Position Paper on Ecolabel for Heating Generators - July 2013 - EPEE

POSITION PAPER EU ECOLABEL CRITERIA FOR HYDRONIC HEATING GENERATORS – July 2013
Based on the latest version of the draft criteria for heating generators presented during the last EU Ecolabelling
Board meeting (19 June 2013), the European Partnership for Energy and the Environment (EPEE) takes the
following position. EPEE represents the heating, cooling and ventilation sector in Europe.
EPEE welcomes the latest criteria for the Ecolabel for Hydronic Heating Generators as presented
by the European Commission, given that they:
o
o
Keep hydronic heat pumps in the scope of the Ecolabel for Heating Generators.
Include balanced and fair criteria, including a technology neutral noise criterion which
allows for one noise level test per family of products.
EPEE calls on the Commission, however, to:
o Ensure full alignment with the Energy Label of ENER LOT 1.
While the latest version of the criteria is considerably more aligned with the Energy Label of
ENER LOT 1, discrepancy remains between the definitions of space heaters used in the
current draft criteria of the Ecolabel for Heating Generators, in comparison to the
definitions used in the Energy Label of ENER LOT 1. Therefore, EPEE calls on the
Commission to include the definition used in the Energy Label of ENER LOT 1:
“- ‘package of space heater, temperature control and solar device’ means a package
offered to the end-user containing one or more space heaters combined with one or more
temperature controls and/or one or more solar devices;
- ‘package of combination heater, temperature control and solar device’ means a package
offered to the end-user containing one or more combination heaters combined with one or
more temperature controls, and/or one or more solar devices”
o
o
Clarify the wording package of space heater used in criterion 1, 1 as this provision seems
to suggest that each separate heat generator within the package would need to meet all
criteria. This would – when several heat generator technologies are combined – render it
effectively impossible to obtain the Ecolabel.
Provide clear guidance on the criterion on Substances of Very High Concern (SVHC).
While EPEE understands that criterion 10 is a direct result of the applicable framework
legislation, currently, no Ecolabel can be obtained when a SHVC under article 59 REACH
Regulation is present. This rends the viability of the Ecolabel questionable.
1 "Table 1 presents the applicability of the different criteria to each heat generator technology. In the case of a
package of space heater, it shall comply with all the criteria applicable to each of the heat generator
technologies it is made of."
EPEE
46, Avenue des Arts, 1000 Brussels, Belgium
Tel : +32-2 732 70 40 / Fax : +32-2 732 71 76
Secretariat@epeeglobal.org / www.epeeglobal.org

About EPEE
The European Partnership for Energy and the Environment (EPEE) represents the refrigeration, air-conditioning
and heat pump industry in Europe. Founded in the year 2000, EPEE’s membership is composed of 40 member
companies and national associations across Europe realising a turnover of over 30 billion Euros and employing
more than 200,000 people in Europe. As an expert association, EPEE is supporting safe, environmentally and
economically viable technologies with the objective of promoting a better understanding of the sector in the
EU and contributing to the development of effective European policies. For more information please visit:
www.epeeglobal.org.
EPEE
46, Avenue des Arts, 1000 Brussels, Belgium
Tel : +32-2 732 70 40 / Fax : +32-2 732 71 76
Secretariat@epeeglobal.org / www.epeeglobal.org