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HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V.

HKI

HKI Industrieverband Haus-, Heiz und Küchentechnik e.V.

Lobbying Activity

Response to Heating and cooling strategy

8 Oct 2025

The European building sector faces significant challenges in decarbonising heating and hot water supply while ensuring security of energy supply. Our position highlights the role of electric and hybrid heating systems, including modern wood-fired local space heaters, in reducing fossil fuel dependency, lowering CO emissions, and supporting regional economic development. Modern technical standards, sustainable biomass supply, and integration into intelligent energy systems are essential to ensure environmentally responsible and efficient operation. For a detailed position and supporting data, please refer to the attached PDF document.
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Response to Omnibus Regulation Aligning product legislation with the digital age

14 Jul 2025

Please find attached our position paper concerning the digital provision of product-related information under Regulation (EU) No 305/2011 (Construction Products Regulation). While we fully support the Commissions initiative to promote digital formats through the Omnibus IV package, we believe that similar progress is urgently needed for products still covered by the old CPR including, for example, individual room heaters. In our view, it would be both proportionate and timely to allow digital formats also under the current legal framework, given that many products will remain under the old CPR well into the 2030s. The paper outlines our reasoning and suggests a legislative adjustment to ensure legal clarity and alignment with the broader goals of digitalisation and sustainability.
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Response to Sustainable products - disclosure of information on unsold consumer products

30 Jun 2025

You can find the statement from the German Industry Association of House, Heating and Kitchen Technology (Industrieverband Haus-, Heiz- und Küchentechnik e.V.) in the attached PDF document.
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Response to Towards a Circular, Regenerative and Competitive Bioeconomy

13 Jun 2025

Please find our statement in the file attached.
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Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

13 May 2025

Please find our association's position paper in the attached file.
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Response to Revision of the Cost-Optimal Methodology framework for calculating minimum energy performance requirements for buildings

6 May 2025

HKI, the Industry Association of House, Heating and Kitchen Technology represents manufacturers of domestic heating and cooking appliances across Europe. The debate on including external costs, such as fine particulate matter (PM2.5) and nitrogen oxides (NOx) emissions, in the energy performance requirements for buildings is significant. However, attributing these emissions to specific heat energy sources, especially biomass, involves considerable uncertainty. Regulatory measures must accurately reflect the actual contribution of modern, efficient biomass systems to air quality and energy performance. The Ecodesign requirements already ensure that devices are continuously becoming more environmentally friendly, pushing manufacturers to improve emissions standards over time. A double regulation for these products is leading to costs for industry without an environmental benefit. One key issue is the difficulty in identifying the sources of emissions. It is not always clear whether particulate matter comes from wood combustion or whether it originates from modern, low-emission stoves or older, more polluting systems. In many cases, the presence of older, inefficient stoves in the same area can skew emissions profiles, leading to an inaccurate picture of the impact of modern, cleaner systems. Penalizing low-emission biomass systems, which contribute significantly less to particulate pollution, would be unjust and counterproductive. The argument that there is no "safe" amount of particulate matter overlooks the fact that health risks from air pollutants depend on the concentration and duration of exposure. Studies show that moderate levels of particulate matter, like those emitted by modern biomass systems, do not pose significant health risks when within regulatory limits, in full alignment with the Ambient Air Quality Directive (AAQD). The real issue lies in the large number of older, inefficient stoves, which are the main contributors to particulate pollution. Replacing these with modern systems would largely resolve the problem. Moreover, the introduction of advanced biomass technologies leads to significant emission reductions. Replacing outdated systems with modern, high-efficiency stoves can reduce emissions by up to 90%. This reduction is supported by various research findings and industry reports that highlight the substantial improvements in emission levels achieved through the adoption of modern biomass systems. Focusing regulatory efforts on encouraging the adoption of these advanced systems, rather than penalizing biomass overall, will address air quality and energy efficiency concerns effectively. Energy performance regulations should consider the full range of factors that influence energy efficiency and sustainability. Biomass is a vital part of Europe's energy transition, especially in regions where renewable electricity generation is limited during colder months. Unlike intermittent renewables, biomass is storable and provides a reliable energy supply. Hybrid systems combining biomass and heat pumps further enhance this reliability by allowing flexible use of energy sources based on availability and demand These systems can contribute meaningfully to building energy performance by combining low emissions, seasonal efficiency, and grid-friendly operation. Penalizing biomass systems that are already reducing emissions would undermine decarbonization and energy security goals. In conclusion, while air quality is essential, addressing emissions must be nuanced and based on the actual impact of energy sources. Modern biomass systems, when used correctly, pose minimal risks to air quality and offer sustainable, reliable energy solutions. Penalizing these systems based on generalized emission assumptions would hinder progress toward a sustainable energy future. The focus should be on promoting cleaner, more efficient technologies to achieve environmental and energy performance goals.
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Meeting with Niels Ladefoged (null Energy)

