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Federation of European Heating, Ventilation and Air-conditioning Associations

REHVA

REHVA, the Federation of European Heating, Ventilation and Air-conditioning Associations, established in 1963, is an independent, pan-European, professional association representing more than 120.000 building services engineers and HVAC professionals from 24 European countries.

Lobbying Activity

Meeting with Stefan Moser (Head of Unit Energy)

18 Nov 2025 · Addressing building affordability and energy poverty in the ongoing EU legislature

Response to Union framework for the calculation of life-cycle Global Warming Potential for new buildings

30 Oct 2025

We welcome the overall approach proposed by the Commission in the Delegated Act to advance the harmonization of GWP calculations across Member States. In particular, we agree with other feedback that emphasizes the importance of reducing administrative burdens and ensuring a level playing field in the GWP calculation process. To this end, the degree of flexibility granted to Member States should be limited and managed at the EU level. We would like to raise a question regarding the life-cycle stages listed in Table 2 of the document Annex - Ares(2025)8384118. Specifically, the Maintenance (B2) and Repair (B3) modules are challenging to estimate due to limited data availability and precision. All these phases are related to assumptions, and defining the typical cycle of intervention is not easy. Moreover, their GWP is relatively low compared to other modules. These phases rely heavily on assumptions and defining a typical intervention cycle is complex. Other modules, such as A5, and C1 and D, are also generally calculated using assumptions or generic data. Including these stages in the calculation may risk overcomplicating the procedure without significantly contributing to the decarbonization of buildings even though the Commission clearly states in the table that Member States may limit the calculation to product-level information and equivalent generic data or default values. The draft regulation states that all data must be sourced from the CPR/ESPR. Under the CPR no specific background database is designated; this results in large discrepancies between different sources. This should be addressed. Regarding the Annex - Ares(2025)8384118 document, we also believe that including the building elements and technical equipment listed in Tier 3 of Table 4 as minimum requirements (shell and core categories) could overburden the calculation process. Items such as sanitaryware, IT and data systems, external building-mounted lighting, etc., are typically assessed using generic data; they now lack completely, but it is unclear whether they should be considered, because of the considerable impact of the building services components to the embodied carbon of a building. Furthermore, the allocation of installations for building-related on-site renewable energy generation is unclear. At present, different options appear possible, which will lead to confusion in practice. It may also result in undesirable differences between Member States. The recommendation is to choose the method whereby the entire installation for renewable energy generation is included, but only as it is connected behind the meter. On the other hand: even when EPDs are available, collecting this level of detail at the building level remains burdensome Therefore, it would be reasonable to fix Tier 2 as the minimum requirement, and Tier 3 can be left voluntary to be decided by Member States
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Response to Heating and cooling strategy

2 Oct 2025

REHVA contribution to the upcoming Heating and Cooling Strategy REHVA is the Federation of European Heating, Ventilation and Air Conditioning Associations (HVAC). It represents over 120,000 HVAC designers, building services engineers, and technicians across 24 European Countries. 1) THE STRATEGY SHOULD CONSIDER THE EVOLUTION OF ENERGY NEEDS IN BUILDINGS The space and ventilation heating demand is reducing (insulation of buildings, heat recovery). The space cooling use is increasing (climate change, heat waves). There will be a shift towards low temperature heating systems and all-air systems. The domestic hot water demand becomes higher than the space heating demand. This energy saving potential is highly untapped. The use of renewables is increasing (on-site photovoltaics). The building becomes an energy producer. Self-use, storage and system integration (electro mobility) should be developed The re-use of existing boilers and the use of the existing gas grid infrastructure for renewable energy carrier (e.g. biomethane) could be an interesting option. These evolutions are well identified and are new challenges for the building sector. But they are not always well addressed in the building regulations. 2) NEEDED ACTIONS AND BARRIERS FOR THE DECARBONIZATION OF HEATING AND COOLING The needed actions for decarbonization are: Energy savings (e.g. insulation, domestic hot water flow reduction devices), free cooling), Energy efficiency (e.g. cogeneration, heat pumps, heat recovery, district low-temperature networks), Use of renewables and system integration (e.g. photovoltaics, biomass, peak demand). The heating and cooling strategy should cover all these actions, and not favor one of them. These actions can be implemented at building, energy community, municipalities or national level. Special attention should be given to the following topics: Peak demand The development of renewables and electrification of the uses creates new problems, as the intermittency of production (summer, winter) and electricity peak loads. Therefore, storable solutions, back-up systems and system integration (electricity mobility, peak load) are key. Lack of professional skills The complex technical systems require new expertise. An EU common training and qualification scheme, based on European standards, would help professionals to work EU-wide and avoid EU market fragmentation. There is no one fits all solution Each action needs to be seen in the overall context (at building level, at neighbourhood level) and by considering the whole energy chain from the building needs to primary energy. Affordable buildings and public infrastructure Buildings should be affordable. The needed investment to become Zero Emission buildings should be cost-effective. Subsidies should help to finance the initial higher investment, but subsidies should be performance driven and cost-effective. 3) RESUME OF THE REHVA PROPOSAL FOR NON-LEGISLATIVE ACTIONS TO ACCELERATE IMPLEMENTATION To be efficient and affordable, the EU strategy to decarbonize heating and cooling systems must be holistic, performance based, cost effective and create an EU wide level playing field with common key performance indicators. There is no one fits all solution. Without a skilled, qualified and sufficient workforce, the EU strategy implementation will fail. The non-legislative actions to accelerate implementation should be done in close cooperation with the EU HVAC associations. REHVA is ready to cooperate.
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Response to Energy labelling requirements for local space heaters (review)

