European Heat Pump Association (EHPA)

The European Heat Pump Association (EHPA) welcomes the Industrial Accelerator Act (IAA) and its objective of strengthening Europes industrial base while accelerating the deployment of net-zero technologies. In the current geopolitical and economic context, reinforcing European manufacturing capacity, reducing strategic dependencies and supporting industrial competitiveness are legitimate and necessary policy…

More than 60% of the energy used by European industry is for the provision of heat. Industrial heat pumps can help decarbonise low to medium temperature heat supply within industries by reusing waste heat and generating renewable energy thus replacing oil and gas. Industrial heat pumps are part of a European clean tech sector, ready and deployable today and able to reach temperatures of up to 180-200°C.

On behalf of the heat pump, air conditioning and refrigeration equipment sector, represented by the European Heat Pump Association (EHPA) and the European Partnership for Energy and the Environment (EPEE), we welcome the opportunity to provide feedback on the revision of the EU Taxonomy Climate Delegated Acts to simplify and update their technical screening criteria.

Despite significant progress in making electricity cleaner and more efficient, its share of final energy consumption has grown by less than 3% over the past two decades. This slow uptake is consistent across sectors and countries, underscoring the need for coordinated, strategic action to fully realise electrification as a cornerstone of a sustainable European energy system.

To reduce the use of fossil fuel in the heating and cooling sector, several alternatives exist. However, these options come with specific limitations related to cost, scalability, geography, or environmental impact.

The revision of the Governance Regulation comes at moment when EU is entering a new phase of its climate and energy framework, including the proposed 2040 climate target, while at the same time facing new challenges related to energy security, industrial competitiveness and energy affordability.

Heat pumps play a pivotal role in enhancing Europes energy security by harnessing natural energy from the air, ground, or water, requiring only a small amount of driving electricity. Their deployment reduces Europes reliance on fossil gas imports for heating and cooling across residential, commercial, and industrial settings.

As the proposed reporting requirements under Article 24 of Regulation (EU) 2024/1781 which establishes a framework for setting Ecodesign requirements for sustainable products (hereinafter referred to as the ESPR) are set to be implemented across industries, EHPA wishes to express its concerns regarding the potential impact these obligations may have on the heat pump sector.

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.

EHPA believes a separate category should remain available for smaller equipment, similar to today's Category II. This is particularly important in view of the uptake of heat pump systems supported by the REPowerEU targets, which require the amount of newly installed heat pumps to double every four years. Furthermore, EHPA suggests certificates also indicate which Regulation the certificate refers to.

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.

This paper sets out the European Heat Pump Associations (EHPA) feedback on the draft Ecodesign and Energy Labelling Regulations for space and combination heaters, as well as for water heaters and storage tanks (hereinafter referred to as Lots 1 and 2).