Guidance Note On EPBD Building Modernisation, EC, 2019

L 165/70 EN Official Journal of the European Union 21.6.
2019
RECOMMENDATIONS
COMMISSION RECOMMENDATION (EU) 2019/1019

of 7 June 2019
on building modernisation
(Text with EEA relevance)
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union, and in particular Article 292 thereof,
Whereas:
(1) The Union is committed to developing a sustainable, competitive, secure and decarbonised energy system. The
Energy Union and the energy and climate policy framework for 2030 establish ambitious Union commitments to
further reduce greenhouse gas emissions by at least a further 40 % by 2030 compared with 1990, to increase the
proportion of consumption of renewable energy, and to make energy savings in accordance with Union level
ambitions, improving the Union's energy security, competitiveness and sustainability. Directive 2012/27/EU of
the European Parliament and of the Council (1), as amended by Directive (EU) 2018/2002 (2), establishes an
energy efficiency headline target of at least 32,5 % savings at Union level by 2030. Directive (EU) 2018/2001 of
the European Parliament and of the Council (3) sets a binding target of at least 32 % energy from renewable
sources at Union level by 2030.
(2) Buildings are central to the Union's energy efficiency policy as they account for nearly 40 % of final energy
consumption.
(3) The 2015 Paris Agreement on climate change that followed the 21st Conference of the Parties to the United
Nations Framework Convention on Climate Change (COP 21) boosts the Union's efforts to decarbonise its
building stock. Given that almost 50 % of the Union's final energy consumption is for heating and cooling, of
which 80 % is used in buildings, the Union's achievement of its energy and climate goals is linked to its efforts to
renovate building stocks by giving priority to energy efficiency, applying the ‘energy efficiency first’ principle and
considering the deployment of renewables.
(4) The Commission highlighted the importance of energy efficiency and the role of the building sector for the
achievement of the Union's energy and climate goals and for the transition to clean energy in its Communication
on energy efficiency and its contribution to energy security and the 2030 framework for energy and climate
policy (4), in its Communication on a Framework Strategy for a Resilient Energy Union with a Forward-looking
Climate Change Policy (5), and in its Communication on a European strategic long-term vision for a prosperous,
modern, competitive and climate neutral economy (6). The latter Communication stresses that energy efficiency
measures should play a central role in achieving a climate neutral economy by 2050 and reducing energy
consumption by as much as half compared to 2005.
(1) Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency, amending Directives
2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC (OJ L 315, 14.11.2012, p. 1).
(2) Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 amending Directive 2012/27/EU on
energy efficiency (OJ L 328, 21.12.2018, p. 210).
(3) Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy
from renewable sources (OJ L 328, 21.12.2018, p. 82).
(4) Impact Assessment accompanying the document Communication from the Commission to the European Parliament and the Council
Energy Efficiency and its contribution to energy security and the 2030 Framework for climate and energy policy (SWD(2014) 255 final).
(5) Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee, the
Committee of the Regions and the European Investment Bank ‘A Framework Strategy for a Resilient Energy Union with a Forward-Looking
Climate Change Policy’ (COM(2015) 80 final).
6
( ) Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and
Social Committee, the Committee of the Regions and the European Investment Bank ‘A Clean Planet for all — a European strategic long-term
vision for a prosperous, modern, competitive and climate neutral economy’ (COM(2018) 773 final).
21.6.2019 EN Official Journal of the European Union L 165/71
(5) Full implementation and enforcement of existing energy legislation is considered as the first priority in
establishing the Energy Union.
(6) Directive 2010/31/EU of the European Parliament and of the Council (7) (‘EPBD’) is the main legislation, together
with Directive 2009/125/EC of the European Parliament and of the Council (8) and Regulation (EU) 2017/1369
of the European Parliament and of the Council (9), addressing energy efficiency in buildings in the context of the
2030 energy efficiency targets. The EPBD has two complementary objectives, namely to accelerate the renovation
of existing buildings by 2050 and to support the modernisation of all buildings with smart technologies and
a clearer link to clean mobility.
(7) In 2018 the EPBD was amended by Directive (EU) 2018/844 of the European Parliament and of the Council (10)
in order to accelerate the modernisation of buildings in the Union.
(8) The performance of technical building systems has a significant impact on overall building energy performance
and should therefore be optimised. It is important to ensure that improvement of energy performance of
buildings follows an integrated approach, taking into account measures both on building envelope and on
technical building systems.
(9) National legislation transposing Article 8(1) of the EPBD has to ensure that system requirements are established
and enforced for an expanded group of technical buildings systems, and that new requirements are introduced on
the installation of self-regulating devices in buildings.
(10) To meet the objectives of energy efficiency policy for buildings, the transparency of energy performance
certificates should be improved. National legislation transposing the requirements of Article 8(9) of the EPBD is
required to ensure that the overall energy performance of the altered part, or where relevant, of the whole
system, is documented for use in building certification and compliance checking when technical building systems,
such as for space heating, air-conditioning or water heating, are installed, replaced or upgraded.
(11) Innovation and new technology also make it possible for buildings to support the overall decarbonisation of the
economy, including in the transport sector. For example, buildings can support the development of the
infrastructure necessary for the smart charging of electric vehicles, which can provide a basis for Member States,
if they choose to, to use car batteries as a source of power.
(12) Electric vehicles are an important component of a clean energy transition based on energy efficiency measures,
alternative fuels, renewable energy and innovative solutions for the management of energy flexibility. Building
codes can be effectively used to introduce targeted requirements to support the deployment of recharging
infrastructure in the car parks of residential and non-residential buildings. National legislation transposing the
requirements of Article 8(2) to Article 8(8) of the EPBD is required to ensure the deployment of recharging
infrastructure for electric vehicles in buildings' car parks.
(13) When applying the requirements of Article 8(2) to Article 8(8) of the EPBD Member States should consider the
need for holistic and coherent urban planning; as well as the promotion of alternative, safe and sustainable
modes of transport and their supporting infrastructure, for example through dedicated parking infrastructure for
electric bicycles and for the vehicles of people with reduced mobility.
(14) Member States should lay down measures to simplify the deployment of recharging infrastructure with a view to
addressing barriers that individual owners encounter when trying to install a recharging point on their parking
space, such as split incentives and administrative complications.
(15) To digitalise the building sector, thus facilitating the emergence of smart homes and well-connected communities,
targeted incentives should be provided to promote smart-ready systems and digital solutions in the built
environment.
(7) Directive 2010/31/EU of the European Parliament and of the Council of 19 May 2010 on the energy performance of buildings
(OJ L 153, 18.6.2010, p. 13).
(8) Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of
ecodesign requirements for energy-related products (OJ L 285, 31.10.2009, p. 10).
(9) Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and
repealing Directive 2010/30/EU (OJ L 198, 28.7.2017, p. 1).
(10) Directive (EU) 2018/844 of the European Parliament and of the Council of 30 May 2018 amending Directive 2010/31/EU on the
energy performance of buildings and Directive 2012/27/EU on energy efficiency (OJ L 156, 19.6.2018, p. 75).
L 165/72 EN Official Journal of the European Union 21.6.2019
(16) It is important to raise awareness amongst building owners and occupants of the value of building automation
and the electronic monitoring of technical building systems; and give occupants confidence in the actual savings
those enhanced functionalities offer.
(17) To ensure the initial and continued performance of heating systems, air-conditioning systems and ventilation
systems, inspection schemes should be designed to maximise their results. Articles 14 and 15 of the EPBD
expand the scope of technical building systems subject to mandatory regular inspections or alternative
measures. In addition, those Articles lay down alternatives to inspections based on automation and control or
electronic monitoring and set out new requirements on the installation of building automation and control
systems in certain non-residential buildings.
(18) Building automation and electronic monitoring of technical building systems have proven to be an effective
replacement for inspections, in particular for large systems. As a result, they hold great potential to provide cost-
effective and significant energy savings for both consumers and businesses. The installation of such equipment
should be considered as a cost-effective alternative to inspections of large non-residential and multi-apartments
buildings of a sufficient size, as it offers an interesting return on investment and enables action to be taken on
the information provided, thereby securing energy savings over time. The implementation of the requirements in
Article 14(4) and Article 15(4) of the EPBD will ensure that building automation and control systems are
installed in non-residential buildings where heating or air-conditioning effective rated output is above a certain
threshold, and where this is technically and economically feasible.
(19) To meet the objectives of energy efficiency policy for buildings, the transparency of energy performance
calculations should be improved by ensuring that all necessary parameters for both certification and minimum
energy performance requirements, are set out and applied consistently across the Union.
(20) Annex I to the EPBD was amended in order to introduce a degree of transparency in the calculation of primary
energy factors, to ensure the central role of the building envelope and to address the role of on-site and off-site
renewable energy sources
(21) Member States are to bring into force the laws, regulations and administrative provisions transposing Directive
(EU) 2018/844 by 10 March 2020.
(22) The full transposition and effective implementation of the amended EPBD is fundamental to support the
achievement of 2030 energy efficiency targets and to put the Union on track for the full decarbonisation of
national building stocks by 2050.
(23) The EPBD leaves to Member States a large margin of discretion when designing their building codes and
implementing technical requirements regarding renovations, building certificates and technical building systems in
a way which fits best the national climatic conditions and building stocks. This Recommendation aims at
explaining the substance of these technical requirements and the different ways in which the objectives of the
Directive can be achieved. It also presents the experience and best practices the Commission has seen amongst
Member States.
(24) The Commission is committed to work closely with the Member States in their transposition and effective
implementation of the EPBD. To this end the present Recommendation has been prepared to explain in more
detail how certain provisions of the EPBD should be read and can be best applied in the context of national trans
position. The aim in particular is to ensure a uniform understanding across Member States in the preparation of
their transposition measures. This Recommendation does not alter the legal effects of the EPBD and is without
prejudice to the binding interpretation of the EPBD as provided by the Court of Justice. This Recommendation
deals with subjects in the EPBD which are legally complex, demanding to transpose and have high potential in
terms of impact on the energy efficiency of buildings. This Recommendation focuses on the provisions relating to
the modernisation of buildings and concerns Articles 2, 8, 14, 15, and Annex I of the EPBD, which include
provisions on technical building systems and their inspections, electromobility, and the calculation of energy
performance of buildings. Provisions in the EPBD dealing with renovation are addressed in a separate Recommen
dation.
(25) Therefore this Recommendation should allow Member States to achieve strong impacts in terms of modernisation
of their building stock,
HAS ADOPTED THIS RECOMMENDATION:
1. Member States should follow the guidelines provided in the Annex to this Recommendation in transposing the
requirements laid down by Directive (EU) 2018/844.
2. This Recommendation is addressed to the Member States.
3. The Recommendation shall be published in the Official Journal of the European Union.
Done at Brussels, 7 June 2019.
For the Commission

Miguel ARIAS CAÑETE
Member of the Commission
ANNEX
1. INTRODUCTION
Directive 2010/31/EU (‘EPBD’) promotes improvement in the energy performance of buildings, including of
technical building systems. In particular, the Directive clarifies the systems to which the requirements are to be
applied and includes specific provisions to ensure that those systems are designed, dimensioned, installed and
adjusted in a way that optimises performance. For those systems that have a particularly significant impact on
energy performance, the Directive also requires inspections that regularly monitor system efficiency. It considers
electronic monitoring and control as a possible alternative to inspections.
Directive 2012/27/EU (‘EED’) contained provisions on building renovation and long-term strategies for
mobilising investment in the renovation of national building stocks.
The EPBD and the EED have been amended by Directive (EU) 2018/844, which entered into force on 9 July
2018, strengthens the above elements and, increases the types of system whose performance are to be
optimised. It also strengthens the role of electronic monitoring, automation and control and includes additional
requirements that support the deployment of electric vehicle recharging infrastructure in building car parks.
Expanding the scope of the definition of technical building systems to include more systems and, more
generally, the need to reflect the evolution of buildings and the energy system have made it necessary to update
the EPBD's framework for calculating the energy performance of buildings. Most notably, this means improving
the transparency of energy performance calculations and energy performance certificates, in particular in
relation to the calculation of primary energy factors.
The aim of this Recommendation is to help ensure full implementation and enforcement of Union energy
legislation. It provides guidance on how to understand and transpose the EPBD, specifically those provisions
that concern technical building systems and their inspections, including: requirements on installing self-
regulating devices and building automation and control systems (Article 8 and Articles 14 and 15 of the EPBD),
electromobility recharging infrastructure (Article 8 of the EPBD), and the calculation of primary energy factors
(Annex I to the EPBD).
The guidelines set out in this Annex present the view of the Commission services. It does not alter the effects
of the Directive and is without prejudice to the Court of Justice binding interpretation of Articles 2, 8, 14, 15
and Annex I of the EPBD.
2. TECHNICAL BUILDING SYSTEMS AND THEIR INSPECTIONS, INCLUDING REQUIREMENTS ON THE INSTALLATION OF
SELF-REGULATING DEVICES AND BUILDING AUTOMATION AND CONTROL SYSTEMS
2.1. Aim: to ensure optimal performance of technical building systems and support the management of
energy and the indoor environment
The EPBD includes provisions on requirements for technical building systems and on the assessment and
documentation of system performance, whose aim is twofold. Firstly, the assessment and documentation of
system performance aims to ensure that technical building systems are adequately designed, installed and
commissioned in order to optimise their actual performance. Secondly, it aims to ensure that any intervention
that can have an impact on the performance of a technical building system is tracked and documented. This is
important as such information is valuable to the owner and to facilitate the assessment of the performance of
the building as a whole (e.g. in the context of energy performance certification).
The amendment to the EPBD expands the scope of the regular inspection of technical building systems. The
aim of these inspections is to evaluate system performance. Inspections should also identify issues or problems,
propose solutions or improvement measures, and log the results of the inspection in a report for future
reference.
The EPBD includes requirements for the installation of self-regulating devices that are able to regulate indoor
temperature in buildings, with the aim of improving the management of energy consumption while limiting
costs. It also includes a requirement to install building automation and control systems (BACS) in all (existing
and new) non-residential buildings over a certain effective rated output of heating, ventilation and air-
conditioning systems. This is because BACS lead to significant energy savings, improve the management of the
indoor environment and, as such, are beneficial to both building owners and users, in particular in large non-
residential buildings.
2.2. Scope of provisions on technical building systems and their inspections, self-regulating devices and
BACS
This sub-section recalls the scope and content of these provisions and highlights the differences introduced by
amendments from Directive (EU) 2018/844 where relevant.
2.2.1. Technical building systems: system requirements, assessment and documentation of overall energy performance (Article 2,
Article 8(1) and 8(9) of the EPBD)
Before amendment: before the amendment, Article 8(1) of the EPBD required Member States to set system
requirements in respect of the overall performance, proper installation and appropriate dimensioning,
adjustment and control of technical building systems. This obligation applied to technical building systems
installed in existing buildings and Member States could also apply it to technical building systems installed in
new buildings. In addition, before amendment, Article 2(3) of the EPBD defined a technical building system as
‘technical equipment for the heating, cooling, ventilation, hot water, lighting or for a combination thereof, of
a building or building unit’.
After amendment: with regard to technical building systems, Article 8 of the EPBD was replaced, with the
following to be noted:
(a) the provisions on technical building system requirements in Article 8(1) remain substantially unchanged
(with the exception of the systems for which the system requirements had to be applied, listed in
subparagraph 2, which has been repealed);
(b) the amendment updates and extends the definition of ‘technical building systems’ (Article 2(3));
(c) the amendment introduces new provisions on the assessment and documentation of the overall
performance of technical building systems (Article 8(9)).
2.2.2. Technical building systems: inspections (Articles 14 and 15 of the EPBD)
Before amendment:
Article 14 of the EPBD set inspection requirements for heating systems with a rating over 20 kW. Member
States had to determine inspection frequencies based on the type of the system, effective rated output, the costs
of inspections and estimated energy savings. Heating systems with an effective rating of over 100 kW had to be
inspected at least every 2 years. Member States could also allow for reduced inspection frequency for systems
with electronic monitoring and control systems in place. As an alternative to inspections, Article 14(4) allowed
Member States to opt to take measures that would ensure that users receive advice concerning the replacement
of boilers, other modifications to the heating system and alternative solutions to assess boiler efficiency and
appropriate size. The overall impact of this approach had to be equivalent to the expected impact of
inspections.
Article 15 of the Directive set inspection requirements for air-conditioning systems with a rating over 12 kW.
Member States had to determine inspection frequencies based on the type of the system, effective rated output,
the costs of inspections and estimated energy savings. Member States could allow for reduced inspection
frequency for systems with electronic monitoring and control systems in place. As an alternative to inspections,
Article 15(4) allowed Member States to opt to take measures that would ensure that users receive advice
concerning the replacement of air-conditioning systems and other related modifications, including inspections
to assess the system's efficiency and appropriate size. The overall impact of this approach had to be equivalent
to the expected impact of inspections.
After amendment:
Article 1(7) of Directive (EU) 2018/844 replaces the provisions related to inspections in Article 14 and 15 of
the EPBD.
Under Article 14 of the EPBD, heating systems and combined heating and ventilation systems with an effective
rating of 70 kW or lower no longer require inspections. Under the same Article, heating systems and combined
heating and ventilation systems with an effective rating over 70 kW must still be inspected at regular
intervals. The EPBD allows for exemptions for:
(a) systems that are under energy efficiency contractual arrangements (or similar), in accordance with
Article 14(2);
(b) systems operated by a utility or a network operator, in accordance with Article 14(2);
(c) systems in non-residential buildings equipped with automated and control systems, in accordance with
Article 14(4) and 14(6);
(d) systems in residential buildings with specific monitoring and control functionalities, in accordance with
Article 14(5) and 14(6).
Under Article 15 of the EPBD, air-conditioning systems and combined air-conditioning and ventilation systems
with an effective rating of 70 kW or lower no longer require inspections. Under the same Article, air-
conditioning systems and combined air-conditioning and ventilation systems with an effective rating over
70 kW must still be inspected at regular intervals. The EPBD allows for exemptions for:
(a) systems under energy efficiency contractual arrangements (or similar), in accordance with Article 15(2);
(b) systems operated by a utility or a network operator, in accordance with Article 15(2);
(c) systems in non-residential buildings equipped with automated and control systems, in accordance with
Article 15(4) and 15(6);
(d) systems in residential buildings with specific monitoring and control functionalities, in accordance with
Article 15(5) and 15(6).
2.2.3. Requirements related to the installation of self-regulating devices (Article 8(1) of the EPBD)
Before amendment: Not applicable (these provisions were introduced with the amendment)
After amendment: Article 1 of Directive (EU) 2018/844 introduces new requirements related to the installation
of self-regulating devices and building automation and control systems in buildings that meet specific
conditions. More precisely, under the third subparagraph of Article 8(1) of the EPBD, Member States must
require the installation of self-regulating devices in all new buildings and in existing buildings when heat
generators are replaced, where technically and economically feasible.
2.2.4. Requirements related to the installation of building automation and control systems (Article 14(4) and 15(4) of the
EPBD)
Before amendment: Not applicable (these provisions were introduced with the amendment)
After amendment: Under Article 14(4) and Article 15(4) of the EPBD, Member States must require the
installation of building automation and control systems in all non-residential buildings in which the effective
rated output of heating, air-conditioning, combined heating and ventilation and combined air-conditioning and
ventilation is more than 290 kW. In accordance with Article 14(4) and 15(4) of the EPBD, this must be done
by 31 December 2025 where technically and economically feasible (see section 2.3.4 for more guidance on the
feasibility of meeting requirements).
2.3. Understanding provisions on technical building systems and their inspections, self-regulating devices
and BACS
2.3.1. Technical building systems requirements and assessment and documentation of overall energy performance of technical
building systems (Article 2, Article 8(1) and 8(9) of the EPBD)
2.3.1.1. E xte ns i on of th e d e fi ni t i o n of a ‘ tec hnica l b ui l di ng system ’ (Ar tic le 2 (3 ) of the E PB D )
The obligations arising from Article 8(1) and 8(9) of the EPBD apply to technical building systems as defined in
Article 2(3). According to this definition, the term ‘technical building system’ means ‘technical equipment for
space heating, space cooling, ventilation, domestic hot water, built-in lighting, building automation and control,
on-site electricity generation or a combination thereof, including those systems using energy from renewable
sources, of a building or building unit.’
A ‘technical building system’ was already defined in the EPBD before the last amendment. The EPBD updates
this definition by: using a different wording for some systems, in order to clarify their scope; and extending it
to include additional systems (‘technical equipment for building automation and control’ and ‘technical
equipment for on-site electricity generation’).
The following table summarises the changes made to the definition under the EPBD:
Table 1
Changes to the definition of a ‘technical building system’ introduced under the EPBD
Before the amendment With the amendment Type of change
heating space heating clarification of scope
cooling space cooling clarification of scope
ventilation ventilation no change
hot water domestic hot water clarification of scope
lighting built-in lighting clarification of scope (1)
n/a building automation and control new technical building system
n/a on-site electricity generation new technical building system
(1) The Directive was already on built-in lighting before the amendment (built-in lighting installations were taken into con
sideration in the methodology used to calculate the energy performance of buildings). This is also consistent with consid
ering built-in lighting as part of the energy uses which have an impact on the energy performance of buildings (see An
nex I of the EPBD).
The concept of ‘on-site electricity generation’ under the EPBD should be subject to interpretation in the light of
Article 15 of the Electricity Directive (1) on common rules for the internal market in electricity that regulates
the status, rights and obligations of electricity customers that also own generation units, and of the notion of
‘active customers’ within the meaning of the same Directive.
2.3.1.2. Ne w t e ch n i c a l b u il d i n g sy s tem s in the EPBD (Ar ti c le 2 (3) a nd 2(3 a) of the EP B D)
Technical equipment for building automation and control and technical equipment for on-site electricity
generation have been added to the definition of technical building systems.
(a) ‘Building automation and control systems’ are defined in Article 2(3a) of the EPBD: ‘“building automation
and control system” means a system comprising all products, software and engineering services that can
support energy-efficient, economical and safe operation of technical building systems through automatic
controls and by facilitating the manual management of those technical building systems’;
(b) ‘On-site electricity generation systems’ refers to systems that are designed to produce electricity, that are
installed in or within confined boundaries of the premises where the building is located and that have some
level of integration with the building and its electrical installation (2). Such systems include, in particular,
photovoltaic panels (e.g. roof-mounted photovoltaics panels), micro combined heat and power (CHP) instal
lations and small wind turbines.
(1) The Directive of the European Parliament and of the Council on common rules for the internal market in electricity (recast) was
approved by the European Parliament at first reading on 26 March 2019, following a provisional agreement reached in interinstitutional
negotiations. Adoption by the Council is foreseen for May 2019 and publication in the Official Journal will follow.
2
( ) Member States will need to decide how to transpose the notion of ‘on-site’ in cases where the system is not in or on the building. Whether
the electricity generation system shares a connection to the electricity grid or not could help distinguish between on- and off-site
systems.
2.3.1.3. Us efu l d ef i n i ti o n s : ‘ h ea ti ng s y s tem ’ a nd ‘a ir-c ond iti on in g sy stem’ (A r tic l e 2 (1 5 a) an d 2 ( 1 5 )

of t h e EP B D )
In addition to the definition of a technical building system, Article 2 of the EPBD includes definitions of
a heating system and air-conditioning system (3):
(a) ‘“Heating system” means a combination of the components required to provide a form of indoor air
treatment, by which the temperature is increased (4)’.
(b) ‘“Air-conditioning system” means a combination of the components required to provide a form of indoor
air treatment, by which temperature is controlled or can be lowered (5)’.
2.3.1.4. Wh en d o t he ob l igati on s ap p l y ? ( Ar ti c le 8( 1) a nd 8 (9) of the EPBD )
The technical building system provisions under Article 8(1) and 8(9) of the EPBD apply when a technical
building system is installed, replaced or upgraded.
Note that the conditions that need to be met for these obligations to apply relate only to the technical building
systems themselves and not to the type of building or building unit under consideration. The definition of
a technical building system makes it clear that a technical building system is equipment in a building or
building unit, meaning that provisions that apply to technical building systems are applicable in the buildings
or building units concerned, regardless of building type or characteristics.
However, the provision on setting system requirements is obligatory only with regard to technical building
systems in existing buildings. It is up to Member States whether they choose to extend the obligation to
technical building systems in new buildings.
2.3.1.5. M ea nin g of ter m s ( Ar tic l e 8( 1) a nd 8(9 ) o f t he EPBD )
The new provisions on the documentation of system performance (Article 8(9) of the EPBD) use some of the
same concepts as the provisions on setting system requirements: ‘overall energy performance’, ‘installation’,
‘replacement’ and ‘upgrading’. The meaning of these terms remains the same in the new provisions. These terms
should therefore be transposed at national level in the same way as in the provisions on setting system
requirements.
The provisions on the documentation of system performance also use the term ‘altered part’, which refers to
the specific part (i.e. component) of a system that is affected when the system is upgraded. This is only relevant
in the context of a system upgrade, not when a system is installed or replaced.
2.3.2. Inspection of heating, air-conditioning, combined heating and ventilation and combined air-conditioning and ventilation
systems (Article 14 and 15 of the EPBD)
2.3.2.1. Evolu t ion of p r ov is ion s on i n s pec ti ons u nder the EPBD (Ar ti c le 14 a n d 15 of the EPBD )
In summary, the main changes in inspection requirements introduced under the EPBD are: (1) the different
thresholds for inspections; (2) introduction of inspections of ventilation systems for combined heating (air-
conditioning) and ventilation systems; (3) a greater focus on normal operating conditions; and (4) a greater role
for building automation and control systems (BACS) and electronic monitoring and control systems.
As an alternative to inspections, Articles 14(3) and 15(3) of the EPBD include the possibility for Member States
to opt to take alternative measures that would ensure that users receive advice. The EPBD's provisions on
alternative measures are similar to those set out in the EPBD before the last amendment.
(3) The definition of ‘air-conditioning system’ was already provided before the amendment and has not been modified in the EPBD. The
definition of ‘heating system’ is new in the EPBD.
(4) The EPBD refers both to ‘heating system’ and to ‘system for space heating’ — these two terms are equivalent within the meaning of the
Directive.
(5) The EPBD refers both to ‘air-conditioning system’ and ‘system for space cooling’ — these two terms are equivalent within the meaning of
the Directive.
However, Member States that choose to apply alternative measures must ensure that their impact is equivalent
to the impact that inspections carried out under Article 14(1) and Article 15(1) of the EPBD would have had
(this includes elements such as the new thresholds, combined heating and ventilation systems, exemptions, etc.).
The provisions in Article 15 of the EPBD are almost identical to those in Article 14. The only difference is that
Article 14 applies to heating systems while Article 15 applies to air-conditioning systems. Member States
should therefore apply the recommendations provided for the inspection of heating systems in Article 14 to
the inspection of air-conditioning systems in Article 15 (or their alternative measures if applicable). It follows
that references to heating systems also apply to air-conditioning systems, and references to heat generators or
boilers also apply to cooling generators or chillers. In order to avoid redundancies, the following sections
mainly address the inspection of heating systems under Article 14; separate references to air-conditioning
systems under Article 15 are only made where necessary.
2.3.2.2. E ffec ti v e r a ted out put ( A r t i c le 2 ( 17 ), 1 4 an d 15 of the EPBD )
The definition of ‘effective rated output’ is given in Article 2(17) of the EPBD.
For heating and air-conditioning, the effective rated output means the maximum output (in kW) during
operation, as specified by the system manufacturer (6):
(a) rated heat output for a heating system;
(b) rated cooling output for an air-conditioning system.
Where applicable, the threshold for the effective rated output applies to each system individually (heating, air-
conditioning, combined heating and air-conditioning and ventilation).
Where combined systems are in place, the effective rated output should reflect the capacity of the combination
of systems, as clarified in sections 2.3.2.3 and 2.3.2.4.
Usually, a system will comprise more than one unit that operate jointly. In this case, the effective rated output
corresponds to the sum of the effective rated outputs of the individual units.
2.3.2.3. H e atin g an d c om b i n ed h e at in g an d ven ti la ti on system s (Ar ti cl e 1 4 of the EPB D)
The last amendment to the EPBD expands the scope of inspection to also include the ventilation part of
combined heating and ventilation systems.
For those Member States which already have inspection regimes in place, the scope of the heating system itself
should have already been defined in the context of transposition. In accordance with Article 14(1) of the EPBD,
it must include all accessible parts, such as the heat generator, control system and circulation pumps.
The EPBD also requires the inspection of the ventilation in combined heating and ventilation systems. Since this
is a new requirement, Member States should define the types of systems that will now be considered as
The notion of combined heating and ventilation systems should be understood as including the following
categories:
(a) Type 1: ventilation systems connected to the heating system. These are systems where the ventilation
system is composed of one or more air handling units (AHUs) delivering treated air to the heated space(s)
and where these AHUs are connected to one or more heat generators in order to use its heat to treat the
air. Examples of this type of system: boiler + AHU + terminal units (fan coils/fan convectors/radiators) or
boiler + variable air volume system;
(6) Such information is part of the product information required under the different Ecodesign regulations for heating and cooling products.
(b) Type 2: ventilation systems coordinated with the heating system. These are systems where there are one or
several air handling units delivering treated air to the heated space(s). The ventilation system is connected to
an independent heat source (e.g. dedicated boiler or heat pump) or uses an internal heat source (e.g.
electrical resistance). Space is heated mostly by a system that uses a different heat source. Even though the
heating and ventilation systems do not share heat sources, they operate in an integrated and coordinated
way (e.g. in terms of schedules, flow temperatures or flow rates). Examples of this type of system: rooftop
units (variable refrigerant volume or variable refrigerant flow) + AHUs;
(c) Type 3: ventilation systems independent from the heating system. These are systems where the ventilation
system is completely independent from the heating both in terms of heat source and operation. Examples
of this type of system: extract-only systems, supply and extract systems (without pre-heating).
Type 1 systems should be considered as combined heating and ventilation systems. This means that the
requirements of the EPBD apply (recital 35 of Directive (EU) 2018/844 helps establish this). Regardless of the
share of heat used by the ventilation system, both the heating and the ventilation system are fully involved in
the delivery of the heat within the building. This type of system requires careful integration between ventilation
and heating to adequately provide for the indoor environment in the most efficient way, particularly under
typical or average operating conditions. Inspections carried out on such systems are a good opportunity to
identify ways to save energy at a reduced cost (low hanging fruit).
Type 2 systems should also be considered as combined heating and ventilation systems. This is mainly because
of the need to adequately integrate the operation of the heating and ventilation systems. Similarly to Type 1
systems, an inspection is a good opportunity to identify ways to save energy at a reduced implementation cost.
Type 3 systems should not be considered as combined heating and ventilation systems. The heating system and
the ventilation system should be dealt with as individual and separate systems for the purposes of the EPBD.
In general, Type 1 and Type 2 systems are more common in non-residential buildings (such as offices, shopping
centres, etc.), whereas Type 3 systems are more common in residential buildings.
The effective rated output of a combined heating and ventilation system should be the sum of the effective
rated output of the different heat generators installed in the system (7).
The calculation of the effective rating of a system depends on the type of system. In Type 1 and Type 3
systems, the size of the heat generator is the determining factor. In Type 2 systems, the size of the heat
generator should be added to the size of the separate heat generator in the ventilation system (e.g. electric
heaters, solar thermal panels, etc.). This is because the heating capacity of both elements is used to compensate
for the heat losses in the treated space.
The EPBD does not specify to what extent the inspection applies to the air management and treatment aspects
of the system (such as ductwork, dampers or air filters). However, it would be good practice that the
independent expert still includes them in the inspection, at least to a certain degree, based on the accessibility
of the system and the energy-saving opportunities available. In practice, in a combined heating and ventilation
system, the different parts of the system may be located together or in close proximity. Since the inspector is
physically visiting the building, the added workload and cost are limited, while the opportunities to save energy
are good.
2.3.2.4. C om bin e d he atin g an d ai r- co n d it i oni n g an d vent i la ti on syst ems (Ar t i cl e 1 4 an d 15 of t he

EP B D)
It is common for a ventilation system to be connected to both the heating and the air-conditioning system.
In Member States that have decided to implement inspections for both heating and air-conditioning systems,
the ventilation could be subject to a double inspection (once with the heating system and once more with the
air-conditioning system). This scenario of double inspections should be avoided to limit the burden on building
and users.
(7) For example: boiler, heat pump, electric resistance, solar thermal panels, etc. This should be taken into consideration when establishing
whether a system falls above or below the 70 kW threshold for inspections.
Combined heating and air-conditioning and ventilation systems should preferably be inspected in a single visit
by an expert qualified to inspect both. Failing that, it is recommended that the ventilation system is inspected
by an expert qualified to carry out inspections of air-conditioning systems.
In Member States that have decided to implement inspections for one type of system and alternative measures
for another, the risk of double inspection does not exist. However, the inspection should ensure that the heating
or cooling cycle in the ventilation system do not fight each other.
To establish whether a system is over or under the 70 kW threshold, the respective heating and cooling
effective rated outputs should be considered separately. For example, a combined heating and air-conditioning
system with a heating rated output of 50 kW and a cooling rated output of 30 kW would be below the
threshold for both heating and air-conditioning inspections. A combined system with a heating rated output of
80 kW and a cooling rated output of 30 kW would be over the threshold for heating inspections, and below
the threshold for air-conditioning inspections.
The reason for this separate treatment is that the EPBD treats heating and air-conditioning systems separately
(Article 14 and Article 15, respectively). There are no provisions in the EPBD that treat such systems together.
Consequently, even though in practice such combined systems may well exist, according to Article 14 and 15
of the EPBD, they nonetheless must be treated separately, with their respective inspection requirements,
reporting obligations, periodicity, certification of inspectors, etc.
2.3.2.5. He a t p u m p s an d ro o f top u n it s ( A r ti cle 2( 18 ), 1 4 a nd 1 5 of the EPBD )
Article 2(18) of the EPBD defines heat pumps as ‘a machine, a device or installation that transfers heat from
natural surroundings such as air, water or ground to buildings or industrial applications by reversing the
natural flow of heat such that it flows from a lower to a higher temperature. For reversible heat pumps, it may
also move heat from the building to the natural surroundings’. Heat pumps are therefore capable of acting as
generators for both heating and air-conditioning systems, although in some applications they may provide only
one or the other function. Because of this capacity to provide both heating and cooling, heat pumps could fall
under both Article 14 and Article 15.
If a heat pump is used as the heat generator in a system that provides only heating, then the system should fall
under Article 14. For example, this would be the situation of a heat pump generating heat for heating and
domestic hot water.
If a heat pump is used as the heating or cooling generator in a system that provides both heating and air
conditioning, then the system should fall under Article 15.
Rooftop units are a special category of heat pump and are commonly used in relatively large non-residential
buildings. They work as heat pumps and have the added capability of providing heating and cooling simultan
eously. They should always be considered as falling under Article 15.
2.3.2.6. Pe rfor m an c e un d er t y p i c a l or a vera ge oper ati n g cond iti ons (R ec i tal 3 6 , A r ti c le 1 4 (1 )

a nd 1 5( 1 ) o f t he EP B D )
Before the amendment, recital 26 of the EPBD stated that ‘regular maintenance and inspection of heating and
air-conditioning systems by qualified personnel contributes to maintaining their correct adjustment in
accordance with the product specification and in that way ensures optimal performance from an environmental,
safety and energy point of view’ and Article 14(1) stated that the inspection must include an assessment of the
boiler size compared with the requirements of the building.
With the amendment, the EPBD refers not only to the boiler, but to the system as a whole and in particular the
heat generator. Therefore, there is a greater emphasis on normal operating conditions. Recital 36 of Directive
(EU) 2018/844 indicates that it is preferable for inspections to focus on real-life use conditions, with varying
operating conditions that may require only a part of the nominal output capacity. This is because only a small
fraction of the energy consumption in a heating system takes place under conditions approaching design
conditions. Instead, the greatest proportion of energy is consumed when the system is running under ‘part load’
(i.e. when the system does not operate at full capacity). Therefore, the objective should be to ensure that the
system can perform efficiently and effectively under all conditions.
Under Article 14(1) of the EPBD, the inspection of heating systems includes, where relevant, an assessment of
the system's capability to optimise its performance under typical or average operating conditions. Member
States must update their legislation to ensure that this performance assessment is included, where relevant, in
the scope of inspections.
The operation of a heating system depends on many factors, including: outdoor conditions, building character
istics, building use and system characteristics. It is complex and possibly impractical to define typical or average
operating conditions for all possible combinations.
Systems rarely operate at full capacity, operating instead at what is known as part load. It is possible to provide
some rough guidelines on typical or average operating conditions based on the percentage of system output
over a given period. For example, as a rule of thumb, it could be said that typical or average conditions result
in a system operating between 20 % and 40 % of its design output over a period of time (e.g. a day). However,
this gives an incomplete picture. Even in a typical or average day, the most efficient settings for a system may
differ substantially throughout the day. As a result, it is not recommended that typical or average operating
conditions are defined as a function of system load in national legislation.
It is also possible to provide some general guidelines for defining typical or average operating conditions based
on outdoor temperature and specify how these differ from design conditions. For example, if design conditions
were set at – 10 °C, one could define typical or average operating conditions as a function of a less demanding
outdoor temperature (e.g. between 5 and 10 °C) or based on the temperature difference between inside and
outside (e.g. a 60 % temperature difference between inside and outside in the design conditions). However, the
same system may behave completely differently depending on the building in which it is installed, how it is
used, and the weather at a specific moment. As a result, it is not recommended that typical or average
operating conditions are defined or tabulated as a function of outdoor conditions (e.g. standard day) in national
legislation. The same can be said for building characteristics or building usage (e.g. 80 % occupancy).
The technical details on how to carry out the assessment can be set out in the training or documentation
provided to inspectors.
The need to account for the operation of systems under typical or average conditions is well understood by
technical bodies and associations. There are a number of published manuals and guidelines that address
performance of systems under part load (as opposed to full load or design load). It is recommended that
Member States follow or use these guidelines when developing their training material (8).
2.3.2.7. Ele c troni c mon itor in g an d e f fe c tive co ntro l f u nc ti on a li ti es in r esi dent i al bu il di ng s

( Ar ti cl e 1 4( 5 ) an d 15( 5) of th e EP B D)
The installation of electronic monitoring and effective control functionalities in residential buildings can lead to
significant energy savings, improve the management of the indoor environment and be beneficial to building
owners and users. This is particularly the case for large buildings, where access to system controls and system
information is limited for most users.
(8) E.g. the guide to carrying out inspections of air-conditioning systems developed by the Commission-funded iSERV project (‘Inspection
methodology — Air conditioning maintenance tasks — Identifying energy services’ http://www.iservcmb.
info/sites/default/files/results/Physical-Inspections/Public-report-Methodology-for-HVAC-System-Inspections.pdf) or the technical paper
on improving the performance of heat pumps in working conditions from the REHVA association (‘Capacity control of heat pumps’
https://www.rehva.eu/publications-and-resources/rehva-journal/2012/052012/capacity-control-of-heat-pumps-full-version.html).
Article 14(5) of the EPBD on electronic monitoring and control functionalities covers only residential
buildings. According to this Article, it is up to Member States to decide whether they will opt to establish
requirements to ensure that residential buildings are equipped with such functionalities, introducing them into
their national transposition measures.
Article 14(5)(a) of the EPBD concerns the provision of continuous electronic monitoring. Systems that do this
measure their own energy consumption and use it to calculate system performance, which should be made
available to the system owner or manager. If system performance falls significantly or if there is a service need,
the system notifies the system owner or manager. The system should operate on a continuous basis, as opposed
to a periodical basis (for example every 3 months).
Article 14(5)(b) of the EPBD concerns the provision of effective control functionalities to ensure optimum
energy generation, distribution, storage and use. These control functionalities should take into consideration the
scenario of a multi-apartment building with a single heating system, where the individual users would only be
able to control the system within the boundaries of their building unit.
Article 14(5) of the EPBD concerns the optional introduction of both functionalities in residential buildings.
Unlike Article 14(1) and Article 14(4) of the EPBD, which provide for specific thresholds that trigger the
mandatory obligations to be reflected in national transposition measures, Article 14(5) has an optional
character (‘may’) and therefore does not include details on thresholds for effective rated output and implicitly
covers all residential buildings regardless of their size. It is recommended that Member States take into consider
ation the differences in system and building type when setting out requirements.
2.3.2.8. E xempt io n f r om in s pec ti on s ( A r ti cl e 14 (2), 14 (4), 14(5 ), 1 5(2 ), 1 5 (4 ), an d 1 5 (5 ) of t he

