The European Heat Pump Association (EHPA) has provided feedback on the European Commission’s draft Delegated Act concerning the list of components for heat pumps under the Net-Zero Industry Act (NZIA) EU 2024/1735. EHPA welcomes the opportunity to contribute but highlights several concerns regarding the current proposal.
Definition of Heat Pumps
EHPA argues that the definition of "heat pump" in the draft Delegated Act does not align with existing legislation. The association recommends adopting the definition from Article 2(18) of the 2010 Energy Performance of Buildings Directive (EPBD), which covers air, water, and ground source heat pumps for residential, industrial, and commercial use.
Concerns Over Component Selection
The association raises issues regarding the selection of components listed in the Annex, stating that some choices lack technical justification. Specifically, EHPA questions the inclusion of scroll compressors and four-way valves without a clear rationale. The association also notes that several key components essential for energy efficiency are missing. Additionally, EHPA believes that the inclusion of “heat pumps” in the list is an error and suggests replacing it with “heat exchangers.”
EHPA urges the European Commission to conduct a detailed technical assessment and provide clear justification for the selected components. To support this, EHPA plans to submit an industry-backed list of additional components for consideration.
Additional Components for Industrial and Commercial Heat Pumps
To ensure fair treatment of all heat pump technologies, EHPA recommends expanding the list to better reflect the needs of industrial and commercial systems. The association proposes adding a separate category for industrial heat pumps, including components such as centrifugal, screw, and piston compressors, condensers, sub-coolers, evaporators, and mechanical vapor recompression (MVR) systems.
EHPA emphasizes the importance of continued dialogue between policymakers and industry stakeholders to ensure a technically sound and inclusive Delegated Act that supports European manufacturing and innovation in heat pump technology.
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