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Association of the European Heating Industry

EHI

The Association of the European Heating Industry represents 36 companies and 12 associations producing heating technologies including boilers, heat pumps, and renewable systems.

Lobbying Activity

Meeting with Peter Liese (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

8 Jan 2026 · Austausch

EHI urges realistic EU waste targets for heating systems

6 Nov 2025
Topic — The Commission is consulting on rules to boost the European circular economy.
Message — EHI requests simplified regulations and waste collection targets tailored to products with long lifespans. They advocate for shared responsibility among consumers, retailers, and recyclers to manage waste.12
Why — The industry would benefit from lower waste collection targets and reduced administrative complexity.3
Impact — Unregulated private collectors would lose market share if forced to report waste and follow standards.4
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European heating industry urges harmonized digital rules for appliances

4 Nov 2025
Topic — New EU strategy to integrate artificial intelligence and digital tools into energy systems.
Message — The industry calls for heating to be a core component of the digital energy ecosystem. They advocate for harmonized EU rules to avoid fragmented national requirements that increase costs. They also urge the Commission to refrain from overburdening manufacturers with unnecessary data provision.123
Why — Harmonized rules would lower manufacturing expenses and prevent new costs from data reporting regulations.45
Impact — National authorities lose the power to set local technical requirements for their energy grids.6
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European Heating Industry Urges Harmonized Building Carbon Standards

31 Oct 2025
Topic — A framework for calculating the life-cycle global warming potential of new buildings.
Message — EHI requests a harmonized EU methodology for heating appliances under ecodesign regulations. They propose using both EN 15804 and EN 50 693 standards during the transition. Additionally, they suggest allowing data extrapolation within product families to simplify compliance.123
Why — Unified standards would lower administrative costs and prevent market fragmentation across Member States.4
Impact — National authorities would lose the ability to mandate specific local environmental impact categories.56
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European Heating Industry Urges Multi-Technology Path to Decarbonization

9 Oct 2025
Topic — Action plan addressing barriers to increasing electricity demand to achieve EU climate targets.
Message — The organization advocates for a multi-technology approach including heat pumps and renewable gas solutions. They urge the Commission to maintain legislative stability and reduce administrative burdens for manufacturers.12
Why — These measures would protect existing industrial investments and lower the costs of regulatory compliance.34
Impact — Non-EU manufacturers would face tougher market entry due to stricter surveillance and carbon taxes.5
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European Heating Industry Urges Policy Support to Boost Demand

9 Oct 2025
Topic — The EU initiative focuses on accelerating the decarbonisation of industrial and residential heating.
Message — The association calls for stable financial incentives and rejects potential technology bans. They recommend reducing red tape and cutting electricity prices to encourage appliance sales. They also advocate for a variety of renewable technologies to decarbonize European buildings.123
Why — Stable policies and lower administrative requirements would reduce compliance costs and increase sales.45
Impact — International companies exporting non-compliant heating products would face tougher market surveillance and enforcement.6
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European heating industry backs 90% target but demands stability

16 Sept 2025
Topic — This consultation concerns amending the European Climate Law to include 2040 targets.
Message — The association supports a 90% reduction target but warns against legislative changes. They advocate for a technology-neutral approach including heat pumps and renewable fuels.123
Why — Predictability would allow the sector to scale up manufacturing and innovation profitably.45
Impact — Inconsistent policies risk delaying the transition and undermining the EU's climate targets.67
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European heating industry urges multi-technology approach to global decarbonisation

10 Sept 2025
Topic — A proposal defining the European Union's global climate and energy strategy through 2029.
Message — The industry advocates for a multi-technology approach to decarbonization instead of focusing solely on electrification. They recommend replacing old systems first and providing stable financial support to households. They also urge policymakers to refrain from technology bans.12
Why — A technology-neutral approach allows members to continue selling diverse heating product ranges globally.3
Impact — Consumers face higher costs and slower decarbonisation if trade tariffs are introduced.4
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Heating Industry Urges CBAM Extension with Simplified Compliance Rules

26 Aug 2025
Topic — The consultation examines extending the carbon border adjustment mechanism to downstream industrial products.
Message — The group supports including heating products in CBAM to ensure fair competition. They request the use of default values and exemptions for specific net-zero components to reduce complexity.123
Why — Local producers would gain protection against cheaper, carbon-intensive imports from countries with laxer rules.45
Impact — Foreign exporters would lose their competitive edge by no longer avoiding European carbon costs.6
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Response to Quality Jobs Roadmap

29 Jul 2025

The present document contains input from the association of the European Heating Industry (EHI) to the call for evidence on the Quality Jobs Roadmap. EHI represents 90% of the European market for heat and hot water generation, heating controls and heat emitters, 75% of the hydronic heat pump market, 80% of the biomass central heating market (pellets, wood) and 70% of the solar thermal market. EHI Members employ about 120,000 people in Europe, including installers. However, we estimate that in order to reach the REPowerEU targets to achieve 10 million heat pumps installed by 2030, 750.000 additionnal installers will be needed. As an industry, we are committed to providing training for the additionnal installers needed. Moreover, our member companies are continuously innovating to ease the installation of heating systems and are developping digital tools to support the work of the installer. In addition, the Quality Jobs Roadmap has the potential to increase the attractivity of the profession, which will contribute to increasing the amount of trained installers, and ultimately to reach the EU climate targets. In particular, we are convinced that a lot can be done during the training phase in order to improve the overall quality of the profession: Providing financial support along the entire training process for existing installers that want to re-skill and up-skill: o 1) To face the upfront cost of training (e.g. through direct financial support at national or local level for training centers to provide free trainings; or through a credit system like the French compte personnel de formation); o 2) And to maintain a revenue during the training period (through financial support at EU or national level) Providing continuing education programs for professors and trainers will ensure the provision of effective and up-to-date learning material; Providing resources (e.g. in the form of subsidies) for training centers to develop hybrid training (i.e. training that would include phases of e-learning) and create an environment of continuous learning will allow installers to acquire some of the digital skills they will increasingly need to master. In this perspective, the different age profiles (e.g. students and young newcomers and/or experienced installers) and related pre-existing digital skills should be taken into account and addressed when establishing training programmes. Including language classes in training will ease cross EU mobility and facilitate integration for installers working outside of their country of origin. We also recommend that: Organisations, agencies and authorities working on environmental policy on one side and those working on labour markets and skills policy on the other side should establish a close collaboration. In the general education system, young people should benefit exposure to technical energy pathways and careers and manual subjects, well before they enter secondary schools and universities; More details are to be found in our 2022 report Heating Systems Installers: Expanding and upskilling the workforce to deliver the energy transition , as well as in the 2024 position paper from the Renewable Energy skills Partnership.
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Response to Energy labelling of low temperature heat emitters

29 Jul 2025

This document contains comments from the association of the European Heating Industry (EHI) to the call for evidence on energy labelling for low temperature heat emitters. You will find more details on our position in the documents attached, i.e. our comments to the preparatory study conducted by VHK, as well as our technology paper on heat emitters, published in May 2025. EHI represents 90% of the European market for heat and hot water generation, heating controls and heat emitters. Energy labelling is not the right legislative tool Heat emitters are part of a broader heating system, and do not consume energy on their own. As such, it is impossible to assess their performance without taking into account all the elements of the heating system, including the heat generator, the presence and functionality of controls, how all these elements interact and how the system is balanced. With this context in mind, we acknowledge that heat emitters are often not considered in the energy transition, despite their importance in improving the efficiency of a heating system. As such, we agree that there is a need to raise more awareness about their role in the energy transition, and that one of the ways of achieving this, is via policy. However, considering that ecodesign and energy labelling are limited to the product rather than the system, we are not convinced it is the right legislative tool. Instead, the implementation of the recast Energy Performance of Buildings Directive (EPBD) , which regulates the technical building systems as part of the building's overall energy performance, should highlight the importance of heat emitters. Indeed, the new legislative framework includes a few recommendations going into that direction. For instance, it introduces in the Energy Performance Certificates and inspection protocols, an assessment of the feasibility of heating systems to operate at more efficient temperature settings, such as low temperature emitters for water based heating systems. More generally, the revised EPBD foresees the thermal renovation of the existing building stock by 2050 and mandates that all new buildings are zero-emission buildings by 2030. This will expedite the rate of renovation and enhance the overall energy efficiency of buildings in Europe. From that perspective, the role of heat emitters will be essential to optimise the energy consumption of heating systems operating at low temperatures, as foreseen by the EPBD. In addition, municipalities upcoming heating and cooling plans as part of the Energy Efficiency Directive and the Heating and Cooling Strategy, announced by the European Commission and planned for Q1 2026, should also provide the right framework for policy measures that consider the heating system, including the emitters. Need for equal conditions and opportunities for all types of emitters The most common types of heat emitters are radiators (including convection radiators) and underfloor heating systems. Since all emitter types can function at low temperatures under the right conditions, they are in direct competition with one another. Therefore, if an energy label were to apply to heat emitters, it should create equal conditions and opportunities for all types of emitters. Need for support to the demand side We would like to highlight the need to act on the demand side, among others by providing financial support for the replacement of heat emitters. Indeed, existing incentive schemes tend to focus only on the heat generator rather than the entire heating system, leading households to neglect replacing their heat emitters. And even when incentive schemes do target heat emitters, they are often unstable and complex, resulting in consumers to adopt a wait-and-see attitude. Instead, stable and long-term incentives that also cover the emitters, are the key in providing households the confidence and certainty to replace their old and inefficient systems.
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Heating industry urges alignment of raw material and waste rules

