On the 17th of November 2021, we submitted our feedback on revising the Energy Efficiency Directive (EED).

First, we welcome higher and more stringent ambitions on energy efficiency and that the revision provides a legal basis for applying the Energy efficiency first (EE1st) principle.

Second, we are satisfied with the new and strengthened instruments to decarbonise the heating and cooling system and improve the uptake of energy services, particularly energy performance contracts (EnPCs).

However, to fulfil the higher ambitions, we believe that we must:

  • Give a higher priority to energy efficiency measures as a prerequisite to fuel switching;
  • Better promote district solutions as critical tools for systemic energy efficiency gains at the local level;
  • Further improve the uptake of energy services by strengthening the requirements on the Member States to facilitate energy management solutions such as EnPCs.

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