Policy Recommendations Local Space Heaters

Complete policy recommendations for download (pdf, August 2022), covering the entire proposed merged Energy Labelling of room heaters (incl. local space heaters), room air conditioners and comfort fans.

Current Regulations

The corresponding Ecodesign regulation has entered into force January 1st 2022. The regulation for the energy label was already mandatory and entered into force Januar 1st 2018.

Policy recommendations Energy Labelling

Topten welcomes the revision of the Regulation (EU) No 2015/1186 regarding energy labelling of local space heaters.

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 and gives the market a clear indicator which technologies are sustainable and which obsolete in the long-term.

One major change that we propose across all technologies within the scope of the merged regulation is the elimination of the correction factors in the calculation of the energy efficiency index (EEI); specifically of the correction factors for control features as listed in table 30 of the Working Document. We see 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.

Scope

To achieve maximum impact of the regulation under review, we propose increasing the scope of all local space heaters to 50 kW. This will also prevent misunderstandings on the market about which products fall within the scope of the regulation.

The Working Document also rightfully proposes the inclusion of electric joule room heaters into the merged regulation. As the review study ascertained, electric joule room heaters represent more than 70 % of the sales volume of all local space heaters, adding importance to the inclusion of this highly inefficient technology into the scope.

Biomass label factor

We strongly support the proposal in the Working Document to abolish the biomass label factor of 1.45 for local space heaters running on biomass. We agree that leaving it in would be going against the Zero Pollution Action Plan and Air Quality Directive and misdirecting consumers.

Label Information – Emissions

Air pollution is the “elephant in the room”. Due to the current political and economic situation, sales of solid fuel heaters have gone through the roof in many European Countries. We agree with the proposal in the Working Document that the estimated particle emission levels be shown on the label; providing this information to consumers and official stakeholders at first glance will improve their ability to make truly informed decisions.

Benchmarks:

Current BAT models on the European market can be found on https://www.topten.eu/private/products/local_space_heaters. The calculation of the new EEI values includes many correction factors and requires knowledge of many additional features that are not declared for the products on Topten; due to this complexity, we did not calculate the future energy classes of the current BAT products. This example shows well why we recommend to reduce correction factors in the EEI calculation significantly.

Policy recommendations Ecodesign

One of the main concerns is the emission of pollutants when wood is burnt. Many regions/countries have forbidden certain biomass stoves as a result. This may be reversed now that the Ecodesign minimum requirements have come into action and stoves emit less pollutants. Ecodesign for stoves and boilers needs to push for increasingly strict air-pollutant regulations.

Another important aspect is proper maintenance of the chimney and stove, not only for a clean burning process but also for fire safety reasons. Some countries have national regulations on this (e.g. in Switzerland, control and cleaning is mandatory on a regular basis - depending on the oven once to twice a year). It would be advisable to include adequate requirements in the Ecodesign regulation.


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08/2022 Hepp

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