Contribution ID: 5dbc7e4e-0107-41ac-af62-e49e1de9b3b4
Date: 08/02/2021 16:50:56

Consultation on the Review and the Revision
of Directive 2012/27/EU on Energy Efficiency
Fields marked with * are mandatory.

Introduction
This consultation aims to collect views and suggestions from stakeholders and citizens on the review and
the revision of Directive 2012/27/EU on energy efficiency (Energy Efficiency Directive or EED), as partially
amended in 2018 (Directive (EU) 2018/2002), foreseen by June 2021[1].
Energy Efficiency dimension of the Energy Union and the EED
Since the beginning, Energy Efficiency targets and policies have been one of the cornerstones of the EU
Energy and Climate policy. Energy efficiency is one of the five dimensions of the Energy Union and will
continue playing a key role in delivering the 2030 energy and climate framework supported by the
governance process under the Governance Regulation[2]. In addition, Energy Efficiency First[3] has
become a guiding principle of EU energy policy. To facilitate the operationalization of the principle, the
Commission will issue a guidance.
The EED was adopted in 2012 to promote energy efficiency across the EU, to tap the existing energy
saving potential with concrete measures, to remove barriers and overcome market failures that impede
efficiency in energy supply and use in different sectors in order to achieve the EU headline energy
efficiency targets for 2020.
The EED is part of the broader EU energy efficiency policy framework, which brings together other key
instruments, such as the Energy Performance of Buildings Directive[4], as amended by Directive (2018/844
/EU) (EPBD), the Energy Labelling Regulation[5] and the Ecodesign Directive[6].
The EED is part of the overall decarbonisation policy framework and is interlinked with other energy and
climate policy areas, notably, the Renewable Energy Directive (RED)[7], the EU Emissions Trading System
(ETS) Directive[8] and the Effort Sharing Regulation[9] (non-ETS sectors), and security of supply and
internal energy market. The EU level energy and climate targets are linked together in the Governance
Regulation, which requires Member States to prepare their integrated National Energy and Climate Plans
(NECPs) for 2030. In these NECPs Member States set out their national contributions to the EU level
targets and policy objectives, and the intended policies and measures to implement them.
The EED was subject to a first, limited revision in 2018[10] as part of the Clean Energy for All Europeans
package[11]. This revision sets the EU headline energy efficiency target for 2030 of at least 32.5% and

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amended certain provisions[12], including adding a new requirement for a general review of the Directive
and a possible, upwards revision of the target[13]. The transposition deadline for the amending Directive
(2018/2002) was, in general on 25 June 2020, and, for Articles 9 to 11, on 25 October 2020.
The European Green Deal and the increased energy efficiency target for 2030
The Commission announced in the European Green Deal[14] that it would present an impact-assessed
plan to increase the EU’s greenhouse gas emission reductions target for 2030 to at least 50% towards 55%
in a responsible way. The Commission also committed to “review and propose to revise”, where necessary,
the relevant energy legislation by June 2021”, including the EED.
In the impact assessment[15] accompanying the Communication on the Climate Target Plan[16] adopted
on 17 September 2020, the Commission examined the effects on the economy, society and environment of
reducing emissions by 50% to at least 55% by 2030 (compared to 1990 levels). The assessment also
considered the mix of available policy instruments and how each sector of the economy could contribute to
these increased targets.
To this end and based on this impact assessment, the Communication on the Climate Target Plan puts
forward an emissions reduction target of at least net 55% by 2030 as a balanced, realistic, and prudent
pathway to climate neutrality by 2050. It also highlights that, to achieve this level of greenhouse gas
emission reductions, there is a need to significantly step up energy efficiency efforts (to 36-37% for final
and 39-41% for primary energy consumption) by 2030 from the current headline target of at least 32.5%.
The assessment of Member States’ national contributions to the current headline target[17] shows
insufficient level of ambition in terms of energy efficiency. The gap is equal to 2.8 percentage points for
primary energy consumption and at 3.1 percentage points for final energy consumption.
Trends in energy efficiency
In terms of energy consumption, transport is the sector with the highest energy consumption accounting for
34% of final energy consumption in 2018. It is followed by industry and the residential sectors with both
representing 25%, and the services’ sector representing 13% of final energy consumption. The remaining
sectors including, agriculture, fishing and forestry represent 3% of final energy consumption. Following a
gradual decrease between 2007 and 2014, energy consumption has started to increase in recent years,
and is now slightly above the linear trajectory for the 2020 targets. This is mainly due to weather variations,
notably colder winters in 2015 and 2016, but also increased economic activity, low oil prices and increase in
transport. Energy intensity in industry has continued to improve by as much as 22% between 2005 and
2017 and energy savings have indeed helped offset parts of the impact of these increases.
The latest assessment of progress for 2018 shows a decline of 0.6% in primary energy consumption
compared to 2017[18], but this pace of reduction is insufficient to meet the EU target in 2020.
To address the growing energy consumption since 2014, the Commission set up a dedicated Task Force in
the summer 2018 to mobilise Member States’ efforts to reach the EU energy efficiency targets for 2020[19].
Partial and preliminary data for 2020 indicate that the impact on energy consumption of the COVID-19
crisis is significant and, as a result, the 2020 energy efficiency targets may well be met. However, these
reductions are not caused by structural changes. Moreover, it was clear before the crisis that the level of

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energy efficiency efforts by Member States would not alone be sufficient to reach the 2020 targets. The subsequent recovery from the COVID-19 crisis is expected to lead to a return of energy consumption close to
the pre-crisis levels.
Taking the above-mentioned elements into consideration and given the collective ambition gap of the
national contributions proposed in the NECPs, the policies in place would have to be significantly increased
in order to reach even the current 2030 targets
Review and the revision of the EED
The process will cover two elements:
1. The evaluation of those elements of the EED that were not revised in 2018.
2. The Impact assessment for a revision of the EED in view of meeting the increased 2030 GHG
emissions reduction ambition.

Against this background, the Commission shall undertake a two-step process. As a first step, the evaluation
will assess the existing framework of the EED since its entry into force in 2012[20], except for those
elements already revised in 2018. It will assess whether the provisions are efficient, effective, and coherent
with the broader EU legislative framework. It shall assess whether the EED is fit to overcome remaining
regulatory and non-regulatory barriers, and market failures, whether there are some shortcomings, gaps
and weaknesses for the existing measures or whether additional measures would be needed to deliver on
their expected results.
The findings of the evaluation will then offer the basis for what needs to be streamlined, strengthened,
added or changed in the EED in order (a) to address the remaining ambition gap to the 2030 EU energy
efficiency targets and (b) to deliver the increased EU greenhouse emissions reduction target of at least
55% by 2030. The impact of these policy choices will be thoroughly analysed and the impact assessment
will look at the impacts of the entire EED, irrespective of the articles that were revised in 2018.
The questions of this consultation are formulated to respect the requirements of the Better Regulation rules
[21] and to support this two-step process of evaluation and impact assessment.