19 Mar 2025 · Visit to stand of manufacturers of biomass heating appliances.

Response to Single Market Strategy 2025

31 Jan 2025

The appendix contains the detailed statement of Industrieverband Haus-, Heiz- und Küchentechnik e.V. (HKI).
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Response to Ecodesign requirements for solid fuel local space heaters (review)

8 Dec 2023

The German HKI industry association represents the interests of more than 110 manufacturers of domestic heating and cooking appliances. As such, it strongly supports the goals of sustainable and, as far as possible, CO2-neutral heat generation and improved air quality. The development and manufacture of efficient and clean products is a constant concern for our members. Solid fuel domestic heating is an economically important sector in the EU. The entry into force of the Ecodesign Regulation for these appliances in the EU, and national legislation in Germany (1st BImSchV) well before that, has led to improvements in efficiency and a significant reduction in emissions from these products. Air quality in Germany, in particular, has been improving steadily for years, as measured by the Federal Environment Agency's (UBA) monitoring stations. A further significant improvement in air quality could certainly be achieved by encouraging citizens to replace old fireplaces (with low efficiency, uncontrolled combustion and higher emissions) with highly efficient, clean-burning solid-fuel individual room heaters. This is because wood fuel, when sustainably produced and locally sourced, is a very low-carbon heat source that perfectly complements other heat sources such as low-temperature heat generators such as heat pumps, especially in the cold seasons. In Germany, sustainable forestry is already a matter of course and is recognised by law. In the attached document, we provide a detailed statement on the planned revision of the Ecodesign Regulation for solid fuel local space heaters.
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Response to Verification of suppliers and other operational aspects for the functioning of product database - EPREL

17 Nov 2023

As an industry association, we see two problems with EPREL: Registrations can only be made by companies or individuals from the EU, EEA or Northern Ireland. Companies from third countries need to have an importer or legal representative in an EU/EEA country. This is an unnecessary additional burden for the companies concerned. We do not understand why it should not be possible for third country nationals to register on EPREL when placing their products on the internal market. This cannot be for technical reasons. It would be a considerable improvement for the operators concerned if this situation were to change. Our second point is that EPREL is too complicated for small companies, especially when it comes to authentication. It should be examined whether simplification is possible here.
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Response to Revision of EU Ambient Air Quality legislation

7 Mar 2023

In general, our industry supports the setting of air quality standards to prevent the build-up of excessive concentrations of pollutants. Clean air is important for human health and the environment. However, it should be noted that the WHO recommendations on which the revision of the Air Quality Directive is based focus only on health impacts, leaving out impacts on economic factors, etc. The draft also contains measurement requirements for additional pollutants, especially chemical pollution. Apart from the fact that their measurement and determination is not that easy and expensive (especially at the level of all measuring stations in Europe), it is questionable why the main polluters are not directly addressed. Furthermore, it should be clarified whether qualified (and validated) measurement methods are already established. In the attached document, the most important comments on the different air pollutants are presented.
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Response to Energy labelling requirements for local space heaters (review)

12 Aug 2022

Generally energy labelling is supported by our industry as a good opportunity to inform the customer and help him or her to choose the appropriate product for his/her purpose. But there is the need of a clear differentiation between good and less good products in a certain product range. However, the planned merging of the two energy labels of ENER Lots 10 (air-to-air heat pumps, air conditioners, and comfort fans) and 20 (local space heaters) in its current form cannot be supported. The combination of the different technologies in one energy label provides no benefit for the consumer. Due to the merging, the labelling range for the individual technology or product group is very small, so that granulation within a product group is not possible. Our experience is that a consumer is not fully free to choose between different room heating systems on basis of an energy label only. The decision on the purchase of a specific room heating technology is done with respect to the individual situation of the buyer regarding the state and location of the building, the costs of the room heater and availability and costs of energy sources etc. In addition the results of the Study on consumer understanding of the energy label for space heaters and air conditioners cannot at all be interpreted such that the consumer uses the label to make a choice between different room heating equipment. The removal of the Biomass Label Factor (BLF) is considered as a wrong signal. The contribution of biomass local space heaters (LSHs) to energy supply security and geopolitical independence in the sense of the EU resilience strategy must play its own role in today's economic and political situation. Biomass is essential in the heating market; the energy transition is not feasible without it. Especially in the current political situation, energy independence and the use of all green energy sources at our disposal is crucial. Therefore, the most efficient appliances using biogas, wood logs, wood pellets and, in the future, hydrogen, should not be downgraded to the lowest categories (with no option for higher categories), as European manufacturers should continue to have an incentive to further develop their products. Currently, manufacturers are working on improvements in, among other things, the efficiency of appliances for gas and woody biomass. Similar developments are not expected for appliances for oil and non-renewable solid fuels such as coal, as these products will disappear from the market in Europe. For natural gas, the main improvement is to develop appliances for operation with a mixture of biogas and hydrogen. There are already appliances that can run on a mixture of 25% biogas and/or hydrogen. In addition, manufacturers are working on appliances that can run on 100% hydrogen. A consideration of these devices is missing in the present draft. Finally we would like to highlight that there must be no mixing of requirements. The energy label is intended to assess the energy efficiency of a product. In the current draft, however, further requirements for emissions and sound levels are set that are already regulated in e.g. EU regulations or European harmonised standards. This leads to double regulation with inadequate bureaucratic burdens on industry and suppliers and will in the end confuse the customer. In the attached document the main topics are detailed and additional technical comments are addressed.
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Response to Sustainable Products Initiative

