Rising temperatures and the growing frequency of extreme heat events are placing summer thermal comfort at the centre of the debate on building energy policy in Europe. Against this backdrop, the European Solar Shading Organisation (ES-SO) proposes incorporating the Ladder of Cooling as a reference framework for the implementation of the Energy Performance of Buildings Directive (EPBD).

The proposal sets out a sequence of measures that prioritises the prevention of overheating through urban design, solar shading, insulation and passive ventilation before resorting to active cooling systems. This approach would help reduce cooling demand, ease pressure on electricity grids during periods of peak consumption and improve the resilience of buildings to climate change. In addition to reinforcing the principle of ‘energy efficiency first’, the initiative aims to provide Member States with practical guidance on integrating thermal comfort, health and climate adaptation into the transposition of the EPBD, without introducing new regulatory obligations.