On the 15th April 2021, we sent a letter to the EU Commission to react to the latest draft delegated act on Sustainable Finance (Taxonomy).

As representatives of the energy services’ sector, hence promoters of energy management solutions allowing to improve and keep energy performance over time (such as Energy Performance Contracts, EnPCs), we are particularly pleased to see that the future DA will confirm the inclusion of a new category of activities, covering key energy efficiency services in buildings: “Professional services related to energy performance of buildings” (Section 9.2).

We also welcome the revision of some important provisions in the energy section, such as those relating to bioenergy, which is no longer considered as a transitional activity, and the confirmation of criteria previously developed for thermal energy storage, district heating & cooling, heat and cool production from waste heat.

However, we believe that some issues still need to be better addressed by the DA, which fails to ensure a full and complete application of the Energy Efficiency First principle across all sectors and in some critical activities, such as energy generation. For this to happen, the list of eligible activities for climate change mitigation and their relevant technical screening criteria (in Annex I to the DA) should be reviewed, in order to integrate and reflect the following elements:

  • Energy Efficiency First should be fully recognised and applied to Industry
  • Energy Efficiency First should be prioritised and applied to the ICT sector too
  • Energy Efficiency First should be reflected in the criteria for energy generation activities

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