25 Jul 2025
Topic — Commission list of products and waste streams with critical raw material recovery potential.
Message — The industry recommends merging the product list into the existing WEEE Directive. This avoids overlapping regulations and uses established national collection systems. It prevents unnecessary administrative duplication for manufacturers and national governments.12
Why — This would reduce administrative costs and prevent a doubling of compliance requirements.3
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Response to Revision of the Standardisation Regulation

18 Jul 2025

As an active participant in European and International standardisation technical committees and the High Level Forum on Standardisation, the European Heating Industry (EHI) welcomes the opportunity to share its views on the forthcoming revision of the EU standardisation framework. Standards play a key role in supporting the EUs green and digital transitions while ensuring public safety by maintaining a high level of quality for the products to be put on the market. We think that practical and easy-to-implement solutions can be implemented to accelerate the adoption of harmonised standards. Standardisation process should remain consensus-driven and inclusive; common specifications, developed directly by the European Commission without the involvement of standardisation organisations and relevant stakeholders, would create a risk of bypassing the transparency, technical expertise, and industry engagement that give harmonised standards their legitimacy and broad acceptance. For more details about our proposals, please read our position paper attached.
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European heating industry seeks exemption from product destruction reporting

9 Jul 2025
Topic — New rules requiring companies to disclose data on the disposal of unsold products.
Message — The association requests the removal of boilers, heat pumps, and water heaters from the reporting list. They argue these are professional equipment, not consumer goods, and are rarely destroyed.123
Why — Manufacturers would avoid significant administrative costs and reporting obligations for high-value appliances.45
Impact — Environmental groups lose transparency regarding the waste and disposal of large industrial systems.67
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European heating industry urges multi-technology industrial decarbonisation

8 Jul 2025
Topic — This initiative aims to accelerate industrial decarbonisation and boost Europe's global competitiveness.
Message — EHI advocates for a multi-technology approach instead of single-technology mandates. They support non-price procurement criteria but firmly reject additional carbon labels.12
Why — Allowing diverse technologies secures demand for their members' broad heating product portfolios.3
Impact — Climate transparency advocates lose standardized data if proposed carbon labels are scrapped.4
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Response to European Affordable Housing Plan

3 Jun 2025

Introduction The European Heating Industry (EHI), representing leading manufacturers, delivers up to 90% of the European market for hydronic heating technologies. Heating accounts for 80% of energy consumption in buildings across Europe and constitutes 3-13% of total consumer expenditure. Affordable heating, therefore, has a significant impact on housing affordability and should be a crucial consideration in the European Affordable Housing Plan. Given heatings substantial share of energy use in buildings, decarbonising this sector is essential to achieving broader climate goals. However, transitioning to more efficient and renewable heating technologies often imposes financial burdens, increasing upfront costs for appliances and fuels. To ensure affordability for consumers during this transition, EHI proposes several recommendations for policymakers: 1. Ensuring Stable and Long-Term Financial Support The high upfront costs of future proof heating systems remain a significant barrier, particularly for low-income households. To address this, governments must provide predictable, straightforward, and targeted incentive schemes for vulnerable groups. EHI calls for: The European Commission to offer Member States a toolbox outlining optimal national incentive structures, durations, and strategies for targeting specific households effectively. Integration of support schemes into "One-Stop Shops" under the Energy Performance of Buildings Directive (EPBD) to streamline access to financial resources for consumers, SMEs, and stakeholders. 2. Reducing the Operating Costs of Clean Heating Technologies Policies must ensure that consumers investing in efficient heating systems experience lower energy bills. Suggested measures include: Implementing the Emissions Trading System for buildings and transport (ETS2), with revenues reinvested into building decarbonisation while protecting vulnerable households via the Social Climate Fund. Allowing Member States to frontload ETS2 revenues for targeted financial measures to start building and renovation measures. Promoting dynamic pricing and time-of-use tariffs for heat pumps, which lower costs and emissions by shifting consumption to off-peak hours. Ensuring National Regulatory Authorities (NRAs) monitor tariffs transparently, while mitigating potential electricity network tariff increases. Revising the Energy Taxation Directive to establish minimum taxation on renewable fuels and electricity. Avoiding cost-shifting from electricity to gas bills, which disproportionately affects energy-poor consumers. Public budgets should help absorb the costs related to the electricity grid. 3. Harmonising EU-Wide Rules for Heating Appliances Fragmented national regulations on appliance design, testing, and certification raise costs and hinder heat pump adoption. EHI advocates for harmonised EU legislation, standardisation, and certification to achieve economies of scale and lower prices. Specifically: Heat pump requirements ensuring their integration onto the grid should be set at EU-level within the Ecodesign framework to ensure technical feasibility and cost-effectiveness, accompanied by CE conformity marking. Incentive schemes should align with EU legislation to reduce redundant testing for energy and resource efficiency and streamline mutual understanding of conditions related to the Net Zero Industry Act. 4. Supporting a Multi-Technology Approach While electrification, through heat pumps, is commonly associated with decarbonising heating, EHI stresses that electrification should not be the sole focus. Decarbonisation, broadly, is the ultimate goal, and there are various approaches to achieving it. The industry offers diverse products compatible with renewable fuels, hybrid systems, and heating technologies. Varying assumptions in studies about the costs of decarbonisation lead to different results and it is thus important to keep technology options open.
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Meeting with Yannis Maniatis (Member of the European Parliament)

23 Apr 2025 · Introductory Meeting

Response to Technical description of important and critical products with digital elements

18 Apr 2025

Dear Sir/Madam, Please find attached the recommendations of the European Heating Industry (EHI) on the draft Implementing Act on technical descriptions of the categories of important and critical products with digital elements listed in Annex III and IV of the Cyber Resilience Act. At EHI, we bring together European heating market leaders Ariston, BDR Thermea, Bosch, Groupe Atlantic, Vaillant, Viessmann, just to mention a few and connect our members market knowledge and technological expertise with European policymakers. Our members represent up to 90% of European market for technologies ranging from heat pumps to boilers, from solar thermal systems to fuel cells, and radiators to underfloor heating, smart controls and home energy management systems. These technologies are tailored to the EUs diverse buildings and climates, playing a crucial role in decarbonising the EUs building stock.
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Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen), Martin Engell-Rossen (Cabinet of Commissioner Dan Jørgensen)

16 Apr 2025 · Heating efficiency and decarbonisation

Response to Ecodesign requirements for circulators (review)

11 Apr 2025

The attached document contains comments from the association of the European Heating Industry (EHI) to the call for evidence in view of reviewing ecodesign requirements for circulators. About EHI, the Association of the European Heating Industry : EHI represents 90% of the European market for heat and hot water generation, heating controls and heat emitters, 75% of the hydronic heat pump market, 80% of the biomass central heating market (pellets, wood) and 70% of the solar thermal market. EHI Members produce advanced technologies for heating in buildings, including: heating systems, burners, boilers, heat pumps, components and system integrators, radiators, surface heating & cooling and renewable energy systems. In doing so, they employ about 120,000 people in Europe and invest over a billion Euros per year in energy efficiency.
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Meeting with Niels Ladefoged (null Energy)

