Offentligt
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR ENERGY
Directorate B – Just Transition, Consumers, Efficiency and Innovation
B.3 – Buildings and Products
Brussels
ENER.B.3/NL/ener.b.3(2025)9209320
Dan Belusa
Denmark
Subject:
Ref.:
Your letter concerning the need under the EPBD for preparing a fossil-
fuelled boiler phase-out plan
Ares(2025)6217331
Dear Mr Belusa,
The Cabinet of Commissioner for Energy and Housing, Dan Jorgensen, has forwarded
your email of 30 July 2025 to me for reply, as our unit is in charge of the questions you
raise.
In your email you refer to a public debate over whether Denmark is exempt from the
obligation to submit a fossil fuel boiler phase-out plan, as part of its National Building
Renovation Plan (“NBRP”) under Directive (EU) 2024/1275 on the energy performance
of buildings (“EPBD”), based on the reasoning that natural gas supply in Denmark is
expected to be fully covered by biogas by 2032 and ask for advice. Below is a summary of
the legal provisions that can hopefully clarify matters.
Under Article 3 of the EPBD, all Member States are required to submit a draft NBRP to
the Commission by 31 December 2025. This submission must adhere to the template set
out in Annex II to the Directive. Specifically, Annex II, point (c) provides an overview of
implemented and planned policies and measures and lists, under point (f), as a mandatory
indicator “the
decarbonisation of heating and cooling, including through district heating
and cooling networks, and the phasing out of fossil fuels in heating and cooling with a
view to a complete phasing out of fossil fuel boilers by 2040”.
The Commission will assess
the draft NBRPs in line with Article 3(5) and may issue country-specific recommendations.
It will then be for Member States to update their NBRPs to take into account the
Commission assessment and to submit a final version by 31 December 2026.
Any plan by the Danish government to fully decarbonise the natural gas grid by 2032
should be outlined or referenced in the National Building Renovation Plan. In this context,
as regards biogas consumption within the EU, it may only be counted once towards the EU
renewables and greenhouse gas reduction targets, in line with the Renewable Energy
Directive (Directive (EU) 2018/2001). The Commission is confident that the full use of
the Union database for biofuels will ensure this in the near future. Exports or imports of
biogas should of course be taken into account when considering whether a national gas
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111