Energy labelling requirements for space and combination heaters (review/rescaling)

COGEN Europe welcomes the opportunity to comment on the European Commission proposals for Energy efficiency labelling and ecodesign requirements for space and combination heaters (review/rescaling). While fully supportive of an ambitious approach to energy efficiency of space heaters, COGEN Europe considers that the proposals made for micro-cogeneration systems fall short of the energy efficiency first principle and…

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.

Please find attached the comments and proposals of the Uniclima trade union. Uniclima is the French group of thermal, aeraulic and refrigeration industries. It includes manufacturers of heating, air conditioning, ventilation, refrigeration and domestic hot water equipment for all types of industrial buildings and processes. Uniclima has 92 brands for 69 leading companies or groups in their markets.

Filed in French · English published by the European Commission

Solar Heat Europe welcomes the revision of the Energy Labelling requirements for space and combination heaters and supports the Commissions objective to improve clarity, comparability and consumer understanding. However, the current draft unintentionally removes the main mechanism through which solar thermal technologies have been visible in the space heating framework: the installer made package label.

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.

EQUIUM, a French Deeptech company developing thermoacoustic technology enabling a new generation of compressor less & refrigerant free heat pump. We welcome the Commissions proposal. We fully support the intention to stimulate innovation by lowering the minimum efficiency requirements and the Primary Energy Factor (CC). This signals a willingness to open the market to sustainable, refrigerant-free technologies.

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 energy labelling of space and combination heaters. BlueHeart is developing a radically different heating and cooling engine that uses thermoacoustic technology (sound waves to move heat). It eliminates risks caused by refrigerants as it does not contain a refrigerant and it eliminates the sound emission of a compressor by not having one.

Vaillant welcomes the opportunity to provide feedback on the draft Labelling 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).

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…

SHV Energy welcomes the revision of the energy labelling rules and supports the move to a clearer AG scale. However, as a supplier of LPG and bioLPG, we are concerned that the proposal does not sufficiently reflect: methodological differences between heat pumps and combustion boilers, the needs of rural, off-gas-grid and hard to electrify buildings, and the proven air quality and decarbonisation benefits of LPG/rLG…

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.

We welcome the opportunity to participate in the revision of energy labelling framework and appreciate Commissions effort to assess the technical and environmental aspects of space heaters. While we support the objective of improving consumer transparency and accelerating decarbonisation, we believe the draft needs alignment with the broader regulatory framework established by the Energy Performance of Buildings…

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.

The European Geothermal Energy Council (EGEC) welcomes the European Commissions initiative to review the energy labelling and Ecodesign requirements for space and combination heaters. These revisions are timely and necessary to reflect technological progress, market developments, rescaling obligations under the Energy Labelling Framework Regulation, and the objectives of the European Green Deal.

EdEn believes that this regulation should strongly incentivise consumers to choose heat pumps. To achieve this objective, the energy labelling framework for heat pumps should be clearly and visibly differentiated from that of fuel-fired boilers, which are intended to be phased out.

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) supports the European Union's ambition to boost energy efficiency and decarbonise the heating sector. However, the current draft regulation revision risks diverging from its primary objective: helping consumers to identify the most efficient appliance for their specific needs (suitable for their specific building, budget and local energy infrastructure).

GRDF welcomes this review of the labelling requirements for space and combination heaters, and thanks the European Commission for organising this consultation. GRDF shares the objectives of phasing out fossil CO2 emissions, manage energy savings and demand flexibility in the building sector, and is convinced that its a key point for these policies to give to consumers information about the performance of heating…

Assotermica is the Italian Association (member of ANIMA/CONFINDUSTRIA) which represents manufacturers of equipment and components for heating systems, an advanced industrial sector that has paved the way for many advances in technological innovation at an international level over the last 40 years, which employs more than 12,000 people in Italy and generates a turnover of approximately 3.5 billion, as well as…

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 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…

Welcoming the EU proposal for a revision of energy-labelling requirements, that enables consumers to make informed choices and by guiding market evolution toward more efficient solutions, Italgas underlines that this tool should primarily function as a transparent and technology-neutral efficiency comparator, taking in considerations peculiarities like building characteristics, economic constraints and local energy…

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.

The water heater shall permanently exceed 50 °C. As regards the hygiene aspects of drinking water, the recognised codes of practice for the installation of drinking water must also be observed. Request that the temperature at the water heater outlet be corrected from 55° to 50 °C.

Filed in German · English published by the European Commission

- Hager Electro feedback on the Draft Commission Delegated Regulation on Energy Labelling of Space and Combination Heaters (Ares(2025)10453708). Hager Electro welcomes the European Commissions initiative to revise the energy labelling framework for space and combination heaters.

EAB Elektroanlagenbau GmbH Rhein/Main Feedback on the Draft Commission Delegated Regulation on Energy Labelling of Space and Combination heaters (Ares(2025)10453708) Introduction EAB Elektroanlagenbau GmbH Rhein/Main, welcomes the European Commissions initiative to update the energy labelling framework for space and combination heaters.

