The European Commission has proposed revisions to the EU Taxonomy Climate Delegated Act with the aim of simplifying technical screening criteria and improving the framework’s practical application. Energy Efficiency for Europe supports this effort, with the view that targeted adjustments can help ensure the Taxonomy continues to effectively support investment in energy efficiency and decarbonisation projects.

A particularly positive development is the proposed revision of Activity 9.3, which would explicitly incorporate professional services related to energy efficiency in industry. This better reflects the reality of energy efficiency projects, many of which extend beyond traditional building renovations and involve industrial processes, waste heat recovery and integrated site-wide improvements. The change would also facilitate more coherent reporting of mixed projects and strengthen investment signals for industrial decarbonisation.

Energy Efficiency for Europe also welcomes several proposed modifications supporting the heating and cooling sector. In particular, the recognition of waste heat and cold recovery as a cost-effective and underutilised energy efficiency solution would strengthen support for clean heating projects and better reflect the contribution of recovered heat to the energy transition. Likewise, the simplification of technical screening criteria for geothermal energy would help remove unnecessary barriers and improve the Taxonomy’s role as a clear investment guide.

However, the federation also cautions that some proposed changes could unintentionally undermine clean heat investments. Proposed amendments affecting cogeneration and bioenergy activities risk creating additional complexity and implementation challenges, whilst overlooking certain technical requirements faced by critical infrastructure and energy systems.

Another concern is the proposed removal of Activity 4.16 covering the installation and operation of electric heat pumps. Removing this activity would create a significant gap in the framework and reduce regulatory certainty for investors and operators.

Energy Efficiency for Europe therefore calls for a revision that improves clarity and usability whilst continuing to support industrial energy efficiency, waste heat recovery, clean heating solutions and the deployment of heat pumps across the EU.

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