For the past weeks, Solar Heat Europe (SHE) has submitted feedback to several public consultations by the European Commission. The details of the consultations, including their objectives, summary of responses, and links to the full documents, are detailed below:

• Delegated regulation on renewable energy directive: Method for calculating the quantity of renewables used for cooling and district cooling.

Objective: The Renewable Energy Directive (RED) promotes greater use of renewable energy in all sectors. This delegated regulation aims to establish a methodology to calculate the quantity of renewables that EU countries are using for cooling and district cooling and the nature of the document is more technical than political

Summary of Response: The legal act must ensure a level-playing field among RES providers, to this end, local renewable energy input should be incentivized, double counting should be avoided, and the contributions of different solutions must be calculated fairly (e.g. full-load hours reflect the average use in some systems).

Links:

Link to Regulation: Here

Link to Response: Here

 

• Energy Efficiency: Labelling and ecodesign requirements for space and combination heaters, and water heaters and tanks.

Objective: Energy labelling informs consumers of the energy performance and other environmental parameters, while also creating ecodesign measures setting minimum energy efficiency requirements. The Commission will review these labelling and ecodesign requirements considering market developments, labelling rescaling, and the EU Green Deal.

Summary of Responses: SHE welcomes that solar thermal was included, encouraging additionally the inclusion of thermosiphon systems as a package. We also see the necessity to have package labels for installers and to adapt the label design to current requirements (e.g. climate dependent labels, retrofitting label…)

Links:

Link to Response: Here

 

• EU Social Climate Fund.

Objective: This new Social Climate Fund will help EU citizens meet the social and economic costs of the climate transition. The fund should address the social impacts from the new ETS for transport and buildings, it will (1) finance temporary direct income for vulnerable households and (2) support measures to reduce emissions from the building sector (energy efficiency, decarbonization of H&C, integration of RES…). The size of the fund will correspond to 25% of revenues from the new and parallel ETS, or approx. €72bn from 2025 till 2032.

Summary of Response: SHE asks to consider alternatives to the ETS for buildings, such as a fund based on carbon taxes for buildings. We encourage the Commission to consider a decentralized approach that includes local authorities, especially for H&C, and ask them to align it with a fast deployment of energy efficiency and renewable heat.

Links:

Link to Regulation: Here

Link to Response: Here

 

• Energy Taxation Directive:

Objective: The Energy Taxation Directive is revised to deliver on the EU’s increased climate ambition, it will align energy taxation with the 2030 and 2050 targets, as well as revise the scope and exemptions of the tax rates structure.

Summary of Response: The revision must ensure a level-playing field among renewable energy vectors, promote transparency among the taxation of energy sources, and encourage a fair approach to energy generation supply and equipment.

Links:

Link to Directive: Here

Link to Response: Here

 

• Energy Efficiency Directive:

Objective: The EED will be revised to achieve a more ambitious reduction of GHG emissions by 2030, as well as to contribute to the objectives of the EU Green Deal.

Summary of Response: SHE asks for the inclusion of ambitious national binding targets in combination with energy efficiency and decentralized renewable solutions such as solar thermal. We also welcome the focus on energy poverty and ask for planned replacements, as well as the improvement of the Primary Energy Factor (PEF).

Links:

Link to Directive: Here

Link to Response: Here