Ecodesign requirements for space heaters and combination (review)

We are thankful for the opportunity to comment on the updated version of the ecodesign and energy labelling revision proposals for space heaters. We look forward to a prompt adoption of these long-due revisions. Please find attached our comments in response to the European Commissions Have Your Say Consultation on the Ecodesign and Energy Labelling space heating Regulations.

The proposed revision of the EU Regulation on Ecodesign and energy labelling for space heaters, combination heaters and water heaters aims to improve environmental performance and consumer transparency while reflecting technological progress.

Immergas S.p.A., an Italian company active in manufacturing water-based heating appliances, welcomes the opportunity to provide feedback on the draft Ecodesign proposal. From our perspective, we support the overall objectives of the eco-design Regulation and are pleased to give our contribute for a multi-technology and multi-energy approach.

Solar Heat Europe welcomes the revision of the Ecodesign requirements for space and combination heaters and supports the Commissions objective to improve energy performance, regulatory clarity and consumer protection. However, the current draft risks unintentionally weakening the role of solar thermal technologies within the Ecodesign framework.

EHI is the Association of the European Heating Industry and 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.

The European Building Automation and Controls Association (eu.bac) welcomes the European Commissions initiative to update the Energy Labelling and Ecodesign regulations for space heaters and combination heaters (the review of Commission Regulations 811/2013 and 813/2013).

BlueHeart welcomes the opportunity to provide feedback on the review of the ecodesign requirements of space and combination heaters. BlueHeart Energy is developing a radically different heating and cooling engine that uses thermoacoustic technology (sound waves to move heat).

Vaillant welcomes the opportunity to provide feedback on the draft Ecodesign proposal and appreciate the constructive dialogue with stakeholders as part of this consultation process. From an industry perspective, we support the overall objectives of the initiative and are pleased to contribute our experience and practical insights. Our detailed comments and suggestions are set out in the attached document.

Schneider Electric, leader in the digital transformation of energy management and automation welcomes the opportunity to comment on this future regulation. We would like to share two specific points of concern: 1) on product information on temperature control classes. 2) on energy-smart appliances supporting energy flexibility. See more details in the attached document.

The Japan Business Council in Europe (JBCE) would like to express its support for the position paper submitted by the European Partnership for Energy and the Environment (EPEE) on 23 January 2026. The paper concerns the proposed revisions to the Ecodesign implementing Regulation and the Energy Labelling delegated Regulation for space and combination heaters, as well as water heaters (ENER Lot 1 & 2).

Eurofuel, representing the European liquid heating fuels sector, welcomes the opportunity to contribute to the consultation on the revision of the Ecodesign Regulation for space and combination heaters. Eurofuel supports the EUs objectives of improving energy efficiency, reducing emissions, and accelerating decarbonisation.

Panasonic welcomes the opportunity to provide feedback on the latest legislative drafts released by the European Commission. As the European Union accelerates its transition toward decarbonised heating and cooling, it is essential that forthcoming regulations effectively support the deployment of heat pumps while safeguarding consumer benefits, ensuring high levels of energy efficiency, and enabling a competitive…

THE FULL CONSOLIDATED CONTRIBUTION TO THE 4 CONSULTATIONS AND ARTICLE-BY-ARTICLE SUGGESTIONS ARE OUTLINED IN THE DOCUMENT ENCLOSED. ABOUT GCP EUROPE: GCP Europe represents national associations of HVAC, plumbing and building-services contractors across Europe.

POSITION PAPER ON THE REVISION OF ECODESIGN AND ENERGY LABELLING REQUIREMENTS FOR SPACE, COMBINATION AND WATER HEATERS ENER Lots 1 & 2 The European Partnership for Energy and the Environment (EPEE) welcomes the final stages of the European Commissions revisions of the Ecodesign implementing Regulation 813/2013 and the Energy Labelling delegated Regulation 811/2013 for space and combination heaters (ENER Lot 1), the…

This paper sets out the European Heat Pump Associations (EHPA) feedback on the draft Ecodesign and Energy Labelling Regulations for space and combination heaters, as well as for water heaters and storage tanks (hereinafter referred to as Lots 1 and 2).

