Lobbying by AFECOR - European Control Manufacturers Association

AFECOR - European Control Manufacturers Association

AFECOR

AFECOR is a non-profit Association.

Links

Website Transparency Register Profile

ID: 18638678159-24

Lobbying Activity

Response to Electrification Action Plan

8 Oct 2025

Please read in the document attached the feedback from Afecor ivzw, the European Controls Manufacturers Association.

Read full response

Response to Omnibus Regulation Aligning product legislation with the digital age

8 Aug 2025

Afecor, the European Control Manufacturers Association, broadly supports the Omnibus proposal aimed at amending several directives and regulations concerning digitalization and common specifications. We believe that fully leveraging digital product information can significantly contribute to achieving the EUs goals in sustainability, digitalisation, and competitiveness. However, it is crucial to ensure that simplification efforts do not inadvertently result in additional burdens for manufacturers. Therefore, Afecor proposes the amendments as laid out in the attached file.

Read full response

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Afecor, the European Controls Manufacturer Association, supports the list of net-zero technologies and their critical components. In the heating industry, net-zero technologies and appliances can significantly contribute to an energy-efficient transition and climate neutrality across residential, commercial, and industrial sectors. Afecor welcomes the inclusion of certain heating technologies in the list of net-zero technologies, as well as the primary and specific components used for these technologies. It is crucial that these technologies are considered in the Delegated Regulation on 'primarily used components for the production of net-zero technologies' and the Implementing Act on 'main specific components for the purposes of assessing the contribution to resilience.' Given the diversity of heating appliances, infrastructure, and industrial needs, it is important not to focus solely on a few heating technologies, such as solar thermal and heat pumps. A multi-technology approach is essential to support the European economy in terms of competitiveness, innovation, resilience and independence. Therefore, it is important to also include other heating technologies and their primary and specific components, such as: Hybrid heat pumps with safety controls like hybrid controllers Boilers using renewable fuels such as hydrogen, biomethane, and RDME for residential applications, particularly the H2 conversion kit. Burners using renewable fuels for commercial and industrial applications, where an energy-efficient and stable heat supply is crucial, such as in ceramic production or hospital heat supply. Specific flame sensors and safety controls are primary components here. CHP, combined heat and power We believe that a multi-technology approach in the heating sector, with technologies engineered and produced in Europe, will enhance European competitiveness and resilience, leading to a climate-neutral European economy and society.

Read full response

Response to List of net-zero technology final products and their main specific components

20 Feb 2025

Read full response

Response to Evaluation of the Pressure Equipment Directive (PED) and the Simple Pressure Vessels Directive (SPVD)

20 Jun 2024

AFECOR - The European Control Manufacturers' Association President: Klaus Jesse Vice President: Sabine Pintaske General Secretary: Harald Petermann Creation date: 1963 Members: Manufacturers of controls for gas and oil industries Afecor ivzw. Luchthavenlaan 16, 1800 Vilvoorde, Belgium Transp.-Reg. 18638678159-24