14 Sept 2022

General Statement REHVA, the Federation of European HVAC associations appreciates the work and impact of the EU Ecodesign and energy labeling regulations that helped to increase the energy efficiency of HVAC components. REHVA strongly supports transparent and comprehensive Ecodesign and energy labelling requirements that should further improve energy efficiency of HVAC products available on the EU market by covering all existing technologies and fostering innovative, low-carbon technological solutions with high efficiency. Scope of the labels REHVA welcomes the harmonization of energy labels of all heating and cooling technologies to allow for the transparent comparison of efficiencies. Therefore, REHVA supports both the merger of energy labels for local (space) heaters (ENER Lot 20) and air conditioners (ENER Lot 10) as well as the inclusion of electric heaters in the scope of the energy labelling. REHVA agrees with the scope of the energy labelling regulation proposed in the draft Working document Proposal for labelling of room heaters, room air conditioners and comfort fans. Definition of efficiency ranges of heat pumps Regarding the efficiency ranges of air source heat pumps, REHVA proposes considering seasonal efficiency, as heat pump performance depends on the climatic zone while other technologies (like electric heaters) don’t. The Work document proposed one average climate condition, which may result in the disadvantage of the highly efficient and low-carbon heat pump technologies compared to other technologies. REHVA proposes reporting all 3 seasonal efficiency factors as used in the EN standard EN 14825:2018 Labeling scale and complementary information The scale and information displayed on the labels should be meaningful and easy to understand for consumers. Beside the energy class as major indicator, we support the display of numerical efficiency values to ease the comparison of different heating and cooling technologies by consumers. At the same time, we recommend considering eventual rescaling of the energy classes and the minimum efficiency performance requirements for the different product groups covered by the merged label. Regarding the labeling of biomass stoves, REHVA proposes to continue the use of the biomass label factor (BLF) in the calculation, as well as displayed in the label, to allow for a distinction between biomass and fossil fuel stoves, so that the former can eventually get a better label if a distinction between renewable and non-renewable energy source use is made. At the same time, REHVA strongly supports adding with supplementary information regarding the air pollutant emissions of solid fuel space heaters as well as the GWG impact of refrigerants used in air-to-air heat pumps to the merged label. The current BLF factor of 1.45 can be seen as a practical way (=energy policy factor) to promote the use of renewable energy sources. Because renewable and fossil energy sources are distinguished in all European strategies and directives such as EED, RED, EPBD, RePowerEU, and there are targets to increase renewable energy use in buildings, also the labelling of products used in the buildings should be in line with this common principle.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

REHVA welcomes the Renovation Wave Strategy and supports policy option 3, revising the EPBD to foster deep energy renovation that delivers healthy and energy efficient buildings. However, more attention shall be paid to improved indoor environment quality (IEQ) in energy renovation. The COVID-19 pandemic shows the importance of indoor air quality (IAQ), the public health impact and cost of buildings ill-suited to mitigate risks due to inadequate ventilation. The WHO Roadmap to improve and ensure good indoor ventilation in the context of COVID-19, should be considered. IAQ and ventilation requirements should be integrated in renovation policies in the scope of EPBD, which is the only legislation tackling energy efficient ventilation systems and IEQ in buildings. REHVA calls to consider the EP report on Maximising the energy efficiency potential of the EU building stock that requests improved IEQ and air quality standards in the renovation wave. The massive investment in the renovation wave shall result in improved health and comfort. Outcomes of the study on inspection of ventilation systems should be included in the revised directive. REHVA calls for the revision of the EPBD with the aim to ensure improved IEQ with the renovation wave. 1. REHVA supports mandatory minimum energy performance standards for different building categories. They should consider IEQ and ventilation criteria to ensure indoor climate improvement by energy renovation. Stricter MEPS for non-residential and public buildings prioritized by the renovation wave may be a start, but ventilation criteria should be defined also for residential buildings where IAQ is often deteriorated by energy renovation. MEPS can be developed from existing NZEB requirements for major renovation and shall be defined for both deep and step-by-step renovation with clear performance targets. Incentives should be linked to comprehensive IEQ and energy performance requirements. 2.Updating the EPC framework -Current EPCs are not consistent with actual energy use which has decreased trust. EPCs should provide relevant data for end users who, when selling or renting, prefer energy-use information that relates to energy bills. Including measured energy use and cost data, connected to user behaviour data (as in EN 16798-1) would make EPCs meaningful for end users and strengthen credibility. -The EPBD should define non-renewable primary energy as main performance indicator according to the energy efficiency first principle. Additional minimum safeguards may be added in line with the EU taxonomy. -Existing minimum requirements may lead to buildings with similar energy cost causing very different power load to the grid. Adding an HVAC and lighting electricity power indicator (W/m2) would suit the balancing of energy demand and supply, in line with the SRI flexibility criteria. -EPCs should contain an IEQ indicator like in the EN/ISO EN 16798–1 standard and a certificate of ventilation system performance. REHVA recommends the ALDREN‑TAIL indicator to rate IEQ of buildings undergoing deep energy renovation. -REHVA supports the development of an open-source software kernel & dynamic performance calculation tools meeting Art. 3 requirements of the EPBD. The EPBD review should mandate the development of a delegated regulation on a common energy calculation framework. -REHVA supports a common EU voluntary certification scheme (Art.11(9) of EPBD) as developed by ALDREN. 3.REHVA supports a deep renovation standard in the context of financing. Performance based and descriptive technical requirements should be a prerequisite for finance. Reporting in-use performance by EPC after 1-year operation and digital technical monitoring, quality management during the renovation lifecycle should be part of the standard. 4.REHVA calls for a public workshop on IEQ criteria & health aspects in energy renovation with stakeholders from building engineering, occupational health & other involved sectors.
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