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European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers

EUROVENT

Eurovent is a leading European association representing manufacturers in the heating, ventilation, air conditioning, and refrigeration sectors.

Lobbying Activity

Eurovent seeks Taxonomy recognition for B2B cooling equipment

22 Nov 2025
Topic — The initiative reviews technical screening criteria within the EU taxonomy environmental delegated act.
Message — Eurovent requests alternative efficiency benchmarks for B2B products lacking EU Energy Labels. They propose targeting "significantly populated" classes to ensure stable sustainability reporting.12
Why — This change would allow manufacturers to attract green investment through their sustainability reports.34
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HVAC industry seeks incentives and harmonised EU circularity standards

5 Nov 2025
Topic — The EU is consulting on a Circular Economy Act to promote sustainable production and recycling.
Message — They demand harmonised EU definitions and standards for circular design to ensure fair competition. The association requests financial incentives and subsidies to make circular business models economically viable. They advocate for an all-actors approach where recycling responsibilities are shared across the entire supply chain.123
Why — Harmonisation and shared responsibility would reduce the regulatory and financial burden on manufacturers.45
Impact — Installers and scrap dealers would face new reporting requirements and higher compliance costs.6
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Eurovent calls for harmonized EU building emission calculation rules

15 Oct 2025
Topic — The European Commission is establishing a framework for calculating life-cycle emissions of new buildings.
Message — The industry group requests that product data from Ecodesign regulations be used exclusively for building emission calculations. They urge the EU to prevent national authorities from imposing additional or divergent sustainability reporting requirements.12
Why — Harmonized data requirements would reduce administrative burdens and ensure a level playing field.3
Impact — National regulators lose the authority to impose stricter sustainability information requirements for products.4
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Meeting with Rosalinde Van Der Vlies (Director Energy) and

8 Oct 2025 · The role of sustainable cooling in heating and cooling

Eurovent urges EU to treat cooling as distinct policy priority

7 Oct 2025
Topic — The EU is drafting a strategy to accelerate the decarbonisation of heating and cooling.
Message — Eurovent requests that the upcoming strategy treats cooling as distinct from heating to address skyrocketing demand. They propose updating ecodesign standards and providing financial incentives for energy-efficient cooling solutions.123
Why — This would strengthen the global competitiveness and market dominance of European manufacturers.4
Impact — Producers of sub-standard equipment would face exclusion through significantly stricter market surveillance.5
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Meeting with Robert Nuij (Head of Unit Energy)

2 Oct 2025 · Exchange of views on ecodesign and energy labelling policy, in particular as regards refrigerating appliances

Meeting with Robert Nuij (Head of Unit Energy)

2 Oct 2025 · Exchange of views on ecodesign and energy labelling policy, in particular as regards refrigerating appliances

HVAC Industry Backs Carbon Tax Extension for Heating Equipment

26 Aug 2025
Topic — A consultation on expanding the Carbon Border Adjustment Mechanism to downstream steel and aluminium products.
Message — The industry cautiously supports extending carbon taxes to final heating and cooling products to ensure fair competition. They request using existing environmental declarations to measure carbon content and keep administrative burdens manageable.123
Why — This would level the playing field against foreign manufacturers who do not face high EU carbon costs.4
Impact — Non-EU manufacturers lose their current price advantage while European exporters may face retaliatory taxes.56
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Eurovent urges EU to scrap common specifications proposal

19 Aug 2025
Topic — An initiative to align European product legislation with digital-by-default industry practices.
Message — Eurovent urges the Commission to withdraw its proposal for common specifications. They support digital-by-default practices but want a single-entry point for compliance.12
Why — Withdrawing common specifications prevents extra financial burdens and maintains global competitiveness.3
Impact — Regulators lose a reliable fallback mechanism to maintain safety when standards fail.4
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Response to Energy labelling of low temperature heat emitters

