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European Partnership for Energy and the Environment

EPEE

EPEE represents the refrigeration, air-conditioning, and heat pump industry in Europe.

Lobbying Activity

Meeting with Jens Geier (Member of the European Parliament)

14 Jan 2026 · Exchange on Heating and Cooling Strategy

Meeting with Yannis Maniatis (Member of the European Parliament)

2 Dec 2025 · Introductory Meeting

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

18 Nov 2025 · PFAS

EPEE Urges Refrigerant Reclamation Support in Circular Economy Act

6 Nov 2025
Topic — New EU legislation to promote sustainable production and circular economy business models.
Message — EPEE requests a comprehensive revision of waste rules to harmonize reporting through digital logbooks. They advocate for simplified permits for transporting hazardous gases and mandated sorting to enable refrigerant reclamation.123
Why — This would reduce administrative burdens and ensure coherence with existing industry practices.45
Impact — Illegal importers and uncertified recyclers would face stricter oversight and business restrictions.67
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EPEE seeks clarity on B2B exemptions for unsold product reporting

10 Jul 2025
Topic — The EU is establishing rules for disclosing information about discarded unsold consumer products.
Message — EPEE requests that only the economic operator holding ownership at the time of discarding be responsible for disclosures. They recommend clarifying that products predominantly sold in B2B channels are not in scope. They also seek to resolve confusion regarding the application date.12
Why — This would prevent manufacturers from being held liable for waste they cannot control.3
Impact — Regulators will have less visibility into the disposal of commercial and industrial equipment.4
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Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

3 Jul 2025 · PFAS

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

20 Jun 2025

EPEE, the voice of the air-conditioning, heat pump, and refrigeration industry in Europe, appreciates the opportunity to provide feedback. In response to the Call for Evidence opened by the Commission on 25 May 2025, EPEE is glad to provide comments to the European Commission. Please see below and attached EPEE's initial comments and open questions about the current process for Regulation (EU) 2019/2024 and Regulation (EU) 2019/2018. We remain available to provide any information and relevant feedback to the consultants during the span of the revision process. EPEE believes the ongoing Evaluation report by Viegand Maagoe and DTI presents a great opportunity to understand the effectiveness of energy labelling for display cabinets in helping improve buyers behaviour. In this regard, EPEE would appreciate hearing back from the research team about the in-field use of those energy labels EPEE would also like to underline that the energy efficiency of a food retail store is mainly influenced by its complete refrigeration system of the store consisting of compressor packs or remote condensing units, remote refrigerated display cabinets, cold rooms and condensers plus its integral refrigerated display cabinets (and an additional air conditioning system where needed). EPEE considers the proposed mandatory energy labelling of remote refrigerated display cabinets as not appropriate since these energy efficiency labels tend to give misleading information with regards to the energy efficiency of the entire refrigeration systems used in the stores.
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Response to Revised ecodesign requirements for refrigerating appliances with a direct sales function

20 Jun 2025

EPEE, the voice of the air-conditioning, heat pump, and refrigeration industry in Europe, appreciates the opportunity to provide feedback. In response to the Call for Evidence opened by the Commission on 25 May 2025, EPEE is glad to provide comments to the European Commission. Please see attached EPEE's initial comments and open questions about the current process for Regulation (EU) 2019/2024 and Regulation (EU) 2019/2018. We remain available to provide any information and relevant feedback to the consultants during the span of the revision process.
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Response to Declaration of conformity and verification by independent auditor

16 Jun 2025

EPEE welcomes the Commissions draft Implementing Act setting the clear and detailed rules for the declaration of conformity under Regulation (EU) 2024/573. EPEE would like to submit comments and suggestions regarding the draft Annexes: 1. Re-import of Pre-charged Equipment 2. Structure of Point C in Annex I
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Response to Review of the energy labelling for professional refrigerators

31 Mar 2025

ASERCOM and EPEE have brought together a Joint Industry Expert Group (JIEG), as DG GROW knows, and is now responding to the Call for Evidence opened for the ecodesign and energy labelling requirements revision of professional refrigeration products, ENTR Lot 1. We compiled a large, comprehensive, and substantial technical database based on the input from ASERCOMs and EPEEs members and have prepared an alternative proposal that considers economic and regulatory uncertainty, without creating loopholes. This paper aims to address our main concerns and suggestions, based on findings from this technical work. Also, please note that additions are shown compared to the March 2024 paper available on our website in the table of contents. Therefore, to understand better our concerns and have a look at the detailed analysis, please read our attached paper. The JIEG remains available for further discussion with the Commission.
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Meeting with Paul Speight (Head of Unit Environment)

28 Mar 2025 · PFAS restriction

Heat pump association urges mandatory green public procurement rules

7 Mar 2025
Topic — The EU is evaluating directives governing public procurement and concession contracts.
Message — EPEE recommends establishing a harmonized EU framework for green public procurement. They propose making environmental criteria mandatory for buildings, including social housing and schools. The group also asks for alignment with existing energy and refrigerant laws.123
Why — Unified rules would prevent market fragmentation and stop unfavorable national regulations.45
Impact — National governments would lose the power to set their own procurement standards.67
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Response to Amendment of Reg (EU) 2024/1834) on ED for fans driven by motors with an electric input power between 125Wand 500kW

