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Comité Européen des Fabricants d’Appareils de Chauffage et de Cuisine Domestiques

C.E.F.A.C.D.

The purpose of CEFACD is to study – primarily from a scientific, technical, pedagogical, economic and institutional point of view – topics of common interest to the domestic individual heating appliances, stoves, fireplaces, cooking appliances and related equipment industries and to represent and promote efficient and environmentally friendly individual heating appliances and cooking appliances and to safeguard the supranational interests of members as appropriate, in particular by: - exchanging information and experiences on issues that are important to the industry; - conducting joint technical and economic activities in order to ensure a level playing field for competition; - cooperating with similar national, European, international and worldwide associations - representing and promoting its members’ common economic, technical and political interests before the European Commission, the European Council, the European Parliament and other European and international bodies. (...)

Lobbying Activity

Response to Heating and cooling strategy

9 Oct 2025

CEFACD posits that with the transition to renewable energy in Europe still being developed and energy prices still high, domestic scale woodburning stoves provide a stable and manageable low carbon heat source, reducing the draw on electric grid and gas networks. Wood fuel production for LSH promotes the rural economy and wood fuel is a key economic driver in sustainable woodland management. It gives the most vulnerable population a cost-effective and low carbon means to heat their homes. It should be noted that 38% of European households heat their homes using solid fuel local space heaters, which amounts to more than 50 million appliances in use. CEFACD will respond fully to the consultation but urges the full benefits of wood LSHs and their wider cotribution to EU objectives are recognised
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Response to Electrification Action Plan

9 Oct 2025

CEFACD posits that by reducing peak demand, wood burning Local Spaceheaters support ; - energy poverty alleviation - household energy resilience - optimal electrical heating performance - cohesion - supporting rural economies - competitiveness - wellbeing
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Meeting with Robert Nuij (Head of Unit Energy) and Grayling

1 Oct 2025 · Exchange of views on the review of the ecodesign and energy labelling legislation on solid fuel local space heaters

Meeting with Piotr Müller (Member of the European Parliament) and Grayling

4 Apr 2025 · Ecodesign Rules for Solid Fuel Heaters – Impact on SMEs and the Single Market

Meeting with Niels Ladefoged (null Energy)

14 Mar 2025 · Meeting to discuss ongoing work on reviewing EU ecodesign rules for solid fuel local space heaters (inc. biomass stoves).

Response to Single Market Strategy 2025

31 Jan 2025

CEFACD Response to the Single Market Strategy Solid fuel local space heaters (LSH) play a crucial role in the European economy. These appliances are a significant part of the Eurozone's low-carbon heating solutions, providing sustainable heat to approximately 38% of European households. They are a stable and manageable heat source that helps reduce the strain on electric grids and gas networks, especially during times of crisis or high energy prices. Additionally, wood fuel production for LSH promotes the rural economy and supports sustainable woodland management. The LSH industry is highly competitive and largely comprised of small and medium-sized enterprises (SMEs) within the EU. Approximately 95% of local space heater appliances are produced in Europe, supporting around 11,000 SMEs and around 200,000 jobs. This sector is vital for the European manufacturing base and contributes to economic resilience. The continuous technological advancements and investments made by manufacturers have significantly improved the efficiency and emissions of wood-burning stoves. However, the industry faces challenges that could hinder its competitiveness. Over-regulation and frequent changes in testing and certification requirements place a disproportionate burden on manufacturers. These regulations can lead to increased costs and operational inefficiencies, discouraging innovation and potentially driving businesses to relocate outside the EU. It is essential to adopt a proportionate approach to legislation that supports the sector's growth and innovation while maintaining high environmental standards. The solid fuel LSH sector is a major employer within the EU, particularly in rural areas. The supply chain for wood fuel and the production of local space heaters provide significant employment opportunities, contributing to the economic sustainability of these regions. The bioenergy sector, which includes wood fuel production, is the largest sector for heating in the EU, employing approximately 550,000 citizens. Maintaining and enhancing the competitiveness of the LSH industry is crucial for job retention and creation. Over-regulation and excessive testing requirements could lead to job losses and negatively impact the rural economy. Ensuring a balanced regulatory framework that supports innovation and competitiveness will help safeguard these jobs and promote The solid fuel LSH industry experiences several business frictions that could be addressed through the Single Market Strategy. These include: The continuous introduction of new testing and certification standards creates a significant burden on manufacturers. Harmonizing these standards and ensuring they are validated through normalization routes can reduce unnecessary costs and operational disruptions. Excessive regulation can stifle innovation by diverting resources away from research and development. A proportionate approach to evolving legislation can encourage continued innovation and technological advancements in the sector. Ensuring fair and consistent treatment of LSH across the EU is crucial for market access. Removing regulatory and administrative barriers can facilitate the cross-border movement of goods and services, allowing businesses to scale up and compete globally.
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Response to Ecodesign requirements for solid fuel local space heaters (review)

