EU consultation
116 submissions from 112 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 617 submissions on this file. Shown here: the 116 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
83 submissions from industry — companies and their trade associations — against 28 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 3.0 industry submissions for every one from civil society.
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
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 14 Dec 2023 — it ran from 21 Sept 2023.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Reg draft, Reg.
One block of text on this file was submitted, identically, by three or more organizations. Shared text is a fact about the filings; what it means is for the reader.
3 organizations: GONCER CALEFACCION SL, Schiedel Metaloterm bv, Schiedel Skorsteiner AS
“Tightening of eco-design requirements for local biomass heaters is unwarranted, as it would cause more harm than good in terms of sustainable development. The rationale for this change is attributed to the adverse impact of these devices on the environment and health. The current Eco-design Directive (2009/125/EC) in Article 15, paragraph 5b, states that 5.”
Showing 25 of 116 submissions.
Subject: The indispensable nature of wood heating in the energy mix and in particular the masonry stove. AFPMA wants to promote masonry stoves more widely as a tool to combat climate change and air pollution. OUR APPROACH: To achieve these carbon neutrality objectives by 2050, this requires: 1- an energy mix through an increase in the wood-fired fuel fleet by installing new equipment as an alternative or as a…
Filed in French · English published by the European Commission
AEFECC (Asociación Española de Fabricantes de Estufas Chimeneas y Cocinas de Combustible Sólido) is the Spanish Association of Solid Fuel Fireplace Manufacturers. Our members are Spanish biomass stove and insert manufacturers, but also national representatives of main European brands and suppliers of equipment, flue pipes and accessories required for construction and installation of biomass fireplaces.
· · filed 14 Dec 2023 · source
Referring to the types of devices covered by the regulation, we would like to point out that it is justified to formally enable confirmation of compliance with Ecodesign requirements by a standardized method other than laboratory tests, i.e.
As a representative and scientific advisor of the professional organization of stove fitters, the Małopolska Association of Stove-Fitters and Related Professions I would like to present our opinions on the impact and effects of Ecodesign requirements in our professional activities and its impact on the development of individual heating technologies based on the professional experience of our members .
· · filed 14 Dec 2023 · source
With regard to the types of equipment covered by the Regulation, we would like to point out that it is justified to formally allow the demonstration of compliance with ecodesign requirements by a different standardised method than laboratory testing, i.e.
Filed in Polish · English published by the European Commission
As a representative and scientific adviser to the professional organisation of the Małopolskie Association of Poisons and Familiar Professions (MCZiZP), I would like to present our views on the impact and impact of the introduction of ecodesign requirements in our professional activities and its impact on the development of individual heating technology based on the professional experience of our members.
Filed in Polish · English published by the European Commission
· · filed 14 Dec 2023 · source
The FIPC (French national federation of stove and fireplace installers) would like to submit the following inputs on behalf of its 300 members: Seasonal energy efficiency (ɳs) needs a new calculation method. In that, the FIPC supports the working document supplied by the Technical Committee 295 of the European Committee for Standardization (CEN) that take into account partial load output, and the renewable aspect of…
· · filed 14 Dec 2023 · source
As Ustroński Alarm Smogowy, we want to express our support for the revision of the requirements for solid fuel local space heaters (EC 2015/1185) The air quality in Poland, especially for PM2.5 and B(a)P, is still poor. This poses a threat to the health and life of residents, as evidenced by the data published in the European Environment Agency’s Air Quality in Europe 2022 report.
Filed in Polish · English published by the European Commission
· · filed 14 Dec 2023 · source
As the SmogLab Foundation, we want to express our support for the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185) The air quality in Poland, especially for PM2.5 and B(a)P, is still poor in particular during the winter season.
Filed in Polish · English published by the European Commission
· · filed 14 Dec 2023 · source
The Cool Heating Coalition welcomes the Commissions initiative to review ecodesign requirements for solid-fuel local space heaters. We generally agree with the description of the issues with the current ecodesign requirements.
Dear representatives of the European Commission. Our professional organisation brings together and represents organisations and business community that has been active in solid fuel local space heaters for many years. This is one of the main reasons why we have registered with you and we want to be credible partners in these assessments or referrals.
Filed in Slovak · English published by the European Commission
As INICJATYWA SMOG WAWERSKI, we want to express our support for the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185) The air quality in Poland, especially for PM2.5 and B(a)P, is still bad in the winter season.
Filed in Polish · English published by the European Commission
Eco-design stoves, although cleaner in some respects, are equally very harmful to human health, the environment and the climate. They produce a lot of CO2, particulate matter, ultrafine particulate matter (UFP) and polycyclic aromatic hydrocarbons (PAH) with the marker substance benzo (a) pyrene (BaP). In the annex, we give the arguments in a row, supported by sources with a link.