About you
* Language of my contribution

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French
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* I am giving my contribution as

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* First name
Willemijn

* Surname
Meltzer

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* Email (this won't be published)
w.c.s.meltzer@minezk.nl

* Scope

International
Local
National
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* Level of governance

Parliament
Authority
Agency
* Organisation name

255 character(s) maximum
Ministry of Economic Affairs and Climate Policy (The Netherlands)

* Organisation size

Micro (1 to 9 employees)
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* Country of origin
Please add your country of origin, or that of your organisation.

Afghanistan

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and Miquelon

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and the
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Andorra

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and the South

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/Burma

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Bosnia and

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and McDonald
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Cocos (Keeling)

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Transparency register number
255 character(s) maximum
Check if your organisation is on the transparency register. It's a voluntary database for organisations seeking to
influence EU decision-making.

* Does your organisation or institution primarily deal with energy, climate and/or

environmental issues?
Yes
No

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* In which sector / activity? (more choices are possible)

Energy
Climate
Environment
* Does your organisation or institution primarily deal with OTHER issues than

energy, climate and/or environmental issues?
Yes
No
* In which sector / activity? (one choice is possible – please chose the predominant

one)
Water
Transport
ICT
Construction
Production
Other (please specify)
* If you selected 'other', please specify here:
Economic affairs

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Anonymous
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name will also be published.
I agree with the personal data protection provisions

Part I – Questions of general nature
1. Assessing the implementation and the effectiveness of the Energy
Efficiency Directive
Although the progress towards the achievement of the 2020 targets is still to be assessed, it is important to
assess the effectiveness of the existing EED framework and to see how and to what extent the original
objectives were achieved in the context of the proposed higher climate ambition of at least 55% net
emissions reduction by 2030.

1.1 To what extent do you agree with the following statement?
“The original objectives of the EED - to increase energy efficiency across the EU
and to remove barriers and market failures in energy supply and energy use - are
still relevant”?
Strongly
disagree

Disagree

Neither agree nor
disagree

Agree

Strongly

No

agree

opinion

* Please select
your answer

Please explain your answer:

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Dutch climate policy focuses on CO2 reduction through cost-effective solutions. The objective is still relevant
today. There is still a lot of potential for cost-effective energy-efficient solutions, for example in the built
environment and industry. Flexibility for member states is necessary to meet the European targets, such as
alternative approaches and having an indicative energy efficiency target, based on either primary or final
energy consumption

1.2 To what extent has the EED attained its objectives – to increase energy
efficiency across the EU and to remove barriers and market failures in energy
supply and energy use ?
Not

To a little

To some

To a moderate

To a large

No

at all

extent

extent

extent

extent

opinion

* Please select
your answer

Please explain your answer:
Energy efficiency is an important pillar to cut greenhouse gas emissions in a cost-effective manner. The
directive has contributed to increasing energy savings and energy use in Member States and in the different
sectors. Please refer to the Dutch Energy Agreement for Sustainable Growth (2013) for policies

* 1.2.A Which factors helped the most to achieve the objectives of the EED? (m

ultiple options are possible)
Binding nature of the measures of the EED (e.g. Article 5 on exemplary role
for public buildings and Article 7 on energy savings obligation, etc.)
Significant flexibility left to Member States how to achieve various obligations
under the EED
Existence of targets at the EU level
Requirement to set national targets
Requirement for planning policies and measures at national level
Wide scope of the EED covering both the energy supply and demand and
targeting different market actors (e.g. energy suppliers and distributors,
transmission grid operators, national regulators, enterprises and consumers)
Strong monitoring and reporting framework at EU level
Other (please specify)
1.3 To what extent could the below mentioned positive effects and outcomes
(achieved to date) be associated with the EED since its entry into force in
2012? (use a rating scale of 1 to 5, where 1 = to a very little extent and 5 = to a
very large extent)
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1

2

3

4

5

No
opinion

* My country is more committed to energy efficiency
* There is greater awareness about energy efficiency and its
role in achieving the overall climate objectives (i.e. Paris
Agreement)
* More developed market of energy services
* Innovative technologies and techniques are more often used
* Greater availability of funding for energy efficiency
investments
* Energy efficiency policies triggered more jobs and growth
* Energy efficiency led to an increased security of supply
* Energy efficiency led to lower energy bills
* Energy efficiency reduced energy poverty
* Energy efficiency increased resource efficiency

1.4 To what extent could the below mentioned negative effects be associated
with the EED?
(use a rating scale of 1 to 5, where 1 = to a very little extent and 5 = to a very large
extent)
1

2

3

4

5

No
opinion

* Obligations under the EED led to higher administrative
burden besides costs
* Obligations under the EED led to disproportionately higher
costs
* Enterprises have lost substantial revenues
* Obligations under the EED led to flawed investment
decisions
* Obligations under the EED further complicated existing rules
* Guidance on implementation of the EED from national
authorities to enterprises and consumers was unclear
* Obligations under the EED put strain on already limited
national administrative resources
* Obligations under the EED led to too diverging
implementation across Member States

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* The benefits of the EED were unequally distributed among
the population.

Please explain what administrative burden you perceive:
Monitoring is very difficult

* 1.5 Which measures stemming from the EED have been the most successful

in your country in terms of energy savings and other benefits? (multiple
options possible)
Energy efficiency obligation schemes introduced to achieve annual energy
savings among final customers
Obligation for public authorities to renovate buildings owned and used by the
central government
Obligation for public authorities to purchase only products, services and
buildings with high energy-efficiency performance
Obligation for large enterprises to carry out regular energy audits to learn
about their energy consumption profile and identify energy saving
opportunities
Support provided to small and medium-sized enterprises to carry out energy
audits to learn about their energy consumption profile and identify energy
saving opportunities
Measures introduced on awareness raising of energy efficiency and
promoting change of consumer behaviour
Deployment of individual meters and obligation to provide consumers with
better and more frequent information about their energy consumption
Introduction of subsidies, support schemes and fiscal incentives for energy
efficiency
Increased efficiency in energy production/conversion, transmission and
distribution
Introduced measures to address regulatory barriers or split incentives in
national legal frameworks or administrative practices
None of the above
Other (please specify)
* If you selected 'other', please explain your answer here:

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The Netherlands’ existing instrument for energy-saving which requires businesses to implement energyefficiency measures when they lead to a five-year payback period (please refer to Wet Milieubeheer
energiebesparingsplicht).

