EuroWindoor is glad to provide input to the public consultation on the Climate, Energy and Environmental Aid Guidelines 2022 and supports the new guiding Efficiency First principle of buildings. One of the most important part for EuroWindoor is chapter 4.2 “Aid for the improvement of the energy and environmental performance of buildings”.
As much as EuroWindoor welcomes the improvement of buildings in the focus, it is questionable that national or regional subsidies to improve the energy efficiency of buildings do affect international trade and thus competition in the European internal market. EuroWindoor asks for clarification and recommends – if it does not affect trade and competition – adding guidelines for the promotion of energy efficiency for the building sector to the Energy Performance Building Directive (EPBD) instead.
In case that subsidies for energy efficiency of buildings are considered as aid EuroWindoor proposes some modifications. Following the principle “efficiency first” the technical equipment should always be renewed after or in combination with a renovation of the building envelope. Otherwise, the technical equipment could be using too much energy for a building that needs less energy after a renovation of the building envelope.
Furthermore, it is requested to include aid for step-by-step renovations, increasing the threshold of at least 20% reduction in the primary energy demand compared to national NZEB for new buildings and to delete or specify the requirements to be allegeable for maximum aid in regards to the economic viability.
[Here you will find all position papers / publications]