On 25 September 2019, the European Commission adopted three recommendations to illustrate how Member States can practically implement the Energy Efficiency Directive, namely Directive 2012/27/EU as revised by Directive (EU) 2018/2002 (the EED). The adopted recommendations are:

The Recommendations (i) aim at ensuring a uniform understanding across Member States of certain aspects of the EED; (ii) aim at putting clean energy transition into practice; and (iii) herald the national measures to follow in implementation of the EED.

The revised EED

The EED together with the revised Renewable Energy Directive (Directive (EU) 2018/2001) and the Governance Regulation (Regulation EU (2018)1999), form the "Clean Energy for All Europeans" package. The EED rules require Member States to use energy more efficiently at all stages of the energy chain to boost EU’s efforts for energy independence.

The 2012 Directive (2012/27/EU) established a set of binding measures in order for the EU to improve its energy efficiency by 20% compared to 1990 by 2020.

The key point of the revised EED is the 2030 headline target on energy efficiency of at least 32,5%. The new Recommendations adopted provide insight into what the future holds following this revision.

The revised EED also includes:

  • The extension to the energy savings obligations in end use introduced in the 2012 Directive.
  • The requirement for clearer rules on energy metering and billing so that consumers have a better overview of their energy consumption.
  • The requirement for rules on the allocation of heating, cooling and hot water consumption in buildings with collective systems for such services.

Member States are required to transpose the revised EED through laws, regulations and administrative provisions by 25 June 2020, except for the metering and billing provisions that shall be transposed by 25 October 2020.

The Recommendation on the energy savings obligations

In light of the new 2030 implementation requirements of the revised EED, mapping out the plan of action to achieve the targets for the 2021-2030 obligation period is a priority.

Articles 7, 7a and 7b of the EED set out the rules on the energy savings requirements. The cumulative end-use savings may be achieved by establishing mandatory energy efficiency schemes, or policy measures. The choice of the specific means to implement the EED energy savings obligations, however, lies within the Member States' margin of discretion.

According to the EED, in each year of the 2021-2030 obligation period and beyond, Member States shall achieve cumulative end-use energy savings equivalent to new savings of at least 0,8% of their final energy consumption. For Cyprus and Malta, given the limited range of measures available to these small island Member States to meet the energy savings obligations, this rate is set at 0,24%.

The new recommendation on the energy savings obligations provides clarifications on:

  • The calculation of energy savings required for the 2021-2030 period.
  • Examples of measures to achieve the end-use energy savings requirements, such as (i) financial incentives; (ii) fuel taxes designed to trigger behavioural savings; (iii) the imposition through regulation of specific technologies or techniques; (iv) energy labelling schemes, training and education.
  • The obligation to designate "obligated parties" among utility companies that will be required to help final customers to achieve energy savings.
  • The discretion of Member States to select the sectors to which they will apply measures to meet the requirements. For example, in the transport sector they may apply measures to accelerate the uptake of new, more efficient vehicles; in the water sector, they may wish to reduce water losses along the distribution network, which eventually translates into reduced amounts of energy used to produce and treat water.

The Recommendation on the implementation of the new metering and billing provisions

Recognising that heating and cooling accounts for almost 50% of EU’s total energy consumption, the Commission through this second recommendation provides clarifications on the application of the EED provisions on the metering and billing of thermal energy.

In particular, this recommendation contains clarifications on:

  • The obligation of metering (Article 9a).
  • The obligation for sub-metering (Article 9b (1)).
  • The specific obligation for sub-metering domestic hot water in residential parts of new buildings (Article 9b (2)).
  • The heat cost allocation rules (Article 9b (3)).
  • The transition to remotely readable devices (Article 9c).
  • The billing and consumption information that need to be made available to the final users and customers (Article 10a).

The Recommendation on the content of the comprehensive assessment of the potential for efficient heating and cooling under Article 14 of the EED

Under Article 14 of the 2012 Directive, Member States had to carry out first comprehensive assessments of the potential for efficient heating and cooling by 31 December 2015. Member States are required to submit updated comprehensive assessments under Article 14(1) of the EED by 31 December 2020. The aim of the third recommendation is to provide guidance to Member States as to the information that needs to be notified to the Commission in the comprehensive assessments.


The Recommendations contain detailed guidance on how to transpose and best implement various aspects of the revised EED, that has not been transposed for the time being by any of the Member States. They are of particular relevance in light of the ambitious 2030 energy and climate targets set by the EU and they are expected to steer Member States through this new era. The new Commission is expected to rigorously implement such targets as the EU tries to establish itself as a world leader in energy efficiency and climate protection.