We welcome the revision of the EU’s ecodesign requirements for air heating and cooling products (EU 2016/2281) and we would support standards in the UK aligning to these.
In particular and in line with ECOS’ submission, we think the following should be considered:
Expand the scope of the ecodesign requirements
We suggest the scope of the ecodesign requirements should be extended to include chillers using evaporative condensing and free coolers. We would also support the inclusion of:
- Absorption process-based refrigeration chillers, typically using heat as the energy source.
- Chillers operating within different temperature ranges
- Products using solid fuels, such as biomass
- Products that co-produce power and/or heating, as cogeneration or trigeneration.
Expand the scope of energy labelling regulations
The most used products that are within the scope of this regulation should be required to have an energy label. This should include all products with predicted sales above 50,000 units per year until 2050.
Revise the energy efficiency requirements
We recommend the revision of the energy efficiency requirements so that they align with the requirements of similar products such as space heaters (EU2013/813) and air conditioners/ air to air heat pumps (EU2016/2281).
Reduce NOx emission for warm air heaters
As the current regulation allows higher NOx emissions for warm air heaters compared to boilers of the same capacity, we recommend that these are aligned.
Additionally, in light of the new F-gas regulation which limits the greenhouse warming potential for air-to-air heat pumps, we support these limits being applied to the products in the scope of this review.
It is crucial to prioritise using natural refrigerants and accelerate the phase out of PFAS.
Measurements and calculations
We support the recommendation that air conditioners and heat pumps should be tested with the compensation method, currently in the requirements revision for space and water heaters.
For heat pumps, we question the need to have the option of a water loop with an inlet temperature on the primary side of 20°C. Such high temperatures give a very high efficiency that is not comparable with the results of tests with lower inlet temperatures, the latter being closer to real-life operations.
Products tested with this inlet temperature will show a very high efficiency without having a better efficiency for other temperature sets, potentially leading to confusion among consumers and allowing low efficiency products to remain on the market. We therefore support the proposal to lower the temperature sets for tests, for more conventional working mode.
For air-conditioning, the specified indoor temperature is 27°C is unrealistically high and support having it at 24°C to reflect generally acceptable indoor comfort. We support the introduction of third-party conformity assessment and allow interoperability and smart demand control management with the grids.
Circular economy requirements
We support the introduction of circular economy requirements in the revised regulation, including:
- access to spare parts and repair information within 15 days for the average product lifetime of 17 years, also for non-authorised repairers as long as they have the necessary authorisation to work with gas, electricity and heating equipment
- we support removing the distinction between professional repairers and end-users in terms of access to spare parts and repair information.
- recyclability criteria to ensure recycling of materials, including heating technologies from 48 months after entry into force that contain copper, aluminium, lead, and steel will have to contain a share of at least 50% recycled content from manufacturing waste or post-consumer waste.
- For the maximum delivery time of spare parts, 15 working days to deliver spare parts is too long for heating appliances as consumers should not have to live without heating for over 3 weeks, especially during the coldest season, and should be significantly shortened.