20 Jun 2022

In general, HKI supports the Ecodesign instrument which already delivered for EU consumers, industry and the planet by taking due consideration of all aspects of the life cycle of the product, setting measurable and enforceable requirements and based on the proportionality principle. It is the impetus to develop standardized methods that enable appliances and machines to be better compared. We are particularly looking forward to the new Ecodesign towards more durability and repairability, which has long been as important to our industry as energy efficiency. A good balance of all those requirements would create a complex enough approach to contribute to the environmental objectives of the EU. These developments are very welcome, but the bureaucracy required is inadequate for the specialized b-to-b sector or SME sector.
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Response to Ecodesign and energy labelling working plan 2020-2024

1 Jun 2021

Ecodesign and energy labelling is a good instrument to reduce the environmental impact of appliances. However, Ecodesign and energy labelling should be very carefully considered. It is the impetus to develop standardized methods that enable appliances and machines to be better compared. This aspect is very welcome, but the bureaucracy required is inadequate for our sector. We also generally see no benefit for our clients in the introduction of energy labels. The economic effects of the pandemic and climate change must be countered effectively and not with more bureaucracy. Lockdown and food delivery changed faster than ever in the past year. The whole sector is working on these disruptive changes. The manufacturers of food service equipment are primarily medium-sized companies. Bureaucratic burdens in connection with Ecodesign such as EPREL, labelling, product passport, testing efforts and documentation in general are disproportionately high for manufacturers with very small series production of a wide product range. Energy consumption in our overall sector is assumed, but Ecodesign should be considered on a product-specific basis. So far, the considerations for this approach are too general to consider the energy consumption without considering the specific energy demand of catering equipment for its main purpose. One thing is already overlooked: The professional sector has already an efficiency advantage. Due to a high food output per cooking unit a professional kitchen has a reduced environment footprint in comparison with the private sector. Measures or test methods that lead to confusion and mixture between household and professional are detrimental to our business. The sector-specific requirements such as the number of food preparations, conditions in the workspace with different cooking processes, which depends on the working staff and operability, different hygiene requirements, etc. must be able to be met in the long term. The preparation of food in a hospital at the weekend must be more effective than during the week with more personnel, in the restaurant it must be quick but of high quality, etc. These matters are still being developed and so far could not be brought under a common denominator. Here is a market by professionals for professionals who are familiar with energy consumption and environmental impacts and take this into account in the purchase situation.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

16 Mar 2021

The energy consumption of professional kitchens is one of the largest energy consumers in restaurants, hotels or even office buildings. Technically, there is potential for improvement. However, these are poorly implemented as the industry and developments are misunderstood. A proactive cooperation with policymaker would be better than an intervention against the industry. The technical points mentioned in the enclosed document are probably a kind of Smart Readiness Indicator for kitchen systems, thresholds for the future of foodservice equipment according to the targets of the renovation wave.It's about power optimisation, digitisation, building information modeling (BIM) ...
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Response to Revision of EU Ambient Air Quality legislation

11 Jan 2021

The Industrial Association HKI sees the greatest potential for improving air quality in overcoming the blockade when replacing old appliances with more effective, combined biomass central and individual room heating. The announced Renovation Wave should, among other things, also target precisely there. Modernisation through innovative technology reduces particulate matter emissions by up to 90 percent. At the same time, energy efficiency has increased by over 200 percent (source: BMWi). The efficiency factor used to be between 50-70 percent. Today it is between 80-90 percent. The decentralised use of biomass in urban areas only plays a subordinate role. But it is quite important in the country. However, there are still many outdated appliances in place. And while there are a large number of options for heat supply available in the city, a decentralized approach must be chosen in rural areas - in particular using biomass to reduce CO2. The problem is that the exchange is increasingly associated with additional requirements (e.g. EEG2 in Germany). That makes the exchange unattractive and uneconomical. Every exchange must be justified individually. Exchange barriers must be dismantled.
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