Ecodesign requirements for air heating and cooling products (review)

Energy Saving Trust welcomes the revision of the EUs ecodesign requirements for air heating and cooling products (EU 2016/2281) and we would support standards in the UK aligning to these. In particular and in line with ECOS submission, we think the following should be considered: 1) Expand the scope of the ecodesign requirements We suggest the scope of the ecodesign requirements should be extended to include…

The European Heating Industry (EHI) would like to thank the European Commission for consulting us on the draft impact assessment roadmap for the review of the ecodesign regulation for air heating products, cooling products, high temperature process chillers and fan coil units (Regulation (EU) 2281/2016) and would like to share with the European Commission some first considerations.

Uniclima represents the heating, ventilation, air-conditioning and refrigeration industries. It has 83 companies or groups that manufacture essential equipment for the energy renovation of buildings and for the industry sector.

Filed in French · English published by the European Commission

Eurochiller welcomes the opportunity to contribute to the Call for Evidence on the Ecodesign requirements for air heating products, cooling products, high temperature process chillers, and fan coil units. As a leading manufacturer of industrial process chillers, we support the introduction of new regulations to enhance market transparency and ensure fair competition.

EPEE, the voice of the air-conditioning, heat pump, and refrigeration industry in Europe, supports the EU Ecodesign and energy labelling policies and agrees with the need to keep the legislation up-to-date and in line with the latest technological developments. This paper provides EPEEs position to the Call for Evidence opened by the European Commission on this dossier on 21 June 2024.

Daikin would like to express our appreciation to the Commission and the study team for conducting this review and providing stakeholders with the opportunity to give input. We believe that further increases in MEPS are unnecessary/unreasonable at this time.

We welcome the long-awaited review of the Ecodesign regulation of air heating and cooling products covered by EU 2016/2281 and similar products that could also be in the scope of Ecodesign rules. We support the position paper of ECOS/EEB/Coolproducts.

Enel supports the EU Ecodesign and energy labelling policies and agrees with the need to keep the legislation up-to-date and in line with the latest technological developments, with cost-effectiveness and proportionality criteria in mind.

Eurovent with the attached paper provides some input to the public Call for Evidence on the revision of the lot 21. The paper in particular focuses on: - The importance of the new F-Gas regulation for the future development of the units - Eurovent proposal for A/A process and IT cooling - Eurovent proposal for VHT process chillers - Current landscape of free cooling - Heat recovery and simultaneous heating and…

Panasonic Heating, Ventilation and Air-conditioning Europe would like to thank the European Commission for the opportunity to provide a contribution to the call for evidence on the review of Ecodesign requirements for air heating products, cooling products, high temperature process chillers, and fan coil units.

In the call for evidence related to the evaluation and impact assessment performed in the framework of the revision of the Ecodesign requirements for air heating and cooling products, the free-cooling is mentioned as a missing technology in the present regulation that could hinder further energy efficiency gain.

As we move toward a climate-neutral future, the role of natural gas in its current form is increasingly uncertain. To achieve our sustainability goals, it is essential to introduce biofuels, fuel mixtures, and other "green" alternatives. The combustion of these new fuels must be optimized for maximum efficiency, with emissions kept at acceptably low levels.

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative "Energy efficiency ecodesign requirements for air heating and cooling products (review)". Please find detailed comments in the Attachment.

The Japan Business Council in Europe (JBCE), representing companies of Japanese parentage operating in Europe, and the Japan Refrigeration and Air Conditioning Industry Association (JRAIA), representing manufacturers of refrigeration and air conditioning equipment in Japan, would like to commend the efforts of the European Commission and the study teams regarding the revision of the Ecodesign Regulation…

We are a manufacturer of stationary process chiller and welcome the revision. The vast majority of our chillers are operated by customers indoors, where the temperature never falls below 5°C (the lowest ambient temperature in both EU2015/1095 and EU2016/2281 regulations).

The situation today is that many end users want to have a natural refrigerant. The first choices would be hydrocarbon or ammonia. In many cases the 2 options are very expensive or impossible due to the risk assessment. Therefor they come to us and ask for a CO2 solution. Technically we can easily solve the task, but very often we are turned down due to the energy frame on the building.

We are a manufacturer of chillers with either propane (R290) or CO2 (R744) as a refrigerant, and we find parts of the testing conditions in commission regulation 2016/2281 unrealistic. For propane we think the testing conditions are ok, however the testing conditions with a 5K temperature differential on the hot side for water-water comfort chillers and high-temperature process chillers are not typical for a CO2…

District heating and cooling (DHC) are critical for transitioning away from fossil fuels, currently serving 77 million Europeans and offering scalable decarbonization solutions with a 2030 phase-out target for new fossil fuel additions according to the Efficient District Heating and Cooling requirements of EED.

Réseau Cler welcomes the revision of ecodesign requirements for air heating and cooling products (EU 2016/2281) and supports the position of ECOS/EEB/Coolproducts (of which latter campaign we are part) also submitted to this call for evidence. Regarding the scope of the regulation, it shall be extended to chillers using evaporative condensing and free cooling.

On behalf of ECOS/EEB/Coolproducts, we welcome the revision of ecodesign requirements for air heating and cooling products (EU 2016/2281). We propose the extension of the scope to chillers using evaporative condensing and free cooling.

Assotermica, the Italian association that represents manufacturers of appliances and components for environmental climatic comfort, wants to provide its contribution in the attached file within the revision of Lot 21 Ecodesign Regulation. Comments are focused on the warm air heaters technology.

While it is recognized that recovery and use of waste heat is referenced in several EU legislations, certain applications for this free energy source continue to be overlooked. Current schemes focus on waste heat recovery in the context of DHC applications which are complex and costly to implement and require considerable infrastructure and municipal planning.