23 Jan 2025

The European Partnership for Energy and the Environment (EPEE) wishes to submit this short note in the context of the Public Consultation regarding the amendments proposed by DG ENER for the Regulation 2024/1834, namely ENER Lot 11, which has been adopted in July 2024 by the EU Commission. I) The proposed amendments provide better clarity to Regulation 2024/1834. EPEE supports the two main amendments that were first presented by DG ENER on 3rd July, during the Consultation Forum of that day held in Brussels, and published in December for feedback. First, Article 9(1) is clearer thanks to the editorial amendment given in Article 1(2) of the proposed amending Regulation. There were concerns over the transitional periods of both fans integrated into other products and spare part fans, and, as such, the new wording explicitly states that integrated fans have a 3-year transitional period and spare part fans a 13-year transitional period. Second, the substantial amendment regarding the verification tolerance value of the fan speed in Table 3 of Annex IV sets it now at 5%, while it was previously set at 2% (Annex(4)) of the proposed amending Regulation). 5% is welcomed by EPEE as it fits better the current market and is in line with similar technical requirements of tolerance found in ecodesign requirements for professional refrigeration (ENTR Lot 1) and ecodesign requirements for air-to-air heat pumps and air-conditioners (ENER Lot 10). II) However, changes in certain definitions require further precision in order to avoid confusion. The substantial amendment leads to a rework on the definitions. The fifth row of Table 3 of Annex IV does not read fan speed (rpm) with the value set at 5% but inherent speed at BEP (rpm) instead. DG ENER proposed therefore new versions of the definitions of BEP, best efficiency point and inherent speed. These proposed definitions in the amending Regulation (Article 1(1)) are confusing. The Inherent speed definition reads: (32) inherent speed means the rotation speed of the fan impeller, when the fan is operated at its nominal voltage and frequency (50 Hz, or 60 Hz in case of motors rated at 60 Hz only), applying the out-of-the-box default settings in case of VSD- driven fan. Yet, it is not precise which default settings should apply in the case of a fan integrated into another product. While EPEE understands this is relevant for standalone fans, it is not appropriate for fans integrated into products. The inherent speed can be different for the same fan in different products. As such, we would like to suggest a change to the new definition to BEP, best efficiency point as follows, to ensure that also fans integrated into products are considered: (3) best efficiency point (BEP) means the best energy efficiency point for fan operation, determined at inherent speed; or as declared by the manufacturer for fans integrated into products; EPEE believes this will avoid confusion among manufacturers, importers of equipment, and authorised representatives. ABOUT EPEE EPEE represents the refrigeration, air-conditioning and heat pump industry in Europe. Founded in the year 2000, EPEEs membership is composed of over 50 member companies as well as national and international associations from three continents (Europe, North America, Asia). With manufacturing sites and research and development facilities across the EU, which innovate for the global market, EPEE member companies realize a turnover of over 30 billion Euros, employ more than 200,000 people in Europe, and create indirect employment through a vast network of small and medium-sized enterprises such as contractors who install, service and maintain equipment. Please see our website for further information: www.epeeglobal.org.
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Meeting with András Tivadar Kulja (Member of the European Parliament)

19 Nov 2024 · Decarbonisation of heating and cooling in the EU

Meeting with Barry Andrews (Member of the European Parliament)

23 Sept 2024 · Heat Pumps

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

30 Aug 2024

EPEE, the voice of the air-conditioning, heat pump, and refrigeration industry in Europe, supports the EU Ecodesign and energy labelling policies and agrees with the need to keep the legislation up-to-date and in line with the latest technological developments. This paper provides EPEEs position to the Call for Evidence opened by the European Commission on this dossier on 21 June 2024. It reasserts the points raised in our position paper provided following the Consultation Forum of 11 December 2023. The RACHP industry finds itself in a transitional phase and seeks a holistic and coherent approach to address the latest regulatory developments and sustainability requirements across various pieces of legislations. In this regard, it is imperative that cutting-edge technologies take centre stage to guarantee optimal performance for specific applications. In light of this, please see our recommendations and answers to the questions raised with further explanation inside the attached document.
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Response to Update of format for F-gas reporting

10 Jun 2024

EPEE representing the Refrigeration, Air Conditioning and Heat Pump (RACHP) Industry in Europe supports the F-Gas Regulation as an essential tool to reduce emissions of F-gases and would like to bring its contribution to this implementing act on reporting requirements and its draft annex. EPEE thanks the Commission for giving the opportunity to deliver feedback on this draft implementing act and its draft annex. EPEE has summarized its thinking in the attached document.
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Response to Minimum requirements for certification programmes and training attestations for RACHP equipment

10 Jun 2024

EPEE representing the Refrigeration, Air Conditioning and Heat Pump (RACHP) Industry in Europe supports the F-Gas Regulation as an essential tool to reduce emissions of F-gases and would like to bring its contribution to this implementing act on on training and certification requirements and on its draft annex. EPEE thanks the Commission for giving the opportunity to deliver feedback on this draft implementing act. EPEE has summarized its thinking in the attached document. In the attached document, EPEE is sharing its interpretation of the scope of the F-gas regulation: according to article 2 of Regulation (EU) 2024/573, installers exclusively working with alternatives do not fall in scope of the F-gas Regulation, and thus, do not need F-Gas certification. Installers dealing with F-gases (either HFCs or HFOs) fall within the scope of the F-gas Regulation (EU) 2024/573 and will additionally need to be informed about the necessity of education for safe and energy efficient handling of alternative refrigerants. EPEE shares in the attachment its proposal for the certificate categories with a chart for supporting visualization (article 3 of the draft Implementing Act): Category A*: EPEE highly recommends keeping a separate category for smaller systems (residential sector). This category is for installers tackling all activities of Art 2(1) (leak checks, installation, repair, maintenance or servicing and recovery) for F-gases. EPEE proposes to keep the same threshold for HFCs as in the current Implementing Act (EU) 2015/2067, i.e. 3kg for non-hermetically sealed systems and 6 kg for hermetically sealed systems. EPEE believes a dedicated threshold for HFOs would be necessary. We are currently discussing the appropriate threshold for HFOs and we will come back to DG CLIMA as soon as a proper proposal is consolidated. Category B*: is for all charges of equipment and all activities described in Article 2(1). Category C*: concerns the recovery of F-gases. It corresponds to the current category III, although extended to all F-gases. Category D: covers leak checks of systems using F-gases. It corresponds to the current category IV but extended to all F-gases. (*)The certificate categories A, B, C include the safe handling of equipment containing flammable or toxic gases or operating under high-pressure or involving other relevant risks according to Article 10 (5) e. of (EU)2024/573. We would like to have further discussions on what this requirement on "safe handling" means, as it is necessary to avoid conflicts with qualification programmes already existing in Member States. Additionally, this requirement should not create a barrier for the uptake of alternatives. Therefore, we believe the safe handling should include theoretical information, but not replace certifications already existing in Member States. Consequently, EPEE would like to have further discussion on the proposed tables of the draft Annex of this draft implementing act, which contains the overview of Theoretical (T) and Practical (P) examination tests. EPEE would like to remind that this certification is not a diploma; it is not possible to cover with the F-Gas certificate the skills required to install, troubleshoot, control, maintain and dismantle the diversity of refrigeration, air conditioning and heating systems. Finally, EPEE would like to remind that the employer must, already, among his legal obligations, take the necessary measures to ensure the safety and protect the health of workers. Information, training and prevention actions for professional risks as well as appropriate means must be put in place by informing and training exposed employees. Examples of national requirements that already exists are the ATEX workplace directive, the pressure equipment directive, the Low Voltage and Machinery Directive. As well as voluntary programmes such as OHSAS, ISO.
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Response to Update of format of F-gas labels