1.6 To what extent has the EED stimulated energy efficiency efforts in the
following sectors?
( 1 = to a very little extent and 5 = to a very large extent)
1

2

3

4

5

No opinion

* Buildings
* Heating and cooling
* Industry
* Information and communication technologies (ICT)
* Transport
* Agriculture
* Services (i.e. commercial and public)

1.7 To what extent do the following factors represent barriers impeding the
energy efficiency improvements across different sectors?
(use a rating scale of 1 to 5, where 1 = to a little extent and 5 = to a very large
extent)
1

2

3

4

5

No
opinion

* Lack of clear information among consumers about available
energy efficiency measures and support schemes
* Split incentives (different interests of owners and tenants or
investors and users)
* Administrative burden associated with energy efficiency
investments
* Regulatory barriers preventing energy efficiency investments
* Lack of awareness among investors of profitability of
investments in energy efficiency
* High transaction costs to finance the energy efficiency
measures
* Limited access to capital for households and small and
medium-sized enterprises to invest in energy efficiency

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* Lack of available skills to make energy efficiency
improvements
* Low profitability and return on investment
* Complexity or hassle associated with making energy
efficiency investments
* Lack of fiscal measures and incentives including carbon
pricing and energy taxation to provide incentives for energy
efficiency

Please explain your answer (optional):

1.8 To what extent were the costs associated with the implementation of the
EED proportionate to the achieved energy savings and other benefits?
(please rate 1 to 5, where 1 - disproportionate, 5 - proportionate)
1

2

3

4

5

No opinion

* Please select your answer

Please explain, provide further data and information on the costs and benefits
associated with the implementation of the EED and specific EED articles.
The EED does not significantly contribute to the Dutch climate policy. While there is more attention for
energy efficiency improvements, the focus on CO2 reduction is sometimes lacking. Requirements for
monitoring under Article 7 are complex and rather stringent. Lastly, the “energiebesparingsplicht” instrument
is more successful in the Netherlands.

* 1.9 Are there any parts / specific provisions of the EED that are obsolete or

have proven inappropriate?
Yes
No
No opinion
Please explain your answer:

* 1.10

In your view, does the EED have positive synergies with the Effort

Sharing Regulation and the Emission Trading System? If yes, what are those?
Yes
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No
No opinion
Please explain your answer:
Stimulating & facilitating energy efficiency makes it easier to reduce GHG emission in ESR and ETS

* 1.11 In your view, does the EED have positive synergies with the Renewable

Energy Directive? If yes, what are those?
Yes
No
No opinion
Please explain your answer:
Energy savings make it easier to attain RES targets, as the denominator of the RES share is reduced.
Energy savings also lessen the need to increase RES capacity (which requires other scares resources like
materials and space).

* 1.12 In your view, does the EED have positive synergies with the Energy

Performance of Buildings Directive? If yes, what are those?
Yes
No
No opinion
Please explain your answer:
EED stimulates energy savings in buildings by providing funding, to perform audits, to stimulate energy
services and ensures quality of energy auditors.

* 1.13 To what extent has the EED contributed to an optimisation of the overall

energy system (higher system efficiency)?
1000 character(s) maximum
Through synergies with RES by lowering demand helping to balance the energy system, avoiding higher
costs in infrastructure and supply.

* 1.14 What are the main lessons learned from the implementation of the EED?

1000 character(s) maximum

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Article 7 is complicated and difficult to monitor, while it’s added value compared to article 3 and ETS, ESR
and RES are unclear. Cost-efficient attainment of climate targets should be the central focus.
EED is a cross cutting framework Directive that enhanced cross-sectoral policymaking in the field of energy,
buildings, infrastructure and transport, leading to stronger and more sustainable policy making.

* 1.15 What is missing in the EED?

1000 character(s) maximum
Improving the energy audit definitions could contribute to the effectiveness of the energy audit.

2. Assessing possible options for revising the Energy Efficiency Directive
(EED) in view of contributing to the 55% climate target for 2030 and
addressing the ambition gap in the final NECPs
The impact assessment supporting the 2030 Climate Target Plan concluded that a contribution at the level
of 36-37% for final energy consumption and 39-41% for primary energy consumption by 2030 would be
required.
Therefore, the Commission has launched the EED revision process. The revision would reflect on the need
to increase energy efficiency efforts to match the level of ambition of a higher 2030 climate target and
would also aim to strengthen those parts of the EED, which could address the remaining ambition gap for
energy efficiency in the NECPs, to ensure the achievement of the current level of the EU energy efficiency
target for 2030. In addition, the revision will be vital to contribute to the implementation of the other
European Green Deal Initiatives[22]. This is particularly relevant especially in the context of actions
identified in the Commission’s Recovery Plan[23], which need to be reflected in the national Recovery and
Resilience Plans.
The EED revision also offers the important opportunity to address any shortfall in its effectiveness and
efficiency. A notable case relates, for instance, to the need for a more consistent application of the Energy
Efficiency First principle. Another important area is the need to address any outstanding regulatory and nonregulatory barriers for additional energy savings and emissions reduction throughout all economic sectors.
In this context, the revision of the EED will also have to consider whether the EED sufficiently addresses
emerging opportunities and needs for energy efficiency improvements in sectors like ICT sector, as well as
agriculture and water.
In addition to the results of the evaluation of the Directive, the impact assessment of the 2030 Climate
Target Plan and the Commission assessment of the final NECPs will feed into formulation of policy options
to identify which elements of the EED – and to what extent – need to be amended, and what needs to be
added to achieve the objectives outlined above.
*

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2.1 Do you agree that energy efficiency should play a key role in delivering a
higher climate ambition (of at least 55% net) for 2030 and in view of achieving
the EU’s carbon neutrality by 2050?
Agree
Neutral
Disagree
No opinion
Please explain your answer:
It is important that member states have flexibility to achieve the 2030 greenhouse gas reduction target of at
least 55% in the most cost-effective manner. This is to ensure that there is room for the EU and for each
member state, with different starting positions, to arrive at the most optimal and cost-effective mix of
measures related to energy efficiency, renewable energy and other CO2 reducing practices.

* 2.2 Given the suggested increase in energy efficiency efforts by 2030, which

instruments of general nature should be considered to achieve the higher
energy efficiency ambition? (multiple options possible)
Making the “Energy Efficiency First” principle* a compulsory test in relevant
legislative, investment and planning decisions
Strengthening the EED requirements
Setting a higher energy efficiency target at EU level for 2030
Setting energy efficiency targets in specific sectors of the economy
Stronger focus on implementation and on enforcement of the existing
legislation at national and EU level
Stronger focus on life-cycle efficiency and circularity.
The EU should provide additional technical support to Member States
Stronger focus on fiscal measures and incentives including through carbon
pricing.
Stronger focus on awareness raising of energy efficiency and behavioural
change
Other (please specify)
* Energy Efficiency First (in line with Article 2(18) of the Regulation (EU) 2018/1999), means taking utmost account in energy planning, and in
policy and investment decisions, of alternative cost-efficient energy efficiency measures to make energy demand and energy supply more
efficient, in particular by means of cost-effective end-use energy savings, demand response initiatives and more efficient conversion,
transmission and distribution of energy, whilst still achieving the objectives of those decisions.

