The European Commission is reviewing ecodesign Regulation 813/2013 and energy labelling
Regulation 811/2013 for space heaters (ENER Lot 1) and ecodesign Regulation 814/2013 and energy
labelling Regulation 812/2014 for water heaters (ENER Lot 2). 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 EPEE’s position on the most recent proposals from the Commission on the review
of the requirements for space and water heaters. In the first part, we highlight general concerns that
apply to both policy files. In the second part, we elaborate our views on the ecodesign proposals for
space and water heaters, which were presented at the last Consultation Forum of 27 and 28
September 2021. The third part continues with our comments to the energy labelling proposals, which
were also discussed at the Consultation Forum.

CHAPTER I: GENERAL

1. Content of legal text.
2. Enforce requirements that are technology neutral.

CHAPTER II: ECODESIGN

1. No introduction of the compensation methods without thorough assessment.
2. Avoid significant penalties for heat pumps for unrealistic peak temperature requirements.
3. Ensure adequate requirements for hybrid systems.
4. Reduce MEPS for LT applications.
5. Reduce MEPS for large tapping profiles of heat pumps.
6. More study needed on real life data monitoring.
7. Do not change the sound power requirements.
8. Define the scope of material efficiency requirements.
9. Introduce a secure platform for the upload of test settings.
10. Ensure that the scope extension does not lead to double regulation.
11. Strengthen market surveillance first.
12. Remove detailed test methods and procedures from the regulation.
13. Further evaluation is needed before changing the brine temperatures.
14. Clarify the definition for circulation water heater.

CHAPTER III: ENERGY LABELLING

1. Introduce a single energy label with a single scale for all technologies.
2. Better balancing of the MT labelling scale
3. Lower the energy labelling scale of LT heat pumps.
4. Rebalance the energy label scale for large combi heaters.
5. Remove the optional regime at 65 ˚C.
6. Enhance digital information sharing