First stakeholder meeting of the review study
03 July 2018
The European Commission is open for modifications of the Ecodesign Regulation, including Ecodesign limits, although the Commission acknowledges that since the Ecodesign Regulation has only been implemented since January 1, 2018, it is not possible to assess the market data before and after its application.
The review study team's suggestions to modify the Regulation include:
- rewording of thermal comfort to avoid loopholes;
- inclusion of slave heaters in scope, or adjust definitions;
- definition of “tower heaters” to clarify the scope;
- for resource efficiency, assess the use of critical raw materials in energy related products + support collection of materials at end of life;
- check compliance of local space heaters due to the different bonuses;
- study third party verification vs. certification;
- assess appropriateness of tolerances;
The review study is to determine whether the introduction of third-party requirements is appropriate. An ongoing study on third party conformity assessment is running in parallel for solid fuel local space heaters (see this link for further information). This was not discussed in detail at the meeting, but it was noted that a cost-benefit analysis should be carried out, particularly for electric heating as there’s not emissions or security risks.
There is an agreement of a lower Primary Energy Factor (PEF) of 2.1 for the Energy Efficiency Directive, but there is no automatic application to Ecodesign Regulations; Viegand Maagøe will assess the impact of a lower PEF and the impact on the Ecodesign Regulation for local space heaters. I asked whether it could be possible to further lower this value, but the Commission clarified that they would like to see a harmonized PEF across different pieces of legislation.
Further information can be found in the meeting report attached below. Minutes of the meeting have been published and are also attached below
. Please send any comments to [email protected].