18 Mar 2025 · Technology tour on the stands of EHI member companies.

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

20 Feb 2025

The European Heating Industry welcomes the inclusion of some heating technologies in the list of net-zero technologies as well as the specific components used for those technologies. In particular it is important that solar thermal and heat pumps as final products are identified in the Implementing Regulation on main specific components for the purposes of the assessment of the contribution to resilience. While the list of components of solar thermal technologies seems quite comprehensive - including solar thermal collectors (e.g. flat-plates, evacuated tubes, concentrating systems and air collectors), solar thermal absorbers, solar glass and solar thermal trackers - the list of components of heat pumps is too limited as it covers only four-way valves and scroll compressors. According to our internal survey, other components such as the compressor, condenser, evaporator, refrigerant piping, fans, and the expansion valve stepper (for the outdoor unit) should be in the list. These above-mentioned components fulfil the criteria of the Net Zero Industry Act: they are specific, commercially available, and necessary to the heat pump technology. In addition, heat pumps could also be hybrid and thermally driven, therefore components of these types of heat pumps should also be included in the list. For hybrid-ready heat pumps, the hybrid heating controller and or energy manager are key components, with an important European know-how. For thermally driven heat pumps, depending on the type, key components include the burner, generator, absorber, condenser, adsorption bed, sorption heat exchanger, condenser, the sub cooler, and fans. Hydrogen heating technologies are also missing from the list of hydrogen technologies, with the exception of fuel cells. Heating manufacturers are at the forefront of the hydrogen applications in buildings, with more than 100 projects running in Europe today, and have developed appliances that can run 100% on hydrogen. These are gas appliances that are either dedicated to work with 100% hydrogen or appliances that are installed as normal gas appliances but can operate safely and efficiently using 100% hydrogen following the installation of boiler specific conversion kit. We believe these dedicated hydrogen boilers and hydrogen conversion kits are a specific components that should be on the list; alternatively, the parts composing the conversion kit, could be considered as specific components as they have been specifically designed to run on pure hydrogen. These would be: the burner, ignition system, flame detector, ventilation system, and the valve. Last but not least, hot water storage should be mentioned in the list of energy storage technologies as final product. Indeed, they can help reduce energy consumption and be combined to the above-mentioned technologies such as solar thermal and heat pumps. Attached you can find our full position paper on both the Delegated and Implementing Acts for primarily used components and main specific components.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

The European Heating Industry (EHI) welcomes the inclusion of some heating technologies in the list of net-zero technologies, as well as the specific components used for those technologies. It is important that final products such as solar thermal systems and heat pumps are taken into account by the Delegated Regulation on primarily used components for the production of net zero technologies. While the list of components of solar thermal technologies seems quite comprehensive - including solar thermal collectors (e.g. flat-plates, evacuated tubes, concentrating systems and air collectors), solar thermal absorbers, solar glass and solar thermal trackers - the list of components of heat pumps is too limited as it covers only four-way valves and scroll compressors. According to our internal survey, other components such as the compressor, condenser, evaporator, inverter, refrigerant piping, fans, three-way valve, and the expansion valve stepper (for the outdoor unit) should be in the list. These above-mentioned components fulfil the criteria of the Net Zero Industry Act: they are specific, commercially available, primarily used and essential. In addition, heat pumps could also be hybrid and thermally driven, therefore components of these types of heat pumps should also be included in the list. For hybrid heat pumps, the hybrid heating controller and or energy manager are key components, with an important European know-how. For thermally driven heat pumps, depending on the type, key components include the burner, generator, absorber, condenser, adsorption bed, sorption heat exchanger, condenser, the sub cooler, and fans. Hydrogen heating technologies are also missing from the list of hydrogen technologies, with the exception of fuel cells. Heating manufacturers are at the forefront of the hydrogen applications in buildings, with more than 100 projects running in Europe today, and have developed appliances that can run 100% on hydrogen. These are gas appliances that are either dedicated to work with 100% hydrogen or appliances that are installed as normal gas appliances but can operate safely and efficiently using 100% hydrogen following the installation of a boiler specific conversion kit. We believe these dedicated hydrogen boilers and hydrogen conversion kits are a specific components that should be on the list; alternatively, the parts composing the conversion kit, could be considered as specific components as they have been specifically designed to run on pure hydrogen. These would be: the burner, ignition system, flame detector, ventilation system, and the valve. Attached you can find our full position paper on both the Delegated and Implementing Acts for primarily used components and main specific component.
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EHI warns short lead exemption timelines threaten industry supply

10 Feb 2025
Topic — EU consultation on lead use exemptions in steel, aluminium, and copper.
Message — The association calls for extending exemption expiry dates to at least two years after publication. They argue against splitting exemptions into sub-categories, which adds unnecessary administrative burdens. They also oppose new footnotes restricting lead release from consumer products.12
Why — Longer timelines would prevent compliance backlogs and ensure technical continuity for manufacturers.34
Impact — Consumers could lose access to electronic products due to immediate market bans.5
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Heating industry urges longer RoHS lead exemption timelines

10 Feb 2025
Topic — Consultation on renewing hazardous substance exemptions for lead in electronic components.
Message — The association requests extending expiry dates to at least two years after official publication for existing exemptions and five years for split categories. They also oppose new sub-exemptions and restrictive footnotes that could immediately ban essential electronic products.123
Why — Extended timelines and fewer sub-exemptions reduce administrative burdens and maintain market access.4
Impact — Environmental groups lose because toxic lead remains in products longer without stricter controls.5
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Meeting with Andrea Wechsler (Member of the European Parliament) and IBERDROLA

29 Jan 2025 · EU Energy and industry policy

Meeting with Pascal Canfin (Member of the European Parliament)

28 Jan 2025 · Clean Industrial Deal

Meeting with Elisabetta Gualmini (Member of the European Parliament)

28 Jan 2025 · ITRE Committee

Response to Digital Product Passport (DPP) service providers

9 Dec 2024

The association of the European Heating Industry (EHI) would like to stress the need for the Commission to take into account the activities on the building information modelling (BIM) for the development of the Digital Product Passport. More concretely, the standardized BIM data should be considered as a source of information and its interoperability ensured because this data format, which rests on norms such as EN ISO 16757, EN ISO 23386, EN ISO 23887 and EN ISO 12006-3, will be used by the technical building equipment sector to bring its digital data into the market.
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Meeting with Andrea Wechsler (Member of the European Parliament) and BUSINESSEUROPE and

23 Sept 2024 · EU Energy and Industry Policy

Response to Ecodesign requirements for air heating and cooling products (review)

30 Aug 2024

The European Heating Industry (EHI) would like to thank the European Commission for consulting us on the draft impact assessment roadmap for the review of the ecodesign regulation for air heating products, cooling products, high temperature process chillers and fan coil units (Regulation (EU) 2281/2016) and would like to share with the European Commission some first considerations. Exemptions from the scope of the Regulation: We suggest to better specify in the future text the units out of scope of the Regulation. We know that it is impossible to consider all the specific cases, however a better definition could allow for a clearer and more homogeneous application within the European Union (as an example, a clear distinction between a process equipment and a comfort equipment). In addition, we suggest keeping reversible heat pumps 400 kW out of the scope of this regulation, since they are already covered for heating requirements in Regulation (EU) No 813/2013, where the review is looking into adding information requirements on cooling efficiency if we understood correctly to enhance the transparency on the cooling function. Heat pumps specifically designed for heating purposes, as currently regulated by Regulation (EU) No 813/2013, cannot achieve the same cooling performance as chillers, as outlined in Regulation (EU) 2016/2281. If the same requirements are imposed on both types of appliances, heat pumps specifically designed for heating would have to compromise their heating efficiencies to meet the cooling requirements. Given that their primary function is heating, this compromise might lead to an overall increase in Energy consumption. Conversely, reversible heat pumps > 400 kW should remain in the scope of this regulation with cooling requirements as is the case today.
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Response to Amendment of F-gas Registy act - F-gas Portal

