Eurovent

The HVACR industry is increasingly engaged in the circular economy. While we are overall in favour of the increased importance of circular economy, we do want the Commission to be aware of several possible hurdles: - There is a lack of clarity with the definitions, concepts and standards used. - There is need for further harmonisation that will benefit the Single Market.

Eurovent supports the further reliance on renewable energies. While outlining the future Renewable Energy Directive (RED) the implementation of the National Energy and Climate Plans (NECPs) of the member must be assessed to check if the national 2020 renewable energy targets have been achieved.

The Taxonomy Climate Delegated Act recognises that the manufacture of energy efficient HVACR equipment is a sustainable activity that contributes to climate change mitigation. However, many HVACR products do not have Substantial Contribution Criteria because not covered by an EU Energy Labelling measure.

Eurovent, the European Industry Association for Indoor Climate, Process Cooling, and Food Cold Chain Technologies, is grateful for the opportunity to submit feedback on the proposal for a recast Energy Performance of Buildings Directive. The proposal is positive overall. It ups the ambition level and seeks to address many of the shortcomings of the current Directive.

Eurovent strongly supports policy option 3 to inscribe the ambition of the Renovation Wave initiative into legislation. The review should also focus on mainstreaming indoor environmental quality (IEQ) considerations into the Directive, for which a dedicated stakeholder workshop on IEQ should be convened.

Eurovent appreciates the recognition by the Commission of the proliferation of green claims and the related measurement and assessment methods. National legislation regarding green claims exists, supported in cases by the fact that some Member States recognize specific voluntary labels. This proliferation confuses consumers and industry due to the various methods use to substantiate the claims.

Eurovent supports the Ecodesign Regulation for Sustainable Products proposal. Product sustainability must be addressed in harmonised way across the EU to ensure the free movement of products within the Single Market. For the new Ecodesign framework to be as successful as possible while stimulating innovation and preserving the competitiveness of European industry, Eurovent makes the following recommendations: 1.

The Sustainable Products Initiative builds upon Circular Economy Action Plan and intends to extend the scope of the Ecodesign Directive. While not addressing directly the policy objective, the revision Methodology of Ecodesign of Energy Related Products (MEErP) is paving the way for the Sustainable Products Initiative and the Circular Economy by considering the inclusion of material efficiency and ecological profile…

Eurovent supports the energy efficiency (EE) first principle. While outlining the future EE requirements the implementation of the National Energy and Climate Plans (NECPs) of the member must be assessed and enforcement of the NECPs be strengthened so that the EED may reach its targets. EE in the building sector can provide a major share of EE but health and cost aspects should be borne in mind.

Eurovent is the voice of the European Heating, Ventilation, Air Conditioning and Refrigeration (HVACR) industry. This paper outlines Eurovents position on the extension of CBAM to downstream products, insofar as it may include HVACR equipment.

The Taxonomy Climate Delegated Act recognises that the manufacture of energy efficient HVACR equipment is a sustainable activity that contributes to climate change mitigation. However, many HVACR products do not have Substantial Contribution Criteria because not covered by an EU Energy Labelling measure.

Eurovent Position Paper Team member [name removed] PP — 2022-06-28 Phone [phone removed] Email [email removed] Date 2022-06-28 Eurovent comments on the European Commission proposal for a revised F-Gas Regulation — 2022-0099(COD) In a nutshell With this paper Eurovent provides its position on the European Commission proposal for a revised F-Gas Regulation, in view of the ongoing public consultation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurovent is committed to the success of the F-Gas Regulation and appreciates the opportunity to submit feedback on its improvement. The review of the F-Gas Regulation should focus on avoiding circumvention, removing barriers to flammable and reclaimed refrigerants, and retrofitting existing equipment, without compromising energy efficiency, reliability, and safety.

Eurovent is the European association for indoor climate, process cooling and cold chain technologies. We call on the EU to address the distinct challenges and opportunities related to sustainable cooling in the upcoming EU Heating and Cooling Strategy, to ensure Europe is prepared for a future marked by rising temperatures and a growing demand for cooling.

Eurovent holds that gap between the AAQ Directives and the WHO guidelines on PM2.5 must be closed, that air quality data must be disseminated to the public more effectively, and that ambient air quality legislation must be complemented with policies addressing indoor air pollution as well. More information in the document attached.

Eurovent supports the EU data centre rating scheme, welcomes its simplification and technology-neutral approach, and calls for a revised WUE scale to better reflect regional conditions and energywater trade-offs. Please refer to the complete position in the attachment.

Eurovent supports the Commission Omnibus proposals aimed at promoting digital-by-default practices. On the other hand, we are deeply concerned by the introduction of common specifications. We welcome the principle digital by default proposed by the Commission.

Eurovent has already provided the EC with its comments on the review of the Commission Regulations (EU) 206/2012 and (EU) 626/2011 with a set of Position Papers. The comments remain. Eurovent would like to reiterate and reinforce its positions as already presented in its past Position Papers, the below (non-exhaustive) list summarises them (we recommend to carefully re-assess our past position papers).

Eurovent has already provided the EC with its comments on the review of the Commission Regulations (EU) 206/2012 and (EU) 626/2011 with a set of Position Papers. The comments remain. Eurovent would like to reiterate and reinforce its positions as already presented in its past Position Papers, the below (non-exhaustive) list summarises them (we recommend to carefully re-assess our past position papers): Single and…

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.

We call on the European Commission to maintain the scope of the upcoming ESPR Delegated Act to iron and steel intermediate products as set out in the ESPR Working Plan and to refrain from extending Digital Product Passport (DPP) obligations to final products containing iron or steel at this stage.

Eurovent supports the Commission Omnibus proposal, which aims at simpler and more effective rules for complying with the energy label delivery and display. We welcome efforts for a simpler registration in the EPREL database and improved filters. Furthermore, we would favour a swift conclusion to the ongoing reviews of Ecodesign and Energy Labelling legislation.

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…

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.

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…

Having reference on the Call for evidence on Energy labelling requirements for local space heaters (review) and following the Consultation Forum for the revision of the Energy Labelling Regulation on air-to-air conditioners and heat pumps, local space heaters and comfort fans, held by DG ENERGY on 24 June 2022, please find enclosed the Eurovent position.

Eurovent with the attached paper provides some input to the public Call for Evidence on the revision of the lot 21. The paper in particular focuses on: - The importance of the new F-Gas regulation for the future development of the units - Eurovent proposal for A/A process and IT cooling - Eurovent proposal for VHT process chillers - Current landscape of free cooling - Heat recovery and simultaneous heating and…

With the enclosed Position Paper, Eurovent would like to provide the European Commission with its comments on the draft Commission Delegated Regulation (EU) amending, inter alia, the Delegated Regulation (EU) No 2019/2018, the Delegated Regulation (EU) No. 2019/2015, and the Regulation (EU) No 2019/2020.

Eurovent has recently received the results of the market analysis based on sales for 2023-2024 and is currently evaluating them. Therefore, detailed feedback and comments will be presented as soon as possible, together with an appropriate analysis of the EPREL results. The feedback prepared after the first stakeholder meeting on 20 March 2025 (PP-2025-04-16) is published in the attachment.