to  be  over-complicated  and  poorly  suited  to  the  needs  of  non-expert 
building owners; this means they are at greater risk of being ignored. Inspection reports 
are  seen  as  duplicating  the  recommendation  section  of  the  EPCs  where  advice  on 
building  improvements  is  already  being  given.  Though  the  opinion  of  the  Member 
States is that the information produced for EPCs is not sufficiently detailed for heating 
and AC systems.138.  

inspection 

is 

Although  reinforced  by  the  EPBD,  studies139  show  overall  limited  progress  made  as 
regards  the  independent  quality  control  of  EPCs  and  inspections.  After  surveying  the 
Member  States  in  March  2014,  the  Commission  services  observed  that  too  small 
samples were randomly checked in most Member States to derive any conclusion on the 
quality of EPCs and inspection reports.  

Certification  is  sometimes  seen  as  an  administrative  burden,  and  there  is  limited 
willingness to pay higher prices for high quality EPCs and it is generally agreed that the 
reliability  of  EPCs  must  be  significantly  improved.  In  particular,  concerns  were 
expressed,  although  not  fully  grounded  by  evidence,  with  the  quality  and  possible 
benefits of systematic recommendations, when compared to their costs140. Today EPCs 
for  single  family  houses/apartment  are  typically  sold  for  85-140€141,  but  lower  prices 
below 50€ are also observed on the market. Such prices hardly leave the time to provide 
tailor made recommendation that could be trusted and taken up by building owners.  

Targeted  advice  for  households  is  considered  effective  in  only  13  Member  States142. 
Online calculators that act as a quick and simple way to work out how you could reduce 
your  energy  bills  can  use  EPC  data  to  propose  concrete  energy-efficiency  solutions 

137  Energy Efficiency Financial Institutions Group, "Energy Efficiency – the first fuel for the EU Economy. How 

to drive new finance for energy efficiency investments", February 2015, http://www.eefig.eu  
Implementing the Energy Performance of Buildings Directives, 2016, Concerted Action EPBD 

138 
139  Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 

by ICF international) 

140  Public  Consultation  on  the  Evaluation  of  the  EPBD  –  Final  synthesis  report,  2015,  European  Commission 

(written by Ecofys) https://ec.europa.eu/energy/sites/ener/files/documents/MJ-02-15-954-EN-N.pdf 

141   http://www.viadiagnostic.fr/tarif-diagnostic-immobilier.html  
142   Energy Efficiency Watch, 1015, Survey report - Summary and main conclusions 

85 

 
                                                 
(sometimes  referred to as called Home Energy Check) offer alternatives to systematic 
cheap recommendations143.  

More  holistic  approaches  to  EPCs  implementation  are  already  in  application  in  some 
Member States and may reduce administrative burden, for example:  
  The setting of minimum requirements according to EPC energy classes that enable 
the  use  of  EPCs  to  ensure  compliance  and  a  monitoring  of  the  building  stock 
through a central EPC database,  

  The involvement of other actors in the checking process (e.g. notaries for the hand 
over, of ECPs  including for the rental agreement  which  practically  ensures 100% 
compliance),  

  Appropriate accompanying measures such as a more systematic link between EPCs 
and financial support, e.g. with an ex-ante and ex-post energy performance rating 
to set and check the appropriate level of financial support, or linking cost effective 
recommendations in EPCs to mortgage options.  

Regarding  inspection  schemes,  the  EPBD  left  the  possibility  to  opt  for  alternative 
measures to regular inspection schemes, to the condition that the alternative measures 
demonstrate  equivalent  energy  saving  impacts.  In  fact,  13  Member  States  opted  for 
equivalent alternative measures to the regular inspections of heating systems and 7 for 
air-conditioning systems144. The justifications provided by the Member States that opted 
out  of  the  regular  inspection  regime  include  high  cost  relative  to  benefits,  the  small 
number  of  individual  boilers  compared  with  district  heating,  and  that  regulations 
already ensure high standards beyond which there is little scope for improvement.  

Other factors influencing the decision are that inspection is intrusive and unpopular, has 
doubtful  benefits  as  there  is  no  obligation  to  follow  the  recommendations  in  the 
inspection report, and the risk that it becomes simply a ‘compliance exercise’ with little 
value.  

Energy performance certification of buildings on the other hand, is considered as a key 
policy  instrument  that  can  assist  governments  in  reducing  energy  consumption  in 
buildings145, by increasing public awareness and stimulating the creation of a demand-
driven market for energy efficiency in buildings.  

However, energy performance certification of buildings should not be viewed as a goal 
in itself but as a key instrument to support and monitor the policy implementation and 
enforcement. Building rating programmes are considered to have greatest impact when 
integrated  into  a  strategic  and  coordinated  energy  efficiency  policy  framework146.  The 
relevance  of  such  instrument  is  therefore  conditioned  to  its  better  integration  into  the 
regulatory framework (link to minimum standards) and to broader initiatives designed 
to tackle multiple barriers (information campaigns and financial support).  

There  is  an  increasing  number  of  best  practices  across  Europe  that  demonstrate  the 
added  value  of  EPC  data  for  policy  making  (e.g.  to  inform  relevant  renovation 
strategies)  and  monitoring,  as  well  as  market  and  research  analysis.  IEE  project 

143   Request to Action project IEE/13/789, www.buildings-request.eu, Best practice meeting 
144 
145  
146  

Implementing the Energy Performance of Buildings Directives, 2016, Concerted Action EPBD 
IEA, 2010, Policy Pathways: Energy Performance Certification of Buildings 
IPEEC, 2014, Building Energy rating schemes 

86 

 
                                                 
EPISCOPE147 has found that EPC's are an important data source but need to be cross-
referenced with other data. If used in isolation data from EPCs often do not fully align 
with data/policy needs, are insufficiently accurate or not representative.  

While it is not compulsory to set up a central/regional EPC register, almost all MS have 
advanced in setting up a system to collect EPC data. These measures were mostly taken 
in  the  context  of  monitoring  and  quality  control  of  energy  certification  processes 
(required by the EPBD). In 2014, 24 countries had an operational central/regional EPC 
registers (plus Norway; Poland, Latvia, Luxemburg and the Czech Republic lining up to 
launch their own registries). In some countries (e.g. the United Kingdom and Belgium – 
Flanders), there are separate databases for residential and non-residential buildings. For 
Italy  and  Spain  the  databases  are  only  available  in  selected  regions.  The  standardised 
methodologies and formats of data collecting and sharing are still limited and should be 
promoted. EPC schemes are a tool that could be used for mapping and monitoring the 
national  and  European  building  stock  and,  if  properly  implemented,  they  could  allow 
for  the  assessment  of  real  market  needs  and  the  potential  for  energy  efficiency 
improvements in the building sector148.  

Best practice from several EU member states, in particular Italy (Lombardy) Portugal, 
UK (Scotland), Ireland and the Netherlands has shown the potential of EPC databases 
when linked with other datasets and when opened up to wider circles of stakeholders. 
However, data protection and privacy issues need to be taken into account. 149  

Evidence derived from the public consultation shows that the recommendations section 
of  EPCs  is,  in  principle,  also  relevant  in  targeting  renovations.  However,  simply 
providing  tailor  made  recommendations  to  improve  energy  performance  proved  to  be 
insufficient to trigger investments if EPCs are not embedded within an integrated policy 
framework that includes accompanying measures. In addition, the current low level of 
confidence in the instrument150 limits the potential role that recommendations can play.  

In  multi-unit  buildings,  the  association  of  energy  rating  with  recommendation  poses 
specific challenges. When subject to individual metering, the energy performance rating 
of  single  building  units  based  on  the  average  performance  of  the  whole  building 
provides inconsistent information to individual owners. This would be in favour of an 
energy  performance  individual  rating.  However,  at  the  same  time,  recommendations 
targeting individual flats or building units would be in contradiction with the necessary 
agreement  of  the  different  owners.  Such  individual  recommendations  would  render 
whole building retrofit based on EPC recommendations virtually impossible151.  

Therefore,  policy  options  regarding  energy  performance  rating  and  recommendations 
should explore new approaches to remove the barriers to full effect of EPCs and to the 
emergence  of  a  market  for  renovation  and  subsequent  transformation  of  the  building 
stock.  

147   See www.episcope.eu  
148   EPCs across the EU, 2014, BPIE 
149  Request to Action project IEE/13/789, European Best Practice meeting on EPC Databases, 04.11.14, Brussels 
150   Energy Performance of Buildings Directive (EPBD) - Compliance Study, 2015, European Commission (written 

by ICF international) 
151   LEAF Challenge project 

87 

 
                                                 
2.4.  Efficiency  in  relation  to  financial  and  fiscal  incentives  and  information 
campaigns (EPBD Articles 10 and 20)  

When  looking  at  all  the  economic  instruments  for  energy  efficiency  which  were 
running  in  2013,  it  is  estimated  that  around  €  9  billion  were  collectively  spent  on 
average by these programmes every year to support buildings renovation, which led to 
investments  of  around  €24  billion.  90%  of  these  funds  were  coming  from  national  or 
regional budgets, while remaining sources were constituted of EU funds, revenues from 
selling  Assigned  Amount  Units  (AAU)  Surplus,  funds  by  International  Financial 
Institutions  and  other  sources.  These  funds  were  mainly  channelled  through 
governments  and  energy  efficiency  agencies.  They  were  predominantly  offered  in  the 
form of grants/subsidies, followed by loans and tax incentives152.  