E PBD)
Before the amendment, the Directive allowed the possibility for Member States to reduce the frequency of
inspections or lighten them as appropriate where electronic monitoring and control systems were in place.
The amendment to the EPBD introduces exemptions if:
(a) the technical building system is covered by an energy performance contract (or similar) or is operated by
a utility or a network operator (exemption laid down in Article 14(2)); or
(b) the heating system has specific control and monitoring features as defined in Article 14(4) and (5)
(exemption laid down in Article 14(6)).
(a) Technical building systems covered by energy performance contracts (or similar) (Article 14(2) and 15(2) of
the EPBD)
Article 14(2) of the EPBD excludes from inspections those technical building systems that are explicitly covered
by an agreed energy performance criterion or a contractual arrangement specifying an agreed level of energy
performance improvement. An energy performance contract as defined in Article 2(27) of the EED fulfils these
requirements.
Buildings operated by a utility or network operator that are therefore subject to performance monitoring on the
system side are also exempt.
The exemptions specified in Article 14(2) of the EPBD only apply if the overall impact of the approach is
equivalent to the impact resulting from the application of inspections under Article 14(1) of the EPBD.
The EPBD does not indicate how this equivalence should be established. One possibility could be to determine
whether the technical building system is already undergoing a regular inspection as part of the contract or
agreement, and that this is similar in nature to inspections under Article 14(1). If the technical building system
undergoes such inspection, an exemption from the requirements set out in Article 14(1) could be established.
It is safe to assume that most energy performance contracts or agreements already include some level of regular
inspection. However, the full extent of such inspections may not be completely in line with the requirements of
the EPBD. Under normal circumstances, it would not be feasible for Member States to individually check each
energy service contract to determine whether they are equivalent or not. In addition, since such contracts may
be signed by two private companies, the terms and conditions may differ widely between contracts. As a result,
Member States may decide to streamline and normalise such contracts.
Article 2(27) of the EED defines energy performance contracting as ‘a contractual arrangement between the
beneficiary and the provider of an energy efficiency improvement measure, verified and monitored during the
whole term of the contract, where investments (work, supply or service) in that measure are paid for in relation
to a contractually agreed level of energy efficiency improvement or other agreed energy performance criterion,
such as financial savings.’
Amongst other measures, the EED also introduces provisions on energy services. Article 16 of the EED requires
Member States to, where necessary, develop certification and/or accreditation schemes.
Article 18 of the EED requires Member States to support the public sector by providing model contracts for
energy performance contracting. Under Article 18 of the EED, these model contracts must include at least the
items which are listed in Annex XIII.
For the purposes of the equivalence requirements indicated in Article 14(2) of the EPBD, energy performance
contracts signed by an accredited/certified company which adequately follows a model such as the one specified
by Annex XIII to the EED could be considered to have an equivalent impact to that of inspections.
Member States would therefore need to have a publicly available list of accredited or certified companies
together with publicly available model contracts.
For the purposes of record keeping, the status of a system exempt from inspections due to an energy
performance contract should be recorded in the inspection database. This should include a reference to the
duration of the contract and, therefore, the period for which the exemption applies.
In Member States where model contracts and a list of accredited or certified companies are not publicly
available, authorities will need to check contracts individually to verify whether there is equivalence or not. The
contracting parties could facilitate this by adding an annex to their contract, clearly and unequivocally
indicating at least the following points listed in Annex XIII to the EED:
(a) guaranteed savings to be achieved by implementing the measures of the contract;
(b) duration and milestones of the contract terms and period of notice;
(c) reference date to establish achieved savings;
(d) obligation to fully implement the measures in the contract and documentation of all changes made during
the project;
(e) clear and transparent provisions on measuring and verifying the guaranteed savings achieved, quality checks
and guarantees (ideally with reference to national or EU standards).
Member States may find it useful to refer to existing standards (9), guidelines (10) and contract models (11).
(b) BACS, continuous electronic monitoring and effective control functionalities (Article 14(4), 14(5), 15(4)
and 15(5) of the EPBD)
Article 14(6) of the EPBD exempts from the inspections provided for in Article 14(1) those buildings that
comply with the requirements of Article 14(4) and Article 14(5).
Under Article 14(4) of the EPBD, non-residential buildings with heating or combined heating and ventilation
systems with an effective rated output of over 290 kW are required to have BACS installed by 2025, wherever
technically and economically feasible (12).
(9) e.g. Italian standard UNI CEI 11352, which includes general requirements, checklists for verifying the organisation's requirements and
the contents of the service offer, and a checklist and specific references to Annex XIII of the EED, or Spanish standard UNE 216701
‘Clasificación de proveedores de servicios energéticos’, for the classification of providers of energy services.
(10) e.g. the Guide for the drafting of documents of administrative and technical clauses for energy performance contracting with guaranteed
savings subject to harmonised regulation (service contracts). It is a guide for tendering procedures related to energy performance
contracts (available at http://icaen.gencat.cat/web/.content/10_ICAEN/18_actuacio_internacional/Enllacos/Arxius/20180717_EPC_
Public_Tendering_GUIDE.pdf).
(11) e.g. the Spanish ‘Modelo de contrato de rendimiento energético con inversión adaptado a la le 9/2017 y a la guía de tratamiento
estadístico de Eurostat’, and in Slovenia, the ‘Oris Vzorca Pogodbe’ (available at http://www.energetika-portal.
si/podrocja/energetika/energetska-prenova-javnih-stavb/projektna-pisarna/).
(12) See Sections 2.2.4, 2.3.3.1 and 2.3.3.3(b).
Non-residential buildings with systems that have an effective rated output between 70 kW and 290 kW are not
affected by the requirement to have BACS installed, although Member States may decide to lower the threshold
and require heating systems with smaller systems to also have BACS installed. Buildings that fall under the new
requirement and have BACS installed should also be exempt from inspections.
Individual building owners may decide to install a BACS that is in compliance with the substantive
requirements set out in Article 14(4) of the EPBD. In such cases, Member States may decide to exempt those
buildings even if their systems do not reach the 290 kW threshold. If Member States decide to do this, they
should however include it in their transposition measures for the EPBD.
Article 14(5) of the EPBD introduces the possibility for Member States to ensure that residential buildings are
equipped with continuous electronic monitoring and effective control functionalities. In a similar scenario to
BACS, some of these elements may already be present in the market in some form or other. However, they
might not completely fulfil the requirements of Article 14(5) of the EPBD. Therefore, the definition of these
systems and how they are introduced in national legislation should clearly address the differences.
As indicated in recital 39 of Directive (EU) 2018/844, Member States may choose to continue applying the
inspection regimes which are already in place. Nevertheless, the exemptions applicable under Article 14(2) and
Article 14(6) should still be considered.
2.3.2.9. Al te r n at i ve m eas u re s
Article 14(3) of the EPBD sets out the provisions and obligations for Member States to opt to take alternative
measures concerning heating systems or combined heating and cooling systems. In such cases, Member States
are required to ensure that the measures have an overall impact that is equivalent to the impact that would
have been achieved had an inspection scheme been in place, as set out in Article 14(1). This means that
a baseline of what would be achieved under the measures set out in Article 14(1) should be calculated, in order
to know whether the alternative measures will have the same impact.
There are four scenarios that reflect the different situations that Member States may encounter when applying
alternative measures.
(a) Scenario 1: Member States already applied alternative measures before the amendment and decide to
continue to apply these measures
The amendment to the EPBD does not substantially change the provisions on alternative measures to
inspections. However, they are affected by the amendments to the provisions in the other paragraphs of
Article 14. Those provisions have different effects on Article 14(3) of the EPBD, as described in the subsequent
paragraphs.
The introduction of the new threshold (70 kW) in the EPBD means that Member States that opt to apply
alternative measures must apply these measures in relation to the systems that are covered by the new
increased threshold. This could result in a reduction in the number of systems to be covered by the alternative
measures and, consequently, might result in a reduction in the energy savings achieved.
In contrast, the new requirement to inspect the ventilation part of combined heating and ventilation systems
should increase the impact in terms of energy savings per inspection. Member States should consider this when
setting the baseline that they should achieve with their alternative measures.
The provisions on exemptions specified in Article 14(2) of the EPBD (exemptions of systems covered by energy
performance criteria) and Article 14(6) (exemptions of systems with BACS) could also result in a reduction in
the number of inspections.
Under Article 14(5) of the EPBD, Member States may set out requirements related to electronic monitoring and
enhanced control functionalities in residential buildings. Under Article 14(6) of the EPBD, buildings covered by
systems providing those functionalities would be exempt from inspections. As a result, Member States that
apply alternative measures would have to exclude this group of buildings if they decide to apply such
requirements.
The range of measures that Member States may take in order to apply Article 14(3) of the EPBD has not
changed with the amendment.
In view of the above, Member States that decide to continue applying alternative measures under the EPBD are
under an obligation to ensure that these measures have an overall impact that is equivalent to the impact that
would have been achieved had an inspection scheme been in place, as set out in the Article 14(1). This requires
that the baseline of what would be achieved under an inspection regime set up under Article 14(1) be re-
calculated in light of the Article 14(1), as well as in view of the above-mentioned amendments and
requirements in the EPBD. Such a re-calculation will enable the Member State concerned to know whether the
alternative measures that it has in place have the same impact as an inspection would or if they fall short, and
to modify the measures accordingly in order to ensure equivalent impact.
Member States should include the results of this process in the report documenting equivalence that must be
submitted, in accordance to Article 14(3), to the Commission before the alternative measures are applied by the
Member State.
(b) Scenario 2: Following transposition, Member States that already applied alternative measures decide to
change the nature of their alternative measures
This scenario reflects a situation where, following the initial transposition of Article 14(3) into national law,
a Member State decides to change the scope and/or nature of the equivalent alternative measures that it has put
in place. For example: a Member State applying measures A, B and C decides to change them and start applying
measures C, E and D.
As explained under Scenario 1 above, Article 14(3) of the EPBD states that requires Member States to notify the
Commission of their intention to take alternative measures before the alternative measures are applied. In order
to do so, according to Article 14(3), a Member State must submit to the Commission an additional report that
shows that the impact of the amended alternative measures is equivalent to the impact of the inspection
schemes referred to in Article 14(1). The Commission will then evaluate this additional report to ensure that
the Member State in question continues to achieve an equivalent level of savings.
(c) Scenario 3: Changes to the building stock affect the scope of Article 14(1) and consequently have an impact
on the scope of the alternative measures
As the building stock changes and evolves, the scope of an inspection scheme as set out under Article 14(1)
will change accordingly. For example, as more and more Nearly Zero-Energy Buildings (NZEBs) enter the
market, it is likely that the proportion of buildings with systems over 70 kW will decrease. In addition,
buildings with BACS installed (see Chapter 2.8) will be exempt from inspections. Over time, these two elements
could have a significant impact on the scope of inspection schemes and therefore on any equivalent alternative
measures that Member States already have in place.
Member States may for example identify such changes through a standalone study or through ongoing
evaluation of the alternative measures scheme. They may also notice such changes as part of the integrated
national energy and climate progress report which, according to Article 17 of Regulation (EU) 2018/1999 of
the European Parliament and of the Council (13) (‘Regulation (EU) 2018/1999’), must be submitted every
2 years.
If the changes in national building stock are such that the scope or intensity of alternative measures is no
longer equivalent to those of an inspection regime, then the Member State in question should adapt the
alternative measures. Member States can do this either by amending the existing measures or introducing new
ones.
Article 14(3) of the EPBD requires Member States to notify the Commission of their intention to take
alternative measures before they apply the alternative measures. Changes in the building stock might require
a Member State to amend its equivalent measures; in such cases, according to Article 14(3) of the EPBD, the
Member State in question must notify the Commission of any changes before the amended alternative measures
are applied.
(13) Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the Governance of the Energy
Union and Climate Action, amending Regulations (EC) No 663/2009 and (EC) No 715/2009 of the European Parliament and of the
Council, Directives 94/22/EC, 98/70/EC, 2009/31/EC, 2009/73/EC, 2010/31/EU, 2012/27/EU and 2013/30/EU of the European
Parliament and of the Council, Council Directives 2009/119/EC and (EU) 2015/652 and repealing Regulation (EU) No 525/2013 of the
European Parliament and of the Council (OJ L 328, 21.12.2018, p. 1).
According to Article 14(3) of the EPBD, Member States must notify the Commission by submitting a report
that shows that the impact of the amended alternative measures is equivalent to the impact of the inspection
schemes referred to in Article 14(1). The Commission will then evaluate this additional report to ensure that
the Member State in question continues to achieve an equivalent level of savings.
(d) Scenario 4: Member States opt to take alternative measures for the first time
This scenario concerns a situation where a Member State that had so far used inspection schemes decides to
switch to alternative measures for the first time.
Article 14(3) of the EPBD requires Member States to notify the Commission of their intention to use this
option before they apply the alternative measures. In order to do so, according to Article 14(3) of the EPBD,
Member States must submit to the Commission a report which shows that the impact of the alternative
measures is equivalent to the impact of the inspection schemes referred to in Article 14(1). The Commission
will then evaluate the report to ensure that the Member State in question will in fact achieve an equivalent level
of savings.
(e) Submission of reports
According to Article 14(3) of the EPBD, a Member State must submit an equivalence report to the Commission
before they apply any alternative measures. The Commission will evaluate the report and take appropriate
action vis-à-vis the Member State.
Under Article 14(3) of the EPBD, Member States must also submit any equivalence report as part of their
integrated national energy and climate plans (NECPs). Under Article 17 of Regulation (EU) 2018/1999, each
Member State is to submit this at the next appropriate step of the reporting cycle (14). If the timing of the
reporting cycle fits in with the timing of introducing the new or amended alternative measures, the Member
State can simply submit the equivalence report as an annex to the NECP.
If the timing does not fit in the way described above, the Member State must in any case, under Article 14(3)
of the EPBD, submit their report to the Commission before the measures are put in place. Member States can
submit their report directly to DG ENER, although they must, under Article 17 of Regulation (EU) 2018/1999,
also submit it during the next NECP cycle.
2.3.3. Requirements related to the installation of self-regulating devices and BACS (Article 8(1), 14(4) and 15(4) of the EPBD)
2.3.3.1. B ui l di ng a u tom a tion an d c on tr ol system s ( BACS) (Ar ti cl e 2 (3a ), 14 (4) a nd 1 5 (4) of t h e

E PBD )
Building automation and control systems (BACS) are a widely known and used concept whose meaning can
vary significantly. Before addressing BACS requirements, it is important to underline what this term refers to in
the specific scope of Articles 14 and 15 of the EPBD.
First of all, a BACS is a system that complies with the definition given in Article 2(3a) of the EPBD, which reads
as follows (15):
‘3a. “building automation and control system” means a system comprising all products, software and
engineering services that can support energy efficient, economical and safe operation of technical building
systems through automatic controls and by facilitating the manual management of those technical building
systems;’
(14) Member States are required to submit their first final NECP by the end of 2019. The NECP will then be updated in 2023 (draft) and 2024
(final update). From March 2023 and then every 2 years, Member States must also submit a progress report on their NECP.
(15) This definition is close to the one given in standard EN 15232.
In addition, a BACS within the scope of Articles 14 and 15 of the EPBD are required to have all of the
capabilities listed in Articles 14(4) and 15(4) of the EPBD, which read as follows:
(a) ‘continuously monitor, log, analyse and allow for adjusting energy use;
(b) benchmark the building's energy efficiency, detect losses in efficiency of technical building systems, and
inform the person responsible for the facilities or technical building management about opportunities for
energy efficiency improvement; and
(c) allow communication with connected technical building systems and other appliances inside the building,
and be interoperable with technical building systems across different types of proprietary technologies,
devices and manufacturers.’
Building automation and control systems that are installed in non-residential buildings under the obligations of
Articles 14(4) and 15(4) of the EPBD must both comply with the definition of Article 2(3a) of that Directive
and include the capabilities listed above. Those capabilities should be ensured at least for the technical building
systems that fall under the scope of Articles 14 and 15 of the EPBD: heating systems, air-conditioning systems,
combined heating and ventilation systems, combined air-conditioning and ventilation systems.
Although automation and control systems have been common for some categories of buildings (e.g. non-
residential), most buildings do not have such advanced capabilities and the ones that must comply with the
above obligations will therefore require upgrades, which can be a significant undertaking.
It is therefore of particular importance that the interested parties (e.g. facility managers of buildings that must
comply with the obligations) are made aware of the fact that the scope of the requirements goes beyond what
such systems usually cover.
2.3.3.2. S e l f-r eg u l at i n g d e v i ce s ( A r ti c le 8 ( 1) of the EPBD )
The EPBD refers to ‘self-regulating device’ without giving any specific definition of what it is. However,
Article 8(1) of the EPBD clarifies that such a device must allow for the separate regulation of the temperature in
each room (or, where justified, in a designated zone) of the building unit. The devices installed as a result of the
implementation of these provisions should therefore:
(a) allow for the automatic adaptation of heating output depending on the indoor temperature (and optionally
additional parameters (16));
(b) allow for the regulation of heating output in each room (or zone), in accordance with the heating settings
of the considered room (or zone).
This means in particular that:
(a) any solution based on the manual regulation of heating output would not fulfil the requirements, even if
the adjustment can be performed at room (or zone) level;
(b) any solution that allows for the automatic regulation of temperature but not at room (or zone) level, e.g.
automatic regulation at dwelling-level, would not fulfil the requirements.
It is important to note that, regardless of the number or types of system(s) installed, what matters is that the
systems make it possible for users to adjust temperature settings and ensure that these settings are
respected (17).
(16) In this context, ‘automatic’ means that the device allows for the automatic regulation of heating output when ambient temperature
evolves based on pre-defined settings. Adjustment of the settings themselves, however, is generally manual and performed by users (e.g.
manual adjustment of temperature settings with a thermostatic radiator valve).
(17) For instance, where a building or building unit is equipped with more than one heating system, the requirement could apply to only one
of the systems, provided that the expected capability is ensured.
The following table gives some indicative examples of devices that fulfil the requirement for different types of
systems (18):
Table 2
Examples of self-regulating devices
Device Type of system Regulation capability
Thermostatic radiator Hydronic heating system and radiators Regulation of hot water flow in emitters
valve according to temperature setting
Room thermostat Hydronic heating system and surface Regulation of hot water flow in the sur
heating (e.g. floor heating) face heating thanks to the room's mixing
valve
Fan coil unit thermostat Hydronic heating/cooling system Control of hot/cool water- and air-flow
based on temperature setting
Individual thermostat Standalone heaters or air-conditioners Control of heat output depending on

temperature setting
(a) Heating, air conditioning, or both?
The second and third subparagraphs of Article 8(1) of the EPBD refer to technical building systems in the broad
sense, i.e. as in the definition given in Article 2 of the EPBD. As regards the specific provisions on self-
regulating devices (subparagraph 3), the text does not specify which type of system is concerned but does refer
to regulation of temperature, which applies both to heating and systems for space cooling.
Therefore, not only heating systems but also air-conditioning systems and systems for space cooling should
meet the requirements related to self-regulating devices.
In particular, the reference to ‘heated zone’ in the text should not be interpreted as implicitly restricting the
requirements to only heating systems.
However, the focus of these provisions is effectively on heating, as the vast majority of air-conditioning/cooling
systems are already equipped with room- or zone- level monitoring and control.
In addition, when heat generators are replaced in existing buildings, the requirement to install self-regulating
devices should apply only to heating systems (19).
Also, the third subparagraph of Article 8(1) of the EPBD does not require the installation of self-regulating
devices in cases where cooling generators are replaced in existing buildings. However, Member States may
consider establishing such an additional requirement (20), as it would be consistent with the general objective of
these provisions: to ensure adequate regulation capability and avoid wasting energy.
The following table summarises the different cases that may arise.
(18) Self-regulating devices can be electronic or not (e.g. a thermostatic radiator valve); what matters is the self-regulation capability, not the
technology itself.
(19) This means in particular that when heat generators are replaced in an existing building that is equipped with a system for space cooling
that has no self-regulation at room- or zone-level, the requirement to install self-regulating devices at room- or zone-level would not
extend to the system for space cooling.
(20) Most space cooling systems will have the self-regulation capability anyway but this is not a requirement under Ecodesign regulations.
Table 3
Cases that should trigger the requirement to install self-regulating devices
Should requirement to install self-regulating

New or existing building Type of intervention
devices apply?
New Installation of heating system Yes
New Installation of space cooling system Yes
Existing Replacement of heat generators Yes, only for heating system
Existing Replacement of cool generators Up to Member State
(b) Room- or zone-level?
The principal requirement is the possibility to regulate temperature at room-level. The installation of self-
regulating devices at zone-level, however, has to be justified.
A ‘room’ is to be understood as a part or division of a building enclosed by walls, floor and ceiling.
A ‘heated zone’ is to be understood as a zone of a building or building unit, located on a single floor, with
homogeneous thermal parameters and corresponding temperature regulation needs (i.e. the equivalent of
a ‘thermal zone’, a common concept in the scope of energy performance calculation).
Here are two examples of cases (21) where it may be justified to consider zone-level instead of room-level for
the application of requirements:
(a) adjacent offices with identical indoor environment requirements in an office building;
(b) adjacent rooms/spaces that are not physically separated one from the other (e.g. open-plan kitchen and
living room in an apartment).
The assessment of the most appropriate scope of the regulation (room or zone) will generally depend on the
design and intended use of the specific building or building unit, and of the spaces therein. In making this
assessment, the main parameter to consider will generally be whether several rooms can share the same indoor
environment requirements and, therefore, could be merged into a single zone (from a temperature regulation
perspective). Such cases should be well justified.
However, taking into account certain national, regional or local specificities, Member States may allow zone-
level temperature regulation for some categories of buildings or building units, when there is sufficient justifi
cation for doing so. In such cases, Member States should clarify the categories of buildings or building units
targeted and the national, regional or local specificities considered. They should also justify (22) allowing an
upfront deviation from the principal requirement for these categories of buildings or building units.
2.3.3.3. W he n d o th e o bli gati on s ap pl y? ( Ar tic l e 8 (1 ) , 1 4(4 ) an d 1 5(4 ) of t he E PBD )
(a) Self-regulating devices (Article 8(1) of the EPBD)
The text requires that new buildings are equipped with self-regulating devices. It requires the same for existing
buildings when heat generators are being replaced.
(21) These are indicative examples. There can be other cases where zone-level regulation is justified.
(22) Such justification can, for example, be based on scientific studies whose results would back the assessment that zone-level regulation is
preferable in the considered cases.
The obligations apply to all types of buildings and all types of systems unless meeting them is not technically
and economically feasible (see section (b)).
Article 2(15b) of the EPBD defines a ‘heat generator’ as follows:
‘“heat generator” means the part of a heating system that generates useful heat using one or more of the
following processes:
(a) the combustion of fuels in, for example, a boiler;
(b) the Joule effect, taking place in the heating elements of an electric resistance heating system;
(c) capturing heat from ambient air, ventilation exhaust air, or a water or ground heat source using a heat
pump;’
It is important to note that this definition does not differentiate between heat generators that are distinct from
heat emitters (e.g. boiler and radiators) and those that are integrated with the heat emitter in a standalone
heating system (e.g. electric resistance heaters). This means that the obligations (on self-regulation) should also
apply in the latter case (i.e. when a standalone heating system is replaced in an existing building).
When buildings are equipped with multiple heat generators, situations may arise where only a part of the heat
generators is replaced. In such situations, the requirement to install self-regulating devices should also apply,
where technically and economically feasible. In particular, if several heat generators are coupled together and
serve the same space, and at least one of the heat generators is replaced, then the requirement applies. If
a building is equipped with several heat generators that are independent and serve different spaces, Member
States may allow the requirement to apply only to the space(s) served by the replaced heat generator(s).
Where existing buildings are connected to district heating and are not equipped with any heat generators at
building level, the requirement to install self-regulating devices would normally apply when district heat
generators are replaced. In some cases, this could lead to difficulties, e.g. related to ownership (23) or to
economic feasibility (24). In such cases, Member States may investigate alternative paths to ensure that self-
regulating devices are installed, for instance:
(a) requiring that self-regulating devices are installed when heat exchangers in buildings are replaced;
(b) drawing up and implementing a roadmap for the progressive deployment of self-regulating devices, aiming
at full coverage of buildings but spreading the costs over a sufficient time period.
The installation of a new heating system in an existing building or building unit that was already equipped with
a heating system (e.g. installation of a central heating system that replaces individual heating systems in
a building) should trigger the requirement to install self-regulating devices, as it implies the replacement of heat
generators.
The installation of a heating system in a construction that was formerly not a building within the meaning of
the EPBD but which, for example subsequently, due to restoration works, becomes a building in the sense of
the EPBD, should also trigger the requirement to install self-regulating devices.
(b) BACS (Article 14(4) and 15(4) of the EPBD)
The provisions on installing building automation and control systems apply to all (i.e. new and existing) non-
residential buildings with heating, air-conditioning, combined heating and ventilation, combined air-
conditioning and ventilation systems with an effective rated output over 290 kW.
The 290 kW threshold applies to each system individually, i.e. the obligations apply in all of the following
cases, according to Article 14(4) and 15(4):
(a) when the effective rated output of the heating system is above 290 kW;
(23) When the district heating system and buildings connected to it are under different ownerships.
(24) When a high number of buildings is impacted by the requirement at the same time, which could lead to disproportionate costs. Such
cases should however be covered by the economic feasibility conditions defined by Member States.
(b) when the effective rated output of the combined heating and ventilation system is above 290 kW;
(c) when the effective rated output of the air-conditioning system is above 290 kW;
(d) when the effective rated output of the combined air-conditioning and ventilation system is above 290 kW.
Additional clarifications on how to determine effective rated output are given in section 2.3.2.2.
2.3.4. Technical, economic and functional feasibility (Article 8(1), 14(4) and 15(4) of the EPBD)
The notion of ‘feasibility’ is relevant for:
(a) the application of system requirements under Article 8(1) of the EPBD, which states that system
requirements must be applied ‘in so far as these are technically, economically and functionally feasible (25)’; and
(b) the installation of self-regulating devices (Article 8(1)) of the EPBD and BACS (Article 14(4) and 15(4) of
the EPBD), as related requirements apply only ‘where technically and economically feasible’.
Note that it is for Member States to detail in which specific cases meeting the requirements is not feasible from
a technical, economic and/or functional perspective. Member States should ensure that these cases are clearly
identified, framed and justified (26).
The interpretation of technical, economic and functional feasibility should not be left to the sole judgement of
interested parties (e.g. owners or system installers (27)). The conditions under which feasibility is evaluated
should be defined at Member State level or, where regional conditions affect only part of a Member State's
territory, at regional level. However, in the latter case, regional conditions should be defined in national transpo
sition measures. In all cases, these conditions should be documented (e.g. as part of technical guidelines) and
should apply uniformly on the national, or, where applicable, regional, territory. Finally, the non-application of
system requirements should be assessed using clear procedures established and supervised by public authorities.
These procedures may differentiate between different types of buildings, in particular to address specific types
for which technical, economic or functional feasibility is an issue.
One example is historical or listed buildings, which can have specific constraints that make it more difficult to
apply some of the requirements. In this context, note that compliance with these requirements would not, in
principle, alter the character or appearance of historical or listed buildings.
To avoid any doubt, also note that the requirements are also applicable to all categories of buildings for which
the Directive allows Member States to introduce derogations in the application of minimum energy
performance requirements (Article 4(2) of the EPBD).
Nevertheless, the specificities of certain buildings can be taken into account when evaluating the technical,
economic and/or functional feasibility of meeting the requirements. In exceptional cases, where the evidence
points to the conclusion that compliance with the requirements is technically, economically or functionally
impossible for a specific building, the requirements can be disregarded. Such a conclusion can only be reached
on a case-by-case basis, and Member States should not introduce systematic exemptions for any category of
buildings.
(25) This mention was already included before the amendment.

