EK’s views on the revision of the Energy Efficiency Directive EED
We appreciate the possibility to deliver the views of Finnish Industries regarding the revision of the Energy Efficiency Directive (EED).
EK supports a climate target of at least 55% for 2030 and a climate neutrality target for 2050 in the EU. EK sees it is fully possible to achieve a very ambitious EU target of at least 55% by 2030 and at the same time preserve or even improve the competitiveness of European industry.
Energy efficiency has taken its important role on the climate agenda of the EU. The EED has formed a major part of the implementation of the EU energy efficiency target 2020, and this continues during the present phase 2021 – 2030. Improving energy efficiency is on every companies’ agenda, and the same time EK recognizes a principal weakness of the EU energy efficiency target. It is expressed as absolute primary and/or final energy consumption, which does not 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.
If the target setting stays as it is, EK prefers only minimum changes to the EED. A full revision will slow down the smooth implementation of the present legislation significantly. For instance, obligation schemes or other measures have already started in Member States, and revision only creates uncertainty among those who are obligated by article 7.
Energy efficiency is difficult to measure, and improving it means many various and continuous actions like operational and behavioural changes and investments with short and long pay-back times. In many cases it is not possible to monitor exact energy consumption and product output figures before and after the change. Therefore, more stringent monitoring and verification systems will not bring more energy efficiency but will put the resources in the wrong place. EK wish all efforts will be put on energy efficiency actions, and less on bureaucracy.
Mandatory energy audits for large companies (article 8) have worked well after the implementation phase, but EU-wide harmonization is needed concerning determination of ”a large company”. There are now various approaches in use in the Member States. The decision-making of energy efficiency investment mentioned in the audit report needs to be left to companies. Then they can realize energy efficiency investment according to rational schedule and order.
There has been good market-based development concerning use of secondary heat in the heating solution of buildings, for instance. Flexibility is needed also in article 14. An economically and technologically viable business case to use secondary heat need to be found for both parties (producer/user).
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 fulfil requirements of the EU legislation. The present Agreements 2017-2025 form a key element in implementing the EED in Finland. It covers over 60 % of Finland’s total energy use. More information on Voluntary energy efficiency agreements in Finland: