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Stiebel Eltron GmbH Co. KG

STE

STIEBEL ELTRON ist eine international ausgerichtete Unternehmensgruppe und gehört weltweit zu den Markt- und Technologieführern in den Bereichen ‚Haustechnik‘ und ‚Erneuerbare Energien‘.

Lobbying Activity

Response to Minimum requirements for certification programmes and training attestations for RACHP equipment

10 Jun 2024

In our view, it is important to point out that the transition from the previous regulations in Commission Implementing Regulation (EU) 2015/2067 to a possible new categorisation with categories A - D in accordance with the current draft does not create any additional hurdles for the current holders of certification. Article 10 Certification and training of the new F-Gas Regulation (2024/573) clarifies that existing certificates and training attestations issued in accordance with Regulation (EU) No 517/2014 shall remain valid. The required refreshment training courses or evaluation processes for already certified natural persons should be understood and carried out in accordance with this principle and enable the holders of certificate files to make the transition to the proposed new certificate categories as simple as possible, both in terms of time and cost. There should be no additional training for holders of the previous category I, as they already have the highest category and are trained and work in a correspondingly practice-orientated manner. The new topics to be covered are manageable. And if they do, then the hurdle for recertification must be very low and as favourable as possible for the certificate holder. Care should also be taken to ensure that the transitional phase of a maximum of 7 years laid down in the F-Gas Regulation is utilised. It must also be questioned whether it is appropriate and expedient to define explicit and separate requirements for certificates for natural persons working with the substances (NH3) and (CO2) in a Commission Implementing Regulation for the F-Gas Regulation. In our view, this approach should be reconsidered.
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Response to Energy labelling requirements for local space heaters (review)

9 Aug 2022

When deciding on a uniform label for individual room heaters and air conditioners, it is important to also make a non-technical but political assessment of the issue. The technology of electric heating must never run the risk of being banned via ErP product regulation. As a pioneer in the field of heat pumps and with more than 45 years of experience in this area, we are convinced of the outstanding importance of heat pump technology for building heating and its decisive contribution to the success of the energy transition. However, we also see the long-term importance of electric heating systems (hot water and space heating) as a supplement to or in combination with other heating systems. • Electric heaters are conceivable in a wide variety of forms and power ranges and deliver the energy required with wattage precision. Similar to the comparison of electric instantaneous water heaters for decentralised hot water preparation with a central hot water supply (keyword: distribution and standby losses), decentralised electric heaters can have great energy advantages over hydraulic systems for space heating. The exclusive comparison with air-conditioning systems is therefore misleading and does not represent the complete range of applications of electric heaters. For example, electric heaters/heating elements are an indispensable component of modern and highly efficient air/air heating systems. Here, the central air/exhaust air heat pump is specifically supplemented by decentralised heating elements when required. They are ideally and efficiently suited to meet local or short-term comfort requirements. This demand only occurs at a fraction of the heating time, but it does occur. This combination of units allows for a very efficient design of the overall system. Air-conditioning systems would be completely unsuitable for this application. • There is a wide variety of applications for electric heaters that make a lot of sense from an energy point of view when looking at the system level (storage heaters in case of power surplus, etc.). • Electric heaters would fall into class “G” if Lot 10 and 20 are merged. How does one make the builder of a low-energy house understand a heating plan with a high-efficiency HP or ventilation heating in combination with direct electric heaters of class “G” as the overall energy-optimal solution? • Even before the publication of the new regulation, the Commission will announce a new value for PEF electricity in Europe on 25 December 2022. The corresponding study has started with a workshop on 30 June. When the new ErP regulation is published, the efficiency values of e-heaters will thus already be outdated. This circumstance applies to all product lots, but in the case of electric heating this circumstance is elementary. • The poor classification in class “G” bears the real danger that products in this class will be banned in a future revision of the directive, as the efficiency classes are to be "shifted" successively upwards. From our point of view, it is therefore important with regard to the overall efficiency of buildings that the technology of electric heating in its range must never run the risk of being banned via the ErP product regulation. Supplementary assessment criteria such as sound or a look ahead to the new legal framework "Establishing a framework for setting ecodesign requirements for sustainable products (ESPR)" will give the technically very simple technology of electric heating advantages in the comparative assessment.
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Meeting with Michael Bloss (Member of the European Parliament)

12 Apr 2022 · ETS2

Response to Ecodesign and energy labelling working plan 2020-2024

7 May 2021

On behalf of the Stiebel Eltron Group I would like to comment on the Ecodesign and Energy Labelling Working Plan 2020-2024. Special topis are: -LT-emitters under Ecodesign policy -Horizontal Measures: Lightweight design, Recycled content, Ecological profile, Durability; Scarce and critical raw materials Please find the attached letter.
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