28 Jul 2025

Eurovent provided the study consultant with a set of technical comments on the interim preparatory study report. The comments provided at that time are confirmed and constitute the technical background for the negative opinion on the inclusion of fan coil units expressed hereafter. The interim preparatory study is proposing to adopt the European standard for radiators and convectors (EN 442) to specify the technical requirements and assess the performance of fan coil units, even if for fan coil unit performances there are already dedicated European standards (EN 1397 and EN 16583). While the proposed test still remains interesting, the scope of application of fan coil units also did not accurately reflect the reality of installations, as it is focused exclusively on home renovations. In general, Eurovent believes that fan coil units differ from other low temperature emitters with natural or forced convection, which are the subject of the study published in December 2024; therefore, it is wrong to include fan coil units among the products covered by the study. Consequently, the evaluation of an Energy Label for a product that should not be considered together with the others is not useful, given that the applicable standards are different from those indicated by the study. Moreover, the explicit reference in the document to the combination of low temperature heat emitters with heat pumps further reinforces the lack of need for new standards for fan coil units: the performance of fan coil units is already aligned with that of heat pumps in terms of water-side temperature range (in the case of heating, 45-40°C for fan coil units and 40-45°C for heat pumps). It is not needed to establish other temperature ranges and ΔT values. The official Eurovent position paper is attached.
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Meeting with Aurel Ciobanu-Dordea (Director Environment)

23 Jul 2025 · Exchange of views on the Circular Economy Act and the WEEE review

Response to Revised EU energy labelling for refrigerating appliances with a direct sales function

20 Jun 2025

Eurovent has recently received the results of the market analysis based on sales for 2023-2024 and is currently evaluating them. Therefore, detailed feedback and comments will be presented as soon as possible, together with an appropriate analysis of the EPREL results. The feedback prepared after the first stakeholder meeting on 20 March 2025 (PP-2025-04-16) is published in the attachment.
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Response to Revised ecodesign requirements for refrigerating appliances with a direct sales function

20 Jun 2025

Eurovent has recently received the results of the market analysis based on sales for 2023-2024 and is currently evaluating them. Therefore, detailed feedback and comments will be presented as soon as possible, together with an appropriate analysis of the EPREL results. The feedback prepared after the first stakeholder meeting on 20 March 2025 (PP-2025-04-16) is published in the attachment.
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Eurovent calls for including indoor air quality in cost-optimal calculations

7 May 2025
Topic — The Commission is revising the methodology for calculating minimum energy performance for buildings.
Message — Eurovent argues that the cost-optimality framework must account for positive effects on indoor environmental quality. They request clear guidance for monetising health-related benefits like improved productivity and quality of life.12
Why — Broader assessments would demonstrate that Eurovent's high-efficiency climate systems are more cost-effective.3
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Meeting with Niels Ladefoged (null Energy)

6 Mar 2025 · Meeting to present Eurovent and discuss different policy issues

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

20 Feb 2025

Eurovent is the voice of the European HVACR industry, representing over 100 companies directly and more than 1.000 indirectly through our 16 national associations. We welcome the inclusion of the heat pump industry as a net zero technology and would like to include additional primarily used components. Eurovent suggests considering the addition of the following primary components: - Valves (expansion,Schrader, shut-off etc.) - Fans (according to EU 2024/1834) - Compressors - Heat exchangers - Inverter technology - Pumps Explanation: Valves ensure optimal performance and energy efficiency. Expansion valves are primarily used components, specific to heat pumps. They ensure the regulation of the refrigerant cycle within heat pumps. Electronic pressure-independent valves with energy monitoring and dynamic hydraulic balancing are also essential for heat and cooling network technologies. In the distribution systems, hydraulic balancing has the greatest influence on the dimming of the generator and the energy efficiency and comfort of the whole system. Fans are a primary used component of heat pumps. They convey air through the heat pump, mainly via the heat exchanger, overcoming the internal pressure losses of the heat pump. Fans play a critical role in optimizing the heat transfer within heat pumps, specifically the air source systems. Compressors are predominantly used in heat pumps and refrigeration technologies as a key component for controlling the refrigerant cycle in heat pumps. Heat exchangers are critical to the operation of heat pumps. While it may not be exclusively used in heat pumps, it is a critical part of heat pumps.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

