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.

THIS IS A SUMMARY OF EHPA'S MAIN REQUESTS. THE DETAILED POSITION HAS BEEN ATTACHED TO THIS SUMMARY. On the 8th of July, the European Commission published its EU Energy System Integration Strategy as part of the European Green Deal to reach climate neutrality by 2050.

About EHPA The European Heat Pump Association (EHPA) promotes awareness and deployment of heat pump technology in Europe. All activities aim at creating a market environment that facilitates a faster deployment of heat pump technology to unleash its benefits on a European level: efficient heating and cooling using renewable energy.

The revision of the EPBD is an important opportunity to increase the ambition for decarbonising the building stock with efficient and renewable heating and cooling solutions such as heat pumps in buildings. EHPA proposes the following measures: 1) Efficient and renewable heating system required in new buildings and major renovations EHPA recommends setting mandatory minimum energy performance standards at such an…

EHPA would like to thank the European Commission for the opportunity given to send feedback on the Commission proposal. General remarks Overall, when discussing about the Ecodesign for Sustainable Products Regulation and its requirements, it is important to keep in mind the following: - EHPA would like to recall the importance of a product group specific approach to take into account the specificities of the heat…

THIS IS A SUMMARY OF EHPA'S MAIN REQUEST. THE DETAILED POSITION HAS BEEN ATTACHED TO THIS SUMMARY. The revision of the EED is an important opportunity to further expand the energy efficiency benefits of heat pumps, as well as to support their large-scale deployment in accordance with the EU Energy System Integration Strategy.

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.

FULL CONTRIBUTION IN DOCUMENT ATTACHED This position paper presents: - EHPA's concern about an EC F-gas Regulation proposal that risks jeopardising the EU’s overall ambition to achieve its decarbonisation and energy security goals. o The phase-down trajectory suggested in the F-gas Regulation proposal is incompatible with an accelerated massive deployment of heat pumps (REPowerEU targets).

FULL CONTRIBUTION IN DOCUMENT ATTACHED 1) The multiple benefits of heat pumps are based on the refrigerant cycle which needs refrigerants to function. Key component of heat pump technology, refrigerants are required to fully exploit the heat pumps’ potential in decarbonising heating and cooling – they are the working medium that absorbs heat in a cooling process at low temperature and low pressure and emits heat at…

The European Commission is taking the right step in supporting the heat pump growth through the Net Zero Industry Act and the upcoming Heat Pump Action Plan. As sector, we support this initiative since it addresses the workers and skills shortage and the supply chain fluidity.

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.

Before going into details, EHPA would like to stress that heating products are not the focus of this newly plan legislation because they are completely different products which we will further explain below. Furthermore, heat pumps are already performing well and an example when it comes to long-lasting products, availability of spare parts, repair and maintenance.

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 air-to-air conditioners, air-to-air heat pumps and comfort fans.

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 air-to-air conditioners, air-to-air heat pumps and comfort fans. Thermal Comfort EHPA appreciates that thermal comfort of occupants has been taken into account.

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.

With the present paper, the European Heat Pump Association (EHPA) aims to further contribute to the European Commissions Call for Evidence on the Energy Product Omnibus initiative. The present paper builds on EHPAs January 2026 feedback by refining earlier recommendations and introducing additional proposals for consideration.

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.

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).

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).

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.

We consider the LIFE programme to be a very suitable initiative that complements and reinforces the actions of Horizon Europe, as well as Interreg and the Innovation Fund. We find the calls under it to be extremely relevant to the Heat Pump sector and to the energy transition as a whole.