According  to  the  ex-post  evaluation  of  Cohesion  Policy  Programmes  2007-2013,  129 
national public financing mechanisms were identified to be in place between 2007 and 
2013 in the EU 27 Member States to increase energy efficiency in buildings153. 90% of 
the  European  Regional  Development  Fund  (ERDF)  and  the  Cohesion  Fund  (CF) 
investments  for  energy  efficiency,  co-generation  and  energy  management  were 
provided in the form of non-repayable grants.  

In general, there is some small progress in most Member States in terms of improving 
the focus, leverage and impact of informational and financial initiatives154.  

Although  public  funds  allocations  underpinning  investments  in  building  energy 
efficiency  are  steadily  increasing  (e.g.  EUR  18  billion  of  European  Structural  and 
Investment Funds (ESIF) 2014-2020 allocated to energy efficiency investments, mainly 
in  buildings),  information  on  their  effectiveness  still  remains  limited  both  at  EU  and 
national levels.  

An overview of value added tax (VAT) rates across the European Union indicates that 
several  Member  States  apply  reduced  rates  for  social  housing  and  for  renovation  of 
private  dwellings155.  One  of  the  purposes  of  these  reduced  rates  is  to  stimulate  energy 
efficiency related investments in buildings and improve their affordability which could 
lead  to  increased  renovation  activity  at  national  level  and  its  depth.  As  regards  the 
latter, the latest analysis of Member States’ measures in support of the implementation 
of NZEBs156 shows that several Member States have adopted tax incentives for energy 
renovations and taxation mechanisms as a tool to support building renovations towards 
deeper, NZEB levels.  

The majority  of energy efficiency measures in  buildings are and should be funded by 
private  finance,  with  public  subsidies  (both  direct  and  indirect)  acting  as  a  lever  and 
catalyst,  not  only  to  allocate  scarce  public  resources  where  they  are  needed  most  but 
also  to  mobilize  private  capital  allocation.  In  this  respect,  one  of  the  delivery 
mechanisms (notably in public buildings sector and SMEs) based on private finance – 
funded  investments  paid  off  through  savings  is  the  Energy  Performance  Contracting 

152   JRC report on Financing building energy renovations, 2014 
153   A  recent  study  mapping  the  current  financial  schemes  for  energy  efficiency  across  the  EU  is  under 

development. 
Implementing the Energy Performance of Buildings Directives, 2016, Concerted Action EPBD 

154 
155   http://ec.europa.eu/taxation_customs/resources/documents/taxation/vat/how_vat_works/rates/vat_rates_en.pdf 
156   JRC synthesis report on national plans for NZEB, 2016 

88 

 
                                                 
(EnPC) 157. However, despite its potential158 and solid business case, the EnPC market is 
still underdeveloped in the EU (compared for example to the US market159).  

The EPBD's impact on the EnPC market growth has so far been limited, mostly due to 
the  fact  that  the  track  record  (data)  on  energy  efficiency  investments'  impacts  in 
buildings has not been robustly established, which in turn prevented building operators 
and  Energy  Service  Companies  from  realising  the  full  investment  potential  related  to 
the  reduction  of  operational  costs.  Another  stumbling  block  for  EnPC  investments 
growth  in  the  public  sector  that  go  beyond  the  EPBD  provisions  are  the  EU  Stability 
and  Growth  Pact  and  related  provisions  (ESA  2010,  MGDD).  According  to  these 
provisions,  EnPC  investments  are  required  mostly  to  be  consolidated  on  the  balance 
sheet  of  public  sector  entities  (unless  constructed  as  PPPs),  increasing  public 
debt/deficit.  In  turn,  many  energy  efficiency  investments  planned  in  the  public  sector 
are  either  not  realised,  or  decided  to  be  funded  through  subsidies  (that  have  no 
implications on debt/deficit) which, as a consequence, limits the scope for EnPCs going 
forward in the EU.  

A  number  of  IEE  and  Horizon  2020  projects  support  the  development  of  the  EnPC 
market,  by  improving  confidence  in  EnPC160,  developing  EnPC  facilitation  services161, 
or training EnPC contractors to develop new service offers162. Concrete implementation 
of EnPC is also addressed by several Project Development Assistance (PDA) projects163, 
funded  under  IEE  and  H2020,  with  a  focus  on  public  buildings164,  including  the 
aggregation of small investments by municipal authorities165, as well as on multifamily 
buildings166 and social housing167.  

A number of other financing and delivery mechanisms for building energy renovation 
are  being  developed  and  implemented  throughout  the  EU168.  They  include  the 
development  of  integrated  services  or  operators  for  building  renovation  on  public 
buildings169 or deep renovation of private housing170.  

157  Energy  Performance  Contracting  (EPC)  is  a  form  of  ‘creative  innovative  financing’  for  capital  energy 
retrofitting improvement which allows funding energy upgrades from cost reductions by providing a guarantee 
on energy savings; upfront investments may be financed by the contractor or by the building owner. 

158  The European ESCO Market Report 2013, 2014, European Commission DG JRC 
159  In  the  USA,  the  volume  of  investments  through  Energy  Performance  Contracting  transactions  reached  around 

USD 7.9 billion since 1999 and is expected to grow to around USD 11-15 billion by 2020.  

160   Transparense and Trust EPC South projects 
161   Transparense, EESI2020, Streetlight EPC, EnPC Intrans, GuarantEE projects  
162  EPC PLUS project 
163  http://ec.europa.eu/energy/intelligent/getting-funds/project-development-assistance/  
164   MLEI BEAM GRAZ (AT) project 
165   MLEI  2020TOGETHER  (IT),  FESTA  (IT),  MLEI  GLEE  AM  (PT),  MLEI  MARTE  (IT),  MLEI  ENSAMB 

(NO) 

166   MLEI POSIT'IF (FR), SUNSHINE (LV) projects 
167   ENERSHIFT (IT), LEMON (IT) projects 
168   An  analysis  can  be  found  in  'Increasing  capacities  in  Cities  for  innovating  financing  in  energy  efficiency.  A 
review of local authority innovative large scale retrofit financing and operational models', CITYnvest project, 
2015, 
http://www.citynvest.eu/sites/default/files/library-documents/20151202_WP2%20Final%20Report-
V1.3.pdf. The CITYnvest project assesses innovative financing models, introduces them in a tailored way in 3 
pilot regions and conducts corresponding capacity building in 10 focus countries. 

169   MLEI ESCOLIMBURG2020 (BE) project 
170   MLEI POSIT'IF (FR), MLEI PSEE Alsace (FR), ELENA Picardie (FR) 

89 

 
                                                 
The strong economic narrative for MFF 2014-2020, also  supported by the Investment 
plan for Europe, calls for innovative approaches when allocating public funds through 
wider use of appropriate financial instruments171. Some progress has been achieved (e.g. 
European Energy Efficiency Fund and Private Finance for Energy Efficiency Initiative 
at  the  EU  level  and  the JESSICA  II  Fund  in  Lithuania  are  explicitly  targeting  energy 
efficiency  investments  in  buildings),  but  the  energy  efficiency  investments  market 
needs  to  evolve,  mature  and  grow  further.  Large  scale  renovation  of  buildings  across 
Europe  requires  (at 
finance  supply  side)  standardisation172,  simplification, 
transparency, right combination of public/private funds and development and roll-out of 
attractive financing products (e.g. green mortgages). On the finance demand side, long-
term regulatory stability and clarity, demand creation and full understanding of related 
benefits are key drivers that need to be addressed.  

the 

The regulatory framework and financial architecture (i.e. ways of using public money) 
have to be mutually supportive, and address important barriers that still hamper further 
uptake of energy efficiency investments in buildings, including:  
  Lack  of  awareness  and  expertise  regarding  structuring  investible  projects  on  the 

part of all actors, in particular public authorities173;  

  Fragmented and isolated small-scale investments driving up transaction costs;  
  High initial capital expenditure, with relatively long pay-back periods;  
 

(Perceived) high credit risk mostly stemming from missing (financial performance) 
track  record  due  to  weak  monitoring  and  reporting  of  impacts,  and  leading  to  an 
asset-based  lending  (mortgages,  corporate  debt)  rather  than  non-recourse  lending 
(featuring-in the increase in asset value or cash flows generated by savings) ; and  

  Competing investment priorities of final beneficiaries174.  

To address this diagnosis, the Energy Efficiency Financial Institutions Group provided 
six recommendations to policy makers175:  
  Ensure 
the  effective 

transposition  and  enforcement  regarding 
performance of buildings (including their performance certification),  
  Deliver regulatory stability for energy efficiency investments in buildings,  
  Address the need for high quality buildings performance data and standards.  
 

Initiate  a  review  and  benchmarking  process  to  better  understand  the  decision 
making frameworks for public buildings,  

the  energy 

  Benchmark  and  compare  the  relative  successes  of  retail  residential  energy 

efficiency investment programmes in the Member States,  

171  Cf.  Infinite  Solutions  project,  developing  financial  instruments  for  renovation  of  housing  and  internal 

performance contracting in 9 cities in Europe; CITYNVEST project 

172   Under  Horizon  2020,  the  Investor  Confidence  Project  Europe  (ICPEU)  is  developing  standard  protocols  to 
facilitate the due diligence process for financiers; on this basis, the SEAF project is developing an integrated 
project  valuation  and  risk  assessment/mitigation  platform  which  will  facilitate,  inter  alia,  the  match-making 
between project developers and investors.  