We welcome the inclusion of the heat pump industry as a net zero technology and would like to include additional primarily used components. Eurovent suggests considering the addition of the following primary components: - Valves (expansion,Schrader, shut-off etc.) - Fans (according to EU 2024/1834) - Compressors - Heat exchangers - Inverter technology - Pumps Explanation: Valves ensure optimal performance and energy efficiency. Expansion valves are primarily used components, specific to heat pumps. They ensure the regulation of the refrigerant cycle within heat pumps. Electronic pressure-independent valves with energy monitoring and dynamic hydraulic balancing are also essential for heat and cooling network technologies. In the distribution systems, hydraulic balancing has the greatest influence on the dimming of the generator and the energy efficiency and comfort of the whole system. Fans are a primary used component of heat pumps. They convey air through the heat pump, mainly via the heat exchanger, overcoming the internal pressure losses of the heat pump. Fans play a critical role in optimizing the heat transfer within heat pumps, specifically the air source systems. Compressors are predominantly used in heat pumps and refrigeration technologies as a key component for controlling the refrigerant cycle in heat pumps. Heat exchangers are critical to the operation of heat pumps. While it may not be exclusively used in heat pumps, it is a critical part of heat pumps.
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Response to Ecodesign requirements for air heating and cooling products (review)

30 Aug 2024

Eurovent with the attached paper provides some input to the public Call for Evidence on the revision of the lot 21. The paper in particular focuses on: - The importance of the new F-Gas regulation for the future development of the units - Eurovent proposal for A/A process and IT cooling - Eurovent proposal for VHT process chillers - Current landscape of free cooling - Heat recovery and simultaneous heating and cooling for polyvalent units and VRF - A proposed new definition for rooftop unit - A reminder of the situation of reversible hydronic heat pumps up to 1 MW Who is Eurovent Eurovent is the voice of the European HVACR industry, representing over 100 companies directly and more than 1.000 indirectly through our 16 national associations. The majority are small and mediumsized companies that manufacture indoor climate, process cooling, and cold chain technologies across more than 350 manufacturing sites in Europe. They generate a combined annual turnover of more than 30 billion EUR and employ over 150.000 Europeans in good quality tech jobs. Transparency Eurovents structure rests upon democratic decision-making procedures between its members and their representatives. The more than 1.000 organisations within the Eurovent network count on us to represent their needs in a fair and transparent manner. Accordingly, we can answer policy makers questions regarding our representativeness and decisions-making processes as follows: At Eurovent, the number of votes is never determined by organisation sizes, country sizes, or membership fee levels. SMEs and large multinationals receive the same number of votes within our technical working groups: 2 votes if belonging to a national Member Association, 1 vote if not. In our General Assembly and Eurovent Commission (steering committee), our national Member Associations receive two votes per country. The Eurovent Commission acts as the associations steering committee. It defines the overall association roadmap, makes decisions on horizontal topics, and mediates in case manufacturers cannot agree within technical working groups. The Commission consists of national Member Associations, receiving two votes per country independent from its size or economic weight. More than 90 per cent of manufacturers within Eurovent manufacture in and come from Europe. They employ around 150.000 people in Europe largely within the secondary sector. Our structure as an umbrella enables us to consolidate manufacturers' positions across the industry, ensuring a broad and credible representation. Eurovent represents more than 1.000 companies of all sizes spread widely across 20+ European countries, which are treated equally. As each country receives the same number of votes, there is no leading country. Our national Member Associations ensure a wide-ranging national outreach also to remote locations.
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Response to Verification of suppliers and other operational aspects for the functioning of product database - EPREL

20 Nov 2023

While appreciating the work done by the European Commission, Eurovent provides in the attached document comments on draft Draft implementing regulation - Operational details for the functioning of EPREL and the product database
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Response to Regulatory measure on the review of ecodesign requirements for industrial fans

3 Nov 2023

While appreciating the work done by the European Commission, Eurovent and European AMCA provide in the attached document comments on draft ecodesign requirements for industrial fans (review).
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Eurovent demands regulatory break for heat pump manufacturers

26 May 2023
Topic — European Commission initiative to accelerate the deployment of heat pumps across the EU.
Message — Eurovent calls for a regulatory break to give manufacturers time to adapt to new rules. They request a renewed dialogue to ensure policies are practicable and avoid supply chain disruptions. The industry also wants all heat pump technologies included in renewable energy accounting.123
Why — A regulatory pause would reduce the compliance burden and uncertainty for European heating manufacturers.45
Impact — European citizens may face higher costs and fewer heating choices due to demanding regulations.6
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

Eurovent represents the European Industry of Indoor Climate (HVAC), Process Cooling, and Food Cold Chain Technologies. With this paper, Eurovent wishes to convey four main points to feed into the definition of priorities for the new Ecodesign for Sustainable Products Regulation: - The review of existing implementing measures should not be deprioritised - The focus for HVACR products should remain on energy performance - Requirements should be set product group by product group - Due diligence aspects should not be included under Ecodesign The full justification is provided in the paper submitted herewith.
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Response to Energy labelling requirements for local space heaters (review)