4 Jun 2024

EPEE representing the Refrigeration, Air Conditioning and Heat Pump (RACHP) Industry in Europe supports the F-Gas Regulation as an essential tool to reduce emissions of F-gases and would like to bring its contribution to this implementing act on format of F-gas labels. EPEE thanks the Commission for giving the opportunity to deliver feedback on this draft implementing act. EPEE has summarized its thinking in the attached document.
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

EPEE, representing the Refrigeration, Air-Conditioning and Heat Pump industry (RACHP) in Europe, welcomes the opportunity to provide our comments on the new guidance and report on the recast of the Energy Efficiency Directive (EED) concerning Article 30, and would like to highlight a few concerns to be addressed. The revised EED represents a key pillar to achieve the 2030 EU climate targets ensuring sustainability and energy efficiency. Referring particularly to Article 30, new provisions and measures shall be taken to ensure implementation. EPEE supports the publication of a report and guidance proposal, as there is still a long way to go to fully achieve all of the objectives of the 2030 targets. While significant progress has been achieved since its recast, a green fatigue is also at risk of undermining the legislation and its implementation. Please find more details in attachment.
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Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

EPEE, representing the Refrigeration, Air-Conditioning and Heat Pump industry (RACHP) in Europe, welcomes the opportunity to provide our comments on the new guidance and report on the recast of the Energy Efficiency Directive (EED) concerning Article 30, and would like to highlight a few concerns to be addressed. The revised EED represents a key pillar to achieve the 2030 EU climate targets ensuring sustainability and energy efficiency. Referring particularly to Article 30, new provisions and measures shall be taken to ensure implementation. EPEE supports the publication of a report and guidance proposal, as there is still a long way to go to fully achieve all of the objectives of the 2030 targets. While significant progress has been achieved since its recast, a green fatigue is also at risk of undermining the legislation and its implementation. Please find in attachment more details.
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Response to 8th Environment Action Programme – Mid-term Review

26 Jan 2024

EPEE, representing the refrigeration, air-conditioning and heat pump industry (RACHP) in Europe, welcomes the opportunity to participate in the mid-term review of the 8th Environment Action Programme (EAP), and would like to highlight a few concerns to be addressed in parallel to this Action Programme. The Environment Action Programme aims to speed up the transition to a climate-neutral, resource-efficient economy, recognizing that human well-being and prosperity depend on healthy ecosystems. In order to achieve this, an ambitious programme needs to be set while ensuring the closure of important files under the Green Deal, such as the Energy Performance of Buildings Directive and the Packaging and Packaging Waste Regulation, accompanied by a proper implementation at national level. EPEE supports the publication of a legislative proposal added in annex to the 8th EAP to reach the set priorities to 2030, as there is still a long way to go to fully achieve all of the objectives of the Green Deal. While significant progress has been achieved since its launch in 2019, a green fatigue is also at risk of undermining the legislation and implementation to come from 2025.
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Response to Reporting scheme for data centres in Europe

15 Jan 2024

EPEE, representing the Refrigeration, Air-Conditioning and Heat Pump Industry (RACHP) in Europe, welcomes the provisions on data centre efficiency and sustainability included in the European Commissions proposal for a revised Energy Efficiency Directive (EED). The number and size of data centres are expected to grow steadily due to the constant digitalization of more and more aspects of daily life. The high computational capacity of data centres translates into high quantities of energy used. In Europe alone, data centres are projected to generate 3.2% of the total electricity demand in the EU by 2030 . In addition, the role of data computing technologies as contributors to the green transition will require ever larger volumes of data to be stored and processed, e.g. in the Green Deal Data Space, the Digital Product Passport, and to support the proliferation of the Internet of Things/connected devices/products. EPEE proposes that the delegated act should prioritize and facilitate the integration of local heat sources, particularly waste heat from data centers, into heating and cooling plans. This incorporation is essential for maximizing the utilization of available heat resources within the community. Municipalities should be enabled to assess the feasibility and potential benefits of integrating waste heat from data centers into their local heating plans, consequently contributing to enhanced energy efficiency and sustainable heat management.
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Response to Regulatory measure on the review of ecodesign requirements for industrial fans

