
150 R. Hinrichs-Rahlwes
For the energy savings target of 20% by 2020, which is not legally binding, progress is insuffi-
cient. With the Energy Efficiency Directive (Energy Efficiency Directive 2012) adopted in 2012,
there is a comprehensive legal framework now, but with a “lack of appropriate tools for monitor-
ing progress and measuring impacts on the Member State level” (European Commission 2013c,
page 5) and without sufficient certainty to reach the 2020 target.
The Green Paper identifies four key issues for consultation, the first of which is about targets,
relating “to the types, nature and level of targets and how they interact. Should the