3 Aug 2022

Having reference on the Call for evidence on Energy labelling requirements for local space heaters (review) and following the Consultation Forum for the revision of the Energy Labelling Regulation on air-to-air conditioners and heat pumps, local space heaters and comfort fans, held by DG ENERGY on 24 June 2022, please find enclosed the Eurovent position.
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Eurovent warns steep HFC phase down threatens heat pump roll out

28 Jun 2022
Topic — Review of EU rules on fluorinated greenhouse gases used in refrigeration and air-conditioning.
Message — Eurovent requests maintaining current HFC phase down steps until 2030 and calls for the removal of additional product bans for heat pumps. They also seek exemptions for fixed double duct air conditioners and better definitions for technical terms.123
Why — This would give manufacturers more time for research and development while protecting the affordability of their products.45
Impact — The environment loses as fossil fuel appliances may remain in the market longer due to slower heat pump adoption.6
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Response to Sustainable Products Initiative

22 Jun 2022

Eurovent supports the Ecodesign Regulation for Sustainable Products proposal. Product sustainability must be addressed in harmonised way across the EU to ensure the free movement of products within the Single Market. For the new Ecodesign framework to be as successful as possible while stimulating innovation and preserving the competitiveness of European industry, Eurovent makes the following recommendations: 1. Avoid overlaps and double regulation. 2. Specify requirements product group by product group. 3. Allow sufficient lead times and predictability before requirements come into force. 4. Ensure proper stakeholder consultation and evidence-based decision-making. 5. Use harmonised European standards rather than common specifications. 6. Avoid third-party conformity assessment if not strictly justified. 7. Implement the Digital Product Passport respecting proportionality. More details in the paper attached.
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Response to Ecodesign requirements for water heaters and tanks (review)

30 Mar 2022

Eurovent would like to thank for the opportunity of providing feedback following the Call for Evidence for an Impact Assessment on Ecodesign and Energy Labelling (review) for LOT 1-2. The Eurovent comments and positions are reported in the attached document.
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Response to Energy labelling requirements for space and combination heaters (review/rescaling)

30 Mar 2022

Eurovent would like to thank for the opportunity of providing feedback following the Call for Evidence for an Impact Assessment on Ecodesign and Energy Labelling (review) for LOT 1-2. The Eurovent comments and positions are reported in the attached document.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

Eurovent, the European Industry Association for Indoor Climate, Process Cooling, and Food Cold Chain Technologies, is grateful for the opportunity to submit feedback on the proposal for a recast Energy Performance of Buildings Directive. The proposal is positive overall. It ups the ambition level and seeks to address many of the shortcomings of the current Directive. An ambitious EPBD that enables the objectives of the Renovation Wave is essential to meet the EU’s decarbonisation objectives and unlock the co-benefits of building renovation. Eurovent supports the move to Zero Emission Buildings with clearly defined maximum thresholds (Articles 2 and 7, Annex III), the introduction of EU-wide MEPS based on harmonised energy scales (Article 9), renovation passports which indicate health and comfort co-benefits (Article 10), mandatory indoor air quality (IAQ) monitoring and control devices in new buildings and major renovations (Article 11), making the smart readiness scheme mandatory for large non-residential buildings (Article 13), energy performance certification reform, including more harmonised energy classification, public EPC databases, and tighter quality controls (Articles 16, 17, 18, 14, Annexes V and VI), the addition of ventilation in scope of mandatory inspection requirements (Article 20), moving towards (sub)hourly energy calculation methods (Annex I), the reference to EN 16798-1 (Annex I), and the stipulation that product information requirements per Ecodesign shall be sufficient for energy performance calculations (Annex I). That said, more clarification in the definitions and metrics is required, health and well-being aspects remain underdeveloped, and more must be done to harmonise energy calculation methods. Eurovent makes the following recommendations: 1. Base Zero-Emission Building requirements on relevant decarbonisation metrics 2. Include health and well-being indicators in National Building Renovation Plans 3. Mandate Member States to define IEQ requirements and ensure transposition 4. Include IEQ and ventilation-specific aspects in inspections of HVAC systems 5. Better define IAQ monitoring and control devices and their functionality 6. Add IEQ indicators to the optional elements in the EPC template 7. Create a common European calculation methodology for energy performance Please refer to the full paper attached for further elaboration, including proposed amendments.
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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