Filed in German · English published by the European Commission

Thank you for the opportunity to provide feedback on the draft. We hope that the feedback received will also be appreciated and taken into account by those involved. 1. The proposed load profiles (Load Profiles 3XS to 4XL) are not very intuitive for consumers. Proposal: The use of emblematic representations in the product information (e.g. profile L 5 persons) would be more specific here. 2.

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.

The French Association of Geothermal Professionals has taken note of the changes to the testing conditions for geothermal (ground sourced) heat pumps. The simplification brought about by the elimination of the two categorieswater and brineis good news for heat pump manufacturers, who will no longer have to choose one category or the other to have the power and performance of their equipment certified.

1/3 for the attention of Mr Robert Nuij, Head of the Buildings and Products Unit, DG Energy We are a small SME importer of liquid and gaseous fuel boilers and soon hybrid systems. Our products are tested in accredited laboratories, often outside the European Union, and we have invested for many years to comply with existing rules on energy decodesign and labelling.

Filed in French · English published by the European Commission

2/3. We therefore ask very clearly: * Since 2013, how many national authorities have actually taken legal action against manufacturers for failure to comply with the rules on the efficiency of heat generators or water heaters? * How many final judgments per Member State found significant non-compliance of the declared values?

Filed in French · English published by the European Commission

3/3. On NOx, the project retains a tolerance of 20 %. The limits for liquid fuels remain almost unchanged after more than 10 years. Given the importance of NOx for health and air quality, it is difficult to understand why: * the limits have not been tightened, * the tolerance remains at 20 %. Maintaining wide limits on NOx while complicating the rules on energy efficiency gives a confusing signal.

Filed in French · English published by the European Commission

COGEN Europe welcomes the opportunity to provide feedback on the review of the energy labelling of space and combination heaters. While fully supportive of an ambitious approach to energy efficiency of space heaters, COGEN Europe considers that the proposals made for micro-cogeneration systems are inconsistent with the “energy efficiency first” principle and the move towards smarter buildings that actively…

We are thankful for the opportunity to comment in view of the launch pf the Impact Assessment Study for the revision of the ecodesign and energy labelling regulations for space and combination heaters. Concerning the proposed scenario for the ecodesign regulation, we are concerned that the proposed efficiency levels are not aligned with the climate target of the EU.

Solar Heat Europe welcomes the opportunity to provide additional feedback on the call for evidence for the impact assessment on the Ecodesign requirements for space and combination heaters, 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

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

Energy Labelling was designed at a time when electricity was mostly fossil based, to help consumers select the most efficient solution to meet their needs, with the lowest energy consumption costs for them. This approach was relevant for comparing similar products, using the same energy, such as two fridges, but far less relevant when comparing appliances offering different services, using different energy vector…

Energy Labelling was designed at a time when electricity was mostly fossil based, to help consumers select the most efficient solution to meet their needs, with the lowest energy consumption costs for them. This approach was relevant for comparing similar products, using the same energy, such as two fridges, but far less relevant when comparing appliances offering different services, using different energy vector…

We welcome this initiative to revise the Ecodesign and Energy Labelling requirements for space and combination heaters, to reflect technological development and the need to achieve higher energy efficiency. In previous occasions, we have consistently called for an accelerated switch towards more efficient and more climate friendly heating appliances, highlighting the need to align product policy to the EU climate…

Space and combination heaters are the main heating products for households, and buildings have the largest energy savings and emission reduction potential, compared to other energy consumption sectors. It is also the main market for EU gas consumption.

On March 8th, the European Commission published their key Communication to react to the urgency to move away from EU’s dependency on fossil fuel imports “REPowerEU”. Heat pumps are seen as a central and key technology for reshaping the EU’s heating energy needs, today and in the future.

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 space heaters and combination heaters. 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 space heaters and combination heaters.

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 1 (ecodesign Regulation 813/2013 and energy labelling Regulation 811/2013 for space 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.

The European Heating Oil Association (Eurofuel) represents organisations that promote the use of liquid fuels for domestic heating in Europe. Our members are committed to ensuring the competitiveness and efficiency of heating with oil and liquid fuels, while also reducing its environmental footprint. We fully support the objective of Ecodesign to increase the efficiency of products.

Please consider our attached document for a deeper analysis, here below you can find a synthesis. 4. Ecodesign requirements – extending the rules to cover appliances with a capacity from 400 kW to 1 MW Having in mind the last version of the draft Regulation presentend, in the future a reversible appliance will be a heating product if its capacity is below 400 kW and starting from 401 kW it will must be declared as a…

Please consider our attached document for a deeper analysis, here below you can find a synthesis. 4. Ecodesign requirements – extending the rules to cover appliances with a capacity from 400 kW to 1 MW Having in mind the last version of the draft Regulation presentend, in the future a reversible appliance will be a heating product if its capacity is below 400 kW and starting from 401 kW it will must be declared as a…

Dear Madame, Dear Sir, finally, with the communication on "REPowerEU: Joint European Action for more affordable, secure and sustainable energy" the COM underline again the necessary effort to even reach the climate and energy goals earlier: "30 million newly installed heat pumps installed in 2030, saving 35 bcm in 2030".

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 1 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.