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European Infrared Heating Alliance

EIHA

The European Infrared Heating Alliance (EIHA) is a network of national associations that represents infrared heating manufacturers who have a strong European footprint.

Lobbying Activity

Meeting with Robert Nuij (Head of Unit Energy)

12 Nov 2025 · Exchange on energy labelling policy

Response to Electrification Action Plan

9 Oct 2025

The European Infrared Heating Alliance (EIHA) welcomes the opportunity to contribute together with the Electric Underfloor Heating Alliance (EUHA) 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and recommendations: The Action Plan must be system-centred and technology-neutral approach rather than focused on outdated appliance-level metrics.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 European Infrared Heating Alliance (EIHA) welcomes the opportunity to contribute together with the Electric Underfloor Heating Alliance (EUHA) 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

12 May 2023

The European Infrared Heating Alliance (EIHA) 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 European Infrared Heating Alliance (EIHA), representing the European manufacturers of infrared heating, supports the review of 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 position that was shared earlier on 22 June 2022, 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; and 5) A level playing field and technology neutrality are ensured by split energy label scales. Attached is our most recent position, in which we have elaborated the following 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. Our most recent 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 European Infrared Heating Alliance (EIHA) 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 Promoting sustainability in consumer after-sales

4 Apr 2022

The European Infrared Heating Alliance (EIHA) appreciates the possibility to provide feedback to the European Commission's Sustainable Consumption of Goods Initiative (SCGI). Nonetheless, the EIHA 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 the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

The European Infrared Heating Alliance (EIHA) welcomes the Commission’s ambition to achieve zero-emission buildings (ZEBs) by 2050. We strongly believe that local space heaters (LSH), especially infrared 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 the attached position for an elaboration of our recommendations.
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Response to Ecodesign requirements for local space heaters (review)

18 Feb 2022

The European Infrared Heating Alliance (EIHA) 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, and more specifically about slave heaters and the Primary Energy Factor (PEF). We would also like to stress our support for the Circular Economy objectives. Slave heaters We disagree 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. Primary Energy Factor (PEF) As a principle, we support driving technologies to become more efficient over time. Nonetheless, if the energy source of that technology becomes sustainable, then it should be seen as a benefitting factor to the technology using the sustainable energy versus other technologies relying on more polluting forms on energy. As such, infrared heaters powered with renewable energy are in themselves already more sustainable in their power sourcing than fossil fuel powered heating systems. This should be reflected in the Primary Energy Factor for infrared heating. Circular Economy objectives The EIHA strongly supports the inclusion of elements supporting the uptake of Circular Economy objectives. We believe that local space heaters, and heating in general, should consist of fully removable, replaceable, and repairable components by professional installers, with in mind the recyclability of parts. The infrared heating industry has a strong expertise in this field, and we are more than willing to support the European legislators in developing the appropriate framework that supports durability, reparability, and recyclability.
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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 European Infrared Heating Alliance (EIHA) welcomes the European Commission’s revision of ecodesign and energy labelling requirements for local space heaters (LSH) in order to align them with the latest technological and market developments. We are a supporter of the Commission’s ecodesign and energy labelling framework, as it provides energy savings and contributes to achieving Europe’s climate objectives. As one of the co-signatories of the 15 September 2021 joint industry position against the merger of the energy labels for both ENER Lots 10 (air conditioners) and 20 (LSH), the EIHA disagrees strongly with the introduction of an integrated energy label for heating technologies. Merging the energy labelling classes will not contribute to meeting the energy labelling’s objectives because: 1) LSH and air conditioners are not comparable, 2) merging different energy labels will not help improving the effectiveness of the energy label, and 3) the consumer study itself does not univocally support the merger of the energy labelling scales. A detailed explanation of above mentioned arguments, including examples from infrared heating, can be found in our position attached to this feedback reply.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Nov 2021

The European Infrared Heating Alliance (EIHA), representing the infrared heating manufacturers in Europe, welcomes the opportunity to share its feedback on the proposed revision of the Renewable Energy Directive (RED). Achieving the 55 % emissions reduction targets by 2030 and climate neutrality by 2050 require ambitious policies to bring change in the EU energy system. Energy efficiency, but also renewable energies will be fundamental to reach these climate objectives. The heating sector still largely relies on fossil fuel energy and therefore offers a large cost-effective potential to reduce emissions through energy saving measures, a wide electrification of the sector, as well as the integration of renewable energies in the mix. European policies, such as the Renewable Energy Directive (RED), the Energy Efficiency Directive (EED) and the Energy Performance of Buildings Directive (EPBD) should all thrive to phase-out fossil fuels in heating systems with a faster phase-out of the most polluting fuels. This will only be achieved through a better RED. We call on the co-legislators to consider the points mentioned in our position paper (see attachment).
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Response to Review of Directive 2012/27/EU on energy efficiency

17 Nov 2021

The European Infrared Heating Alliance (EIHA), representing the infrared heating manufacturers in Europe, welcomes the opportunity to share its feedback on the proposed revision of the Energy Efficiency Directive (EED). Achieving the 55 % emissions reduction targets by 2030 and climate neutrality by 2050 will require ambitious policies to bring change in the European energy system. While renewable energies will be essential to achieving these targets, energy efficiency also represents a key enabler to reach the decarbonisation objectives of the European Union. The heating sector still largely relies on fossil fuel energy and therefore offers a large cost-effective potential to reduce emissions through energy saving measures, a wide electrification of the sector, as well as the integration of renewable energies in the mix. European policies, such as the EED, the Renewable Energy Directive (RED), and the Energy Performance of Buildings Directive (EPBD), should all thrive to phase-out fossil fuels in heating systems with a faster phase-out of the most polluting fuels. This will only be achieved through better energy efficiency policies, hence the reason for why the EIHA welcomes this EED recast. We call on the co-legislators to consider the points mentioned in our position paper (see attachment).
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