Ecodesign requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans (review)
66 submissions from 60 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 197 submissions on this file. Shown here: the 66 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
52 submissions from industry — companies and their trade associations — against 7 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 7.4 industry submissions for every one from civil society.
Industry 52Civil society 7Public authorities, academia, other 7
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
10 of 60
in the EU Register
61
full-time lobbying staff
€3.1M+
declared costs a year
29
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 18 Feb 2022 — it ran from 21 Jan 2022.
Policy area
Energy (DG ENER)
Where it stands
In planning
Adoption expected
31 Dec 2027 · in 485 days
How it got here
Call for evidence · impact assessment18 Feb 2022
Also on the Commission’s pipeline for this file, with no date recorded: Reg draft, Reg.
2 blocks of text on this file were submitted, identically, by three or more organizations. Shared text is a fact about the filings; what it means is for the reader.
3 organizations: Perotti Stefano e Ferigo Gianni snc, piccola impresa installatrice, srl
“Single-block air-to-air air conditioners without external units are in some cases the only solution if classic split systems with external motor condensers cannot be installed. In the context of the thermohydraulic system in which my company operates, there are a number of applications where this type of solution appears to be the only possible alternative to ensure efficient comfort and respect for various…”
3 organizations: Hugro Technics, Tradesam a.s., VSA Belgium
“Air-to-air monobloc air conditioners without outdoor unit are sometimes the only solution whenever traditional split systems with an outdoor condensing unit cannot be installed. My company operates in the construction and installation sector and very often this is the only viable solution if we want to meet our customers needs while complying with architectural, municipal, regional or condo regulations and…”
The Environmental Investigation Agency (EIA) welcomes the proposed common energy label for similar products and the introduction of requirements for comfort fans. However, we are concerned that the impact assessment takes an environmental backstep by omitting policy measures aimed at promoting uptake of low global warming potential (GWP) refrigerants.
Norwegian Electric Heating Association – Elvarme Norge - welcomes the Commission’s initiatives and opportunity to send feedback on the call for evidence for the impact assessment on the energy labelling requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans. Our main concern is the approach to merge products without main common functionality under common energy labels.
We are a rental company that operates throughout Europe. For our thousands site-huts (office units) we currently offer the use of the fixed double duct solutions for cooling and heating. There are different reasons for using fixed double duct and not split units. - In our installations we are unable and the customers mainly don't want to have the outdoor units (of split units).
The French renewable energy association (SER) is convince of the usefulness of the energy labelling to help consumers to choose less energy consuming products and to help therefore to reduce the energy consumption of the EU.
Single-block air-to-air air conditioners without external units are in some cases the only solution if classic split systems with external motor condensers cannot be installed. In the context of the thermohydraulic system in which my company operates, there are a number of applications where this type of solution appears to be the only possible alternative to ensure efficient comfort and respect for various…
Filed in Italian · English published by the European Commission
We welcome this initiative to revise the Ecodesign and Energy Labelling requirements for Air-to-air Conditioners and Comfort Fans. These appliances considerably contribute to households’ energy consumption and the monthly energy bill of consumers.
As a commercial agent in the thermohydraulic sector, I became aware of the draft revision of European legislation on the design and energy labelling of air-air air conditioners and heat pumps. I take part in this invitation to express my views. I agree with the principles expressed regarding the development of increasingly efficient and circular economy products.
Filed in Italian · English published by the European Commission
EuropeOn is the European Association of Electrical Contractors. With 1.8 million professionals in over 300.000 businesses and with a turnover of over 200 billion euros, electrical contractors provide electrical installations for buildings and infrastructure, enabling cities and citizens to take part in the energy transition.
