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pas disposé à partager

Company · France

3
positions filed
in the 326 files tracked
1
legislative file
of 326 tracked
0
with a full position paper
attached to a submission

Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.

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Their record over time

pas disposé à partager filed 3 positions on 5 Dec 2025, across 1 of the 326 legislative files tracked here.

What they argued

Energy labelling requirements for space and combination heaters (review/rescaling)filed 5 Dec 2025source

1/3 for the attention of Mr Robert Nuij, Head of the Buildings and Products Unit, DG Energy We are a small SME importer of liquid and gaseous fuel boilers and soon hybrid systems. Our products are tested in accredited laboratories, often outside the European Union, and we have invested for many years to comply with existing rules on energy decodesign and labelling.

Filed in French · English published by the European Commission

Energy labelling requirements for space and combination heaters (review/rescaling)filed 5 Dec 2025source

2/3. We therefore ask very clearly: * Since 2013, how many national authorities have actually taken legal action against manufacturers for failure to comply with the rules on the efficiency of heat generators or water heaters? * How many final judgments per Member State found significant non-compliance of the declared values?

Filed in French · English published by the European Commission

Energy labelling requirements for space and combination heaters (review/rescaling)filed 5 Dec 2025source

3/3. On NOx, the project retains a tolerance of 20 %. The limits for liquid fuels remain almost unchanged after more than 10 years. Given the importance of NOx for health and air quality, it is difficult to understand why: * the limits have not been tightened, * the tolerance remains at 20 %. Maintaining wide limits on NOx while complicating the rules on energy efficiency gives a confusing signal.

Filed in French · English published by the European Commission

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