Feedback to the EPBD Recast Proposal

9 March 2022

EuroACE – Energy Efficient Buildings welcomed the proposed recast of the Energy Performance of Buildings Directive (EPBD). The EPBD must play a more central role in the Fit for 55 Package. In line with the need to strengthen its level of ambition, our main recommendations were:

Minimum Energy Performance Standards (MEPS): we welcome the establishment of MEPS. However, the targeted level of ambition needs to be strengthened, as this instrument should truly deliver against the objectives of the EU Renovation Wave Strategy. A more prominent role for good planning and holistic deep renovations (whether one-shot or staged) should be secured, and the deployment of Renovation Passports should be accelerated.
Zero-emissions buildings (ZEB): the concept is a step forward. When defining a ZEB, both primary and final energy consumption indicators should be used, the thresholds should be more ambitious, and a clearer differentiation between ZEB and NZEB standards is needed.
Provisions on new buildings: we welcome the requirement for new buildings to report on their Global Warming Potential, relying on the Level(s) framework and standard EN 15978 as a starting point for a common vision on whole-life carbon.
Multiple benefits: we welcome the new provisions to better factor in health, comfort and indoor air quality, and suggest going a step further by defining a “Healthy Indoor Climate”.
Energy Performance Certificates (EPCs): we welcome a common template for EPCs and greater convergence of the A to G scale. EPC coverage must improve, and EPCs should be better linked with Renovation Passports and the Smart Readiness Indicator via Digital Building Logbooks.
Technical Building Systems (TBS): the scope should be extended to electrical installations, and outdated and inefficient TBS should be replaced as part of holistic deep energy renovations.
Inspections: the inclusion of inspections of ventilation and air conditioning systems is welcome, with a three-year timeline to implement the recommendations from inspection reports.