Eurovent has already provided the EC with its comments on the review of the Commission Regulations (EU) 206/2012 and (EU) 626/2011 with a set of Position Papers. The comments remain. Eurovent would like to reiterate and reinforce its positions as already presented in its past Position Papers, the below (non-exhaustive) list summarises them (we recommend to carefully re-assess our past position papers): Single and double duct units (both fixed and portable): o Keep the actual testing method as defined in the EN 14511 to measure cooling/heating capacity of single and double duct ACs (both fixed and portable). o Dedicated ED requirements for SD/DD fixed units as well as for SD/DD portable  Minimum requirements for single/double duct fixed unit: EER: 2,6; COP 2,6  Minimum requirements for single/double duct portable unit EER: 2,7; COP 2,2 o The Seasonal efficiency approach for portable SD, fixed SD, portable DD and fixed DD is not justified  ED and EL requirements to be based on COP and EER Energy labelling: o Define separate energy label scales for split units, double ducts unit (both fixed and portable) and single duct units (both fixed and portable) - Load-based testing methods o Keep the current testing approach and avoid any load-based testing method  The load-based testing methods cannot be applied before the next review; an early review 3 years after the publication of the revised regulation might be too optimistic considering the current status of repeatability and reproducibility of the mentioned testing methods. Implementation timing: o The implementation period is to be at least two years after the publication. The implementation date should start in January, this will allow for an easing pairing of the products’ seasonality Thermal human comfort: o The same maximum airflow limitations for both heating and cooling it is to be considered. This should provide the industry with stability, and not change with each review Scope o Units which are not designed for the comfort of human beings (e.g. close control units) are to be excluded from the scope of the regulations Review of the Energy Labelling Regulation for local space heaters The title of this initiative is “Ecodesign and energy labelling – air-to-air conditioners, air-to-air heat pumps and comfort fans (review)” Eurovent shares the objectives and policy options outlined. However, the last sentence under this item B. refers to the assessment of a further option, namely, to have a single energy label for the heating function of reversible air conditioners and local space heaters. This aspect has not been considered under item A/ Political context, problem definition and subsidiarity check. Eurovent holds it is not appropriate to address the merging of the labels that are covered by two separate regulations under this (single?) call for evidence. The Eurovent Position Paper of 15 September 2021 is enclosed. Eurovent holds that the consumer study carried out at the time was and is insufficient to motivate the merger of two labelling schemes. During the 2nd Consultation Forum held on 6 July 2021 the Chair asked why efficiency was not investigated as one of the possible ways to allow more granularity on a merged label. The authors of the study, CENTERDATA, explained that this was not within the contract for the study. Before advancing with the idea of merging both labels, Eurovent recommends undertaking a new study to understand the consumer comprehension of a label that would range from a wood or coal fired stove to an electrical heat pump. Once such a study would have been conducted, and in line with the better regulation principles, Eurovent would recommend a new and separate call for evidence is launched with a clear statement in the title of the product ranges covered. This would only be fair towards stakeholders of local space heaters, that may or may not be aware of the present call for evidence.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

19 Mar 2021

Eurovent strongly supports policy option 3 to inscribe the ambition of the Renovation Wave initiative into legislation. The review should also focus on mainstreaming indoor environmental quality (IEQ) considerations into the Directive, for which a dedicated stakeholder workshop on IEQ should be convened. Eurovent makes the following specific suggestions for improvement: - Better implement and enforce the requirements on long-term renovation strategies. - Revisit the flexibility allowed for transposition, converge towards harmonised models. - Introduce EU-wide Minimum Energy Performance Standards. - Align the Ecodesign framework and the EPBD. - Add IEQ aspects to technical building system requirements. - Make access to funds for building renovation conditional upon IEQ criteria. - Improve the EPC framework and include mandatory IEQ and SRI indicators in the EPC. - Mandate the inspection of ventilation systems, add IEQ aspects to all inspections. - Include information requirements related to IEQ. - Make air quality objectives explicit in the review. A more detailed breakdown of the suggestions can be found in the Position Paper attached.
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Response to Revision of EU Ambient Air Quality legislation