Filed in Dutch · English published by the European Commission
As Zabierzowski Alarm Smogowy, we want to support the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185). Air quality in Poland, especially for PM2.5 and B(a)P, is still poor in particular during the winter season.
Filed in Polish · English published by the European Commission
· · filed 14 Dec 2023 · source
There is no one-size-fits-all solution. We do not defend wood heating as a one-size-fits-all solution. We defend this method of heating as the most suitable for rural areas that are underserved by the networks and have a low population density, making it possible to use slightly emitting heating.
Filed in French · English published by the European Commission
· · filed 14 Dec 2023 · source
Tightening of eco-design requirements for local biomass heaters is unwarranted, as it would cause more harm than good in terms of sustainable development. The rationale for this change is attributed to the adverse impact of these devices on the environment and health. The current Eco-design Directive (2009/125/EC) in Article 15, paragraph 5b, states that 5.
As the Workshop for All Beings (Workshop for All Beings), we want to express our support for the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185). A very significant problem in Poland is the air pollution of benzo(a)pyrene by annual air quality assessment indicated that in as many as 32 zones (out of 46 assessed) covering a total of around 90 % of the country’s surface area, the…
Filed in Polish · English published by the European Commission
Ecodesign for solid fuel space heaters contribution to call for evidence The European Respiratory Society (ERS) and the European Public Health Alliance (EPHA) welcome the revision of the ecodesign requirements for solid fuel space heaters and the opportunity to provide feedback to the decision-making process.
· · filed 14 Dec 2023 · source
Housing Europe position on review of ecodesign requirements for Solid fuel local space heaters The Social, Cooperative and Public Housing providers are at the forefront of the decarbonisation of the European building stock.
The European Public Health Alliance (EPHA) and the European Respiratory Society (ERS) welcome the revision of the ecodesign requirements for solid fuel space heaters and the opportunity to provide feedback to the decision-making process. The key messages we would like to emphasise are as follows: 1. The health community should be consulted on relevant product policies 2.
· · filed 14 Dec 2023 · source
Comments on the Ecodesign Regulation 1) strict limits are better than prohibitions 2) strict limit values promote the further development of technologies in the country where they apply and in neighbouring countries 3) strengthen strict limits in internal suppliers (see emission standards for cars that prevent “low-cost imports” into the EU), 4) wood firing stabilise electricity grids – see very rapid increases in…
Filed in German · English published by the European Commission
As Kraków Alarm Smog, we want to express our support for the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185)Air quality in Poland, especially for PM2.5 and B(a)P, is still bad in the winter season.
Filed in Polish · English published by the European Commission
· · filed 14 Dec 2023 · source
We appreciate the opportunity to contribute to "Have your say." As a major Norwegian fireplace and stove manufacturer, we believe the report relies on outdated data and clichéd views regarding wood burning. Wood burning is a crucial, CO2-neutral biofuel. Modern wood stoves with minimal emissions provide safe, responsible heating. It offers reliability during power outages with a low climate footprint.
On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid-fuel local space heaters/SFLSH (EU 2015/1185). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.
· · filed 14 Dec 2023 · source
Contura is part of NIBE AB in Markaryd, Sweden, which develops, produces, and sells stoves and chimney systems. Contura is also part of the NIBE Stoves business area, which has sales of EUR 350 million. NIBE AB is a modern and successful industry with a turnover of EUR 2,600 million and almost 1,400 employees in Sweden.
As the Polish Ecological Club Mazowiecki, we support the revision of the ecodesign requirements for solid fuel local space heaters (EC 2015/1185), the air quality in Poland, especially in winter, is still bad. This poses a threat to the health and life of residents, as confirmed by data from the EEA Air Quality in Europe 2022 report, according to which 36.5 thousand premature deaths per year are caused by exposure…
Filed in Polish · English published by the European Commission
· · filed 14 Dec 2023 · source
Wood energy and wood heat, as forms of energy that are climate-friendly, economical and consumer-friendly, are an indispensable part of the energy transition in order to achieve the 65 % renewable heating target. Wood is essential as an energy source. Due in particular to its climate friendliness and eagerness, it already replaces traditional fossil fuel toys such as gas and oil in many places.
Filed in German · English published by the European Commission
Residential burning with solid fuels is the predominant source of health and climate damaging pollutants. The sector is responsible for 58% of fine particles (PM2.5), 37% of black carbon (BC) and 85% of benzo(a)pyrene (BaP) emitted in the EU [1]. This is despite only a small proportion of households heating with wood.
