Industry association position on PEF revision

Get the Primary Energy Factor (PEF) for electricity right – at 2.0 and with a regular review

In view of the trialogue discussions on the review of the PEF, EUHA co-signed a letter with other industry partners on the importance of getting the Primary Energy Factor (PEF) in the energy efficiency directive right. We advocate for:

  • Deciding on  a PEF of 2.0 for 2020 (when the directive will be implemented nationally), as supported by the Fraunhofer Institutes’s scientific methodology, prepared for the Commission: a higher PEF incentivises electricity savings over direct fossil savings, acting as a barrier for the decarbonisation of the heating sector.
  • Setting a regular review of the PEF in order to reflect changes in the reality of the energy mix: by 2030 the EU RES share in power generation is projected to be at least 49%. The accelerated greening of the electricity mix justifies a frequent review of the value based on the aforementioned methodology.

2018 Industry association position on PEF revision February 2018_FINAL

EUHA – Presentation of the Alliance

The Electric Underfloor Heating Alliance – EUHA – unites manufacturers to promote the interests of the product sector within a new electrified smart grid infrastructure. The group promotes the adoption of higher efficiency electric underfloor heating systems, providing primary but mainly secondary comfort heating in low energy demand buildings.

Decarbonized electricity from renewables in the heating and cooling sector remains one the best options for the European Union to meet the 2050 goals for reduction of carbon emissions.

This document will provide you with a general presentation of EUHA, and presents Electric underfloor heating solutions to European regulations.

  • Smart and efficient buildings in Europe
  • The Future is green and clean
  • Energy efficiency First
  • More than heating, comfort for consumers

Please find the document here.

Joint Position Paper on the Review of the PEF

The signing organizations of this joint statement support the European Commission’s initiative to review the PEF value based on a standardized calculation method.

In this context, we suggest to the Commission to consider the importance of the guiding function of the PEF in decarbonizing the energy system. A lower primary energy factor will accelerate the efficient electrification of the heating and cooling sector and enable a deeper integration of the electricity and heating and cooling markets. While it supports the EU climate and energy targets, it will also:

  • provide a more rapid decarbonisation of the heating & cooling sector and avoid lock-in of fossil fuel investments for decades;
  • facilitate deeper integration of electrical renewables through more flexible heat demand;
  • improve EU security of supply through replacing fossil imports with indigenous renewables;
  • empower consumers, to become active participants in the electricity markets, giving them the ability to reduce or shift electricity loads.

Key considerations to be taken into account by the European Commission:

  1. Review PEF on a regular basis and provide flexibility to Member States.
  2. The PEF revision needs to support the 2050 decarbonization targets set by the
    European Commission and recognize the rapidly increasing share of renewable energy in the power system.
  3. The calculation value of the PEF should include the non-RES primary energy approach.
  4. The current difference between the PEF for fossil fuels of 1.1 and for non-combustible renewables of 1 is inconsistent with the decarbonization strategy.
  5. The PEF revision should focus on consumers as in the Energy Union Strategy.
  6. Rapid revision of PEF values in eco-design and labelling product regulation.

The signing organizations

  • AIE European Association of Electrical Contracting Companies
  • ECI European Copper Institute
  • EHPA European Heat Pump Association
  • EUEW European Union of Electrical Wholesalers
  • EUHA Electric Underfloor Heating Alliance
  • EURELECTRIC Association of the electricity industry in Europe
  • NHO Confederation of Norwegian Enterprise
  • SOLARPOWER Solar Power Europe

To read more about this, click here

EUHA – Review Of The Energy Efficiency Directive (EDD

Letter from stakeholders concerned with PEF review in the EED revision

The EU needs a primary energy factor that supports the objectives of the Energy Union

We are a group of companies and associations that are committed to EUs goal of decarbonising the European energy system, while increasing energy security; and see increased integration between sectors (heating, cooling, transport and electricity) as a cost-efficient tool to achieve this. We are in this context concerned that the European Commission’s (EC) review of the primary energy factor1 (PEF) for electricity constitutes a barrier to these objectives.

To not be a barrier to decarbonisation, the outdated PEF must be updated wherever it is currently used (for example: Ecodesign and Energy labelling legislation use a PEF of 2.5, which reflects the power system of the nineties). In order to reflect the changes in the power mix, the PEF should therefore be reviewed on a regular basis.

To read more about this please click here.

Joint letter to the European Commission Head of DG Energy

AIE – European Association of Electrical Contractors
CECED – European Committee of Domestic Equipment Manufacturers
EUEW – European Union of Electrical Wholesalers
European Copper Institute
EUHA – Electric Underfloor Heating Alliance
EURELECTRIC – Association of the electricity industry in Europe
NHO – Confederation of Norwegian Enterprise


In this letter, the above organisation seek to address challenges regarding the use of a primary energy factor on electricity (PEF) in the context of EU energy and climate policy.


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.


Joint EUHA EURELECTRIC position paper


In the context of the interservice consultation on the draft measures for energy labelling and ecodesign requirements for local space heaters, the Electric Underfloor Heating Alliance would like to reinforce the following points:
• Electric heating is a tried and tested technology that will be increasingly needed in the future and should be supported by decision-makers. No market distorting measures should be taken, especially not if they create costs, complexity and risks to consumers with no environmental benefits.
• The Members of EUHA welcome the maintaining of the exclusion of electric room heaters from the energy labelling scheme and the adoption of minimum efficiency standards as a feasible and appropriate alternative to a multi-fuel energy label.
• The Alliance is committed to continue working closely with the European Commission in the definition and deployment of measures and strongly supports the objective of energy savings.

EUHA reaction to draft proposals interconsultation

Electric underfloor heating industry unites to promote the role of comfort heating as part of Europe’s sustainable energy future

Brussels, 28 February 2013: Comfort appliances such as electric underfloor heating systems have a key role to play in Europe’s sustainable energy future, yet they remain under constant threat of regulators, who believe electricity is only beneficial when used in other sectors such as transport. The Electric Underfloor Heating Alliance (EUHA) was set up to showcase the sustainability of electric comfort heating.

Today the EUHA officially announced its launch with the opening of its website. Jacob Madsen, EUHA chairman and VP of Danfoss said “Europe cannot ignore the role of electricity in the future of energy supply. While other solutions may be challenged by this transition, electric heating, thanks to it characteristics and flexibility, is clearly to remain a great part of the solution to Europe’s energy and environmental challenges.”

Electric underfloor heating systems are used across Europe to render high levels of heating and comfort. While typically used in small areas such as bathrooms and kitchens, they are also often used to provide central heating in many parts of the EU.
Those appliances offer a perfect fit for the switch towards renewables and the further expansion of green electricity. Moreover, they offer the necessary complementary comfort heating in the low energy building of the future.
EUHA is committed to using its expertise to highlight the role of electric heating in securing a sustainable energy future for Europe. In 2013, EUHA’s priority focus will be on Eco-design Directive, notably LOT 20, on which the European Commission is about to issue its implementing proposal. EUHA has been working with all parties involved in this process and continues to do so to ensure the future rules are effective in terms of market transformation and confer the best practice solutions to the current as well as future challenges.