173   For example, IEE project CERtuS identifies barriers to financing of renovation projects in four Mediterranean 

municipalities. See www.certus-project.eu  

174   Communication COM(2013)225 final of 18 April 2013 reporting on Financial support for energy efficiency in 

buildings 

175   Energy  Efficiency  –  the  first  fuel  for  the  EU  Economy:  How  to  drive  new  finance  for  energy  efficiency 

investments, 2015, Energy Efficiency Financial Institutions Group (EEFIG) 

90 

 
                                                 
  Ensure  that  Member  States  adequately  identify  the  funding  streams  for  their 

National Buildings Renovation Strategies (Article 4 of the EED).  

A  number  of  EU-funded  projects  gave  examples  about  how  to  overcome  such  non-
technical  barriers.  In  northern  European  countries,  the  project  Total  Concept  is 
proposing  to  owners  of  non-residential  buildings  a  package  of  energy  efficiency 
measures when they plan to renovate their assets. The package is tailor-made not only 
to  the  building  and  to  the  needs  of  the  users,  but  also  in  line  with  the  profitability 
expectations of the investor. By packaging the measures, deeper energy cuts and higher 
return  on  investment  can  be  reached176.  In  warm,  Mediterranean  countries,  the  project 
RepublicZEB  has  developed  a  definition  of  passive  houses  in  warm  climates.  It  has 
enabled participating public authorities to learn from best-practice is similar European 
regions177. The LEAF project works with multi-owner apartment blocks on overcoming 
challenges  of  decision-making  in  divided  ownership178.  The  Powerhouse  NZC  has 
boosted knowledge, monitoring and implementation of NZEB in social housing across 
Europe179.  All  projects  have  confirmed  the  importance  of  seizing  windows  of 
opportunity, in particular moments when deep renovations are anyways planned and/or 
when financing becomes available.  

The  recently  adopted  EU  Strategy  on  Heating  and  Cooling  indicated  that,  under  the 
Smart Financing for Smart Buildings initiative, the Commission will:  
  Facilitate  the  aggregation  of  small  projects  into  investible  packages,  and,  with 
EEFIG,  test  a  framework  for  underwriting  procedures  for  financial  institutions  to 
incorporate energy efficiency in everyday market practice;  

  Encourage Member States to establish one stop shops for low-carbon investments 
(encompassing  advisory  services,  Project  Development  Assistance  and  project 
financing); and  

  Encourage retail banks to offer products adapted for renovation of privately rented 
buildings (e.g. deferred mortgages, term loans) and disseminate best practices, also 
in relation to tax treatment of renovation.  

It has been estimated that public support for building renovation investment frequently 
yield a net financial gain to the State, around €5 back to public finances for €1 invested 
by government in renovations180.  

However,  a  significant  weakness  is  that  monitoring  of  results  and  effectiveness  of 
policies  and  programmes  remains  underdeveloped 
in  most  Member  States181. 
Incorporating  the  need  for  both  ex-ante  evidence  base  and  ex-post  monitoring  into 
policy and programme planning will help identify data needs and collection approaches, 
and there is scope for standardised performance data collection and evaluation systems 
to  minimise  administration  and  transaction  costs182  for  financiers  and  users.  Ex-ante 

176   Total Concept, IEE/13/613, www.totalconcept.info  
177   RepublicZEB, IEE/13/886, www.republiczeb.org  
178   LEAF, IEE/12/658, www.lowenergyapartments.eu 
179   PowerhouseNZC, IEE/11/007, www.powerhouseeurope.eu  
180   Horizon  2020  projects  COMBI  and  IN-BEE,  Renovate  Europe  Campaign  and  KfW  energy  efficiency 

programmes in Germany 

181  Study " Lead market initiative - assessing the impact of national recovery measures on construction in the EU-

27" 
Implementing the Energy Performance of Buildings Directives, 2016, Concerted Action EPBD 

182  

91 

 
                                                 
assessments  are  essential  when  developing  energy  efficiency  financing  schemes  as 
different  market  segments  require  different  approaches.  Financial  products  need  to  be 
customised and adapted to local conditions in order to be successful. They need to take 
into  account  the  characteristics  of  local  businesses,  organisational  behaviour  patterns, 
legal  framework  as  well  as  the  availability  of  technical  capacities  to  develop  good 
investment projects which could be attractive to both project owners and financers.  

A major challenge remains to accelerate building renovation rates in both the residential 
and  non-residential  sector,  especially  deep  renovations  where  possible  and  relevant. 
The  need  for  increased  private  investments  and  related  (appropriate  and  attractive) 
financing products, as well as the need to motivate building owners/tenants to invest are 
still  relevant.  Barriers  to  renovations  are  particularly  difficult  to  overcome  for  low-
income households and vulnerable consumers, or in situations where energy efficiency 
measures  do  not  match  the  lifecycle  of  the  building  (e.g.  when  partial  renovation  has 
been implemented recently).  

With the right set of policy tools, it is generally excepted that governments will play a 
crucial  role  in  promoting  energy  efficiency  and  leveraging  more  investments  in  the 
building  sector,  especially  in  the  existing  stock,  where  (as  experience  shows) 
investment  opportunities  are  insufficiently  understood  and  seized.  For  now,  public 
support  schemes  appear  to  dominate  the  policy  framework  for  existing  buildings,  as 
they  are  particularly  important  for  tackling  risks  associated  with  lengthy  payback 
periods and activating the market for energy renovations. At the same time, the need for 
more market action and enhanced private sector involvement is increasingly recognised 
as this offers the only sustainable route for scaling up existing efforts183.  

Experience  so  far  in  the  context  of  Cohesion  Policy  funding  in  the  2014-2020  period 
shows that synergies between financial incentives and compliance with EU obligations 
on energy efficiency in buildings need to be maximised184 to deliver the required upfront 
investments.  The  introduction  of  so-called  ex-ante  conditionalities  linking  financial 
support  for  building  renovation  and  compliance  with  Articles  3,  4,  5  and  11  of  the 
EPBD  (minimum  energy  performance  requirements  and  Energy  Performance 
Certification)  have  proven  to  be  effective  at  driving  implementation  of  the  key 
provisions of the EPBD.  

Under the Article 4 of the Energy Efficiency Directive, Member States have developed 
long-term strategy for mobilising investment in the renovation of the national stock of 
residential  and  commercial  buildings,  both  public  and  private.  74  %  of  the  submitted 
strategies satisfactorily address the main elements of the Energy Efficiency Directive185. 
Taking  into  consideration  that  these  were  the  first  renovation  strategy  documents 
submitted  by  the  Member  States,  the  quality  and  the  actual  implementation  of  the 
strategies are expected to improve further in the future. In this respect, to ensure long-
term  consistency,  it  will  be  important  that  the  Strategies  include  also  a  solid 
investment/financing  plan  including  the  identification  of  funding  sources,  financing 
mechanisms,  their  complementarities  and,  most  important  of  all,  solid  analysis  over 
achieved and further expected impacts.  

183   Final report on financing EE in buildings, 2014, European Commission (DG JRC) 
184   Technical  guidance  "Financing  the  energy  renovation  of  buildings  with  Cohesion  Policy  funding,  European 

Commission, 2014 

185   Synthesis Report on the assessment of Member States' building renovation strategies, 2015, JRC. 

92 

 
                                                 
3. Conclusion  

The  choice  of  a  cost-optimal  benchmarking  methodology  to  steer  existing  national 
energy  performance  requirements  towards  cost-efficient  levels  has  proved  to  be  an 
efficient  and  results-oriented  approach.  The  cost-optimal  calculations  allowed  the 
identification  of  cases  where  there  is  still  a  significant  potential  for  cost-effective 
energy  savings.  The  analysis  of  the  first  cost-optimal  calculations  showed  that  some 
Member States took the political decision of setting minimum requirements above the 
cost-optimal  levels,  possibly  because  of  the  non-economic  benefits  of  improved 
building  energy  performance,  which  are  not  integrated  in  the  framework  calculation 
methodology.  

The NZEB targets have been found coherent with the principles of cost-optimality and 
cost-efficiency.  The  evidence  suggests  that  existing  technologies  related  to  energy 
savings,  energy  efficiency  and  renewable  energies  are  sufficient  to  reach,  in 
combination, a suitable target for nearly zero-energy buildings. A technology gap that 
would need to be bridged by 2021 has not been identified. Analysis of the cost-optimal 
reports required under Article 5 of the EPBD indicates that a smooth transition between 
cost  optimality  and  NZEB  is  achievable.  No  Member  State  has  yet  reported  any 
legislative  regime  for  not  applying  the  NZEB  requirements  in  specific  and  justifiable 
cases,  as  permitted  under  Article  9(6)  of  the  EPBD.  This  non-use  of  the  exception 
permitted  implies  that  Member  States  do  not  find  the  NZEB  concept  and  targets 
problematic.  

It can be questioned whether the requirement to establish national EPC schemes, which 
has resulted in different layouts for labels and recommendations across Member States 
and  regions,  is  efficient.  EPCs  have  a  different  layout  and  content  in  different  EU 
Member States, though most countries have implemented an A-G scheme similar to the 
EU energy labelling for energy using products. Even when label layouts are similar, the 
rating of the building cannot be compared across Member States as based on a different 
energy  performance  calculation  methodology.  For  the  user  or  citizen,  a  comparable 
layout  could  be  potentially  more  misleading  given  that  the  underlying  calculation 
differs. However, there is a case for better comparability across Member States to drive 
investments  in  the  most  energy  efficient  buildings.  This  is  demanded  in  particular  by 
market participants in the non-residential sector, which are often multinational property 
owners  and  development  companies.  This  need  is  being  tackled  through  a  voluntary 
common  European  Union  certification  scheme  for  the  energy  performance  of  non-
residential  buildings,  currently  under  development  as  part  of  the  implementation  of 
Article 11(9) of the EPBD. This scheme will be based on CEN standards for calculating 
the energy performance of buildings, presently under finalisation. This common scheme 
will allow for the fair comparison of different buildings' energy use across borders.  