SER (French renewable energy trade association) would like to submit the following inputs : Seasonal energy efficiency (ɳs) needs a new calculation method. In that, SER support the working document supplied by the Technical Committee 295 of the European Committee for Standardization (CEN) that take into account partial load output, and the renewable aspect of the wood.
The seasonal efficiency does not apply to SFLSH and should therefore be replaced by nominal efficiency. The current correction factors are partly unrealistic and should be adjusted. Seasonal efficiency is not appropriate for LSH, which is intended for heating purposes only and does not use excess liquids (chemicals, refrigerants) to “enhancing” the heating capacity of the appliance.
Filed in Finnish · English published by the European Commission
As specialists in exhaust gas plant construction, we can provide the following experience: Basic principle: The more chemically oxidation is burning biogenic fuels such as wood, the higher the energy yield ABER is lower and the lower the release of emissions.
Filed in German · English published by the European Commission
· · filed 14 Dec 2023 · source
Heating with wood is known to be neutral and resilient to crises. Another important advantage is that the fuel has very short and risk-free transport routes. The installation and calculation of modern burning rooms and heating applications will reduce emissions to a minimum. It is important to explain the operator’s rigour in this regard.
Filed in German · English published by the European Commission
As Gierałtowicki Alarm Smogowy, we want to express our support for the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185) The air quality in Poland, especially for PM2.5 and B(a)P, is still bad in the winter season.
Filed in Polish · English published by the European Commission
As the Association, we express our support for the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185) The air quality in Poland, in particular PM2.5 and B(a)P, is still poor. This is a threat to health and life, as confirmed by data from the EEA Air Quality in Europe 2022 report, according to which 36.5 thousand premature deaths per year are caused by exposure to PM2.5 in Poland.
Filed in Polish · English published by the European Commission
· · filed 13 Dec 2023 · source
I am of the opinion that it does not require stricter directives or, in any event, a ban on wooden stoves. Especially in the current era, a wooden oven is essential and for many the only way to heat their homes, especially in the event of a power failure. Wooden stoves are simply crisis-proof!
Filed in German · English published by the European Commission
Dear, I find this issue very exaggerated. 1. The Earth is in a very normal cycle, which we cannot change in the first place, and we are struggling with the earth’s overpopulation. 2. Heating with wood is not as problematic as described above; this problem would also need to be tackled by providing the right heat to the population.
Filed in German · English published by the European Commission
Ravelli is one of the most important manufacturers of stoves, fireplaces, boilers and cookers powered by renewable sources such as pellets and wood. Thanks to investments in Research & Innovation and attention to Design, Ravelli exports Italian style excellence to over 40 countries with a strong presence in Europe.
Italian manufacturers strongly believe in the effectiveness of the Ecodesign Regulation 2015/1185., A revision may be beneficial, but the approach should not change, and Ecodesign should focus on identifying and defining more ambitious yet achievable limits to improve efficiency and emissions of the solid fuel Local Space Heaters (LSHs) stock.
· · filed 13 Dec 2023 · source
As the EKO Lubusz Foundation for Environmental Development and Environmental Protection, we want to express our support for the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185) The air quality in Poland, especially for PM2.5 and B(a)P, is still bad in the winter season.
Filed in Polish · English published by the European Commission
As the Podhale na Zielona Foundation, we want to support the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185) The air quality in Poland, especially for PM2.5 and B(a)P, is still bad in the winter season.
Filed in Polish · English published by the European Commission
Edilkamin&Co. is a European leader in the domestic biomass heating sector. Fondo in 1963, it boasts 60 years of experience in the production of wood and pellet stoves, boilers, fireplaces, and inserts. With a consolidated network of retailers and service centres distributed throughout the national territory, it successfully exports cutting-edge technologies, designs, and solutions, in line with the changing needs of…
· · filed 13 Dec 2023 · source
As a chimney sweep, I deal with individual fireplaces such as cookers and solid fuel stoves on a daily basis. Particularly in times such as the current crisis in recent years, I have noticed that wood-fired fireplaces have grown enormously, and people who are heated with oil and gas increasingly rely on individual fireplaces.
Filed in German · English published by the European Commission
As Polish Alarm Smogowy, we want to support the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185). Air quality in Poland, especially for PM2.5 and B(a)P, is still poor in particular during the winter season.
Filed in Polish · English published by the European Commission
As a European Clean Air Centre, we want to support the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185). A very significant problem in Poland is the air pollution of benzo(a)pyrene by the annual air quality assessment indicated that in as many as 32 zones (out of 46 assessed), covering a total of around 90 % of the country’s surface area, the target for this substance set by…
Filed in Polish · English published by the European Commission
As Lubuska Alarm Smogowy, we want to express our support for the revision of ecodesign requirements for solid fuel local space heaters (EC 2015/1185) The air quality in Poland, especially for PM2.5 and B(a)P, is still bad in the winter season.