3 Nov 2023

EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, welcomes the opportunity to provide feedback to the Commissions proposals for a revised Ecodesign Regulation (EU) No 317/2011 for fans (ENER Lot 11). We welcome the discussion that followed the Consultation Forum of 9 June 2023 and appreciate the opportunity to provide further input in writing through the « Have your say » platform, after the publication of the latest draft proposal on the 06th of October. We welcome the 3-year transition time for integrated fans, which is a necessary period to juggle the different regulatory challenges industry is facing (F-gas Regulation, PFAS restriction under REACH and higher MEPS in Ecodesign Regulations for final products). EPEE believes that an overarching view of these ongoing files is critical to deliver a homogenous and robust legislation, that will encompass all aspects of durability of our products. The deletion of the requirement to provide information with the technical data sheet of the final product in which the fan is integrated is also greatly appreciated. However, EPEE still is of the opinion that the cascading approach followed by the Commission leads to a double regulation regarding the components integrated into products that are already regulated. This approach will drive up the costs of final products, without any certainty that it will lead to improvements in energy efficiency on product level. Furthermore, we believe the 10-year spare part exemption, should be replaced by an unlimited time period for fans integrated into products, or an extension of the exemption to 20 years, in order to avoid premature replacement of products. For further information, please read the attached Position Paper on Ecodesign Regulation (EU) No 317/2011.
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Meeting with Virginijus Sinkevičius (Commissioner) and

4 Jul 2023 · To discuss with PFAS producers and users on the proposal for a REACH restriction on PFAS.

Response to European Critical Raw Materials Act

30 Jun 2023

Please find the full feedback from EPEE in attachment.
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Heat pump lobby seeks regulatory alignment in Net Zero Act

27 Jun 2023
Topic — The consultation addresses strengthening Europe's manufacturing capacity for net-zero energy technologies.
Message — EPEE calls for a precise definition of heat pumps to cover all applications. They urge policy coherence across F-gas and PFAS rules to avoid production delays. Industry representatives must also have a formal role in the Net Zero Platform.12
Why — Legal consistency would enable manufacturers to meet manufacturing targets and ensure long-term growth.3
Impact — Biodiversity goals are threatened if restrictive gas rules force consumers toward fossil-fuel heating.4
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Heat Pump Industry Urges Regulatory Consistency for EU Targets

26 May 2023
Topic — This consultation addresses the European Commission's plan to accelerate heat pump deployment.
Message — The industry requests a coherent legal framework that aligns chemical restrictions with climate goals. They urge the inclusion of all heat pump technologies, including air-to-air systems, in the plan. They also call for rebalancing energy prices and ending fossil fuel subsidies.12
Why — Clearer rules would reduce research burdens and help maintain manufacturing competitiveness in Europe.3
Impact — Fossil fuel boiler manufacturers would lose financial incentives and market access.4
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

EPEE, representing the Refrigeration, Air-Conditioning and Heat-Pump (RACHP) industry, welcomes the European Commissions technical report on new product priorities under the Ecodesign for Sustainable Products Regulation (ESPR) for non-Energy-related Products. The present position aims to highlight the need to assess requirements on a product-by-product approach by applying the proportionality principle in setting product specific requirements and ensure these are measurable and verifiable. Please see our position paper attached. Thank you very much. EPEE
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Heating industry opposes ban on fluorinated gases in taxonomy

3 May 2023
Topic — EU initiative setting sustainable investment criteria for the transition to a circular economy.
Message — The group strongly supports the deletion of the ban on fluorinated gases to protect investments. They argue the requirement to achieve the top class of performance on repair scores is premature. They recommend allowing manufacturers to register professional repairers before providing access to repair information.123
Why — This protects investments in current technologies and reduces the burden of meeting repair standards.4
Impact — Environmental objectives could be harmed by allowing the continued use of high-warming fluorinated gases.56
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Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur)

27 Apr 2023 · The Energy Performance of Buildings Directive (Assistant on behalf of MEP)

Meeting with Emma Wiesner (Member of the European Parliament)

17 Jan 2023 · Diskussion om F-gas och kommande lagstiftning

Meeting with Bas Eickhout (Member of the European Parliament, Rapporteur)

28 Sept 2022 · F-gas Regulation

Response to Energy labelling requirements for local space heaters (review)

23 Aug 2022

EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, supports the EU energy labelling policies, and agrees with the need to keep the legislation up-to-date and in line with the latest technological and market developments. Enclosed paper provides EPEE’s position on the most recent proposals from the Commission and additional points raised during the Consultation Forum on the review of the energy labelling Regulations (EU) No 2015/1186 for local space heaters (ENER Lot 20) and (EU) No 626/2011 for air-to-air heat pumps, air conditioners, and comfort fans (ENER Lot 10). It explains our support to merge the energy labelling of both product groups, as we believe that this will help consumers choose the most energy efficient products, across heating/cooling technologies, and thus to make selection decisions that maximise their contribution to the EU’s decarbonisation objectives. EPEE strongly supports the proposed merger of energy labelling classes: 1) Merging the energy labels for cooling between ENER Lot 10 technologies and in heating across ENER Lot 10 and 20 products will increase energy savings 2) A merged energy label will enable consumers to make informed choices EPEE also offers recommendations for optimising energy savings under the merged labelling classes: 1) Revise the proposed cooling and heating class distributions 2) Further assessment needed on control features 3) Adapt the layout of the Energy Label - Avoid misunderstanding by including energy efficiency values and leaving out energy consumption - Clarify that declarations for warmer and colder climate are optional - Reinstate the requirements from the current Energy Labelling Regulation for providing the energy label in the box 4) Reconsider the introduction of the compensation method 5) Exclude data centre cooling from the scope 6) Maintain one sound power instead of two for reversible units 7) Maintain the market surveillance tolerance values of the current regulation 8) Adhere to at least two years between publication and enforcement of new rules 9) Ensure alignment with the ongoing review of the Primary Energy Factor Please see enclosed position paper for further information and explanations.
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Response to Sustainable Products Initiative

