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Electric Underfloor Heating Alliance

EUHA

The Electric Underfloor Heating Alliance (EUHA) represents European manufacturers of electrical underfloor heating and their immediate supply chain.

Lobbying Activity

Meeting with Robert Nuij (Head of Unit Energy) and Grayling

10 Oct 2025 · Exchange on ongoing revision of the EU energy label for local space heaters and harmonisation of labels for heating appliances. Input into Implementation Dialogue

Response to Electrification Action Plan

9 Oct 2025

The Electric Underfloor Heating Alliance (EUHA) welcomes the opportunity to contribute together with the European Infrared Heating Alliance (EIHA) to the European Commission's consultation on the Electrification Action Plan. Our detailed position is provided in the attached document. Below we summarise our key messages and recommendations: The Action Plan must be system-centred and technology-neutral approach rather than focused on outdated appliance-level metrics. - Primary Energy Factor (PEF) methodologies and retail tariff structures (including taxation, network charges and non-energy levies) should be adjusted and promoted to reflect grid decarbonisation and time-of-use value - Energy labelling and ecodesign frameworks must be adapted, either through dedicated methodologies or via allowing system-level assessment routes, so that consumer information reflects heat delivered and real-world performance. - Reforming retail electricity pricing, taxation and network charging structures to remove distortions that currently penalise electrification and to create fairer cost comparisons with fossil fuels. - The Action Plan should support pilots and demonstrators that connect direct electric heating to aggregators, local storage and demand-response platforms and promote smart-tariff trials that value pre-heating and other flexible operation modes. - The Action Plan should reduce burdens to SME, by developing harmonised and proportionate compliance rules, and enhancing digitalised administrative processes and targeted manufacturing support.
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Response to Heating and cooling strategy

9 Oct 2025

The Electric Underfloor Heating Alliance (EUHA) welcomes the opportunity to contribute together with the European Infrared Heating Alliance (EIHA) to the European Commissions consultation on the upcoming Heating and Cooling Strategy. Our detailed position is provided in the attached document. Below we summarise our key messages and recommendations: The Strategy should explicitly recognise direct electric heating naming electric underfloor and infrared heating as valid, strategic decarbonisation options. Energy labelling and ecodesign frameworks must be adapted, either through dedicated methodologies or via allowing system-level assessment routes, so that consumer information reflects heat delivered and real-world performance. Primary Energy Factor (PEF) methodologies and retail tariff structures (including taxation, network charges and non-energy levies) should be adjusted and promoted to reflect grid decarbonisation and time-of-use value. The Strategy should support pilots and demonstrators that connect direct electric heating to aggregators, local storage and demand-response platforms and promote smart-tariff trials that value pre-heating and other flexible operation modes. The Strategy should reduce burdens to SME, by developing harmonised and proportionate compliance rules, and enhancing digitalised administrative processes and targeted manufacturing support.
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Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

The Electric Underfloor Heating Alliance (EUHA) supports the need to keep legislation up-to-date and in line with the latest technological developments. We believe that technological progress coupled with the current climate crisis necessitates measures that go beyond energy efficiency by including stringent sustainability, material, and resource efficiency requirements. 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 the 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) ErPs are already prioritised by default through their review clauses; 2) to maintain product-specific approaches to optimise circular economy; and 3) to avoid duplication of rules and contradictory requirements.
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Response to Energy labelling requirements for local space heaters (review)

31 Aug 2022

The Electric Underfloor Heating Alliance (EUHA) unites manufacturers to promote the interests of the product sector within a new electrified smart grid infrastructure. We support the review of European energy labelling policies in line with technological and market developments. As such, we are strongly opposed to the proposed merger of energy labelling scales under ENER Lots 10 (air-to-air heat pumps, air conditioners, and comfort fans) and 20 (local space heaters). In our 22 June 2022 position paper, we elaborated the following concerns: 1) Local space heaters and air conditioners are incomparable products. 2) Merging different energy labels will not enable consumers to make informed purchase decisions. 3) Smart local space heaters provide the potential of flexible grid management. 4) Incentivising investment and innovation are needed and fostered by split energy label scales. 5) A level playing field and technology neutrality are ensured by split energy label scales. Building on the 22 June 2022 joint industry paper, we have elaborated further concerns: 1) The consumer study cannot predict real-life effects of a merged energy label scale; 2) The consumer study is based on the response of only 50 % of the interviewees; 3) The study ignores the supply aspects of the market; and 4) The consumer study does not consider that existing buildings do not always offers the conditions for switching between heating appliances types. Attached you can find our latest position paper. Our paper also offers a proposal for aligning the energy labels with technological and market developments, whilst optimising energy efficiency and savings.
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Response to Sustainable Products Initiative

22 Jun 2022

The Electric Underfloor Heating Alliance (EUHA) supports the need to keep legislation updated and in line with the latest technological developments. In that light, we appreciate the European Commission’s proposals for an Ecodesign for Sustainable Products Regulation (ESPR). We believe that technological progress coupled with the current climate crisis necessitates measures that go beyond energy efficiency by including stringent sustainability, material, and resource efficiency requirements. Nonetheless, we are concerned with certain elements that may bypass the potential offered by the ESPR as tool to achieve sustainability while simultaneously strengthening the European economy. As such, we recommend the following: 1. Align definitions with existing legislation: remove redundancies and avoid loopholes; 2. Further explanation needed for the Digital Products Passport; 3. Ensure that substances of concern are selected by experts on the subject; 4. Improve the labelling requirements by making them streamlined and more sustainable; 5. Avoid disclosing of skewed competitively sensitive information on unsold goods; 6. Remove data duplication to support market surveillance; 7. Support for anti-circumvention clauses; 8. Include customs in the surveillance system to support market surveillance; 9. Ensure that standards are being followed, and not the other way round to avoid loss of expertise and inconsistencies; and 10. Avoid one-size-fits-all and maintain specific considerations for ErP groups. Our recommendations are further elaborated in the enclosed joint industry position paper.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