14 Jan 2021

Eurovent holds that gap between the AAQ Directives and the WHO guidelines on PM2.5 must be closed, that air quality data must be disseminated to the public more effectively, and that ambient air quality legislation must be complemented with policies addressing indoor air pollution as well. More information in the document attached.
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Response to Sustainable Products Initiative

16 Nov 2020

The Sustainable Products Initiative builds upon Circular Economy Action Plan and intends to extend the scope of the Ecodesign Directive. While not addressing directly the policy objective, the revision Methodology of Ecodesign of Energy Related Products (MEErP) is paving the way for the Sustainable Products Initiative and the Circular Economy by considering the inclusion of material efficiency and ecological profile aspects (durability, re-use, repairability,…) and societal life cycle costs. Eurovent, representing the Heating, Ventilation, Air Conditioning and Refrigeration industries, believes that the revision of the MEErP can contribute towards shaping the revision of the Ecodesign Directive as it addresses the manner in which the policy objectives can be met. From the Eurovent point of view the Ecodesign directive must remain a directive that supports the Single Market based on harmonised legislation in Europe. The inclusion of the ecological profile in the future MEErP and the implementing regulations should ensure that national initiatives, that are fragmenting the European market are harmonized. The stringency level of future Ecodesign requirements should be based on the SMERC-principles: Specific, Measurable, Enforceable, Relevant and Competitive. Because of the wide variation among products, a specific case-by-case assessment, as applied today under Ecodesign must remain. The future ecodesign and/or sustainable requirements must provide for a fair competitive playing field that can count on enforceable market surveillance. When the requirements are supported by evidence, these can and will contribute to the transition towards sustainable products that fit within a circular economy. Due to the ambition level, the transition will depend also on coherence and coordination among European legislation. Possibly there could be scope for integrating different existing policy instruments. The revision of the MEErP should be available at the end of 2021 and could provide the necessary technical input to consider the shaping of the future sustainable policies. Revision MEErP: https://susproc.jrc.ec.europa.eu/product-bureau//product-groups/521/what-s-new
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Response to Energy labelling omnibus amendment of 2019 regulations

2 Nov 2020

With the enclosed Position Paper, Eurovent would like to provide the European Commission with its comments on the draft Commission Delegated Regulation amending, inter alia, the Delegated Regulation (EU) No 2019/2018, the Delegated Regulation (EU) No. 2019/2015, and the Regulation (EU) No 2019/2020.
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Response to Ecodesign omnibus amendment of 2019 regulations

2 Nov 2020

With the enclosed Position Paper, Eurovent would like to provide the European Commission with its comments on the draft Commission Delegated Regulation (EU) amending, inter alia, the Delegated Regulation (EU) No 2019/2018, the Delegated Regulation (EU) No. 2019/2015, and the Regulation (EU) No 2019/2020.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

19 Oct 2020

The EU Action Plan Towards Zero Pollution must focus on air pollution, indoor air pollution in particular. The dangers of air pollution, both outdoors and indoors, are severe, and more needs to be done to protect the right to clean air. Improving air quality goes hand in hand with decarbonisation, and the HVACR sector has major contributions to make to both.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

20 Sept 2020

Eurovent supports the further reliance on renewable energies. While outlining the future Renewable Energy Directive (RED) the implementation of the National Energy and Climate Plans (NECPs) of the member must be assessed to check if the national 2020 renewable energy targets have been achieved. Deployment of future measures in transport, heating and cooling in industry and buildings would push the development of renewables to contribute to the 2050 climate ambitions and greater greenhouse gas reductions. More details about the Eurovent feedback can be found in the attached paper.
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Response to Review of Directive 2012/27/EU on energy efficiency

20 Sept 2020

Eurovent supports the energy efficiency (EE) first principle. While outlining the future EE requirements the implementation of the National Energy and Climate Plans (NECPs) of the member must be assessed and enforcement of the NECPs be strengthened so that the EED may reach its targets. EE in the building sector can provide a major share of EE but health and cost aspects should be borne in mind. More details about the Eurovent feedback can be found in the attached paper.
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Eurovent Urges Improved F-Gas Enforcement and Technological Neutrality