SHV Energy welcomes the update of Ecodesign requirements and supports higher efficiency, lower emissions and better consumer information. As a leading supplier of LPG and bioLPG, we support technology-neutral rules that reflect real-world heating needs, especially in rural and off-gas-grid areas.

EWO Energie.Wärme.Austria would like to thank you for the opportunity to comment on the Commission’s proposal on the requirements for space heaters. EWO, representing the interests of liquid, in particular renewable, liquid energy, supports the objectives of decarbonisation, increasing efficiency and reducing emissions in order to achieve the EU’s climate objectives.

Filed in German · English published by the European Commission

Achieving climate neutrality by 2050 will require leveraging all available solutions: in particular, LGE emphasizes the vital contribution of renewable liquid gases (rLGs) such as bioLPG (biopropane) and renewable dimethyl ether (rDME) to delivering decarbonised, affordable heating for Europes citizens, especially in rural and off-grid areas.

The revision of EU Ecodesign and Energy Labelling rules for space and water heaters aims to improve environmental performance and transparency. MARCOGAZ supports these goals but warns that combined measures may undermine technological neutrality, feasibility, and consumer choice, slowing the energy transition.

Assoclima welcomes the Commission's initiative to simplify and improve the existing Ecodesign and Energy Labelling framework and supports the proposed single-scale approach and the transition to an A-G energy efficiency classification. The attached document provides Assoclima's detailed comments on the draft regulations, structured into 17 topics with identified priority levels.

Assogasliquidi is the national association of Federchimica representing companies in the LPG and LNG liquefied gas supply chain, which are committed to making the necessary investments for the development of the entire liquefied gas supply chain, including in their bio and renewable formulations: from supply infrastructure to final distribution, as well as companies building equipment and facilities or providing…

Filed in Italian · English published by the European Commission

This submission is provided by the Dutch Hot Water Association (DHWA) in response to the European Commissions consultations on the review and rescaling of the energy efficiency labelling and ecodesign requirements for space heaters, combination heaters, water heaters and water heater tanks.

a) EdEn believes that this regulation should actively incentivise manufacturers to place high-performance equipment on the market, with a clear and unambiguous differentiation from fuel-fired boilers, which should be phased out as rapidly as possible.

Groupe Atlantic supports the European Commissions (EC) efforts to modernise the regulatory framework of Ecodesign and Energy Labelling Regulations for Lot 1, as well as for Lot 2, improve energy performance, strengthen consumers accessibility to information and better reflect technological progress and the EUs climate and energy objectives.

Sedigas unites companies, institutions, and professionals committed to the development, innovation, and sustainability of the gas industry. As a driving force behind Spains energy transition, Sedigas actively promotes natural gas, renewable gases such as biomethane and hydrogen, and other low-carbon solutions to support the European Unions climate and sustainability objectives.

Gas Distributors for Sustainability (GD4S) strongly supports the EUs objective of reducing greenhouse gas emissions from buildings and industry and recognises the important role of ecodesign requirements in improving energy efficiency.

GRDF welcomes this review of these Ecodesign requirements and shares the objectives of decarbonisation and energy saving. Gradual improvement of the minimum energy performance required for heating equipment, and demand flexibility are key points for a fast and affordable transition.

We welcome the publication of the draft Ecodesign and Energy labelling regulations for space and combination heaters. The uptake of sustainable heating and cooling solutions requires a systematic and practical approach to ensure consumers can better control their energy bills and live in healthier and more comfortable homes.

Assotermica is the Italian Association representing manufacturers of equipment and components for heating systems, a sector that has paved the way for many advances in technological innovation over the last 40 years, employs more than 12,000 people and generates a turnover of 3.5 billion.

ECOS, as part of the Coolproducts campaign and the Cool Heating Coalition, strongly welcomes the long-due publication of the European Commissions ecodesign and energy labelling proposals for space and water heaters. The decarbonisation of the energy sector goes hand in hand with reducing gas use in the European Union, especially at residential and heating level.

