EUPAG: The REHVA Tool for Policy Advocacy

What EUPAG is and who it brings together

EUPAG — the EU Policy and Advocacy Group — is the structure through which REHVA’s member associations, HVAC professionals, building designers and engineers, and industry supporters give a collective voice to the sector in EU policymaking. It exists because the building services sector has expertise that is indispensable to well-designed legislation, but that expertise does not automatically reach those who draft it. EUPAG closes that gap.

The Group operates under the principles set out in the REHVA Manifesto, which calls for technology neutrality, performance-based regulation, system-level thinking, a single EU market underpinned by harmonised standards, and the cross-border recognition of HVAC professional qualifications. These are not abstract commitments: they translate directly into concrete positions on every legislative dossier the Group follows. REHVA’s advocacy is built on a holistic, performance-based, and technology-neutral approach to the energy transition, and the Manifesto gives EUPAG a stable normative reference point from which to engage regardless of the political cycle.

Without early engagement in EU policy processes, decisions are made before the sector can effectively shape them. EUPAG’s purpose is to ensure that REHVA and its members are present when key choices are being made — not after.

From monitoring to institutional credibility

EUPAG has evolved from simply monitoring legislation to helping shape it through position papers, formal consultations, and direct dialogue with EU institutions. The change is evident: today, EU bodies actively seek REHVA’s input rather than only hearing from it through public consultations.

Several recent engagements illustrate this. In February 2026, REHVA was invited to a breakfast meeting with Kurt Vandenberghe, Director General of DG Climate Action, on efficient buildings and support for vulnerable communities via the Social Climate Fund (ETS2) [[1]]. In March 2026, REHVA participated in a stakeholder workshop on the revision of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action, attended by Pierre Schellekens, Director of Energy Policy Strategy and Coordination at DG ENER, and Yvon Slingenberg, Director of Strategy, Analysis and Planning at DG CLIMA [[2]]. In April 2026, the EESC issued a specific request to REHVA to contribute to the hearing on opinion TEN/872 on the Strategy for Housing Construction — one concrete sign of a working relationship that has grown steadily, with the 2025 Brussels Summit hosted at the EESC premises [[3]]. At CLIMA 2025, Niels Ladefoged, Acting Head of Unit ENER B.3, acknowledged REHVA and its member associations as valuable partners in the energy transition and in translating European policy goals into national practice [[4]].

EUPAG dossiers in 2025–2026

EUPAG follows the Commission’s annual work programme and engages on every dossier of direct relevance to the HVAC sector. For each, a formal position paper has been published and disseminated, in most cases accompanied by a LinkedIn communication.

EPBD implementation

The central file of this period is the implementation of the recast EPBD (EU/2024/1275), which entered into force on 28 May 2024 and must be transposed by 29 May 2026. On 30 June 2025, the Commission adopted a support package comprising a delegated regulation, an implementing regulation, and a comprehensive guidance document with thirteen thematic annexes (guidance documents for Member States) [[5]]. REHVA has set up a dedicated task group on Technical building systems, indoor environmental quality and inspections. Other provisions under close EUPAG scrutiny include the BACS thresholds, the Minimum Energy Performance Standards for the non-residential stock, requiring renovation of the worst-performing of non-residential buildings by 2030 and by 2033, and the IEQ requirements.

Life-cycle Global Warming Potential [[6]]

On 16 December 2025, the Commission adopted the delegated regulation under Article 7(3) of the EPBD (C(2025) 8723), establishing a Union methodology for calculating the whole life-cycle GWP of new buildings, anchored in EN 15978 [[7]] and aligned with the Level(s) framework. The life-cycle GWP will have to be calculated and disclosed in energy performance certificates for all new buildings with a floor area larger than 1,000 m² from 2028, and for all new buildings from 2030. REHVA engaged in the stakeholder consultation preceding its adoption and published a position paper [[8]].

Heating and Cooling Strategy

REHVA participated in the Commission’s stakeholder consultation on the Heating and Cooling Strategy, flagging the risk that current subsidies allocation criteria can result in oversized installations with poor performance, and proposing EU-wide guidelines to prioritise spending on measurable outcomes [[9]]. A position paper was published and circulated [[10]].

Ecodesign and Energy Labelling for space heaters [[11]]

REHVA published its comments [[12]] in January 2026 on the Ecodesign and Energy Labelling review for space heaters, advocating for system-level performance metrics over stand-alone product assessments, in line with the Manifesto’s position on fair competition between integrated building solutions.

IEQ Model Regulation [[13]]

In January 2025, REHVA published a Model Indoor Environmental Quality Regulation [[14]] as a reference framework for Member States transposing the IEQ provisions of Articles 5 and 8 of the recast EPBD, drawing on technical input from member associations across Europe.

EU Energy Governance and energy efficiency after 2030

REHVA submitted its contribution to the revision of Regulation (EU) 2018/1999 in March 2026 [[15]], addressing the integration of National Building Renovation Plans into the EU’s climate governance architecture. In April 2026, REHVA also responded to the Commission’s call for evidence on the energy efficiency legal framework after 2030, setting out the sector’s priorities for the next legislative cycle [[16]].

REHVA’s principles and the Manifesto

All EUPAG positions are grounded in the REHVA Manifesto [[17]]. Its core principles — technology neutrality, performance-based regulation, system efficiency, harmonised EU methods and standards, cross-border recognition of professional qualifications, and the alignment of European funding with European rules — serve as the practical standard against which every legislative proposal is assessed. Where a regulatory requirement targets a specific technology rather than a performance outcome, REHVA’s position is that it should instead define what is to be achieved and allow qualified professionals the flexibility to find the optimal solution for each building. This is the line REHVA has held consistently across the EPBD, Ecodesign, and Heating and Cooling Strategy negotiations.

Next steps

Two internal structures have been piloted to broaden EUPAG’s reach.

·         A contact group on policy advocacy, begun on the Ecodesign dossier, has achieved a 23% engagement rate amongst member associations.

·         A contact group on communications, focused on disseminating REHVA’s policy outputs, including through the REHVA Journal, has reached 46%.

The immediate external priorities are to deepen engagement with the European Parliament and extend REHVA’s presence towards Member State authorities, where transposition decisions are being finalised.

Members, supporters, and national associations wishing to contribute to EUPAG’s work are encouraged to contact the REHVA Policy and Advocacy Officer at fr@rehva.eu.

References