Position paper
Position Paper on energy labelling for ENER Lot 10 following the Commission’s Call for Evidence
Position paper
Position Paper on energy labelling for ENER Lot 10 following the Commission’s Call for Evidence :
4/03/2022

The European Commission is reviewing energy labelling Regulation (EU) No 626/2011 for air-to-air heat pumps, air conditioners, and comfort fans (ENER Lot 10). EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, supports the EU ecodesign and energy labelling policies, and agrees with the need to keep the legislation up-to-date and in line with the latest
technological and market developments.

This paper provides EPEE’s position on the most recent proposals from the Commission on the review of ENER Lot 10. We explain our support for a merged energy label for air-to-air heat pumps, air conditioners, and comfort fans (ENER Lot 10) and local space heaters (ENER Lot 20), as we believe that this will help consumers choose the most energy efficient products.

1. Continue merger proposal of energy labels for heating products.
2. Efficiency to be considered further in terms of granularity

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