POSITION PAPER – MAKE ECODESIGN AND ECOLABELLING HEAT-PUMP-READY?
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
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
CHAPTER II: ECODESIGN
CHAPTER III: ENERGY LABELLING