We believe that this recast is a crucial opportunity to ensure a concrete implementation of the Energy Efficiency First principle (EE1st), already better recognised by co-legislators in the current discussions on the Fit for 55 Package. This principle must now materialise in the revised directives through concrete measures, and this especially in the EED recast. Thus, looking at the current trilogue discussions, we want to highlight three key elements to keep in mind when revising the EED:

  1. Primary energy consumption is key to consider energy efficiency across the whole value chain (Article 4)
  2. Energy savings achieved through ETS measures must be counted towards the EED Article 8 targets
  3. Energy management solutions are essential to support the energy transition
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