(26) It is recommended that Member States ensure the adequate involvement of stakeholders in defining conditions for technical, economic
and functional feasibility.
(27) Meaning that, in cases where such parties are responsible for assessing feasibility, their interpretation has to be supported by guidelines
and procedures provided by public authorities. This should also ensure a degree of consistency, supervision and control when applying
the guidelines and procedures.
The following table sets out how each type of feasibility can be interpreted and gives examples.
Table 4
Interpretation of technical, economic and functional feasibility
Type of feasibility (1) Meaning Examples
Technical feasibility There is technical feasibility when the Technical feasibility would be an issue if
technical characteristics of the system a system does not allow for the installa
and the building (or building unit) tion of the devices needed to comply
make it possible to apply the require with the requirements, for example if:
ments. There is no technical feasibility — for requirements on heat recovery for
when it is impossible to apply them ventilation systems, the inlet and ex
from a technical perspective, i.e. when haust are not located in the same
the system's technical characteristics areas;
prevent the requirements from being
applied. — for requirements on the insulation of
pipes, portions of pipes are not ac
cessible.
Economic feasibility Economic feasibility relates to the costs Economic feasibility can e.g. be calcu
of applying the requirements and lated based on:
whether: (i) these costs are proportion — a maximum ratio between the costs
ate with regard to the costs of the of applying the requirements and the
planned intervention (e.g. system up costs of the planned intervention (e.g.
grade); (ii) the expected benefits out heat generator replacement);
weigh the costs (2) taking into account
the expected lifetime of the system. — a maximum recovery period, taking
into account monetary benefits of ap
plying the requirements.
Functional feasibility (3) It is functionally not feasible to apply The application of system requirements
requirements if these would lead to may not be functionally feasible for
changes that would impair the opera example when:
tion of the system or the usage of the — applicable regulations (e.g. on safety)
building (or building unit), taking into contradict the requirements;
account the specific constraints (e.g.
regulations) that may apply to the sys — applying the requirements would re
tem and/or building. sult in a significant loss of usability
of the building or building unit (e.g.
substantial loss of building space).
(1) The two first rows (technical and economic feasibility) apply to system requirements in Article 8(1) of the EPBD, and to
requirements on the installation of self-regulating devices (Article 8(1)) and BACS (Article 14(4) and 15(4) of the EPBD),
while the third row (functional feasibility) applies only to system requirements in Article 8(1).
(2) This means that a cost-benefit assessment would be carried out. This cost-benefit assessment approach is probably the
most relevant, as applying the requirements will generally lead to the costs being recovered (in particular due to energy
cost savings).
(3) Applies only to system requirements in Article 8(1) of the EPBD.
(a) Additional considerations related to the technical and economic feasibility of installing self-regulating
devices
In the vast majority of cases, the question of technical and economic feasibility of installing self-regulating
devices will not apply to new buildings, as the need for temperature self-regulation at room (or zone) level can
be addressed in the design phase, which prevents technical barriers from appearing in subsequent steps and
ensures that related costs are optimal. One straightforward example of a case where it would not be technically
feasible to install self-regulating devices in a room or a zone is when this room or zone will not be heated (or
cooled).
For existing buildings, technical feasibility can be an issue where it is not possible to install self-regulating
devices without carrying out substantial alterations to the systems and/or to the building, which would
inevitably lead to prohibitive costs (this can e.g. be the case for some types of floor heating systems in existing
buildings).
Economic feasibility can be an issue for existing buildings as well, when the cost of installing the self-regulating
devices is excessive as compared to the cost of replacing the heat generator. When they choose to evaluate
feasibility based on costs, Member States should clarify how the costs are calculated and how they compare.
The two following approaches may be considered:
(a) Comparing the upfront costs of installing self-regulating devices with the costs of replacing the heat
generators and setting a threshold for the maximum ratio between the two. This approach is in line with
recital 21 of Directive (EU) 2018/844, which reads as follows:
‘The installation of self-regulating devices in existing buildings for the separate regulation of the
temperature in each room or, where justified, in a designated heated zone of the building unit should be
considered where economically feasible, for example where the cost is less than 10 % of the total costs of
the replaced heat generators.’
(b) Comparing the upfront costs of installing self-regulating devices with the expected energy cost savings
resulting from their installation and setting a threshold for the maximum cost recovery period (e.g. 5 years).
While both approaches are possible, the latter option should be preferred, as in the vast majority of cases the
initial costs will be recovered within a short period of time (typically 2 to 3 years).
Table 5
Possible interpretation of technical and economic feasibility for the installation self-
regulating devices
Can apply to
Type of feasibility How it can translate
New buildings Existing buildings
Technical feasibility The room (zone) has no heating/cool Yes (but rare) Yes (but rare)
ing.
The heating system makes it impossi No Yes (but not

ble to install self-regulating devices. frequent)
Economic feasibility The upfront costs are too high com No Yes (but not
pared to other costs. frequent)
The investment cannot be sufficiently No Yes (but rare)

recovered.
(b) Additional considerations related to the technical and economic feasibility of installing BACS
In the vast majority of cases, the question of whether installing self-BACS is technically and economically
feasible will not apply to new buildings, as:
(a) the building- and system design can ensure that there are no technical barriers to installing BACS;
(b) the building- and system design can ensure that the costs of installing BACS are minimised;
(c) installing BACS is already part of common practice for new large non-residential buildings.
For existing buildings, the only cases where technical feasibility can be an issue are those where the technical
building systems cannot be controlled, or when making them controllable would require substantial alterations
to the system and/or the building, which would inevitably lead to prohibitive costs. Such situations are limited
to buildings that are equipped with old systems and should rarely arise.
The economic feasibility of installing BACS in existing buildings can also be linked to the upfront and running
costs and/or to the cost recovery period required. A possible approach is to evaluate economic feasibility based
on the expected energy cost savings generated by the BACS and to compare them to the upfront and running
costs of installing the BACS, over the system's lifetime. This can be supplemented by an evaluation of the
proportionality of the upfront costs of installing BACS in the building in question, based on such parameters as
e.g. building size or energy consumption (28).
Table 6
Possible interpretation of technical and economic feasibility for the installation of BACS
Can apply to
Type of feasibility How it can translate
New buildings Existing buildings
Technical feasibility The technical building systems cannot No Yes (but rarely)
be controlled without substantial al
terations.
Economic feasibility The upfront costs are excessive com No Yes (but rarely)
pared to the building's characteristics.
The investment cannot be sufficiently No Yes (but rarely)

recovered.
2.4. Guidelines on transposition of provisions on technical building systems and their inspections, self-
regulating devices and BACS
2.4.1. Technical building systems requirements, and assessment and documentation of overall energy performance of technical
building systems (Article 2, 8(1), 14 and 15 of the EPBD)
2.4.1.1. Trans p o s it i on of de fi n it i on s ( A r t i cl e 2 of the EPBD )
Where relevant, Member States should consider giving additional clarifications to supplement the definitions of
technical building systems, for instance to describe in more detail the capabilities that building automation and
control systems are expected to achieve.
2.4.1.2. E s ta b l is h m en t of s y st em req u i rem en ts (Ar tic le 8 (1) of the EPBD )
(a) New technical building systems
For systems that were not considered before the amendment (building automation and control systems and on-
site electricity generation), Member States will have to define and lay down system requirements at national
level and ensure that these requirements cover all the aspects referred to in Article 8(1) of the EPBD: ‘overall
energy performance’, ‘proper installation’, ‘appropriate dimensioning’, ‘adjustment’ and ‘control’. The following
table outlines the meaning of each of these requirement areas, giving examples (for illustration purposes only)
for the two types of systems that have been added to the list of technical building systems in the EPBD.
(28) The ‘décret tertiaire’ French act (2017) e.g. set a threshold of maximum 200 EUR/m2 for the investment and a maximum payback time
of 10 years for public buildings and 5 years for others (hotels, offices, etc.).
Table 7
Different system requirements areas
Examples
Type of
Refers to
requirement
BACS On-site electricity generation
‘overall energy The performance of the Control capabilities that System performance factor of
performance’ system as a whole (not to have an impact on building a photovoltaic (PV) system
be confused with the per energy performance (e.g. (e.g. following EN 15316-4-6
formance at product or following EN 15232 stand standard (2))
component level and the ard (1))
performance of the whole
building)
‘appropriate The appropriateness of the Determine the optimal con Determine the optimal size
dimensioning’ system size or capacity giv trol capabilities based on of the PV system based on
en the needs and character the type of building, ex electricity cost reduction,
istics of the building under pected usage, potential en available mounting area and
expected use conditions ergy savings other constraints that could
apply
‘proper The way the system should Installation by a trained an Installation by a trained
installation’ be installed in the building d/or certified installer and/or certified installer
in order to operate properly
‘appropriate Testing and fine-tuning ac Sequence of tests to be per Sequence of tests to be per
adjustment’ tions on the system, once formed after installation to formed after installation to
installed, under real usage check that the system oper check that the system oper
conditions ates in accordance with its ates in accordance with its
specifications specifications
‘appropriate Desired or required control Scope of control functions (Where applicable) control of
control’ capabilities of systems electricity feed (e.g. to grid,
self-consumption, or storage)
(1) EN 15232 ‘Energy performance of buildings — Impact of Building Automation, Controls and Building Management’.
(2) EN 15316-4-6 ‘Heating systems in buildings — Method for calculation of system energy requirements and system effi
ciencies — Part 4-6: Heat generation systems, photovoltaic systems’.
(b) Systems already covered before the amendment
For systems already covered before the amendment, Member States could consider using the transposition of
Directive (EU) 2018/844 as an opportunity to review and possibly update applicable system requirements. This
review could in particular be an opportunity to check that the applicable requirements cover sufficiently the
different areas listed in the EPBD and assess whether the requirements could be further developed. Feedback
from the Concerted Action EPBD (29) European network suggests that: (i) the focus of applicable requirements is
generally on component-level performance requirements; and (ii) the way other areas (i.e. proper installation,
appropriate dimensioning, adjustment and control) are addressed can vary across the EU. Member States are
therefore encouraged to take part in this review and, where relevant, draw on available good practices.
(29) ‘Book: 2016 — Implementing the Energy Performance of Buildings Directive (EPBD) — Featuring Country Reports’, Concerted Action
EPBD, 2016, https://www.epbd-ca.eu/ca-outcomes/2011-2015
(c) Consideration of product-specific Regulations under the ecodesign Directive
Technical building systems include many products that are regulated under product-specific Regulations that
implement Directive 2009/125/EC (‘ecodesign Directive’). In relation to product-specific Regulations
implementing the ecodesign Directive which concern products that can be part of technical building systems as
defined in Article 2(3) of the EPBD, it is worth emphasising that requirements under Article 8(1) of the EPBD
apply to whole systems, as installed in buildings, and not to the performance of standalone components, which
falls under the scope of product-specific Regulations implementing the ecodesign Directive. By way of example,
the scope of requirements of Article 8(1) of the EPBD for a building hydronic heating system would cover the
whole system (boilers, distribution and emission components), whereas the scope of ecodesign requirements for
products being part of the same system would be limited to those applying to boilers.
It is generally beneficial to encourage the installation of high-performance products, however, where

requirements under Article 8(1) of the EPBD would apply to products already covered by product-specific
Regulations implementing the ecodesign Directive, these requirements must not go beyond the requirements set
by the latter, as product-specific Regulations implementing the ecodesign Directive are directly applicable har
monisation measures.
Banning specific types of products which comply with the applicable ecodesign requirements would go beyond
what the EPBD requires and allows, because products from other Member States which comply with all
ecodesign requirements could not be sold on other national markets, in breach of the basic principle of free
movement of goods.
However, Member States may, in certain cases, restrict the free movement of goods for environmental reasons,
but only after having notified the Commission (30). This is consistent with recital 35a (31) and Article 6 (32) of
the ecodesign framework.
2.4.1.3. Tran s po s i tio n o f th e p rovi s i ons on a ssessi ng an d d ocu me nt i ng syst em perfor m anc e
(Ar ti c l e 8 (1 ) o f th e EP B D)
(a) System or altered part?
Article 8(9) of the EPBD stipulates that when a technical building system is installed, replaced or upgraded, the
overall performance ‘of the altered part and, where relevant, of the complete altered system’, must be assessed
and documented.
This means that:
(a) in all cases, the performance of the altered part has to be assessed and documented. For example, if the
heat generator of a heating system is replaced — which corresponds to a system upgrade, the performance
of the new heat generator should be assessed and documented;
(b) in some cases (i.e. ‘where relevant’), the performance of the whole system must be assessed and
documented. This should be required in the following three situations:
(i) a new system is installed;
(ii) a whole system is replaced;
(iii) a part, or parts, of a system undergo a major upgrade that can significantly affect that system's overall
performance.
(30) For further information, see Article 114(4) and (5) of the Treaty on the Functioning of the European Union (TFEU).
(31) This recital states that: ‘Directive 2010/31/EU of the European Parliament and of the Council of 19 May 2010 on the energy
performance of buildings requires Member States to set energy performance requirements for building elements that form part of the
building envelope and system requirements in respect of the overall energy performance, the proper installation, and the appropriate
dimensioning, adjustment and control of the technical building systems which are installed in existing buildings. It is consistent with the
objectives of this Directive that these requirements may in certain circumstances limit the installation of energy-related products which
comply with this Directive and its implementing measures, provided that such requirements do not constitute an unjustifiable market
barrier.’
(32) The Energy Efficiency Directive adds the following sentence to Article 6 of the Ecodesign framework (‘Free movement’): ‘This shall be
without prejudice to the energy performance requirements and system requirements set by Member States in accordance with
Article 4(1) and Article 8 of Directive 2010/31/EU.’
Cases referred to in points (i) and (ii) of subparagraph (b) are straightforward: when a whole new system is
installed or replaced (whether in a new building or in an existing building), there is a clear need to assess and
document the performance of the whole (new) system.
In the case referred to in point iii of the subparagraph (b), a part or parts of the system are replaced or
improved, thereby upgrading their energy performance. Because the part is so important, this results in an
upgrade in the performance of the whole system. In this scenario, the whole system performance should be
assessed. For instance:
(a) replacing a major component (e.g. the heat generator in a system) or a large number of minor components
(e.g. all heat emitters in a building) should be considered in principle as a major upgrade as it has
a potentially significant impact on overall performance.
(b) altering aspects of the whole system (e.g. improved insulation of pipes, replacement of pipes, replacement
of all light sources, replacement of all radiators) should be considered in principle as a major upgrade.
(c) the same applies to any upgrade or alteration that affects the balance of the system.
In the following examples, the assessment obligation should not be triggered:
(a) maintenance and repairs that only aim to ensure the safe and optimal operation of the system;
(b) replacement of a minor system component (e.g. replacement of a heat emitter).
In any case, it is up to Member States (and not to building and dwelling owners) to set out in their national
legislation the cases where it is relevant to assess the performance of the whole system, as opposed to those
where only the assessment of the performance of the altered part is required.
In this context, Member States may differentiate between the different buildings and building units that can be
affected by these provisions. This can concern for example the type of buildings (for example, residential or
non-residential, individual dwelling or multi-family building). This can also possibly relate to system size, as it
may be more appropriate to perform a more detailed assessment when a system is larger and more complex.
(b) Overall performance
Within the scope of the provisions on assessing and documenting system performance, assessing the overall
performance (of the altered part or of the whole system) means taking the necessary steps to evaluate and
express the energy performance (of the altered part or of the whole system).
The term ‘overall’ emphasises the need — where it applies — to assess the performance of the system as
a whole opposed to performance at product or component level. This is less relevant when it is the
performance of the altered part that is being assessed.
Member States should ensure that the scope of overall energy performance of a technical building system under
Article 8(9) of the EPBD includes for assessment and documentation purposes at least the scope of overall
energy performance under Article 8(1) for system requirements, and also those aspects that can affect overall
energy performance under the other requirement areas (in particular control). This will ensure that compliance
with system requirements is assessed and documented, that the owner is made aware of this compliance and
that compliance can be proven (e.g. when the building or building unit is sold to a new owner).
Performance can be assessed in different ways; Member States should clarify which approach should be
followed. These can vary depending on different factors (e.g. type of system considered, type of intervention:
installation, replacement, upgrade, etc.) Upgrades that are limited in scale and impact could lead to lighter
assessment approaches e.g. recording the intervention and ensuring that all relevant technical documents on the
component(s) impacted are collected. More substantial interventions (typically installation or replacement) could
require a more thorough assessment of the impact on the system as a whole e.g. based on the simulation of
system performance when the system is designed and on verification of key system capabilities after instalment.
When determining their approach to performance assessment, Member States should ensure consistency with
the requirements in Article 14 and 15 of the EPBD on inspections of heating, air-conditioning and ventilation
systems, in particular in relation to the requirement to assess (where relevant) the system's capabilities under
typical or average operating conditions. For instance, where guidelines or templates for the inspection of
technical building systems under Articles 14 and 15 of the EPBD are available, references to these guidelines or
templates may be made in the performance assessment under Article 8 of the EPBD.
(c) Documentation of system performance
Article 8(9) of the EPBD requires that the results of the assessment of the system (or of an altered part of it)
performance are documented and passed on to the building owner. Member States are free to determine the
form and content of this documentation, which can vary depending on the type of intervention considered.
However, in this context, Member States should ensure that the documentation covers the scope of the
assessment performed and can be useful for the verification of compliance with the minimum requirements on
energy performance laid down pursuant to Article 8(1) of the EPBD and for energy performance certification
(see next sub-section). Member States are also free to determine how the documentation is to be passed on to
the building owner.
(d) Relation with building energy performance requirements and energy performance certificates
The obligations in Article 8(9) of the EPBD on documenting system (or altered part) performance aim to ensure
that up-to-date information on technical building system performance is made available to building
owners. Such information can be used, for instance, for energy performance certification or to verify
compliance with minimum energy performance requirements (e.g. when a building undergoes a major
renovation). It is up to Member States to decide whether a new energy performance certificate (EPC) will have
to be issued as a result of the energy performance assessment of the technical building system (or an altered
part of it).
2.4.2. Inspection of heating, air-conditioning, combined heating and ventilation, and combined air-conditioning and ventilation
systems (Article 14 and 15 of the EPBD)
2.4.2.1. I nsp e c t i on s of h ea ti n g a nd c om bi ned he ati ng a nd ven til ati on syste ms (A r ti c le 1 4 of t he

