Position Papers

One of Eurovent’s key tasks is to accompany the development of legislation and standards on a national, regional, European Union, and international level. As a globally recognised representative of the HVACR industry, Eurovent is a frequently consulted third party by political institutions such as the European Commission and UNEP.

While most of our advocacy takes place via personal meetings with decision makers, we regularly publish Position Papers on issues of importance – either independently or in cooperation with partner associations such as eurammon, EVIA, EPEE, EHPA, or REHVA.

When assessing position papers, are you aware whom you are dealing with?

Eurovent’s structure rests upon democratic decision-making procedures between its members and their representatives. The more than 1.000 organisations within the Eurovent network count on us to represent their needs in a fair and transparent manner. Accordingly, we can answer policy makers’ questions regarding our association representativeness and decisions-making processes as follows:

1. Who receives which number of votes?

At Eurovent, the number of votes is never determined by organisation sizes, country sizes, or membership fee levels. SMEs and large multinationals receive the same number of votes within our technical working groups: 2 votes if belonging to a national Member Association, 1 vote if not. In our General Assembly and Eurovent Commission (‘steering committee’), our national Member Associations receive two votes per country.

2. Who has the final decision-making power?

The Eurovent Commission acts as the association’s ‘steering committee’. It defines the overall association roadmap, makes decisions on horizontal topics, and mediates in case manufacturers cannot agree within technical working groups. The Commission consists of national Member Associations, receiving two votes per country independent from its size or economic weight.

3. How European is the association?

More than 90% of manufacturers within Eurovent manufacture in and come from Europe. They employ around 150.000 people in Europe largely within the secondary sector. Our structure as an umbrella enables us to consolidate manufacturers' positions across the industry, ensuring a broad and credible representation.

4. How representative is the organisation?

Eurovent represents more than 1.000 companies of all sizes spread widely across 20+ European countries, which are treated equally. As each country receives the same number of votes, there is no ‘leading’ country. Our national Member Associations ensure a wide-ranging national outreach also to remote locations.

Eurovent and transparency

You can check on us in the European Union Transparency Register under identification no. 89424237848-89. All Eurovent meeting documents are being made available on request for political decision-makers.

Recently published Position Papers

The following section provides a collection of our recently published Position Papers.

Eurovent publishes feedback on preliminary findings of F-Gas review study

Scenarios modelled by study consultant not considered realistic

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The European Commission and Öko-Recherche recently presented the preliminary findings of the F-Gas review study. The study notably models the degree to which F-Gases could be substituted in RACHP equipment until 2050. Eurovent considers the substitution scenarios unrealistic and has expressed scepticism about the modelling assumptions used by the study consultant.

Healthy buildings must be a top priority in EPBD review

Eurovent petitions the Commission to strengthen IEQ throughout the Directive

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The review of the Energy Performance of Buildings Directive (EPBD) has started. In its submission to the roadmap, Eurovent calls on the European Commission to mainstream indoor environmental quality (IEQ) considerations into the Directive. If this is done well, the EPBD could serve to achieve both healthier and more energy efficient buildings, leveraging the synergies between the two. Read the full Eurovent Position Paper on the review of the EPBD now.

IEQ Gathering Manifesto: Healthy Buildings for All

Putting people’s health and well-being at the centre of the EU built environment

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2020 - IEQ Gathering Manifesto: Healthy Buildings for All

Together with other European industry associations, Eurovent has prepared a joint Manifesto, with the objective to collectively promote healthy buildings with an adequate level of Indoor Environmental Quality (IEQ), and to safeguard the wellbeing of EU citizens. The Manifesto is a result of joint work of the IEQ Gathering that brings together eight European industry associations, representing organisations involved in technical building systems and their maintenance.

COVID-19 industry shutdown must exclude HVACR businesses

Joint Eurovent-REHVA Position Paper

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Eurovent and REHVA call on all relevant authorities in the EU and globally to recognise the manufacturing, distribution, installation, maintenance and repair of HVACR equipment as essential business activities and therefore exempt them from COVID-19 shutdown orders and travel restrictions. HVACR equipment supports critical infrastructure in the healthcare, food cold chain, data centre and building sectors notably. Prolonged shutdown of HVACR manufacturing activities might have severe consequences during and after the COVID-19 pandemic.