Please refer to the attached document for the Eurovent comments on the draft proposals for space, combination and water heaters. The Eurovent positions are summarised below for ease of reading. - Avoid contradictory measures: Do not hinder heat pump deployment with incoherent provisions - Definitions: Confirm that Pdesign and Prated are identical, and ensure consistency - TPCA is not supported - Self-monitoring…

The Dutch Heat Pump Association (Vereniging Warmtepompen) hereby submits the Dutch comments in the attached document. We appreciate the opportunity to provide feedback and would like to urge the commission to have a real thorough review of all ecodesign and labelling requirements (at this stage we would have expected to have found a lot less errors and editorial comments).

The European Biogas Association welcomes the Commissions focus on a competitive and resilient transition, which offers Europe the opportunity to reduce its dependence on fossil fuels while strengthening energy security and affordability. Appliance efficiency, together with building insulation, renewable energy, and demand flexibility, are a key part of this solution.

EurEau represents Europe's water services sector, bringing together 70,000 public and private drinking water and wastewater service providers across 33 countries. We take note of the provisions in the draft Commission Regulation on ecodesign requirements for space and combination heaters, in particular Recital 14.

The Cool Heating Coalition, the civil society voice on heating and cooling, supports the review of the regulations on ecodesign and energy labelling requirements for space and water heaters. Please find attached our submission to the public consultation.

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA), representing manufacturers of refrigeration and air conditioning equipment in Japan, welcomes the final stage of the revision by European Commission on Ecodesign Implementing Regulation (EU)813/2013 and Energy Labelling delegated Regulation (EU) 811/2013 for space heaters (ENER Lot1) and Ecodesign Implementing Regulation (EU)814/2013 and…

REHVA is the umbrella organisation representing over 120,000 HVAC design engineers, building services engineers and technicians across 24 European Countries. REHVA members are key actors in the needed energy transition and support the EU 2050 climate and energy targets. The Ecodesign and labelling regulations are highly impacting the daily work of HVAC professionals and industrials.

Welcoming the draft of Ecodesign Regulation, since it represents an important step towards improving energy efficiency in heating, Italgas underlines that its measures should be designed to minimise total energy system costs, safeguard security of supply and ensure affordability for citizens and industry.

Thank you for the opportunity to provide feedback on the draft. We would like to draw your attention to a few specific comments regarding the icon showing that the appliance is compliant with the EU Code of Conduct for the interoperability of energy-smart appliances: We do not support this icon proposed for both space and water heaters.

As the Business Area NIBE Climate Solutions within the NIBE Group, we have been manufacturing heat pumps since the 1980s. We welcome the draft revision of the Ecodesign regulation for space heaters and view it as a well balanced proposal that reflects the expectations of the various stakeholders, including Member States and industry representatives.

We would like to point out that there are important requirements for operating temperatures in potable water installations in order to prevent the proliferation of pathogens, especially Legionella bacteria. Legionella bacteria can cause serious and sometimes lethal forms of pneumonia. To prevent proliferation of pathogens the temperature of water in water heater needs to be maintained at 60°C.

France gaz is pleased to be able to participate in this consultation, which presents major challenges for the French and European gas sectors. However, we regret that no stakeholder meeting is organised in view of the many proposals that could have a significant impact on the heating and domestic hot water market.

Filed in French · English published by the European Commission

Thank you for the opportunity to provide feedback on the draft. We would be grateful if the following points could be taken into account: 1. According to the new draft, the requirements for heating systems installed by craftsmen with products from different manufacturers will be abolished.

Filed in German · English published by the European Commission

a) Currently, a lot of regulatory uncertainty remains on the future of fossil boilers versus heat pumps. This could be resolved by revising the Ecolabelling framework so that fossil fuel boilers cannot receive an A-label and only appliances with efficiency above 100% (on higher heating value) should qualify for top-tier labels. b) Devices without a water storage tank, are often sold as heating only.

Please find in attached letter our objection against the proposed change to test water heaters at 50°C instead of the current 55°C, as required by EN 806-2. The undesirable result of the foreseen change will be that: - If the efficiency of water heaters is determined at a too low water temperature, the performance on the energy label is not realistic/overrated; - There will be appliances on the market that will not…