EPB D)
(a) Systems to be inspected
The amendment to the EPBD expands the scope of systems to be inspected under Article 14(1), to include
Member States should include a definition of ‘combined heating and ventilation system’ in their national
legislation.
Member States should ensure that the definition of such systems includes heat pumps and determine whether
they fall within the scope of Article 14 or 15 of the EPBD (see Section 2.3.2.4).
(b) Effective rated output
Article 14(1) of the EPBD requires inspections of systems with an effective rated output over 70 kW. Before the
amendment to the EPBD, the threshold laid down in its Article 14(1) for inspections of a boiler's effective
output was only 20 kW.
This change affects both the threshold on output (increased from 20 kW to 70 kW) and the scope to consider
when rating the output. Before the amendment, the rating made reference only to the boiler, while the rating in
the EPBD now makes reference to the system as a whole. Systems with multiple heat generators (e.g. Type 1
and Type 2 systems as described in section 2.2) should also fall under the obligation laid down in Article 14(1)
of the EPBD if the overall rating of multiple heat generators serving the same area or building unit exceeds
70 kW.
As indicated in recital 39 of Directive (EU) 2018/844, Member States may choose to continue applying the
inspection regimes already in place, including inspections for smaller heating systems (i.e. of a threshold
between 20 kW and 70 kW of effective rated output). If Member States decided to continue to operate those
schemes, there would be no obligation on Member States to notify those more stringent requirements to the
Commission.
(c) Performance under typical or average operating conditions
According to Article 14(1) of the EPBD, Member States must expand the scope of the inspection to include,
where relevant, assessment of the system under typical or average operating conditions.
Member States should determine what changes are required in the inspection methodology. This should focus
on inspection requirements and guidelines.
(d) Exemptions based on energy contracts or agreements
Member States may update their national legislation to include exemptions for buildings covered by an agreed
energy performance criterion or a contractual arrangement specifying an agreed level of energy performance
improvements. Member States may also include exemptions for buildings operated by a utility network or
operator.
If Member States decide to allow such exemptions, they should ensure that new legislation addresses the
definition of ‘energy performance criterion’ or ‘contractual arrangement specifying an agreed level of energy
performance’.
If Member States decide to include the exemptions indicated under Article 14(2) of the EPBD, they must ensure
that the overall impact of the approach is equivalent to those of inspections resulting from Article 14(1) of the
EPBD.
To ensure this equivalence, it is recommended that Member States make use of the possibilities to implement
Article 18 of the EED by creating a publicly available list of certified/accredited companies. In addition, Member
States would need to produce publicly available models for energy performance contracts in line with
Annex XIII to the EED.
For those Member States without a list of certified/accredited companies or without publicly available models
for energy performance contracts, the equivalence should be established on a case-by-case basis. Under this
scenario, the contracting parties could facilitate the process by introducing an annex in their contract clearly
identifying the following points from Annex XIII to the EED:
(a) guaranteed savings to be achieved by implementing the measures of the contract;
(b) duration and milestones of the contract terms and period of notice;
(c) reference date to establish achieved savings;
(d) obligation to fully implement the measures in the contract and documentation of all changes made during
the project;
(e) clear and transparent provisions on measurement and verification of the guaranteed savings achieved,
quality checks and guarantees (ideally with reference to national or EU standards).
(e) Voluntary requirements for residential buildings
Article 14(5) of the EPBD refers to the option to introduce both functionalities (i.e. electronic monitoring and
effective control functionalities) for residential buildings.
Member States that decide to introduce the requirements for residential buildings should include a clear
definition of the meaning of continuous electronic monitoring and effective control functionalities.
Article 14(5) of the EPBD has an optional character (i.e. the term ‘may’ is used in its wording) and does not
include details on thresholds in terms of effective rated output. Instead it implicitly refers to all residential
buildings regardless of their size. It is recommended that Member States take into consideration the differences
in types of systems or buildings when laying down the requirements.
(f) Exemptions based on BACS or continuous electronic monitoring and effective control functionalities
The EPBD exempts from inspection technical building systems that comply with Article 14(4) (building
automation and control systems) and 14(5) (voluntary requirements for residential buildings).
Member States must update national legislation to introduce the definition of BACS.
Member States may decide to lower the threshold for the requirement on installing BACS indicated in
Article 14(4) of the EPBD. Those buildings under the new requirement and with BACS installed should also be
exempt from inspections.
Member States may decide to extend the exemption on inspections for individual building owners with systems
under 290 kW that have BACS installed in compliance with Article 14(4) of the EPBD. Member States that
extend this exemption should inform the Commission of this when they notify it of their transposition
measures.
Member States that choose to introduce requirements for residential buildings should also consider exemptions
to inspections.
(g) Alternative measures
The transposition of Article 14 of the EPBD for Member States that decide to apply alternative measures is to
a large extent only affected by the changes in scope, thresholds and exemptions (see Section 2.3.2.8). Member
States may continue to apply the same range of measures.
Member States already applying alternative measures must ensure, according to Article 14(3) of the EPBD, that
the measures in place are equivalent to those set out in Article 14(1) of the EPBD. This may require adaptation
of the alternative measures. According to Article 14(3) of the EPBD, Member States must document in a report
to the Commission the equivalence of the measures and the report must be sent before any new or adapted
measures are put in place.
If at some point after transposition of the EPBD, a Member State decides to modify the range or scope of
existing measures or introduce new measures, it must notify the Commission of such changes. To do so,
Member States must submit a report on the equivalence of the measures, before the new or adapted measures
are put in place.
In accordance with Regulation (EU) 2018/1999, each Member State must submit equivalence reports required
by the EPBD as part of its national energy and climate plan (NECP). The timeline for submitting NECPs and
progress reports is indicated in Section 2.3.2.9.
If the timing of the NECPs is not suitable for a Member State, it may submit the equivalence report directly to
the Commission. However, the Member State must ensure that the equivalence report is also included in the
next step of the NECP.
2.4.2.2. I ns pe c t io n s o f a i r-c on d i t i oni n g a nd com bi ned ai r-cond iti oni n g an d ven ti la ti on sys te m s
( Ar ti cl e 15 of th e E P B D )
As with Article 14, the requirements of Article 15 of the EPBD must also be incorporated into national law.
The obligations in Article 14 are the same as those for Article 15. The provisions in this Annex relating to
Article 14 should also be applied by analogy in the context of Article 15.
Information on how to transpose Article 15 of the EPBD is provided in Sections 2.4.2.1(a) to 2.4.2.1(g) of this
Annex:
(a) systems to be inspected (Section 2.4.2.1(a));
(b) effective rated output (2.4.2.1(b));
(c) performance under typical operating conditions (2.4.2.1(c));
(d) exemptions based on energy contracts or agreements (2.4.2.1(d));
(e) voluntary requirements for residential buildings (2.4.2.1(e));
(f) exemptions based on BACS or continuous electronic monitoring and effective control functionalities
(2.4.2.1(f));
(g) ensuring transposition of Article 14(3) of the EPBD — alternative measures (2.4.2.1(g)).
2.4.3. Requirements on installation of self-regulating devices and BACS (Article 8(1), 14(4) and 15(4) of the EPBD)
2.4.3.1. Tr ans p os i ti on o f re qu i rem en ts on i n st all ati on of se lf -re gul ati n g devi c es (Ar t ic le 8 (1 ) of t h e
EPB D)
Under the obligations on installing self-regulating devices (Article 8(1) of the EPBD):
(a) every new building must be equipped with self-regulating devices by the transposition deadline. This should
be ensured in the case of buildings for which permit applications are submitted after the transposition
deadline.
(b) all existing buildings whose heat generators are replaced as from the date of the national transposition of
these obligations must be equipped with self-regulating devices.
Those obligations apply except in infrequent/rare cases where it is not technically or economically feasible to
install such devices.
Member States should advertise these requirements sufficiently in advance so that professionals can take them
into account early enough when designing new buildings and when preparing the replacement of heat
generators in existing buildings.
In transposing the requirements on the installation of self-regulating devices, Member States should ensure that
the expected self-regulating capability of such devices is clearly expressed and in line with the one given in
Article 8(1) of the EPBD, as detailed in Section 2.3.3 of this Annex.
In the EPBD, this self-regulating capability is expressed in a technology-neutral way. This leaves flexibility on
the specific solutions that can be used to achieve this capability. While this flexibility can be considered
beneficial (as it allows designers and installers to select the best solution for a given building or building unit),
Member States are also encouraged to provide further technical guidance on how to implement self-regulation
for the various systems that can be encountered, in particular the most common ones. The table in
Section 2.3.3.2 gives some examples.
On the scope of regulation (i.e. room or zone), Member States are also encouraged to provide technical
guidance on cases where zone-level regulation could help professionals in their assessment and could support
consistent implementation of the requirements in the national (or, where applicable, regional) territory.
In cases where Member States allow zone-level regulation for well-identified categories of buildings or building
units (see Section 2.3.3.2(b)), this should be made clear in the transposition of the requirements or in the
technical guidelines supporting their implementation.
2.4.3.2. Tra ns p o s it i on of re qu i rem en ts on the in stal la tio n of BACS (A r ti c l e 1 4 (4 ) a nd 1 5 (4 ) o f t he

EPB D)
Articles 14(4) and 15(4) of the EPBD refer to 2025 as the date by which non-residential buildings must be
equipped with building automation and control systems satisfying the conditions established in those
articles. However, the requirements ensuring installation are required to be transposed by the transposition
deadline of 10 March 2020.
In transposing the BACS installation requirements, Member States must ensure that the capabilities of the
required systems are in line both with: (i) the definition of building automation and control systems in
Article 2(3a) of the EPBD; and (ii) the capabilities listed in points (a), (b) and (c) of Articles 14(4) and 15(4) of
the EPBD (see Section 2.3.3.1).
While compliance with the definition of BACS should not bring any particular difficulty, it can be challenging
to identify — for a given building — the available capabilities and how they correspond to those provided for
under the EPBD. One way to make this easier is to map these capabilities to BACS functions and classes as
defined in available standards, in particular under EN 15232 (33).
(33) As a first-order estimate, the BACS capabilities required under Article 14-15 could correspond to B-class BACS under EN 15232.
In any case, Member States are encouraged to provide professionals with dedicated technical guidelines. Such
guidelines would help professionals assess BACS capabilities and identify potential gaps, and would give
recommendations on how to fill such gaps effectively.
2.5. Additional considerations on system requirements, system performance assessment and documen
tation, inspections and BACS
This section will highlight good practices. The information and references provided here are neither exhaustive
nor prescriptive — they are provided for information only.
2.5.1. Possible interpretations of requirements on technical building systems (Article 8(1) of the EPBD)
2.5.1.1. Ne w te ch ni c al b ui l d i n g s y stem s
Two new technical building systems are introduced in the EPBD: (i) building automation and control systems
(BACS); and (ii) on-site electricity generation systems. The following tables summarise how such requirements
could be interpreted when implementing the EPBD.
As regards on-site electricity generation, our assumption is that the main target is photovoltaic panels. However,
wind turbines (where their size allows for on-site usage) and micro combined heat and power (micro CHP)
systems are also within the scope of the EPBD.
Table 8
Possible interpretation of system requirements for BACS
Type of
Possible interpretations for BACS Useful references (1)
requirement
‘overall energy Minimum requirements on control capabilities that have an EN 15232 (2),
performance’ impact on building energy performance. These requirements EN 16947-1:2017 (3) and
can concern the scope of control (i.e. which systems are con TR 16947-2 (4)
trolled), the depth (or granularity) of control, or both. In defin
ing these requirements, references can be made to available
standards, for instance to BACS energy classes as defined in
EN 15232 standard. Requirements can vary depending on the
type of buildings (e.g. residential vs non-residential) and on
some characteristics of buildings (e.g. surface area).
‘appropriate Dimensioning would refer here not to system size (as it would ISO 16484-1:2010 (5)
dimensioning’ for some other systems), but more to the way the design of
a BACS can be tailored to a specific building. The aim of di
mensioning is to reach the best compromise between costs
and capabilities in consideration of the specific needs of the
considered building. Requirements on dimensioning will list
the relevant aspects that should be taken into account when
designing a BACS for a specific building (e.g. expected or mea
sured energy consumption, building usage, technical building
systems installed in the building, operation and maintenance
requirements) in order to reach this optimal compromise.
Within the scope of these requirements, it can be useful to
refer to relevant standards or guidelines.
‘proper Requirements on the ‘proper installation’ is a generic reference EN 16946-1:2017 (6) and
installation’ to the need to ensure that the system (here, the BACS) is in TR 16946-2 (7)
stalled in a way that will ensure safe and optimal operation.
Usually this is linked to requirements on the qualification of
the installer (e.g. certified installer) and to specific technical
guidelines.
Type of
Possible interpretations for BACS Useful references (1)
requirement
‘appropriate ‘Adjustment’ refers to: (i) a post-installation test of the system EN 16946-1:2017 (6)
adjustment’ to check that it operates properly; and (ii) fine-tuning when and TR 16946-2 (7);
the system is operating under real conditions. Such actions ISO 50003 (9)
would generally require human intervention, but BACS give
the opportunity to also consider ongoing commissioning
approaches where this process is partially automated (8).
‘appropriate This category applies mostly to technical building systems that EN 15232 (2),
control’ are controlled (e.g. heating systems) rather than to BACS, EN 16947-1:2017 (3)
whose main purpose is to control other systems. However, and TR 16947-2 (4)
‘appropriate control’ can refer here to the functions that
a BACS can offer to support or facilitate human control (e.g.
display of consumption data or any other interaction with
building operator and building occupants).
(1) The references given all relate to standards. In addition to these, Member States can consider drawing on the practices of
some industry-led schemes, whether European, e.g. the eu.bac certification scheme (https://www.eubac.org/system-
audits/index.htm) or national, e.g. in Germany the VDMA 24186-4 ‘Program of services for the maintenance of technical
systems and equipment in buildings — Part 4: Measurement and control equipment and building automation and control
systems’.
(3) EN 16947-1:2017 ‘Energy Performance of Buildings — Building Management System — Part 1’.
(4) TR 16947-2 ‘Building Management System — Part 2: Accompanying prEN 16947-1:2015’.
(5) ISO 16484-1:2010 Preview ‘Building automation and control systems (BACS) — Part 1: Project specification and imple
mentation’.
(6) EN 16946-1:2017 ‘Energy Performance of Buildings. Inspection of Automation, Controls and Technical Building Manage
ment’.
(7) TR 16946-2 ‘Inspection of Building Automation, Controls and Technical Building Management — Part 2: Accompanying
TR to EN 16946-1’.
(8) This comment also applies to some extent to all technical building systems that are monitored and controlled by BACS.
(9) ISO 50003:2014 ‘Energy management systems — Requirements for bodies providing audit and certification of energy
management systems’.
Table 9
Possible interpretation of system requirements for on-site electricity generation
Type of
Possible interpretations for on-site electricity generation systems Useful references (1)
requirement
‘overall energy Minimum requirements on the performance of the system (as EN 15316-4-6 (3) EN
performance’ installed) in terms of electricity generation under typical oper 61724 (4) and IEC
ating conditions. In defining these requirements, Member 61853-2:2016 (5) for
States are encouraged to consider applicable standards, in par photovoltaic systems, EN
ticular from the list of EPB standards (see third column), and 15316-4-4 standard (6)
applicable Ecodesign and Energy Labelling regulations (2). for building-integrated
cogeneration system, EN
15316-4-10 (7) and IEC
61400-12-1 (8) for wind
power generation
systems
Type of
Possible interpretations for on-site electricity generation systems Useful references (1)
requirement
‘appropriate Dimensioning can first relate to the generation capacity of the Calculation of design
dimensioning’ system considered. One aim can be to ensure that this capa heat load:
city is adequate with regard to considered needs (e.g. the de EN 12831-1 (10)
sign of heat load for cogeneration space heaters). Dimension ISO 15927-5:2004 (11)
ing can also relate to the physical dimensions of systems'
components, taking into account the constraints that apply to
the specific building (9) (e.g. position, orientation, slope of
photovoltaic panels, maximum power point tracking configur
ation, cable size, etc.).
‘proper Requirements on ‘proper installation’ is a generic reference to For BIPV systems,

installation’ the need to ensure that the system is installed in a way that EN 50583-2 (12)
will ensure safe and optimal operation. Usually this is linked
to requirements on the qualification of the installer (e.g. certi
fied installer) and to specific technical guidelines. For photo
voltaic systems, standards applying to building-integrated
photovoltaics (BIPV) can be relevant in this context.
‘appropriate ‘Adjustment’ refers to: (i) a post-installation test of the system For PV systems,
adjustment’ to check that it operates properly; and (ii) fine-tuning when IEC/EN 62446 (13)
the system is operating under real conditions.
‘appropriate In this context, ‘control’ refers to the ability of the system to N/A
control’ control its own operation, taking into account parameters
from the environment and from the building. This is most rel
evant for micro CHP systems, due to their simultaneous pro
duction of thermal and electrical energy.
(1) The references focus on EU standards. In addition to these, Member States are invited to consult available resources at
national level, e.g. in Belgium the ‘Spécifications techniques (STS)’ on photovoltaic systems: https://economie.fgov.
be/sites/default/files/Files/Publications/files/STS/STS-72-1-systemes-photovoltaiques.pdf
(2) To date, the most relevant regulation for on-site electricity generation is the one on heaters and water heaters, which
covers cogeneration space heaters, see ‘Commission Regulation (EU) No 813/2013 of 2 August 2013 implementing
Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for space
heaters and combination heaters’. In addition, the Ecodesign working plan 2016-2019 (COM(2016) 773 final) mentions
that solar panels and inverters will be subject to preparatory studies, which means such systems could be covered by
Ecodesign and/or energy labelling regulations in the future. See http://susproc.jrc.ec.europa.eu/solar_
photovoltaics/projectplan.html for more details.
(3) EN 15316-4-6 ‘Heating systems in buildings — Method for calculation of system energy requirements and system
efficiencies — Part 4-6: Heat generation systems, photovoltaic systems’.
(4) IEC/EN 61724: Photovoltaic system performance monitoring — Guidelines for measurement, data exchange and analy
sis.
(5) IEC 61853-2:2016 ‘Photovoltaic (PV) module performance testing and energy rating — Part 2: Spectral responsivity,
incidence angle and module operating temperature measurements’.
(6) EN 15316-4-4 ‘Heating systems in buildings — Method for calculation of system energy requirements and system effi
ciencies — Part 4-4: Heat generation systems, building-integrated cogeneration systems’.
(7) EN 15316-4-10 ‘Energy performance of buildings — Method for calculation of system energy requirements and system
efficiencies — Part 4-10: Wind power generation systems’.
(8) IEC 61400-12-1 Ed. 2.0 b:2017 ‘Wind energy generation systems — Part 12-1: Power performance measurements of
electricity producing wind turbines’.
(9) The aim is to ensure that the system will have optimal performance over its lifetime. Suboptimal dimensioning could
lead to poor performance, which is detrimental to the building owner.
(10) EN 12831-1 ‘Energy performance of buildings — Method for calculation of the design heat load’.
(11) ISO 15927-5:2004 ‘Hygrothermal performance of buildings — Calculation and presentation of climatic data — Part 5:
Data for design heat load for space heating’.
(12) EN 50583-2:2016 ‘Photovoltaics in buildings. BIPV systems’.
(13) IEC/EN 62446 ‘Grid connected photovoltaic systems — Minimum requirements for system documentation, commission
ing tests and inspection’.
(a) Built-in lighting systems
Lighting systems were already part of the technical building systems before the amendment but were not
covered by the provisions on system requirements. However, following the amendment, system requirements
have to be established for ‘built-in’ lighting systems. As explained in Section 2.3.1.1, the update of the wording
is only a clarification of the scope. The new wording of the scope emphasises that it covers only lighting
equipment that is installed in order to implement lighting specifications defined at design time, and to fulfil
related requirements.
Table 10
Possible interpretation of system requirements for built-in lighting
Type of
Possible interpretations for lighting systems Useful references
requirement
‘overall energy Minimum requirements on the performance of the built-in EN 15193-1:2017 (1),
performance’ lighting system as a whole, taking into account relevant para CEN/TR
meters. The LENI (lighting energy numeric indicator) as 15193-2:2017 (2)
defined in EN 15193-1:2017 standard can, for example, be
a way to express requirements on the performance of lighting
systems.
‘appropriate For lighting systems, ‘appropriate dimensioning’ refers to: EN 12464-1 (3),
dimensioning’ (i) determining illumination level requirements, taking into ac CEN/TS 17165 (4)
count relevant parameters (in particular intended usage of the
building and its spaces); and (ii) translating those requirements
into design specifications for lighting systems.
‘proper Installation of electric equipment, including lighting, in ac N/A