COVID-19 industry shutdown must exclude HVACR businesses

Eurovent Middle East, along with the Eurovent Association and other industry organisations warn of severe consequences to critical infrastructure

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2020 - COVID-19 industry shutdowns must exclude HVACR businesses

Dubai, 8 April 2020. Several governments around the world have imposed shutdowns of non-essential businesses as part of the measures to contain the COVID-19 outbreak. In some countries, this includes manufacturers, suppliers and service professionals of HVACR equipment. Eurovent Middle East, along with other international industry organisations have published a Position Paper to warn of severe consequences to critical infrastructure if the supply and servicing of HVACR equipment is halted.

Eurovent develops Position Paper on particulate concentration limits in ventilation systems and indoor air

Association’s position a response to continued lack of meaningful EU regulatory requirements on IAQ after recast EPBD

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The Eurovent Association has developed a plain and concise Position Paper recommending the European Commission to introduce limits on the particulate matter concentration in the supply air of ventilation systems and to develop a comprehensive approach to PM in indoor air itself. The Position Paper reflects the industry’s support for regulatory requirements that level the playing field and foster recognition of the importance of adequate ventilation for the health and well-being of building occupants.

Eurovent publishes preliminary Position Papers concerning revision of EU Ecodesign Regulation on Ventilation Units

Comprehensiveness of association’s documents reflects need to redevelop essential parts of the currently applicable Regulations

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2019 - Eurovent publishes preliminary Position Papers concerning revision of EU Ecodesign Regulation on Ventilation Units

The Eurovent Association’s Product Groups ‘Air Handling Units’ and ‘Residential Air Handling Units’ (covering non-residential and residential ventilation units respectively) have released Position Papers concerning the ongoing review of Commission Regulation (EU) No 1253/2014 (Ecodesign requirements for ventilation units). The papers include clarifications and amendments to the regulatory text, as well as in-depth suggestions for improvement concerning air filters, leakages, humidity recovery, control systems, labelling aspects, and many other issues of high relevance.

Eurovent Position Paper for the European Commission Guideline Document on the European Commission Regulation 2016/2281

An unambiguous interpretation of the requirements set out in the Commission Regulation 2016/2281 is fundamental for ensuring the-level-playing-field

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2017-04 - urovent input for the European Commission Guideline Document on the European Commission Regulation 2016 2281

Eurovent has just published its Position Paper related to the European Commission Guideline Document on the European Commission Regulation 2016/228. Eurovent and its Members hold that the EU Ecodesign regulations and measures are a powerful tool to achieve the European Union energy saving targets and to ensure the level-playing-field. Eurovent does not regard these measures as a burden, but as a motivation to further innovate while contributing to progressive thinking throughout all sectors of our industry.

Eurovent Position on Points system methodology

Eurovent input for the European Commission technical assistance study on ‘points system’ methodology

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Since the advent of the 2012-2014 Ecodesign work plan, the analysis and investigations of complex energy-related products and systems for prospective Ecodesign and Energy Labelling implementing measures have significantly increased. These complex products and systems have degrees of heterogeneity that complicate their assessment against common metrics and measurement methods. The European Commission is working on a technical assistance study aiming to address the complex energy-relataed products within the Ecodesign Framework.

Eurovent comments on the November 2014 CLASP analysis

Eurovent comments on the November 2014 CLASP analysis of specific issues regarding EU policy proposals for DG ENER lot 12 Commercial Refrigeration

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On 27 November 2014, CLASP, the European NGO focusing on the growing energy demand resulting from the use of appliances, lighting and equipment, published an analysis on the possible development of Ecodesign and Energy Labelling requirements for refrigerated commercial display cabinets. In reaction, manufacturers within the Eurovent network published a comment document on 12 December 2015.