One of the key tasks of Eurovent is to represent its industry vis-à-vis public decision-makers at a national (through its member associations), European, and international level. In the following, we elaborate on some key policy areas that we are regularly dealing with.

Ecodesign

Ecodesign is a forward-thinking concept whose regulations require our members to decrease the energy consumption of their products by establishing minimum energy efficiency requirements. By setting these requirements at European level, manufacturers do not have to navigate through multiple national regulations when placing their products on the market. Customers are provided with an effective tool to choose the right product in a comparative manner.

While Eurovent is strong supporter of the Ecodesign framework and regards it as a driver for innovation and environmental responsibility, it also acknowledges various challenges.

It is getting complex

Europe’s manufacturers of Indoor Climate (HVAC), Process Cooling, and Food Cold Chain Technologies see themselves confronted with an increasing amount of Ecodesign measures with which they have to comply.

This includes, for instance:

  • Ecodesign Regulation 327/2011: ‘Ventilation fans’
  • Ecodesign Regulation 206/2012: ‘Room air conditioning appliances, local air coolers and comfort fans’
  • Ecodesign Regulation 813/2013: ‘Space and combination heaters’
  • Ecodesign Regulation 1253/2014: ‘Residential and Non-Residential Ventilation Units’
  • Ecodesign Regulation 2015/1095: ‘Refrigerating and freezing equipment’
  • In development: ‘Air heating products, cooling products, high temperature process chillers and fan coil units’
  • In development: ‘Commercial refrigerators and freezers’
  • In development: ‘Central heating products using hot air to distribute heat’
  • In development: ‘Smart Appliances’

What frequently comes along with Ecodesign measures are Energy Labelling Regulations as well as horizontal legislative requirements such as EPBD (Energy Performance of Buildings Directive), F-Gas Regulation, Low Voltage Directive, Machinery Directive, Pressure Equipment Directive, RoHS (Restriction of Hazardous Sub- stances), WEEE (Waste of Electric and Electronic Equipment), or REACH.

In addition, many Ecodesign Regulations do not just apply to one product only, but often two (energy-related products integrated into other energy-related products), or sometimes even more. These Regulations again are not always coherent. The entering into force of minimum energy efficiency requirements (‘Tiers’) of different energy-related products is not consistently coordinated either.

All of this leads to a growing complexity. Following up with all legislative development marks a major challenge for our industry, and especially SMEs.

Accordingly, Eurovent and its members strongly recommend EU decision-makers to

  • Maintain the equipment-focus of Ecodesign
  • Align the dates for the coming into force of the requirements within different regulations
  • Avoid overlapping or conflicting legislative requirements for the same products
  • More strongly harmonise national and European legislation

Good things take time

Our association also asks to recon- sider the pace and timing with which Ecodesign measures are being tackled by EU regulators. Often, these are not in line with industrial realities. While our industry is ready to innovate, it has product and innovation cycles to follow that should be respected.

That said, for example, a product is commonly being developed to be sellable for a longer period of time, and the time for it to be market-ready tends to be around three years. The short cycle in which minimum energy efficiency requirements enter into force, and the non-alignment of different implementing measures create challenges for product developers.

Consequently, we see a necessity to

  • Increase the length of legislative development cycles to align it with industrial realities
  • Allow for a reasonable amount of time between each minimum energy efficiency requirement (‘Tiers’) enters into force
  • Align the dates for the coming into force of the requirements within different regulations
  • Always develop an impact assessment with each regulatory revision
  • Make all impact assessments publically accessible to increase the overall transparency

Efficiency is not an all-purpose answer

The overall approach of Ecodesign to decrease the energy consumption by establishing minimum energy efficiency standards is being very much appreciated by Eurovent. However, we also realise that there are certain limitations attached to this approach.

In general, energy efficiency also has physical limits based on thermodynamic laws. It deserves to be assessed until which stage it makes economic and ecologic sense to further improve product efficiencies.

An increase in energy efficiency should consider industrial realities, consumer demands, and other important requirements. Ecodesign deserves to be developed further – beyond a sole energy efficiency focus, considering requirements such as IAQ, size, health, noise, or food safety.

Products integrated into products

Several Regulations adopted under the ‘EU Ecodesign Directive’ apply to pro- ducts integrated into other products (e.g. fans and motors). These products may also be sold as ‘stand-alone’ products.

Eurovent and its national member associations represent manufacturers of components, of products incorporating these components, and manufacturers offering solutions for entire system. The opinions of members differ on whether energy-related products integrated into other energy-related products should be regulated, with each side bringing up its specific arguments.

Aside from this, Eurovent and its members share the following view:

  • The technical neutrality and the equipment-focus of Ecodesign should be maintained, not diluting it with system measures
  • Any additional Ecodesign measure on components should be carefully evaluated to avoid adding additional complexity to an already complex framework. Decision-makers should act cautiously when adding any additional layer of legislation (e.g. on systems) that might increase complexities even further
  • An alignment of all related Ecodesign implementing measures is necessary and overdue in terms of, for example, ‘Tiers’ and content

Energy Labelling

A key policy area closely related with Ecodesign is Energy Labelling. While minimum energy efficiency standards aim to ensure the compliance of products with Ecodesign requirements, Energy Labelling visibly promotes a product’s energy efficiency. It can thus constitute a powerful tool to ensure a level-playing field.

For products that fall under an Ecodesign measure, it is possible to calculate their energy consumption based on harmonised EN standards that provide for the necessary calculation methods. Eurovent and its members hold that, where appropriate, Energy Labelling requirements should be issued together with Ecodesign measures for these kinds of products.