*

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2.3 Do you agree that the EED should be strengthened by introducing new
measures and stricter requirements in the context of a higher energy
efficiency ambition for 2030?
Yes
No
No opinion
Please explain your answer:

* 2.4 Could the EED be simplified while preserving its objectives and if so,

how?
1000 character(s) maximum
Art 8 and art 14 have limited effect in the Netherlands and do not, in themselves, contribute to the energy
efficiency targets.

* 2.5 With the suggested increase in ambition for energy efficiency for 2030,

what should the nature of the EU targets be?
Indicative
Binding
Not specified
Other (please specify)
* 2.6 With the suggested increase in ambition for energy efficiency for 2030,

what should the nature of the national targets be?
Indicative national targets (to contribute to EU energy efficiency target for
2030)
Binding national targets
Not specified
Other (please specify)
If you selected 'other', please specify here:
It is important that there is room for a state-specific approach in a possible revision of the EED, in line with
the choices that have been made in the NECP.

*

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2.7 In which sectors would additional energy efficiency efforts be most
needed to achieve a higher energy efficiency ambition for 2030? (multiple
options possible)
Buildings
Heating and cooling
Industry
Information and communication technologies (ICT)
Transport
Agriculture
Services (i.e. commercial and public)
Other (please specify)
Please explain your answer:

2.8 Should the following measures be considered to achieve a higher
ambition?
(use a rating scale of 1 to 6, where 1 = strongly disagree and 6 = strongly agree)
1

2

3

4

5

6

No
opinion

* Strengthening the renovation obligations for public
buildings
* Strengthening energy efficiency requirements for
public procurement
* Requiring that local authorities (above a certain size)
develop an energy efficiency action plan with
measurable impact indicators
* Requiring that large enterprises implement certain
energy efficiency improvements identified in energy
audits
* Requiring that small and medium-sized enterprises
are offered free energy audits
* Extending the requirement on frequent consumption
information from electricity and thermal energy to
also cover gas and roll-out remotely readable gas
meters
*

20

Establishing sector specific goals or measures
addressing sectors for which the energy efficiency
potential is higher (e.g. services, data centres,
energy-intensive industries)
* Strengthening the requirements for efficiency in
energy transformation, transmission and distribution
* Strengthening the requirements for using energy
performance contracting in renovation of public
buildings
* Introducing or extending fiscal measures and
incentives, including carbon pricing and energy
taxation
* Other (please specify)

Please explain your answer:

2.9 Should the following measures in the heating and cooling policy area be
considered in order to achieve more effectively the decarbonisation
objectives?
(use a rating scale of 1 to 6, where 1 = strongly disagree and 6 = strongly agree)
1

2

3

4

5

6

No
opinion

* Member States should introduce specific energy
efficiency targets for the heating and cooling sector
to ensure that energy consumption in this sector is
sufficiently taken into account
* Fossil fuels in heating systems (in buildings and
district heating) should be gradually phased out with
a faster phasing out of the most polluting ones
* Fossil fuel heating system should be banned for new
buildings whenever technical feasible
* Member States should unbundle the management of
the generation and distribution heat network
* Allow public support for heating systems only to nonfossil fuel technologies
* The recovery of waste heat from heating and cooling
(air-conditioning) systems in individual buildings
should be promoted
*

21

Specific requirements for utilization of waste heat
and waste cold should be set for industry and
services
* Requiring district heating and cooling operators to
prepare long-term plans to improve their energy
efficiency in terms of primary energy intensity energy
* Member States should facilitate local and district
approaches to policy and infrastructure planning and
development in heating and cooling
* Other (please specify)

Please explain your answer:

2.10 Can the following principles ensure overall consistency of energy
efficiency and renewable energy as key policies for decarbonisation?
(use a rating scale of 1 to 6, where 1 = strongly disagree and 6 = strongly agree)
1

2

3

4

5

6

No
opinion

* Having distinct energy efficiency and renewable
targets is the best avenue to decarbonisation.
* Member States’ progress towards decarbonisation
targets should be the primary indicator to assess the
renewables and energy efficiency policies and
measures.
* Member States need to progress on both energy
efficiency and renewables to reach their
decarbonisation targets.
* Non-binding nature of national renewable and energy
efficiency targets allows Member States to choose
cost-efficient decarbonisation paths.
* Energy efficiency policies and measures should be
prioritised where fossil-based energy solutions are
currently used.

* 2.11 How could synergies between the EED and the Renewables Energy

Directive be strengthened in the future?
1000 character(s) maximum
No opinion

*

22

2.12 How could synergies between the EED and the Energy Performance of
Buildings Directive be strengthened in the future?
1000 character(s) maximum
No opinion

* 2.13 How could synergies between the EED and the Emission Trading

System (ETS) be strengthened in the future, especially in the context of a
possible extension of the ETS?
1000 character(s) maximum
Dutch climate policy is based on CO2 reduction in the most cost-effective manner. Synergies between the
ETS and the EED could be strengthened by combining CO2 reduction measures with energy-efficiency.
Simultaneously, it is important that member states have flexibility to achieve the 2030 greenhouse gas
reduction targets.

* 2.14 How could synergies between the EED and the Effort Sharing Regulation

be strengthened in the future?
1000 character(s) maximum
Dutch climate policy is based on CO2 reduction in the most cost-effective manner. Synergies between the
Effort Sharing Regulation and the EED could be strengthened by combining CO2 reduction measures with
energy-efficiency. Simultaneously, it is important that member states have flexibility to achieve the 2030
greenhouse gas reduction targets.

* 2.15 How could EU citizens - and especially young people - be more engaged

and contribute to achieving a higher ambition of energy efficiency?
1000 character(s) maximum
No opinion

* 2.16 The “Energy Efficiency First” principle is established in energy

legislation to contribute to a higher energy efficiency ambition. Which
measures in your view could be implemented to ensure the principle is
consistently applied? (multiple options possible)
Providing more information to users on energy efficiency and energy
consumption of products and infrastructures, considering their life-cycle.
Requiring that the “energy efficiency first” principle is applied to all relevant
EU energy policies related to the whole energy value chain
Requiring that the “energy efficiency first” principle is applied to all relevant
national energy policies related to the whole energy value chain

23

Developing guidelines on implementation in relevant policy, planning and
investment decisions
Developing mechanisms to monitor implementation of the principle at
national level
Others (please specify)
None
Please elaborate on your answer:
1000 character(s) maximum
It is key that the energy efficiency first principle is determined in line with a cost-effective strategy to achieve
55% greenhouse gas reduction.

* 2.17 Is there a need to develop a common methodology on the application of

the “Energy Efficiency First” principle in energy networks investment
programmes and operation practices?
Yes, and it should be developed by the European Commission, ENTSO(-e,g), national energy regulator, TSO, other
Yes, and it should be accompanied by an appropriate monitoring mechanism
No, there are already specific documents and methodology developed on this
No, this would intrude into the independence of the National Regulatory
Authorities
No, the energy networks in the EU are too diverse to be covered by a
common methodology (principle of subsidiarity)
No, while the case can be made for a common methodology, it would be too
cumbersome to implement in practice
Other (please specify)

This is the end of Part I.
If you wish to contribute on technical aspects of different articles, please continue with part II.

