The Commission is in the process of updating some of the content on this website in light of the withdrawal of the United Kingdom from the European Union. If the site contains content that does not yet reflect the withdrawal of the United Kingdom, it is unintentional and will be addressed.

OVERVIEW | Impact of the Ecodesign and Energy Labelling Directives on HVAC products

Share this Post:

Two European directives, the Ecodesign Directive and the Energy Labelling Directive, together with their accompanying regulations, are being implemented and will extensively modify the regulatory landscape for heating, ventilation and air conditioning (HVAC) products in the European market. This article presents the changes these directives imply with respect to HVAC product performances, and explains how to publish these performances.


The Ecodesign Directive


European Directive 2009/125/EC (sometimes called the ErP Directive or Ecodesign Directive) requires that energy-related products fulfil ecodesign requirements as defined in specific implementing measures, usually Commission Regulations, for the different products.


Such ‘ErP regulations’ exist for the following HVAC appliances: 

  • space heaters up to 400 kW {gas and oil boilers, electric boilers, heat pumps (electrical and gas), cogeneration of heat and power appliances, integrated packages (space heater + supplementary space heater + solar thermal device + temperature control)}; 
  • water heaters and hot water storage tanks up to 400 kW {gas or oil water heaters, electric water heaters, heat pump water heaters, solar thermal water heaters, storage tanks up to 2,000 litres, integrated packages (water heaters + solar thermal device)};
  • air conditioners and air-to-air heat pumps up to 12 kW; 
  • ventilation units {either residential (<1,000 m3/h) or non-residential (>250 m3/h)};

and some of their components:

The requirements of some of these regulations are already in force (e.g. for air conditioners since January 2013), while others will enter into force very soon (e.g., in September 2015 for space heaters and water heaters, and in January 2016 for ventilation units).


Other regulations are under preparation by the European Commission (e.g. for large capacity heat pumps and air conditioners, chillers, fan coil units, condensing units, solid fuel boilers, local room heating products, etc.).


Such regulations include requirements for:

  • energy performance levels (energy efficiency, stand-by losses, heat losses);
  • sound power levels;
  • nitrogen oxide emissions for combustion appliances (boilers, water heaters, cogeneration systems, gas or oil heat pumps);
  • some specific aspects of product design (for example mandatory multi-speed drive or variable speed drive for ventilation units).

Often, the regulations establish requirements with thresholds that become stricter over time, in order to phase the least efficient products out of the market.


The regulations also list which information data must be published in the products' technical documentation.


In addition, the regulations define the way to assess energy efficiency. For example, the metrics considered are seasonal efficiency for air conditioners and space heaters, daily efficiency for water heaters, and specific energy consumption (per year and per square metre of building floor area) for residential ventilation units.


The Ecodesign Directive requires the manufacturer to keep and make available a ‘Conformité Européenne’ (EC) declaration of conformity and to affix the CE marking. The implementing regulations define the rules for the conformity assessment, usually a choice by the manufacturer between internal design control or management system (as described in annexes to that Directive), with an exception for gas and oil boilers up to 400 kW, for which energy efficiency has to rely on an EC type-examination by a third party (notified body), as stated in Directive 92/42/EEC. These regulations also describe the verification procedure for market surveillance by Member States.


The Ecodesign Directive and its implementing regulations have thus deeply modified the regulatory landscape for HVAC products in the European market, by defining new methods for the assessment of the conventional performance of products. Therefore harmonised European standards need to be developed as regulations are being defined and published. These standards will define how to measure and test the relevant parameters for the performance assessment.


Frequently Asked Questions on the ErP Directive and its implementing regulations have been published by the European Commission.


The Energy Labelling Directive


The European Directive 2010/30/EC (also called the Energy Labelling Directive) relates to the indication of the consumption of energy and other resources by energy-related products through labelling and information to end-users.


Commission Delegated Regulations supplementing Directive 2010/30/EC have already been published for household air conditioners (in force), space heaters and water heaters (with a deadline for entry into force of labelling in September 2015) and residential ventilation units (with a deadline for entry into force of labelling in January 2016). They define the energy efficiency classes, the contents of the label and the product information to be made available to consumers.


These regulations may have a more limited scope than the ErP regulations as far as the capacity of the product is concerned (e.g. space heaters labelled up to 70 kW, or ventilation units labelled only if for residential use). However, some energy-related products may have ErP requirements but no energy labelling.


The label includes information such as:

  • for space heaters: energy efficiency class for space heating and if applicable for water heating, rated heat output for the three reference climates and sound power level;
  • for water heaters: energy efficiency class, annual energy consumption and sound power level;
  • for hot water storage tanks: energy efficiency class, heat losses and volume;
  • for air conditioners: energy efficiency class for cooling and, if applicable for heating, design load, seasonal efficiency (or efficiency), annual (or hourly) energy consumption and sound power level of indoor and/or outdoor units;
  • for residential ventilation units: energy efficiency class, maximum air flow rate and sound power level. 

The Energy Labelling Directive requires that Member States ensure that suppliers produce technical documentation which is sufficient to enable the accuracy of the information contained in the label. The supplementing regulations describe the verification procedures for market surveillance purposes.


In May 2013, the European Commission launched the review process of the Energy Labelling Directive and of certain aspects of the Ecodesign Directive (see also the evaluation report of the revision).


Summary of Impact on the HVAC products


The two Directives have a deep impact on the HVAC appliances concerned:

  • they rely on new methods to assess product energy efficiency; these methods are generally very different from those that are used to assess the performance of HVAC products in the calculation of the energy performance of buildings (national transpositions of the European Energy Performance of Buildings Directive 2010/31/EU);
  • they create a need for a corresponding revision of the European standards;
  • they define requirements that will gradually take less efficient products out of the market; in some cases, certain technologies could cease to exist on the market;
  • they introduce labelling of products providing better information for consumers.