10 Jul 2024

The European Heating Industry (EHI) thanks the European Commission for preparing this draft implementing act and welcomes the amendments suggested. Nonetheless, we would like to request clarifications on the following point: Definitions of business activity and legal and financial status These information are requested under articles 2 and 3, however they are not defined in article 1. We would like to get a more precise understanding of what exactly will be requested under these two terms. We also suggest adding a link with an explanation of those terms on the corresponding section on the portal.
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Response to Minimum requirements for certification programmes and training attestations for RACHP equipment

10 Jun 2024

The European Heating Industry (EHI) thanks the European Commission for preparing this draft implementing act that will update the certification requirements, in line with F-Gas Regulation (EU) 2024/573. We agree that an update is needed to include non f-gas alternatives (hydrocarbons, ammonia, CO2). However, we do think that the certificate types can be further improved in order to facilitate the extension of the qualified workforce. In the present paper, we elaborate on an alternative proposal that reflects this. Certificates for natural persons- article 3 Article 3 of the draft implementing act includes a proposal for five types of certificates, attesting that the holder fulfils the requirements to undertake the activities referred to in article 2(1) (leak checks; installation; repair, maintenance or servicing as well as decommissioning; and recovery of fluorinated greenhouse gases). The certificate types, named from A to C, are differentiated based on the refrigerant type, while certificate D concerns equipment containing less than 1kg of F-gases, and certificate E concerns activities that do not entail breaking into the refrigeration circuit containing fluorinated greenhouse gases. While we see that this approach makes sense from a theory approach, we think it is necessary to integrate a certificate type dedicated to applications in the residential sector. Indeed, in order to achieve the REPowerEU target to have 10 million additional hydronic heat pumps installed in Europe by 2027, it becomes urgent to train more installers to work with fluorinated gases and their alternatives. With this in mind, offering a type of certificate that is targeted at applications in the residential sector would be particularly beneficial to smaller companies and independent installers. Indeed, it would spare them from the parts of training that are only relevant to industrial applications, and allow them to concentrate their training hours on the competencies that they are more likely to use. Ultimately, this would make training and certification more attractive for these small companies that may be reluctant to sacrifice too many working days. In this spirit, we recommend a certification scheme including the following certificate types: Certificate A, intended for all activities described in article 2(1), both with fluorinated gases and hydrocarbons. The certificate would also include optional modules dedicated to the use of Carbon Dioxide (Sub-category A1) and Ammonia (Subcategory A2). Offering a complete training for all activities and potentially all refrigerant types, this certificate category would be targeted mainly to large companies, that may have to install a variety of heat pump types both in the residential and the industrial sector. Certificate B, intended for all activities described in article 2(1), but limited to smaller heat pump equipments, and hence more accessible to smaller companies and faster to accomplish. For this certificate to be targeting residential applications, it should include thresholds for the maximum charge of fluorinated gases and hydrocarbons that are covered, that are still to be determined. Certificate C, covering only recovery activities for all fluorinated gases; Certificate D, covering only leak checks for all fluorinated gases. All in all, this certification scheme should allow more installers to get the training that fits their specific needs and business model, thus supporting the roll out of heat pumps in the European Union.
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Response to Update of format for F-gas reporting

10 Jun 2024

The European Heating Industry (EHI) thanks the European Commission for preparing this draft implementing act that will update the format of the F-gas reporting. We agree that an update is needed to avoid inconsistencies with the new F-gas regulation. We do however have some concerns, which we will elaborate on in this paper. 1) Timing of the application In line with the F-gas Regulation (EU) 2024/573, the proposed new format for the F-gas reporting includes significant changes in the categories to be used when reporting the number of heat pump units put on the market (section 11). To ensure a smooth transition with the previous categorization system, we strongly recommend that the new format should apply for the first time in 2026 for the reporting of quantities put in the market in 2025. Indeed, manufacturers need sufficient time to implement new categorization in their monitoring. Moreover, as the year 2024 is already well advanced, it would be an extremely difficult conversion exercise for manufacturers to start now using the new categories to report the quantities put in the market since the beginning of the year. Therefore, the 2025 declaration for the quantities put on the market in 2024 should still be done using the current categories. 2) Rated capacity and Primary function (Section 11) The draft regulation specifies that Where there is a reference to rated capacity and the equipment can have different functions the rated capacity refers to the primary function of the equipment (page 19). However, it fails to clarify how this primary function should be determined. This is especially difficult in the case of heat pumps that have both a heating and cooling function. For more clarity, we recommend explicating the link with ecodesign. In addition, using the term rated capacity is too vague, because the rated capacity for an appliance can be calculated under a variety of conditions. In order to be more specific, EHI would welcome a guidance document specifying the conditions at which the rated capacity should be defined, referring to the relevant Ecodesign Regulations. For heat pump space and combination heaters (in scope of Regulation 813/2013), we suggest referring to design load for heating (Pdesignh), as defined in Annex I (37): design load for heating means the rated heat output (Prated) of a heat pump space heater or heat pump combination heater at the reference design temperature, whereby the design load for heating is equal to the part load for heating with outdoor temperature equal to reference design temperature, expressed in kW.
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Response to Update of format of F-gas labels

4 Jun 2024

The European Heating Industry (EHI) thanks the European Commission for preparing this draft implementing act that will clarify the format of the F-gas labels. We agree that a good description of the format is needed to avoid inconsistencies with the new F-gas regulation. We do however have some concerns, which we will elaborate on in this paper. 1) The application time (Article 3) Although we understand that the application time of 1 January 2025 is part of the F-gas Regulation (EU) 2024/573, the timing between publication of this implementing act and the application date will be too tight for full compliance with the F-gas label. Indeed, the application of a label in a manufacturing process takes several months from the design of the label to sticking it to all relevant products. We would therefore like to ask the Commission to inform national market surveillance authorities about this too short time frame and to not launch any infringement procedures in case national market surveillance authorities do not enforce the obligations in accordance with this regulation in the first 12 months following its publication. In addition, it should be made clear that the application date applies to the placing on the market of products, not the subsequently supplying or making available to any other person, because this is not clear for the moment. Once it is placed on the market it out of the control of the manufacturer, hence, if the application date would apply to the supplying or making available after the placing on the market there is no possibility to comply with the requirements in this regulation. 2) Article 1.1 We fail to understand the reason for proposing this change (i.e., adding the reference to package leaflets) in comparison to the current regulation. In the current regulation, the F-gas label the font size of the label should not be smaller than the minimum size used in labels already affixed to the product. This requirement is much clearer and results in a clearly legible label. Requiring a change where not absolutely needed, only increases the burden for the manufacturer without a beneficial result. 3) Article 1.8 There is no reason to change this text, the end result is the same, the consumer is informed about the fact that F-gases have been used during the production of this product. If this change is required, it will force manufacturers to change their labels without a clear benefit. 4) Article 1.12 This requirement should be strengthened, to avoid that it is not fulfilled. We suggest specifying in the Implementing Act that the information mentioned in Art. 1.12 is to be filled out before putting into operation. 5) Article 1.10 We doubt that indicating the labelling info (e.g., type of refrigerant, GWP, weight,..) only via a QR code and not on the label itself is appropriate in view of compliance with safety legislations (e.g., Low Voltage Directive, Machinery Regulation,...) and the waste legislations (WEEE). Instead, we suggest using the QR code to provide the different language versions of the label.
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Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

5 Dec 2023 · Heating

Response to Drinking water - conformity assessment procedure

16 Nov 2023

Please find enclosed EHI feedback on the draft delegated act 5 of Article 11 of the European Drinking Water Directive (DWD).
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Response to Drinking water - procedures and methods for testing and accepting final materials

16 Nov 2023

Please find enclosed EHI feedback on the draft legal act 4 of Article 11 of the European Drinking Water Directive (DWD).
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Response to Drinking water - establishing the European Positive Lists of starting substances

16 Nov 2023

Please find enclosed EHI feedback on the draft legal act 2 of Article 11 of the European Drinking Water Directive (DWD).
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Meeting with Beatrice Covassi (Member of the European Parliament) and Ariston S.p.A.

