Bioenergia ry – the Bioenergy Association of Finland – welcomes the initiative to evaluate the Energy Efficiency Directive for the next decade.
The EU has recently agreed a new binding climate target for 2040 in the EU Climate Law. In the coming months, several legislations will be introduced to implement this target. As a general principle for decarbonisation, the focus should be on decreasing fossil emissions in the EU. Additional renewable energy, improvements in energy efficiency, growing carbon capture and technical carbon sinks should all be considered key tools as the EU advances toward its 2040 climate target.
We note that based on the recent assessment from the EEA, the EU is likely not on track to meet the current 2030 targets on energy consumption. Despite this the EU is close to being on track to cut its greenhouse gas emissions by 55 % by 2030 (current estimate with additional measures is 54 %). Emissions have particularly decreased in the EU ETS sector.
The 2040 climate target will be further implemented with binding sub-targets for emission cuts backed by compliance systems in emissions trading and other sectors. In the current difficult competitive environment of the EU, the main principles in the design of these binding cuts should be technology-neutrality, cost-effectiveness and flexibility. Therefore, the Bioenergy Association of Finland believes that once Member States have achieved a minimum level of renewable energy deployment and energy efficiency (for example, the 2030 target), Member States and companies should have greater flexibility in choosing subsequent measures to reduce emissions and increase carbon sinks. Progress monitoring should increasingly focus on greenhouse gas emissions and removals in the agreed sectors – not on secondary indicators, such as the shares of different energy sources or the total amount of energy saved.
As the EU energy system becomes more dependent on variable renewable generation, an overly static and consumption‑centric approach to energy efficiency risks becoming counterproductive. Energy efficiency policies should better reflect the system value of flexibility, where demand is aligned with periods of abundant clean energy and reduced during times of scarcity, rather than prioritising energy savings as an isolated objective.
EED Article 26(4) on efficient district heating and Annex III on high‑efficiency cogeneration allows the use of natural gas as a secondary or support fuel alongside biomass. The Bioenergy Association of Finland does not consider it fair and justified that one fossil fuel – natural gas, which is up to 90 % imported in Europe – receives a preferential treatment at the same time as the Renewable Energy Directive contains stringent and cumbersome requirements for the use of all domestic and renewable biomasses. Also, a significant number of boilers taken into use in Finland are designed to allow the use of RDF (waste) as a secondary fuel, since some waste always remains after recycling. Flexibility to utilize RDF would support energy security of supply in Finland.