EU Ecodesign Regulation: Comparison of the energy efficiency of room heaters with air-to-air heat pumps not expedient

The Ecodesign Regulation (EU) 2015/1188 and the Energy Labelling Regulation (EU) 2015/1186 are currently under revision. The Ecodesign Regulation also includes heating appliances for commercial and industrial halls under the title of room heaters. 

Gas-powered infrared heaters - light and dark radiators - with a future output limit of up to 300kW - are also covered by the Ecodesign Regulation, but are exempted from the Energy Labelling Regulation (EU) 2015/1186. 

figawa at meeting of the advisory board of the Federal Institute for Materials Research and Testing (BAM) in Berlin

On 13 August 2019, a national meeting of various stakeholders took place in Berlin to exchange views on the planned revision of the EU Eco-design Regulation. In particular, the previously applicable Ecodesign Regulation was examined and unclear factors or terms in need of explanation were questioned by representatives of the ministries.

In addition to representatives of the Ministry of Economic Affairs, the Federal Ministry for the Environment, Nature Conservation and Nuclear Safety, the Federal Environment Agency from Dessau and BAM, market surveillance participants as well as company and association representatives were also present. figawa was also present and actively involved.

During the meeting, the Federal Environment Agency presented a draft of a new, more comprehensive energy label which, in addition to radiators and other space heaters, should also include electrically operated heat pumps ≤ 12 kW. In such a common labeling only heat pumps received best evaluations, gas-operated devices cannot come over a C or D. 

figawa made clear in the meeting that it concerns radiators and small electrical heat pumps around different ranges of use as well as different physical effect mechanisms and consequently different computation procedures of the energy efficiency. The direct comparison of energy efficiency values and joint labelling would therefore lead to errors and misinterpretations.

figawa submits position paper

An official detailed statement by figawa was submitted to BAM.

In particular, it emphatically contradicts the idea of directly comparing the energy efficiency of the room heaters mentioned above with the energy efficiency of air-to-air heat pumps in a joint label.

A more comprehensive statement on the entire revision process at European level was already submitted to the EU Commission in March 2019 by ELVHIS, the leading European association of manufacturers of gas infrared heaters.

Before the consultation forum on the Ecodesign Regulation begins in Brussels on 7 October 2019, a national consultation forum will take place on 10 September.