REHVA has submitted a coordinated contribution to the European Commission’s consultations on the review of ecodesign requirements and energy labelling rules for space heaters and combination heaters (space and domestic hot water). The feedback was prepared by the REHVA EU Policy Advisory Group (EU PAG) and reflects the practical experience of HVAC engineers, designers, technical experts and manufacturers across Europe.
The two initiatives, Energy efficiency labelling requirements for space and combination heaters and Ecodesign requirements for space and combination heaters, will play an important role in shaping the EU framework for heating technologies, market access and consumer information towards 2030 and beyond.
A system-based perspective from HVAC professionals
In its contribution, REHVA underlines that heating appliances are not “out-of-the-box” products, but components of integrated systems whose real energy performance depends heavily on design, sizing, installation and operating conditions.
REHVA stresses that this system dimension must be taken into account even in product-based regulations such as ecodesign and energy labelling, which rely on standardised testing and conventional assumptions. From the perspective of HVAC professionals, product requirements should therefore not unintentionally limit the ability to design efficient, affordable and fit-for-purpose systems on site, particularly in renovation projects, hybrid configurations and renewable-integrated solutions.
Key messages on ecodesign requirements
Regarding the revision of ecodesign rules, REHVA recognises the role of ecodesign in setting minimum performance levels for products placed on the EU market, while cautioning that these minimum requirements primarily determine market access and are based on conventional test conditions. For HVAC systems, real seasonal performance depends strongly on system integration, operating conditions and sizing.
REHVA therefore underlines the importance of maintaining a technology-neutral approach that preserves flexibility for designers and installers and avoids excluding products that can contribute to efficient, affordable and optimised system solutions, including hybrid and renewable-based configurations. In addition, REHVA highlights the need for coherence between product testing methods and system-level calculation standards used in building regulations, to ensure consistency between declared product performance and real-world application.
Improving energy labelling for clearer information
On energy labelling, REHVA welcomes the Commission’s intention to rescale energy-efficiency classes and restore the label’s ability to differentiate between products. However, REHVA notes that the proposed class thresholds risk grouping very different technologies into the same class, reducing the label’s usefulness for end users and professionals.
In particular, REHVA highlights the risk of introducing an empty A class, which may confuse consumers and have unintended consequences for support and subsidy schemes often linked to top energy classes. REHVA therefore proposes alternative class thresholds that better reflect the performance ranges of commercially available heating technologies.
Next steps
The consultation on the draft delegated and implementing acts closed on 23 January 2026. The European Commission is expected to proceed with adoption in the first quarter of 2026.
REHVA will continue to follow the process closely and engage with EU institutions to ensure that the final regulations support high-performance, low-emission heating solutions while remaining workable for HVAC professionals and manufacturers.
The full REHVA contribution, developed by the EU PAG, is available here