Energy labelling requirements for local space heaters (review)

Thank you for the opportunity to comment on this important consultation. I am writing on behalf of Clean Air in London (CAL) which campaigns for full compliance, urgently and sustainably, with the World Health Organisation's new air quality guidelines throughout London and elsewhere. Please see our website here: https://cleanair.london/.

We are fully allign with the views expressed by ECOS, EEB (European Environmental Bureau) and Coolproducts coalition: We welcome the long-awaited revision of Energy Labelling Regulation (2015/1186) for local space heaters.

ZERO - Associação Sistema Terrestre Sustentável is a Portuguese Environmental NGO working on various issues where Climate Change and Energy are major action priorities and is an active member of several European NGO networks - ECOS (European Environmental Citizens Organisation for Standardisation), EEB (European Environmental Bureau) and CAN-Europe (Climate Action Network).

eu.bac would like to thank the European Commission for the opportunity to provide feedback on the review of energy labelling requirements for local space heaters, including the proposed merging of the energy labels for Lot 10 and Lot 20.

As a general comment, Assoclima is not against the merging of labels and scales of Room Air Conditioners and Room Heaters for the heating function. Assoclima is also open to evaluate and contribute whether a separate cooling scales scenario will be analysed by the Commission.

You will find enclosed Uniclima’s comments about the proposal of new labels for local space heaters and their merging with air conditioners, those already described in the (EU) 626/2011 regulation, of which the review is also ongoing.

General Statement REHVA, the Federation of European HVAC associations appreciates the work and impact of the EU Ecodesign and energy labeling regulations that helped to increase the energy efficiency of HVAC components.

Energy labelling requirements for local space heaters Feedback to electrical local space heaters The efficiency of electrical local space heaters is nearly 100% due to the physical conditions. To improve electrical space heating the percentage of renewable electricity production must be raised.

While supporting the Commission's intention to update the existing label, as well as to remove less efficient products from the market, we oppose the merger of these two lots and strongly oppose the creation of a single classification for energy labelling of local space heaters (LSH) and air-to-air heat pumps (HP) as proposed by the Commission.

Topten welcomes the merging of regulations for room appliances with the same function into one energy label and the corresponding widening of the scope to include electric joule room heaters and comfort fans. Especially in the context of a challenged economy, the market cannot afford to misdirect consumers who often believe that class A models even of different room heating technologies are similarly efficient; true…

As stated in the co-signed open letter published on 8 February 2022, the joint industry position of 22 June 2022, and the Consultation Forum of 24 June 2022, the European Heating Industry is opposed to the merger of the energy labels under Lots 10 (air-to-air heat pumps, air conditioners, and comfort fans) and 20 (local space heaters).

CEFACD, which represents the manufacturers of domestic local space heaters, supports the review of European energy labelling policies in line with technological and market developments. As such, we are strongly opposed to the proposed merger of energy labelling scales under ENER Lots 10 (air-to-air heat pumps, air conditioners, and comfort fans) and 20 (local space heaters). Attached is our position.

The Electric Underfloor Heating Alliance (EUHA) unites manufacturers to promote the interests of the product sector within a new electrified smart grid infrastructure. We support the review of European energy labelling policies in line with technological and market developments.

The European Infrared Heating Alliance (EIHA), representing the European manufacturers of infrared heating, supports the review of energy labelling policies in line with technological and market developments. As such, we are strongly opposed to the proposed merger of energy labelling scales under ENER Lots 10 (air-to-air heat pumps, air conditioners, and comfort fans) and 20 (local space heaters).

EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, supports the EU energy labelling policies, and agrees with the need to keep the legislation up-to-date and in line with the latest technological and market developments.

Glen Dimplex would like to thank the European Commission for the opportunity to provide feedback on the review of energy labelling requirements for local space heaters including the proposed merging of the energy labels for Lot 10 and Lot 20.

Liquid Gas Europe is a European association composed of national LPG associations, main LPG suppliers, distributors and equipment manufacturers of LPG and renewable LPG including bioLPG, renewable DME (rDME) and other drop-in and complementary gases.

A Working Document recently published by the EU Commission outlines the intent to combine energy labels for products falling under ENER Lot 10 (air-to-air heat pumps, air conditioners), ENER Lot 20 (Local space heaters), and comfort fans.

JRAIA supports the Commission's position on the energy label which should allow different types of technologies (products) to be evaluated fairly. We will state this in our joint position paper with JBCE to the consultation forum held on 24 June 2022 concerning the merged labelling regulations for room heaters, room air conditioners and comfort fans.