4 Sept 2020
Topic — The European Commission is reviewing rules to reduce emissions from fluorinated greenhouse gases.
Message — The review should focus on avoiding circumvention of quotas and removing barriers to flammable or reclaimed refrigerants. It must maintain energy efficiency and provide a predictable schedule so industry can adapt.123
Why — Better enforcement and predictable price levels would protect compliant manufacturers from unfair competition.45
Impact — Illegal gas importers and uncertified equipment installers would face more effective market surveillance.67
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Eurovent appreciates the recognition by the Commission of the proliferation of green claims and the related measurement and assessment methods. National legislation regarding green claims exists, supported in cases by the fact that some Member States recognize specific voluntary labels. This proliferation confuses consumers and industry due to the various methods use to substantiate the claims. Due the large variety on products subject to green claims a product specific approach would make sense. The efforts to develop a common Product Environmental Footprint (PEF) did not progress beyond some pilot cases. Since then and even before publication of the Recommendation 2013/179/EU diverging approaches have taken place both at Member State and European level. Products subject to Ecodesign and Energy Labelling Regulations rely on a simplified common life cycle assessment that has been adopted successfully. Progressive insights and evolving methodologies do improve the know-how on environmental impacts. To achieve and benefit from the Single Market efforts towards a common approach across national and EU legislation would be welcome. The proliferation of various schemes does provide for diverging information on products resulting from the fact that different institutions and bodies are develop their approach in isolation. For manufacturers it is getting more difficult to meet the numerous voluntary labels that exist and that increasingly become mandatory through reference in legislation. While the Inception Impact Assessment seems to focus mainly on consumer products, it is appropriate to considers the case of Heating, Ventilation, Air Conditioning and Refrigeration (HVAC-R) products that comply with Ecodesign and Energy Labelling legislation. However, within the national transpositions of the Energy Performance of Buildings (EPBD) one sees the emergence of reference to environmental product declarations. These references find their origin in national legislation relating to the environmental performance of construction products and do differ by country. The declarations themselves rely on different assessment but tend to refer to Life Cycle Assessment to ISO 14025. In some Member States the EPBD transposition does allow for individual and collective environmental product declarations, and while voluntary these become de facto mandatory when one does not wish to rely on default values when calculating environmental performance of buildings. Because the calculation of the energy performance of buildings is not harmonized across the European Union, additional reference to environmental declarations is likely to support further proliferation of environmental methodologies. A harmonization of environmental product declarations used within the context of the EPBD would be appropriate. Lastly, and irrespective of the options that would be pursued, one should point out that any effort should be supported by adequate enforcement to ensure fair competition, supporting the reduction in environmental impacts.
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Response to Establishment of a smart readiness indicator for buildings

14 Jul 2020

Eurovent supports the modernisation of the EPBD. The transposition by the Member States has seen a proliferation of EPBD calculation models. Because physics are the same across the globe, it would have been preferable to have a harmonised EPBD calculation method complemented by objective parameters to account for local conditions. Eurovent supports the concept of a common calculation methodology for the SRI and would wish to see harmonised uniform implementation by the Member States that wish to make use of the option to introduce the SRI. Eurovent welcomes the in-depth consideration in the SRI calculation methodology of the specific features of HVAC system controls that contribute to energy efficiency and comfort. Eurovent believes that taking into account the actual performance of a building in the assessment would be most beneficial. Eurovent regrets that Article 6 of the delegated act allows that Member States may decide to modify, adapt, or terminate the implementation of the scheme at any time without providing any justification to that end. This would mean that the calculation of the SRI could vary across the EU. The possible adaptation of the standard calculation process is even further described in the Annex VII. While there may be valid reasons to include the options to adapt and modify the calculation methodology of the SRI, these options do undermine the concept of the Single Market, and may lead to proliferation of different requirements and understanding of the SRI across the EU.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

