The undersigned associations welcome the 16 June 2021 publication of the European Commission’s report of the study on consumer understanding of the energy label for space heaters and air conditioners. The report provides further clarity on consumer interpretation of energy labelling classes without further context.
However, based on this report, the Commission is evaluating the possibility of merging the energy labels for ≤ 50 kW local space heaters (ENER Lot 20) and ≤ 12 kW air-to-air heat pumps (ENER Lot 10), as it could remove consumer confusion about which product type is more energy consuming on the basis of the energy labelling classes alone: merging the energy labels has, according to supporters of the merger, the potential of directly influencing end-user choices towards more energy efficient heating technologies.
The undersigned associations strongly disagree with the introduction of an integrated energy label for heating technologies, as a merger of the energy labelling classes for both product categories will not help meet the energy labelling’s objectives. This paper explains that 1) local space heaters and air-to-air heat pumps are not comparable, 2) merging different energy labels will not help improving the effectiveness of the energy label, and that 3) the consumer study itself does not univocally support the merger of the energy labelling scales.