Filed in Polish · English published by the European Commission
· · filed 13 Dec 2023 · source
We are Norsk Kleber, a producer of soapstone stoves with the possibility to burn wood or pellets (with a patented ultra-clean burn from BluComb). The data used in your assessment are not up to date, with severe mistakes. Modern woodstoves emit very little, and will emit even less in the future. Old woodstoves are the culprit.
· · filed 13 Dec 2023 · source
Tightening of eco-design requirements for local biomass heaters is unwarranted, as it would cause more harm than good in terms of sustainable development. The rationale for this change is attributed to the adverse impact of these devices on the environment and health. The current Eco-design Directive (2009/125/EC) in Article 15, paragraph 5b, states that 5.
On behalf of Fern, we welcome the revision of the Ecodesign Regulation for solid fuel space heaters (EC 2015/1185). The energy prices crisis which followed the Russian invasion of Ukraine has driven up both the prices of fossil fuels and wood solid fuels.
· · filed 13 Dec 2023 · source
As one of the French SME representative SFLSH manufacturers, I would like to share the following contribution : Seasonal energy efficiency as defined does not fit to SFLSH products but only to central heater. It needs a new calculation method, at least taking into account a well fitted formula with a lower abatment and specific downsized correction factors (heating directly in the house and with the user aside for…
On behalf of ECOS/EEB/Coolproducts, we welcome the revision of the Ecodesign Regulation for solid fuel local space heaters (EC 2015/1185) The energy crisis which followed the Russian invasion of Ukraine has driven up both the sales of solid fuels and those of solid fuel appliances, as more and more households turned to local space heating when the price of gas went up.
Bulgaria is one of the countries in EU, where air quality is unhealthy and domestic heating with wood and to lesser extend coal are a dominant source. Despite the programmes for heating appliances exchange targeting the oldest and dirtiest stoves (space heaters) the progress is slow.
La Nordica Spa is a company that has been working in the biomass sector - particularly with wood logs - for over 50 years. Our products have always been designed and placed on the market in compliance with current European and national technical standards and regulations.
Extraflame Spa is a company that has been working in the biomass sector - particularly with pellets - for over 20 years. Our products have always been designed and placed on the market in compliance with current European and national technical standards and regulations.
CEFACD supports the pursuit of sustainable low-carbon heating and improved environmental product performance. Its members work continually to produce efficient and durable products. As such, we would like to emphasise the important role of local space heaters (LSH) in fostering the energy transition and reducing energy poverty.
· · filed 13 Dec 2023 · source
I am urgently in favour of maintaining the possibility of heating with solid fuels in an emergency. The reasons for me are the following: Black or brownout Preparedness Preparedness for the phase-out of tested fireplaces operate very efficiently and with low emissions.
Filed in German · English published by the European Commission
· · filed 13 Dec 2023 · source
Hello, I represent builders of individual heaters, manufacturers and sellers of industrial heaters, materials and components for such installations, professional educational institutions or firms involved in metering and research. This is a segment related to the construction, production and operation of local combustion sources for woody biomass.
Filed in Czech · English published by the European Commission
Ladies and gentlemen, I have been in contact with operators of small combustion plants, individual stoves, on a daily basis in my work as a chimney sweep responsible for the object. I am glad to share the views of my customers with the operators and me through this way!
Filed in German · English published by the European Commission
We would like to thank us for the possibility of presenting our perspective on the clean burning of wood. The producers of dust separators organised in the CEA are in principle in favour of clean stack and caching stoves in order to protect health and the environment. Wood-based heat has advantages that otherwise do not satisfy any energy source.
Filed in German · English published by the European Commission
· · filed 12 Dec 2023 · source
The efficiency assessment should take into account the reduction of heating costs for households using wood eco-design appliances and the economic benefits for local communities of harvesting, processing and use of wood for heating purposes in the framework of the circular economy (GOZ). Wood management is an example of an ideal GOZ (useful wood, renewable energy from ash residues as fertiliser).
Filed in Polish · English published by the European Commission
Italian manufacturers strongly believe in the effectiveness of the Ecodesign Regulation 2015/1185., A revision may be beneficial, but the approach should not change, and Ecodesign should focus on identifying and defining more ambitious yet achievable limits to improve efficiency and emissions of the solid fuel Local Space Heaters (LSHs) stock.
