European Commission public consultation on EU energy efficiency directive (EED) – evaluation and review

Published initiative by European Commission. Further information: European Commission.

Finnish Industries supports energy efficiency as such, and the same time we recognize a principle weakness of the EU energy efficiency target: it is expressed as absolute primary and/or final energy consumption, which doesn’t measure energy efficiency or its improvement.

Confederation of Finnish Industries EK represents the entire private sector and has 24 member associations and 16,000 member companies. We speak for employers of all sizes, from public limited companies to SMEs. Our member companies create jobs and welfare in Finland, and are responsible for 70% of exports, 70% of R&D expenditure, 2/3 of the GDP created by companies and 2/3 of the private sector jobs.

Climate change is a huge global challenge on every level in societies. Confederation of Finnish Industries strongly supports the Paris agreement and 1.5-degree policies: EU2050 climate neutrality and EU2030 target of 50-55%. We are fully committed to the implementation of necessary measures to mitigate climate change. Enterprises are in the core of this long-lasting combat by innovating, investing and offering solutions globally.

We appreciate the possibility to deliver the views of Finnish Industries regarding the road map of EU’s Energy Efficiency Directive revision.

Energy efficiency has taken its important role on the climate agenda of the EU. The Energy Efficiency Directive (EED) has formed a major part of the implementation of the EU energy efficiency target 2020, and this continues during the next phase 2021 – 2030.

Finnish Industries supports energy efficiency as such, and the same time we recognize a principle weakness of the EU energy efficiency target: it is expressed as absolute primary and/or final energy consumption, which doesn’t measure energy efficiency or its improvement. Energy efficiency means the comparison of “energy input” to the “product output”. For industry, it is essential to allow economic growth with low carbon energy, which might mean growth of absolute energy consumption in these sectors. Therefore, energy consumption should not be capped by energy efficiency target.

We have severe concerns regarding the re-opening of all relevant EU2030 energy and climate legislation including the Energy Efficiency Directive. Member States have already created energy efficiency schemes to fulfill the requirements of mandatory savings under article 7, for instance. A full revision will slow down the proper implementation of the present legislation significantly. It would be better to focus on the smooth implementation of the regulation, and revise the EED only very minimum way.

Finally, Finland has a long history to use long-term voluntary agreements to improve energy efficiency in different sectors of society. In addition to this, these agreements have been used to fulfill requirements of the EU-legislation. The present Agreements 2017-2025 form a key element in implementing EED in Finland. It covers over 60 % of Finland’s total energy use. Voluntary energy efficiency agreements in Finland: https://energiatehokkuussopimukset2017-2025.fi/en/