Read full response

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

29 Sept 2023

September 2023- Afecor contribution to the call for evidence on European standardisation- As an active player in the European and International technical committees of standardisation, afecor welcomes this opportunity to share its views on the current EU framework of standardisation. Standards play a key role in delivering the EU targets in the green and digital transition while ensuring public safety by maintaining a high level of quality for the products to be put on the market. Harmonised standards are necessary to support technical legislations, such as for example for Ecodesign and Energy Labelling Regulations or the Gas Appliances Regulation (GAR) as they ensure legal certainty for manufacturers who need to comply with these regulations. While the current European Standardisation System is satisfying on many aspects, like allowing the build-up of a big EU single open market, where innovative, competitive, safe and high-quality level products are freely traded in many different sectors, it needs to be improved when it comes to the length of the process to adopt a harmonised standard. For example, the Ecodesign and Energy Labelling Regulations (EU) No 811 to 814/2013 were published in 2013 and the harmonised standards are still not available. This is also the case for the Gas Appliances Regulation (GAR) 2016/426 that was adopted in 2016. Indeed, standards can take a long time to develop within the European Standardisation Organisations (ESOs), due to the complexity of the overall process , and once they are developed, the harmonisation process by the European Commission takes in many cases an equally long time. To speed up the process, the cooperation between the European Commission and the ESOs should be improved. In the current procedure, the EU Commission is often not consulted after the Standardisation Request is sent until the moment they have to assess the published standards provided by CEN/CENELEC and submitted for approval. By involving the EU Commission at an earlier stage of the process we could anticipate issues in the standards and thus avoid having to restart the whole procedure as it happens when the standard is rejected. Another issue is the uncertainty resulting from the period between the entry into force of a new legislation and the sending of the Standardisation Request (SR) to the ESOs. In the case of the Gas Appliances Regulation (GAR), which was adopted in 2016, the Standardisation Request was sent by EC services to ESOs only in the past few weeks, that is to say seven years after the publication of the Regulation in the Official Journal of the EU. This requirement from GAR to develop a new Standardisation Request went against the background of maintaining harmonization of the relevant standards, a prerequisite for the use of the privilege of "Presumption of Conformity", which was specifically introduced by the legislator to support manufacturers in showing the compliance of their products with EU legislation under the New Legislative Framework. Between 2016 and 2023, the manufacturers could not make use of this privilege due to the lack of technical standards which could be accepted for harmonization, in many cases due to formal non compliances with legal aspects. As a result, higher risks had to be taken into account by EU industry in their process of bringing new products to the market so affecting also their capability to foster innovation and competitiveness. Another important issue is directly linked to the publication of a harmonised standard in the Official Journal of the EU by the EU Commission. In the run-up to the announcement, a qualified analysis and assessment by the Harmonised Standard (HAS) consultant must be carried out. HAS Consultants have the task to assess to which extent the standard published by the ESOs, and candidate to be cited on OJEU as Harmonised Standard, comply with the Commission requests and to which extent they deal with and support releva

Read full response

Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

• Renovation of buildings to improve their energy efficiency is moving very slowly. The major hurdle is to be seen in the investment level that a building owner has to decide for. • In the past building renovation has primarily been understood as an optimization of the building envelope (insulation, windows etc.). These measures are rather costly and building owners will go through a difficult decision process to opt for these measures. If these measures have a reasonable payback period, then at least for commercial buildings such decisions will come easier. That would however only be the case for very inefficient buildings. Public buildings often show the dilemma that there is no budget for an investment in equipment but higher annual operating cost are regularly in the budget and accepted. • Improving the technical building equipment involves a lower cost burden than working on the envelope and it allows also for upgrades in several stages. This is a viable alternative if the improvement of the building envelope is difficult to do. • If there is only a limited budget for building improvement of older buildings, it is required to have affordable solutions to still achieve efficiency gains. A measure that marks a first step in building renovation / efficiency improvement is to upgrade or replace the heat generator, which in many cases is rather old and does not have the efficiency one would expect to achieve today. The cost to do this is in the lower range of the spectrum of all possible measures. • Heat pumps are an efficient space heater solution, but they have limitations for old buildings with poor insulation, because they require higher operating temperatures for the heating system. • Upgrading existing residential heating systems by going to condensing boiler solutions. Even better is to install hybrid systems including a heat pump for transitional periods and a boiler for lower outside temperatures. This works also for older buildings. • For rental property legislative measures are required so that the building owner cannot just levy high energy cost on the tenants. • For a stronger push to renovate buildings it would need funding support.