As historical manufacturer of wood and pellet burning local space heaters, in the last 20 years we experienced and cooperated to a true Copernican revolution of our sector, starting from a factual absence of rules, than going throw the first standardisation steps, mandatory third party certifications, the continuous EU product standards improvements till the recently harmonized EN 16510, and in parallel the…
As Nowotarski Alarm Smogowy, we want to support the revision of the ecodesign requirements for solid fuel local space heaters (EC 2015/1185) mainly recommend: 1. Introduction of an obligation to equip heaters with automated air supply controllers (similar to the requirements of the German Blue Angel certificate). 2. Introduction of mandatory emission limits for benzo(a)pyrene. 3.
Filed in Polish · English published by the European Commission
· · filed 12 Dec 2023 · source
Throughout, we feel that old data and clichéd attitudes towards wood burning are used in the report. Wood burning is an important source of biofuel and is CO2-neutral. By using modern wood stoves with minimal emissions, you contribute to being able to ensure safe and responsible heating for homes.
· · filed 12 Dec 2023 · source
The free #ofenzukunft initiative supports the goals of a successful energy transition and aims to contribute to making the most of the heat transition together. Wood firing, which already accounts for 6 % of Germany’s heat demand today, will play an important role in the future. We see wood firing as an important building block for solving a much bigger problem.
Filed in German · English published by the European Commission
Bioenergy Europe would like to submit the following inputs concerning the revision of Ecodesign requirements for Solid-fuel Local Space Heaters (LSHs) First of all, a new calculation for seasonal efficiency is needed. When measuring efficiency, renewability must be taken into consideration to ensure a fair evaluation and comparability for all appliances in the market.
· · filed 12 Dec 2023 · source
Tightening of eco-design requirements for local biomass heaters is unwarranted, as it would cause more harm than good in terms of sustainable development. The rationale for this change is attributed to the adverse impact of these devices on the environment and health. The current Eco-design Directive (2009/125/EC) in Article 15, paragraph 5b, states that 5.
Fossil solid fuels (coal) should be separated from renewable solid biomass fuels (lignite wood, chipped material, pellets) in the Ecodesign Directive. Coal is highly harmful to the climate, wood is a renewable energy source and burns climate neutral if it comes from sustainable forest management, as is the case in Europe.
Filed in German · English published by the European Commission
According to current figures, there are around 12 million individual fireplaces in Germany using solid fuel wood. A large proportion of these are hand-operated individual fireplaces, the classic wooden furnace. More than one in four households in Germany wins heat in this way.
Filed in German · English published by the European Commission
We start from the conclusions of the 2021 JRC report, which has clearly shown that the use of biomass for heating is a lose-lose choice, contributing to both the climate and biodiversity crises, two major concerns addressed by the European Green Deal.
· · filed 11 Dec 2023 · source
Strengthening ecodesign requirements for local biomass heating is not justified, as it would harm sustainable development more than would be beneficial. The reason for this change is attributed to the negative environmental and health impacts of these devices. The current Ecodesign Directive (2009/125/EC) states in its Article 15(5b): 5.
Filed in German · English published by the European Commission
· · filed 11 Dec 2023 · source
Its own fireplace is gold worth wood fire, which is a centuries-old sausage of human beings. A fire brings heat, joy, light and atmosphere to each house. The use of local resthout, the selection of the right stone stove and the correct firing process will provide a pleasant indoor climate and the environmental burden is minimal. For many people, a sense of independence also plays a major role.
Filed in Dutch · English published by the European Commission
· · filed 11 Dec 2023 · source
However, the burning of biomass has historically been the first heating system for humans. Technological developments have made it possible today to produce very efficient and low emission impact generators on an industrial scale.
Filed in Italian · English published by the European Commission
· · filed 11 Dec 2023 · source
FEBHEL, the Belgian Federation of Wood Energy, would like to make the following contributions. Wood energy, as a by-product from the wood recovery industry, is a means of local and renewable heating. In the calculation of energy efficiency, renewability must be taken into account to ensure a fair assessment and comparability of all appliances on the market.
Filed in French · English published by the European Commission
· · filed 11 Dec 2023 · source
SOLID fuel local space heaters play a significant role in the heating of buildings all over europe. This role has to be seen very different in the specific countries and in specific social areas in these countries.
Filed in German · English published by the European Commission
· · filed 9 Dec 2023 · source
The current technical possibilities to increase the efficiency and cleanliness of the stoves and stoves are not currently required by default and are necessary. An effective method to reduce operational errors and improve burning is automatic control.
