Review of energy labelling requirements for solid fuel boilers

Dear Ladies and Gentlemen, MCZ has been a manufacturer of pellet boilers for more than 15 years, and we have always believed in the virtuous and well regulated use of woody biomass which represents the main renewable energy source in domestic heating.

Dear Ladies and Gentlemen, MCZ has been a manufacturer of pellet boilers for more than 15 years, and we have always believed in the virtuous and well regulated use of woody biomass which represents the main renewable energy source in domestic heating.

SER (French renewable energy trade association) would like to submit the following inputs : Data more representative of the market should be used for the revision. The Commission should not use data from BAFA, the German financial aid scheme, but use instead data from the Flamme Verte label.

Bioenergy association of Finland would like to submit the following inputs concerning the revision of Ecodesign requirements for Solid-fuel Boilers. Solid fuel boilers are proven technologies that have shown significant improvements in energy efficiency through the years, using less feedstock and therefore reducing emissions.

Solar Heat Europe (SHE) welcomes the opportunity to contribute to the public consultation on ecodesign and energy labelling requirements for solid-fuel boilers. We support the proposals of topics and options as mentioned in the call for evidence.

Solar Heat Europe (SHE) welcomes the opportunity to contribute to the public consultation on ecodesign and energy labelling requirements for solid fuel boilers. We support the proposals of topics and options as mentioned in the call for evidence.

The European Heat Pump Association (EHPA) supports the Commissions proposal to merge the labels and believes that this step will contribute significantly to achieving the decarbonization of heating and cooling in EU buildings.

Doctors and Scientists Against Wood Smoke Pollution (DSAWSP) is an international coalition of doctors, academic researchers, and other professionals whose mission is to reduce the public health and climate harms that are linked with wood burning. Please see the attached file for our comment.

Dear Mr Martinez, Dear Ladies and Gentlemen, Extraflame Spa is a company that has been working in the biomass sector - particularly with pellets - for over 20 years. Our products have always been designed and placed on the market in compliance with current European and national technical standards and regulations.

Dear Mr Martinez, Dear Ladies and Gentlemen, La Nordica S.p.A. works in solid biomass heaters, especially wood logs, since 50 years. We strongly believe in the effectiveness of the Ecodesign and Energy labelling Regulations for solid fuel boilers.

On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid fuel boilers/SFB (EU 2015/1189). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.

Dear Mr Martinez, Dear Ladies and Gentlemen, Manufacturers strongly believe in the effectiveness of the Ecodesign and Energy labelling Regulations for solid fuel boilers. Manufacturers believe that a revision could be beneficial, but the approach should not change: Ecodesign should focus on identifying and defining achievable limits, solid fuel boilers are a minor source of energy consumption and pollution and…

The Call for Evidence explains: solid fuel boilers remain significant contributors to energy consumption, greenhouse gas and pollutant emissions. Pollution, mostly from particulate matter, is very high in densely populated areas with a large share of solid fuel boilers, amplifying the threat to public health.

Wood heating using wood fuels from sustainable forest management is climate neutral. CO2 emissions from wood fuels move within the above-ground carbon cycle and cannot be compared to CO2 emissions from millions of old fossil fuels from the earth’s crust.

Filed in German · English published by the European Commission

Dear Mr Martinez, Dear Ladies and Gentlemen, Manufacturers strongly believe in the effectiveness of the Ecodesign and Energy labelling Regulations for solid fuel boilers. Manufacturers believe that a revision could be beneficial, but the approach should not change: Ecodesign should focus on identifying and defining achievable limits, solid fuel boilers are a minor source of energy consumption and pollution and…

The Cool Heating Coalition welcomes the Commissions initiative to review the energy labelling and ecodesign requirements for solid-fuel boilers. We broadly concur with its analysis of the shortcomings of current energy labelling and ecodesign requirements.

Dear European Commission, We are Habitat for Humanity Hungary, a national office of the global non-profit organization that works to ensure that everyone has a decent place to live. We appreciate the opportunity to comment on the intended initiative on ecodesign and energy labelling requirements for solid fuel boilers.

Dear Mr Martinez, Dear Ladies and Gentlemen, Manufacturers strongly believe in the effectiveness of the Ecodesign and Energy labelling Regulations for solid fuel boilers. Manufacturers believe that a revision could be beneficial, but the approach should not change: Ecodesign should focus on identifying and defining achievable limits, solid fuel boilers are a minor source of energy consumption and pollution and…

The producers of dust separators organised in the CEA are grateful for the possibility of participating in European regulation. An ecological and social heat transition will only be feasible through the use of biomass. We are observing with concern that the long-standing technological efforts of industry and taxpayers’ investment in efficient air pollution are being challenged in many countries, including Germany.

Filed in German · English published by the European Commission

The heating sector in Germany has a high degree of heterogeneity in the building and ownership structure. The necessary high level of ambition for renewable heating therefore makes it imperative to grant building owners the greatest possible technical and economic freedom and to provide the widest possible range of options for climate-neutral heating of buildings.

