Energy labelling requirements for water heaters and tanks (review/rescaling)

Solar Heat Europe welcomes the revision of the Energy Labelling requirements for water heaters and hot water storage tanks and strongly 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 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.

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.

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 liquid gasesand in particular renewable liquid gases (rLGs) such as bioLPG (biopropane) and renewable DMEin delivering reliable, affordable heat and hot water, notably for rural and off-grid households and light-commercial users.

We continue to strongly support the Commissions ambition to improve energy efficiency and the proposed tightening of minimum energy efficiency requirements for storage tanks. We are, however, concerned about the very late introduction of a double tightening of requirements for water heaters, which in addition to having to meet stricter energy efficiency targets potentially now have to be declared under a different…

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.

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.

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.

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).

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.

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 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.