Filed in German · English published by the European Commission
The German HKI industry association represents the interests of more than 110 manufacturers of domestic heating and cooking appliances. As such, it strongly supports the goals of sustainable and, as far as possible, CO2-neutral heat generation and improved air quality. The development and manufacture of efficient and clean products is a constant concern for our members.
Dear Sir/Madam, Le bois-énergie, as a by-product from the wood-recovery industry, is a local, renewable and accessible means of heating for citizens of the European Union (RED III). It supports sustainable forest management, both ecologically and economically.
Filed in French · English published by the European Commission
· · filed 8 Dec 2023 · source
Bearing in mind that particulate matter pollution has fallen steadily over the last 50 years and life expectancy has increased significantly over the same period, I do not understand exactly why this is the health problem. I would like to look closely at what arguments arise and come from. The fact is that the current single-space fireplaces burn at very high quality levels.
Filed in German · English published by the European Commission
· · filed 7 Dec 2023 · source
I think all this will be very exaggerated with the new planned tightening of the Solid Fuel Regulation to complicate our work (I am oven grower with our own business). It seems that the EU is no longer seeking to have successful business. For me, such decisions are almost dictatorial, because we simply have to accept them and cannot do anything against them.
Filed in German · English published by the European Commission
· · filed 7 Dec 2023 · source
The European Commission, I call Paolo Caruso, who has been working for 19 years in a historic Italian company (LINCAR) for a few years and has been renamed to Corisit s.r.l., a producer of domestic appliances powered by biomass, including pellets and wood. I now head the Municipal Directorate, but for many years I have followed the technical area, from after-sales to the laboratory.
Filed in Italian · English published by the European Commission
· · filed 7 Dec 2023 · source
I am an installer and I see that biomass heating is chosen in 80 % of cases for economic reasons as gas or diesel heating is much less demanding but more expensive. I therefore believe that an increase in the cost of stoves would make it possible for end users to make cheaper installations and smoke cans and therefore not more polluting, or to use gas or diesel for heating purposes.
Filed in Italian · English published by the European Commission
· · filed 7 Dec 2023 · source
Solid fuel local space heaters have contributed to reducing energy costs in the 2022 crisis and reduced the need for energy imports. However, these furnaces are not suitable for reducing greenhouse gas emissions. As indigenous energy wood is persistently insufficient, it is very likely that healthy trees will be imported from poorly controlled supplier countries.
Filed in German · English published by the European Commission
· · filed 7 Dec 2023 · source
We thank you for the opportunity to give our input in "Have your say". We are Harstad Varme Flis og Steinsenter AS. Throughout, we feel that old data and clichéd attitudes towards wood burning are used in the report. Wood burning is an important source of biofuel and is CO2-neutral. By using modern wood stoves with minimal emissions, you contribute to being able to ensure safe and responsible heating for homes.
We thank you for the opportunity to give our input in "Have your say". Jøtulgroup is a Norwegian company that sells products to approx. 43 countries World Wide, but EU is where we have most of our sales.Our turnover is approx. 1,4 Billion . Since we are a Norwegian company our stoves has been developed based on Norwegian laws.
· · filed 7 Dec 2023 · source
As a kiln building plant, we have been replacing old, inefficient and clean fireplaces for years for modern and much cleaner fireplaces such as stoves, heating stoves, storage furnaces. These are optimised by burning and generate very low emissions.
Filed in German · English published by the European Commission
· · filed 7 Dec 2023 · source
About Energy labelling I just want to inform you about the the merger of LSH with air to air heat pumps, air conditioners and comfort fans will increase energy poverty, will prevent the European consumer in choosing the best heating option and will seriously hurt the large amount of European SMEs in this sector LSH are incomparable with heat pumps since they serve distinct functions, use different fuels and have a…
· · filed 6 Dec 2023 · source
We are Annecy Chemés, an installer for more than 20 years of wood chimneys, gas, stoves, granulated and wood. We also have a second company (AltiFlammes) dedicated to sweeping, maintaining it and bringing old installations into conformity.
Filed in French · English published by the European Commission
· · filed 6 Dec 2023 · source
The proposal for new ecodesign requirements, which aims to reduce the use of wood and woody biomass, according to the Association, is not only unwarranted, but is not justified by the forest management process and the prevailing environmental awareness, which is reflected, inter alia, in an increase in woodland.
Filed in Polish · English published by the European Commission
· · filed 5 Dec 2023 · source
Good for everyone, I believe that biomass is a source of renewable fossil fuel heating that would enable many countries, and people, to benefit from a system that is economic and if it is done correctly also to help the environment.