Do you want to continue with part II on the technical aspects of different articles?
Yes
No
If you decide to end the survey here, we thank you very much for your valuable contribution.

24

Part II – Technical questions on specific Articles of the
Energy Efficiency Directive
The EED lays down a set of measures aimed to step up Member States’ efforts to use energy
more efficiently at all stages of the energy chain – from the transformation of energy and its
distribution

to

its

final

consumption

-

and

those

are

as

follows:

Articles 1 & 3 (energy efficiency targets) sets the EU headline energy efficiency
targets for 2020 (of 20%) and for 2030 (of at least 32.5%) and Member States have to
set their national indicative targets and indicative contributions in view of achieving
those headline targets for 2020 and 2030 respectively. Member States shall report
annually on the progress towards their national indicative energy efficiency targets and
submit National Energy Efficiency Action Plans (‘NEEAPs) every three years, starting
from 2014. For the headline EU 2030 target, Member States shall fulfil the planning and
reporting obligations under the Governance regulation (set their national contributions
towards the EU 2030 target and define the national measures to fulfil those contributions
in the National energy and Climate Plans to be submitted to the Commission by end
2019.
Article 5 (exemplary role of public bodies’ buildings) requires that Member States
renovate 3% (or implement alternative measures resulting in equivalent savings) of their
central government buildings of over 500 m² which do not meet the cost-optimal energy
efficient standards. This threshold dropped to 250 m² as of 9 July 2015.
Under Article 6 (purchasing by public bodies) central governments have the
obligation to purchase energy efficient products, buildings and vehicles, and Member
States should encourage public bodies of local and regional government do so as well.
This Article was evaluated in 2016[24], however the findings were not conclusive given
that the implementation had just started and it was too early to assess the impact[25].
Article 7 (energy saving obligations) sets an obligation on Member States to achieve
new energy savings each year (of 1.5% of the annual energy sales for the period 20142020 and of 0.8% (0,24% for Malta and Cyprus) of the final energy consumption for the
period 2021-2030) by putting in place an energy efficiency obligations scheme or other
policy measures. Article 7 is responsible for about half of the energy savings the EED is
expected to deliver. As mentioned above, this Article was amended as part of the
focused EED review in 2016 (amending Directive EU/2018/2002). Under
Article 8 (energy audits and energy management systems) Member States must
ensure that large companies have their first energy audit by 5 December 2015 and then
every four years. The review of the implementation of the definition of small and medium
size enterprises for the purposes of Article 8(4) is carried out in a separate process (in
line with the amended Article 24(12)).

25

Articles 9 to 11 (metering and billing) provide requirements for metering and billing of
energy use. As mentioned above, those Articles were already amended as part of the
focussed EED review in 2016 (amending Directive EU/2018/2002) by adding new, more
precise and specific provisions applicable for thermal energy (heating and cooling)[26].
Electricity related provisions were transferred to the recast Electricity Directive (EU) 2019
/944. For an overview and a detailed discussion of the changes made please refer to
Commission Recommendation (EU) 2019/1660 of 25 September 2019 on the
implementation of the new metering and billing provisions of the Energy Efficiency
Directive 2012/27/EU[27].
Article 14 (promotion of efficiency in heating and cooling) requires that Member
States promote efficiency in district heating and cooling systems and carry out
comprehensive territory-wide assessments of the potential for efficient heating and
cooling by 31 December 2015 which should be resubmitted again by 31 December 2020
(on basis of the updated methodology and the amended Annex VIII and part of Annex
IX)[28]. It also requires individual cost-benefit analysis to be carried out in the context of
the planning and permitting of certain types of installation (thermal electricity generation,
industrial installations, district heating and cooling network), in order to assess the
potential benefits of high-efficient cogeneration installation or utilising waste heat from
nearby industrial installations(Art. 14(5) and 14(7)).
Article 15 (energy transformation, transmission and distribution) requires that
Member States ensure that energy efficiency is taken into account in energy
transformation, transmission and distribution and contains specific provisions to this
end. Certain of these (parts of Art. 15(5) and Art. 15(8)) were removed as part of the
focussed revision in 2018 and replaced with consolidation provisions in the new
Electricity Market legislation.
Article 16 (on qualifications and accreditation schemes for providers of energy
services and energy audits) had a later transposition deadline than the rest of the
Directive (31 December 2014) and it is also closely linked to the implementation of
Articles 17 and 18.
Under Article 17 (information and training) Member States shall ensure that
information on available energy efficiency mechanisms and financial and legal
frameworks is widely disseminated to all relevant market actors. The effectiveness of
the implementation of this Article was assessed in 2017[29]. The findings of the
assessment showed that while most of the Member States have put in place information
and awareness raising measures, it is hard to assess their impact on the uptake of
energy efficiency improvements and investments due to lack of robust monitoring results
and ex-post evaluations.
Member States are required to promote the energy services market under Article 18
(energy services) with a particular focus put on supporting the public sector including
through the use of energy performance contracting. A number of reports to assess

26

progress of energy service markets in the EU including the uptake of the energy
performance contracting have been carried out by the JRC in the framework of an
administrative arrangement with DG ENER.
Article 19 (other measures to promote energy efficiency) requires the Member
States to take action to remove regulatory and non-regulatory barriers to energy
efficiency and to report on this to the Commission as part of their first National Energy
Efficiency Action Plan (NEEAP). Progress made by Member States in relation to Article
19(1) was assessed on basis of the notified NEEAPs 2014 and 2017 and a report was
published in 2019[30].
Article 20 (Energy Efficiency National Fund, financing and technical support)
provides that the Member States shall facilitate the establishment of financing facilities
and that they may set up an Energy Efficiency National Fund. This Article was amended
in the focussed EED review by adding additional requirements for the Member States
and the Commission (providing guidance on how to unlock private investments).
Article 21 on the conversion factors set out in Annex IV was amended for the
purposes of reviewing the default coefficient - primary energy factor for electricity
generation (in footnote 3) and which should be again reviewed by 25 December 2022
(as required by amending Directive EU/2018/2002). Article 24 (review and monitoring of
implementation) contains reporting obligations for the Commission (while the reporting
obligations for the Member States have been transferred to the Governance Regulation,
(EU)2018/1999). This Article thus has been partially amended to ensure the coherence
with the Governance framework and the amendments of Articles 3 and 7, and it is thus
specifically targeted in this consultation.