13 Dec 2023

CEFACD supports the pursuit of sustainable low-carbon heating and improved environmental product performance. Its members work continually to produce efficient and durable products. As such, we would like to emphasise the important role of local space heaters (LSH) in fostering the energy transition and reducing energy poverty. - We stress the importance of LSH as secondary heating: in times of high energy costs and in order to keep costs down, tenants increase their use of LSH so that they only heat the room they are in, rather than use central heating for the whole house. In fact, SFLSH is a low carbon heat source that complements other heat sources, such as lower temperature steady-state heat emitters (i.e., heat pumps); - We are concerned by the focus on combining Energy Labels, removing granularity, and thereby not allowing consumers to choose the most efficient products in their desired choice of fuel; - CEFACD highlights the importance of maintaining consumer choice and their right to heat their homes under any circumstances; - Wood-burning LSH is a high efficiency, low carbon sustainable renewable heat source. We estimate a stock of 100 million appliances in the EU, of which 45 million are solid-fuel LSH (SFLSH). SFLSH constitute an economically significant industry within the EU, and Ecodesign requirements have driven improvements in efficiency and reduced emissions from those products significantly. Many products have useful (real, not calculated) thermal efficiencies greater than 80 % and emissions well below the Ecodesign limits currently in force. Whilst the SFLSH industry is supportive of driving down emissions and improving efficiency, CEFACD recommends that a larger impact can be made immediately by encouraging replacement of older technology and open fires. Good existing products already make a significant impact on reducing emissions and alleviating fuel poverty by replacing older technology. Proper legislation would encourage consumers to replace older appliances with more efficient ones. It is against these concerns that we make our further technical comments in the following sections: a) Political context, evaluation, problem definition, and subsidiarity check b) Objectives and policy options c) Likely impact Please refer to the attachment for our a detailed elaboration of our comments and recommendations.
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Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

CEFACD is the European industry association representing manufacturers of local space heaters (LSH) and cooking appliances. We support the need to keep legislation up-to-date and in line with the latest technological developments. In that light, we welcome the Commissions efforts and proposal to repeal and replace the Ecodesign Directive 2009/125/EC with an ESPR. Energy-related Products (ErP) have been subject to ecodesign requirements since 2009. As such, ErPs have been successfully regulated in product-specific regulations in terms of their energy efficiency, and since 2016 2019 also increasingly in terms of their material efficiency. In our paper attached to this message, we react to the Call for Evidence on the product group prioritisation under the ESPR. We would like to highlight and recommend that: 1. EpRs are already prioritised by default through their review clauses; 2. Maintain product-specific approaches to optimise circular economy; and 3. Avoid duplication of rules and contradictory requirements.
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Response to Ecodesign requirements for local space heaters (review)

18 Apr 2023

CEFACD is the European industry association representing manufacturers of local space heaters (LSH) and cooking appliances. We support the need to keep legislation up-to-date and in line with the latest technological developments. In that light, we appreciate the European Commissions openness to receiving comments from stakeholders concerning the review of Ecodesign Regulation (EU) No 2015/1188 for local space heaters (ENER Lot 20). Nonetheless, we are concerned with the measures proposed for gaseous LSH. This paper presents our recommendations for improving the requirements, so that clarity is created and the envisaged objectives of the regulation can be achieved. 1. Replace the term 'seasonal efficiency' for LSH by 'nominal efficiency' 2. Correct or further substantiate the energy efficiency formula for LSH 3. Strengthen the correction factors to encourage energy efficiency 4. Ensure granularity for LSH Our points are further explained in the attachment.
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Response to Promoting sustainability in consumer after-sales

