HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V.

The energy consumption of professional kitchens is one of the largest energy consumers in restaurants, hotels or even office buildings. Technically, there is potential for improvement. However, these are poorly implemented as the industry and developments are misunderstood. A proactive cooperation with policymaker would be better than an intervention against the industry.

In general, HKI supports the Ecodesign instrument which already delivered for EU consumers, industry and the planet by taking due consideration of all aspects of the life cycle of the product, setting measurable and enforceable requirements and based on the proportionality principle. It is the impetus to develop standardized methods that enable appliances and machines to be better compared.

The HKI supports a systemic and technology-neutral approach to the post-2030 renewable energy framework for buildings. Hybrid heating systems, combining electrification with sustainable biomass, represent a cost-effective and resilient pathway for decarbonisation. In this context, ensuring a stable and sustainable supply of biomass, as well as flexible and proportionate regulatory frameworks, is essential.

The European building sector faces significant challenges in decarbonising heating and hot water supply while ensuring security of energy supply. Our position highlights the role of electric and hybrid heating systems, including modern wood-fired local space heaters, in reducing fossil fuel dependency, lowering CO emissions, and supporting regional economic development.

The German HKI industry association represents the interests of more than 110 manufacturers of domestic heating and cooking appliances. As such, it strongly supports the goals of sustainable and, as far as possible, CO2-neutral heat generation and improved air quality. The development and manufacture of efficient and clean products is a constant concern for our members.

In general, our industry supports the setting of air quality standards to prevent the build-up of excessive concentrations of pollutants. Clean air is important for human health and the environment. However, it should be noted that the WHO recommendations on which the revision of the Air Quality Directive is based focus only on health impacts, leaving out impacts on economic factors, etc.

The Industrial Association HKI sees the greatest potential for improving air quality in overcoming the blockade when replacing old appliances with more effective, combined biomass central and individual room heating. The announced Renovation Wave should, among other things, also target precisely there. Modernisation through innovative technology reduces particulate matter emissions by up to 90 percent.

Please find attached our position paper concerning the digital provision of product-related information under Regulation (EU) No 305/2011 (Construction Products Regulation). While we fully support the Commissions initiative to promote digital formats through the Omnibus IV package, we believe that similar progress is urgently needed for products still covered by the old CPR including, for example, individual room…

In the attached position paper, HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V. sets out its views on the revision of Regulation (EU) 2019/1020. From an industry perspective, effective market surveillance is a key element of the internal market, but can only function properly as part of a coherent and consistent product law framework.

HKI welcomes the European Commission's efforts to simplify energy labelling requirements and reduce administrative burdens. Our main concern is that digitalisation must lead to genuine simplification rather than creating additional obligations.

HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V. has submitted a detailed position paper as an attached PDF. The document outlines our assessment and recommendations regarding the announced Energy Products Omnibus. In summary, HKI supports the objective of simplifying and improving the coherence of EU product legislation for energy-related products.

Generally energy labelling is supported by our industry as a good opportunity to inform the customer and help him or her to choose the appropriate product for his/her purpose. But there is the need of a clear differentiation between good and less good products in a certain product range.