Air-to-Air monobloc air conditioners without being out by unit are sometimes the only solution which has traditionally split systems with an outby Condensing unit cannot be installed. My company operating in the construction and installation sector and very often this is the only viable solution if we want to meet our customers needs to deal with architectural, community, regional or Condo regulations and…
Filed in Dutch · English published by the European Commission
We are responding to this CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT with the aim to express our concern comment about the revision of the Ecodesign Regulation and Energy Labeling Scheme. According to our experience as HVAC engineers Association, several specific products such as: air-to-air split air conditioner with “outdoor” unit located inside the building (the connection between the “outdoor” unit and the…
As a sales agent in the ambient air conditioning sector, I have taken note of plans to revise EU legislation in relation to energy design and labelling for air-conditioning and air-to-air heat pump equipment. In view of this, I am of the opinion that I should express my view on the matter.
Filed in Portuguese · English published by the European Commission
It seems, that nobody thought about monobloc air conditioners preparing the study and the document. The new regulation can eliminate monoblock air conditioners from the market, which would leave people, who live in legacy buildings, historical centres or other buildings where no outside items can be installed on the facade.
ZERO - Associação Sistema Terrestre Sustentável, welcomes the review of the Commission Regulation (EU) 206/2012 and (EU) 626/2011, recognizing that ecodesign and energy labelling is paramount to accelerate the establishment of circular economies and to stimulate the production of higher efficiency products.
The adoption of reviewed regulation for this product group is already heavily delayed. With this consultation we are relieved to see the process finally moving forward and we expect the Commission to make sure any further delays in the final steps of the review are strictly avoided.
Single-block air-to-air conditioners without external units in some cases are the only air conditioners solution if classic split systems equipped with motor-condensers cannot be installed external. In the context of the thermohydraulic system in which my company operates, there are several applications in which this type of solution appears to be the only possible alternative to ensure comfort.
Filed in Italian · English published by the European Commission
The Italian legislation strictly adapted to the rules applicable for the installation of air conditioners/heat pumps. These rules are specifically addressed within the Italian Legislative Decree No n.42/04 and the Presidential Decree No 31/2017 and many other municipal building regulations.
Filed in Italian · English published by the European Commission
As a sales agent in the airconditioner & heating sector, I’ve recently become aware of the plans to review the EU legislation regarding the design and energy labelling for air conditioners and air-to-air heat pumps.
As a sales agent in the airconditioner & heating sector, I’ve recently become aware of the plans to review the EU legislation regarding the design and energy labelling for air conditioners and air-to-air heat pumps.
I have become aware of this invitation to comment on ecodesign and energy labelling of air conditioners and I want to contribute with my personal experience. In the city in which I live, Florence, there are a number of historic centres and valuable buildings that would be rubbed aesthetically if external units were installed on their facets.
Filed in Italian · English published by the European Commission
EHPA would like to thank the European Commission and the study team for the work already carried out and welcomes the opportunity given to send feedback on the call for evidence for the impact assessment on the energy labelling requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans.
EHPA would like to thank the European Commission and the study team for the work already carried out and welcomes the opportunity given to send feedback on the call for evidence for the impact assessment on the Ecodesign requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans. Thermal Comfort EHPA appreciates that thermal comfort of occupants has been taken into account.
Although the initiative to update the energy label is certainly positive we have a strong concern about the passage in (Ares(2022)465851) Chapter B. Objectives and policy options that purpose “a single energy label for the heating function of reversible air conditioners and local space heaters”.
I support the European Commission’s invitation to express my opinion on the initiative to review the Ecodesign and Energy Labelling Regulations for air conditioners. In my daily technical assistance activity carried out mainly in the Ferrara area, there are large areas of historic centre where it is not possible to install air conditioners with external units due to architectural constraints, municipal regulations…
Filed in Italian · English published by the European Commission
The European Infrared Heating Alliance (EIHA) welcomes the European Commission’s revision of ecodesign and energy labelling requirements for local space heaters (LSH) in order to align them with the latest technological and market developments. We are a supporter of the Commission’s ecodesign and energy labelling framework, as it provides energy savings and contributes to achieving Europe’s climate objectives.