In general, the additional administrative and regulatory processes created by the EPBD 
are considered necessary by most of the respondents to the public consultation, in the 
light of the energy saving potential in the buildings sector.  

The national implementation of the Directive could be more efficient in several cases. 
For example, half of the Member States have a different calculation method for setting 
and  ensuring  minimum  energy  requirements,  on  the  one  hand,  and  for  certifying 
buildings on the other hand.  

93 

 
Such implementation choices create complexity and limit the readability of the policy 
for  end  users.  For  the  comparison,  it  could  be  compared  to  a  framework  related  to 
manufactured  products  where  Ecodesign  and  Energy  Labelling  would  have  two 
different measurement standards.  

More holistic ways to implement the Directive generally would result in a reduction of 
the administrative burden and give more clarity to the overall system.  

Efficient mechanisms to effectively enforce the legislation have not always been found 
at national level, especially elements related to renovation.  

The EPBD offers a certain guarantee of efficiency by indicating that Member State are 
not  required  to  set  minimum  energy  performance  requirements  which  are  not  cost-
effective  over  the  estimated  economic  lifecycle.  This  adds  to  the  setting  of  minimum 
requirements  at  cost-optimal  level,  which  prevent  from  overly  ambitious  minimum 
requirements  that  the  market  would  not  able  to  cost-effectively  deliver.  Such 
overambitious requirements could have a negative impact on the activity.  

The efficiency  of a few specific components is questioned by several Member States. 
This concerns in particular requirements for inspections of heating and cooling systems 
and  the  technical,  economic  and  environmental  assessment  of  alternative  heating  and 
cooling systems, including decentralised or district solutions, preceding the construction 
of new buildings.  

94 

 
Annex 11  EVALUATION OF THE RELEVANCE  

The European building stock is responsible for 30% of the EU greenhouse emissions186 
and  approximately  40%  of  the  final  energy  consumption187.  The  building  stock  is 
expanding in size and its energy consumption and CO2 emissions are bound to increase 
in  absence  of  tighter  energy  performance  minimum  requirements.  Hence,  addressing 
the  energy  performance  of  buildings  remains  relevant  to  address  the  2020-2030-2050 
energy and climate policy objectives and boost energy security.  

1. EU energy and climate targets  

Most  of  the  saving  potential  lays  within  the  EPBD  scope  (space  and  water  heating, 
space cooling, ventilation and their auxiliary, and lighting in the non-residential sector). 
Remaining cost-effective saving potential of 33 to 80.5 Mtoe are estimated by 2030188.  

The mechanisms of the EPBD remain relevant:  
  The choice of a cost-optimal benchmarking methodology to steer existing national 
energy performance requirements towards cost-efficient levels is recognised to be 
an efficient and results-oriented approach. The continuation of this mechanism of 
periodic review of minimum levels of energy performance requirements based on 
cost-optimality will effectively maintain a level playing field across Europe;  
  The  influence  on  property  valuation  confirms  that  the  energy  performance,  as  an 
asset  rating,  can  provide  an  accurate  real  estate  market  signal  by  reflecting  the 
characteristics  of  the  building  in  typical  use  conditions,  independently  from 
behaviour  of  former  and  prospective  occupiers189.  As  integrated  metric,  energy 
performance leaves sufficient flexibility to the construction industry to design and 
build new buildings and renovation programs in the most cost-effective way within 
the local conditions of each specific project.  

The transposition of the EPBD into ambitious building codes in the Member States is 
and will continue to help Member States to reach their GHG reduction targets for the 
non-ETS  sector  under  the  Effort  Sharing  Decision  (ESD)190.  The  ESD  covers  mainly 
GHG  emissions  in  the  transport,  buildings,  agriculture,  small  industry  and  waste 
sectors.  These  sectors  accounted  for  more  than  55%  of  total  EU  GHG  emissions  in 
2013.  The  ESD  does  not  set  specific  emission  targets  for  these  individual  sectors 
covered by it, but leaves it to Member States to choose where to achieve the necessary 
reductions.  According  to  recent  estimates,  the  building  sector  is  expected  to  have  an 
above  average  (above  current  trends)  contribution  to  continued  emissions  reductions 
post 2020, mainly thanks to the continued impact of energy efficiency improvements191.  

186  GHG emissions in the overall inland GHG emissions for Commercial/Institutional/Residential sectors (without 

LULUCF and without international aviation and international maritime transport). Source: Eurostat. 

187   Calculation made by aggregating annual final energy consumption data from Eurostat.  
188   Calculation  based  on  the  Study  evaluating  the  current  energy  efficiency  policy  framework  in  the  EU  and 
providing orientation on policy options for realising the cost-effective energy efficiency/saving potential until 
2020 and beyond, 2014, Fraunhofer ISI.  

189   e.g.  IEE  project  RenoValue  is  developing  a  training  toolkit  on  building  energy  performance  for  property 

valuation professionals, building upon EPCs in particular. See http://renovalue.eu/ 

190   Decision  No 406/2009/EC  of  the  European  Parliament  and  of  the  Council  of  23 April  2009  on  the  effort  of 
Member  States  to  reduce  their  greenhouse  gas  emissions  to  meet  the  Community’s  greenhouse  gas  emission 
reduction commitments up to 2020 
Impact Assessment accompanying the document Proposal for a Regulation on binding annual greenhouse gas 
emission  reductions  by  Member  States  from  2021  to  2030  for  a  resilient  Energy  Union  and  to  meet 

191  

95 

 
                                                 
2. Other benefits  

Better  energy  performance  of  buildings  can  deliver  social  co-benefits  as  a  result  of 
enhanced usability of the building, more efficient use of resources, enhanced health and 
quality  of  life,  stimulating  economic  recovery  and  promoting  growth  and  the  creation 
and retention of jobs192.  

2.1. Economic benefits  

In  macro-economic  terms  the  construction  industry  and  in  particular  the  building 
industry  is  very  important  to  the  EU  economy.  The  construction  sector  provides  20 
million direct jobs, mainly in SME’s, and contributes to about 10 % of the EU‘s GDP. 
In  2014,  the  total  Construction  sector  output  was  €1,211  billion,  €961  billion  on 
buildings193.  

The JRC-LUISA modelling platform and the ESPON TIA Quick Scan tool were used to 
carry  out  a  pilot  Territorial  Impact  Assessment  (TIA)  on  the  Energy  Performance  of 
Buildings  Directive194.  Preliminary  results  in  using  the  ESPON  TIA  Quick  Scan  tool 
suggest  positive  territorial  impact  of  the  EPBD  in  particular  on  employment  in  the 
construction sector: 16% of metropolitan regions might experience a very high and 79% 
a high positive impact on employment in the construction sector.  

2.2. Health and indoor environment  

The  Directive  2002/91/EC  and  EPBD  requires  energy  performance  to  take  indoor 
climate  into  account  but  leaves  to  EU  Member  States  the  way  to  regulate  and  ensure 
that  the  improvement  of  the  energy  performance  of  buildings  adequately  takes  into 
account  and  efficiently  implement  indoor  environment  quality  (i.e.  indoor  air  quality, 
thermal  comfort,  noise  and  lighting)  and  ventilation  requirements  at  national  level. 
However,  gaps  in  the  national  regulatory  framework  can  be  observed  today195,  in 
particular  for  existing  buildings  where  health-based  mandatory  minimum  IEQ 
requirements can hardly be found in national/regional building codes.  

It  is  essential  that  meeting  minimum  energy  performance  requirements  and  achieving 
the  required  level  of  indoor  environmental  quality  (IEQ)  196  receive  the  same  level  of 
attention  and  are  mutually  and  consistently  reinforced  in  plans  and  actions  of  EU 
Member  States  for  renovating  the  European  building  stock.  Without  such  precaution 
and clear implementing provisions, current trends towards more airtight and less glazed 
building  envelopes  could  further  deteriorate  the  indoor  environmental  quality  of 
buildings in EU and consequently  the  comfort and health  conditions  of the buildings’ 
occupants.  

commitments under the Paris Agreement and amending Regulation No 525/2013 of the European Parliament 
and the Council on a mechanism for monitoring and reporting greenhouse gas emissions and other information 
relevant to climate change SWD(2016) 0247 final of 20 July 2016 

192   Multiple benefits of EE renovations in buildings, 2012, Copenhagen Economics 
193   Source: FIEC 
194   Pilot  Test  on  the  Territorial  Impact  Assessment  of  the  Energy  Performance  of  Buildings  Directive,  2016, 

European Commission 

195   “Promoting healthy and energy efficient buildings in the European Union: National implementation of related 
requirements  of  the  Energy  Performance  Buildings  Directive  (2010/31/EU)”,  2016,  European  Commission’s 
JRC report (EUR 27665 EN) 
Indoor Air Quality Thermal Comfort Daylight, 2015, BPIE 

196  

96 

 
                                                                                                                                               
Buildings  play  an important  role  on EU  citizen’s  living  and health  conditions.  People 
spend  60-90%  of  their  life  in  indoor  environments  (homes,  offices,  schools,  etc.).  In 
2012, 99,000 deaths in Europe were attributable to household indoor air pollution197. 2.2 
million estimated DALYs (Disability Adjusted Life Years) are lost each year in Europe 
due to exposures to pollutants in buildings198.  

