The German association of industrial energy consumers (VIK e.V.) welcomes an opportunity to provide feedback on the Proposal for a Directive of the European Parliament and the Council on energy efficiency (COM(2021) 558 final).
An introduction of the new energy efficiency measures in the industrial sector should primarily take into account the fuel switch needed for climate-friendly production in the future, especially a broad industrial use of renewable energies, which is limited due to the current availability, installed capacity of renewables as well as the associated costs. In our view, the proposed version of the Directive should consider the following points: the absolute targets for final and primary energy consumption should remain non-binding; an obligation for the application of “Energy Efficiency First Principle” should be allowed voluntarily to balance with other environmental targets; national energy savings obligations should focus on economic sectors with high untapped potential (buildings, transportation); obligatory introduction of Energy Efficiency Obligation Schemes should be avoided, as the flexible design of policy instruments is a better option for the achievement of cumulative end-use energy saving targets.
An application of energy audits and energy management systems should be allowed on a voluntary basis and not be connected to the energy consumption level and type of the enterprises. Finally, it is important to ensure a reliable legal framework for high-efficiency cogeneration and seasonal manufacturing. Clear definitions for calculation of energy savings and accounting methodologies for renewable electricity, hydrogen and synfuels should also be provided.