Air-to-air monobloc air conditioners without outdoor unit are sometimes the only solution whenever traditional split systems with an outdoor condensing unit cannot be installed. My company operates in the construction and installation sector and very often this is the only viable solution if we want to meet our customers needs while complying with architectural, municipal, regional or condo regulations and…
CEFACD, the European association representing manufacturers of individual heating and cooking appliances, is a strong supporter of the European Commission’s energy labelling framework and welcomes the initiatives to keep product requirements in line with the latest technological and market developments.
As one of the leading specialist seller and installer in the consumer market of air treatment products in the Czech Republic we know that Air-to-air monobloc air conditioners without outdoor unit are sometimes the only solution whenever traditional split systems with an outdoor condensing unit cannot be installed (e.g.
Good Day, We are a Romanian company engaged in the marketing of air conditioning systems for Rezidential, Commercial and Industrial use. Trading monobloc air conditioning systems without external unit. In the following, we understand that these systems will be disqualified, which puts us at a disadvantage. We have projects, works, where we cannot fit these monobloc climate systems without external unity.
Filed in Romanian · English published by the European Commission
We would like thank the Commission for sharing the call for evidence on airco, comfort fans and local heaters and for providing us with the opportunity to comment on it. While we support the Commission’s intention to update the labels, some of the energy efficiency calculations and the option of removing the least efficient products from the market, we would like to see it done without harming manufacturers…
We agree as an installation company to the European Commission’s call for an opinion on the initiative to review the Ecodesign and Energy Labelling Regulations for air conditioners. In the daily technical assistance activity carried out mainly in the area of Verona, Veneto and Italy, there are large areas of historic centre where it is not possible to install air conditioners with external units due to architectural…
Filed in Italian · English published by the European Commission
Eurovent has already provided the EC with its comments on the review of the Commission Regulations (EU) 206/2012 and (EU) 626/2011 with a set of Position Papers. The comments remain. Eurovent would like to reiterate and reinforce its positions as already presented in its past Position Papers, the below (non-exhaustive) list summarises them (we recommend to carefully re-assess our past position papers).
Eurovent has already provided the EC with its comments on the review of the Commission Regulations (EU) 206/2012 and (EU) 626/2011 with a set of Position Papers. The comments remain. Eurovent would like to reiterate and reinforce its positions as already presented in its past Position Papers, the below (non-exhaustive) list summarises them (we recommend to carefully re-assess our past position papers): Single and…
This legislation is absurd. I'm talking from a perspective of an installer who is focusing on installing air conditioners without our door unit (which because of the compact technology have of course a lower effiiciency class).
Air-to-air monobloc air conditioners without outdoor unit are sometimes the only solution whenever traditional split systems with an outdoor condensing unit cannot be installed. My company operates in the construction and installation sector and very often this is the only viable solution if we want to meet our customers needs while complying with architectural, municipal, regional or condo regulations and…
The Electric Underfloor Heating Alliance (EUHA) welcomes the Commission’s initiatives to review the energy labelling policies to keep them updated and aligned with the latest technological developments. Nonetheless, we strongly disagree with the European Commission’s consideration to merge the energy labelling classes under ENER Lot 10 (air-to-air heat pumps, air conditioners, and comfort fans) and ENER Lot 20…
EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, welcomes the opportunity to provide comments on the ENER Lot 10 energy labelling proposals to review Regulation (EU) No 626/2011.
EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, welcomes the opportunity to provide comments on the ENER Lot 10 ecodesign proposals to review Regulation (EU) No 206/2012.
17/02/2022 Buongiorno, I agree with the European Commission’s invitation to express my opinion on the initiative to review the Ecodesign and Energy Labelling Regulations for air conditioners. In my daily technical assistance activity carried out mainly in the area of VENEZIA, where there are very large areas of historic centre, where it is not possible to install air conditioners with external units due to…
Filed in Italian · English published by the European Commission
I support the European Commission’s invitation to express my opinion on the initiative to review the Ecodesign and Energy Labelling Regulations for air conditioners. In my daily technical assistance activity carried out mainly in the area of RAVENNA and IMOLA, there are large areas of historic centre where it is not possible to install air conditioners with external units due to architectural constraints, municipal…
Filed in Italian · English published by the European Commission
The Association of the European Heating Industry (EHI) represents 90% of the European market for heat and hot water generation, heating controls and heat emitters, 75% of the hydronic heat pump market, 80% of the biomass central heating market (pellets, wood) and 70% of the solar thermal market.