About you - What is your field of expertise?
Energy policy
Energy efficiency
Energy audit and management
Energy performance of buildings
Heating and cooling
Other (please specify)
If you selected 'other', please specify here:

Article 1 and 3 - Energy efficiency targets

27

3.1 How do you assess the level of ambition of the existing EU energy
efficiency targets?
(too high - adequate level - too low)
Too high

Adequate level

Too low

No opinion

For 2020 targets
For 2030 targets

3.2 Could you please give your opinion on the current aspects of the Union’s
energy efficiency targets for 2020?
(Appropriate – Not appropriate – Difficult to say/ No opinion)
Appropriate

Not

Difficult

No

appropriate

to say

opinion

The nature of the target is not specified (whether it
is binding or indicative)
Indicators used for defining the target: primary or
final energy consumption
Same level of ambition for both primary and final
energy consumption
Definition of the baseline (2007 Reference
Scenario projections for 2020)
Clarity of the target

Please explain your answer here (optional):
Saving final energy is much harder than saving primary energy considering most energy used is based on
combustion of fossil fuels

3.3 Could you please give your opinion on the following aspects of the
national energy efficiency targets for 2020?
(Appropriate – Not appropriate – Difficult to say/ No opinion )
Appropriate

Not

Difficult

No

appropriate

to say

opinion

Approaches for setting national targets are not
prescribed - Member States can chose the
methodology and indicators for setting their target
(s) (primary/ final energy consumption, savings or
intensity)
Indicative nature of national targets (no sanctions
for non-compliance)

28

No reference values/formula at EU level for
assessing the level of national ambition
No need to set intermediate milestones/ trajectory
to targets
Possibility to revise the national targets

Please explain your answer here (optional):

3.4 Has the EED provided the right monitoring and enforcement mechanisms
to achieve national energy efficiency targets?
Yes
No
No opinion
Please explain your answer:
Monitoring of Article 7 savings proves to be more challenging methodologically & increases administrative
burden compared to monitoring Article 3 targets.

Article 5 – Exemplary role of central government buildings

3.5 Has the EED made central government buildings in your country more
energy efficient?
Yes
No
No opinion
Please explain your answer:
The energy saving ambition for 2030 in the national roadmap of the Central Government Real Estate Agency
is higher and more than equivalent to the energy saving of taking the mandatory renovation measures under
EED article 5. Realization of this ambition in the roadmap satisfies as alternative approach for EED article 5.
The roadmap is made for the national Climate Agreement and describes how to come to a low emission
building stock of the central government in 2050.

3.6 What are the main factors limiting central government in effective and
efficient renovation of its buildings (multiple options possible)?
Insufficient enforcement of the regulatory framework in my country

29

Insufficient national budget earmarked for renovation
Requirement to renovate can be achieved by alternative measures that are
not clearly defined and are hard to monitor
Requirement to renovate does not apply to rented buildings and central
government authorities often rent their buildings
Other (please specify)
3.7 How do you assess the current 3% annual goal on renovation of central
government’s buildings in line with Article 5?
The 3% goal is too low and does not go beyond the standard rate of
renovation
The 3% goal is at an adequate level to promote renovation of central
government’s buildings
The 3% goal is too high
Other (please specify)
If you selected 'other', please explain here:
Of the Dutch central government building stock, 3.9 million m2 of useable floor area currently does not meet
the EPBD requirements. If 3% of that were to be renovated annually, this would result in a saving of 0,2PJ in
the period 2021-2030.
The saving of 0,2 PJ for article 5 EED has been compared with the saving from the Sectoral Roadmap of the
Central Government Real Estate Agency. The intended saving by following the roadmap is 1,3 PJ in 2030.
This is higher than the EED saving because the roadmap focuses on the whole real estate portfolio and not
only the 3& yearly renovated part of the stock that doesn’t meet the EPBD requirements. Although the
saving per square meter of 111 MJ/m2 in the roadmap is approximately 60% lower than that for the EED of
approximately 180 MJ/m2, which is mainly because the EED focuses on the buildings with the highest EI,
the higher amount of useable floor area gives higher total energy savings.

3.8 Given that additional energy efficiency efforts are needed, how could
Article 5 be made more effective? (multiple options possible)
The obligation to renovate public buildings should be extended to regional
and local authorities
The obligation should be extended to include buildings simply occupied by
the central government
The obligation should be extended to include buildings simply occupied by
the central, regional and local public authorities
The obligation should target specific type of public buildings, such as
schools and hospitals
30

The required floor area to be renovated each year should be higher than 3%
of all public buildings
The obligation shall require deep renovations in order to reach higher than
minimal energy standards
Minimum energy performance requirements for owned and rented public
buildings should be introduced
Minimum levels of renewable energy use should be introduced
Public authorities should be required to adopt an energy management
system and track buildings performance
Wider approaches to achieving sustainable built environment (such as
circular economy considerations) should be better considered for public
buildings renovations
Other (please specify)
If you selected 'other', please explain here:
In the Dutch National Climate Agreement, it has been agreed upon to draw up 12 sectoral roadmaps,
including for education, sports, healthcare, municipalities, the police and the Central Government Real
Estate Agency. Via four-yearly roadmaps at portfolio level, sustainable multi-year maintenance plans and / or
multi-year real estate sustainability plans the sectoral roadmaps will visualize which measures they have
already taken and how they are working towards the target for 2030 and a low-carbon real estate portfolio by
2050. The reporting method will be standardized by the national government, in collaboration with the
sectoral organizations and other competent authorities.
Each sector has a diverse portfolio of buildings with its own challenges of energy efficiency and renewable
energy. The Dutch tailor-made approach of sectoral roadmaps in combination with a unified reporting
method addresses these challenges. It will contribute to a cost effective reduction of CO2-emissions in the
buildings within the different sectors. Article 5 would strengthen the approach if it requires Member States to
set a minimum target for public buildings and specific types of buildings such as schools and hospitals
owned and occupied by central, regional or local government.

Article 6 – Purchasing by public bodies

3.9 Has the requirement for central governments to purchase only products,
services and buildings with high energy-efficiency performance helped to
develop a market for energy efficiency products and services in your
country?
Yes
No
No opinion
31

Please explain your answer:
There are no recent researches on the effects on the market. However, we do notice an increasing interest
from companies wanting to collaborate with the Dutch government on these topics.