22 Jun 2022

EPEE, representing the Refrigeration, Air-Conditioning and Heat-Pump (RACHP) industry, welcomes the European Commission’s proposal for a new Ecodesign for Sustainable Products Regulation as an ambitious piece of legislation. Enclosed position paper aims to highlight the loopholes where the draft regulation may fall short in the future implementation and provide an overview of the main recommendations in this respect: - Assess requirements on a product-by-product approach by applying the proportionality principle in setting product specific requirements and ensure these are measurable and verifiable. - Ensure a consistent approach with existing EU legislations by aligning definitions to avoid loopholes or overlap. - Consider the expertise of standardisation bodies and avoid the introduction of inconsistencies among the different policy areas and legislation. - Streamline information requirements and clarify the reference to the performance levels and the Digital Products Passport’s provisions. - Support e-labelling as a more sustainable alternative to providing physical paper-based information. - Assess the introduction of a performance label on case-by-case basis, to avoid an overlap with the products that are already in scope of the Energy Labelling Regulation. - Avoid one-size-fits-all and maintain specific considerations for ErP groups. - Consider the risks of disclosing competitively sensitive information on unsold goods. - Support market surveillance authorities by including customs into the surveillance systems and ensure unnecessary duplication of data. The annex to the position paper contains a list of amendments that EPEE would like to propose in order to strengthen the current draft proposal.
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EPEE warns F-gas rules may jeopardize European heat pump rollout

22 Jun 2022
Topic — This consultation reviews rules for reducing climate-harming fluorinated greenhouse gases in refrigeration and heating.
Message — EPEE calls for maintaining current phase-down levels until 2030 to ensure enough refrigerants for heat pumps. They request removing specific bans on heat pump technology to avoid jeopardizing EU energy goals. Additionally, training requirements should cover all refrigerants to improve safety.123
Why — A slower phase-down protects manufacturers from unachievable redesign timelines and potential product shortages.45
Impact — Consumers face higher costs and safety risks from a rushed transition to flammable refrigerants.6
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Response to Promoting sustainability in consumer after-sales

4 Apr 2022

EPEE, the voice of the refrigeration, air conditioning, and heat pump industries, appreciates the possibility to provide feedback to the European Commission's Sustainable Consumption of Goods Initiative (SCGI). Nonetheless, EPEE 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

31 Mar 2022

EPEE, representing the Refrigeration, Air Conditioning and Heat Pump (RACHP) Industry in Europe, is delighted to give feedback to the European Commission's proposal for a recast Energy Performance of Buildings Directive (EPBD). The building sector merits to be at the centre of regulatory efforts for clean electrification through the integration of renewable energy and reductions in energy consumption. Buildings are responsible for roughly 36% of greenhouse gas (GHG) emissions in the European Union, most of which originate from heating and cooling. Heating systems based on fossil fuels still dominate in the European building stock, with two thirds of heating demand currently covered by fossil-based technologies. Yet highly efficient zero-carbon heating and cooling technologies are available and scalable today and the RACHP sector is ready to provide the technologies needed. To succeed, a massive replacement of fossil fuel heating with electric heat pumps will have to take place in the coming decades and the EPBD is a key part of the legislative framework to enable this transition. EPEE would like to highlight several positive improvements to the EPBD, proposed by the European Commission. At the same time, our sector would like to stress further potentials for improvement on many of the priority elements , which are outlined in detail in more detail in our attached position paper. The attached paper summarizes our positions and recommendations with a focus on 1) the Zero Emission Building (ZEB) concept, 2) the introduction of minimum energy performance standards (MEPS), 3) the calculation methodology for the energy performance of buildings, 4) the improvement of Energy Performance Certificates (EPC), 5) the need to rapidly phase out fossil fuels in heating, 6) the importance of creating an adequate framework to address indoor environmental quality (IEQ) in the EU, and 7) how to promote the deployment of smart Technical Building Systems (TBS), particularly heating, ventilation, and air-conditioning (HVAC) systems and Building Management Systems (BMS).
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Response to Ecodesign requirements for water heaters and tanks (review)

30 Mar 2022

EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, welcomes the opportunity to provide comments to the Commission’s proposals for reviewing ENER Lot 2 (ecodesign Regulation 814/2013 and energy labelling Regulation 812/2013 for water heaters). We welcome the Commission’s considerations of the industry comments following the last Consultation Forum of 28 September and we support the need for reviewing the requirements for water heaters. Nonetheless, we believe that certain aspects could be further optimised. In light of the REPowerEU Communication and the Fit-for-55 strategy, which are a result of the ever-increasing pressure to decouple our economic future from the use of fossil fuels, the Commission has put forward the goal to accelerate the rollout of heat pumps to 10 million newly installed units by 2027 and 30 million by 2030. There is a clear need to facilitate the uptake of heat pumps, especially in the legislative framework provided by the ecodesign and energy labelling regulations for water heaters (ENER Lot 2). In view of these developments, EPEE welcomes transitioning to an A – G energy labelling scale as fast as possible. This is not only welcome but also needed to move towards higher efficiencies in the market by allowing for a proper comparison between the energy efficiencies of the various water heating technologies. EPEE calls for further investigation on whether the currently proposed additional requirements for heat pumps in ENER Lot 2, such as the additional testing requirements for Tpeak and sound power, are not imposing a too large burden on heat pump suppliers entering the market and inadvertently creating an unlevel playing field with fossil fuel-powered space heaters. Furthermore, the potential consideration of immature test methodologies, such as compensation methods, are not helpful in fostering the uptake of heat pumps in the market. In addition, test methodologies, such as Tpeak, must be considered carefully in view of facilitating the market towards lower temperatures. Although the need for test modification is recognised, any considerations of applying the test or adding penalties should be balanced and reasonable. Please see our recommendations with more detailed explanation in our attached position paper (dated 15 November 2021).
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Response to Energy labelling requirements for space and combination heaters (review/rescaling)

