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Consultation on Action Plan for Energy Efficiency

Publication date: 26 August 2009

1. General questions
In the context of this evaluation and the preparation of the envisaged new Energy Efficiency Action Plan, the Commission is open to re-evaluate its present legislation and policy portfolio.

The Action Plan for Energy Efficiency of 2006 identified 6 key areas and proposed 10 priority actions (out of a total of 85 actions and measures). Which of the actions and measures of the 2006 EEAP should be continued / redefined / discontinued, and why ? (Max. 4000 characters) (optional)
All of the priority actions should be continued. But, it should be taken into account that several targets are jeopardised due to delays in the policy-making process.
2. Specific questions
Please provide an answer to each of the following questions and, if possible, justify it by quantifying the environmental, social and economic impacts.
2.1. The existing Energy Performance of Buildings Directive (2002/91/EC) and its recast, as well as other relevant legal acts, go a long way for introducing ambitious but realizable energy performance requirements for buildings and increase consumers' awareness. However, much more can be done. (compulsory)
No opinion

2.2. Sustainable transport and energy consumption of cars is currently addressed in the Greening transport package (COM(2008)433), the Regulation on Emission performance standards for new passenger cars (COM(2007)0856), the proposed Directive on labelling of tyres (COM(2008)0779), the proposal on greening car taxation (COM(2005)261) and the 'Green Cars' initiative. The Commission is also working on a proposal on light commercial vehicles and a revision of CO2/cars labelling. Do you consider that additional measures at EU level need to be undertaken? (compulsory)
For example, a regulation concerning the additional fuel consumption of Mobile Air Conditioning System (MAC). Further, the European Union should give clearer indications concerning the importance of biofuels.

2.3. The Eco-Design (2005/32/EC) and Energy Labelling (92/75/EEC) framework Directives are significant steps as regard to product policy. A number of implementing measures have been already or are soon to be adopted and the ongoing amendments of the two Directives provide for their more ambitious and wider application. Do you consider that additional measures can be taken forward in order to increase the impact of these instruments? (compulsory)
No opinion

2.4. Lack of access to appropriate financing is an important bottleneck for making a real step forward in our ambitions on energy saving. Innovative financing instruments are now being developed by institutions such as EIB, EBRD, national promotional banks and private banks in particular in association with the Covenant of Majors initiative. Demonstration projects of the application of energy efficient technologies in a competitive manner, e.g. 'smart cities', could also be considered. Do you think other financing measures at EU level are needed? (compulsory)
  No opinion

2.5. Well targeted fiscal incentives could be a driver for energy efficiency investments and innovation. The EU has already taken measures to make it easy for Member States to allow for more advantageous VAT rates for some labour-intensive services, such as renovation and repairing of private dwellings. Do you consider that additional measures at EU level need to be undertaken to shape consumer choices? (compulsory)
No opinion

2.6. Education and training on energy efficiency are vital ingredient of a successful energy efficiency policy. These were already mentioned above regarding buildings but the challenge is much broader. Do you consider that measures/actions at EU level to catalyze training at school and university level should be undertaken? (compulsory)

For example, eco-driving leads to substantial fuel savings (average fuel savings of 5-10%) and therefore adequate teaching and training methods should be supported at European level.

2.7. Awareness of final consumers on energy savings possibilities and their benefits is still low. This in particular concerns domestic consumers and SMEs. Some actions to target different groups are already undertaken at national and EU level. For example, the Sustainable Energy Europe Campaign is focusing on grouping social stakeholders and market actors to undertake joint action. Do you think that further communication action at EU level is needed? (compulsory)
European-wide campaigns concerning eco-driving and environmentally-friendly car technologies, for example in the form of EcoTours (fuel consumption/CO2 emissions competition with the most fuel-efficient car models taking part). One important element already underlined by the European motoring and touring clubs and only now starting to be addressed by the European Commission is the need for high-quality consumer information. In this respect, the EcoTest has made the first step to provide consumers all over Europe with easy to understand information concerning the environmental aspects to be taken into account when purchasing passenger cars as well as their fuel-efficiency. The EcoTest is based on a harmonised measuring methodology and real driving conditions. The FIA European Bureau sees the EcoTest programme as a good basis for developing a European harmonised fuel-efficiency label. The annual EcoTest – developed by the ADAC under the commission of the FIA
Foundation – supports consumers in choosing environmentally-friendly cars, taking into consideration individual needs regarding vehicle size and class. The EcoTest assesses the emissions of hydrocarbon (HC), carbon monoxide (CO), nitrogen oxide (NOx), particulate matter (PM) and carbon dioxide (CO2). The final star rating awarded to the different car models is based on emissions and on fuel consumption. The public interest in this important consumer information is shown by the numerous enquiries and requests for further measurements. The results are seen as an important input for the political discussion on car emissions. Website:

