Cross-Industry Joint Statement: A European Agenda For Evidence-Based and Better Policy-Making

In April 2021, the European Commission published its new Better Regulation Communication1 aimed at improving EU policy-making. The undersigned European trade associations strongly welcome the principles and the objectives of the Communication. Nonetheless, we would like to herewith share recommendations to further improve the European policy-making process in the context of the busy policy agenda and ahead of crucial upcoming policy initiatives.


To this purpose, we call for:


● EU Legislation to be developed fully on the basis of and supported by evidence and thorough impact assessments;


● Sufficient time and resources to be allocated at all phases of the decision-making process, so as to ensure sound policy decisions;


● Consultations to be conducted via thorough process, involving expert input from all relevant stakeholders, and allow for sufficient time to provide feedback;


● Key regulatory provisions such as definitions and scope to be agreed upon and clearly defined at a primary legislative stage, rather than through implementing acts or guidance documents, to prevent the adoption of diverging and disproportionate national measures and EU market fragmentation;

● The impact on innovation to be considered in all legislative initiatives to ensure
future-proof policy-making;


● EU legislation to be implemented and enforced in a harmonised way
safeguarding the Single Market. If applicable, legal requirements that need
specific verification procedures by authorities must be verifiable through
established methods, including the timely listing in the OJ of references to the
harmonised standards.

An evidence-based approach for all initiatives:
Legislation needs to be developed on the basis of and supported by evidence. The complexity of many sensitive and highly political topics, particularly regarding the EU Green Deal, requires high quality data, and evidence-based impact assessments. To this end, legislative proposals should be published following a thorough impact assessment that clearly outlines the implications of all the policy options proposed.


Stakeholders’ responses to consultations as well as findings of impact assessments should be made available and published ahead of, and not together with, the respective legislative proposal. This will help improve transparency and accountability, and support a constructive exchange of views among stakeholders.

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Joint Industry Statement – Healthy Buildings for All

Put people’s health and well-being at the center of EU built environment

The informal Indoor Environmental Quality (IEQ) Gathering brings together European industry associations, which represent companies involved in technical building systems and their maintenance. Our objective is to collectively promote healthy buildings through an adequate level of indoor environmental quality.


Healthy Buildings are buildings in which the indoor environment is healthy for people to live in and carry out their activities. An appropriate indoor air quality, a lighting design adapted to the needs of the occupants, sufficient access to daylight and views and an adequate mechanical or hybrid (natural ventilation assisted mechanically) ventilation are important for creating a healthy indoor environment. Thermal comfort, moisture, dust and pests, water quality, noise, as well as safety and security are aspects that must also be considered in the context of any healthy building.


The World Health Organisation (WHO) estimates that people spend approximately 90% of their time indoors in residential and non-residential buildings and that 26 million European children are living in unhealthy homes1. Moreover, Copenhagen Economics evaluated the health co-benefit of energy efficient renovations in the EU to amount to 42 billion euros annually in a low energy efficiency scenario and as much as 88 billion euros in the case of a high energy efficiency one. It is also to be noted that, due to a poor indoor air quality alone, 120 000 Europeans die prematurely every year incurring an annual cost of 260 billion Euro.


With 97%4 of EU buildings in need of renovation, the EU Renovation Wave Initiative and the upcoming targeted revision of the Energy Performance of Buildings Directive (EPBD) represent a true opportunity to boost both energy efficiency and indoor environmental quality that cannot be missed: by making the most of an appropriate indoor air quality, human-centric lighting, acoustic, thermal comfort and control and automation systems, the health and well-being of the occupants will be improved and productivity gains delivered.

Read More: Joint Industry Statement – Healthy Buildings for All. Put people’s health and well-being at the center of EU built environment

Joint Position on the combination of Energy labels for local space heaters (ENER Lot 20) and air-to-air heat pumps (ENER Lot 10)

The undersigned associations welcome the 16 June 2021 publication of the European Commission’s report of the study on consumer understanding of the energy label for space heaters and air conditioners. The report provides further clarity on consumer interpretation of energy labelling classes without further context.


However, based on this report, the Commission is evaluating the possibility of merging the energy labels for ≤ 50 kW local space heaters (ENER Lot 20) and ≤ 12 kW air-to-air heat pumps (ENER Lot 10), as it could remove consumer confusion about which product type is more energy consuming on the basis of the energy labelling classes alone: merging the energy labels has, according to supporters of the merger, the potential of directly influencing end-user choices towards more energy efficient heating technologies.


The undersigned associations strongly disagree with the introduction of an integrated energy label for heating technologies, as a merger of the energy labelling classes for both product categories will not help meet the energy labelling’s objectives. This paper explains that 1) local space heaters and air-to-air heat pumps are not comparable, 2) merging different energy labels will not help improving the effectiveness of the energy label, and that 3) the consumer study itself does not univocally support the merger of the energy labelling scales.

Joint Position on the combination of Energy labels for local space heaters (ENER Lot 20) and air-to-air heat pumps (ENER Lot 10)

Cross-Industry Joint Statement: A European Agenda For Evidence-Based and Better Policy-Making

In April 2021, the European Commission published its new Better Regulation Communication1 aimed at improving EU policy-making. The undersigned European trade associations strongly welcome the principles and the objectives of the Communication. Nonetheless, we would like to herewith share recommendations to further improve the European policy-making process in the context of the busy policy agenda and ahead of crucial upcoming policy initiatives.

