ClientEarth’s comments on the Energy Efficiency Directive proposal

ClientEarth argues that the recast Energy Efficiency Directive (EED) must remove support for fossil-fuel technologies, including natural gas and high-efficiency cogeneration, to avoid carbon lock-in. The organization recommends raising the 2030 EU energy efficiency target to at least 45% and making national contributions legally binding. It further advocates for the 'Energy Efficiency First' (EE1st) principle to be extended to all planning and investment decisions, not just 'major' ones, and calls for a more robust role for energy communities in achieving energy savings.

• The recast EED should eliminate all provisions that support fossil-fuel technologies, specifically high-efficiency cogeneration and district heating and cooling systems using natural gas, to prevent a 'lock-in effect' that hinders the transition to clean alternatives.
• ClientEarth challenges the efficiency claims of cogeneration, noting that some German plants are only about 12% more efficient than separate energy generation, and argues that the EED's current calculation methods for efficiency are 'technically obsolete'.
• The 'Energy Efficiency First' (EE1st) principle should be expanded to cover all planning, policy, and investment decisions, removing the current restriction to 'major investment decision' which creates legal uncertainty due to the lack of a legal definition for 'major'.
• The proposed 2030 EU energy efficiency targets (36% for final energy and 39% for primary energy) are insufficient; ClientEarth recommends raising the target to at least 45% compared to the 2007 EU Reference Scenario.
• National energy efficiency contributions should be made mandatory and enforceable, including binding milestones and a stronger governance system, as the EU already failed to meet its 2020 energy efficiency target.
• Energy communities should be formally integrated into the EED's energy saving obligations, allowing their achievements to count toward cumulative end-use energy savings and recognizing their role beyond just fighting energy poverty.

APA

ClientEarth (2021). ClientEarth’s comments on the Energy Efficiency Directive proposal. https://www.clientearth.org/media/wjafrqfx/clientearth-comments-on-the-energy-efficiency-directive-proposal_2021.pdf

Chicago

ClientEarth. ClientEarth’s comments on the Energy Efficiency Directive proposal. 2021. https://www.clientearth.org/media/wjafrqfx/clientearth-comments-on-the-energy-efficiency-directive-proposal_2021.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth’s comments on the Energy Efficiency Directive proposal |date=November 2021 |url=https://www.clientearth.org/media/wjafrqfx/clientearth-comments-on-the-energy-efficiency-directive-proposal_2021.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021clientearths, author = {{ClientEarth}}, title = {{ClientEarth’s comments on the Energy Efficiency Directive proposal}}, publisher = {ClientEarth}, year = {2021}, month = nov, url = {https://www.clientearth.org/media/wjafrqfx/clientearth-comments-on-the-energy-efficiency-directive-proposal_2021.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }