The European Commission is currently preparing the legal framework that will govern energy efficiency policy beyond 2030, with a Call for Evidence open between 19 March and 16 April 2026 and a public consultation running until 12 June 2026. The legislative proposal is expected in the fourth quarter of 2026. REHVA has submitted formal comments to this Call for Evidence, setting out the HVAC sector's technical perspective on the key design choices that will shape the future framework.
The initiative is closely aligned with the EU's binding target to reduce greenhouse gas emissions by 90% by 2040 and the overarching objective of climate neutrality by 2050. It builds on existing EU legislation, including the Energy Efficiency Directive, the Energy Performance of Buildings Directive, the Emissions Trading System, and the Renewable Energy Directive, aiming to create a more streamlined and investment-friendly framework across all sectors.
Energy efficiency as a principle, not a requirement
REHVA's submission makes a fundamental conceptual point for the architecture of the future framework. Under Article 3 of Directive (EU) 2023/1791 (the recast Energy Efficiency Directive), the "energy efficiency first" principle obliges Member States to consider energy efficiency solutions in planning, policy, and investment decisions across all sectors. As Article 2, point (18) of Regulation (EU) 2018/1999 makes clear, the underlying objective is the delivery of cost-effective end-use energy savings and more efficient conversion, transmission, distribution, and use of energy. Energy efficiency is a means to that end, not a target in itself.
REHVA therefore recommends that the future framework treat energy efficiency as an indicator or guiding principle, rather than a hard regulatory requirement capable of withdrawing products from the market.
The critical importance of assessment boundaries
A recurring weakness in current EU energy regulation is the failure to define assessment boundaries when measuring or comparing efficiency. Under the EED, energy efficiency is defined as the ratio of useful output to energy input — but which inputs and outputs count, and at what system boundary, is left open. This creates serious distortions.
REHVA illustrates this with a concrete example. A heat pump, measured on electricity input versus heat output, may achieve a coefficient of performance of 3, yielding an apparent efficiency of 300%. A thermal solar panel, by contrast, must account for solar radiation as an energy input, and registers an efficiency of around 80%. Yet when assessed across the full energy chain, including upstream electricity generation, the picture changes: a heat pump operating on German grid electricity produces around 100 gCO₂/kWh of useful energy, while the solar panel produces zero during operation. Neither figure is wrong — what differs is the boundary.
REHVA does not question the value of heat pumps: they are an excellent technology central to the electrification of heat. The point is that meaningful comparison requires consistent boundary conditions. The future framework must specify assessment boundaries, inputs, and outputs whenever efficiency figures are used to set requirements or inform policy decisions.
System integration and holistic performance
HVAC products are not off-the-shelf commodities: their real-world efficiency depends on running conditions, system integration, control strategies, and interaction with other components. An efficient and affordable system is not simply the sum of the highest-rated individual products — it is the outcome of building-level optimisation.
The case of the electric boiler illustrates this. Under current Ecodesign rules it carries a low standalone efficiency rating of approximately 43%, yet in a system context — particularly for thermal storage of renewable electricity from photovoltaics — it can contribute to grid flexibility, avoid peak loads in electricity distribution, and exploit periods of low or negative electricity prices. Restricting such products on the basis of standalone efficiency metrics risks undermining the broader system benefits they can deliver.
REHVA's position is clear: for the HVAC sector, only a holistic approach encompassing the whole energy chain is technically meaningful. Product-level efficiency requirements that ignore system integration are not a reliable path to meeting climate targets.
Choosing the right targets: primary energy and CO₂ emissions
The choice of indicator for energy targets matters enormously. Article 4 of Directive (EU) 2023/1791 establishes a binding final energy consumption target and an indicative primary energy consumption target, without specifying whether the latter is expressed in total or non-renewable terms. This ambiguity has real consequences.
Final energy accounts for losses within the building but not upstream. Switching from a gas boiler to a heat pump improves the final energy figure substantially — not necessarily because less primary energy is consumed, but because transformation losses are shifted outside the building boundary. Where electricity is generated by a low-efficiency coal plant, primary energy consumption may actually be higher despite the apparent final energy improvement.
REHVA recommends that post-2030 targets be anchored in primary energy (both total and non-renewable) and CO₂ emissions — the indicators that reflect actual climate and energy security impact regardless of where losses occur in the chain.
Real performance, commissioning, and skills
REHVA's submission also stresses the persistent gap between calculated and real energy performance of building systems, arising from differences between standardised user patterns and actual occupant behaviour, as well as suboptimal system integration, control strategies, and operation. Policies must actively promote measurement and verification of in-operation energy performance, supported by continuous monitoring, data-driven optimisation, and building automation and control systems.
Proper commissioning, regular re-commissioning, and lifecycle optimisation are essential to achieving and maintaining expected performance. These demands are not only regulatory in nature — they require sustained professional training and skills development across the value chain, an area that sits squarely within REHVA's broader work on the skills gap in the building and HVAC sector.
Local heating and cooling plans: widening the scope
REHVA's comments also address Article 26 of Directive (EU) 2023/1791, which requires local authorities in municipalities above 45,000 inhabitants to prepare local heating and cooling plans. These plans have real potential to drive the energy transition, but as currently framed they focus exclusively on heat and cooling demand without considering how the increased electricity demand arising from electrification will be supplied and managed.
Matching electrification of heat demand with renewable electricity production, storage, and distribution must be integral to these plans. The current annual assessment timestep is also insufficient for addressing the intermittency of wind and photovoltaic production; dynamic modelling with shorter timesteps is necessary to properly manage flexibility and demand.
REHVA further flags the risk of fragmentation in the national calculation methodologies being developed to implement these plans. Experience under the EPBD has shown that nationally developed methods vary widely in quality and create barriers for professionals and industry operating across borders. REHVA recommends that guidance documents and related databases be developed and standardised at European level by the Commission, drawing on the expertise of European professionals.
Next steps
REHVA will continue to engage actively throughout the consultation process leading to the Commission's legislative proposal. The public consultation remains open until 12 June 2026, and REHVA encourages its members and supporters to contribute directly. For further information on REHVA's position, the full comments submitted to the Call for Evidence are available on the REHVA website.