The burden of cold temperatures can be measured through the number of Excess Winter 
Deaths  (EWD).  There  is  strong  evidence  that  cold  housing  is  largely  responsible  for 
excess  winter  mortality:  the  literature  shows  that  between  30%  and  50%  of  excess 
winter  mortality  is  attributable  to  housing.  Given  that  in  Europe,  there  are  about 
250,000  excess  winter  deaths  each  year,  it  can  be  estimated  that  50,000  to  85,000 
excess winter deaths are attributable to cold housing in the EU199.  

2.3. Energy poverty  

Buildings  have  also  a  big  influence  on  EU  citizen’s  and  households'  economic 
conditions.  In  2012,  11.2  %  of  the  EU-28  population  lived  in  households  that  spent 
more than 40 % of their disposable income on housing. In Greece, Denmark, Germany, 
Romania,  Bulgaria,  the  Netherlands  and  Spain  this  rate  exceeded  14.0  %  while  the 
lowest  rates  were  reported  by  Cyprus  (3.3  %)  and  Malta  (2.6  %)200.  In  2010,  it  is 
estimated  that  around  20%  of  EU-28  households’  expenditures  for  housing  were  for 
electricity, gas and other fuels201.  

Energy  efficiency  measures  in  buildings  are  one  of  the  means  to  address  high-energy 
expenditure  in  households,  which,  together  with  low  income,  is  one  of  the  indicators 
used  to  identify  households  in  risk  of  energy  poverty.  For  example  many  Member 
States  have  been  implementing  programs  to  support  measures  to  improve  the  energy 
performance  of  low-income  homes  and,  thereby,  address  energy  poverty.  However, 
such  energy  poverty  schemes  mostly  remain  stand-alone  instruments  and  are  not 
integrated  in  a  broader  strategy  on  national  or  even  on  EU  level202.  Some  Member 
States203  are  using  EPCs  as  a  proxy  for  high-energy  expenditure  and  a  tool  to  target 
national policies with a social aim.  

Improving  Energy  performance  of  the  building  stock  supports  the  achievement  of  the 
EU  energy  and  climate  targets  and  contributes  more  broadly  to  an  efficient  use  of 
resources,  stimulating  economic  recovery  and  promoting  growth  and  creation  and 
retention  of  jobs.  Interventions  in  buildings  must  be  seen  more  globally  as  an 
opportunity to improve indoor environment and living conditions, including in relation 
to energy poverty. Low energy efficiency is one of the main causes of energy poverty. 
Energy efficiency measures, particularly those focusing on building retrofits, are a key 
part of strategies to address energy poverty204.  

197  Burden of disease from Indoor Air Pollution for 2012, 2014, World Health Organisation 
198   Promoting actions for healthy indoor air (IAIAQ). European Commission’s Directorate General for Health and 

Consumers. Luxembourg, 2011 

199   Environmental burden of disease associated with inadequate housing, 2011, World Health Organization 
200   SILC-Survey, 2013, Eurostat 
201   Household Budget Survey, 2010, Eurostat 
202   Alleviating Fuel Poverty in the EU, 2014, BPIE 
203   Developing  the  regulation  of  energy  efficiency  of  private  sector  housing  -  Modelling  improvements  to  the 

target stock, 2015, Scottish government 

204   Energy  poverty  and  vulnerable  consumers  in  the  energy  sector  across  the  EU:  analysis  of  policies  and 

measures, INSIGHT-E, May 2015 

97 

 
                                                 
2.4. The building renovation challenge:  

The  quality of  the  supplied  energy  is  already  considered  in  through  the conversion  to 
primary  energy.  The  district-scale  is  an  attractive  option  due  to  the  potential  high 
upscaling factor of any intervention. Transformation of the energy supplied to buildings 
can improve the energy performance of several buildings.  

However,  the  workshop  organized  by  EASME  on  this  topic  (Cf.  also  Annex  4) 
highlighted that challenges and barriers are aggravated when scaling up from building 
to district.  

There  is  space  for  the  consideration  of  energy  in  the  urban  planning.  The  need  for 
district-scale  planning  is  certainly  higher  for  the  integration  of  renewable  energy 
sources than it is to work on the energy efficiency of buildings.  

No strong argument to change the current boundary conditions of the EPBD could be 
found.  

3. Areas of improvement  

There  are  however  three  aspects  where  the  stakeholder  consultation  reveals  that  the 
EPBD is not yet fully delivering on the identified needs:  
 

ensuring a closer link between the energy performance of buildings. Disclosure and 
accessibility  of  performance  data  by  third  parties  (such  as  ESCOs  and  Financial 
Institutions)  is  an  important  driver  for  reaching  market  maturity,  necessary  for 
scaling up private investment. Different stakeholder groups require information that 
makes sense to them and that can support informed decisions and the actual energy 
consumption  appear  to  be  one  of  the  information  necessary  to  establish  more 
strongly the business case of energy renovation, especially in a context where gaps 
are reported between the estimated savings at design stage and actual savings after 
renovation . Synergies could therefore be reinforced with additional information on 
actual energy consumption Technical progress on better ICT can play an important 
role, e.g. through the use of central databases to collect information and redistribute 
statistical data .  

  making  more  explicit  that  cost-effective  energy  performance  upgrades  requires 

 

both energy efficiency and renewable energy measures;  
taking better advantage of the technological progress for the decarbonisation of the 
economy  by  creating  a  stronger  link  between  building  codes  and  ‘smartness’  of 
technical  building  systems,  e.g.  ability  to  provide  information  on  operational 
energy consumption to the consumer; to adjust to the needs of the user; to run the 
efficient  and  comfortable  operation  of  the  building;  to  connect  to  electric  vehicle 
charging, to host energy storage and to support demand response.  

Options to address these three aspects should be analysed in the Impact Assessment.  

98 

 
Annex 12  EVALUATION OF THE COHERENCE  

No  internal  contradiction  was  found  within  the  EPBD,  nor  with  other  EU-Policies  at 
this  point  in  time.  Important  complementarities  within  the  EPBD  and  between  the 
EPBD and other pieces of legislation exist and should be further exploited, in particular 
in the national implementation frameworks.  

1. Internal coherence  

No  internal  contradiction  could  be  identified  during  the  evaluation.  The  provisions 
related  to  the  setting  of  minimum  requirements  for  new  and  existing  buildings,  the 
provisions for EPCs and inspections, and on more general measures to address market 
barriers, are focusing on different and complementary aspects. These provisions support 
each other and, as established in Annex 10 analysing the efficiency, can benefit better 
of this complementarity.  

2. External coherence  

2.1. Coherence with other legislation promoting energy efficient buildings  

The  objective  of  the  EPBD  to  support  the  increase  of  building  renovation  depth  and 
rates  is  supported  by  other  EU  legislation;  inter  alia,  the  EED  and  by  the  European 
Structural Investment Funds (ESIF).  

The  ESIF  framework  and  EED  building-related  provisions  aim  at  providing  and/or 
optimising  financial  support  for  the  renovation  of  the  building  stock  and  triggering 
increased  renovation  rates.  There  is  room  to  improve  their  implementation,  which 
implies aligning the renovation depth with the minimum quality standards provided by 
the EPBD and the monitoring of effectiveness of financial support with the operational 
benefits that EPCs can provide.  

The long term renovation strategies bring together different elements of the EED and of 
the EPBD.  More  specifically, Article 9(2) of the EPBD aims  at increasing  renovation 
depths  by  setting  national  support  policies  to  refurbish  existing  buildings  to  deeper, 
NZEB levels. The obligation in Article 9(2) of the EPBD is complemented by national 
long term building strategies under Article 4 the EED, which should result in increased 
renovation rates through mobilising finance and investments in building renovation.  

The assessment of the national long-term renovation strategies developed under Article 
4 of the EED205 revealed that in most cases Member States merely reported a reference 
to the cost-optimal methodologies but did not integrate the results within the strategy. 
The use of national EPC databases to link EPCs with financing schemes and contribute 
to better enforcement of building provisions was generally lacking. Further, disclosure 
and  accessibility  of  performance  data  by  third  parties  (such  as  ESCOs  and  Financial 
Institutions) is an important driver for reaching market maturity, necessary for scaling 
up private investment.  

Articles  5  and  6  of  the  EED  establish,  respectively,  renovation  targets  for  central 
government  buildings  and  purchasing  by  public  bodies  of  high  energy  efficiency 
performing products, services and buildings. These EED articles work in synergy with 

205   Synthesis  Report  on  the  assessment  of  Member  States'  building  renovation  strategies,  2015,  European 

Commission (JRC) 

99 

 
                                                 
the provisions of the EPBD: whilst articles 5 and 6 of the EED stimulate the renovation 
rate  and  the  demand  for  highly  energy  efficient  buildings  in  public  bodies,  the 
provisions of the EPBD ensure the necessary quality of results (i.e. to meet at least the 
minimum energy performance requirements).  

Finally,  Article  7  of  the  EED  on  energy  saving  obligation  schemes  (and  alternative 
policy measures) has indirect links to buildings. Energy saving obligations schemes are 
one  of  the  tools  for  financing  energy  efficiency  measures  in  building.  Though  the 
involvement  of  energy  distributors or  retail  companies,  these  schemes  have  proved  to 
be  in  practice  an  effective  means  to  aggregate  small  scale  investments,  stimulating 
higher renovation rates. Of the alternative measures used by Member States to achieve 
the energy savings required under Article 7 of the EED, 42% are building related.  

2.2. Coherence with the legislation related to energy efficient products  

The obligations arising from the EPBD to set and ensure minimum energy performance 
requirements  for  building  elements,  on  the  one  hand,  and  the  EU  legislation  on 
ecodesign and energy labelling energy efficiency of products, on the other hand, were 
found coherent.  

