EU Clean Industrial Deal
The European Underfloor Heating Alliance (EUHA) represents a sector committed to providing sustainable, energy-efficient heating solutions that support Europe’s energy transition. As discussions continue on the EU Clean Industrial Deal, it is critical to recognise the unique characteristics of electric underfloor heating systems and their pivotal role in achieving Europe’s climate and energy goals. Electric underfloor heating offers precise, efficient, and sustainable heating while seamlessly integrating with renewable energy sources. They also represent a an important European industry that provides affordable and renewable energy choices to consumers at a time of ongoing challenges of security and energy affordability. The current EU Clean Industrial Deal currently risks unfairly penalising this technology, undermining its market viability and its contribution to Europe’s green transition. It also risks European competitiveness and the affordability of heating.
Electric underfloor heating is uniquely positioned to address Europe’s energy challenges, offering benefits that align with modern building standards and sustainability objectives
Adaptability for modern homes
Electric underfloor heating excels in nearly zero-energy buildings, providing efficient and precise heat delivery. It is particularly suited for low-energy buildings with minimal heat loss.
Energy efficiency
Electric underfloor heating systems convert 100% of electricity into heat, ensuring no waste. This precision minimises energy use while maintaining comfort.
Renewable integration
These systems integrate seamlessly with renewable energy sources, such as photovoltaic panels and battery storage, supporting energy self-sufficiency and a sustainable future.
Alignment with decarbonisation goals
As Europe transitions to greener energy, the sustainability of electric underfloor heating systems will continue to improve, making them a reliable, future-proof choice.
Our concerns
- Distortion of the internal market Heat pumps over their lifetime contribute more carbon, need replaced frequently and are financially not viable for many. Subsidies aimed at promoting heat pump adoption can inadvertently distort the heating technology market, potentially leading consumers to favour heat pumps over more suitable or cost-effective alternatives, such as underfloor heating thereby impacting the diversity and competitiveness of the market. Direct electrical heating solutions should be seen as complimentary.
- SME/Overall competitiveness The European Commission’s Competitiveness Compass emphasizes the importance of supporting small and medium-sized enterprises (SMEs) to enhance the EU’s economic growth and innovation. We worry that many small European businesses will be negatively impacted by the current presentation and subsidy preference of heat pumps, without the inclusion of other heating solutions.
- Energy Label places us lower when we are 100% efficient The proposed energy label for electric local space heaters focuses has a very narrow interpretation of efficiency and does not factor in lifetime costs, carbon used during the production of the heater or situational use of products. It does not take into account how end users use heating products where some may be situationally cheaper than others.
- Energy poverty Underfloor heating is a cost effective, futureproof technology with low lifetime costs. When comparing underfloor heating with heat pump water heater for domestic water with air source heat pumps, the total cost of ownership of electric underfloor heating is lower than the alternatives, benefitting European citizens suffering from energy poverty.
- Lack of democracy in the policy-making process The introduction of measures with significant implications being brought in through comitology with the Commission acting without the involvement of the Member States or the Members of the European Parliament is unhelpful to ensuring democratic scrutiny and accountability. The industry is concerned that measures with such serious implications for European industry and the ability of citizens to heat their homes are being brought in with the Commission acting alone.
Our policy asks
EUHA proposes the following steps to ensure fair treatment of electric underfloor heating systems
- That the Clean Industrial Deal supports SMEs that may be negatively affected by the Energy Label
The Clean Industrial Deal aims to support businesses in the green transition, but non heat pump SMEs will struggle with a lower rank on the energy label. While the initiative acknowledges industrial transformation, it lacks a strong focus on these SMEs, which often face greater financial and administrative challenges.
- That the Commission addresses the imbalances within the proposed Energy Label
The Draghi report and the Competitiveness Compass, both highlighting how EU policies tend to favour larger firms while SMEs face disproportionate barriers and are unable to use scale to overcome costs. A more SME-focused approach alongside other heating technologies is needed to maintain competitiveness and prevent smaller businesses from being unfairly disadvantaged.
Conclusion
EUHA agrees with the direction of the Clean Industrial Deal (CID), decarbonising and promoting a greener EU. However, it is critical to recognise the unique characteristics of electric underfloor heating systems in the CID and their pivotal role in achieving Europe’s climate and energy goals. Currently it favours heat pumps while other heating solutions, such as electric underfloor heating offers precise, efficient, and sustainable heating while seamlessly integrating with renewable energy sources.