22 May 2020

Eurovent would like to provide feedback to the European Commission on the roadmap for energy efficiency in buildings. HVACR technologies play a key role in the energy performance of buildings and should be in the focus of the building renovation initiative. Buildings are the largest consumer of energy in the EU (41% TFEC) and have the most potential for emissions reductions. The technologies necessary to reach building efficiency targets are already available today. The challenge in decarbonising the building stock lies in the widespread deployment of these energy efficiency technologies in existing buildings. Funding for renovation coupled with strategies to overcome barriers to investment are needed. Building renovation is effective not just in terms of decarbonisation, but also generating growth and creating jobs. It lies at the nexus of the European Green Deal and COVID-19 recovery. The renovation of buildings in the residential sector has the most potential for energy savings. Residential buildings represent the largest share of the total building floor area in the EU (76%) and suffer from typical investment barriers. The uptake of energy efficiency technologies in the residential sector needs to be significantly scaled up. Space heating accounts for most energy use in EU households (68%). Investing in renewable sources of thermal energy for space heating can provide major emissions abatement over legacy heating solutions. Cooling remains a small share of total final energy use in the EU (2%), but demand has been steadily increasing. A focus on efficient cooling today will pay off in the future. Indoor air quality technologies and energy efficiency in buildings go hand in hand. Mechanical ventilation supplies fresh air indoors efficiently, recovering energy from the exhaust air. Air curtains prevent heat losses across open doors and other openings in the building envelope. Digitalisation is a key enabler for energy efficiency. Smart appliances integrated into a building management system can provide major reductions in energy consumption. EU funds earmarked for building renovation should be targeted at projects most likely to realise energy savings. Grants should be reserved for deep renovation projects rather than minor upgrades. The amount of energy saved per euro invested should be tracked.
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Response to Strategy for smart sector integration

22 May 2020

Eurovent would like to provide feedback to the European Commission on the roadmap for the strategy for energy system integration. Energy efficiency should be the core principle in any clean energy strategy. Together with renewable energy, electrification, and energy storage, it provides most of the mitigation measures required to reach the EU climate targets while ensuring a secure and reliable energy supply. HVACR technologies are a key part of the solution. Energy efficiency is the keystone of any effective strategy to reduce carbon emissions. It is a no-regret approach that offers abatement perspectives across sectors. Renewable energy and the electrification of end-uses are necessary to phase out fossil fuels and facilitate sector integration. Even though the COVID-19 shutdown may have reduced energy demand, investment in renewable energy and energy efficiency should be scaled up so that the binding renewable energy and energy efficiency targets for the EU for 2030 are achieved. Highly efficient heating and cooling solutions powered by electrical energy are already available today. Their uptake needs to be significantly scaled up, notably by committing resources to the renovation of inefficient buildings where most energy for heating and cooling is consumed. At scale, these technologies can enable cheap energy storage. During peak renewable energy generation periods, excess energy can be stored as heat in the system, be it in individual buildings or in a district heating system. In systems dominated by cooling needs, the same principles can be deployed for ice thermal storage and district cooling systems. Energy storage is the key to balancing supply and demand in an energy system based on renewable electrical energy. It reduces the need to switch on fossil fuel generators during peak demand periods and ensures the security and reliability of energy supply. Digitalisation is a key enabler for energy system integration, but important challenges need to be overcome before widespread implementation is possible. These include the reliability of the technology, data privacy and cybersecurity.
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Response to Farm to Fork Strategy

20 Mar 2020

Eurovent welcomes and supports the EC Farm to Fork Strategy for the European Union as a key component of the European Green Deal and believes that a comprehensive transition towards a sustainable food cold chain system is needed. In order to reduce the food waste we hold that the whole food cold chain system must be efficient and sustainable, and within this frame we strongly support an effective implementation of the EC Regulation (EU) 2019/2024 (aka Ecodesign requirements for refrigerating appliances with a direct sales function) and EC Regulation (EU) 2015/1095 (aka Ecodesign requirements for professional refrigerated storage cabinets). It is also important to apply the Hazard Analysis and Critical Control Points (HACCP) principles as outlined separate EU Rules regarding Food Hygiene that cover all stages of the production, processing, distribution and placing on the market of food. Furthermore, Eurovent would like to ask the EC to consider and recognise within its Strategy the important role played by the European Refrigeration industry in reducing the food loss and waste. Specifically, Eurovent would like to ask the EC to consider within the Strategy, a clear vision involving the whole Refrigeration industry (Supermarket refrigerated equipment, refrigerated warehouses, refrigerated cold rooms, refrigeration systems for industrial/commercial cooling and food processing).
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Response to Ecodesign for refrigerating appliances with a direct sales function

13 Dec 2018

Please view the enclosed table for Eurovent's detailed comments.
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Response to Energy labelling for refrigerating appliances with a direct sales function

13 Dec 2018

Please view the enclosed table for Eurovent's detailed comments.
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