2.8. Furthermore, small and medium size companies (SMEs) are the backbone of EU's economy as they make up more than 99% of all firms and employ 67% of the EU's workforce but may need more support for implementing energy saving measures. Do you consider that specific measures to target SMEs are necessary? (compulsory)
SMEs normally have much less opportunities to receive financial help when facing problems. It would therefore be a good compensation to give support to SMEs when they implement energy-saving measures.

2.9. Public sector should lead by providing best practice examples. Positive progresses have been made under the voluntary Green public procurement policy and the proposals for mandatory procurement of energy efficient products in the framework of the recast of the Energy Labelling Directive. The leading role of public authorities has also been emphasized under the recast of Energy Performance of Buildings Directive proposal. Do you consider that further actions at EU level should be undertaken? (compulsory)


2.10. The role of energy utilities can be substantial but at present they have insufficiently developed a market for energy efficiency services. Ways to create adequate framework conditions for this market to take-up in liberalized electricity and natural gas markets should be sought, possibly in cooperation with the Regulators. Do you consider that actions at EU level should be undertaken? (compulsory)
But one has to take into account that energy savings could also reduce the turnover of companies.

2.11. Energy efficiency offers significant market opportunities. Do you consider that specific measures at EU level should be adopted to provide incentives for companies to enter these markets, in particularly as regards SMEs? (compulsory)

2.12. In relation to the above question do you consider that there is a need for the introduction of a EU-wide White Certificate scheme? (optional)
No opinion
2.13. The Directive on energy end-use efficiency and energy services (2006/32/EC) already provides for national indicative energy savings target which differs from the ones for renewables and for the greenhouse gas emissions. Giving the increasing priority for ensuring that investment in energy consumption reduction are made in all Member States do you consider that a move towards binding targets is needed? (compulsory)
National indicative energy saving targets should be a first step. They should be replaced by binding energy saving targets only when it becomes obvious that the indicative energy saving targets are not effective.

2.14. Measurement and verification of energy savings is essential aspect for monitoring the results of any measures introduced at national and EU level. Although some targeted measures are being implemented, do you consider that more systematic and harmonized approach at EU level is needed? (compulsory)

2.15. Energy efficiency should become a vector of international co-operation and a subject of international financing programmes, in particular regarding EU neighbouring countries. Do you agree with statement? (compulsory)

3. Other remarks

The FIA European Bureau believes that the current technology-based approach to reduce CO2 emissions from cars needs to be supplemented with infrastructure and driver behaviour related measures, as is the case in other sectors. In this respect, eco-driving is a no-regret measure that can be implemented rather easily, leads to solid results rather quickly and can contribute to fighting climate change. Eco-driving is a smart, energy-efficient and safe way to drive. In many countries however, eco-driving still gets little attention and only plays a marginal role in policy measures. The eco-driving concept and its benefits are not (well) known to the national audiences and policy makers are not (well) aware of the potential of eco-driving. Long-term analysis however shows that the promotion of such driver information and education schemes increases overall fuel-efficiency of passenger cars by five to ten percent, a non-negligible contribution to reducing greenhouse gases. Eco-driving should be part of novice driver training while advanced driver training should help to sustain the long-term effect. Eco-driving also comprises checking tyre pressures as well as using fuel saving in-car technologies, for example cruise control, tyre pressure monitoring systems and gear shift indicators.
On-board diagnostics should inform drivers about the performance of their car and the consequences of driving habits and maintenance. In this respect gear-shift indicators are a valuable development. Such devices could help motorists in realising the full potential of eco-driving, which has been demonstrated to be large in many studies.

Eco-driving training of fleet and commercial drivers has been particularly successful in the United Kingdom and elsewhere across Europe. The Safe and Fuel Efficient Driving (SAFED) programme ( is a very good example.

Employers should be able to exert a much stronger influence over their drivers than governments can ever hope to achieve as quickly over the general public. Adoption of eco-training and the purchase of the most fuel-efficient vehicles should be best practice for all companies and governments departments. Therefore, The FIA European Bureau urges the European governments to educate and to inform private car owners and consumers about the facts concerning fuel savings.

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