Background

The EU legislation on Ecodesign and Energy Labelling aims at improving environmental performance and setting minimum mandatory requirements for the energy efficiency of products. It helps eliminate the least performing products on the market and it contributes to the EU’s 2020 energy efficiency objective. 

Bioenergy installations

When it comes to biomass installations, two groups of products are subject to eco-design requirements: 

• Solid fuel boilers with a rated heat output of 500 kW or lower (Eco-design Directive Lot 15) 

• Local space heaters with a nominal heat output of 50 kW or lower (Eco-design Directive Lot 20) 

The directives impose energy efficiency requirements, as well as emission limits for OGC, CO, NOx and PM. 

The same groups of biomass products are subject to eco-labelling requirements: 

• Solid fuel boilers with a rated heat output of 70 kW or lower (EL Regulation Lot 15) 
• Local space heaters with a nominal heat output of 50 kW or lower (EL Regulation Lot 20) 

Our position

In order to ensure a decarbonised heating and cooling sector, and reduce the level of emissions from the residential sector as soon as possible, it is crucial to foster the replacement of old and inefficient heating installations with highly efficient biomass stoves and boilers. 

On top of this, Lot10 (air to air heat pumps) and Lot20 (local space heaters) of the Energy Labelling Regulation should not be merged, as this would provide misleading information to consumers. Considering that heat pumps and LSH are totally different products, a comparison based only on electrical efficiency would convey the wrong message.