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
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.
The Electric Underfloor Heating Alliance (EUHA) has closely followed the work of the European Commission in the definition of regulatory possibilities which are to develop Ecodesign Lot 20.
The Members of the Alliance welcome the idea of maintaining the exclusion of electric room heaters from the labelling scheme and the adoption of minimum efficiency standards as a feasible and appropriate alternative to a multi-fuel energy label. This new approach, widely supported during the Lot 15&20 Consultation Forum of 20 September, offers the most cost effective way to drive the industry towards higher efficiency standards and energy savings.
The Alliance is committed to continue working closely with the European Commission in the definition and deployment of this proposal for energy reduction in heating products.
EUHA Position Paper on Exclusion of Labeling