24 Oct 2023 · De-carbonization of heating systems

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

29 Sept 2023

As an active player in the European and International standardisation technical committees, the European Heating Industry (EHI) welcomes this opportunity to share its views on the current EU framework of standardisation as standards play a key role in achieving 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. On many aspects, the current European Standardisation System is satisfying, in particular in aiming to strike a balance between providing technical specifications and allow flexibility in compliance with EU legislation. However, there is a clear need to reduce the duration of the process to adopt harmonised standards (HAS). In many regulations published more than five years ago, HAS are still missing. While, in some cases, HAS consultants are appointed to speed up the process in assessing to which extent the standard published by the European Standardisation Organisations (ESOs), complies with the Commission requests, there are still major delays as the process remains difficult. Yet, the publication of HAS is key to strengthen the position of manufacturers in the domestic market and worldwide. An adaptation of the processes and support of standardisation are absolutely necessary here. If there is no HAS consultant, which is the case for many Ecodesign and Energy Labelling Regulations, the cooperation between the EU Commission and the ESOs should be improved. In the current procedure, the EU Commission is often not involved until the moment they have to assess the ESOs published standards. 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 (SReq) to ESOs. In the case of the Gas Appliances Regulation (GAR) which was adopted in 2016, the SReq was sent by EU Commission services to ESOs only in August 2023, namely seven years later. This request to develop new standards went against the background of maintaining the harmonised 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, manufacturers could not take advantage of this privilege. As a result, higher risks had to be taken into account by EU industry during the conception of the products, thus affecting also their capability to foster innovation and competitiveness. We appreciate the efforts put in place in the last period by EU Commission to reinforce and improve the HAS assessment system with the new contracts in place and we look forward to even more positive results in the near future but we still ask for more resources to be made available, in terms of both personnel and financial support, to strengthen the standardization related activities in EU services and also to support the whole work made by ESOs, with the goal to increase as much as possible the participation of EU SMEs experts to standardization activities and help the growth of a new generation of young skilled experts, which are needed for the global competition we are facing in our worldwide activities. Read our full position attached.
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Heating industry urges inclusion of buildings in Hydrogen Valleys

5 Sept 2023
Topic — A roadmap outlining strategic priorities to double the number of EU Hydrogen Valleys.
Message — The association calls for hydrogen use in all sectors, including buildings. They want local flexibility to choose hydrogen solutions alongside electrification.12
Why — Inclusion would create a stable market for their H2-ready appliances and infrastructure.34
Impact — Proponents of building electrification could see reduced investment and policy focus.5
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Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur for opinion)

1 Feb 2023 · ESPR (Staff Level)

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur)

6 Jul 2022 · Meeting on gas and hydrogen regulation

Meeting with Radan Kanev (Member of the European Parliament, Rapporteur for opinion)

18 May 2022 · EPBD

Response to Revision of EU rules on Gas

11 Apr 2022

The European Heating Industry, EHI, welcomes the publication of the Hydrogen and Decarbonised Gas Package that sets the rules for creating a competitive hydrogen market and better includes renewable and low-carbon gases in the legislation. In the current international context, it is more important than ever to reduce our energy dependence, especially from Russian gas. This includes phasing in modern and efficient heating systems in Europe’s buildings, including electric heat pumps and hybrids, but also efficient appliances using gaseous fuels. Crucially, our production and use of green gases, including hydrogen, must increase, as set out by the European Commission in the REPowerEU communication, with the aim of fully decarbonising all energy vectors. EHI is fully committed to supporting the new targets and developed already technologies that can work with these new gases. Our heating appliance can run with biomethane and e-methane without any required adaptation. Moreover, modern condensing boilers can run with up to 20% hydrogen, thus reducing natural gas consumption while creating a large and immediate demand for hydrogen. Heating manufacturers have also developed ‘hydrogen ready’ products that have been tested successfully on field and are designed to replace old and inefficient heating systems based on natural gas. Together with network planning, the bottom-up approach is essential to make the hydrogen economy a reality as local communities know the best where hydrogen and green gases can be the most efficient solution for decarbonisation. Therefore, it is important that the Package clearly allows the use of hydrogen and biomethane in the building sector, as a necessary complement to electrification. A multi-technology, multi-vector approach is key to decarbonise buildings in a fast, sustainable and affordable way and to support our objective of cutting energy dependence. The Package is key to support the switch from natural gas to renewable and low-carbon gases. Yet, the Directive focuses on transmission of hydrogen and pure hydrogen infrastructure and not on distribution. Cutting emissions from buildings is one of the most important challenges of decarbonisation as the sector represents 40% of Europe’s final energy consumption and 36% of CO2 emissions. The legislation should therefore guarantee that hydrogen will be accessible to customers at the distribution level. Despite some flexibility introduced in the Directive, we worry that the decentralised production of hydrogen is not enough promoted by the package, although we know that hydrogen valleys are developing across Europe, via off-grid systems for many of them. The concept of ‘Citizen Energy Community’ foresees a role only in the natural gas market, without mentioning hydrogen. Such communities should have the right to produce hydrogen locally and access the infrastructure to export any surplus as it is the case for biogas. Network planning between gas, hydrogen and electricity is key to optimise our energy system and reach out carbon-neutrality by 2050. To this aim, it is crucial that all the relevant stakeholders of the hydrogen and the gas value chains are involved in the ENNOH established by the Regulation to ensure customers certainty, both for the use of blends and pure hydrogen. To accelerate the transition from natural gas to renewable gases, the Directive should introduce EU-wide binding targets to translate into the legislation the increased ambition announced in the REPowerEU communication. Such targets are key to provide a predictable and stable framework for the decarbonisation of the gas system. Finally, consumers must be informed of the fuels they are using to heat buildings: natural gas, bio or synthetic methane, and hydrogen. However, while the Annex I to the Directive introduces the concept of guarantees of origin, which we support, it is unclear where the actual measuring of gas quality at the point of consumption will take place.
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Response to Revision of EU rules on Gas

11 Apr 2022

The European Heating Industry, EHI, welcomes the publication of the Hydrogen and Decarbonised Gas Package that sets the rules for creating a competitive hydrogen market and better includes renewable and low-carbon gases in the legislation. In the current international context, it is more important than ever to reduce our energy dependence, especially from Russian gas. This includes phasing in modern and efficient heating systems in Europe’s buildings, including electric heat pumps and hybrids, but also efficient appliances using gaseous fuels. Crucially, our production and use of green gases, including hydrogen, must increase, as set out by the European Commission in the REPowerEU communication, with the aim of fully decarbonising all energy vectors. EHI is fully committed to supporting the new targets and developed already technologies that can work with these new gases. Our heating appliance can run with biomethane and e-methane without any required adaptation. Moreover, modern condensing boilers can run with up to 20% hydrogen, thus reducing natural gas consumption while creating a large and immediate demand for hydrogen. Heating manufacturers have also developed ‘hydrogen ready’ products that have been tested successfully on field and are designed to replace old and inefficient heating systems based on natural gas. Together with network planning, the bottom-up approach is essential to make the hydrogen economy a reality as local communities know the best where hydrogen and green gases can be the most efficient solution for decarbonisation. Therefore, it is important that the Package clearly allows the use of hydrogen and biomethane in the building sector, as a necessary complement to electrification. A multi-technology, multi-vector approach is key to decarbonise buildings in a fast, sustainable and affordable way and to support our objective of cutting energy dependence. The Package is key to support the switch from natural gas to renewable and low-carbon gases. Yet, the Directive focuses on transmission of hydrogen and pure hydrogen infrastructure and not on distribution. Cutting emissions from buildings is one of the most important challenges of decarbonisation as the sector represents 40% of Europe’s final energy consumption and 36% of CO2 emissions. The legislation should therefore guarantee that hydrogen will be accessible to customers at the distribution level. Despite some flexibility introduced in the Directive, we worry that the decentralised production of hydrogen is not enough promoted by the package, although we know that hydrogen valleys are developing across Europe, via off-grid systems for many of them. The concept of ‘Citizen Energy Community’ foresees a role only in the natural gas market, without mentioning hydrogen. Such communities should have the right to produce hydrogen locally and access the infrastructure to export any surplus as it is the case for biogas. Network planning between gas, hydrogen and electricity is key to optimise our energy system and reach out carbon-neutrality by 2050. To this aim, it is crucial that all the relevant stakeholders of the hydrogen and the gas value chains are involved in the ENNOH established by the Regulation to ensure customers certainty, both for the use of blends and pure hydrogen. To accelerate the transition from natural gas to renewable gases, the Directive should introduce EU-wide binding targets to translate into the legislation the increased ambition announced in the REPowerEU communication. Such targets are key to provide a predictable and stable framework for the decarbonisation of the gas system. Finally, consumers must be informed of the fuels they are using to heat buildings: natural gas, bio or synthetic methane, and hydrogen. However, while the Annex I to the Directive introduces the concept of guarantees of origin, which we support, it is unclear where the actual measuring of gas quality at the point of consumption will take place.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