30 Mar 2022

EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, welcomes the opportunity to provide comments to the Commission’s proposals for reviewing ENER Lot 1 (ecodesign Regulation 813/2013 and energy labelling Regulation 811/2013 for space heaters). We welcome the Commission’s considerations of the industry comments following the last Consultation Forum of 27 September and we support the need for reviewing the requirements for space heaters. Nonetheless, we believe that certain aspects could be further optimised. In light of the REPowerEU Communication and the Fit-for-55 strategy, which are a result of the ever-increasing pressure to decouple our economic future from the use of fossil fuels, the Commission has put forward the goal to accelerate the rollout of heat pumps to 10 million newly installed units by 2027 and 30 million by 2030. There is a clear need to facilitate the uptake of heat pumps, especially in the legislative framework provided by the ecodesign and energy labelling regulations for space heaters (ENER Lot 1). In view of these developments, EPEE welcomes transition to an A – G energy labelling scale as fast as possible. This is not only welcome but also needed to move towards higher efficiencies in the market by allowing for a proper comparison between the energy efficiencies of the various space heating technologies. EPEE calls for further investigation on whether the currently proposed additional requirements for heat pumps in ENER Lot 1, such as the additional testing requirements for Tpeak and sound power, are not imposing a too large burden on heat pump suppliers entering the market and inadvertently creating an unlevel playing field with fossil fuel-powered space heaters. Furthermore, the potential consideration of immature test methodologies, such as compensation methods, are not helpful in fostering the uptake of heat pumps in the market. In addition, test methodologies, such as Tpeak, must be considered carefully in view of facilitating the market towards lower temperatures. Although the need for test modification is recognised, any considerations of applying the test or adding penalties should be balanced and reasonable. Please see our recommendations with more detailed explanation in our attached position paper (dated 15 November 2021).
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

30 Mar 2022 · Discussion on the review of the F-gas regulation

Response to Energy labelling requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans [review]

17 Feb 2022

EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, welcomes the opportunity to provide comments on the ENER Lot 10 ecodesign proposals to review Regulation (EU) No 206/2012. We welcome the Commission’s consideration of the industry comments following the last Consultation Forum meeting, and we support the need for reviewing the ecodesign rules in line with the latest technological and market developments. Nonetheless, we believe that certain aspects could be further optimised: 1. Foster thermal comfort in a balanced way. 2. Introduction of load based testing requires more time. 3. Consider airflow measurement for all testing facilities. 4. Provide proper determination for airflow limitations of multi-split systems. 5. Exclude units not designed for human comfort from scope. 6. Adhere to at least two years between publication and enforcement of new rules. 7. Allow for more time to adopt the CVP 8. Sharing of confidential technical information has to go through high-security platforms for independent testing. A detailed explanation of abovementioned proposals can be found in our position attached to this feedback reply.
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

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

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

19 Nov 2021

EPEE, representing the refrigeration, air-conditioning and heat pump sector in Europe, is delighted to provide feedback to the European Commission's proposal for a revised Energy Efficiency Directive (EED). Please find our input in the enclosed position paper.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

EPEE, representing the Refrigeration, Air-Conditioning and Heat Pump industry in Europe, is delighted to provide feedback to the European Commission's proposal to revise the Renewable Energy Directive (RED). The heating and cooling sector offers a large cost-effective potential to reduce emissions through the integration of renewable energy. Fulfilling this potential will to a large extent depend on providing the appropriate policy framework for a rapid deployment of renewable, highly-efficient heat pumps. Please find attached EPEE's position paper which outlines in more detail the contribution of the RACHP sector for the EU's climate and energy goals, as well as our suggestions for the further improvement of the RED revision proposal. We remain at your disposal for any questions and to elaborate further on our position.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Please see EPEE's feedback on the revision of the Energy Performance of Buildings Directive (EPBD) in the attached document.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The European Partnership for Energy and the Environment (EPEE), the voice of the cooling and heat pump industry in Europe, welcomes the initiative to establish the EU Taxonomy and the inclusion of activities crucial for the energy transition, such as building renovation, manufacturing and installation of energy efficient appliances, utilisation of waste heat and cold as well as district heating/cooling distribution. Given the urgent need to decarbonise Europe’s heating and cooling sector, and the potential wide-reaching impact of the Taxonomy on economic operators and other EU legislation, it is critical that the eligibility criteria developed for heating and cooling systems are coherent with existing legislation, simple to navigate for financial institutions and are fully aligned with the EU’s energy and climate agenda. To ensure that the Taxonomy delivers on all three fronts, EPEE invites the Commission to consider the following recommendations: – Establish a single set of eligibility criteria for electric heat pumps that are consistent within the Taxonomy and with existing EU legislation – Define eligibility criteria for cooling systems in data centres based on energy efficiency requirements and contribution to the transition to renewables – Revise the calculation methodology for measuring the lifecycle emissions of new buildings – Increase the energy savings requirement for renovation activities to 60% For a more detailed explanation of these recommendations, please consult the EPEE Position Paper attached.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Sept 2020