I support the European Commission’s invitation to express my opinion on the initiative to review the Ecodesign and Energy Labelling Regulations for air conditioners. I therefore believe that European regulation must necessarily take into account the importance of all types of air-air conditioners and heat pumps according to their specificities and applications.
Filed in Italian · English published by the European Commission
My name is Alberto Ferlenga, as a designer, as a professor of architectural design, as a former rector of the Iuav University of Venice, a university specifically focused on architectural and urban design and design, and today President of the Iuav Foundation, I have often been working on the technological upgrading of existing buildings, where the issue of the visual impact of the installations is a delicate issue.
Filed in Italian · English published by the European Commission
I support the European Commission’s invitation to express my opinion on the initiative to review the Ecodesign and Energy Labelling Regulations for air conditioners. In my daily technical assistance activity carried out mainly in the area of Genoa (Italy), there are large areas of historic centre where it is not possible to install air conditioners with external units due to architectural constraints, municipal and…
Filed in Italian · English published by the European Commission
We are pleased to contribute about the labeling requirements for air-to-air conditione. We(Japan Business Council in Europe :JBCE) and Air Conditioning Industry Association (JRAIA) made our position paper in Sep 2021 (attached file). JBCE and JRAIA would like to make further contributions whenever it is useful and needed and share the knowledge and experience of our members.
Please consider the attached document, below a sum of the contents: Within this text, Assoclima would like to provide its comments to the main options that the Impact Assessment will consider. Taking care of the previous studies in the context of the Regulations’ revision process and the previous comments already sent by Assoclima, below are summarized some comments about options 3, 4, 6.
Please consider the attached document, below a sum of the contents: Within this text, Assoclima would like to provide its comments to the main options that the Impact Assessment will consider. Taking care of the previous studies in the context of the Regulations’ revision process and the previous comments already sent by Assoclima, below are summarized some comments about options 3, 4, 6.
Please consider the attached document, below a sum of the contents: Within this text, Assoclima would like to provide its comments to the main options that the Impact Assessment will consider. Taking care of the previous studies in the context of the Regulations’ revision process and the previous comments already sent by Assoclima, below are summarized some comments about options 3, 4, 6.
I'm Full Professor of Building Physics and Thermodynamics at the IUAV University of Venezia (Italy) since 2005. My research fields are in building physics, thermal and fluid-dynamics thermal and energetic behavior of buildings and HVAC systems .
According to the “Renovation wave for Europe” document, renovation targets have to be achieved aiming for aesthetics and architectural quality too. Renovation must respect design, craftsmanship, heritage and public space conservation principles.
I support the European Commission’s invitation to express my opinion on the initiative to review the Ecodesign and Energy Labelling Regulations for air conditioners. In my daily technical assistance activity carried out mainly in the Pavia area, there are large areas of historic centre where it is not possible to install air conditioners with external units due to architectural constraints, municipal regulations and…
Filed in Italian · English published by the European Commission
Single-block air-to-air air conditioners without external units are in some cases the only solution if classic split systems with external condensed motorcycles cannot be installed. In the construction context in which my company operates, there are a number of applications where this type of solution is the only possible alternative to ensure efficient comfort and respect for various municipal or regional…
Filed in Italian · English published by the European Commission
Buongiorno, as a commercial agent in the thermohydraulic sector, became aware of the draft revision of European legislation on the design and energy labelling of air-air air conditioners and heat pumps. I take part in this invitation to express my views. I agree with the principles expressed regarding the development of increasingly efficient and circular economy products.
Filed in Italian · English published by the European Commission
A label which does not take account of technical differences, which objectively distinguish single-block and splitted air-conditioners, would unfairly place air conditioners without external units at a disadvantage.
