ENER Lot 1 – E nergy label requirements for space heaters and c o m b i - h e a t e r s

16 J u l y 2 0 1 2

TO: Mr. José Manuel Barroso, President of the

CC: Mr. , Vice-president and Commissioner for Industry and Entrepreneurship, Mr. Günther Oettinger, Commissioner for Energy, Ms. Connie Hedegaard, Commissioner for Climate Action, Mr. Janez Potocnik, Commissioner for Environment, , Commissioner for Internal Market

Dear President Barroso, Dear Commissioners,

The European Partnership for Energy and the Environment (EPEE) and the European Heat Pump Association (EHPA) welcome the efforts the European Commission is putting into the finalisation of requirements for an energy label for heaters.

Consumers have one house to heat and need to have one label to assess how to do this in the most efficient way, irrespective of the technologies actually used. What they do not need, is separate labels designed for separate yet functionally equivalent technologies. Such an approach would not cater to consumer needs, but instead confuse them by adding more complexity. It would put at risk the impact of a label as an important regulatory tool persuading consumers to choose and invest in more efficient ways to heat their homes.

We fear that as we near the end of many years of debate and discussion that a strong single, technologically-neutral label for consumers could be discarded in favour of separate labels that put technological interests over that of the consumer. We believe such a decision would manifest fossil fuel based heating systems for the foreseeable future, a move that is not in line with the energy and climate targets of the and a move that will actually jeopardize achieving the 2020 targets on renewable energy use and efficiency.

Introducing separate labels means giving up comparability. This is bad for consumers; bad for the environment and bad for Europe. It is detrimental to technical innovation as it limits competition between heating technologies and it negatively impacts the idea of a single market. Lastly, such a decision at this point in time is bad for “better regulation”.

However the opposite is possible. The swift adoption of the documents resulting from inter- service consultation, integrating the Member States’ comments would result in one label layout for all types of heaters also displaying the primary energy efficiency (eta).

We are writing to you, to urge you to support a strong single label for functionally equivalent heaters.

We remain at your disposal should you have any questions related to our position or our associations, and would of course be more than delighted to meet with you should you wish to.

With kind regards,

Thomas Nowak Andrea Voigt Secretary General EHPA Secretary General EPEE 1/2

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: www.epeeglobal.org

About EHPA: EHPA was established in the year 2000 to promote awareness and proper deployment of heat pump technology in the European market place for residential, commercial and industrial applications. EHPA today has 91 members representing the majority of actors in the European Heat Pump Industry.

The association aims to provide technical and economic input to European, national and local authorities in legislative, regulatory and energy efficiency matters. All activities are aimed at overcoming market barriers and dissemination of information in order to speed up market development of heat pumps for heating, cooling and hot water production. It is the declared aim of the association to make heat pumps a core technology in the development towards a more energy efficient, RES based, sustainable energy system. For more information: www.ehpa.org

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