The European Heat Pump Association (EHPA) has submitted comprehensive feedback on the European Commission's draft State Aid Framework accompanying the Clean Industrial Deal (CISAF), calling for structural simplification, faster aid disbursement, and greater support for heat pump technologies.
Framework Structure and Clarity
EHPA stresses that the current draft is too complex, potentially deterring small and medium-sized enterprises (SMEs) from accessing funding. It recommends adding explicit subsections for each aid type to clearly define scope, eligibility criteria, aid intensity, and disbursement procedures. “A well-structured framework will reduce administrative burdens and increase legal certainty,” EHPA states.
Timelines and Aid Accessibility
To avoid investment delays, EHPA urges the Commission to establish indicative timelines—suggesting that regulatory decisions should be made within six months of application submission. The organization also calls for a more flexible penalty system to accommodate justified project delays, such as those due to grid connection issues or complex industrial heat pump installations.
Support for Non-Fossil Flexibility
EHPA warns that the current wording in Section 4.2 may inadvertently exclude heat pumps from flexibility support schemes. It advocates for a revised definition that includes aggregated demand response and interoperability schemes, essential for integrating distributed energy resources. EHPA also recommends expanding eligible financial instruments beyond contracts, to include market-based premiums or operational subsidies.
Decarbonization Priorities and Financial Mechanisms
In Section 5, EHPA calls for the inclusion of Two-Way Carbon Contracts for Difference (CCfDs) to stabilize operating costs and encourage investment in electrified industrial processes. It also recommends aligning aid intensities for electrification projects with those for hydrogen, removing preferential treatment for natural gas, and applying differentiated deadlines for custom industrial heat pump installations.
Manufacturing Capacity and Component Aid
EHPA supports state aid for the production of both heat pumps and their components. It proposes that a list of eligible key components—such as compressors, heat exchangers, and inverters—be included in a dedicated annex. Furthermore, it suggests harmonizing aid ceilings and intensities with those defined in the Temporary Crisis and Transition Framework, advocating for up to EUR 350 million per project in assisted areas.
Private Investment Models
In Section 7, EHPA recommends explicitly including Energy Service Companies (ESCOs) and Energy-as-a-Service (EaaS) providers as eligible private investors. These models, EHPA argues, are critical to scaling heat pump deployment, especially through performance-based contracts. Direct grants, rather than loans or equity, are needed to make these models financially viable.
“By ensuring the aid framework is accessible, simplified, and aligned with market realities, the Commission can accelerate investment in clean technologies and deliver on its climate ambitions,” said Maria Spanó, Senior Policy Officer at EHPA.
This position paper underscores EHPA’s ongoing commitment to advancing heat pump technologies as a cornerstone of Europe’s clean energy transition.