EPEE, representing the refrigeration, air-conditioning and heat pump industry in Europe, welcomes the Commission’s initiative to review the Energy Efficiency Directive (EED) and considers the EED Review key for promoting sustainable cooling as well as synergies between cooling and heating. Under the umbrella of the new Strategy for Energy System Integration, the EED Review represents a major opportunity in that sense, as it could contribute to shifting the focus from a siloed approach on heating only towards an integrated approach, tapping into the synergies between cooling and heating. The heating and cooling sector is crucial to the energy transition as roughly 80% of the energy it consumes is based on fossil fuels (in particular for heating). To phase-out fossil fuels, however, it is necessary to reduce the energy demand for heating and cooling in the first place. Up until now, the EED has exerted limited direct impact on increasing the energy efficiency of heating and cooling systems. Only the provisions in Article 7 result in a direct contribution to this goal via energy efficiency obligations, tax rebates and other measures. On the other hand, the Renewable Energy Directive (RED) and the Ecodesign Directive have contributed significantly to higher efficiency in heating and cooling. The reviews of the EED and RED as well as Ecodesign implementing measures represent an opportunity to boost both, energy efficiency and the transition towards renewable energies, whilst ensuring an optimum alignment of the two. For example, the Primary Energy Factor (PEF) converts final energy use into primary energy use, allowing us to compare the energy efficiency of technologies using different energy carriers. It is therefore crucial that the PEF is as close to reality as possible, reflecting the true composition of the electricity mix which is increasingly based on renewable energies. This is, for instance, highly relevant when comparing the energy efficiency of heat pumps with that of gas condensing boilers in the framework of Ecodesign and Energy Labelling, thereby linking the transition to renewables with energy efficiency. Article 14 waste heat provisions should also be strengthened in this regard. The current EED defines waste heat as heat generated by industrial processes to be used for cogeneration purposes and/or fed into a district heating network. However, it omits the potential of waste heat generated by cooling installations which can be either used directly on-site or fed into a district heating network. This would help to achieve higher system effectiveness in facilities hosting supermarkets, data centres etc. To address this, the scope of Article 14 provisions on waste heat should be extended to “recovery of non-residential waste heat and cold” and “commercial waste heat and cold”. In addition, Cost Benefit Analysis (CBA) provisions should be strengthened to include cross-sector energy system effects and extended beyond electricity generation and industrial installations in order to encourage smaller, decentralised solutions. Price competitiveness of electricity has remained a major hurdle for the adoption of more efficient heating and cooling systems such as heat pumps. For this to change, an increase in the competitiveness of electricity prices is required to raise market uptake. Fixed electricity charges need to be minimised, whilst a greater financial burden should be placed on peak-demand consumption. However, the use of taxation measures has limited the potential effect of EED Article 7 on heating and cooling, as Member States have placed a lower level of scrutiny on taxation measures when compared to other policy instruments. Departing from fixed electricity charges and taxation-heavy implementation of Article 7 (which tends to raise levies placed on electricity) would also help to make the business case for energy efficiency services, thereby helping to attain EED objectives laid out in Articles 8 and 18.
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Response to Review of EU rules on fluorinated greenhouse gases

4 Sept 2020

Executive Summary As a supporter of the F-Gas Regulation and the European Green Deal, EPEE, representing the refrigeration, air-conditioning and heat pump industry, emphasizes that the heating and cooling sector can make an important contribution to achieving climate neutrality in Europe by 2050. Thanks to existing EU legislation on F-Gases, F-Gas emissions have been falling since 2014 and by 2030 it is expected that that they will be reduced by two-thirds compared to 2014 levels. In terms of emissions related to energy production and consumption, which represent nearly 80% of the EU’s total greenhouse gas emissions, the sector has a key role to play in contributing to the reduction of energy demand, enabling the transition to renewable energies and facilitating sector integration. Top priorities to be taken into account therefore include further harmonisation, implementation and enforcement of the F-Gas Regulation across Europe whilst ensuring that the efficient and affordable use of energy and resources take centre stage. Please consider our paper in attachment to read our full feedback.
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Response to Strategy for smart sector integration

29 May 2020

Heating and cooling represent approximately 50% of the total final energy consumption in the EU. One fifth of the final energy consumed by heating and cooling is based on renewable energies – most of it is renewable heat and a little more than 10% are heat pumps. However, 80% of the final energy consumption related to heating and cooling is still based on burning fossil fuels . To ensure a move away from fossil fuels, it is crucial to reduce the energy consumption for heating and cooling and to further increase the share of renewables. Moreover, the share of renewable energy used for electricity generation already amounts to approximately one third and is growing. Again, this represents an important opportunity to decarbonise heating and cooling. The Strategy for Energy System Integration can contribute to this transition by creating an overall framework that maximises the cost-effective uptake of renewable energy. To achieve this, the strategy should integrate the design of energy supply systems (supply side) with the design of energy using systems (demand side). Such an approach recognises buildings as a key element of the energy infrastructure with heating and cooling being at the core of long-term energy system planning. In order to decarbonise the heating and cooling sector, the Strategy for Energy System Integration should: 1.Promote an integrated approach based on renewable and energy efficient electrification 2.Optimise the need for heating and cooling through holistic energy efficiency, control and monitoring measures 3.Enhance grid flexibility through demand side management, thermal storage solutions and end-user engagement For more information, please consult EPEE’s Position Paper on Heating & Cooling in the Strategy for Energy System Integration: https://www.epeeglobal.org/documents/epee-position-paper-on-sector-integration-april-2020/
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Response to Climate change mitigation and adaptation taxonomy

