The Energy Efficiency Directive 2012/27/EU (EED) establishes binding measures and targets in order to increase energy efficiency across the EU. Its review under the Green Deal, proposed in June 2020, aims to increase the target (currently 32.5%) to align with the EU’s new economy-wide 2030 emissions reduction target of 55%. The reform will review mandatory national level mechanisms, such as the energy savings obligation, and update measures to tackle energy efficiency in road transportation. It will also update provisions for heating and cooling relating to private and public housing and renovation.
After intense negative engagement on the EED from the heavy industry sectors, the final policy, adopted in September 2023, implemented weaker energy efficiency targets and a less ambitious Energy Savings Obligation reform.
Energy and Resource Efficiency
Inactive: completed. The file was approved in July 2023 and entered into force in September 2023.
Energy and Resource Efficiency
Inactive: completed. The file was approved in July 2023 and entered into force in September 2023.
On 2nd November, the German chemicals association Verband der Chemischen Industrie (VCI) published an evaluation of the EU Green Deal. In the text the association generally supported the EU’s 2050 target, but expressed major concerns about different elements of the EU ETS reform, the Carbon Border Adjustment Mechanism, Energy Efficiency Directive and Renewable Energy Directive.
In an open letter to the President of the EU Council on 18th October, Corporate Leaders Group Europe and SolarPower Europe advocated for more ambitious, binding targets in the EU Energy Efficiency Directive and the EU Renewable Energy Directive.
De Trouw reported on the 13th October that The Confederation of Netherlands Industry and Employers (VNO-NCW) supported exemptions for heavy industry from the EU energy efficiency legislative tool, the Energy Savings Obligation, in the Netherlands for the past 20 years, justifying the exemption by stating that industry is already regulated under the EU Emissions Trading System. De Trouw reported on the 17th October that VNO-NCW did not support the planned phase out of Dutch overseas fossil fuel financing by 2023, advocating that this should continue until 2030 since fossil gas is a transition fuel, and that Dutch companies developing fossil fuels in developing countries will be replaced by Russia and China.
In a 26th September blog post on its corporate website, Fortum advocated for the REPowerEU proposal to support a technology neutral approach and provide less of a focus on renewable energy. The post did not support strengthening European energy efficiency policy and reducing energy demand, stating it would overlap with other climate objectives and the EU Emissions Trading Scheme. It also did not support stringent criteria for renewable hydrogen production, including the additionality principle, in the EU Renewable Energy Directive reform.
The Federation of German Industries (BDI) published a position paper on the EU’s Fit for 55 package on 20th September, in which the association laid out its opposition to the 2035 zero emissions vehicle standard proposed by the EU Commission. In addition, the association supported quotas for low-CO2 and climate neutral aviation fuels as part of ReFuelEU Aviation, while emphasizing the risk of carbon leakage and the need for flexibility to compensate for additional costs, and called for "ambitious but realistic" quotas for biofuels in the Renewable Energy Directive (RED).
In the same position paper, BDI advocated for a Carbon Border Adjustment Mechanism (CBAM) test phase which only includes industries that support it, and the maintenance of free emissions allowances in the EU Emissions Trading System (ETS). Furthermore, the entity supported the extension of the EU ETS for road transport and buildings, but not for aviation, and it did not support “inappropriate” Minimum-Energy-Performance-Standards (MEPS) in the Energy Performance Buildings Directive (EPBD), as well as not supporting an energy consumption cap in the Energy Efficiency Directive (EED).
The German chemical association VCI published a new position paper on EU climate laws on 12th July, criticizing the EU Emissions Trading System (EU ETS) reforms and the planned phase out of free allocation of certificates, as well as not supporting absolute energy savings targets as part of the EU Energy Efficiency Directive. Meanwhile, on 25th July, VCI emphasized in a tweet the importance of Germany becoming independent of Russian gas, supporting the role of LNG terminals and coal as means to do so.
In a 22nd June joint letter to the EU Council, industry associations including Eurogas and Gas Distributors for Sustainability (GD4S) called for the EU Energy Efficiency Directive revision to extend the energy savings obligation to include renewable and decarbonized gases in the residential heating sector.
