Policy Recommendations Room Air Conditioners

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. One label for all air conditioners

The merger of the energy labels for all types of room air conditioners into one so that all products can be compared to one another. The actual situation is very misleading to the consumer and unfairly favours inefficient mobile air conditioners.

3. Strong energy class thresholds.

Based on the current BAT products, the threshold for class B should be tightened. The new regulation will have a stronger impact on the market if class B is not already highly populated at the time of entry into force of the regulation.

4. 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.

5. Display of power input and output.

The proposal shows the power output (kW) as size indicator on the label. We believe that adding – and labelling – the power input (kW) will serve as an additional size indicator for consumers and installers that will enable them to choose the optimal size and efficiency for their individual requirements. Consumers like to know the power consumption and to calculate their electricity cost.

6. 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 air conditioners and reversible heat pumps, the cooling power (input and output) as well as the room size should be visibly included in the product information sheets.

7. Alignment of the measurement metric.

The calculation of the capacity (kW) for split units and single and double duct units is currently based on different outside temperatures, which leads to larger declared capacities for ducted units. We recommend that that calculation of the capacity be adjusted to the same outdoor temperature for all types of air conditioners.