Building elements generally consist of several products. For example, a wall (building 
element)  generally  consists  of  several  layers  of  material  with  various  insulation 
properties and technical building system generally consists of generation, distribution, 
emission and control sub-systems, involving themselves several products.  

The energy performance of an integrated building element is more than the sum of the 
energy  performance  of  the  individual  products  involved,  although  of  course  those 
products must respect the applicable EU ecodesign and/or energy labelling legislation. 
Proper  design  and  installation,  taking  into  account  internal  and  external  systemic 
interactions, have a big influence on the resulting performance of a building element.  

Energy  efficient  building  products  can  support,  without  guarantee  of  results,  the 
achievement  of  better  energy  performing  building  elements.  For  instance,  an  efficient 
boiler can help to get an efficient heating system (composed of a source of warmed air, 
a means of distributing the air to the rooms being heated (e.g. pipes), and a control used 
to regulate the system (e.g., thermostat)).  

Rather  than  a  matter  of  coherence,  the  question  is  whether  it  is  effective  and 
proportionate to, at the same time, set minimum requirements on the energy efficiency 
of building-related products under ecodesign, and the energy performance of installed, 
retrofitted  or  replaced  building  elements  under  building  codes.  This  is  assessed  on  a 
case-by-case  basis  during  the  process  of  developing  specific  ecodesign  and/or  energy 
labelling  implementing  measures,  having  in  mind  the  requirements  of  the  EPBD:  for 
example it was decided not to set ecodesign requirements for thermal insulation given 
that  they  are  well  covered  under  national  implementation  of  the  EPBD.  In  terms  of 
building related products, at present ecodesign and energy labelling requirements only 
apply to boilers, air conditioning and air heating products.  

100 

 
2.3.  Coherence  with  the  legislation  on  the  promotion  of  the  use  of  energy  from 
renewable sources  

By  looking  at  the  integrated  energy  performance  of  buildings  and  considering,  in 
addition  to  the  quality  of  insulation  of  the  building,  heating  installations,  cooling 
installations, energy for ventilation, lighting installations, position and orientation of the 
building,  heat  recovery,  active  solar  gains  and  other  renewable  energy  sources,  the 
EPBD goes beyond energy efficiency and considers the positive influence of renewable 
energy  sources  requiring  e.g.  that  the  national/regional  calculation  methodologies  for 
the  energy  performance  of  building  consider  the  positive  influence  of  active  solar 
systems  and  other  heating  and  electricity  systems  based  on  energy  from  renewable 
sources, cogeneration or district heating and cooling, consistently with the Directive on 
the promotion of renewable energy sources206.  

The provisions of the EPBD naturally drive the use of renewable energy sources, as the 
calculation of the integrated energy performance should take into account the positive 
influence  of  active  solar  systems  and  other  heating  and  electricity  systems  based  on 
energy  from  renewable  sources,  cogeneration  and  district  heating  and  cooling, 
consistently with relevant Union legislation, including Directive 2009/28/EC.  

The  tightening  of  energy  performance  requirements  results  in  an  increased  cost-
effective use of systems based on energy from renewable sources207. Nearly zero-energy 
buildings will significantly involve the use of energy from renewable sources, although 
not through a one-fits-all cost-effective solution.  

At the same time, under the Directive on the promotion of renewable energy sources, in 
particular Article 13(4), Member States have to, in their building regulations and codes 
(or  by  other  means  with  equivalent  effect  and  where  appropriate),  require  the  use  of 
minimum  levels  of  energy  from  renewable  sources  in  new  buildings  and  in  existing 
buildings  that  are  subject  to  major  renovation.  Member  States  must  permit  those 
minimum levels to be fulfilled, inter alia, through district heating and cooling produced 
using  a  significant  proportion  of  renewable  energy  sources.  These  measures  are 
complementary to the NZEB requirements in the EPBD.  

2.4. Coherence with other initiatives  

In  macro-economic  terms  the  construction  industry  and  in  particular  the  building 
industry  is  very  important  to  the  EU  economy.  The  construction  sector  provides  20 
million direct jobs, mainly in SME’s, and contributes to about 10 % of the EU‘s GDP.  

Increasing  building  renovation  depth  and  rates  including  as  a  result  of  the 
implementation  of  the  EPBD  contributes  to  the  sustainability  and  competitiveness  of 
the  construction  sector,  e.g.  by  improving  environmental  performance  and  creating 
business  opportunities  in  line  with  the  Strategy  for  the  sustainable  competitiveness  of 
the  construction  sector  and  its  enterprises208.  The  energy  performance  of  buildings 

206   Directive 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the 

use of energy from renewable sources 

207  Towards  nearly 

the  EPBD 
(http://ec.europa.eu/energy/sites/ener/files/documents/nzeb_full_report.pdf),  carried  out  by  Ecofys  for  the 
European Commission, DG ENERGY. 

zero-energy  buildings-  Definition  on 

common  principles  under 

208   Communication COM(2012)433 final of 31 July 2012 on a Strategy for the sustainable competitiveness of the 

construction sector and its enterprises 

101 

 
                                                 
during  their  operation  is  only  one  element  of  the  much  broader  environmental 
performance of a building over its life-cycle. The construction and use of buildings in 
the EU account for about half of all our extracted materials 40% of energy consumption 
and about a third of our water consumption. The sector also generates about one third of 
all waste and is associated with environmental pressures that arise at different stages of 
a  building's  life-cycle  including  the  manufacturing  of  construction  products,  building 
construction,  use,  renovation  and  the  management  of  building  waste.  Recycling  these 
materials, as opposed to ending up in landfills, is crucial to the circular economy. These 
manufacturing, recycling and end-of life aspects are outside the scope of the EPBD.  

The  Communication  on  resource  efficiency  opportunities  in  the  building  sector209 
identifies  other  possible  negative  impacts  that  could  be  better  taken  into  account,  and 
paves the way to more global approaches to consider environmental impacts throughout 
a  building's  life  cycle.  This  includes  taking  into  account  of  both  embodied  and 
operational energy during the life cycle of a building. This total energy should be the 
focus,  as  a  highly  energy  efficient  building  may  come  at  a  high  cost  of  embodied 
energy.  Similarly,  this  Communication  as  well  as  the  recent  EU  Action  Plan  for  the 
Circular Economy210 stresses the importance of recycling of construction and demolition 
waste, already laid down in the Waste Framework Directive. This waste stream makes 
up about a third of EU total generated waste. To enable recycling, selective demolition 
where materials are easily separated at the end of life stage is imperative. This in turn 
requires  considerations  at  the  construction  and  renovation  stages,  with  suitable 
materials being put together for easy disassembly. Failure to do so is likely to result in 
increased  land  filling  of  construction  and  demolition  waste.  Existing  experience 
indicates that this is particularly critical during renovation.  

Buildings have also a big influence on EU citizen’s economic conditions. In 2012, 11.2 
%  of  the  EU-28  population  lived  in  households  that  spent  more  than  40  %  of  their 
disposable income on housing. In Greece, Denmark, Germany, Romania, Bulgaria, the 
Netherlands and Spain this rate exceeded 14.0 % while the lowest rates were reported 
by Cyprus (3.3 %) and Malta (2.6 %)211. In 2010, it is estimated that around 20% of EU-
28 households’ expenditures for housing were for electricity, gas and other fuels212. The 
EPBD, in its recital 20, indicates the reduction of energy poverty as a potential benefit 
that  could  be  achieved  by  the  reduction  of  existing  legal  and  market  barriers  and  the 
encouragement of investments and/or other activities to increase the energy efficiency 
of new and existing buildings.  

Studies  have  identified  social  and  other  co-benefits  of  energy  efficiency  measures  in 
buildings,  with  links  to  policies  having  a  social  aim.  Several  Member  States  are 
implementing  programs  to  support  measures  to  improve  the  energy  performance  of 
low-income  homes  and,  thereby,  address  energy  poverty.  However,  such  energy 
poverty  schemes  mostly  remain  stand-alone  instruments  and  are  not  integrated  in  a 
broader strategy on national or even on EU level213.  

The Commission is currently evaluating the Construction Products Regulation (EU no. 
305/2011)  and  is  preparing  a  fitness  check  of  relevant  EU  legislation  impacting, 

209   Communication COM(2014)445 of 1 July 2014 on resource efficiency opportunities in the building sector 
210   Communication COM(2015)0614 final on Closing the loop – An EU Action Plan for the Circular Economy 
211   SILC-Survey, 2013, Eurostat 
212   Household Budget Survey, 2010, Eurostat 
213   Alleviating Fuel Poverty in the EU, 2014, BPIE 

102 

 
                                                 
positively  and  negatively,  the  construction  sector.  This  fitness  check  will  assess 
legislation covering internal market, energy, environment, and health and safety aspects 
in  terms  of  its  impact  on  the  competitiveness  and  sustainability  of  the  construction 
sector.  

Under the Digital Agenda targets (namely all Europeans have by 2020 internet speeds 
above  30  Mbps),  Directive  2014/61/EU214  aims  at  laying  down  some  minimum  rights 
and  obligations,  applicable  across  the  Union,  to  bring  the  high  speed  communication 
infrastructure  closer  to  the  end-user's  location.  The  limited  provisions  of  the  EPBD 
aiming  at  incentivising  the  use  of  electronic  monitoring  and  control  of  technical 
building  systems,  and  more  generally  the  installation  of  building  automation  and 
control, had limited uptake so far. ICT (Information and Communication Technologies) 
are expected to play a major enabling role in the future of buildings. Based on sensors, 
controls, real time data and cloud based solutions, ICT can provide self-learning control 
systems  optimising  building  operation,  allowing  for  reliable  energy  signatures  and 
generating automated proposals for energy savings. The ICT solutions rightly integrated 
into building stock would bring the much needed transparency into the building day-to-
day  operation  and  ease  the  occupant  access  to  his/her  own  assets  and  build-on 
credibility in savings from buildings, thus facilitating the management of buildings also 
from  an  energy  perspective.  This  –  combined  with  much  developed  today  power 
analytics  capacities  based  on  Big  Data  –  should  help  customers  find  ways  to  reduce 
energy usage in a comprehensive and highly effective manner. In this regard, the EPBD 
and  Directive  2014/61/EU  can  be  mutually  supportive  by  creating  respectively  the 
demand and the offer for high-speed electronic communication networks.  