4 Apr 2022

CEFACD, representing domestic and local space heating manufacturers, appreciates the possibility to provide feedback to the European Commission's Sustainable Consumption of Goods Initiative (SCGI). Nonetheless, CEFACD would like to raise some concerns and offer recommendations in order to optimise the efficiency of the SCGI in relation to other policies that are also addressing material efficiency and sustainability. The main aspect of our views is that HVACR equipment should be outside the objectives of the SCGI. The reason is that HVACR are already covered by Ecodesign and Energy Labelling requirements and that double regulation, with the possibility of contradicting requirements, should be avoided. Recommendations: 1) HVACR equipment is long-lasting and repairable 2) Avoid overlaps with existing legislation, e.g., the Ecodesign Directive 3) Product-specific requirements for HVACR equipment under the Ecodesign Directive 4) Include importance of training and certification. Our recommendations are further elaborated and explained in the enclosed position paper.
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Response to Revision of EU rules on Gas

30 Mar 2022

CEFACD as the voice of individual heating and cooking appliances welcomes the European Commission’s proposals (regulation and directive) for a new EU framework to decarbonise gas markets and promote hydrogen (the Gas and Hydrogen Package). The European local space heaters (LSH) industry plays a key role in the European energy transition by its ability to reduce carbon emissions in European households. LSHs are an energy efficient and affordable way to achieve the EU climate objectives, which contribute to reducing energy poverty. CEFACD s is currently supporting the European Green Deal by improving appliances that support increasing renewable energy in the system. In particular, the LSH industry is upgrading its gas appliances to lower their carbon footprint in heating. CEFACD welcomes the uptake of biogas which is already happening in some countries on a large scale. It is also increasingly using hydrogen and gas blends (within the existing gas infrastructure) and aims to develop fully hydrogen powered appliances in the near future. Against this background, CEFACD believes that the proposal for the Gas and Hydrogen Package should be more ambitious on local use of low-carbon and renewable gases and would like to outline key aspects that need to be considered in the proposal for a new gas and hydrogen framework. Please find attached our position paper on the Gas and Hydrogen Package.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

CEFACD as the voice of the local space heating (LSH) industry welcomes the European Commission’s ambition to achieve a zero-emission building stock by 2050. LSH can support this ambitious target by increasing renewable energy use in heating, especially for vulnerable consumers. LSH are both affordable and user-friendly devices, which can be easily installed in peoples’ homes. Consequently, they can offer an immediate contribution to the energy transition compared to the modernisation of heating networks. Moreover, their functionality encourages climate conscious behaviours, by heating dwellings only when needed. Flexibility of switching LSH off when they are not required and adjusting their usage to rooms where necessary, helps to cut energy cost. It is especially crucial for households that are impacted by rising cost. CEFACD and its members are committed to the energy transition by improving their appliances and ensuring they can increasingly run on renewable energy. Against this background, they see the revision of the Energy Performance of Buildings Directive (EPBD revision) as a step in the right direction to improve residential energy use. CEFACD would like to outline key areas that need to be considered in the revision to ensure it is fit for purpose. In particular, it needs to take into account all technologies available and be implemented in an affordable way in order to leave no one behind. Please find attached our position paper and proposals to consider on the EPBD revision.
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Response to Energy labelling requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans [review]

