State Aid: Response to the public consultation on the CEEAG revision

The European Green Deal target to reach climate neutrality by 2050 calls for unprecedented levels of public and private investments accompanied by deep reforms. In this context, well-designed State Aid schemes will be key to unlock investments and make the best use of public funds.

As part of the ongoing revision of the Climate, Energy and Environmental Aid Guidelines (CEEAG) and the General Block Exemption Regulation (GBER), the Commission pledged to set simpler, clearer, and easier-to-apply State Aid rules for Buildings renovation programmes, in particular in the residential and social sectors. Additionally, aid to energy efficiency investments was to be simplified and enhanced, as announced in the Sustainable Europe Investment Plan and in the European Green Deal Investment Plan.

The European Alliance to Save Energy is happy to provide its feedback on the revised CEEAG. Energy efficiency is the bedrock of a decarbonised EU energy system: energy efficiency gains are essential to achieve the increased GHG emission target reduction of 55% by 2030 and full decarbonisation by 2050. In its current form, the CEEAG insufficiently supports the uptake of energy efficient measures and exposes the EU to the risk of missing its GHG reduction target for 2030 and 2050.

EU-ASE calls on the European Commission to:

1.  Assess all measures against the Energy Efficiency First principle
2. Level the playing field in aid intensity for energy efficiency measures (CEEAG Annex 1 and Art 38 GBER)
3. Simplify the definition and methodology to determine cost eligibility (para. 125 and Art 38 GBER)
4. Provide clear guidance on current State Aid rules with a practical approach

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Read more in our paper: Boosting energy efficiency through the revision of State Aid rules

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Response to the Public Consultation on the EPBD revision

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s Public Consultation procedure regarding the revision of the Energy Performance of Buildings Directive (EPBD).

Our contribution touched upon planning and policy instruments, information provision and energy performance certificates, as well as enabling more accessible and affordable financing for building renovation.

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Response to the Roadmap on the EPBD revision

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s publication of an inception impact assessment on the revision of the Energy Performance of Buildings Directive (EPBD). The Alliance brings together businesses, think thanks and Members of the European Parliament to ensure that the voice of energy efficiency is heard across the business and political community.

The EU has committed to a net-zero economy by 2050, and to reach at least -55% GHG reductions by 2030. To get there, this decade must be witness of an unprecedented wave of renovations resulting in buildings emissions reduction by 60% by 2030. Reducing energy demand and increasing energy efficiency in the buildings sector is a prerequisite for achieving the EU ’s energy and climate objectives. Currently around 75% of the building stock is energy inefficient yet almost 85-95% of today`s buildings will still be in use in 2050 . Only 1% of European buildings undergo energy renovations each year and on average the energy saved through renovations is just 9% in homes and 16% in commercial and industrial buildings. The yearly deep energy efficiency renovation rate barely reaches 0,2% for both residential and non-residential buildings.

At this pace, cutting carbon emissions from the building sector to net-zero would require centuries. Last but not least, 75% of buildings energy consumption is still based on fossil fuels. The renovation rate is therefore far too low considering the environmental challenges and the economic opportunities that lie ahead. The Renovation Wave acknowledges this problem and the need to increase the rate and the depth of renovations setting the objective of at least doubling the annual energy renovation rate by 2030 in view of reducing GHG emissions of buildings by at least 60%. EU-ASE believes that the review of the EPBD is a unique opportunity to increase energy savings, optimise energy consumption and reduce GHG emissions from the buildings sector. In this respect, the ongoing revision of the EPBD is key to introduce new policy signals to stimulate a minimum of a 3% renovation rate per year combined with an average energy efficiency improvement of 75% across Europe. This will help the EU to reach its environmental goals while contributing to fast economic recovery, local job creation and delivering of multiple benefits to citizens .

Other measures designed for the decarbonization of the building stock, such as carbon pricing, can be part of this effort, yet we believe it should not replace impactful regulatory measures such as the EPBD which drives energy savings necessary to meet climate neutrality. In our view, policies related to the building sector, including the EPBD, should be kept in the Effort Sharing Regulation sectoral scope with increased ambition.

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Response to the Public Consultation on the revision of the Energy Efficiency Directive

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s Public Consultation procedure regarding the revision of the Energy Efficiency Directive (EED).

We addressed the part assessing the implementation and the effectiveness of the EED and the part assessing possible options for revising the EED in view of contributing to the 55% climate target for 2030 and addressing the ambition gap in the final NECPs. We also provided our views on technical questions for specific Articles of the EED.

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Response to the Roadmap on the revision of the Energy Efficiency Directive

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s publication of an inception impact assessment on the revision of the Energy Efficiency Directive (EED). The Alliance brings together businesses, think thanks and Members of the European Parliament to ensure that the voice of energy efficiency is heard across the business and political community.

The EU-ASE welcomes the strong narrative on energy efficiency in the roadmap as well as its proposal to revise the current EED. The Directive has played a significant role in bringing energy efficiency up in the political agenda, stimulated increased national efforts, and resulted in some energy efficiency improvements. However, it did not lead to the creation of the much needed binding and long term legal framework to mobilize the investments required to tap the savings potentials across sectors and deliver the multiple benefits of energy efficiency to citizens, businesses and the environment. This shortcoming also stems from the imperfect implementation of the Directive. As a consequence, in many countries, the energy savings delivered fell short of the minimum required and are insufficient to achieve the national targets. We note that the Commission is rightly stepping up enforcement and we fully support strengthening the legal requirements for more effective implementation.

The current review should ramp up the ambition in light of the EU’s new climate objectives. The EED targets must be aligned with the European Green Deal and its goal to achieve climate neutrality by 2050 at the latest, as well as intermediary targets. According to the International Energy Agency (IEA), 76% of the European greenhouse gas emission reductions required to keep temperature increases below 1.5°C must come from energy efficiency. Therefore, the overall energy consumption reduction is the foundation for achieving climate targets while ensuring a deep economic transformation that is supporting a circular, resilient and equitable post-COVID recovery.

For policy-makers, investing in energy efficiency means investing in a fast, smart and sustainable recovery which is ‘made in Europe’. The International Patent Classification green patents inventory of the World Intellectual Property Organization shows that among the countries with a higher concentration of filings for patents in energy conservation technologies, there are the EU Member States such as Germany, France, and the Netherlands. Investing in energy efficiency means supporting the growth, competitiveness and long term sustainability of European manufacturers, solution providers and local value chains. The EED review is paramount in that respect and should be carried out in such a way to support job creation, sustainable growth and climate change mitigation and adaptation in one of the most innovative and strategic sectors of the European Union.

Based on this, EU-ASE would like to highlight the following recommendations to support the Commission in its ongoing work on the EED revision.

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