Ecodesign requirements for water heaters and tanks (review)

Solar Heat Europe welcomes the revision of the Ecodesign requirements for water heaters and hot water storage tanks and supports the Commissions objective to improve energy performance, ensure regulatory clarity and strengthen the contribution of renewable technologies. 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.

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.

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).

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…

Liquid Gas Europe (LGE) underlines the role of renewable liquid gases (rLGs)notably bioLPG (biopropane) and renewable DMEas drop-in solutions that can deliver decarbonised, affordable energy for households, especially in rural and off-grid areas.

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.

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.

AMDEA welcomes the improvements presented in the Draft Ecodesign and Energy Labelling Regulations. As a member of APPLiAs network of national trade associations, AMDEA fully supports and endorses APPLiAs policy paper, which has already been submitted as feedback.

GIFAM is the professional organization representing French manufacturers of electric and thermodynamic water heaters. Our document provides detailed responses to the consultation on the draft eco-design regulation as well as the draft energy label regulation.

GIFAM is the professional organization representing French manufacturers of electric and thermodynamic water heaters. Our document provides detailed responses to the consultation on the draft eco-design regulation as well as the draft energy label regulation.

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.

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).

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 water heaters and tanks, in particular Recital 12.

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…

APPLiA's comments on the draft Ecodesign and Labelling regulations for water heaters propose several critical modifications to ensure a fair level-playing field and prevent the unjustified market exclusion of certain efficient technologies, particularly Electric Storage Water Heaters (ESWH) and Electric Instantaneous Water Heaters (EIWH).

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.

ZVEI e. V., the German Electro and Digital Industry Association, welcomes the new Ecodesign and Energy labelling regulation via the revision of Commission Regulation (EU) 814/2013 and (EU) 812/2013. However, several elements of the regulation will disproportionately disadvantage specific product groups.

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

It is important that water heaters can continuously provide a minimum temperature of 60 °C at nominal flow rate and 75 °C at reduced flow rate. This is the only way to ensure hygienic operation in all cases of hygienic defects. This requirement shall be included in the test of equipment.

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…

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for water heaters and storage tanks, while thanking the European Commission services and the experts contributing to this work.

The EU needs to rapidly reduce its dependence on fossil fuels, including Russian gas, to stop financing dictatorial regimes, meet its 2030 climate targets and preserve consumers’ purchasing power. First, the deep thermal renovation of buildings needs to be accelerated much more vigorously and become an absolute priority for the EU and the Member States. Local biogas production is also a route to be developed.

Filed in French · English published by the European Commission

Water heaters are among the most energy-guzzling technologies in our homes and one with the largest potential for energy savings and climate emissions. While they are technically among the appliances that can best profit from local production of renewable energy (i.e. in combination with solar thermal solutions), as of now water heaters are a major driver for gas and electricity domestic consumption.

We appreciate the opportunity to provide feedback on relevant issues for the impact assessment and ask to consider attached position of the Czech Gas Association in detail during the impact assessment. We would like to stress out that we welcome the possibility to indicate future H2-ready appliance on the upcoming energy label.

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 water heaters and storage tanks. Energy Label EHPA believes that we should maintain the label as simple, clear, and understandable as possible for the end-user.

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 water heaters and storage tanks.

EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, welcomes the opportunity to provide comments to the Commission’s proposals for reviewing ENER Lot 2 (ecodesign Regulation 814/2013 and energy labelling Regulation 812/2013 for water heaters).

Eurovent would like to thank for the opportunity of providing feedback following the Call for Evidence for an Impact Assessment on Ecodesign and Energy Labelling (review) for LOT 1-2. The Eurovent comments and positions are reported in the attached document.

Eurovent would like to thank for the opportunity of providing feedback following the Call for Evidence for an Impact Assessment on Ecodesign and Energy Labelling (review) for LOT 1-2. The Eurovent comments and positions are reported in the attached document.

APPLiA supports the decarbonisation objectives of the Green Deal and therefore appreciates the need for an ambitious package of policy measures. Nevertheless, the proposals presented so far by the Commission will not solve the issues with the existing framework and hamper the deployment and installation of more efficient technologies.

We appreciate the opportunity to provide feedback on relevant issues for the impact assessment and ask to consider the following issues in detail during impact assessment: PEF for 100% H2: for Lot 2 We welcome the possibility to indicate future H2-ready appliance on the upcoming energy label.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.