HOTREC considers that the revision of the Energy Performance of Buildings Directive (EPBD) is important to reach carbon neutrality by 2050.
It is positive that awareness-raising on the cost savings companies will have at a later stage is included in the proposal. But companies should not be penalised with tax increases, otherwise, the potential savings will be jeopardised.
We are concerned with new infrastructural adjustments that need to be done by companies, as the last revision of the Directive took place in 2018 (the Member States needed to comply by mid-2021). This will bring more costs and burdens to companies, especially SMEs.
The Directive should take into account the different levels of renovation across the EU (e.g. Zero NET building concept).
Infrastructures for sustainable mobility are relevant for the hospitality sector (e.g. car charging stations; bicycle parking stations). Nevertheless, the level of detail of the proposal is unproportionate. Subsidiary should prevail. In addition, specific financing instruments and incentives should be foreseen especially for SMEs.