Solutions at district and city level function as a multiplier of improvements of energy 
performance in individual buildings, may facilitate integration of renewable energy, and 
aggregation  of  demand  response,  as  well  as  energy  efficiency  solutions,  and  can  help 
attracting investments into energy efficiency and renewable energy. Such locally driven 
approaches are supported by the Covenant of Mayors. The Covenant of Mayors is the 
mainstream  European  movement  involving  local  and  regional  authorities  in  the  fight 
against  climate change. It is  based on a voluntary commitment by signatories to  meet 
and exceed the EU 20% CO2 reduction objective through increased energy efficiency 
and  development  of  renewable  energy  sources215  .It  brings  together  thousands  of  local 
and regional authorities voluntarily committed to implementing EU climate and energy 
objectives  on  their  territory.  Signatories  now  pledge  through  their  sustainable  energy 
action  plans  to  reduce  CO2  emissions  by  at  least  40%  by  2030.  Similarly,  innovation 
and integration of ICT, energy and transport solutions at city level is facilitated by the 
Smart  Cities  and  Communities  Partnership216.  The  Partnership  aims  to  overcome 
bottlenecks impeding the changeover to smart cities, to co-fund demonstration projects 
and  to  help  coordinate  existing  city  initiatives  and  projects,  by  pooling  its  resources 
together.  

2.5. Conclusion on external coherence  

To conclude the EPBD is found coherent with other EU initiatives, which are generally 
complementary. A coherent, integrated and efficient implementation of EPBD together 

214   Directive 2014/61/EU of the European Parliament and of the Council of 15 May 2014 concerning measures to 

reduce the cost of deploying high-speed electronic communication networks 

215   http://www.covenantofmayors.eu/index_en.html  
216   http://ec.europa.eu/eip/smartcities  

103 

 
                                                 
with  other  related  policies,  regulations  and  standards  in  EU  is  possible  but  implies 
considering  the  multi-dimensional  based  concept  of  buildings’  “efficiency”  which 
encompasses  socioeconomic,  energy,  health,  safety  of  constructions  and  sustainability 
aspects  while  considering  national  peculiarities  and  constraints  (economic,  social, 
cultural, climatic).  

104 

 
Annex 13  EVALUATION OF THE EU ADDED VALUE  

Climate change, security of energy supply and environmental protection are challenges 
that cannot be sufficiently addressed at national level only. Energy efficiency and on-
site  renewables  in  buildings  provide  part  of  the  solution  of  these  problems  and  the 
instruments that have already been adopted at EU level reflect this need for EU action.  

The principles of subsidiarity and proportionality were considered by the co-legislators 
and are explicitly mentioned in the recitals of the EPBD and were carefully respected. 
The  main,  predominant  objectives  of  the  initiative  being  to  contribute  to  ensuring 
security  of  energy  supply  in  the  Union  and  to  promote  energy  efficiency,  delivering 
cost-effective greenhouse gas emission reductions, Article 194 TFUE (the legal basis of 
the EPBD) remains appropriate. More generally, EU intervention on energy efficiency 
of  buildings  expanded  prudently,  only  where  it  was  justified  and  leaving  significant 
flexibility to Member States.  

Before  the  adoption  of  the  Directive  2002/91/EC,  many  Member  States  did  not  have 
energy  efficiency  requirements  or  promotional  instruments  in  their  regulation  and 
building codes. As a result of Directive 2002/91/EC and EPBD, all Member States have 
now  energy  efficiency  requirements  related  to  existing  and  new  buildings  in  their 
building  codes.  Prior  to  the  recast,  only  a  few  Member  States  fixed  their  levels  of 
minimum  performance  requirements  based  on  cost-optimal  solutions,  following  an 
assessment  of  economic  impacts217.  The  use  of  cost-optimality  calculations  to  set 
minimum  performance  requirements  for  energy  efficiency  and  renewable  energy 
measures at cost-efficient levels is now common place in all but one Member State.  

The setting of minimum requirements is part of the ex-ante conditionality provisions in 
the  context  of  the  Multi-Annual  financial  Framework218,  set  up  to  ensure  that  EU 
funding is focused on results and creates strong incentives for Member States to ensure 
the effective delivery of Europe 2020 objectives and targets through Cohesion policy.  

1. Relevance for the internal market of harmonisation in this sector  

Although  the  building  market,  especially  the  housing  market,  is  generally  local  and 
buildings  are  stationary,  some  elements  of  the  value  chain  are  increasingly  European 
and  global.  Construction  products  and  services  and  the  heating,  air-conditioning  and 
lighting  devices,  as  well  as  on-building  renewable  systems,  smart  controls,  building 
automation systems, smart meters, etc, are important part of the internal market.  

With the increasing mobility of people and number of businesses with operations across 
the  EU,  the  everyday  activities  of  many  people  and  businesses  are  not  limited  to  a 
single country. Increasing the rate of renovation and the quality of buildings (resulting 
therefore in increased sales of insulation materials, doubled and triple glazed windows, 
on-building  renewable  systems,  etc)  would  have  a  positive  effect  across  the  related 
business sectors.  

217   Communication Staff Working Document of 13 November 2008 accompanying the proposal for a recast of the 

EPBD – Impact assessment SEC(2008)2864 

218   Regulation (EU) No 1303/2013 of the European Parliament and the Council of 17 December 2013 laying down 
common  provisions  on  the  ERDF,  the  ESF,  the  CF,  the  EARFD  and  the  EMFF  and  laying  down  general 
provisions on the ERDF, the ESF, the CF and the EMFF and repealing Council Regulation (EC) No 1083/2006, 
O.J., L 347, 20.12.2013, p. 320) 

105 

 
                                                 
In addition, with the increasing number of Europeans that live in a country other than 
their  native  one  and  companies  that  have  their  businesses  activities  across  the  EU, 
similar  ways  to  measure  the  energy  performance  of  the  buildings  they  rent  or  buy 
would mean a significant decrease of administrative burden. Not surprisingly, requests 
for  more  unified  and  comparable  methods  come  from  owners  of  service-providing 
chains  (such  as  supermarkets  or  hotels)  and  from  construction  materials  and  products 
manufacturing industries.  

2. Facilitation of the cooperation amongst regulators  

Despite  differences  in  building  typologies,  local  and  climatic  conditions,  national 
regulators face similar challenges to improve the energy performance of their buildings. 
Cooperation  between  regulators  is  needed  to  share  best  practises  and  foster  progress. 
The  EU  intervention  has  proven  to  be  crucial,  particularly  to  create  a  shared 
understanding with coherent and valid data, and a comparable level of ambition.  

Addressing  the  energy  efficiency  in  the  building  sector  is  a  global  challenge.  While 
countries  have  different  building  code  requirements,  they  face  common  challenges  in 
improving the energy performance of their buildings. Several international initiatives219 
recently  provided  evidence  of  the  benefits  that  international  collaboration  can  bring 
through  sharing  of  policy  best  practices,  improvement  of  analytical  capabilities,  and 
provision  of  other  resources  that  accelerate  and  maximise  the  benefits  of  energy 
efficiency, increase the cost-effectiveness of implemented building related policies, and 
help bring new technologies to market.  

This  is  confirmed  by  experience  with  the  Concerted  Action  EPBD  initiative  that  was 
initiated  by  the  European  Commission  in  2005  to  promote  dialogue  and  exchange  of 
best  practice  between  the  EU  Member  States.  A  third  phase,  from  2011  to  2015, 
recently delivered its report220 and the fourth phase has just started.  

The  EU  common  framework  to  establish  cost-optimal  minimum  performance 
requirements  already  showed  benefits,  as  the  assessment  of  cost-optimal  performance 
requirements  revealed  significant  cost  effective  potential  in  half  of  the  EU  Member 
States221.  

The  EU  ambition  for  nearly  zero-energy  buildings  is  probably  the  main  area  that 
stakeholders appreciate for its EU added value222. The requirement for NZEBs supports 
a joint approach towards more energy efficient new buildings and comparable ambition 
levels for highly performing buildings. NZEB targets function as a benchmark to create 
a better impulse towards achieving energy and climate targets. The best evidence for its 
added value is the claim for a similar signal to be set at EU level to address the existing 
buildings stock.  

219  

IPEEC, 2014, Building Energy Efficiency – Opportunities for International Collaboration; 
UNECE, 2015, Outcomes of the survey on building standards and regulation in the UNECE Region. 
Implementing the Energy Performance of Buildings Directives, 2016, Concerted Action EPBD 

220  
221   Assessment of cost-optimal calculations in the context of the EPBD, 2015, European Commission (written by 

Ecofys) 

222   Public  Consultation  on  the  Evaluation  of  the  EPBD  –  Final  synthesis  report,  2015,  European  Commission 

(written by Ecofys) https://ec.europa.eu/energy/sites/ener/files/documents/MJ-02-15-954-EN-N.pdf 

106 

 
                                                 
 
3. International leadership in standardisation  

More  harmonised  approaches  open  wider  markets  for  innovative  products,  enabling 
cost  reduction.  Following  the  adoption  of  Directive  2002/91/EC,  the  European 
Commission issued a mandate223 to CEN for the elaboration and adoption of standards 
for  a  methodology  calculating  the  integrated  energy  performance  of  buildings.  This 
work resulted in the adoption and publication of 42 European Standards, including 11 
ISO standards.  