installation’ cordance with applicable regulations at national level.
‘appropriate Adjustment may refer here to: (i) checking that capabilities of Same as below
adjustment’ lighting systems comply with design specifications, particu
larly in terms of controls and; (ii) performing any relevant
fine-tuning.
‘appropriate In this context, ‘control’ refers to the ability of the lighting sys CEN/TR 15193-2 (5),
control’ tem to control the lighting level, taking into account para CIE 222:2017 (6)
meters from the environment (e.g. daylight) and from the
building (e.g. occupation).
(1) EN 15193-1:2017 ‘Energy performance of buildings — Energy requirements for lighting — Part 1: Specifications’.
(2) CEN/TR 15193-2 ‘Energy performance of buildings — Energy requirements for lighting — Part 2: Explanation and justifi
cation of EN 15193-1, Module M9’.
(3) EN12464-1:2011 ‘EN12464-1:2011 Light and lighting — Lighting of workplaces Part 1: Indoor work places’.
(4) CEN/TS 17165 ‘Light and Lighting — Lighting System Design Process’.
(5) CEN/TR 15193-2:2017 ‘Energy performance of buildings — Energy requirements for lighting — Part 2: Explanation and
justification of EN 15193-1, Module M9’.
(6) CIE 222:2017 ‘Decision Scheme for Lighting Controls in Non-Residential Buildings’.
2.5.1.2. Sy s tem s al r ea d y cov e red befor e the am en dm en t
Systems for space heating, space cooling, domestic hot water and ventilation were already covered by the
provisions on system requirements under the EPBD. However, the transposition of the EPBD offers an
opportunity to update these requirements.
Table 11
Possible interpretation of space heating system requirements
Type of
Possible interpretations for space heating systems (1) Useful references (2)
requirement
‘overall energy In this context, overall performance refers to the performance of the EN 15316 standard
performance’ whole process of energy transformation in heat generators, heat distri series, e.g.
bution across the building, heat emission in individual rooms or spaces EN 15316-1 (3)
of the building and, where applicable, heat storage. It is not limited to EN 15316-2 (4)
the performance of heat generators and can include requirements that EN 15316-3 (5)
affect other parts of the system (e.g. insulation of the distribution pip EN 15316-4-1 (6),
ing network). EN 15316-4-2 (7)
EN 15316-4-5 (8),
EN 15316-4-8 (9)
EN 15316-5 (10)
‘appropriate For heating systems, ‘appropriate dimensioning’ refers to: (i) deter EN 12831-1 (11)
dimensioning’ mining heating needs, taking into account relevant parameters (in par EN 12831-3 (12),
ticular the intended usage of the building and its spaces); and (ii) trans Module M8-2,
lating these requirements into design specifications for heating systems. M8-3EN 12828 (13),
EN 14337 (14),
EN 1264-3:2009 (15)
‘proper Proper installation refers to the need to ensure the system will be able EN 14336 (16)
installation’ to operate in accordance with design specifications. Ensuring proper EN 1264-4 (17)
installation can rely on e.g. national technical guidelines, product EN 14337 (14)
manufacturer documentation, certification of installers.
‘appropriate Adjustment refers here to the testing and fine-tuning of the system un EN 15378-1 (19),
adjustment’ der real-life conditions (18), in particular to check and possibly adjust EN 14336 (16),
system functions that can have an impact on performance (e.g. control EN 15378-3 (20)
capabilities — see below).
‘appropriate Concerns control capabilities that heating systems can include in order EN 15500-1 (21)
control’ to optimise performance e.g. automatic adaptation of heat output of EN 15316-2 (4),
emitters in individual rooms or spaces, adaptation of system tempera EN 15232 (22), space
ture based on outside temperature (‘weather compensation’) or time heater energy labelling
schedules, dynamic and static hydronic balancing, system operation regulations (23)
monitoring, adjustment of water-/air-flow depending on needs.
(1) Most of the information given in this table also applies to systems for domestic hot water.
(2) The references focus on EU standards. In addition to these, Member States are invited to consult available resources at national
level, e.g. in Belgium the ‘Spécifications techniques (STS)’ on thermal solar systems: https://economie.fgov.
be/sites/default/files/Files/Publications/files/STS/STS-72-3-systemes-solaires-thermiques.pdf
(3) EN 15316-1:2017 ‘Energy performance of buildings — Method for calculation of system energy requirements and system
efficiencies — Part 1: General and Energy performance expression, Module M3-1, M3-4, M3-9, M8-1, M8-4’.
efficiencies — Part 2: Space emission systems (heating and cooling), Module M3-5, M4-5’.
efficiencies — Part 3: Space distribution systems (DHW, heating and cooling), Module M3-6, M4-6, M8-6’.
(6) EN 15316-4-1:2017 ‘Energy performance of buildings — Method for calculation of system energy requirements and system
efficiencies — Part 4-1: Space heating and DHW generation systems, combustion systems (boilers, biomass), Module M3-8-1,
M8-8-1’.
efficiencies — Part 4-2: Space heating generation systems, heat pump systems, Module M3-8-2, M8-8-2’.
efficiencies — Part 4-5: District heating and cooling, Module M3-8-5, M4-8-5, M8-8-5, M11-8-5’.
efficiencies — Part 4-8: Space heating generation systems, air heating and overhead radiant heating systems, including stoves
(local), Module M3-8-8’.
efficiencies — Part 5: Space heating and DHW storage systems (not cooling), Module M3-7, M8-7’.
(11) EN 12831-1:2017 ‘Energy performance of buildings — Method for calculation of the design heat load — Part 1: Space heating
load, Module M3-3’.
(12) EN 12831-3 ‘Energy performance of buildings — Method for calculation of the design heat load — Part 3: Domestic hot water
systems heat load and characterisation of needs, Module M8-2, M8-3’.
(13) EN 12828:2012+A1:2014 ‘Heating systems in buildings — Design for water-based heating systems’.
(14) EN 14337:2005 ‘Heating Systems in buildings — Design and installation of direct electrical room heating systems’.
(15) EN 1264-3:2009 ‘Water based surface embedded heating and cooling systems — Part 3: Dimensioning’.
(16) EN 14336:2004 ‘Heating systems in buildings — Installation and commissioning of water based heating systems’.
(17) EN 1264-4:2009 ‘Water based surface embedded heating and cooling systems — Part 4: Installation’.
(18) Member States may consider ensuring a degree of alignment between the methods followed for adjusting heating systems for the
purpose of compliance with Article 8(1) on heating system requirements and the methods followed to assess performance of
heating systems under typical or average operating conditions, where relevant, under Article 14-15.
(19) EN 15378-1:2017 ‘Energy performance of buildings — Heating systems and DHW in buildings — Part 1: Inspection of boilers,
heating systems and DHW, Module M3-11, M8-11’.
(20) EN 15378-3 ‘Energy performance of buildings –Heating and DHW systems in buildings — Part 3: Measured energy performance,
Module M3-10 and M8-10’.
(21) EN 15500-1:2017 ‘Energy Performance of Buildings — Control for heating, ventilating and air conditioning applications —
Part 1: Electronic individual zone control equipment — Modules M3-5, M4-5, M5-5’.
(23) Commission Delegated Regulation (EU) No 811/2013 of 18 February 2013 supplementing Directive 2010/30/EU of the European
Parliament and of the Council with regard to the energy labelling of space heaters, combination heaters, packages of space heater,
temperature control and solar device and packages of combination heater, temperature control and solar device (OJ L 239,
6.9.2013, p. 1).
Table 12
Possible interpretation of space cooling system requirements
Type of
Possible interpretations for space cooling systems (1) Useful references
requirement
‘overall energy In this context, overall performance refers to the performance of the EN 16798 standard series
performance’ whole process of energy transformation in cooling generators, cooling on cooling systems, e.g.
distribution across the building, cooling emission in individual rooms EN 16798-9 (2),
or spaces of the building and, where applicable, cool storage. It is not EN 16798-13 (3),
limited to performance of cooling generators, but it can include re EN 16798-15 (4)
quirements that affect other parts of the system (e.g. insulation of dis
tribution piping network).
Type of
Possible interpretations for space cooling systems (1) Useful references
requirement
‘appropriate Dimensioning refers to the optimal sizing of the cooling system with EN 1264-3:2009 (5)
dimensioning’ regard to the cooling needs of the building and its spaces.
‘proper Proper installation refers to the need to ensure the system will be able EN 1264-4 (6)
installation’ to operate in accordance with design specifications. Ensuring proper
installation can rely e.g. on national technical guidelines, product
‘appropriate Adjustment refers here to the testing and fine-tuning of the system un EN 16798-17 (8)
adjustment’ der real-life conditions (7) in particular to check and possibly adjust sys
tem functions that can have a significant impact on performance (e.g.
control capabilities — see below).
‘appropriate Concerns control capabilities that space cooling systems can include to EN 15500-1 (9),
control’ optimise performance e.g. automatic adaptation of cooling output of EN 15316-2 (10),
emitters in individual rooms or spaces. EN 15232 (11)
(1) In line with Article 2(3) and 8(1) of the EPBD, this table focuses on active cooling in buildings. While not covered here, it is
worth bearing in mind that passive cooling — e.g. shading — is also effective.
(2) EN 16798-9 ‘Energy performance of buildings — Ventilation for buildings — Part 9: Calculation methods for energy requirements
of cooling systems (Modules M4-1, M4-4, M4-9) — General’.
(3) EN 16798-13 ‘Energy performance of buildings — Ventilation for buildings — Part 13: Calculation of cooling systems (Module
M4-8) — Generation’.
(4) EN 16798-15 ‘Energy performance of buildings — Ventilation for buildings — Part 15: Calculation of cooling systems (Module
M4-7) — Storage’.
(5) EN 1264-3:2009 ‘Water based surface embedded heating and cooling systems — Part 3: Dimensioning’.
(6) EN 1264-4:2009 ‘Water based surface embedded heating and cooling systems — Part 4: Installation’.
(7) Member States may consider ensuring a degree of alignment between: (a) the methods followed for adjusting space cooling
systems in order to comply with the provisions of Article 8(1) on requirements for space cooling systems; and (b) the methods
followed to assess performance of air-conditioning systems under typical or average operating conditions, where relevant, under
Article 14-15.
(8) EN 16798-17 ‘Energy performance of buildings — Ventilation for buildings — Part 17: Guidelines for inspection of ventilation
and air conditioning systems (Module M4-11, M5-11, M6-11, M7-11)’.
efficiencies — Part 2: Space emission systems (heating and cooling), Module M3-5, M4-5’.
Table 13
Possible interpretation of ventilation system requirements
Type of
Possible interpretations for ventilation systems Useful references (1)
requirement
‘overall energy Refers to the energy performance of the ventilation system as a whole, EN 16798-3 (2),
performance’ taking into account e.g. fans energy efficiency, the characteristics of the EN 16798-5-1 (3),
ventilation duct network, heat recovery. EN 16798-5-2 (4)
Type of
Possible interpretations for ventilation systems Useful references (1)
requirement
‘appropriate Dimensioning refers to the optimal sizing of the ventilation system EN 16798-7 (5),
dimensioning’ with regard to the ventilation needs of the building and its spaces. CEN/TR 14788 (6),
CR 1752 (7)
‘proper Proper installation refers to the need to ensure the system will be able N/A
installation’ to operate in accordance with design specifications. Ensuring proper
installation can rely e.g. on national technical guidelines, products
‘appropriate Adjustment refers here to the testing and fine-tuning of the system un EN 12599 (9),
adjustment’ der real-life conditions (8), in particular to check system components EN 16798-17 (10),
and functions that can have an impact on performance (e.g. ductwork EN 14134 (11)
air-tightness).
‘appropriate Concerns control capabilities that ventilation systems can include to EN 15232 (12),
control’ optimise performance e.g. air-flow modulation. EN 15500-1 (13)
(1) The references focus on EU standards. In addition to these, Member States are invited to consult available resources at national
level, e.g. in France, the NF DTU 68.3 ‘Installations de ventilation mécanique’ standard.
(2) EN 16798-3 ‘Energy performance of buildings — Ventilation for buildings — Part 3: For non-residential buildings — Performance
requirements for ventilation and room-conditioning systems (Modules M5-1, M5-4)’.
(3) EN 16798-5-1 ‘Energy performance of buildings — Ventilation for buildings — Part 5-1: Calculation methods for energy
requirements of ventilation and air conditioning systems (Modules M5-6, M5-8, M6-5, M6-8, M7-5, M7-8) — Method 1:
Distribution and generation’.
(4) EN 16798-5-2 | Energy performance of buildings — Ventilation for buildings — Part 5-2: Calculation methods for energy
requirements of ventilation systems (Modules M5-6, M5-8, M6-5, M6-8, M7-5, M7-8) — Method 2: Distribution and generation.
(5) EN 16798-7 | Energy performance of buildings — Ventilation for buildings — Part 7: Calculation methods for the determination
of air flow rates in buildings including infiltration (Module M5-5).
(6) CEN/TR 14788:2006 ‘Ventilation for buildings — Design and dimensioning of residential ventilation systems’.
(7) CR 1752:1998 ‘Ventilation for buildings — Design criteria for the indoor environment’.
(8) Member States may consider ensuring a degree of alignment between the methods followed for adjusting heating systems for the
purpose of compliance with the provisions of Article 8(1) ventilation system requirements and the methods followed to assess
performance of combined heating/air-conditioning and ventilation systems under typical or average operating conditions, where
relevant, under Article 14-15.
(9) EN 12599:2012 ‘Ventilation for buildings — Test procedures and measurement methods to hand over air conditioning and
ventilation systems’.
(10) EN 16798-17 ‘Energy performance of buildings — Ventilation for buildings — Part 17: Guidelines for inspection of ventilation
and air conditioning systems (Module M4-11, M5-11, M6-11, M7-11)’
(11) EN 14134:2004 Ventilation for buildings — Performance testing and installation checks of residential ventilation systems.
2.5.2. System performance assessment and documentation (Article 8(9) of the EPBD)
2.5.2.1. Sco pe o f pe rfo r m an ce a s ses s m en t
Section 2.4.1.3(a) gives guidance on how to interpret the scope of performance assessment (altered part
v whole system) under Article 8(9) of the EPBD. One additional consideration is that it will be beneficial to
ensure a degree of alignment between Article 8(1) and Article 8(9) of the EPBD. This means in particular that,
unless there is a justification for doing otherwise, a system upgrade under Article 8(1) of the EPBD should
generally also be a system upgrade under Article 8(9) of the EPBD. Member States may however wish to deviate
from this approach for smaller, minor upgrades, which could lead to documenting the performance of the
altered part of the system, while not triggering the application of any system requirements
2.5.2.2. O ve r al l perfor m a nc e
Section 2.4.1.3(b) gives guidance on how to interpret overall performance and on how to frame the assessment
of overall performance. In particular, the need to ensure consistency with inspection practices under Articles 14
and 15 of the EPBD is emphasised for the relevant technical building systems. An additional consideration is
that, for system installation, replacement and upgrades that lead to the application of system requirements,
Member States may find it beneficial to ensure a degree of alignment between the tests performed for the
purpose of compliance with the requirements for system adjustment and those that may be required to assess
overall energy performance for documentation purposes.
2.5.2.3. Docu m en t a ti on of s y s tem p erfor m an ce
As mentioned in Section 2.4.1.3(c), Member States are free to determine the form and content of the documen
tation (on system performance) that is passed on to building owners, provided that this documentation covers
the scope of the assessment of overall system performance. It would also be beneficial if this information were
provided in a way that highlights the compliance of the technical building system with the applicable
requirements. A checklist that sets out the applicable system requirements and how these were assessed, and
summarises the results of the assessment (including tests under average or typical conditions) could do this.
As mentioned in section 2.4.1.3(d), it is for Member States to decide whether a new energy performance
certificate (EPC) will have to be issued as a result of the assessment of the technical building system's (or the
altered part's) energy performance. However, Member States are encouraged to require a new EPC where the
performance of a whole system may be affected (i.e. in cases involving installation, replacement or major
upgrades) as, in such cases, it is likely that the performance of the whole building will also be affected.
Member States may also consider it beneficial to consider existing guidelines at national level (34) and outcomes
from relevant EU projects (35).
2.5.3. Inspections (Article 14 and 15 of the EPBD)
2.5.3.1. Es ta b l i s h t r ain in g n eed s
Due to the expanded scope of the EPBD, Member States should evaluate whether new or additional training is
necessary. This is particularly the case for those areas of competence that relate to typical or average operating
conditions.
Member States should also decide whether this training requires re-accreditation. A calendar for providing
training should also be drawn up.
2.5.3.2. Ch a nges i n t h e re por ti n g m et h od ol ogy
Member States should evaluate whether the reporting methodology, report templates, databases, etc. need to be
updated.
(34) E.g. in Germany, the guidelines from AMEV (https://www.amev-online.de/AMEVInhalt/Infobereich/Aktuelles/technisches-monitoring-

2017.docx).
(35) The QUANTUM Project (https://www.quantum-project.eu) has developed an approach for an appropriate and cost effective quality
management process to assess and document building and system performance. In particular, QUANTUM aims to gives recommen
dations on data provided by technical building systems in order to be able to test performance.
2.5.3.3. Ch ange s i n th e d a t ab as e
Member States should evaluate whether the database of reports (where this exists) and reporting mechanisms
need updating or upgrading.
For those systems that are exempt under Articles 14(2) or 14(6) of the EPBD, the databases should be able to
record the period of validity of these exemptions.
2.5.3.4. C ha nges t o t he a ss ura n ce m echa ni sm
Member States should evaluate the need for updating or upgrading the quality assurance process. Reports are
likely to increase in length, which may therefore require further resources.
2.5.4. Building automation and control systems: requirements for mixed-used buildings and maintenance (Article 14(4)
and 15(4) of the EPBD)
2.5.4.1. M i xed - use b u i l d i ng s
The requirements for installing BACS apply to non-residential buildings only. These are buildings that are used
for a purpose other than residential (i.e. office buildings, healthcare buildings, wholesale and retail trade
buildings, educational buildings, hotels and restaurants, etc.)
With regard to mixed-used buildings, i.e. buildings that include both residential and non-residential units (e.g.
a residential building with shops on the ground floor), Member States may identify the most appropriate
approach. However, they should consider the following guidelines in order to avoid legal loopholes.
When systems are integrated (i.e. the non-residential units and the residential ones use the same systems) and
the effective rated output is above the threshold, the following options are open to Member States:
(a) apply the requirements to the whole building;
(b) apply the requirements only to non-residential units;
(c) apply the requirements only to non-residential units if the associated ‘non-residential’ rated output is above
the threshold (36).
When systems are separate (i.e. the non-residential units and the residential ones have different systems) and the
effective rated output of the non-residential units' systems is above the threshold, the requirements should
apply to at least the non-residential units.
2.5.4.2. Ma i nte n an c e o f B AC S
As for any technical building system, BACS should be properly maintained to ensure that they operate
appropriately, in particular when it comes to their ability to predict, detect and address sub-optimal functioning
or malfunctioning of other technical building systems.
It is therefore important that BACS, as other technical building systems, are monitored over their lifetime in
order to check their performance and make any changes needed. This issue is well known and there are
different schemes, from the industry (37) and national authorities (38), as well as relevant standards (39), to
support the proper maintenance of BACS.
(36) In this latter case, the effective rated output associated with non-residential units can be based on the proportion of non-residential units
in the building. This can be calculated using the energy consumption or (though probably less relevant) the surface area. For instance:
a mixed-use buildings with an effective rated output for heating of 500 kW, in which non-residential buildings represent 70 % of total
energy consumption, would lead to a non-residential effective rated output of 0,7 × 500 = 350 kW, which is above the threshold.
(37) E.g. eu.bac system certification (https://www.eubac.org/system-audits/index.html) or, in Germany, VDMA 24186-4 ‘Program of services
for the maintenance of technical systems and equipment in buildings — Part 4: Measurement and control equipment and building
automation and control systems’ (https://www.vdma.org/en/v2viewer/-/v2article/render/15979771).
(38) E.g. in Germany, AMEV Wartung (https://www.amev-online.de/AMEVInhalt/Betriebsfuehrung/Vertragsmuster/Wartung%202014/).
(39) E.g. EN 16946-1:2017 ‘Energy Performance of Buildings. Inspection of Automation, Controls and Technical Building Management’.
3. PROVISIONS ON ELECTROMOBILITY
3.1. Aim: to support the deployment of a recharging infrastructure for electric vehicles
The lack of a recharging infrastructure is a barrier to the take-up of electric vehicles in the EU. The new
provisions aim to accelerate the development of a denser network of this infrastructure. Buildings can promote
electromobility effectively, particularly by focusing on the private sector (car parks in or adjacent to private
buildings) where up to 90 % of charging takes place. The EPBD complements Directive 2014/94/EU of the
European Parliament and of the Council (40) which, inter alia, defines technical specifications for alternative
fuels infrastructure, including recharging points, and requires Member States to adopt national policy
frameworks to ensure their deployment
3.2. Scope of provisions on electromobility
Article 1 of Directive (EU) 2018/844 introduces new provisions related to electromobility into Article 8 of the
EPBD. Those provisions relate to requirements for installing recharging points and ducting infrastructure, as
summarised in the following table.
Table 14
Summary of electromobility requirements
Scope MS obligation
New buildings Non-residential buildings with more Ensure the installation of at least 1 re
and than 10 parking spaces charging point
buildings undergoing Ensure the installation of ducting infra
major renovation structure for at least 1 in 5 parking
spaces
Residential buildings with more than Ensure the installation of ducting infra
10 parking spaces structure for every parking space
Existing buildings Non-residential buildings with more Set out requirements for the installation
than 20 parking spaces of a minimum number of recharging
points — applicable from 2025
Member States are also required to provide for measures to simplify the deployment of recharging points in
new and existing buildings and to address possible regulatory barriers.
All obligations related to electromobility in the EPBD are new obligations. The aim of this section is to provide
clarity to Member States on the correct transposition of these provisions into national law.
3.3. Understanding the provisions on electromobility
3.3.1. Parking spaces (Article 8(2) to 8(8) of the EPBD)
The scope of the obligations in the EPBD extends to certain parking spaces — namely, those located in car
parks
(a) with a minimum number of parking spaces; and
(b) in or adjacent to certain types of building.
3.3.2. When are obligations triggered? (Article 8(2) and 8(5) of the EPBD)
3.3.2.1. B a s ic c r i te r i a
The obligations to install recharging points or ducting infrastructure are triggered depending on whether
a building is new, undergoing a major renovation or already exists. The Directive does not specify who is
responsible for installing the recharging points and ducting infrastructure (i.e. the owner or the tenant). This is
something Member States should determine in their transposing legislation. Where there is a major renovation,
obligations may also be triggered if the electrical infrastructure of the building or of the car park is included in the
renovation measures.
(40) Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the deployment of alternative fuels
infrastructure (OJ L 307, 28.10.2014, p. 1).
The requirements for new buildings and buildings undergoing major renovation apply only to buildings:
(a) with car parks with more than 10 parking spaces; and
(b) where the car park is inside the building or physically adjacent to it.
Where there is a major renovation, the requirement only applies if renovation measures include the car park or
the electrical infrastructure of the building (if the car park is inside the building (41)). Member States may
consider establishing minimum information requirements for permitting procedures which enable the
verification of whether or not this condition is triggered.
3.3.2.2. Bui ldi ng s th at h ave b oth a r e si d e nti al an d a n on-resi d ent ia l fu nc ti on
The EPBD does not include any express provision regulating the application of electromobility requirements
with regard to buildings that have both a residential and a non-residential function (e.g. a residential building
with commercial spaces on the ground floor), Member States may therefore identify the most appropriate
approach for such cases (42).
3.3.3. Meaning of terms (Article 8(2) to 8(8) of the EPBD)
A number of terms are particularly relevant and are not always explicitly defined.
Car park — no express definition is provided in the EPBD. However, within the context of the EPBD, ‘car park’
should exclude on-street parking located on public roads, for example.
Residential/non-residential — this distinction is present in the EPBD, although it is not defined. ‘Residential’
should be interpreted as including single-family and multi-family dwellings. ‘Non-residential’ includes buildings
that are used for a purpose other than residential (i.e. office buildings, healthcare buildings, wholesale and retail
trade buildings, educational buildings, hotels and restaurants, etc.).
Electrical infrastructure (of a building/of a car park) — no express definition is provided in the EPBD.
However it should be understood as referring to the electrical installation (either the whole installation or any
part of it) of the building or of the car park — including the electrical wiring, apparatus and associated
equipment.
Major renovation is defined in Article 2(10) of the EPBD (43). That definition is applicable to the provisions on
electromobility of the EPBD.
Physically adjacent — no express definition is provided in the EPBD
The notion of physical adjacency is relevant where a car park is not located inside a building, but it
nevertheless has clear links with the building.
A priori, physical adjacency implies that the perimeter of the car park touches the perimeter of the building in
at least one place.
When defining, in their national legislation, the scope of the obligation to deploy recharging points and ducting
infrastructure in buildings with car parks which are physically adjacent, Member States could also consider
a number of additional criteria in their national legislation, such as:
(a) Is there a physical/technical connection between the car park and the building?
(b) Is the car park used only or mostly by the occupants of the building?
(c) Is there a degree of joint ownership between the car park and the building?
(41) In paragraph (a), reference to ‘electrical infrastructure’ is made in relation to the building, when a distinction between car park and
electrical infrastructure of the building is necessary. In paragraph (b), reference to ‘electrical infrastructure’ is made in relation to the car
park. Here, the distinction between car park and electrical infrastructure of the car park is not necessary since the electrical infrastructure of
the car park is part of the car park.
(42) Recital 24 of Directive (EU) 2018/844 states that in the implementation of electromobility requirements, Member States should
consider potential diverse conditions, such as the case of buildings that have both a residential and a non-residential function.
(43) ‘major renovation’ means the renovation of a building where: (a) the total cost of the renovation relating to the building envelope or the
technical building systems is higher than 25 % of the value of the building, excluding the value of the land upon which the building is
situated; or (b) more than 25 % of the surface of the building envelope undergoing renovation. Member States may choose to apply
option (a) or (b).
Member States have some flexibility on how to interpret the notion of adjacency and on how to address
specific cases, and are encouraged to take these three criteria into consideration when transposing and
implementing the obligations.
In particular, there may be situations where the car park is not strictly speaking physically adjacent to the
building (e.g. on the other side of a street, or separated from the building by a green area) but it has a clear link
with the building in terms of ownership and/or usage. This would make application of the obligations relevant
and appropriate (e.g. the parking spaces are owned and used by the occupants in the case of a multi-family
buildings).
The following table sets out examples of situations in which the suggested criteria could be applied.
Table 15
Possible connections between buildings and car parks
Criterion Situation Comment Examples
Physical/technical connection
Car park shares the same elec Generally relevant to apply the Car park for a shopping centre
trical infrastructure as the obligations: strong likelihood or a shared residential building.
building that owners of the building
and the car park are the same.
Car park located beside the Assessment will depend on Public or private shared car
building and has separate elec ownership and/or usage. park with several buildings
trical infrastructure nearby.
Use
Users of the building are users Generally appropriate to apply Company car park used by
of the car park the obligations to the car park. company employees.
Ownership
Owner(s) of the building In such situations, the obliga Non-residential building and car
is(are) the same as the tions will generally be appli park owned by a company;
owner(s) of the car park cable to the car park. parking spaces belonging to
apartments in a multi-family
building.
Owner(s) of the building Will depend on the use of the Non-residential building owned
is(are) different from the car park; in most cases, it will by a company and car park
owner(s) of the car park be appropriate to apply the used only or mostly by the
obligations to the car park company's employees; the car
park is rented
3.3.4. Requirements for installation of a minimum number of recharging points (Article 8(3) of the EPBD)
In addition to the installation requirements set out in Article 8(2) and (5) of the EPBD, Article 8(3) requires
Member States to lay down requirements for the installation of a minimum number of recharging points for all
non-residential buildings with more than 20 parking spaces. These requirements must apply by 1 January
2025.
The requirements, to be laid down by 10 March 2020, must at least determine a minimum number of
recharging points per non-residential building with more than 20 parking spaces. Member States also have the
discretion to adopt requirements with a broader scope (such as also including requirements for installation of
ducting infrastructure, or determining a minimum number of recharging points for non-residential buildings
with 20 or fewer parking spaces or for residential buildings).
The adoption of these requirements by 10 March 2020 will ensure that building owners (44) have a period of
almost 5 years (10 March 2020 to 31 December 2024) during which they can take the necessary steps to make
their buildings compliant.
To ensure the proportionate and appropriate deployment of recharging points, Member States should take
different factors into account when determining the minimum number (45):
(a) relevant national regional and local conditions; and
(b) possible diversified needs and circumstances based on area, building typology, public transport coverage
and other relevant criteria.
Member States may decide to carry out an inventory of car parks with more than 20 spaces in order to identify
those which would be subject to these requirements.
The requirements laid down by Member States under Article 8(3) of the EPBD will apply individually to each
non-residential building with a car park that exists on 1 January 2025 and which has more than 20 parking
spaces.
Member States could determine the minimum number of recharging points by taking into consideration, inter
alia, the estimated number of registered electric vehicles in the Member State at the end of 2024 (date after
which the requirements under Article 8(3) of the EPBD are applicable (46)).
For new buildings or buildings undergoing major renovation with more than 20 parking spaces, where the
requirements set out in Article 8(2), including for ducting infrastructure, differ from the requirements laid down
by a Member State pursuant to Article 8(3) of the EPBD, both requirements apply and must be taken into
account.
3.3.5. Directive 2014/94/EU
The EPBD and Directive 2014/94/EU are complementary legislative instruments. Both include provisions on the
deployment of recharging points for electric vehicles, but their scope and the obligations they place upon
Member States differ.
Directive 2014/94/EU sets the overall legislative framework (47) for the standardisation and deployment of
alternative fuels infrastructure (which includes recharging infrastructure for electric vehicles), including user
information, while the EPBD sets specific requirements for installing infrastructure for electric vehicles in
certain buildings.
Directive 2014/94/EU relates to all recharging points (48) (both public and private and including those which
are not necessarily in or physically adjacent to a building). Article 8 of the EPBD only concerns electromobility
in relation to parking spaces in car parks which are in or physically adjacent to buildings (both public and
private).
(44) The EPBD does not specify whether it is the owner, the operator or the tenant of a non-residential building who would be required to
install the recharging point and ducting infrastructure pursuant to Article 8(3). Alternatively, standard lease and/or contract law may
apply. Member States have a degree of flexibility to define the remit of the obligations in transposing the legal obligations of the EPBD.
(45) Recital 26 of Directive (EU) 2018/844.
(46) This is similar to the approach used in Directive 2014/94/EU, Article 4(1).
(47) Directive 2014/94/EU defines alternative fuels and sets out minimum requirements for the building-up of infrastructure for alternative
fuels that require distinct infrastructure (electricity, natural gas and hydrogen), to be implemented using Member States' national policy
frameworks. Importantly, Member States have to adopt national policy frameworks for the development of the market as regards
alternative fuels in the transport sector and the deployment of infrastructure.
(48) A ‘normal power recharging point’ is defined in Article 2(4) of Directive 2014/94/EU as ‘a recharging point that allows for a transfer of
electricity to an electric vehicle with a power less than or equal to 22 kW, excluding devices with a power less than or equal to 3,7 kW,
which are installed in private households or the primary purpose of which is not recharging electric vehicles, and which are not
accessible to the public.’ A combined reading of Article 4(4) of Directive 2014/94/EU excludes recharging points that meet all of the
following conditions from complying with the standards in Annex II of the EPBD: have a power less than or equal to 3,7 kW; are
installed in private households or their primary purpose is not recharging electric vehicles; and are not accessible to the public. The
definition of ‘high power recharging point’, in Article 2(5) of Directive 2014/94/EU, does not contain any similar exclusion of non-
publicly accessible recharging points. The fact that a recharger is not publicly accessible is not in and of itself enough to exclude it from
complying with the technical specifications set out in Annex II to Directive 2014/94/EU. Only normal power sockets installed in private
households and not made accessible to the public are excluded from these definitions. Consequently, all recharging infrastructure
installed under the EPBD is de facto covered by Directive 2014/94/EU standards and requirements, except if the criteria above are
cumulatively met.
Directive 2014/94/EU defines recharging points (including normal power and high power recharging points),
sets common technical specifications for recharging points and enables the Commission to adopt further
standards and requirements in this respect through delegated acts (49). The EPBD makes reference to these
definitions and specifications.
Directive 2014/94/EU requires Member States to adopt national policy frameworks and to include in them
national targets for the deployment of public and private recharging stations (50). In its Article 4, Directive
2014/94/EU sets a number of minimum requirements in relation to the installation, operation and use of
recharging points.
The EPBD sets out specific installation requirements (for non-residential and residential buildings which are new
or undergoing major renovation) and requires Member States to lay down requirements for a minimum
number of recharging points for certain existing buildings.
Under Directive 2014/94/EU, Member States had to notify their national policy frameworks to the Commission
by 18 November 2016. National targets set therein are to ensure that an appropriate number of recharging
points accessible to the public are put in place by 31 December 2020 in order to ensure that electric vehicles
can circulate at least in urban/suburban agglomerations and other densely populated areas, and, where
appropriate, within networks determined by the Member States. Installation requirements in the EPBD relating
to new buildings and major renovations will apply from 10 March 2020 and those laid down by Member
States and relating to existing buildings will apply by 1 January 2025.
The Commission is required under Directive 2014/94/EU to monitor that an additional number of recharging
points accessible to the public are put in place in each Member State by 31 December 2025, at least on the
TEN-T Core Network, in urban/suburban agglomerations and other densely populated areas. Member States
must also take measures within their national policy frameworks to encourage and facilitate the deployment of
recharging points not accessible to the public.
Directive 2014/94/EU extends to all types of recharging infrastructure: for electric vehicles, as well as for
buses (51), trucks and vessels. The EPBD by definition concerns recharging infrastructure for passenger cars and
vans only.
Although Directive 2014/94/EU primarily relates to ‘publicly accessible recharging points’, it also includes
a number of provisions which apply to all recharging points, public and private alike (including those that are
accessible to the public and those that are not). These are requirements which apply in the case of recharging
points installed under the EPBD:
(a) Article 4(3) of Directive 2014/94/EU requires that Member States encourage and facilitate deployment of
charging points not accessible to the public.
(b) Article 4(4) of Directive 2014/94/EU requires that Member States ensure that all normal and high power
recharging points comply with the technical specifications set out in Annex II to Directive 2014/94/EU.
(c) Article 4(12) of Directive 2014/94/EU requires that Member States ensure that the legal framework permits
choice of electricity supply for all recharging points associated with a household or premises.
3.4. Guidelines for transposition of provisions on electromobility
3.4.1. Ensure correct transposition (Article 8(2) to 8(8) of the EPBD)
Member States are required to transpose all these obligations by the transposition date of 10 March 2020. This
includes setting national requirements for a minimum number of recharging points for electric vehicles for
parking spaces in car parks in existing non-residential buildings, even though these do not need to come into
force until 2025 (52).
(49) For instance, the Commission has done so for L-category motor vehicles: Commission Delegated Regulation (EU) 2018/674 (OJ L 114,
4.5.2018, p. 1), available here: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R0674&from=EN
(50) See Article 3(1) second indent, in conjunction with Article 4(1) to 4(3) of Directive 2014/94/EU.
51
( ) The relevant standards for recharging points for e-buses are under development under the Mandate M/533. Adoption is foreseen by end
2019 or early 2020.
(52) The wording of Recital 26 of Directive (EU) 2018/844 rules out a hypothetical alternative interpretation, under which the date of 2025
in Article 8(3) would apply to the transposition and not the implementation of this requirement.
Some definitions originate in Directive 2014/94/EU and therefore should already have been transposed into
national legislation, including:
Electric vehicle (or Plug-in Electric Vehicle (PEV (53))) is defined in Article 2(2) of Directive 2014/94/EU. An
electric vehicle is ‘a motor vehicle equipped with a powertrain containing at least one non-peripheral electric
machine as energy converter with an electric rechargeable energy storage system, which can be recharged
externally’. This definition includes different types of electric vehicles, including electric passenger cars and light
electric vehicles, e.g. motorcycles.
Recharging point is defined in Article 2(3) of Directive 2014/94/EU as: ‘an interface that is capable of
charging one electric vehicle at a time or exchanging a battery of one electric vehicle at a time’
Directive 2014/94/EU also defines ‘normal power’ (Article 2(4)) and ‘high power’ (Article 2(5)) recharging
points.
In transposing the Article 8 provisions in the EPBD, Member States have the discretion to determine (or not to
determine) whether the recharging points to be deployed are to be normal or high power recharging points as
per the definitions set out in Directive 2014/94/EU.
However, the EPBD contains the following new definition which must be transposed:
Ducting infrastructure (54) means ‘conduits for electric cables’ (Article 8(2) of the EPBD). Here, the wording
should be understood in a broad sense, including cable ducting fixed to walls.
3.4.2. Exemptions (non-application) (Article 8(4) and 8(6) of the EPBD)
The requirements to install recharging points and ducting infrastructure are subject to a number of possible
exemptions (non-application). These are set out in Article 8(4) and 8(6) of the EPBD.
3.4.2.1. M e m ber St a te s ' d i sc re ti on n o t to lay d own or a pply re qu i rem e nts in re l ati on to S M Es
Pursuant to Article 8(4) of the EPBD, Member States may decide not to lay down or apply the requirements
referred to in Article 8(2) and (3) of the EPBD to buildings owned and occupied by small and medium-sized
enterprises (SMEs). These are defined in Title I of the Annex to Commission Recommendation 2003/361/EC (55)
as referred to in Article 8(4) of the EPBD.
3.4.2.2. M em ber S tates ' d is c reti on n ot to ap p ly c er ta in req u ir e men ts to spe ci f i c c a tego r i es o f