3.10 Given that additional energy efficiency efforts are needed, how could
Article 6 be made more effective? (multiple options possible)
The energy efficiency requirement in public procurement should be extended
to all levels of public administration (including to regional and local
authorities)
Requirements on reporting on energy used during the whole lifetime of
procured goods and buildings should be gradually introduced
A mandatory calculation of total cost of ownership shall be introduced for
public procurement The references to limiting conditions (e.g. costeffectiveness, economic feasibility, technical suitability) should be removed
Other (please specify)

Article 7 – Energy Savings Obligation

3.11 Taking into consideration the required higher energy efficiency efforts
for 2030, how do you assess the current level of ambition of Article 7(1) on
energy savings obligation?
(too high - adequate level - too low)
Too high

Adequate

Too low

No opinion

Please select your answer

3.12 What elements of Article 7 should be addressed to ensure the higher
level of energy efficiency for 2030 (ranking the measures by using the scale 1-6,
1 – not important and 6 – very important; or No opinion)
1

2

3

4

5

6

No
opinion

Increase the ambition level of energy savings
obligation for 2021-2030
Strengthen the additionality criteria for existing tax
measures
Make the EEOS a mandatory instrument in all
Member States

32

Require Member States to set a certain level of
energy savings to be achieved in building renovations
Require Member States to set a certain level of
energy savings to be achieved in transport
Strengthen the monitoring and verification rules
Require Member States to target specific sectors
with policy measures under Article 7
Set mandatory requirements to implement a specific
share of policy measures to alleviate energy poverty
Other (please specify)

If you selected 'other', please explain here:
It is of importance that member states continue to have an indicative energy efficiency target, based on
either primary or final energy consumption. In line with the choices that have been made in the NECP.

Article 8 – Energy audits and energy management systems

3.13 Current rules oblige enterprises that are not small or medium-sized to
carry out every four years an energy audit to learn about their energy
consumption profile and identify energy saving opportunities. Should these
rules be changed?
Yes
No
No opinion
Please explain your answer:
These rules should be complementary to existing national policies and programmes.

Articles 9-11 - Metering for gas

3.14 To what extent has the EED contributed to final customers being
informed of actual gas consumption and costs properly and frequently
enough to understand what drives their consumption and make informed
choices about possible energy saving measures?
Contributed to a large extent
Contributed to some extent
33

Did not contribute
I do not know
Please explain your answer:
The implementation of remote reading of gas meters has helped to give the customers more information
about their actual use. The effect on the use of gas is very much dependent on the type of feedback
households receive on their energy use. Research has shown that indirect feedback (a monthly overview of
energy consumption) does not result in significant energy consumption reduction. Direct feedback systems
such as in-home displays do have an energy-saving effect.

Article 14 - promotion of efficiency in heating and cooling and related Annexes and
definitions

3.15 Have the requirements under Article 14 increased energy efficiency in
the heating and cooling sector in your country?
Yes
No
No opinion
Please explain your answer:
The intention of article 14 is in line with the Dutch policy. The detailed requirements in article 14 were legally
implemented, but had little effect.

3.16 What was the impact in your country of the requirement to carry out a
cost-benefit analysis under Article 14(5) in the following areas
(please rank: Very high – High – moderate – Low – Very low)
Very
high

High

Moderate

Low

Very

No

low

opinion

It increased energy efficiency of energy
supply
It increased energy efficiency of heating
and cooling networks
High-efficiency cogeneration was more
often deployed
Efficient district heating and cooling was
more often deployed
Increased reuse of waste heat from
industry

34

It increased reuse of waste heat from
services (including ICT)

3.17 Given that additional energy efficiency efforts are needed, how could
Article 14 and related Annexes and definitions (Article 2) be made more
effective? To what extent do you agree that the following measures should
be implemented
(use a rating scale of 1 to 6, where 1 = strongly disagree and 6 = strongly agree)
1

2

3

4

5

6

No
opinion

Minimum requirements for efficient district heating
and cooling should be strengthened;
Minimum requirements for efficient district heating
and cooling should be established separately for
networks and generation units;
Minimum requirements for high-efficiency
cogeneration should be strengthened;
Minimum requirements for high-efficiency
cogeneration using fossil fuels should be stricter;
The Comprehensive assessments in line with Article
14(1) should explicitly cover renewable energy
potentials in heating and cooling;
The requirement to address the potential identified in
the Comprehensive assessments through policies
and measures should be strengthened;
The requirements for a cost-benefit analysis in line
with Article 14(5) should be based on primary energy
savings;
Member States should better ensure that costs and
benefits of more efficient heating and cooling supply
are taken into account in infrastructure and
investment planning and permitting;
Planning and permitting of infrastructure generating
waste heat or cold should take into consideration
geographical proximity of a potential demand (heat
sink) for this energy;
Member States should introduce specific energy
efficiency indicators for district heating and cooling to
ensure that operators improve energy efficiency of
their generation and reduce network losses;
Other (please specify).

35

If you selected 'other', please explain here:
Efficiency of district heating should be based on CO2-emissions. Requirements can be set nationally. There
is no EU-market for heat, therefore there is no need for an EU-wide requirement. The EU can provide a
guideline for setting up requirements for district heating.

3.18 Which of the following measures would be important to increase energy
efficiency of data centres? (select one answer for each option)
Rules should ensure that:

Very
important

Important
to some
extent

Not

No

important

opinion

large data centres are encouraged to be located
where their waste heat can be used
the potential for waste heat reuse is assessed
when new data centres apply for planning
permissions
existing provisions to exploit industrial waste heat
potential are strengthened

Please explain your answer (optional):
Please note: in the allocation of new large data centres, the potential for waste heat use is only one of many
important considerations to take into account. The proximity of high-grade internet infrastructure and energy
supply and factors such as spatial impact are likely to be of equal or greater importance.

Article 15 – Energy transformation, transmission and distribution

3.19 Do electricity and gas networks (transmission and distribution) operate
in the most energy efficient way in your country?
Yes
No
I don't know
Please explain your answer:
It is impossible to establish whether Dutch electricity and gas networks are operated in the absolutely most
energy efficient way theoretically possible. Nonetheless, in a comparative report from CEER from 2020 it is
clear that the level of system losses in Dutch electricity network operators is relatively low (“2nd CEER
Report on Power Losses”). Furthermore network operators in the Netherlands are strongly incentivized
through the regulatory mechanism to minimize technical losses, improving energy efficiency. Failure to
minimize losses, results in lower revenues for network operators. We therefore feel confident our electricity
and gas networks are managed energy efficiently and are furthermore not aware of any additional measures
possible or necessary to improve energy efficiency

36

3.20 Which are the main factors limiting energy efficiency improvements of
the networks in your country? (multiple options possible)
The regulatory authorities discouraged investments by not accepting the
investment in the Regulatory Asset Base;
Financing for investments is not easily available;
The tariff structure is not conducive to the minimization of energy losses in
the grids;
The capital expenditure would result in an inacceptable increase of network
tariffs for the final consumers;
The efforts needed to upgrade the physical infrastructure of the grid would
disturb households;
The authorisation of permits is too long;
The environmental impact of upgrading the infrastructure would be larger
than that of the energy wasted in the grids;
Other (please specify)
If you selected 'other', please explain here:
We do not perceive there to be any substantial factors limiting energy efficiency improvements in our
networks. We note that the tariff structures for calculating charges for network users within the EU, as per
European regulations, must de designed to fulfill multiple different objectives (see article 18, paragraphs 1
and 2 of the Regulation 2019/943 for instance). In practice, some of these goals will contradict in the way
they inform tariff structure design. Tariff structures for network charges therefore theoretically could be
strengthened to incentivize energy-efficiency more than they do so now, but care should be taken that other
European objectives of tariff structures (such as non-discrimination, transparency, cost-reflectiveness) are
not undermined. We think European and Dutch regulation currently strike a good balance.