Read full response

Response to A EU hydrogen strategy

7 Jun 2020

General • Afecor is the European controls manufacturers association in the field of heat generation. Afecor strongly supports the initiative to develop a EU hydrogen strategy, because hydrogen is to be seen as a key element to reach climate neutrality in the future. • A hydrogen strategy being drafted and implemented as a EU wide approach helps several sectors to create a level playing field. • For an immediate start it would be beneficial to conditionally allocate some of the Covid19 recovery funds to projects which follow the implementation roadmap introducing new technologies in the field of hydrogen. • Hydrogen is an energy carrier which can be stored and transmitted as well being used as a fuel either in 100% concentration or admixtures with natural gas for transport or heat generation, thereby reducing carbon emissions. Application fields • Hydrogen can play a significant role in three gas using application sectors and the power generation sector. o Industry: Energy intensive industries (e.g. steel production) have the potential to reduce their carbon footprint massively. o Transport: Hydrogen has the highest energy density per weight and when used in pressurized tanks it can be used as a fuel for the transport sector. o Buildings: Hydrogen can also be used for the gas utilization sector when injected into the gas grid. Even low admixture percentages provide an immediate improvement of the CO2 emissions and injection can be decentralized. o Renewable power generation can also benefit if hydrogen is being produced using excess renewable electricity to produce hydrogen, which would eliminate idling wind parks. It is another way to contribute to balancing the grid, since also gas turbines can run on these admixtures and recover energy stored in the grid. • It appears that the three application sectors industry, transport and heat generation will need prioritized allocation of hydrogen, but this is not entirely the case. Industrial processes have a defined high and uninterrupted demand and cannot tolerate fluctuations. Transport needs a vast infrastructure and also large volumes of hydrogen. Domestic gas utilization can start with small amounts of hydrogen as admixtures to natural gas. • The challenges for the application sectors are different and come with different time frames. Hence there is not so much a real competition for available hydrogen resources, but rather changing priorities during the introduction phase. The high volume of pure hydrogen for industry and transport and the required infrastructure may take some time to be established, while hydrogen admixtures in the gas grid can start from zero and there is also tolerance for fluctuations in conjunction with general purpose gas utilization. The way forward for products using hydrogen • Hydrogen is being used since a long time. It has also been a major component in the composition of town gas/manufactured gas, which was widely used in gas grids several decades ago and is still used in some places globally. There is existing experience available for admixture up to less than 60% of hydrogen and some products are certified to be used with such gas types. • Advancing the supply of hydrogen via the gas grid to higher content values up to 100% hydrogen requires additional safety assessments and standardization activities, which have been started or will be started shortly as part of a draft standardization request. • The injection of hydrogen in the gas grid up to 20% is likely feasible without changes to products, so this can be a first goal leading already to 7% CO2 reduction • The experience gained during tests using pure hydrogen will help to develop future products, e.g. reliable/ low maintenance fuel cells.

Read full response

Response to Strategy for smart sector integration

7 Jun 2020

• A strong focus on electricity and efforts made have led to significant progress in decarbonizing power generation by increasing the share of renewable energy sources. Taking the perspective into account, technical solutions based on this energy carrier have been rolled out. • Further increase of the share of renewables in power generation comes with challenges that need to be managed. The renewable electricity has large fluctuations which need to be controlled or balanced. The current electricity grid is in many regions close to the limit of its capacity. Further extension of the grid is increasingly difficult and cannot be achieved within the next years/decades to an extent that might be required. • There are additional issues coming with the large scale use of certain technologies. For example, if an urban area would see a high percentage of electrical vehicles, then providing a sufficient charging infrastructure within an existing older building stock environment is very difficult to reach. Take for instance an eight families house without an existing private parking structure and only two parking spaces in front of the house, how shall all the vehicles be charged simultaneously (overnight)? This becomes an issue of managing supply capacity but also of available space for charging. • A large scale deployment of a solution that is built to rely exclusively on a single energy carrier may involve feasibility limits. A better way is to use a wider approach involving different energy carriers concurrently, driving decarbonization for all of them, which makes it possible to reach the climate goals earlier. • Additional benefits become available by managing energy capacity across carriers, for example by means of the Power-to-X solutions converting energy from one carrier to another and back. Energy supply and demand should also be managed across sectors. • Solutions in the individual sectors which benefit from an integrated approach are : - Transport: fuel cells and e-mobility - Industry: hydrogen for process heat - Building: heating solutions using renewable fuels (admixture of hydrogen to gas, e-fuels) / hybrid systems • Fluctuations and changing availability of the energy carriers require smart management of supply and demand. The smart sector integration of this roadmap can help to use energy efficiently but should also keep a level of flexibility to be able to manage flow and consumption of energy. • In this context the upcoming EU strategy on hydrogen and the renovation wave initiative are complementary measures for this approach. • Afecor is the European controls manufacturers association in the field of heat generation. Afecor strongly supports the Commission initiative to develop an EU Smart Sector Integration Strategy, because to achieve the decarbonization goals coordination between all sectors is essential.

Read full response