Filed in Italian · English published by the European Commission
Single-block air-to-air air conditioners without external units are in some cases the only solution if classic split systems with external condensed motorcycles cannot be installed. In the thermohydraulic construction context in which my company operates, there are a number of applications where this type of solution is the only possible alternative to ensure efficient comfort and respect for various municipal or…
Filed in Italian · English published by the European Commission
We, the Midea Group, are of the opinion that energy-efficiency-related devices make a significant contribution to reducing CO2 emissions and achieving a high level of environmental and consumer protection. In order to noticeably increase energy efficiency in the building sector, sustainability and the rapid implementation of improvement measures/resolutions play an important role in achieving the goal of the Climate…
Single-block air-to-air air conditioners without external units are in some cases the only solution if classic split systems with external condensed motorcycles cannot be installed. In the construction context of SIENA in which my company operates, there are a number of applications where this type of solution appears to be the only possible alternative to ensure efficient comfort and respect for various municipal…
Filed in Italian · English published by the European Commission
I support the European Commission’s invitation to express my opinion on the initiative to review the Ecodesign and Energy Labelling Regulations for air conditioners. In my daily technical assistance activity carried out mainly in the area of Verona and Province, there are large areas of historic centre where it is not possible to install air conditioners with external units due to architectural constraints…
Filed in Italian · English published by the European Commission
I'm an HVAC engineer, Full professor on Environmental Technical Physics at the University of Rome Tor Vergata. I believe that the revisions of the regulation on Ecodesign and on the energy labeling system risk penalizing products that are highly deserving of promotion.
Without prejudice, I would like to stress the importance of keeping separate energy labels for air-air monobloc air conditioners. these air conditioners, which for technical reasons are less efficient than others, must nevertheless be maintained because they are necessary for the well-being of people at home and in workplaces where it is not possible for technical/structural/architectural reasons/visa-environmental…
Filed in Italian · English published by the European Commission
Single-block air-to-air air conditioners without external units are in some cases the only solution if classic split systems with external motor condensers cannot be installed. In the context of the thermohydraulic system in which my company operates, there are a number of applications where this type of solution appears to be the only possible alternative to ensure efficient comfort and respect for various…
Filed in Italian · English published by the European Commission
ANCE Brescia, a member of ANCE — Associazione Nazionale Costruttori Edili — and through it in Confindustria, aims to protect the professional interests of construction manufacturers, construction and related contractors, public and private. The representation of the College therefore covers all activities which contribute to the construction of the production process of the construction industry.
Filed in Italian · English published by the European Commission
There are as many as 1.000.000 multi-apartment buildings in Italy; it is very difficult for them to install splitted systems, while monobloc units can be more easily installed, which have also improved in terms of energy efficiency over the years. External units often devastate the facades of multi-apartment buildings and destructive architectural heritage, which in Italy have an invaluable value.
Filed in Italian · English published by the European Commission
I became aware of this invitation to comment on the design eco-friendly and energy labelling of air conditioners and I want to contribute with my personal experience. In the city where you live, Brescia, there are several historic centres and valuable buildings that would be aesthetic compromises if external units are installed on their façades.
Filed in Italian · English published by the European Commission
Buongiorno, our comment as a Cat is that they are essential products in order to meet the needs of those who do not have the possibility of setting up the external unit, we refer to those who live or have activities in historic centres, but also to those who, owing to building problems, do not have the possibility of assembling, and must forcefully abandon the air conditioner.
Filed in Italian · English published by the European Commission
Single-block air-to-air air conditioners without external units are in some cases the only solution if classic split systems with external motor condensers cannot be installed. In the construction context in which my company operates, there are a number of applications where this type of solution appears to be the only possible alternative to ensure efficient comfort and respect for various municipal or regional…
Filed in Italian · English published by the European Commission
The European Commission is planning to merge the energy labels for local space heaters (products from Lot 20) and air-air heat pumps (products from Lot 10). Conversely, energy balance considers that these two lots must retain differentiated labels in order to guide industry and consumers towards the most relevant solutions depending on the architectural constraints of the dwellings.
Filed in French · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.