17 Apr 2020

The European Partnership for Energy and the Environment (EPEE), the voice of the cooling and heat pump industry in Europe, welcomes the initiative to establish a classification of environmentally sustainable economic activities ('taxonomy') and recognizes the important work carried out by the Commission’s Technical Expert Group (TEG) on Sustainable Finance in preparing the Final Taxonomy Report. The eligibility of electric heat pumps is addressed in sections 4.16 and 8.3 of the Final TEG Report. However, the climate change mitigation criteria listed in these two sections are inconsistent. Under activity 4.16. heat pumps are eligible when meeting the refrigerant threshold of GWP ≤675 as well as the ERP minimum energy efficiency requirements. Under activity 8.3. heat pumps are eligible when contributing to the renewable energy targets for heating and cooling under the 2018 Renewable Energy Directive (RED). EPEE’s September 2019 Position Paper on the Draft TEG Taxonomy Report called for an exclusion of refrigerants related criteria as they are technologically prescriptive and are already detailed under the EU F-Gas Regulation. The HFC Phase Down mechanism is ensuring the industry’s transition towards refrigerants with a lower GWP. Given the urgent need to decarbonise the heating and cooling sector in order to meet the objectives of the European Green Deal, climate change mitigation criteria based on the RED and ERP are more appropriate than those based on GWP criteria. If GWP criteria are deemed necessary in secondary legislation, such requirements should provide coherence with existing tools and predictability going forward. By setting a GWP limit of ≤675 in section 4.16 (installation and operation of Electric Heat Pumps), the Technical Expert Group has demonstrated its intention to include heat pumps using the R-32 refrigerant, which has been allocated a GWP value of 675. However, GWP values are regularly re-evaluated under IPCC Assessment Reports. As the threshold is currently set at ≤675, there is considerable risk that the R-32 refrigerant would be excluded by the mitigation criteria, even if the slightest adjustment to its GWP value is made. This is clearly not the intention of the Technical Expert Group. The solution proposed in the TEG Report is to place this criterion under regular review. However, in such a case the solutions may prove worse than the problem, as the potential for regular review creates uncertainty for investors, financial services professionals and the industry in question. To address this, GWP criteria should refer to the 4th IPCC Assessment report, which is in line with the international Montreal Protocol – Kigali amendment and the relevant segments of the EU F-Gas regulation. Sections 8.1 and 8.2. of the TEG Report address the construction of new buildings and renovation activities. As a strong advocate of EU level action to boost the renovation rate across Europe, EPEE welcomes the inclusion of these activities in the TEG Report. However, the ‘pollution’ aspect of the ‘do no significant harm assessment’ should be reconsidered. The TEG Report excludes building components and materials that contain substances of very high concern (SVHC) as identified on the basis of the “Authorisation List” (Annex XIV) of the REACH Regulation. This approach is problematic, as the REACH Regulation itself allows the continued use of such substances as long as this is covered by a use exemption. To get an authorisation for continued use, applicants need to demonstrate they are not able to substitute the use and that they can control the risk. When this has been proven and therefore an Authorisation has been provided, such use should not be considered as ‘doing significant harm’. Therefore, the ‘do no significant harm assessment’ should permit the usage of building components and materials containing substances listed in Annex XIV of the REACH Regulation, so long as the necessary use exemptions have been obtained.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

14 Feb 2020 · Decarbonisation of the heating sector in the context of the European Green Deal

Response to Ecodesign for refrigerating appliances with a direct sales function

20 Dec 2018

EPEE has carefully reviewed the draft Ecodesign Regulations for ENER Lot 12 products and would like to emphasise a number of concerns that need to be taken into consideration in view of the setting of an optimal framework: 1. Further differentiate between product categories 2. Refrain from technology prescriptive measures 3. Set achievable MEPS for remote and plug-in display cabinets EPEE's detailed position can be found in the attached document.
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Response to Energy labelling for refrigerating appliances with a direct sales function

17 Dec 2018

EPEE has carefully reviewed the draft energy labelling Regulations for ENER Lot 12 products and recommends the deletion of the mandatory energy labelling for remote display cabinets in view of the setting of an optimal framework. EPEE calls for a deletion of the proposed requirement of mandatory energy labels for products falling under the scope of ENER Lot 12 – in particular for remote supermarket cabinets – as these are B2B products in the food retail business and are procured and tested by experienced engineers in the procurement departments of retailers. In particular for remote supermarket cabinets an energy label makes no sense, as the energy efficiency of a centralised refrigeration system depends on the interaction of a number of factors such as the efficiency of the multi-compressor pack, the quality of the piping network and of the controls system, the hours of operation, the ambient temperature, the number and size of units, the desired storage temperature in the cabinet, etc. Moreover, the Commission should take a coherent approach to energy labelling. For example, residential air-conditioners <12kW (ENER Lot10), space heaters <70kW (ENER Lot1) and blast cabinets (ENTR Lot1) have to carry an energy label, as these are considered to be consumer applications meaning that the consumer will be able to directly select the product. On the other hand – and rightly so – there are no labels intended for space heaters >70kW (ENER Lot1), process chillers & condensing units (ENTR Lot1) and large heating and cooling products (ENER Lot21 - VRF, multi-split systems, chillers). The latter are B2B products where many factors come into play and where the purchase decision is made in a professional way by experienced engineers. We recommend a similar approach to ENER Lot 12. - The mandatory label needs to be deleted for remote display cabinets as the system approach prevails. - The introduction of a label for integral cabinets, beverage coolers and small ice cream freezers may be envisaged as these are plug-in appliances where the energy efficiency can be directly measured at the unit. Contrary to remotely operated cabinets, retailers will be able to assess “at a glance” whether an appliance is energy efficient or not.
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

The Commission intends to emphasise circular economy aspects, such as reparability, durability, upgradability or recyclability in the EU Product Policy framework in the context of the EU Circular Economy agenda. EPEE, representing the heat pump, cooling and refrigeration industry, welcomes the opportunity to share our views on the potential contribution of EU Product Policy and of the HVACR sector to a more circular economy. Please find attached our initial feedback.
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Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

14 Dec 2016 · Energy efficiency

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

24 Jun 2016 · Energy efficiency and decarbonisation