CEMR’s Joint Response to the EU Energy Efficiency and Renewable Energy Directive Reviews
The Council of European Municipalities and Regions (CEMR) submitted a joint response to the European Commission’s consultations on the Energy Efficiency Directive (EED) and the Renewable Energy Directive (RED) in early 2021. This contribution reflects CEMR’s deep commitment to achieving climate neutrality by 2050 while safeguarding the role and autonomy of local and regional governments (LRGs).
CEMR supports ambitious climate targets at the EU level, with a focus on greenhouse gas (GHG) reduction. However, it argues that targets for energy efficiency and renewable energy should remain indicative at the national level, respecting the subsidiarity principle and local conditions. The organisation firmly opposes EU obligations that impose rigid requirements on LRGs, particularly concerning building renovations, public procurement, and energy planning.
A key concern is the extension of renovation obligations for public buildings to LRGs. CEMR highlights that such mandates overlook the economic realities, building uses, and planning capacities at the local level, and may burden communities with higher costs and social impacts. Instead, it advocates for flexible, cost-effective approaches tailored to local and regional contexts, supported by adequate funding, technical assistance, and capacity-building.
CEMR also calls for a technology-neutral approach to energy policy, where different forms of renewable and low-carbon energy, whether on-site, from the grid, or district heating, are treated equally. It stresses that regulations should reflect GHG savings and sustainability from a life-cycle perspective, not just the type or source of energy.
The response urges the Commission to recognise the central role of LRGs in the energy transition. This means involving them directly in National Energy and Climate Plans (NECPs), ensuring multi-level governance, and avoiding overregulation that could stifle local innovation and initiative.
In short, CEMR’s response is a strong call for an EU climate framework that is ambitious, but also realistic, inclusive, and enabling, one that empowers cities and regions to lead in achieving a just and effective energy transition.
For more information, contact:
Advisor – Environment and mobility