On  14  December  2010,  the  European  Commission  issued  a  new  mandate224  to  review 
this  first  set  of  standards  so  that  they  become,  on  the  one  hand  unambiguous  and 
compatible,  and  on  the  other  hand  a  clear  and  explicit  overview  of  the  choices, 
boundary conditions and input data that need to be defined at national or regional level. 
On the basis of this work, ISO reserved the ISO 52000 series of standards, with positive 
outcomes  on  the  public  enquiry  on  the  overarching  standard  DIS  52000-1  integrating 
the final energy performance calculation, both at CEN and ISO level.  

Mirroring  Eurocodes’225  approach  for  structural  and  safety  requirements,  the  set  of 
standards  currently  developed  by  CEN  for  an  integrated  calculation  of  the  energy 
performance of buildings can be a tool for accelerating the process of convergence of 
different  national  and  regional  regulatory  approaches  and  for  fostering  the  global 
competitiveness  of  the  European  construction  enterprises,  beyond  the  borders  of  the 
European Union.  

4. Support to financing in the energy performance of buildings  

In  addition  to  EU-level  action  regarding  national  EPC  schemes,  specific  EU  added 
value is seen by property and portfolio managers in the voluntary common scheme for 
the  certification  of  non-residential  buildings  to  facilitate  swift  comparison  of 
international  properties  and  investments  (e.g.  in  renovation).  This  voluntary  common 
scheme,  currently  under  development  in  line  with  Article  11(9)  of  the  EPBD,  will  be 
underpinned  by  the  updated  EPBD  standards.  EU  action  is  needed  to  allow  for  a 
reliable  comparison  of  buildings’  energy  use  across  borders,  particularly  relevant  for 
market participants in the non-residential sector.  

Financial institutions226 also gave clear indications that the efforts to increase of public 
and  private  investments'  effectiveness  and  contribute  to  the  further  development  of 
appropriate  and  attractive  financing  products  on  the  market  are  needed  at  both 
national/local and EU level. Standardisation and improvement of buildings certification 
and  open  source  EU  Buildings  energy  database  (i.e.  the  EU  Building  Stock 
Observatory) are needed to facilitate the financing and refinancing of energy efficiency 
investments.  

223   Mandate  M/343  of  30  January  2004  or  a  methodology  calculating  the  integrated  energy  performance  of 

buildings and estimating the environmental impact. 

224   Mandate  M/480  of  14  December  2010  for  the  elaboration  and  adoption  of  standards  for  a  methodology 
calculating the integrated energy performance of buildings and promoting the energy efficiency of buildings, in 
accordance with the terms set in the recast EPBD. 

225   State of implementation of the Eurocodes in the EU, 2015, European Commission (JRC) 
226   Energy Efficiency Financial Institutions Group, "Energy Efficiency – the first fuel for the EU Economy. How 

to drive new finance for energy efficiency investments", February 2015, www.eefig.eu 

107 

 
                                                 
5. Better data for better policies and smarter financing  

The importance of robust data is a pre-requisite to address the EU global challenge of a 
decarbonised building stock. Although not the last in class at global level, the EU was 
flagged to have weaknesses in data quality, behind the US, in particular for the services 
sector227.  There  is  still  lack  of  data  to  completely  understand  the  interplay  of  the 
different factors, and in particular the specific contribution of improvement of the EU 
buildings stock in the moderation of energy consumption. In that context, the additional 
data collection initiated by Eurostat for households will not completely fill the gap and 
EU action is needed to gain better data on building stocks, starting with the completion 
of the EU Building Observatory in 2016.  

Responses  to  the  public  consultation  and  EEFIG  Report  widely  acknowledge  that 
further  EU-level  harmonisation  and  guidance  concerning  methods  for  data  collection, 
data  analysis  and  protocols  for  data  sharing  are,  e.g.  an  indispensable  prerequisite  for 
aggregation of small scale projects and development of attractive financial products228.  

In  particular, the role that the EU can play to encourage  Member States  to  open their 
national EPC databases to the public and then to aggregate a selection of these data in a 
user-friendly  manner229  was  identified.  Some  Member  States  (e.g.  Denmark,  Estonia, 
Hungary,  Ireland,  Lithuania,  the  Netherlands,  Portugal,  Sweden,  parts  of  the  United 
Kingdom-England  and  Wales,  and  Norway)  provide  open  access  to  selected  EPC 
information  directly  from  these  database.  EPCs  have  the  potential  to  be  important 
sources of initial information on the energy performance of the EU building stock and 
positively influence renovation measures230.  

The  market  for  energy  efficiency  investments  in  buildings  is  still  fragmented  with 
multitude  of  small  scale  transactions.  It  needs  to  mature  and  grow.  The  above-
mentioned  performance  data  standardisation  approaches  on  the  (finance)  demand  side 
must  therefore  be  accompanied  by  the  development  of  a  common  framework  for 
underwriting procedures on the (finance) supply side, allowing for industrialisation of 
this  (so  far)  niche  market.  As  highlighted  in  the  EEFIG  Report,  the  EU  has  a  role  to 
play in making this development in line with the policy objectives and targets, ensuring 
consistency  and  transparency.  This  work  will  therefore  form  a  key  element  of  Smart 
Finance for Buildings Initiative.  

6. Research and innovation  

The  construction  industry  also  gave  a  clear  indication231  that  energy  efficiency  in  the 
built environment cannot be solved on an individual Member State scale. Leveraging at 
EU scale and customisation at local scale are both needed.  

227   Robust building data: A driver for policy development, 2013, GBPN 
228   Energy  Performance  Certificates  across  the  EU.  A  mapping  of  national  approaches,  Buildings  Performance 

Institute Europe (BPIE), 2014; and 
European Energy Performance of Properties Analysis (EEPPA). Supporting the development of an overachring 
European  Energy  Performance Certificate.  2013,  Climate  Knowledge  and  Innovation  Communities (Climate-
KIC) 

229   Public  Consultation  on  the  Evaluation  of  the  EPBD  –  Final  synthesis  report,  2015,  European  Commission 

(written by Ecofys) https://ec.europa.eu/energy/sites/ener/files/documents/MJ-02-15-954-EN-N.pdf 

230   EPCs across the EU, 2014, BPIE 
231   Energy-efficient  buildings  –  Multi-annual  roadmap  for  the  contractual  PPP  under  Horizon  2020,  2013, 

European Commission 

108 

 
                                                 
 
By  offering  solutions  and  possibilities  that  better  respond  to  market's  needs,  future 
technological  developments  and  research  and  innovation  represent  an  opportunity  to 
further underpin the implementation of EU policies and accelerate the transformation of 
our buildings. In particular, the market is looking for technologies and solutions which 
are less costly, easier to install and use, more compatible with existing equipment and 
systems,  more  reliable  in  their  performance,  more  energy  efficient  or  which  provide 
additional benefits to occupants and increase their quality of life (e.g. thermal comfort, 
acoustic, lighting, air quality improvements). The development of such solutions needs 
to be driven by a system-based approach where buildings are considered as an overall 
system  of  combined  technologies  working  together  while  respecting  health-based 
criteria and requirements, e.g. building envelope (walls, doors, windows and the roof), 
heating and cooling systems.  

Significant EU public funds have already been directed to research activities for energy 
efficiency in buildings within Horizon 2020. This includes a public-private partnership 
on  Energy  Efficient  Buildings  where  industry  participation  exceeds  50  %  with  SMEs 
involvement at the level of 30 %. Support will also come from the European Structural 
and  Investment  Funds  (ESIF)232.  Smart  Specialisation  Strategies,  which  are  a  pre-
condition  for  ERDF  funding  for  research  and  innovation,  identify  key  investment 
priorities  for  Member  States  and  regions.  Energy  is  one  of  the  most  widely  chosen 
priorities.  The  Commission  in  2015  launched  a  platform  to  assist  Member  States  and 
regions in the uptake of the Cohesion Policy funds233 for sustainable energy, including 
for  research  and  innovation234.  The  innovative  technologies  needed  to  boost  energy 
efficient buildings are unlikely to be commercially available as quickly as is desirable 
especially  for  buildings  renovation.  Further  EU  wide  public  intervention  is  needed  to 
avoid  market  failures.  Public  intervention  allows  investigating  innovative  solutions, 
thus giving industry more options to address economic scenarios over a long period of 
time (2020-2050).  

In line with the fifth dimension of the Energy Union, the Strategic Energy Technology 
(SET) Plan will play a key role in prioritising our research and innovation activities at 
an  EU  level.  The  development  of  new  materials  and  technologies  for  making  our 
building stock more energy efficient is one of the ten actions identified to accelerate the 
energy system's transformation and create jobs and growth in Europe. As a result, the 
SET  Plan  should  lead  to  more  research  and  innovation  cooperation  and  coordination 
across the EU and lead to synergies among Member States and market actors.  

232   ESIF include the European Regional Development Fund (ERDF), the Cohesion Fund (CF), the European Social 
Fund (ESF), the European Agricultural Fund for Rural Development (EAFRD), and the European Maritime and 
Fisheries Fund (EMFF). 

233   Cohesion Policy funds include the ERDF, CF and ESF. 
234   http://s3platform.jrc.ec.europa.eu/s3p-energy 

109