The European Heat Pump Association (EHPA)
has published detailed feedback on the draft Ecodesign and Energy Labelling Regulations for space and combination heaters, water heaters, and storage tanks (Lots 1 and 2), welcoming the European Commission’s aim to modernise the framework while cautioning against potential unintended impacts on heat pump affordability and deployment.
EHPA supports the Commission’s efforts to improve energy performance, consumer information, and alignment with climate goals. However, it warns that proposed new testing methods, third-party conformity assessments, and data requirements could increase compliance costs and delay market entry of heat pump products.
On Lot 1, EHPA calls for greater clarity and realism in implementation timelines, particularly for the new testing procedures and conformity assessments. It recommends limiting mandatory third-party conformity assessment to products under 70 kW and aligning testing requirements with the Heat Pump Keymark system. EHPA also proposes a uniform 72-month transition period for all models to allow time for industry adaptation.
The association raises concerns over self-monitoring obligations, recommending simplification and focusing only on directly measured parameters. EHPA also calls for flexibility in data access rules, stressing alignment with the EU Data Act and cybersecurity regulations.
Regarding spare parts, EHPA supports a 15-day delivery target but urges exceptions for justifiable delays and proposes limiting the list to critical components. It also highlights the need for manufacturers to retain control over access to safety-sensitive parts.
EHPA further suggests digitalising user manuals, deferring the entry into force of the compensation method until relevant standardisation work is completed, and applying revised sound power testing uniformly to all models. It also calls for adjusted energy label class thresholds to avoid misleading consumers and harming heat pump uptake.
For Lot 2, EHPA recommends maintaining flexibility in load profile declarations for water heaters and dropping requirements that lack corresponding measurement methods. It also proposes postponing the 'out-of-the-box mode' requirement to 24 months after regulation entry into force.
"EHPA believes that the success of the revised framework will depend on its ability to deliver measurable energy and climate benefits while ensuring rules can be implemented efficiently and consistently across Member States," the association states in the position paper.