Filed in Italian · English published by the European Commission
· · filed 5 Dec 2023 · source
Kitching stoves, heating stoves are burnt to the state of the art in any case very low in emissions and customers love your furnaces. this would be very counterproductive if the EU were to set itself too ambitious targets in the private sector: As new fireplaces become much more expensive, the normal replacement would slow down! Residential fireplaces also serve to ensure security of supply!
Filed in German · English published by the European Commission
Wood burners such as wood stoves have an excellent yield. With some education, it is a more super circular and reusable energy source. The market as a whole works together to provide advice. Manufacturers are working on increasingly cleaner appliances. In the ‘Problem the initiation of claims to tackle’ purposes, the turn is quite brief.
Filed in Dutch · English published by the European Commission
· · filed 3 Dec 2023 · source
Currently, the latest wood stoves already comply with state-of-the-art techniques that significantly reduce emissions. We believe that further tightening the current requirements will bring only marginal improvements. A more effective approach to the problem should focus on replacing older wood stoves, in particular those prior to the EcoDesign Act of 2022.
Filed in Dutch · English published by the European Commission
· · filed 3 Dec 2023 · source
Burning woody biomass using a good stove and installation is certainly a good and responsible way to use the energy transition in the Netherlands. On the contrary, informing users of combustion behaviour and fuel consumption is a necessity to minimise nuisance for residents to a bsolute. Wood burning fits into a sustainable future!
Filed in Dutch · English published by the European Commission
· · filed 2 Dec 2023 · source
Burning with wood can be a great way of heating (co-) dwellings. With the latest techniques, the right way of firing and dry wood, their emissions are minimal. Before new rules are introduced, it seems to me prudent that the existing rules are properly enforced and complied with.
Filed in Dutch · English published by the European Commission
· · filed 2 Dec 2023 · source
Wood-fired heating in its place in the current energy mix. New high-performance appliances and constant changes in appliances by manufacturers to emit less and less particulate matter, CO released into the atmosphere, guarantee clean and low-polluting combustion.
Filed in French · English published by the European Commission
· · filed 29 Nov 2023 · source
Newly developed and properly constructed fireplaces such as stoves, heating stoves, storage stoves, etc. are optimised for combustion and produce very low emissions. It would be important for the environment to replace old appliances which do not meet the required requirements and to take all measures to promote the correct operation/lighting of the heaters.
Filed in German · English published by the European Commission
· · filed 27 Nov 2023 · source
— The appliances (mass stoves) we build have very clean fighting: low emissions, low fine particulate matter, high efficiency. Before the appliances are called into question, it is important to give the right instructions for use, which are of good quality. —Reinstalling old stoves with new appliances will help to remove polluting machinery.
Filed in French · English published by the European Commission
· · filed 27 Nov 2023 · source
Modern residential fireplaces (fire stoves, heating stoves, flocks) are now largely burnt-optimised and produce very low emissions, e.g. of particulate matter. It is important for the environment to take all measures to ensure the correct operation and to replace as soon as possible old, non-low-emission residential fireplaces with new low-emission fireplaces.
Filed in German · English published by the European Commission
· · filed 20 Nov 2023 · source
According to the Federal Environment Agency, an average single-family house requires 25 000 kWh of energy for heating and hot water. A house emits 13.25 tonnes of CO2 directly heated with German electricity. The use of an air heat pump with refined electricity still leaves 4.41 tonnes of CO2.
Filed in German · English published by the European Commission
Heating with wood! Traditionally, wood fires have been boiled and heated. The number of people on the planet was certainly far fewer, and these fires were accordingly polluting. In today’s time wood stoves and wood boilers can be burned dry and split wood without major pollution. The use of catalytic converters and fine particulate filters can improve the values.
Filed in German · English published by the European Commission
· · filed 16 Nov 2023 · source
Local solid fuel use is really important from the point of view of security of supply, especially in the current mile situation. Each building should be equipped with a solid fuel heating reserve that is not dependent on the supply of electricity.Each urban agglomeration should have a solid fuel heating centre.There are many of them self-sufficient in the urban settlement area.When compared to coal, wood is much…
Filed in Finnish · English published by the European Commission
Wood is a renewable raw material at our door. It is a valuable source of energy where the short supply chain is ubiquitous. A solid or granular heating system therefore makes an important contribution to the energy transition – far from fossil fuels. Without forest management, it is not possible to extract wood for construction purposes. As a result, all firewood comes from sustainably managed and reasoned cuts.
Filed in French · English published by the European Commission
· · filed 13 Nov 2023 · source
Dear Sir/Madam, Wood is a renewable fuel with short transport distances, which is in most cases regionally available, and is very energy efficient in procurement and production due to the resulting short transport distances. In many cases, fuel wood in forestry comes from waste or by-products, such as: Sections, wind and storm damage to be repaired.
