In the context of the Commission’s proposals for energy labelling and ecodesign requirements for local space heaters notified to the WTO, the Electric Underfloor Heating Alliance (EUHA) and the Union of the Electricity Industry – EURELECTRIC, would like to emphasise the following points:
- Electric heating is a tried and tested technology that will be increasingly needed in the future and should therefore be supported by decision-makers. No market-distorting measures should be taken since hey risk creating costs, complexity, and risks to consumers with no environmental benefits.
- The draft ecodesign rules set out very demanding minimum efficiency requirements. They will require investments and products change from EUHA members who nonetheless support these measures as they will steer the market towards higher standards.
- EUHA and EURELECTRIC are extremely concerned by the last minute inclusion of product information obligations on electric products. This addition makes no sense from a scientific and logical point of view and is sending incomprehensible and mixed messages to consumers.
- The proposed penalisation of electric space heating equipment runs contrary to the Commission’s energy roadmap 2050 vision of decarbonisation (including heating) through low-carbon electrification. The carbon content of electricity has shrunk and continues to decrease, so that its conversion coefficient is in need of revision.
- Both EUHA and EURELECTRIC strongly support the EU energy efficiency goals and are contributing to their achievement.