The Electric Underfloor Heating Alliance (EUHA) welcomes the Commission’s ambition to achieve zero-emission buildings (ZEBs) by 2050. We strongly believe that local space heaters (LSH), especially electric underfloor heaters, can contribute to these objectives as a result of their characteristics and relatively easy installation. As a result, LSH can directly foster the uptake of modernised heating networks as part of the currently ongoing energy transition. We believe that the revision of the Energy Performance of Buildings Directive (EPBD) is indispensable for the achievement of Europe’s climate objectives, fostering economic growth, supporting comfort and wellbeing of building users, while simultaneously decoupling from the use of fossil fuels. As such, we have the following main messages: 1) Support for the complete electrification of heating 2) Recommendation for additional strengthening of zero-emission buildings by lowering the PEF coefficient for local space heaters and by accepting all types of renewable energy sources 3) Support for the proposed Minimum Energy Performance Standards 4) Recommendation to include Indoor Environmental Quality in the Energy Performance Certificates 5) Support for the smartness and digitalisation of heating Please see our enclosed position for a further elaboration on our recommendations.
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Response to Ecodesign requirements for local space heaters (review)

17 Feb 2022

The Electric Underfloor Heating Alliance (EUHA) 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. We would like to raise points of concern regarding the proposals on slave heaters, the Primary Energy Factor (PEF), and the Circular Economy objectives. Slave heaters Concerning slave heaters, the EUHA disagrees with the statement that the exemption of slave heaters as such has resulted in a loophole. The possibility of a loophole lays not in the exemption itself, but in the description and further explanation of the exemption in the FAQ for the ENER Lot 20 requirements. The exemption should only apply to heaters that do not have an integrated controller and need to receive signals from an external controller, such as an underfloor heater with a separately sold and packaged controller. This means that the exemption does not apply to local space heaters that are sold together, in one kit or package, with a controller. The reason for this is that only suppliers can be affected by ecodesign requirements, which apply to electric local space heaters and not the individual components or parts of the system. Primary Energy Factor (PEF) One general PEF does not reflect the reality for a particular installation. Locally at a site, the PEF can be 1, or 1.2, or 2.5, etc.; it changes per country, market, and conditions for the particular installation. Using one PEF from the Energy Efficiency Directive is easily misleading, and when used as a basis it creates a non-scientific and possibly confusing system. The PEF is continuously changing as we move away from coal and fossil fuels to create electricity. The PEF factor is evolving along with the way the energy is produced. With the increase of investments in renewable energy, it is becoming more interesting to use this energy for heating and for comfort applications, such as underfloor heating. This is one of the ways to achieve decarbonized heating in the future. Adapting correction factors for a changing PEF do not make sense, as this would mean that some technologies are penalised for the wrong reasons. The PEF should reflect reality and correction factors should not overrule this reality. Circular Economy objectives The 2019 Viegand Maagøe study did not recommend introducing material and resource efficiency requirements in the current revision. Nonetheless, the EUHA acknowledge that material and resource efficiency requirements are only a part of the broader Circular Economy discussion on product lifecycle and Product Environmental Footprint (PEF). As such, EUHA recommends that: - Material and resource efficiency requirements for electric underfloor heating should focus primarily on upgradability, due to the nature of the product as a durable long-lasting investment. We recommend focussing on controls, as this is where most upgrades can be realised in the long lifetime of electric underfloor heating. Prioritising reparability would come at the expense of upgrades of controls, which could deliver the actual energy efficiency savings. - Concerning spare parts, we propose that electric underfloor heating suppliers shall make available to professional repairers the following spare parts: electronic timers, displays, thermostats, switches and buttons, wirings, plugs, and remote controls. We also suggest adding repair kits for cables, which means that is will become possible to repair a damaged installation without the need of removing or opening up a floor and that a cable can be repaired without the need of replacement.
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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

The Electric Underfloor Heating Alliance (EUHA) welcomes the Commission’s initiatives to review the energy labelling policies to keep them updated and aligned with the latest technological developments. Nonetheless, we strongly disagree with the European Commission’s consideration to merge 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). First, the products within the scope of ENER Lots 10 and 20 are incomparable: lumping them together would lead to skewed results by giving the impression that they are interchangeable. Local space heaters and air-to-air heat pumps are not interchangeable for customers, since they provide different functionalities (i.e., purposes), have highly different heating capacity rates, impose different installation requirements, and bear different costs. As such, the products covered in ENER Lot 20 (storage heaters, radiant heaters, electric underfloor heaters, etc.) have a different way of operating than the products covered by ENER Lot 10. Second, merging the energy labels will reduce the active energy classes down compared to totally different heating technologies. Consumers will obtain less information on what the best appliance of a specific product group is. At best, this will confuse the consumer, and we believe it will limit the incentive to invest in improving the energy performance of heating. Third, 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. This is why the EUHA strongly believes that the products covered in ENER Lot 20 cannot be subject to a combined energy labelling class with products covered under ENER Lot 10. More information can be found in the Joint Industry Position Paper dated 15 September 2021, attached to this feedback input.
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