Article 16 – Availability of qualification, accreditation and certification schemes

3.21 Are you aware of the certification schemes, accreditation schemes and
equivalent qualification schemes for providers of energy services, energy
audits, energy managers and installers available in your country?
Yes
No
No opinion
Please explain your answer:

37

3.22 How you would assess the effectiveness of the existing certification and
/or accreditation schemes in your country?
Effective

Effective to some

Not

I do not know/ no

extent

effective

opinion

Please select your
answer

Please explain your answer:

3.23 In your view, has the EED (Article 16) contributed to setting up the
certification and/or accreditation schemes and/or equivalent qualification
schemes, including training programmes?
Yes
No
No opinion
Please explain your answer:

Article 18 – Energy services

3.24 Have the requirements under Article 18 contributed to the development
of energy services market in your country?
Yes
No
No opinion
Please explain your answer:

3.25 What possible elements should be considered as part of the EED
revision to improve the functioning of energy services and energy
performance contracting?

38

Introduction of reporting requirements for Member States on the certified
energy services providers, number of energy performance contracts
concluded in the public sector etc.;
Introduction of requirements for independent monitoring and verification of
energy performance contracts;
Strengthening of requirements on independent market intermediaries
/facilitators/ one-stop shops to increase trust and facilitate the use of energy
services/ energy performance contracting;
Other option(s). (please specify)

Article 19 – Other measures to promote energy efficiency

3.26 How do you perceive the existence of regulatory, legal or administrative
barriers to energy efficiency in the following areas:
Very

Somewhat

Not

No

significant

significant

significant

opinion

Split incentives between the owner and the tenant
(s) of a building
Split incentives between owners in multi-owner
properties
Investments in energy efficiency by individual
public bodies prevented due to national or regional
rules on public purchasing annual budgeting or
accounting

Please explain your answer:
Additionally, it is desirable that the State aid rules also make it (better) possible to grant State aid with regard
to existing buildings. The Dutch position paper on the state aid rules for environmental protection and energy
includes comments on this topic.

Article 20 – Energy Efficiency National Fund, financing and technical support

3.27 Has Article 20 facilitated access to finance for energy efficiency projects
in your country?
Yes
No
No opinion

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Please explain your answer:

3.28 What was the impact of Article 20 in your country in the following areas?
No
Very
low

Low

Moderate

High

Very
high

opinion/
difficult
to
assess

Setting up an Energy Efficiency National
Fund or a similar national financial support
scheme for energy efficiency in households
Setting up specific financing facilities for
increasing energy efficiency in different
sectors
Setting up specific technical support
schemes for increasing energy efficiency in
different sectors
Dissemination of best practice in the field
of financing energy efficiency
Using revenues from annual emission
allocations under Decision No 406/2009
/EC for the development of innovative
financing mechanisms for improving the
energy performance of buildings

Article 21 – Conversion factors and Annex IV

3.29 Should Annex IV on “Energy content of selected fuels for end use” be
revised? If so, how?
Yes
No
No opinion
Please explain your answer:
Energy contents should reflect developments in memberstates

3.30 In your view, how could the default Primary Energy Factor (the
coefficient referred to in footnote (3) of Annex IV) facilitate decarbonisation?
1000 character(s) maximum

40

Default PEF should reflect developments in EU energy mix. The possibility to use a memberstate specific
PEF should remain in order to reflect developments in memberstates.

This is the end of the survey. Thank you very much for your valuable
contribution.
References
[1] The Roadmap and Inception Impact Assessment was published on 3 August and was made available for public feedback until 21
September 2020: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12552-EU-energy-efficiency-directive-EEDevaluation-and-review
[2] Regulation (EU) 2018/1999
[3] Definition provided in Article 18(2) of the Regulation, EU(2018)1999 on the Governance of the Energy Union and Climate Action
[4] Directive 2010/31/EU
[5] Regulation (EU) 2017/1369
[6] Directive 2009/125/EC
[7] Directive (EU) 2018/2001
[8] Directive 96/61/EC
[9] Regulation (EU) 2018/842
[10] Amending Directive (EU) 2018/2002
[11] https://ec.europa.eu/energy/en/topics/energy-strategy-and-energy-union/clean-energy-all-europeans
[12] Articles 1&3 on headline energy efficiency targets, Art 7 on energy saving obligations, 9-11 on metering and billing, 15(2), 20, 22-24,
footnote 3 in Annex IV, Annex V, a new Annex VIIa, Annex IX
[13] Cf. Article 24(15) and Article 3(6) of the revised EED
[14] COM(2019) 640 final
[15] COM (2020) 562 final
[16] COM(2020) 562 final
[17] COM/2020/564 final
[18] COM(2020) 954 final
[19] A report from the Task Force is available here: https://ec.europa.eu/energy/sites/ener/files
/report_of_the_work_of_task_force_mobilising_efforts_to_reach_eu_ee_targets_for_2020.pdf
[20] Article 24(15) of the EED requires to carry out a general evaluation by 28 February 2024.
[21] See https://ec.europa.eu/info/sites/info/files/better-regulation-guidelines-evaluation-fitness-checks.pdf
[22] Notably – but not limited to – the Renovation Wave initiative (COM(2020) 632), given that a significant share of energy and resource
savings are expected to come from renovation of buildings, the EU Strategy for Energy System Integration (COM(2020) 299 final), the Digital
Strategy (COM(2018) 7118 final) , the forthcoming Zero Pollution Action Plan and new Circular Economy Action Plan (COM(2020) 98 final).
Energy efficiency is relevant especially in the context of actions identified in the Commission’s Recovery Plan[1], which need to be reflected in
the national Recovery and Resilience Plans.
[23] COM(2020) 456 final
[24] SWD(2016) 402 final
[25] See https://ec.europa.eu/energy/sites/ener/files/documents/3_en_autre_document_travail_service_part1_v3.pdf
[26] While removing thermal energy from the original provisions thereby restricting their scope to electricity and gas. Subsequently also
electricity has been removed from their scope and instead regulated under the provisions of the recast Electricity Directive (EU) 2019/944:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2019.158.01.0125.01.ENG&toc=OJ:L:2019:158:TOC
[27] See e.g. section 1.1. and 1.3 of the annex: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1574946822907&uri=CELEX:
32019H1660
[28] C(2019) 6625 final

41

[29] https://ec.europa.eu/energy/sites/ener/files/final_report_of_assessment_of_the_implementation_status_and_effectivenes.pdf
[30] https://publications.jrc.ec.europa.eu/repository/bitstream/JRC115314
/assessement_of_progress_made_by_member_states_in_relation_to_article_19_final.pdf

Contact
ENER-EED-CONSULTATION@ec.europa.eu

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