Complete policy recommendations for download (pdf, August 2022), covering the entire proposed merged Energy Labelling of room heaters (incl. room heat pumps), room air conditioners and comfort fans.
Recommendations in short
Topten welcomes the revision of the Regulations (EU) No 2015/1186 regarding energy labelling of local space heaters and (EU) No 2011/626 regarding energy labelling of air conditioners and comfort fans. Specifically, we support the merging of regulations for room appliances with the same function into one energy label - this offers comparability for the significant percentage of consumers who do have a choice between technologies.
The merging of the Energy Labelling gives the market a clear indicator which technologies are sustainable and which obsolete in the long-term. Designing separate labels for products of the same function that result in class A models for low efficiency as well as high efficiency technologies is misleading consumers and hindering an informed decision making process.
Key policy recommendations
1. Eliminate correction factors for control features.
The correction factors significantly increase the complexity of the calculation without a corresponding usefulness. Most important, however, is the risk that such control features will be added in low quality by manufacturers in order to improve the calculated EEI; this would distort the labelling scheme as the energy consumption of the products would not truly be reduced – or would even be increased in the worst cases – while gaining a better efficiency declaration.
2. Promotion of low GWP refrigerants.
Although the F-Gas regulation has been into force for several years, there should be further measures in place to accelerate the phase-down of HFC refrigerants. The label should indicate whether the used refrigerant has a high climate impact. A malus system that would penalise high GWP air conditioners should be considered.
3. Strong energy class thresholds.
Based on the current BAT products, the thresholds for classes A, B and C should be tightened. For the new regulation to have a strong impact on the market and avoid that products already populate the top classes at the time of entry into force of the regulation, Topten calls for tighter thresholds for the top classes - ideally leaving class A empty.
4. Complete information in product information sheets.
The product information sheet should always contain the energy efficiency index of the products as well as all information necessary to calculate the energy efficiency index for all product types. This includes a field to list all applicable control features that are subject to correction factors (Fcorr) as listed in Table 30 of the Working Document.
For reversible heat pumps, the cooling power (input and output) as well as the room size should be visibly included in the product information sheets.
Standards and labels
- EU Ecodesign regulation: Commission Regulation (EU) No 813/2013 of 2 August 2013 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for space heaters and combination heaters.
- EU Energy Label regulation: Commission Delegated Regulation (EU) No 811/2013 of 18 February 2013 supplementing Directive 2010/30/EU of the European Parliament and of the Council with regard to the energy labelling of space heaters, combination heaters, packages of space heater, temperature control and solar device and packages of combination heater, temperature control and solar device.
- Topten Policy Recommendations from August 2022
- EHPA Quality Label (European Quality Label for Heat Pumps)
- Energy efficiency measures by the European Commission
- The European council for an energy efficient economy eceee provides a status overview on all products in the Ecodesign & Energy Labelling process
- Coolproducts informs about the EU ecodesign process. It is a coalition of NGOs' campaign for a stronger, fast Ecodesign Directive to save the climate and money.
- ECOS (Ecostandard) is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies and laws.
- EPREL (European Product Registry for Energy Labelling) is the European product database. Products with an energy label are registered in EPREL in order to provide consumers with detailed product information.