In the last several months, Solar Heat Europe, together with a coalition of associations representing the renewable and efficient technologies in the heating sector, carried out several actions on the issue of the Primary Energy Factor for electricity, a value that has close links with the broader issue of the electrification of heating, as well as the comparative advantage of electric appliances in eco-design and energy labelling policies.

In the currently negotiated Energy Efficiency Directive (EED), the EU PEF provides Member States with a default value to convert final energy savings into primary energy savings. The 2.0 value proposed in the EED review is based on several assumptions that artificially lower the EU PEF compared to the real efficiency of EU electricity grids. The European Commission has recently indicated its intention to use the PEF value to be adopted in the EED in other energy efficiency-related legislation, thus carrying the danger of an automatic application in eco-design review of the Lots 1&2.

The coalition of associations therefore asked that the EED EU PEF value should not be automatically copied in sectoral legislation for heating and cooling without thorough impact assessment taking into account the seasonality of heat demand, and that the EU PEF value applied in the EED should not be set below 2.3. It elaborated and disseminated a methodological paper defending the 2.3 value, and addressed an open letter to the EU policy-makers, both from the European Commission, the Parliament and the Council.

Unfortunately, after initial successes with the Parliament (who tabled a proposal for 2.3), and with the Bulgarian Presidency of the Council, ready to support our views, the negotiators seem to fall back to the Commission proposal of 2.0, after high-level pressure from the Commission itself.