UNICLIMA
UNICLIMA
Syndicat représentant les industrie Thermiques, Aérauliques et Frigorifiques implantées en France
ID: 304837040742-06
Lobbying Activity
Response to Union framework for the calculation of life-cycle Global Warming Potential for new buildings
31 Oct 2025
Uniclima represents the French manufacturers in heating cooling and ventilation sectors. Uniclima supports the introduction of LCA in the building regulation for new buildings, as it is the case in France from 2022. However, regarding HVAC products which are mainly coverd by ErP regulation (and ESPR in the future), the standard required for LCA is EN50693/prEN IEC63366. So this standard should be mentionned for these products in the Annex of the delegated act.
Read full response26 Aug 2025
Uniclima préconise lextension du dispositif MACF/CBAM aux équipements du génie climatique, du fait de leur forte proportion de matières couvertes par le MACF/CBAM, (supérieure à 75%).
Read full response6 May 2025
Add « and ventilation » at the end of definition « conditioned space » in the delegated regulation draft, article 2 (24). Indeed, ventilation also has an impact on temperature and humidity. Energy recovery ventilation allows to pre-heat or pre-cool passively the air which is introduced in the building. Moreover, it can humidify air through a dedicated functionality or dry it through the air renewal rate. There is a reference to this in the table of page 14 of the annex document. In the Annexes of the delegated regulation draft : - 2.6. of ANNEX I, replace « comfort » by « indoor environmental quality ». Indeed, comfort is not the appropriate word here as indoor environmental quality (IEQ) does not refer only to such a notion. IEQ, including temperature and humidity levels, is clearly a determinant of the health of people living indoors. Too high or too low temperatures and humidity have a detrimental impact on the health of people living indoors. So this aspect cannot be reduced only to comfort. - « Operation schedules and controls » in Table 3 of ANNEX III, about Ventilation section : As indicated in article 5 paragraph 1 of the EPBD recast directive, minimum energy performance requirements have to take into account indoor environmental quality in order to avoid possible negative effects such as inadequate ventilation. As such, ventilation systems should run continuously in residential buildings and during an extended period of time (at least one hour before and one hour after) in relation to the effective presence of people in non-residential buildings. This should be reflected in the schedules transmitted by the member states. - « Building systems » in Table 3 of ANNEX III, about Ventilation rate in l/s, replace the description by « To be indicated and/or evaluated according to the information relative to the products and relevant standards, such as EN 16798 -7 for natural ventilation. ». Indeed, Ventilation should be sub-divided into two categories. A first one for mechanical ventilation systems for which an accurate air renewal rate is readily available based on the type of equipment which is implemented in the building. A second one for window airing and natural ventilation which could partly rely on EN 16798-7, applying a grossing-up factor due to the uncontrolled nature of this type of air renewal in order to ensure that the minimum air renewal rates are reached, and be calculated for each period of time when people are present in the building and cumulated over the whole year. The EN 16798 standard (its part 7) will be useful only to calculate the air renewal rate of window airing and natural ventilation. - « Building energy need » in Table 3 of ANNEX III, replace « natural » by « energy recovery » in the description. Indeed, natural ventilation should not be mentionned in this part as it increases the energy need of the building and doesnt reduce it. Indeed, natural ventilation through grilles or stacks renews air through air temperature difference between the inside and the outside of the building. During winter and mid-seasons, it entails significant air renewal rates leading to important thermal losses and raises substantially the heating needs of the buildings. On the contrary, energy recovery ventilation systems allow to pre-heat and pre-cool, through a passive exchanger, the incoming air in the building allowing to benefit to a very large extent of the air temperature inside the building (hot in winter and cold in summer). - « Building energy use » in Table 3 of ANNEX III, replace the text in brackets with « (not including the energy input for active preheating and pre-cooling of the air) » A few additional details to make a clear difference with the passive energy recovery of mechanical ventilation systems. - 2.2. below Table 3 of ANNEX III, add « Article 5(1) ,» to the list because IEQ is also mentioned in article 5(1) and it should then be quoted. - Below Table 4 of ANNEX III, add « For ventilation syst
Read full responseResponse to Ecodesign requirements for air heating and cooling products (review)
30 Aug 2024
Uniclima represents the heating, ventilation, air-conditioning and refrigeration industries. It has 83 companies or groups that manufacture essential equipment for the energy renovation of buildings and for the industry sector. These include heat pumps (air/water, water/water or air/air), solar thermal systems, biomass, gas or oil boilers, water radiators, ventilation and air handling equipment, and refrigeration equipment. As part of the revision of Regulation (EU) 2016/2281, also known as Lot 21, and in response to the call for contributions issued by the European Commission on 21st June, Uniclima draws the Commission's attention to the following topics: - The revision of this regulation must take into account other regulations or projects that have a direct impact on the design of the equipment subject to this lot - The definitions of the products and equipment subject to this draft revision must be clear - The energy performance of equipment must take into account the energy recovery functionalities of all equipment when this functionality is present - There is no need for energy labelling for equipment subject to this revision. Please find enclosed a detailed contribution
Read full responseResponse to Energy labelling requirements for local space heaters (review)
14 Sept 2022
You will find enclosed Uniclima’s comments about the proposal of new labels for local space heaters and their merging with air conditioners, those already described in the (EU) 626/2011 regulation, of which the review is also ongoing.
Summary:
- Clarify control functions to assess the product efficiency
- Review the energy efficiency classes
- Simplify the energy label layout and its content
- Review the rules for providing the energy label
- Adapt check tolerances for market surveillance
- Avoid two sound power level declarations for a single product
- Maintain two years between publication and enforcement of new rules
- Reconsider the introduction of the compensation method
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