Filed in German · English published by the European Commission

Bioenergy Europe would like to submit the following inputs concerning the revision of Ecodesign requirements for Solid-fuel Boilers. Solid fuel boilers are proven technologies that have shown significant improvements in energy efficiency through the years, using less feedstock in a better way and therefore reducing emissions.

FEBHEL, the Belgian Federation of Wood Energy, would like to make the following contributions. Wood energy, as a by-product from the wood recovery industry, is a means of local and renewable heating. Solid fuel boilers are well-established technologies whose energy efficiency has significantly improved over the years, allowing less raw materials to be used and emissions reduced.

Filed in French · English published by the European Commission

Es sollen die Steuerungen nicht so wie es jetzt ist, sehr kompliziert sein, das sich auch die Elter Sten Personen damit zurecht finden, was ja jetzt durch die EU verhindert wird. Das Ökodesign und Ansicht des Kessel braucht nicht Hype sein, er muß die Leistungen bringen, das Material darf kein Mist sein, wie man es jetzt schon sieht, bei jeder Kleinlichkeit zerfällt der Kessel und die Kammer.

The European Public Health Alliance (EPHA) and the European Respiratory Society (ERS) welcome the revision of the ecodesign requirements for solid fuel boilers and the opportunity to provide feedback to the decision-making process. The key messages we would like to emphasise are as follows: 1. The health community should be consulted on relevant product policies 2.

Ecodesign wood boilers, although cleaner in some respects, are equally very harmful to human health, the environment and the climate. Boilers burn much more hours than wood stoves, and in the smear phase and frequently switch-off, they also produce a lot of CO2, particulate matter, ultrafine particulate matter (UFP) and polycyclic aromatic hydrocarbons (PAH) with the marker dust benzo (a) pyrene (BaP).

Filed in Dutch · English published by the European Commission

Ecodesign and energy labelling requirements for solid fuel boilers contribution to call for evidence The European Respiratory Society (ERS) and the European Public Health Alliance (EPHA) welcome the revision of the ecodesign requirements for solid fuel boilers and the opportunity to provide feedback to the decision-making process.

Build Europe, the European association representing the national federations of European developers and homebuilders, accounting for more than 60% of EUs homebuilding capacity and 17 states, welcomes the EU action plan on accelerating the heat pump market and deployment. We endorse the Commission's initiative to review the ecodesign requirements (e.g.

The idea is tempting that with the fuel wood we make ourselves independent of the countries supplying fossil fuels. Solid fuel boilers can make little contribution to achieving climate neutrality in the EU. Wood is not in itself carbon neutral. Even with a 1 to 1 replanting, it takes decades for the CO2 generated by the combustion to be sequestered again. Wood is not a freely available raw material.

Filed in German · English published by the European Commission

On behalf of Fern, we welcome the revision of the Ecodesign Regulation for solid fuel boilers (EC 2015/1189). The energy prices crisis which followed the Russian invasion of Ukraine has driven up both the prices of fossil fuels and wood solid fuels.

On behalf of ECOS/EEB/Coolproducts we welcome the revision of the Ecodesign Regulation for solid fuel boilers (EC 2015/1189). We have seen a steady increase in the use of biomass for heating and combined heat and power in recent years, and unless rapid regulatory action is taken to encourage consumers to make more sustainable choices, the forthcoming renewable energy targets, particularly in the buildings sector…

On behalf of AirClim we welcome the revision of the Ecodesign Regulation for solid fuel boilers (EC 2015/1189). We have seen a steady increase in the use of biomass for heating and combined heat and power in recent years, and unless rapid regulatory action is taken to encourage consumers to make more sustainable choices, the forthcoming renewable energy targets, particularly in the buildings sector, are likely to…

In my view, solid fuel boilers should have their own energy classification, in the sense that they do not confuse customers at the time of choosing a heating solution. Heat pumps are a separate product with an efficiency of 1: 4 (consumption 1kwh but with up to 4 kwh), but it must not be forgotten that, in order to be equipment considered 100 % green, the electricity consumed by these appliances must come from…

Filed in Portuguese · English published by the European Commission

Point 3: Rescaling of the label, whether or not merging with the label of other hydronic space heaters, and fixing a scale of pollutants. Merging the label would result in the revision or removal of the biomass factor used to favour biomass combustion equipment over fossil fuel combustion equipment = > The reference to eco-design is reliable and fair for all manufacturers.

Filed in French · English published by the European Commission

As "Brussels for Human Rights and Development," we extend our appreciation for your dedicated efforts in driving energy efficiency and advancing climate neutrality through ecodesign requirements. Your proactive approach to review and improve these requirements for solid-fuel boilers is a vital step towards achieving sustainability and addressing the pressing climate crisis.