The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s initiative to enhance the Energy Performance of Buildings Directive and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. EAACA promotes the interests of producers of autoclaved aerated concrete (AAC) and their national associations across Europe. The organisation was founded in 1988 and has members from 18 countries, operating more than 100 production sites and producing around 16 million cubic metres of AAC annually.

Firstly, we would like to emphasise that we appreciate and welcome the Commission’s ongoing efforts to increase energy efficiency rates across Europe and especially in buildings. Concerning the proposed potential measures that are outlined in the roadmap, we would like to comment on the following points:

• Regarding the roadmap’s outlined potential phased introduction of mandatory minimum energy performance standards for different types of buildings, EAACA supports their introduction, but requests that all other aspects of the building performance requirements are also considered. (See our later comment). It is important that indoor air quality and comfort of the occupiers is considered. With climate change we need to recognise future increases in average temperatures and the buildings ability to control indoor overheating.
• We further support the planned update of the framework for Energy Performance Certificates, with inclusion of additional information and more stringent provisions on availability and accessibility of databases.
• EAACA believes that the Commission is right in addressing resource efficiency and circularity principles, to reduce whole lifecycle emissions, digitalisation, climate resilience and health and environmental standards. Increasing standards of resource efficiency in the construction sector is essential and emissions should be looked at holistically over the entire life cycle of products.

It is important that in any future amendment, the legislation must remain material neutral.

EAACA also believes that the revision of the energy efficiency performance measures for buildings should be coherent. In this regard, EAACA would like to highlight, that the Energy Efficiency Directive (2012/27/EU), which is also currently in review, includes several issues related to the energy efficiency of buildings. EAACA believes that all energy efficiency measures related to construction and buildings should be included in the EPBD to have a coherent policy framework and to decrease administrative burden for our industry.

Further, the renovation of buildings can certainly support the enhancement of the energy efficiency of a building. At the same time, any measures included in the EPBD should not lead to unintended consequences. Other essential requirements of the built environment, that impact strongly on the long-term sustainability of dwellings must be considered. This includes for example the durability of a material, fire safety features, or the impact on the interior air quality of buildings. To be clear, the construction materials used while renovating a building should be guaranteed to not hinder or decrease the fire safety standards or indoor air quality. Buildings are not typical consumer goods and therefore require a long-term perspective by policy makers. Renovation is not always the best solution to guarantee the highest living standards for European citizens, given the quality of Europe’s post-War building stock. Revitalisation and new build can allow for buildings to be long-term sustainable, up to European quality standards, and tailored to the needs of the inhabitants.