The European Heating Industry, EHI, welcomes the revision of the Energy Performance of Buildings Directive (EPBD), announced by the Renovation Wave and representing a key step to achieve the objectives of the EU Green Deal. The Directive recast represents a unique occasion to ensure buildings actively contribute to higher energy efficiency and emissions reductions, in line with goal of the Climate Target Plan to lower buildings’ emissions by 60% by 2030, compared to 2015 levels. As European Heating Industry, we have been calling for this target to be explicitly enshrined into the EPBD, to establish a clear obligation for Member States in relation to buildings’ decarbonisation, while leaving enough flexibility in the choice of the most appropriate options and measures at national, local, and even at single building level. While we welcome the increased ambition of the Directive. We are nevertheless concerned by some of the proposed provisions, which we believe need to be further improved: 1. The current proposal should better address the ‘heating dimension’ of buildings and the urgency to accelerate the modernisation of the heating stock. Buildings are responsible for 40% of energy consumption and 36% of greenhouse gas emissions in the EU. At the same time, space and water heating account for almost 80% of energy use in residential buildings, where about 60% of heaters today are old and inefficient, largely based on fossil fuels. This shows how urgent it is to accelerate the installation of efficient heating technologies and to parallelly switch to renewable and decarbonised energies, as a prerequisite to decarbonise the building stock and significantly reduce households’ energy bills. If the EPBD wants to deliver on the decarbonisation of heating (and cooling), one of the pillars of the Renovation Wave, it necessarily needs to push for higher replacement rates, of at least 6% per year, and support the installation of modern heating appliances in buildings. 2. The proposal needs also to address buildings’ decarbonisation within a ‘system perspective’. Buildings are not stand-alone entities but part of a broader energy system. While it is positive to promote on-site production and use of renewable energy and the deployment of local renewable resources, the use of renewable and decarbonised energy supplied via energy networks in efficient heating systems should be equally promoted. This would help balance renewable self-production, while ensuring broader decarbonisation of the energy grids and providing for more options for the uptake green energy in buildings, in line with a multi-technology and multi-vector approach to decarbonisation. 3. Incentives should be available for all technologies supporting buildings’ decarbonisation. While accelerating fuel switching in buildings is essential, all technologies ready to use renewable and decarbonised energies should be able to contribute to buildings’ decarbonisation, including boilers. It is indeed critical to distinguish between technologies and the fuels they use: boilers and other technologies on the market today can already use 100% renewables (biomethane) and variable shares of hydrogen up to 20%, with the aim to reach 100% by the end of the decade. Therefore, technologies ready for renewable and decarbonised energies should remain eligible for incentives. The latter should also be available for boilers that work in combination with renewable-based technologies and support the increasing uptake of renewable energy, such as hybrid heaters and solar thermal systems. 4. New requirements for data exchange should be proportionate, especially regarding access to data by third parties. Please find enclosed our detailed position.
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Meeting with Michael Bloss (Member of the European Parliament) and EUROMETAUX and

8 Feb 2022 · ETS

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards

Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and EPIA SolarPower Europe and

24 Nov 2021 · RED III

Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

The European Heating Industry, EHI, welcomes the Commission’s proposal on the Energy Efficiency Directive. The EED recast, with its proposed higher and binding EU energy efficiency target, offers an opportunity to scale up efforts in energy efficiency, including in heating. In this sense, we argue that the EED should include a 6% yearly target for the replacement of old and inefficient heating equipment. Such objective is key towards achieving our 2030 targets, as modern heating systems cut energy use and CO2 emissions from buildings. Importantly, the proposed review tackles the issue of energy poverty, which is of particular concern in current times of rising energy prices. The importance of granting adequate support to consumers, notably when it comes to switching to more efficient and less emitting heating systems, is a key challenge to be addressed across the entire package, particularly in energy label and in the proposed creation of an EU ETS for buildings and transport. We also take positive note of the inclusion of the Energy Efficiency First principle into the revised Directive, which should be applied consistently with the guidelines published by the Commission in September. Hence, when operationalising the principle, policy makers should fully take into account system efficiency considerations, thereby supporting the deployment of different technologies and solutions that allow for system integration and optimisation (i.e.: hybrids and micro-CHP using renewable gas and electricity, solar thermal heating technologies as well as decentralised renewable energy production and thermal storage, explicitly mentioned in the guidelines). Despite the good elements above a few provisions raise concern and could possibly slow down the much-needed energy transition in the heating sector: ▪ Provisions excluding energy savings obtained in combustion technologies using fossil fuels from 2024 (Annex V and other provisions on the Energy Savings Obligation): it is crucial to distinguish between fossil fuels and technologies operating with (any) fuels. Heating manufacturers are rolling out boilers that can operate already today with renewables (biomethane) and blends of natural gas and hydrogen, and will also be able to work with 100% hydrogen before 2030 (EHI ecodesign proposal). Such approach is fully aligned with the roadmap to Net-Zero by the IEA, stating that ‘any gas boilers that are sold [should be] capable of burning 100% hydrogen and therefore are zero carbon‐ready’. Combustion technologies are needed in heating as a complement to increasing electrification via heat pumps and hybrids, to make sure the system is flexible, resilient and makes full use of the existing energy infrastructures, such as the gas grid (with upgrades where needed). Such a multi-vector approach is part of the draft ENTSOs scenarios for the 2022 TYNDP, where both electrification and green molecules (biomethane, hydrogen) co-exist in 2050. Keeping the current exclusion would stifle innovation and the further greening of technologies while excluding, at the same time, a significant amount of cost-effective, affordable and easily achievable energy savings by MS. The ‘readiness’ of technologies to accommodate more sustainable alternatives is key and should be better reflected into the EED, including in the energy savings obligation rules. ▪ Provisions on public procurement and purchasing requirements for public authorities (Annex IV): these require public authorities to purchase only products that comply with the criterion laid down in Art. 7.2 of the Energy Labelling Regulation. But using only this criterion does not take the heterogeneous on-site conditions and usage patterns of buildings into account. In fact, it would exclude key technologies for the decarbonisation of buildings. On the contrary, requirements for public authorities and incentives should support the uptake of all products ready to work with renewable and decarbonised energy sources.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The European Heating Industry, EHI, welcomes the Commission’s proposal to review the Renewable Energy Directive (RED) along with the new ambition proposed for the renewable energy target. We also welcome the new provisions on heating and buildings, although we had previously called for a higher renewable heating and cooling target, of 2.3%. We stress that the framework for heating and buildings should leverage the deployment of renewable heating systems and accelerate the currently very low replacement of old and inefficient heaters, as this is essential for the decarbonisation of the sector. This is particularly relevant, notably if we consider that space and water heating account for almost 80% of the energy consumed in residential buildings. Furthermore, we see that the proposal provides important signals: it confirms the importance of efficient electrification by maintaining the main provisions promoting heat pumps. It promotes the use of renewable fuels of non-biological origin (RFNBOs), which will play a key role in decarbonising some sectors of the economy, including buildings. This sector is indeed hard-to-decarbonise, due to buildings’ extreme heterogeneity and the variety of factors affecting buildings’ users/owners (individual preferences and financial means), local energy systems (sizing, access to energy grids, local availability of renewable resources), and buildings themselves (age, levels of insulation, possibilities for deep or staged-deep renovations and, consequently, varying heating needs). Hence, we would like to highlight a few elements in relation to the current proposal, which we believe should be duly taken into account in the current negotiations and be reflected into the revised Directive: ▪ Ensure the decarbonisation of heating and, consequently, of buildings, are seen as key priorities across the entire Fit for 55 package, and support them by making the most of all efficient technologies and decarbonised energy carriers (according to a multi-technology and multi-vector approach), to ensure a cost-effective and affordable energy transition. In the RED, this means: - Efficient electrification via all types of heat pumps, including hybrids (allowing for a swift and effective electrification in all buildings, along with significant energy efficiency gains) should be further promoted; - Electrification should be supported and complemented through the deployment of green gases/fuels, notably RFNBOs and biogases/fuels, in efficient heating technologies, which should also be further promoted by the Directive and, possibly, at Member States’ level. Depending on their preferred decarbonisation pathway, MS could indeed set targets for their deployment to facilitate their development and related market. ▪ Support smart system integration and efficiency to underpin the efficient use and storage of renewable energy, by promoting the deployment of decentralised solutions that allow for higher system efficiency and flexibility (including thermal storage and smart heating systems that drive self-consumption, energy storage and demand-side flexibility models). At the same time, this would also mean to make the most, whenever relevant, of the existing energy infrastructure and use it to support the overall system’s flexibility and its balancing. ▪ Continuously promote the role and the sufficient availability of trained installers, who are critical in guiding consumers’ choices, especially when it comes to replacing and upgrading heating systems. In this respect, we welcome the new provisions by Art.18, and we believe it is essential that MS invest in training, qualification and upskilling of installers, capable of supporting the penetration in EU buildings of the efficient and renewable-based heating technologies that will help slashing CO2 emissions. National heating associations can play a key role in this respect and provide support to national authorities in the design and functioning of such schemes.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

