REHVA has submitted formal comments to the European Commission’s Call for Evidence on the post-2030 energy efficiency framework, presenting the HVAC sector’s technical perspective on the design of future rules. The Call for Evidence is open from 19 March to 16 April 2026, a public consultation runs until 12 June 2026, and the Commission’s legislative proposal is expected in the fourth quarter of 2026.
In its submission, REHVA says energy efficiency should be treated as an indicator or guiding principle rather than a hard regulatory requirement that could remove products from the market. It argues that, under existing EU legislation, energy efficiency is a means to deliver cost-effective end-use energy savings and more efficient conversion, transmission, distribution and use of energy, not a target in itself.
A central point in the submission is the need to define assessment boundaries when measuring or comparing efficiency. REHVA says different boundaries can produce different results, citing a heat pump with a coefficient of performance of 3 and an apparent efficiency of 300%, while a thermal solar panel registers around 80% when solar radiation is counted as input. It adds that, across the full energy chain, a heat pump using German grid electricity produces around 100 gCO2/kWh of useful energy, while the solar panel produces zero during operation.
REHVA also says HVAC product performance depends on running conditions, system integration, control strategies and interaction with other components. It cites electric boilers as an example, noting that under current Ecodesign rules they have a standalone efficiency rating of about 43%, but in system use they can support thermal storage of renewable electricity from photovoltaics, grid flexibility and use of low or negative electricity prices.
The association recommends that post-2030 targets be based on primary energy, both total and non-renewable, and CO2 emissions. It also calls for policies that promote measurement and verification of in-operation energy performance, continuous monitoring, data-driven optimisation, building automation and control systems, as well as proper commissioning, regular re-commissioning and lifecycle optimisation.
REHVA further comments on local heating and cooling plans under Article 26 of Directive (EU) 2023/1791, saying these should also address how extra electricity demand from electrification will be supplied and managed. It recommends integrating renewable electricity production, storage and distribution, using dynamic modelling with shorter timesteps, and developing guidance documents and related databases at European level to reduce fragmentation in national calculation methodologies.
