Position paper
EPEE – Position Paper on ENTR Lot 1 (professional refrigeration)
Position paper
EPEE – Position Paper on ENTR Lot 1 (professional refrigeration) :

The European Commission is reviewing Ecodesign Regulation (No) EU 2015/1095 and Energy Labelling Regulation (EU) No 2015/1094 on professional refrigeration (ENTR Lot 1). 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 developments.


This paper provides the EPEE position on the most recent proposals from the Commission on the review of the requirements for professional refrigeration. This document is divided into two parts. In the first chapter, we explain our views on the energy labelling proposals under ENTR Lot 1. The second part focusses on the ecodesign proposals for professional refrigeration. Both policies were presented and discussed at the stakeholder meeting of 13 January 2022, which is also taken into consideration in our position.



  1. No energy label for condensing units.



  1. Exclude Walk-in Cold Rooms from the scope of ecodesign requirements.
  2. Perform complete analysis of MEPS and BAT values for process chillers.
  3. Condensing units: perform proper analysis on performance and market data.
  4. Condensing units: do not increase the scope above 20 KW for LT & 50 KW for MT.
  5. Condensing units: consider to maintain some Global Warming Potential bonus.
  6. Condensing units: use available standards for testing and calculating evaporating temperature with refrigerant mixtures.
  7. Process chillers: maintain MEPS for chillers without the bonus.
  8. Process chillers: rationalise the scope.
  9. Counter cabinets: provide dedicated data for frozen and chilled separately.
  10. Heavy duty cabinets: provide clarification on removing concessional EEI for heavy duty cabinets.
  11. Use the AR4 Report for GWP values.
  12. Maintain verification tolerance levels for all products.
  13. No refrigerated containers in requirements under WICRs.
  14. Further efficiency improvements by considering heat recovery.
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