The German Wood Energy Association (FVH) supports ecolabelling as a beneficial tool for the consumer to recognize whether a product meets his expectations. However, a clear differentiation between good and less good products as well as a defined range of products that share a common technological basis is a prerequisite.

Generally energy labelling is supported by our industry as a good opportunity to inform the customer and help him or her to choose the appropriate product for his/her purpose. But there is the need of a clear differentiation between good and less good products in a certain product range.

The Commission, as part of the energy labelling regulations revision, has recently proposed to merge, into a single scale, the energy labelling of all generators which, as a function, offer space heating (Lot 10 and Lot 20). The proposal also provides for a classification scale (A-G) shared by all technologies.

We welcome the long-due revision of the Energy Labelling Regulation for local space heaters, with the objective of contributing to energy efficiency, reduce CO2 emissions and air pollution, and protect and enable consumers to make the most efficient heating choice.

In our opinion the wood burning local space heaters should not be compared to air-to-air heat pumps, air conditioners, and comfort fans in one single labelling scheme. The most important reason is that wood is a renewable energy source and electricity for electric devices is mainly obtained from the combustion of fossil fuels: gas and coal. Such merging would unfairly favor the use of fossil fuels.

In our opinion the wood burning local space heaters should not be compared to air-to-air heat pumps, air conditioners, and comfort fans in one single labelling scheme. The most important reason is that wood is a renewable energy source and electricity for electric devices is mainly obtained from the combustion of fossil fuels: gas and coal. Such merging would unfairly favor the use of fossil fuels.

Assobagno, one of the eleven statutory associations of FEDERLEGNOARREDO, associates the Italian bathroom and furniture industries within the Confindustria system. These are around 150 companies with a total turnover of around EUR 2 billion and a representativeness on the Italian market of around 52 % of the total turnover of the bathroom furniture sector.

Filed in Italian · English published by the European Commission

As the largest manufacturer of wood burning fireplaces and free-standing stoves in Poland, as well as one of the largest manufactures within the European Union, we would like to present our position in reference to the energy labelling changes. From our point of view, it is not possible to combine the two energy labels ENER Lots 10 (air-to-air heat pumps, air conditioners and portable fans) and 20 (space heaters).

When deciding on a uniform label for individual room heaters and air conditioners, it is important to also make a non-technical but political assessment of the issue. The technology of electric heating must never run the risk of being banned via ErP product regulation.

EHPA would like to thank the European Commission for the work already carried out and welcomes the opportunity given to share its feedback on the European Commission proposal on the merging of the energy labels for air-to-air conditioners, air-to-air heat pumps and comfort fans (Lot 10) and local space heaters (Lot 20).

APPLiA - Home Appliance Europe would like to provide its view on the energy labelling revision for local space eaters. In this paper, we would like to provide a simple and clear explanation of why electric local space heaters (ELSH) should not be compared to other products in one single labelling scheme.

The Swedish Stove Association wants to make it clear that our industry is very critical of the proposal to merge LOT 10 and LOT 20. The product categories affected are significantly different types of heat sources with properties that cannot be equated or compared. Not the technology or the application of air / air heat pumps has anything in common with a wood-fired secondary heat source.

Having reference on the Call for evidence on Energy labelling requirements for local space heaters (review) and following the Consultation Forum for the revision of the Energy Labelling Regulation on air-to-air conditioners and heat pumps, local space heaters and comfort fans, held by DG ENERGY on 24 June 2022, please find enclosed the Eurovent position.

We welcome the long-awaited revision of Energy Labelling Regulation (2015/1186) for local space heaters. Heating products, and their local (room) application, are of crucial interests in the European policy arena, not only for their impact on climate and energy targets, but also to push and increase the independency from fossil fuel and for their human health impact, especially concerning solid fuel-based heaters.

The efficiency of electrical local space heaters is nearly 100% due to the physical conditions. To improve electrical space heating the percentage of renewable electricity production must be raised. Due to that a labelling for electrical local space heaters would increase the burden for the industry and have no benefit for the consumers. As far as we know electric heaters are not intended to be used for cooling.

During the Consultation Forum held on 24 June 2022 in Brussels, the Commission’s intention to bring together in a single energy label all room heaters, including electric room heaters, was confirmed. Several participants emphasized that this merger would result in: ● having all heat pumps at the top of the energy scale; ● having all electric room heaters (i.e using the Joule effect) at the bottom of the energy…

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