The European heating industry is an essential contributor to the EU 2030 and 2050 climate and energy targets. Through energy efficient, smart and secure net-zero emissions appliances, it can drive the use of renewable energy in our homes and offices, providing cost-effective, advanced technological solutions to achieve the 2030 climate and energy targets and climate-neutrality for buildings by 2050. In this sense, we fully support the goals of the Fit for 55 package and the importance of pricing the CO2 externality. We are ready to contribute to these goals with our technologies and know-how. Given this important role of heating products to achieve our common goals, we believe that the design of any carbon border adjustment mechanism (CBAM) should consider the competitiveness of the European industry, while of course being fit to achieve its environmental goals. The implementation of a carbon pricing on materials and components is very likely to lead to price increases. Such increases have an influence on the final goods. This means a potential competitiveness issue for products that are key to lead Europe to achieve carbon neutrality. Moreover, European exporters will have to work with materials and components that have internalised a CO2 price and export final goods that are affected by such pricing. However, they will face competition from non-EU manufacturers, that are not affected by CBAM. This situation will lead to a competitiveness issue for European producers. This aspect should be carefully assessed in the next steps of the legislative process.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and EUROGAS and COGEN Czech, Association for Combined Heat and Power Generation of the Czech Republic

21 Sept 2021 · Meeting on 2030 RENEWABLE GAS AND GAS DECARBONISATION TARGETS

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Please see our feedback to the Inception Impact Assessment enclosed.
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Response to Review of EU rules on fluorinated greenhouse gases

2 Sept 2020

Please find our comments attached. About the European Heating Industry The European heating industry brings together companies that are leaders in the production of efficient heating systems. Our members produce advanced technologies for heating in buildings, including: heating systems, boilers, heat pumps, burners, components and system integrators, radiators, surface heating & cooling. For tomorrow’s changed energy system, our members are innovating in hybrid and digital solutions. They develop high-efficiency and renewable-based systems. These innovations will improve Europe’s homes and our environment. EHI members employ directly more than 125.000 people in Europe and invest over 1 billion euros a year in energy efficiency. Please visit our website (www.ehi.eu) for further information.
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

1 Sept 2020 · Renovation wave

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

8 Jun 2020

Feedback of the European Heating Industry (EHI) to the Commission public consultation on Roadmap on Renovation Wave Please refer to the enclosed file for the complete EHI feedback ** The Renovation Wave must accelerate the replacement of old and inefficient heating equipment ** Europe will be able to achieve its 2030 and 2050 climate targets, only if we replace inefficient heating equipment faster than today. Of the over 103 million heaters installed in European homes, 64% are inefficient (C or D or lower of the energy scale). At the current replacement rate – 4% /year – it would take over 20 years to substitute the old stock. But if the pace were accelerated to 5%, we would cut CO2 emissions by almost 40% by 2030 (ECOFYS, EU pathways to a decarbonised building sector, 2016). Moreover, in view of the post-COVID green economic recovery, replacing old heating systems in Europe will help restart the economy and support 1.8 million local jobs (EU-based heating value chain). And it will much contribute to the Green Deal: the construction sector has the largest gap of investments for achieving the current 2030 targets (EU Commission, Identifying Europe’s recovery needs, 2020). Replacing heating systems is easy and cost-effective, with immediate energy savings and CO2 emissions cuts. This is because in EU households, space and water heating account for about 80% of total final energy use. And payback time is short compared to other energy efficiency measures: even down to 4.5 years, depending on the building and climate zone. This is also the merit of high energy savings – at least 20% when substituting an old and inefficient boiler with a new condensing one, higher savings with renewables. It is also easy to implement: on average it takes one day to change heating equipment, with limited costs and high CO2 reduction benefits. Increased penetration of smart heating is another benefit of modernisation: it optimises energy consumption, increases comfort and allows for predictive maintenance. The good news is: the heating technologies that will lead the way to carbon-neutral buildings already exist. These are condensing boilers, even already working with biomethane and blends of hydrogen, electric and gas heat pumps, hybrids, biomass boilers and solar thermal, micro-combined heat and power and fuel cells, thermal energy storage, controls and smart energy managements systems, low temperature radiators and underfloor heating. More technologies are in the making, for example to work with 100% hydrogen. But they are installed only in a minority of EU buildings. The Renovation Wave is a chance to tackle the barriers preventing a higher penetration of these technologies: low consumer awareness, lack of adequate funding and a shortage of skills and installers are key ones. The Renovation Wave will achieve it, if it addresses 3 priorities: 1. Introduce systematic checks and efficiency labelling of space and water heating equipment in EU legislation. 2. Introduce scrappage schemes to replace old and inefficient space and water heating equipment, which can be coupled with hybridisation programmes for already efficient heating systems. 3. Train enough installers to handle the Renovation Wave.
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Response to Strategy for smart sector integration

2 Jun 2020

Please find enclosed the contribution of the European Heating Industry (EHI) to the public consultation on the Strategy for Smart Sector Integration. We remain at your disposal for any question you may have. With kind regards, Paolo Basso.
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Response to Climate Law