As for energy-related products integrated into other energy-related products, we believe only the final product should be covered by Energy Labelling. This is because the final energy consumption, from the end-user point of view, is the one related to the final product.

Energy Performance of Buildings

The Energy Performance of Buildings Directive (EPBD) is changing the way in which Europe looks at new buildings and renovations. It marks a key policy area of high relevance to our industry.

Eurovent and its members share the ambitious goals to improve energy efficiency in the building sector, which accounts for 40 per cent of the total energy consumption in the European Union.

Background

The first EPBD from 2002 required Member States to define a framework for a methodology of calculation of energy performance of buildings (EPB). It introduced minimum requirements on EPB of new buildings and major renovations by 2006. This was coupled with an Energy Performance Certificate that is mandatory when

a building is constructed sold or let. A regular inspection of heating and air-conditioning systems was introduced. To fit within the context of the ambitious climate and energy package by 2020, the EPBD was revised. The second EPBD of 2010 introduced the calculation of cost-optimal levels of minimum energy performance requirements, and requirements to document the feasibility of using energy from renewable sources mandatory. The major ambitious novelty is that all new buildings should be ‘Nearly Zero Energy Buildings’ (NZEB) by 2021.

Call for harmonised calculation models

To achieve the EPBD’s goals, we believe that the use of harmonised EPB calculation models across Europe, rather than national and regional models, would more effectively contribute to energy-saving and emission reductions. This has multiple reasons, including:

  • The laws of physics are the same across Europe
  • Objective parameters that account for the local particularities exist
  • An integration into European harmonised calculation standards will stimulate a Single Market that can benefit of the effects of scale while realising energy efficiency and a move towards renewable energies at lower costs

The national and regional transpositions of the EPBD by Member States not only represent significant administrative burdens, but also technical ones as European product legislation, in particular Ecodesign requirements, are insufficiently taken into account. It ultimately contradicts the idea of a single European market and level-playing field.

Alignment with Ecodesign reqirements

The efforts by the European Commission to integrate EPBD with Ecodesign requirements in harmonised European standards are fully supported by Eurovent and its members. This issue should be tackled as soon as possible.

We suggest that the EPBD considers the buildings’ benefit and energy saving related to the use of products that are still not covered by any Ecodesign measure. In many areas, sufficient standards or codes of good practice exist that can be made use of. By all means, it should be avoided to add additional national requirements that go beyond the ones set within Ecodesign Regulations.

The move towards NZEB provides challenges for product design and development. Our industry is responding with new products. These need to find their way into the calculation methods in a quick manner within Member States as long as no European approach is available.

Technological neutrality needs to be ensured

The means applied to reach the tar- gets of the EPBD should be chosen by the customer. We regard it as essential in this respect that the Directive maintains a technological and energy neutrality. Certain technologies should not be given advantages over others as this goes counter a level-playing field, distorts the market, and can hinder new innovations.

The importance of providing a healthy indoor air

Eurovent strongly believes that energy efficiency and the use of renewables, even where quantitative targets are put forward, should not go at the expense of providing a safe and healthy environment for buildings’ citizens.

Ensuring a good Indoor Air Quality (IAQ) goes beyond the individual insulation, heating, cooling and ventilation requirements. It is the main motive why Eurovent and its members advocate that IAQ should be given a key priority when moving towards NZEB and the third revision of the EPBD. It should also be an integral part of the EU strategy for Heating and Cooling.

F-Gases

The reduction of emissions from fluorinated greenhouse gases (F-Gases) constitutes another major and widely debated policy area affecting our industry.

At Eurovent, we see ourselves as a representative of refrigerant users. We prepare our members for upcoming realities related to the phase-down of refrigerants with a high global warming potential.

Background

The low-carbon roadmap developed by the European Commission sets out the strong ambition to cut greenhouse gas emissions by 2050 by 80-95% compared with the levels from 1990. The aim of the ‘EU F-Gas Regulation’ is to achieve the objectives by cutting the EU’s F-Gases emissions to one-fifth of 2014 sales levels by 2030. This will be the main driver of the move towards more climate-friendly technologies.

Alternatives are already in place

Eurovent and its members fully sup- port the F-Gas phase-down initiated by the European Union. We hold that the responsible freedom of choice of refrigerants can contribute to innovation and sustainable growth over time. Already today, Indoor Climate (HVAC), Process Cooling, and Food Cold Chain Technologies can make use of a wide range of available refrigerant solutions that fulfil the 2030 requirements.

Challenges

Eurovent holds that training and certification of persons working with refrigerants is an essential part for safe and responsible handling of refrigerants both in production plants and on-site.

Energy-related products covered by Ecodesign and Energy Labelling are subject to market surveillance, which marks another key policy area.

Market Surveillance

Market Surveillance is necessary

To Eurovent and its members, market surveillance constitutes a key tool to verify the coherence from what is declared by manufacturers and what is sold. Market surveillance is necessary to guarantee a level-playing field and we generally support a stronger and more visible market surveillance and inspection.

Conformity assessment is within the responsibility of the National Market Surveillance Authorities. Limited financial resources of the Member States and the limited availability of accredited laboratories represent challenges that should be tackled.

If this is not the case and unless other methods of conformity assessment are being found, it will make little sense to revise and further tighten Ecodesign requirements.

Accredited third party certification and verification

Voluntary and mandatory third-party certification and verification does not replace market surveillance. However, Eurovent and its members hold that proven certified and verified product information can provide a support

to market surveillance activities – in particular where this information can be publicly accessed and results from accredited testing processes.