bui l di ng s
During transposition, Member States may decide not to apply the obligations referred to in paragraphs 8(2),
8(3) and 8(5) in specific situations. These cases are exhaustively listed in Article 8(6) of the EPBD.
3.4.3. Define and lay down requirements for the installation of recharging points (Article 8(2), 8(3) and 8(5) of the EPBD)
3.4.3.1. Tec h ni c a l req ui re me nts for rech ar ging poin ts
Recharging points deployed under the EPBD must comply with the technical specifications set out in Annex II
of Directive 2014/94/EU as well as with any additional technical standards adopted by means of Delegated Acts
under Directive 2014/94/EU — these include normal and high power recharging points and recharging points
for L-category motor vehicles (2- and 3-wheel vehicles and quadricycles) (56).
Article 4(4) of Directive 2014/94/EU requires Member States to ensure that normal and high power recharging
points comply with at least the technical specifications set out in point 1.1 of Annex II, as well as with specific
safety requirements in force at national level.
(53) PEVs include two categories: battery electric vehicles (BEVs) and plug-in hybrid electric vehicles (PHEVs).
(54) The EPBD covers recharging points and ducting infrastructure, while Directive 2014/94/EU does not specifically refer to ducting
infrastructure.
(55) Commission Recommendation 2003/361/EC of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises
(OJ L 124, 20.5.2003, p. 36).
(56) Delegated Regulation (EU) 2018/674.
In transposing the EPBD (notably Article 8(2), 8(3) and 8(5)), Member States have the discretion as to whether
or not to set out whether the recharging points to be deployed are normal or high power recharging points, as
per the definitions in Directive 2014/94/EU.
3.4.3.2. O t he r re qui r em en ts
Additional requirements may also apply depending on the building, and in many cases on whether the
recharging point will or will not be publicly accessible (57).
Requirements relating to electromobility should also be seen in the context of Directive 2009/72/EC of the
European Parliament and of the Council (58) that sets the market framework for the efficient integration of
batteries (including vehicle batteries) into the electricity system. However, in order for vehicles to provide the
necessary flexibility to the system through smart charging and vehicle to grid (59), charging infrastructure and
the underlying electricity infrastructure should be fit for purpose.
Provided that the requirements of the EPBD are transposed, the following additional (type of) element(s) could
be incorporated into national legislation:
(a) specifications for ducting infrastructure (60);
(b) specifications relating to fire safety (61);
(c) specifications for recharging points (62) including relating to accessibility for persons with disabilities (63);
(d) requirements related to dedicated parking infrastructure for electrical bicycles, including (electric-) cargo-
bikes, and for vehicles of people with reduced mobility (64);
(e) requirements related to smart/intelligent metering (65);
(f) requirements related to smart charging (66);
(g) requirements which would facilitate the use of car batteries as a source of power (vehicle to grid) (67);
(h) for publicly accessible charging points, requirements related to ad hoc charging and transparency of
recharging prices (68);
(57) Some of these requirements are obligatory in certain situations by virtue of Directive 2014/94/EU.
(58) Directive 2009/72/EC of the European Parliament and of the Council of 13 July 2009 concerning common rules for the internal market
in electricity and repealing Directive 2003/54/EC (OJ L 211, 14.8.2009, p. 55).
(59) ‘Smart charging’ means the possibility to shift charging to times when electricity is widely available and networks are not congested.
Smart charging can facilitate optimisation of load on the electricity system, in particular where loads may increase due to the number of
electric vehicles charging at the same time. ‘Vehicle to grid’ means the possibility to feed electricity stored in the car battery back onto the
grid.
(60) See for example the Austrian legislation.
61
( ) To address any fire risks associated with electric vehicles and charging infrastructure.
(62) Technical specifications in Annex II to Directive 2014/94/EU, which includes a reference to standard EN 62196-2.
(63) Accessibility of recharging points for people with disabilities should address the following components: the user interface of the
recharger, including payment interface, the accessibility of the plug and connections with the car, and all user information needed to use
the recharger itself (in line with the provisional agreement resulting from interinstitutional negotiations reached on 19 December 2018
on a Proposal for a directive of the European Parliament and of the Council on the accessibility requirements for products and services
(COM(2015) 615 — C8-0387/2015 — 2015/0278(COD))), the location of the recharging point should be accessible (for example
reachable for persons using a wheelchair); the parking space for vehicles needing an accessible recharging point should also be
accessible, ensuring sufficient manoeuvring space; a minimum number of recharging points should be ‘accessible recharging points.’
Relevant standardisation mandates to CEN, Cenelec and ETSI include: mandate M/420 in support of European accessibility
requirements for public procurement in the built environment and mandate M/473 to include ‘Design for All’ in relevant standardisation
initiatives.
(64) Recital 28 of Directive (EU) 2018/844.
65
( ) See Directive 2014/94/EU, Article 4(7).
(66) Recital 22 of Directive (EU) 2018/844 states that buildings can be leveraged for the smart charging of electric vehicles. Smart charging
may require data transmission capabilities. A number of Member States have included references to smart charging in their legislation.
See for example legislation in the UK — Automated and Electric Vehicles Act 2018 (Chapter 15 in part II)/http://www.legislation.gov.
uk/ukpga/2018/18/section/15/enacted; France — Arrêté du 19 juillet 2018 relatif aux dispositifs permettant de piloter la recharge des
véhicules électriques; and Finland -https://www.finlex.fi/fi/laki/alkup/2017/20170478
(67) Recital 22 of Directive (EU) 2018/844 — basis for Member States to use car batteries as a source of power.
(68) See Directive 2014/94/EU, Article 4(9) and 4(10) respectively.
(i) requirements related to recharging point operators being free to purchase electricity from any EU electricity
supplier (69) and the possibility for users to contract with a supplier other than the entity supplying
electricity to the household or premises (70).
Member States should determine to what extent such specific technical requirements for the installation need to
be defined in national legislation.
Simplification of the deployment of recharging points
Article 8(7) of the EPBD requires Member States to provide for measures to simplify deployment of recharging
points in new and existing residential and non-residential buildings and to address possible regulatory barriers,
including permitting and approval procedures (71). This obligation must be fulfilled by transposing the EPBD
into national legislation by the transposition deadline at the latest.
3.4.3.3. Sp l it i n ce n t i v es a n d ad m i ni s t ra t iv e com pl ica ti on s (72)
Lengthy and complex approval procedures can be a major barrier to owners and tenants installing recharging
points in existing multi-tenant residential and non-residential buildings. Obtaining the necessary approvals can
create delays or prevent installation
‘Right to plug’ or ‘right to charge’ requirements ensure that any tenant or co-owner is able install
a recharging point for an electric vehicle without having to obtain (potentially difficult) consent from the
tenant's landlord or from the other co-owners.
In Spain, for example, legislation allows a co-owner to install a recharging point for private use when located in
an individual parking place and when the association of co-owners has been informed in advance. The co-
owners cannot block the installation. The cost of the installation and of the subsequent electricity consumption
is assumed by the individual who has installed the recharging point.
3.4.4. Sustainability (Article 8(8) of the EPBD)
Article 8(8) of the EPBD requires that Member States consider the need for coherent policies for buildings, soft
(or active) and green mobility, and urban planning.
The Sustainable Urban Mobility Planning (SUMP) initiative is a cornerstone of EU urban mobility policy. Incor
porating electromobility early in the development of mobility plans adopted under SUMP can help to realise the
objectives of Article 8(8) of the EPBD.
SUMP provides a long-term, multi-disciplinary, comprehensive approach, covering all transport modes, to help
tackle issues such as congestion, air and noise pollution, climate change, road accidents, health impact, accessi
bility for persons with disabilities and older persons, inefficient use of public space and improved quality of life.
It is complemented by the SUMP guidelines and by comprehensive information on SUMP, available in the
‘Mobility Plans’ section of the Eltis website — the urban mobility observatory (73). Over 1 000 cities have
already implemented sustainable urban mobility plans and the concept has proven its value in bringing together
different public and private stakeholders in urban mobility planning.
In this context, the Urban Agenda for the EU was initiated within the framework of intergovernmental
cooperation in 2016 with the overall objective of including the urban dimension in policies affecting cities in
view of achieving better regulation, better funding and better knowledge for cities in Europe. The Agenda is
implemented through Partnerships in a multi-level governance format, and one of the Partnerships is focused
on Urban Mobility. It aims to propose solutions to improve the framework conditions for urban mobility for
European cities including issues relevant to technological advancements, encouraging the use of active modes of
transport as well as improving public transport.
(69) See Directive 2014/94/EU, Article 4(8).