6 Feb 2020

The proposal of a EU Climate Law aims to enshrine climate neutrality by 2050 into EU legislation. Achieving a climate-neutral building stock by 2050 is a key step in this direction, because buildings represent 40% of the energy used in Europe. Highly efficient, smart and renewable-based heating appliances have a key role to play, because they reduce the energy consumption of buildings (over 80% heating) and cut CO2 emissions. The action to get there should start today, because Europe can only achieve carbon neutrality in 2050, if it first focuses on the decade up to 2030. • Foster the modernisation of old and inefficient heating appliances. With roughly 72 million old, inefficient heaters in Europe’s buildings and low replacement rates, there is huge untapped potential for energy savings. New, efficient systems can bring energy efficiency gains of at least 20% and cut CO2 emissions by 35%; more is achievable, with renewable-based heaters. Hence, the ‘Renovation Wave for Buildings’ should help people change their old heating systems with new ones. It should support national scrapping schemes for old heaters and financial instruments to promote the upfront investment in energy efficient and renewable-based ones. The choice of efficient heating technology should be left to consumers, advised by installers. • Decarbonise the energy sources used for heating. The European Green Deal and related legislation should promote green gases, e.g. hydrogen, biomethane. Why? Gas is the most common heating source in the EU. Already today, heaters can be used with bio- and synthetic methane. Tests on hydrogen-compatible appliances are ongoing. Also, EU countries should keep decarbonising electricity and develop their framework for demand response. • Take a systemic approach to decarbonise buildings. Heating systems (heat generators and emitters, i.e. radiators, underfloor heating), the energy used in buildings, as well as insulation should be involved in the decarbonisation effort. Why? Because, according to the building, local circumstances and peoples’ preferences, the ways to achieve decarbonisation will be different. Moreover, there are synergies between insulation, heating systems and energy sources. • Focus on consumers. People are often unaware that their old heater is inefficient and what technologies are available for replacement. Ecodesign ensures that only efficient products are placed on the market, but this measure is insufficiently flanked by support of market uptake of efficient products. Thus, public administrations should organise awareness campaigns and build a culture of energy efficiency. For example, energy labels for already installed appliances help people visualise that their old boiler needs substituting with a more efficient /renewable heater. Such labels already work in some EU countries and should be promoted at EU level. • Promote smart heating systems. Smart heating helps households achieve comfort and purchase electricity for heating when it is less expensive. It can also allow installers to perform early maintenance (malfunction detection). Smart heating may help use renewable electricity and relieve grids, thanks to demand response. The legal framework for interoperability and the implementation of electricity market design should promote demand-response from heating. • Attract and upskill installers. Installers are gateways to bring innovative heating technologies in EU buildings. To accelerate the replacement rate of old and inefficient heaters, more skilled installers are needed. They should be able to install the heating technologies needed for the transition. • Apply the energy efficiency first principle for heating in industry. Increasing the energy efficiency of industrial heating processes and modernising outdated plants are great ways to reduce greenhouse gas emissions. So is the development of green fuels (e.g.: hydrogen, biomethane) and their use in highly efficient industrial appliances.
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Response to A new Circular Economy Action Plan

18 Jan 2020

The European Heating Industry (EHI) welcomes the opportunity offered by the European Commission to provide feedback on a new Circular Economy Action Plan to increase recycling and reuse of products in the EU. Firstly, the Commission mentions in the roadmap that the future initiative for a sustainable product policy will support design for circularity and provide tools to industry for better managing their supply chain. The European Heating Industry would like to emphasize that so far, Ecodesign measures have been effective for heating products because they regulate measurable and verifiable parameters on the basis of a clear and transparent methodology. To maintain this effectiveness, circular economy criteria should meet five key conditions when applied to EU product policy and regulatory instruments: 1) first, take into account the specificities of each product group. Heating products already comply with circular economy principles through their whole lifecycle due to their specificities and compliance with existing legislation; 2) focus on areas with clear improvement potential and measures than are achievable at a proportionate cost. For example, policies that raise the awareness of consumers on the inefficiency of their old heater and incentivise / support them to switch to highly efficient ones; energy savings achievable thanks to smart products and grids; 3) be easily measurable, refer to existing or forthcoming standards, and be set in a clear and objective manner. 4) be based on robust analyses and thorough impact assessments; 5) be enforceable and verifiable by market surveillance authorities Secondly, the Commission announces in the present roadmap a comprehensive review of waste legislation. We welcome that the Commission identified the risks of multiple regulations between chemicals, waste and product legislation in a previous communication. This should be carefully considered in the new Circular Economy Action Plan. Moreover, to be successful, this Plan will need more harmonised product specific standards regarding material efficiency (i.e. durability), product circularity level, environmental footprint etc. Finally, the industry needs transparent information on the composition of recycled materials to unlock the potential of a secondary market for materials. Therefore, it is a priority to determine a reliable process on how to ensure safety, quality and performance of a material before using it as a secondary raw material. For further details, please find enclosed the EHI contributions to the public consultation on Sustainable Products in a Circular Economy of January 2019, and on a Scoring System on the reparability of products of September 2019.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

18 Dec 2019 · Green Deal and decarbonisation of the heating sector

Response to Methodology for assessing the potential for efficient heating and cooling

10 Jan 2019

Six elements to strengthen and clarify the methodology to assess efficient heating and cooling in the Energy Efficiency Directive On 13 December 2018, the European Commission invited stakeholders to share their comments on the draft Delegated Regulation amending Annexes VIII and IX to Directive 2012/27/EU on the contents of comprehensive assessments of the potential for efficient heating and cooling. The Commission’s proposal is rather comprehensive, but should also include the following elements to reinforce the link with the new legislation of the energy union – namely the EPBD (EU) 2018/844, EED (EU) 2018/2002, RED (EU) 2018/2001 and ‘Governance of the Energy Union and Climate Action’ Regulation (EU) 2018/1999, while maintaining clear requirements and technological neutrality: 1. In part I.2, split the identification of current heating and cooling supply by the type of energy for all the technologies listed to give further accuracy to the assessment; Example: split ‘fossil fuels’ into natural gas, oil products and coal; split ‘renewable sources’ into solar thermal energy, geothermal energy, ambient energy, biomass or biogas, as defined in article 2.1 of the Renewable Energy Directive (EU) 2018/2001. 2. In section 2(a), ‘heat-only boiler’ should be replaced by ‘heat-only generator’ to encompass the various technologies (e.g. heat pumps); in addition, cooling should be adequately formulated in the wording of the text, not only referred to in a footnote. 3. In section 2(a)(iv), ‘energy from renewable sources’ should be clearly worded as not additional to the various renewable sources listed in (i) (ii) and (iii) but including them. Why? Because it will help to calculate the total share of energy from renewable sources and comply with article 23.1 of Directive 2018/2001. 4. In section 2(b), the potential of waste heat and cold in district heating should not be overestimated. This is why, Member States should identify only installations that generate ‘unavoidable waste heat or cold’, as defined in article 2.9 of Directive 2018/2001. 5. In section 7, Member States should assess the economic potential of highly efficient heat generators considering all types of energy sources. A split of heating and cooling supply by energy type (similar to part I.2, see above) would then help compare the current heating and cooling overview with the potential analysis for efficient heating and cooling. 6. In addition, section 7 should clearly promote efficient technologies. Therefore, the footnote concerning heat pumps should refer to article 7.3 of Directive 2018/2001, according to which “heat pump final energy output shall significantly exceed the primary energy input required to drive them.”
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Meeting with Dominique Ristori (Director-General Energy)

3 May 2018 · clean energy transition

Response to Revision of the Drinking Water Directive

28 Mar 2017

EHI feedback to the Drinking Water Directive Revision Roadmap The European Heating Industry (EHI) welcomes the work of the European Commission aiming to revise the Drinking Water Directive (DWD), especially its Article 10 on materials and products in contact with drinking water. EHI takes part in the European Drinking Water (EDW) industrial alliance and we support the recommendations of this industry group to revise the DWD in order to develop a harmonised regulatory framework on materials and products in contact with drinking water. This is important not only to ensure that all European citizens benefit from a high level of human health protection, but also to contribute to a more efficient functioning of the EU internal market and support innovation in this field. In addition to the EDW feedback, EHI would like to stress the following: • Mutual recognition of materials and products in contact with drinking water should be improved in the EU, and should address, in particular, the case of small surface components and products in order to remove barriers to innovation and the introduction of new materials. • The development of EU-wide common procedures for conformity assessment and test methods should take into account the experience from existing Member States’ approval schemes and standards for materials and products in contact with drinking water, and joint initiatives (such as the 4 Member State Initiative) to find some commonality. • Adequate transition periods should be assessed for already tested and recognised materials and products in contact with drinking water to ensure a cost-effective and gradual switch to these new European procedures. Best regards, Fanny Rateau, Regulatory Affairs Manager, EHI About EHI, the Association of the European Heating Industry EHI represents 90% of the European market for heat and hot water generation, heating controls and heat emitters, 80% of biomass central heating, as well as more than 70% of the hydronic heat pump market. Our Members produce advanced technologies for heating in buildings, including: heating systems, burners, boilers, heat pumps, components and system integrators, radiators, surface heating & cooling and renewable energy systems. In doing so, we employ directly more than 120.000 people in Europe and more than seven hundred million euros a year in research and innovation.
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Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and The European Association for the Promotion of Cogeneration and Solar Heat Europe/ESTIF

16 Dec 2016 · energy effiiciency

Meeting with Maroš Šefčovič (Vice-President) and The European Association for the Promotion of Cogeneration and

24 Jun 2016 · Energy efficiency and decarbonisation

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

16 Jun 2015 · Energy Union

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

16 Jun 2015 · Energy Labelling