Gas package: energy system efficiency, rather than a fuel switch
In December 2021, the European Commission issued two proposals, the Gas Directive 2009/73/EC and the Gas Regulation (EC) No 715/2009, laying down the foundation for a European low-carbon gas industry, the so-called “Gas Package”. The Commission’s approach should depart from this old paradigm and uphold the commitment to the Energy Efficiency First Principle (EE1st) to avoid possible stranded assets.
Although urgent action is needed, the proposal focuses exclusively on source diversification. It misses the opportunity to implement the Energy Efficiency First (EE1) principle at the system level and fails to consider the broad socio-economic benefits of energy efficiency and system efficiency.
In current times energy efficiency should be more of a priority than ever, which is being increasingly reflected in the EU’s response to rid Europe of Russian gas imports. The old paradigm needs to be updated accordingly.
The paper highlights gaps and suggests improvements pertaining the following axes:
1. Need for speed
2. Hydrogen for harder-to-abate sectors
3. Benefits of energy efficiency
4. Gas Package and Fit for 55
5. Infrastructure and governance: prioritize climate
6. Conclusion: go beyond 1-1 fuel switch and think energy efficient
In a fast-changing political and economic environment, 2025 was a year of continued efforts to strengthen security, stability, and competitiveness for European businesses.
Throughout the year, our work demonstrated that energy efficiency is not only essential to achieving climate goals, but also a key driver of innovation, energy independence and sustainable long-term growth across Europe.
Strong engagement with policymakers, combined with the successful organisation of the 4th European Energy Efficiency Day, highlighted the importance of collaboration and dialogue in advancing shared objectives. Partnerships across sectors and institutions remained central to delivering impact and shaping effective energy policies.
Looking ahead to 2026, we will intensify our efforts to secure the regulatory certainty that can accelerate the energy transition, while providing businesses with the investment confidence they need and strengthening Europe’s competitiveness.
Read the full Activity Report here.