To this purpose, we call for:


● EU Legislation to be developed fully on the basis of and supported by evidence and thorough impact assessments;


● Sufficient time and resources to be allocated at all phases of the decision-making process, so as to ensure sound policy decisions;


● Consultations to be conducted via thorough process, involving expert input from all relevant stakeholders, and allow for sufficient time to provide feedback;


● Key regulatory provisions such as definitions and scope to be agreed upon and clearly defined at a primary legislative stage, rather than through implementing acts or guidance documents, to prevent the adoption of diverging and disproportionate national measures and EU market fragmentation;

● The impact on innovation to be considered in all legislative initiatives to ensure future-proof policy-making;


● EU legislation to be implemented and enforced in a harmonised way safeguarding the Single Market. If applicable, legal requirements that need specific verification procedures by authorities must be verifiable through established methods, including the timely listing in the OJ of references to the harmonised standards.

Cross-Industry Joint Statement: A European Agenda For Evidence-Based and Better Policy-Making

Industry association position on PEF revision

Get the Primary Energy Factor (PEF) for electricity right – at 2.0 and with a regular review

In view of the trialogue discussions on the review of the PEF, EUHA co-signed a letter with other industry partners on the importance of getting the Primary Energy Factor (PEF) in the energy efficiency directive right. We advocate for:

  • Deciding on  a PEF of 2.0 for 2020 (when the directive will be implemented nationally), as supported by the Fraunhofer Institutes et.al.’s scientific methodology, prepared for the Commission: a higher PEF incentivises electricity savings over direct fossil savings, acting as a barrier for the decarbonisation of the heating sector.
  • Setting a regular review of the PEF in order to reflect changes in the reality of the energy mix: by 2030 the EU RES share in power generation is projected to be at least 49%. The accelerated greening of the electricity mix justifies a frequent review of the value based on the aforementioned methodology.

2018 Industry association position on PEF revision February 2018_FINAL

EUHA – Presentation of the Alliance

The Electric Underfloor Heating Alliance – EUHA – unites manufacturers to promote the interests of the product sector within a new electrified smart grid infrastructure. The group promotes the adoption of higher efficiency electric underfloor heating systems, providing primary but mainly secondary comfort heating in low energy demand buildings.

Decarbonized electricity from renewables in the heating and cooling sector remains one the best options for the European Union to meet the 2050 goals for reduction of carbon emissions.

This document will provide you with a general presentation of EUHA, and presents Electric underfloor heating solutions to European regulations.

  • Smart and efficient buildings in Europe
  • The Future is green and clean
  • Energy efficiency First
  • More than heating, comfort for consumers

Please find the document here.

Joint Position Paper on the Review of the PEF

The signing organizations of this joint statement support the European Commission’s initiative to review the PEF value based on a standardized calculation method.

In this context, we suggest to the Commission to consider the importance of the guiding function of the PEF in decarbonizing the energy system. A lower primary energy factor will accelerate the efficient electrification of the heating and cooling sector and enable a deeper integration of the electricity and heating and cooling markets. While it supports the EU climate and energy targets, it will also:

  • provide a more rapid decarbonisation of the heating & cooling sector and avoid lock-in of fossil fuel investments for decades;
  • facilitate deeper integration of electrical renewables through more flexible heat demand;
  • improve EU security of supply through replacing fossil imports with indigenous renewables;
  • empower consumers, to become active participants in the electricity markets, giving them the ability to reduce or shift electricity loads.

Key considerations to be taken into account by the European Commission:

  1. Review PEF on a regular basis and provide flexibility to Member States.
  2. The PEF revision needs to support the 2050 decarbonization targets set by the
    European Commission and recognize the rapidly increasing share of renewable energy in the power system.
  3. The calculation value of the PEF should include the non-RES primary energy approach.
  4. The current difference between the PEF for fossil fuels of 1.1 and for non-combustible renewables of 1 is inconsistent with the decarbonization strategy.
  5. The PEF revision should focus on consumers as in the Energy Union Strategy.
  6. Rapid revision of PEF values in eco-design and labelling product regulation.

The signing organizations

  • AIE European Association of Electrical Contracting Companies
  • ECI European Copper Institute
  • EHPA European Heat Pump Association
  • EUEW European Union of Electrical Wholesalers
  • EUHA Electric Underfloor Heating Alliance
  • EURELECTRIC Association of the electricity industry in Europe
  • NHO Confederation of Norwegian Enterprise
  • SOLARPOWER Solar Power Europe

To read more about this, click here

EUHA – Review Of The Energy Efficiency Directive (EDD

Letter from stakeholders concerned with PEF review in the EED revision

The EU needs a primary energy factor that supports the objectives of the Energy Union

We are a group of companies and associations that are committed to EUs goal of decarbonising the European energy system, while increasing energy security; and see increased integration between sectors (heating, cooling, transport and electricity) as a cost-efficient tool to achieve this. We are in this context concerned that the European Commission’s (EC) review of the primary energy factor1 (PEF) for electricity constitutes a barrier to these objectives.

To not be a barrier to decarbonisation, the outdated PEF must be updated wherever it is currently used (for example: Ecodesign and Energy labelling legislation use a PEF of 2.5, which reflects the power system of the nineties). In order to reflect the changes in the power mix, the PEF should therefore be reviewed on a regular basis.

To read more about this please click here.