In a position paper published on 19th May, Eurofer advocated to weaken the reform of the Renewable Energy Directive (RED) by supporting the inclusion of recycled carbon fuels and advocating for more flexible additionality criteria. The association also did not support proposed GHG emission standards for cogeneration in the Energy Efficiency Directive reform.
On 11th May, ahead of the REPowerEU plan, Corporate Leaders Group (CLG) Europe published a joint letter that advocated for increased ambition on the Renewable Energy Directive, and advocated for increased ambition and action on the Energy Efficiency Directive and Energy Performance of Building Directives.
In a 12th May statement, the European Round Table for Industry (ERT) communicated high-level support for the EU's Renewable Energy Directive and other renewable energy incentives, including power purchase agreements. In the same statement, ERT supported an acceleration of energy efficiency initiatives, and for a number of measures to strengthen the proposed Energy Efficiency Directive.
In a letter to the Chair of the EU Environment Council on 16th March, BusinessEurope opposed energy efficiency legislation (e.g. Energy Efficiency Directive), arguing against “formulating energy efficiency goals in terms of absolute reduction of energy consumption”, and suggesting that they should focus on optimizing energy intensity.
In a joint statement, published on 2nd March, energy-intensive associations including Eurofer, the International Federation of Industrial Energy Consumers and the Confederation of European Paper Industries advocated for less stringent measures for high-efficiency cogeneration (combined heat and power, CHP) in reforms to EU climate policy. The statement advocated against strong criteria for high-efficiency CHP in the Energy Efficiency Directive and was supportive of exemptions for high-efficiency CHP in the Energy Taxation Directive.
In feedback to the EU Commission in November 2021, the Federation of German Industry appeared to not support the EU Energy Efficiency Directive, advocating for a review of the definition of "energy efficiency", stating that a cap on energy consumption is limiting industrial decarbonization, and describing new energy savings target of 1.5% as "unrealistic."
BusinessEurope released a position paper on the Fit for 55 package, which supported the revision of the Renewable Energy Directive with major exceptions regarding the implementation of binding targets and the inclusion of bioenergy. It did not support several reforms to the Energy Efficiency Directive as it was unsupportive of the increase in energy savings obligations and excluding the direct use of fossil fuels to achieve energy savings.
In a position paper on the EU’s Renewable Energy Directive (RED), the International Federation of Industrial Energy Consumers (IFIEC)advocated that the policy should be based on technology neutrality and supported including recycled carbon fuels in RED. The position paper also supported the revision of the Energy Efficiency Directive with major exceptions as it stressed that low-carbon technologies use more energy than fossil fuels.
Cefic released a position paper detailing its position on the EU Commission’s proposed reform to the Energy Efficiency Directive, which supported the revision but with major exceptions. The association supported increased flexibilities for Member States to meet energy efficiency contributions, and opposed the exclusion of energy savings which could be achieved from the efficient use of fossil gas in contributing to Member States' energy savings obligations. Despite this, the group set out its support for energy efficiency legislation for buildings.
EnBW released a COP26 page on its corporate website discussing several elements of EU climate policy. The company stated support for the reforms made to the EU ETS, in particular suggesting waiting till after 2030 to integrate emissions trading systems for the buildings and road transport sectors.
However, the company appeared to advocate against increased ambition in the EU’s Energy Efficiency Directive, highlighting issues with the inclusion of new CHP high-efficiency criteria. Similarly, it supported a weakening of the EU’s Renewable Energy Directive, by suggesting the criteria for renewable hydrogen and bioenergy were too strong.
Finally, EnBW advocated for a greater role for fossil gas in EU policy. The company called for the weakening of the EU's taxonomy, particularly by including fossil gas for heating/cooling generation as a transitional activity. EnBW also suggested that the EU's Hydrogen and Gas Decarbonization Package applies too much pressure to transition away from fossil gas.
In a press release this week, the Director General of the VCI Wolfgang Große Entrup stated opposition to the EU’s Energy Efficiency Target, asserting that fossil free technologies use more energy than fossil fuels.
The table below lists the entities found to be most engaged with the policy. The entities are ranked by performance band. InfluenceMap tracks over 500 companies and 250 industry associations globally. Each entity name links to its full InfluenceMap profile, where the evidence of its engagement can be found.
| Influencemap Performance Band | Organization | Policy Position | Policy Engagement Intensity |
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