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.

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 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 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 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 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.

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.

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.

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…

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…

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.