17 Feb 2022

CEFACD, the European association representing manufacturers of individual heating and cooking appliances, is a strong supporter of the European Commission’s energy labelling framework and welcomes the initiatives to keep product requirements in line with the latest technological and market developments. Nonetheless, we are concerned about the fact that the European Commission is considering the merger of the energy labelling classes under ENER Lot 10 (air-to-air heat pumps, air conditioners, and comfort fans) and ENER Lot 20 (local space heaters). As such, CEFACD would like to voice the following concerns. First, the products within the scope of ENER Lots 10 and 20 are incomparable nor interchangeable for customers, since they provide different functionalities (i.e., purposes), have highly different heating capacity rates, impose different installation requirements, and have different costs. Lumping them together would lead to consumer confusion by falsely giving the impression that these product groups are interchangeable Moreover, the current energy labelling classes for different heating categories already allow customers to choose the most energy efficient product within the product groups that are most suitable for their specific purposes. Merging the energy labelling classes will move away from the purpose of this policy instrument and render it useless as a comparison tool. Also, the consumer study shared with stakeholders on 16 June 2021 does not provide clear-cut answers on the benefits of merging the energy labels. Granularity is needed in order to differentiate the different product groups to allow for optimal choices for specific purposes. It is also important to note that manufacturers are incentivised to continuously develop and improve their product performance if those improvements can achieve a movement between the energy labelling class bandwidths. The risk of merging the energy labelling schemes is that part of this incentive will be removed, since the energy labelling classes will each be so broad that redeveloping appliances to become more energy efficient would not anymore lead to an improvement in the energy labelling class; please note that it may take several months of research and development to improve a product efficiency 3 – 5 percentage points, which is a realistic improvement and step forward in technology. This undermines the whole philosophy of energy labelling, which is to drive manufacturers to continually improve the technology in their appliances without making them cost prohibitive to their customers. Therefore, the products covered in ENER Lot 20 cannot be subject to a combined energy labelling class with products covered under ENER Lot 10.
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Response to Ecodesign requirements for local space heaters (review)

17 Feb 2022

CEFACD, the European association representing manufacturers of individual heating and cooking appliances, is a strong supporter of the EU ecodesign framework and agrees with the Commission’s objective to maintain product requirements updated in line with the latest technological and market developments. As such, we are pleased to see that the Commission is moving forward on the review of the ecodesign requirements for local space heaters (ENER Lot 20). Nonetheless, we are concerned about the points raised in the Call for Evidence for an Impact Assessment. It is important to clarify that an “open local space heater” refers to an appliance where the combustion chamber and firebed are not sealed to the room in which the appliance is located. The appliance could be either completely open or glass fronted. In any case, it is connected directly to an existing chimney or prefabricated flue system that transitions the products of combustion to the outside of the building. A “closed local space heater” refers to a balanced flue appliance whereby the combustion chamber and firebed are completely sealed to the room in which the appliance is located. The air for combustion is taken into the appliance from outside of the building via the outer chamber of a concentric flue pipe system with the products of combustion exiting through the inner concentric chamber in the flue system. The latest Commission proposal suggests that open LSH efficiency with a glass front should be included in the closed LSH requirement with a minimum efficiency requirement of 72 %. They would therefore require an actual minimum efficiency of 82 %. This is unrealistic for such products, and the target should be set at 65 % with open-fronted LSH remaining at 42 %. Please note that if this target is not revised, it will result in this appliance type being withdrawn from the market and this will preclude installation into social housing, where most do not have the option of installing a balanced flue appliance due to their structure. Closed LSH should remain at the current minimum requirement of 72 %. Achieving higher efficiencies will start to create condensation as a by-product of cooler flue systems. This could lead to a dangerous situation whereby the safety of the appliance has been compromised by corrosion or, indeed, leads to nuisance issues where the moisture affects the electronic control systems employed on some of these appliances. Furthermore, we propose that open-fronted LSH, which do not have a glass panel and are completely open, should be phased out. They are typically much lower in efficiency and this cannot be ignored. As such, CEFACD supports the gradual removal of this product type, noting that timescales should be agreed, so as not to suddenly withdraw the product type. This would allow manufacturers to develop and build a portfolio of alternative higher efficiency appliances and would give customers more time to consider alternative appliance types. To clarify, this would create three appliance categories with the eventual elimination of the first category: - Open Combustion LSH with no Glass Front – Minimum Seasonally Adjusted efficiency – 42% - Open Combustion LSH with a Glass Front – Minimum Seasonally Adjusted Efficiency – 65% - Closed Combustion LSH (Balanced Flue) – Minimum Seasonally Adjusted Efficiency – 72% Further information can be found in our position paper, which is attached to our comments.
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