Filed in German · English published by the European Commission
Natural biomass combustion devices may have a positive impact on the use of natural sources of energy (wood). The biomass which can be used as source of energy come from natural ressources which can be regenerated without footprint ("cultivated" forests, wood coming from cleaning forests) .
· · filed 13 Nov 2023 · source
Wood is a renewable raw material immediately on our doorstep. A valuable energy source that does not need to be procured over long distances. A single space fireplace is therefore a valuable contribution to the energy transition away from fossil fuels. Without forest management, no timber can be taken out of the forest for construction purposes. As a result, wood suitable for incineration is automatically produced.
Filed in German · English published by the European Commission
Dear ladies and gentlemen, we, in Munich, have the strictest regulations in Germany. The wood fireplaces we install as oven set up correspond to the most recent tests. If properly burnt in the tested fireplaces, the wood is relatively CO² neutral. In this case, CO² has been sequestered for years. The wood comes from the region in Bavaria and the transport routes are therefore also negligible.
Filed in German · English published by the European Commission
· · filed 13 Nov 2023 · source
Wood is a sustainable and renewable raw material with a neutral carbon footprint. Wood heating has been modernised in the last 10 years and is now of a high technical standard. Wood-based heating offers, in addition to a certain degree of independence, an economic alternative to oil, gas and electricity sources.
Filed in German · English published by the European Commission
· · filed 13 Nov 2023 · source
Ladies and gentlemen, the energy source of wood, which is naturally growing/prepared in that country/state because of vegetation, hardly requires extraneous energy, neither for transport nor for the production of firewood (lignite wood), chips, pellets, etc. When wood is burned correctly, only that CO² is released for growth in its growth phase. Wood is a CO² reservoir! Wood is the heat supplier of the future!
Filed in German · English published by the European Commission
· · filed 13 Nov 2023 · source
“Heating with wood in modern fireplaces is a clean and environmentally friendly way of producing heat. It is worth noting that many of these fireplaces are awarded the Blue Engel from the Federal Environmental Agency. This award reflects its particularly environmentally friendly functioning. The use of wood as a fuel in modern fireplaces has many environmental benefits.
Filed in German · English published by the European Commission
· · filed 13 Nov 2023 · source
The kiln is a heater that works completely self-sufficient without electricity. It has a centuries of tradition in Austria. Once heated correctly, his massive heat reservoir rapidly increases the heat and gives it down for hours as mild radiant heat. In most cases, it is sufficient to enjoy heat every day once or twice a day.
Filed in German · English published by the European Commission
State-of-the-art wood fires are cleaner than ever before and play an important role in the energy mix. I am aware that in Germany we cannot replace all oil or gas heating systems, but as an alternative, for example, a pellet boiler, a chipping plant or a room furnace (e.g. as a supplement to the heat pump) makes real sense. I also favour Germany’s energy self-sufficiency by using solar and wind power.
Filed in German · English published by the European Commission
· · filed 12 Nov 2023 · source
New requirements have emerged several times in recent years. Tougher requirements are fundamentally good, but changes too often disrupt the industry and generate amounts of red tape, both at the level of businesses and public authorities. Moreover, I see that further changes now risk having little practical changes, at least not big enough to compensate for the disadvantages of new rules.
Filed in Swedish · English published by the European Commission
· · filed 9 Nov 2023 · source
In principle, stricter emission requirements are a good thing for fires, it would also be important to pay attention to the control and ban of stagnant untested bricks. In addition, a ban should be imposed on outpatients. In Finland alone, half a million open people are estimated to cause significant emissions of fine particulate matter.
Filed in Finnish · English published by the European Commission
· · filed 9 Nov 2023 · source
Yes, wood heating is very important in Finland. In a country such as Finland, the backup heating system is absolutely safe in case of crisis. It is good to monitor the emission values of fireplaces and to provide guidance on the burning of wood. It should be possible to better control the testing of emissions from fireplaces. Some manufacturers test their products themselves and sign the test reports.
Filed in Finnish · English published by the European Commission
This ecodesign pushes the market toward the limits of available technologies, which is good! Biomass is a valid strategy (independency, price, local character, recylability, emissions, renewability...) in the energy transition and can help to make consumers more independent from fossil sources. This Ecodesign reduces even more the inconvenience of fine dust to a minimum.
· · filed 1 Nov 2023 · source
The Commission seems to be willing to completely remove these devices from the market and, at the same time, to completely exclude the possibility of using wood as a fuel. Even if the documents consulted do not express this explicitly, the adoption of the proposed solutions, combined with changes to energy labels, will have such effects.
Filed in Polish · English published by the European Commission
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