MBA input to the EPBD inception impact assessment

22 March 2021

As part of the European Green Deal, the European Commission plans to revise the Energy Performance of Buildings Directive (EPBD) to ensure delivery of the EU climate ambition for 2030 and 2050. In this context, the European Commission is now consulting stakeholders on the need for a revision. The inception impact assessment is a first step that will be followed by a public consultation, which will last a couple of months.

The Modern Building Alliance’s input to the inception impact assessment:

Decarbonisation of the building stock must be based on a deep reduction of energy consumption, as it is the very first step to achieving the Renovation Wave that is part of the European Commission’s Green Deal agenda. We call on EU policy makers to support an ambitious EPBD and to further recognise the instrumental role of buildings in achieving the EU’s climate goals in all climate-related policies and strategies.

Due to their performance, durability, weathering resistance, low maintenance, cost-effectiveness, light weight and design flexibility, plastic insulation materials and window profiles are the solution of choice for retrofitting the largely inefficient European building stock.

Based on the above, the Modern Building Alliance supports the Option 2: Non regulatory measures and the Option 3: Amend the EPBD to translate the actions proposed in the Renovation Wave and the increased ambition towards building decarbonisation into legislation. All new or revised measures of the EPBD should be directed towards extensive energy renovation and reinforce the political direction for the coming decades.


The Modern Building Alliance is calling for an EPBD revision that is ambitious in terms of:


  • Depth of renovation – priority should be given to the renovation of the building envelope (energy efficiency first principle), as a complete and effective thermal insulation renovation saves any kind of energy (from fossil to renewable).


  • The full deployment of Energy Performance Certificates to the market with their possible use in building renovation passports.


  • An increased renovation rate – instruments to encourage or ensure energy renovation works, including targets, progress indicators, financing and the introduction of Minimum Energy Performance Standards, must be in place to reduce the energy consumption of the building stock as required to meet the EU climate and energy efficiency targets.


  • Requirement of the involvement of accredited fire safety experts – as is already the case with energy experts – in renovation processes as well as in regular fire and electrical safety inspections to ensure the quality, compliance and safety of buildings.


Deep energy renovation will help to achieve high quality performance of the building stock and is also an opportunity to improve other key dimensions of the environment in which we live. It can lead to improved health and comfort, reduced energy poverty, the creation of jobs and economic growth and greater fire safety.

Achieving highly energy efficient and decarbonised buildings is an ambition that requires many solutions, such as high-performance insulation, resource-efficient materials, renewable energy and energy storage technologies. These innovations involve fire risks and opportunities. Fire safety must neither lag behind nor impede this evolution. It must accompany it.

Such renovation works should take a holistic approach to fire safety with consideration given to the following 7 layers: prevention, detection, early suppression, evacuation, compartmentation, structural safety and firefighting.

The MBA also believes that a revised EPBD offers the opportunity to embed fire safety competency into EU legislation. Skilled and competent professionals with clear roles and responsibilities, who are involved during the buildings’ design, construction and maintenance phases, will ensure a safe transformation of the building stock.

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Renovation also offers the opportunity to upgrade old electrical installations and to install fire detection systems, alarms and suppression systems. This would prove beneficial at a time when building infrastructure is deemed to become more integrated with sustainable mobility solutions like private and public electro mobility.