(70) See Directive 2014/94/EU, Article 4(12).
(71) These measures should be without prejudice to property and tenancy laws in the Member State.
(72) Recital 23 of Directive (EU) 2018/844 — Building codes can be effectively used to introduce targeted requirements to support the
deployment of recharging infrastructure in car parks of residential and non-residential buildings. Member States should provide for
measures to simplify the deployment of recharging infrastructure with a view to addressing barriers such as split incentives and adminis
trative complications which individual owners encounter when trying to install a recharging point on their parking space.
(73) http://www.eltis.org/mobility-plans
Member States without requirements or guidelines on bicycle parking should develop as a minimum, guidelines
to local authorities on the inclusion of bicycle parking requirements in building regulations and urban planning
policies. These guidelines should include both quantitative (i.e. number of parking spaces) as well as qualitative
elements.
3.4.5. Long-term policy and financial measures (Article 2a of the EPBD)
In addition, Member States are encouraged to consider policy and financial measures also as part of their long-
term renovation strategies (Article 2a of the EPBD). These can support and accelerate the deployment of electro
mobility infrastructure in existing buildings, in cases of major renovation (Article 8(2) and (5)) and to meet the
minimum requirements for non-residential buildings set in Article 8(3), taking into account that the situation
on the relevant markets over time is likely to develop, gradually overcoming certain current market failures.
4. PROVISIONS ON THE CALCULATION OF PRIMARY ENERGY FACTORS
4.1. Aim: transparency in the calculation of primary energy factors
The energy performance of a building must be expressed by a numeric indicator of primary energy use, which
is the energy needed to satisfy the energy needs of a building. ‘Primary energy’ is calculated from the amounts
of energy flows delivered, using primary energy conversion factors (PEFs) or weighting factors (74). Energy flows
include electric energy drawn from the grid, gas from networks, oil or pellets (all with their respective primary
energy conversion factors) transported to the building for feeding the buildings technical systems, as well as
heat or electricity produced on-site.
Under the EPBD, Member States are responsible for calculating PEFs for different energy carriers used in
buildings. The calculation of PEFs may be affected by different national electricity mixes, the efficiency of the
power plants share, the share of renewable energy, and different calculation methodologies. Experience has
shown that figures reported by Member States differ significantly and the procedures used to define PEFs are
not always transparent.
To meet the objectives of energy efficiency policy for buildings, the transparency of energy performance
certificates should be improved by ensuring that all the necessary parameters for calculations are set out and
applied consistently, for both minimum energy performance requirements and for certification.
The objectives of the Annex I, point 2 of the EPBD are to introduce a degree of transparency in calculating
PEFs, to ensure the central role of the building envelope and to address the role of on-site and off-site
renewable energy sources (75).
4.2. Scope of the provisions on the calculation of primary energy factors
Annex I of the EPBD has been amended in order to improve the transparency and consistency of the
33 different regional and national energy performance calculation methodologies currently used.
In particular, Annex I, point 2 of the EPBD has been amended to (i) better reflect the energy needs associated
with the typical use of a building in the light of developments in the construction sector; and (ii) give additional
things to consider when setting PEFs.
(74) ‘Weighting factor’ is the terminology used in the CEN overarching standard when referring to PEFs, so ‘primary energy factors’ and
‘weighting factors’ are considered to have an equivalent meaning. Both terms are used by Member States.
(75) With regard to the default PEF value (2.1) for electricity generation in the Energy Efficiency Directive, it has to be noted that in the
context of the EPBD, Member States are free to apply their own PEFs, including for electricity from the grid, even at sub-national level.
Article 3 requires the adoption of national methodologies for calculating the energy performance of
buildings. The provisions of Article 3 and those related to the calculation of cost-optimal levels (Articles 4
and 5 (76)) remain unchanged.
4.3. Understanding of the provisions on calculating primary energy factors
4.3.1. The energy needs to be considered (Annex I, point 2, first paragraph, of the EPBD)
In order to calculate the energy performance of a building, the energy needs should be initially defined. They
refer to the amount of energy (regardless of its source) to be delivered in order to maintain intended indoor
conditions. Defining the energy needs of a building is an important step for calculating its energy performance,
in line with the cost-optimal methodology. This gradually expands the system boundary from energy needs, to
energy use and then to delivered energy and finally to primary energy.
The EPBD sets out that the energy needs for space heating, space cooling, domestic hot water, ventilation,
lighting and potentially other areas are to be covered, reflecting the extended definition of ‘technical building
systems’ (Article 2(3) of the EPBD). As with determining the energy uses of a building, it is for Member States
to decide if additional energy needs from the broader definition of technical building systems will be considered
in calculating energy performance. Member States are also invited to note that built-in lighting is an important
energy use for all buildings, in particular for the non-residential sector.
This provision highlights that the calculation of energy needs must lead to optimise health, indoor air quality
and comfort levels, as defined by Member States at national or regional level, in calculating energy needs (77).
These elements (78) are crucial, as buildings are defined in the EPBD as constructions for which energy is used
to condition the indoor climate. Moreover, better performing buildings provide higher comfort levels and
wellbeing for their occupants and improve healthy indoor climate conditions. These requirements are not new,
as the EPBD already required (before the amendment) general indoor climate conditions to be taken into
account when determining the minimum energy performance requirements (Article 4).
The cost-optimal calculation exercise should be designed in such a way that differences in air quality and
comfort are transparent, in line with the Delegated Regulation (EU) No 244/2012. To avoid the deterioration of
indoor air quality, comfort and health conditions in the European building stock, the stepwise tightening of
minimum energy performance requirements resulting from the implementation of nearly zero-energy buildings
(NZEBs) across Europe should be done, together with appropriate strategies dealing with indoor
environment (79).
4.3.2. Definition of PEFs (Annex I, point 2, second paragraph of the EPBD)
The EPBD clarifies that PEFs or weighting factors per energy carrier may be based on national, regional or local
annual, seasonal or monthly weighted averages or on more specific information made available for individual
district systems. This explicitly acknowledges the current flexibility for Member States when defining PEFs.
(76) The calculation of energy performance of buildings for setting minimum energy performance requirements must also follow the
common methodology framework in the Commission Delegated Regulation (EU) No 244/2012 of 16 January 2012 supplementing
Directive 2010/31/EU of the European Parliament and of the Council on the energy performance of buildings by establishing
a comparative methodology framework for calculating cost-optimal levels of minimum energy performance requirements for buildings
and building elements (OJ L 81, 21.3.2012, p. 18).
77
( ) The EPB Standard EN 16798-1 (revision of EN 15251) ‘Indoor environmental input parameters for design and assessment of energy
performance of buildings addressing indoor air quality, thermal environment, lighting and acoustics’ provides reference comfort
conditions. Annex B.7 of this standard provides WHO health-based criteria for indoor air and suggested guideline values for indoor and
outdoor air pollutants.
(78) Together with the definition of the outdoor conditions (climate).
(79) Commission Recommendation (EU) 2016/1318 of 29 July 2016 on guidelines for the promotion of nearly zero-energy buildings and
best practices to ensure that, by 2020, all new buildings are nearly zero-energy buildings (OJ L 208, 2.8.2016, p. 46).
One example relates to the treatment of electricity (and to some extent district heating) networks, where the use
of seasonal or monthly factors for electricity instead of single annual average values could be more suitable in
the case of heating. Similarly, the photovoltaic component of generation is better described on a seasonal
basis. Local conditions can also be taken into account when defining PEFs for the purpose of calculating the
energy performance of buildings.
4.3.3. Pursuing the optimal energy performance of the building envelope (Annex I, point 2, third paragraph of the EPBD)
Annex I, point 2, third paragraph of the EPBD requires Member States to ensure that the optimal energy
performance of the building envelope is pursued in applying primary energy and weighted factors. Reducing
the overall energy demand is a crucial component when optimising the energy performance of a building. In
this context, the consideration of the envelope should not be underestimated (80). In addition, technical building
systems and building automation and control systems (BACS) have more impact and are most easily optimised
in combination with highly performing envelopes.
In line with the Commission's recommendation for the promotion of nearly zero-energy buildings (81),
renewable energy and efficiency measures should work together.
4.3.4. On-site and off-site renewable energy sources (Annex I, point 2, fourth paragraph of the EPBD)
The EPBD provides that Member States may take into account the renewable energy sources (RES) supplied
through the energy carrier and the RES that are generated and used on-site when defining PEFs. The provision
does not specify the treatment of on-site or off-site RES, allowing Member States to calculate PEFs according to
local or national conditions (82).
The EPBD explicitly sets out the possibility of addressing renewable energy sources when defining PEFs. Several
considerations are worth recalling in this regard:
(a) the energy produced on-site reduces the primary energy associated with the delivered energy;
(b) the calculation of primary energy factors includes both non-renewable energy and renewable energy
supplied to the building (total PEF);
(c) the separation of primary energy into non-renewable and renewable components allows for the comparison
of results between electricity from different renewable energy sources, and also with electricity generation
from fossil fuels;
(d) a distinction between renewable and non-renewable primary energy factors can help people to understand
the energy consumption of a building.
The EPBD further clarifies that it is possible to consider renewable energy sources (supplied through the energy
carrier, and generated on-site), provided that the calculation of primary energy factors applies on a non-dis
criminatory basis.
Generally, the principle of non-discrimination requires that comparable situations should not be treated
differently and that different situations should not be treated in the same way unless such treatment is
objectively justified. This allows Member States to choose the arrangements that are best suited to its particular
situation, taking into account specific national circumstances (83).
(80) The consideration of building envelope elements and their influence on the energy performance of buildings also depends on the
calculation methodologies applied. For instance, the ‘energy balance’ approach, which takes into account both energy losses (related to
heat loss) as well as energy gains (from passive capture of solar irradiance on buildings and building elements) when calculating the
energy performance of a building or a building element of the building envelope, is an approach used in some Member States to take
into account solar conditions (in relation to Annex I, point 4 of the EPBD).
(81) Recommendation (EU) 2016/1318.
(82) According to EN ISO 52000, there are three types of PEFs: the non-renewable PEF, the renewable PEF and the total PEF.
(83) Case C‑195/12: Industrie du bois de Vielsalm & Cie SA (‘IBV’) vs Région wallonne (Walloon Region) [2013], paragraph 50-52, 62.
Deducting the renewable energy share from the total primary energy factor (non-renewable factor) is one
possible way to ensure that on-site and off-site renewables are treated comparably, preventing limits to the
calculation of the energy performance of buildings from having an effect on national or regional renewable
energy policies.
Member States may similarly balance the principle of non-discrimination of renewable energy sources as
compared to non-renewable energy sources. One possible way of ensuring non-discriminatory treatment is
ensuring transparency on figures, conventions (i.e. ways in which Member States treat particular aspects of the
PEF calculation, such as frequency of revision of values, choice between retrospective and prospective values,
definition of network boundaries, variation of PEF over time, etc.) and underlying assumptions for calculating
renewable and non-renewable PEFs.
The following table describes possible situations that may arise, providing examples of the non-discriminatory
treatment of on-site and off-site RES:
Table 16
Treatment of on-site and off-site RES — examples
Examples Are they comparable? Is RES treatment comparable/non-discriminatory treatment?
On-site RES Off-site Not fully comparable The results can significantly vary based on the treat
situations. ment of off-site RES
Off-site RES is Some issues to be considered include:
e.g. PV panels high RES component connected to the grid,
in the grid (e.g. PV — Energy provided from any kind of grid (e.g. electri
PEF = 0 which most likely city or district heating) is often a mix of different
panel park) delivers electricity to
RES produced on-site is sources.
deducted from the PEF = 1 the building through
a mix of different — When comparing situations, it is not only the tech
energy delivered
sources. nology (or mix of technologies) to be considered,
but also the quality of the mix (i.e. the RES com
Even with the same ponent). RES should therefore be reflected in the
technology (e.g. PV calculation of PEF values.
panels) the results
could be different. — Deducting the renewable energy share from PEFs
(non-RES PEF) could help ensure that on-site and
off-site RES are treated in a comparable positive
way.
e.g. district heating Not fully comparable — Transparency on figures, conventions and underly
network with high RES situations. ing assumptions for calculating renewable and non-
component (e.g. solar, renewable PEFs is important.
wind)
PEF = 0,5
4.4. Transposition of the provisions on the calculation of primary energy factors
Member States are encouraged to review their building codes and, if not already stated in their current national
calculation methodologies, make the energy needs clear in their respective transposition measures by the trans
position date.
5. VERIFICATION AND ENFORCEMENT
As part of their wider responsibility and work to ensure the effective implementation and enforcement of the
EPBD, Member States will also have to consider how to verify compliance with and to enforce:
(a) system requirements established pursuant to Article 8(1) of the EPBD;

(b) requirements for the installation of self-regulating devices under Article 8(1) of the EPBD;
(c) requirements for the installation of BACS under Articles 14(4) and 15(4) of the EPBD;
(d) requirements for electromobility under Article 8 of the EPBD;
It is important that owners, facility manager or energy managers of buildings falling under these requirements
are made aware of the entry into force of the requirements in advance, so that they can plan and carry out the
necessary works in the best way.
In addition, as regards requirements for installing self-regulating devices:
(a) where these requirements apply to new buildings, Member States may rely on existing processes related to
building permits;
(b) where these requirements apply to existing buildings where heat generators are replaced, Member States
may rely on existing processes to verify the compliance of heating systems with the requirements set in
Article 8(1), as the replacement of heat generators will generally constitute a system upgrade and trigger the
application of the requirements.
In addition, as regards requirements for installing BACS:
(a) As all Member States have put in place inspections of heating and air-conditioning systems, or equivalent
alternative measures, before the amendment of the EPBD, Member States may consider using those schemes
to verify and enforce the requirements for installing BACS, as all buildings that fall under these
requirements are also in scope for mandatory inspections (or alternative measures) under Articles 14
and 15 of the EPBD;
(b) Member States may also consider linking the supervision and enforcement of these requirements with the
enforcement of system requirements under Article 8(1) of the EPBD, as the installation, replacement or
upgrade of a heating, air-conditioning and/or ventilation system may be an opportunity to also install
a BACS.
6. SUMMARY OF RECOMMENDATIONS
6.1. Recommendations relating to technical building systems and their inspections, self-regulating devices
and BACS
(1) The amendment to the EPBD updates and extends the definition of technical building systems, introducing
additional definitions for specific systems (e.g. building automation and control systems). When
transposing these definitions, Member States are encouraged to provide additional details on the systems
concerned, while ensuring full alignment with the Directive, and also referring, where relevant, to any
applicable standards or technical guidelines, in order to aid understanding by professionals.
Sections 2.2.1, 2.3.1.1, 2.3.1.2, 2.3.1.3, 2.3.1.5 and 2.4.1.1 of this document.
(2) The EPBD requires system requirements to be drawn up for all technical building system requirements. This
particularly entails drawing up requirements for systems that were not required to have them before the
amendment. In doing this, all areas of system requirements must be covered: overall energy performance,
proper installation, appropriate dimensioning, adjustment and control. Applicable standards and technical
guidelines at EU and national level should also be considered, in particular the Energy Performance of
Buildings standards developed by CEN (84) under Mandate M/480 (85).
Sections 2.2.1, 2.3.1.1, 2.3.1.2, 2.4.1.2 and 2.5.1 of this document.
(84) European Committee for Standardisation (https://www.cen.eu/Pages/default.aspx).

(85) M/480 Mandate to CEN, Cenelec and ETSI for the elaboration and adoption of standards for a methodology calculating the integrated
energy performance of buildings and promoting the energy efficiency of buildings, in accordance with the terms set in the recast of the
Directive on the energy performance of buildings (Directive 2010/31/EU).
(3) Member States are encouraged to support awareness and understanding by building owners, system
installers and other parties involved, of the interventions that trigger the application of system
requirements and the assessment and documentation of system performance in all buildings (Article 8(1)
and 8(9) of the EPBD). These interventions are the installation, replacement and upgrade of a system. In
particular, Member States are invited to give additional details on what should be considered a system
upgrade, possibly differentiating between different types of systems, and putting a particular emphasis on
those systems that are the most common in the national building stock.
Sections 2.3.1.4, 2.4.1.3 and 2.5.2 of this document.
(4) ‘Self-regulating devices’ is a concept that could be interpreted in different ways. In transposing the
provisions on installing self-regulating devices, it will be useful for Member States to give additional details
on which devices can meet the relevant needs, in particular for those systems that are the most frequently
used in the national building stock. In relation to the same provisions, Member States should clarify
situations where the self-regulating capability could be applied at zone (as opposed to room) level. Lastly,
it will be useful if Member States can support awareness and understanding by building owners, system
installers and other parties involved, of the situations that lead to the requirement for installing self-
regulating devices in existing buildings being applied, in particular by providing additional details on what
to interpret as a replacement of heat generators in ambiguous cases.
Sections 2.2.3, 2.3.3.2, 2.3.3.3(a) and 2.4.3.1 of this document.
(5) BACS installed in non-residential buildings pursuant to the obligations of Article 14(4) and 15(4) of the
EPBD are required to comply with the definition of Article 2(3a) and include the capabilities listed in
14(4) and 15(4), at least for the technical building systems that fall under the scope of Articles 14 and 15.
Those capabilities go beyond what are expected from usual BACS. Therefore, in transposing these
requirements, Member States should ensure the interested parties are made aware of the exact implications
of these requirements and give clear guidance on how to assess the capabilities of BACS with regard to the
requirements and, where relevant, on how to implement the required upgrades.
See sections 2.2.4, 2.3.3.1, 2.3.3.3(b), 2.4.3.2 and 2.5.4 of this document.
(6) Some provisions apply only when feasibility conditions are met: technical and economic feasibility for
requirements on the installation of self-regulating devices and BACS; and technical, economic and
functional feasibility for system requirements. Member States are responsible for ensuring that the
assessment of feasibility is properly framed and supervised as part of enforcement and verification
mechanisms. In doing so, it is recommended that Member States support the interpretation and
assessment of feasibility, e.g. through dedicated guidance and procedures.
See sections 2.3.4 and 5 of this document.
(7) Inspections of technical building systems are already in place in many Member States but the amendment
of the EPBD has led to significant modifications of the scope of these inspections. This is particularly the
case for the threshold on effective rated output above which inspections are required and the types of
systems that should be inspected. Member States are encouraged to support understanding of these
changes and their implications for all interested parties. In particular, it will be helpful for Member States
to support the identification of combined systems that should be inspected and give guidance on
inspecting ventilation systems, where applicable.
See sections 2.2.2, 2.3.2.1 to 2.3.2.5, 2.4.2.1(a) and 2.4.2.1(b), 2.4.2.2, and 2.5.3 of this document.
(8) One significant change in inspections of technical building systems provided for in Articles 14 and 15 of
the EPBD is the need to consider (where relevant) system performance under typical or average operating
conditions. This should lead to changes of inspection practices and the related framework, e.g. training
schemes. In order to support this transition, it is recommended that Member States translate this general
requirement into technical guidance to support the consideration of performance under typical or average
operating conditions in practice, for the different types of systems affected.
See section 2.3.2.6 and 2.4.2.1(c) of this document.

(9) In transposing the provisions on the inspection of heating and air-conditioning systems, it is
recommended that Member States give due consideration to the framing and supervision of exemptions
that can apply. In particular, Member States will find it beneficial to set out the capabilities expected from
continuous electronic monitoring systems in residential buildings, as alternatives to inspections, and to
ensure that energy performance contracts that cover technical building systems, when these lead to
exemptions, comply with applicable requirements and good practices.
See sections 2.3.2.7, 2.3.2.8, 2.3.2.9, and 2.4.2.1(d) to 2.4.2.1(g) of this document.
6.2. Recommendations relating to electromobility
(10) Provisions on electromobility introduce new terms and concepts into building regulation in most Member
States. Member States are encouraged to provide guidance on interpreting these new terms and concepts
in order to ensure correct implementation. This applies particularly to the scope of the requirements, the
relation between buildings and car parks (e.g. the notion of physical adjacency) and the scope of the
renovation measures that trigger the requirements (e.g. the car park or electrical infrastructure).
See sections 3.2, 3.3.1, 3.3.3 and 3.4.1 of this document.
(11) The requirements for the installation of a minimum number of recharging points in non-residential
buildings (Article 8(3)) are an important aspect of the provisions on electromobility. The definition and
implementation of these requirements should be based on careful planning, in order to ensure an optimal
coverage of the targeted buildings and smooth deployment thereafter. In laying down these requirements,
Member States are particularly encouraged to draw from the experience of EU Member States that have
already drawn up similar requirements.
See section 3.3.4 of this document.
(12) The provisions of the EPBD on electromobility are complementary to Directive 2014/94/EU. It is
recommended that Member States pay particular attention to implementing the two Directives
consistently, in particular when it comes to drawing up requirements for the installation of a minimum
number of recharging points in non-residential buildings. This may require working closely with the
ministry and teams responsible for implementing Directive 2014/94/EU as well as taking a multi-
disciplinary, comprehensive approach across policy areas such as buildings, urban planning, transport and
mobility.
See Sections 3.3.4 and 3.3.5 of this document.
(13) The provisions of the EPBD are equally complementary to Directive 2009/72/EC which promotes the
development of a flexible electricity system. In order to efficiently integrate new loads into the electricity
system, such as electric vehicles, smart charging and vehicle to grid technologies need to be enabled.
Those concepts are especially relevant for charging at homes, offices and car parks where cars are often
parked for several hours and hence can provide services to the grid operator. Investments in charging
infrastructure under the EPBD should take due account of existing and future smart charging and vehicle
to grid standards (e.g. ISO 15118) and be connected to fully functional smart metering systems.
(14) Member States are encouraged to clarify the technical specifications and other requirements for recharging
points that will be deployed under the electromobility provisions of Article 8, including Article 8(3), of
the EPBD. Considerations such as specifications relating to minimum charging capacity, ducting
infrastructure, fire safety, accessibility for people with reduced mobility including persons with disabilities
and smart charging can help ensure effective implementation and can support the uptake of electric
vehicles.
See Section 3.4.3 of this document.

(15) Regulatory barriers and market failures may impede the deployment of electromobility infrastructure and,
consequently, the uptake of electric vehicles. Regulatory simplification, long-term planning and financial
incentives may be necessary to tackle these challenges. To simplify the deployment of recharging points
(Article 8(7) of the EPBD), Member States are encouraged to ensure the ‘right to plug’ to address split
incentives and administrative complications, notably in the case of multi-family dwellings. In addition,
Member States are encouraged to consider policy and financial measures also as part of their long-term
renovation strategies (Article 2a of the EPBD) which can support and accelerate the deployment of electro
mobility infrastructure in existing buildings, both in cases of major renovation (Article 8(2) and (5) of the
EPBD) and to meet the minimum requirements for non-residential buildings set in Article 8(3)), taking
into account that the situation on the relevant markets over time is likely to develop, gradually
overcoming certain current market failures.
See sections 3.4.3.3 and 3.4.5 of this document.
6.3. Recommendations relating to the calculation of primary energy factors
(16) PEFs should be regularly reviewed, to reflect changes in the national energy mix and in the energy market
over time, and in underlying calculation methodologies.
See section 4.2 and 4.3.2 of this document.
(17) When determining their national calculation methodology, Member States should always try to find the
best combination of energy efficiency and renewable measures. Member States should always ensure the
optimal energy performance of the building envelope and, therefore, renewable energy solutions should be
used in conjunction with optimum energy savings from the building envelope and its technical building
systems.
See section 4.3.1, 4.3.3 and 4.3.4 of this document.
(18) Technical guidelines could be provided at national or regional level on how to improve the indoor quality
of buildings by avoiding thermal bridges, inadequate insulation and unplanned air pathways that can
result in surface temperatures below the dew point of the air and dampness.
6.4. Cross-cutting recommendations
(19) As for all other provisions of the EPBD, enforcement and supervision will be paramount for the effective
implementation of the provisions discussed in this Annex. Member States should pay particular attention
to enforcement and supervision measures, including verification and control of exemptions where
applicable, when transposing these provisions. Where relevant, Member States will find it beneficial to
make use of schemes that are already in place (e.g. inspections schemes for technical building systems).
See sections 2.3.1.4, 2.3.2.8, 2.3.3.3, 2.3.4, 3.3.2, 3.4.2 and 5 of this document.

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L 165/70 EN Official Journal of the European Union 21.6.

COMMISSION RECOMMENDATION (EU) 2019/1019

(Text with EEA relevance)

THE EUROPEAN COMMISSION,

HAS ADOPTED THIS RECOMMENDATION:

2. This Recommendation is addressed to the Member States.

Done at Brussels, 7 June 2019.

For the Commission

2.2.2. Technical building systems: inspections (Articles 14 and 15 of the EPBD)

2.3.1.1. E xte ns i on of th e d e fi ni t i o n of a ‘ tec hnica l b ui l di ng system ’ (Ar tic le 2 (3 ) of the E PB D )

Before the amendment With the amendment Type of change

heating space heating clarification of scope

cooling space cooling clarification of scope

ventilation ventilation no change

hot water domestic hot water clarification of scope

lighting built-in lighting clarification of scope (1)

n/a building automation and control new technical building system

n/a on-site electricity generation new technical building system

2.3.1.2. Ne w t e ch n i c a l b u il d i n g sy s tem s in the EPBD (Ar ti c le 2 (3) a nd 2(3 a) of the EP B D)

2.3.1.3. Us efu l d ef i n i ti o n s : ‘ h ea ti ng s y s tem ’ a nd ‘a ir-c ond iti on in g sy stem’ (A r tic l e 2 (1 5 a) an d 2 ( 1 5 )

2.3.1.4. Wh en d o t he ob l igati on s ap p l y ? ( Ar ti c le 8( 1) a nd 8 (9) of the EPBD )

2.3.1.5. M ea nin g of ter m s ( Ar tic l e 8( 1) a nd 8(9 ) o f t he EPBD )

2.3.2.2. E ffec ti v e r a ted out put ( A r t i c le 2 ( 17 ), 1 4 an d 15 of the EPBD )

(a) rated heat output for a heating system;

(b) rated cooling output for an air-conditioning system.

2.3.2.3. H e atin g an d c om b i n ed h e at in g an d ven ti la ti on system s (Ar ti cl e 1 4 of the EPB D)

2.3.2.4. C om bin e d he atin g an d ai r- co n d it i oni n g an d vent i la ti on syst ems (Ar t i cl e 1 4 an d 15 of t he

2.3.2.5. He a t p u m p s an d ro o f top u n it s ( A r ti cle 2( 18 ), 1 4 a nd 1 5 of the EPBD )

2.3.2.6. Pe rfor m an c e un d er t y p i c a l or a vera ge oper ati n g cond iti ons (R ec i tal 3 6 , A r ti c le 1 4 (1 )

2.3.2.7. Ele c troni c mon itor in g an d e f fe c tive co ntro l f u nc ti on a li ti es in r esi dent i al bu il di ng s

2.3.2.8. E xempt io n f r om in s pec ti on s ( A r ti cl e 14 (2), 14 (4), 14(5 ), 1 5(2 ), 1 5 (4 ), an d 1 5 (5 ) of t he

The amendment to the EPBD introduces exemptions if:

(a) guaranteed savings to be achieved by implementing the measures of the contract;

(c) reference date to establish achieved savings;

(e) Submission of reports

2.3.3.1. B ui l di ng a u tom a tion an d c on tr ol system s ( BACS) (Ar ti cl e 2 (3a ), 14 (4) a nd 1 5 (4) of t h e

2.3.3.2. S e l f-r eg u l at i n g d e v i ce s ( A r ti c le 8 ( 1) of the EPBD )

This means in particular that:

Examples of self-regulating devices

Device Type of system Regulation capability

Individual thermostat Standalone heaters or air-conditioners Control of heat output depending on

(a) Heating, air conditioning, or both?

Cases that should trigger the requirement to install self-regulating devices

Should requirement to install self-regulating

New Installation of heating system Yes

New Installation of space cooling system Yes

Existing Replacement of heat generators Yes, only for heating system

Existing Replacement of cool generators Up to Member State

(b) Room- or zone-level?

2.3.3.3. W he n d o th e o bli gati on s ap pl y? ( Ar tic l e 8 (1 ) , 1 4(4 ) an d 1 5(4 ) of t he E PBD )

(a) Self-regulating devices (Article 8(1) of the EPBD)

Article 2(15b) of the EPBD defines a ‘heat generator’ as follows:

(a) the combustion of fuels in, for example, a boiler;

(b) BACS (Article 14(4) and 15(4) of the EPBD)

The notion of ‘feasibility’ is relevant for:

(25) This mention was already included before the amendment.

Interpretation of technical, economic and functional feasibility

Type of feasibility (1) Meaning Examples

The heating system makes it impossi No Yes (but not

‘proper Installation of electric equipment, including lighting, in ac N/A