EPEE: POSITION PAPER – REVIEW OF ENER LOT 38 (BACS) AFTER THE CONSULTATION FORUM OF 15 NOVEMBER 2021

The European Commission is assessing the possibility of introducing ecodesign requirements for building automation and control systems (BACS). The full ENER Lot 38 study on introducing such legislation for BACS was presented and discussed at a Consultation Forum on 15 November 2021.

EPEE, the European Partnership for Energy and Environment, supports the EU ecodesign and energy labelling policies, and agrees with the need to keep the legislation up-to-date and in line with the latest technological developments. Ecodesign is a tool that has delivered considerable energy efficiency savings across Europe. Nonetheless, we have strong concerns regarding the policy options that have been proposed for regulating BACS.

A recently published paper provides EPEE’s position following the Consultation Forum of 15 November 2021. In the first part, the Association highlights general concerns on the study’s proposals. In the second part, it elaborates its views on the ecodesign policy options for BACS. The third part continues with our comments to the energy labelling proposals.