REHVA’s coordinated contribution lays the foundations for the future of European heating
A coordinated contribution by REHVA (Federation of European Heating, Ventilation and Air Conditioning Associations) to the European Commission’s public consultation represents a highly significant step for the future of heating technologies across Europe.
At a time when building decarbonisation is central to the EU’s climate policy, the review of ecodesign requirements and energy labelling rules for heating equipment and combined generators (for the heating of buildings and hot water provision) takes on strategic value.
This initiative is part of a wider spectrum of European energy efficiency policies, in line with climate targets set for 2030 and 2050. In this context, REHVA’s contribution is not merely to provide technical observations, but also to propose a systemic overview which reflects the practical experience of designers, HVAC engineers, manufacturers and energy consultants operating throughout Europe.
The role of REHVA in the European context
The federation represents one of the leading organisations in the HVAC sector at continental level. It brings together national associations of engineers and plant technicians and plays a key role in supporting the various EU institutions by providing technical expertise.
The report presented to the Commission was drafted by the REHVA EU Policy Advisory Group (EU PAG). This working group integrates multidisciplinary skills and uses direct experience in the field to formulate recommendations for regulatory development. This coordinated approach means that the report is firmly rooted in design practices and goes well beyond a theoretical or laboratory-based vision.
The coordinated contribution therefore carries out a dual function: firstly, it ensures that the voices of professionals from the sector are heard and secondly, it promotes the development of genuinely workable, coherent regulations that favour technologically innovative solutions without causing market distortion.
The two initiatives forming the subject of the consultation (the revision of ecocompatible design requirements or ecodesign) and the updating of energy labelling for heating equipment), will have a direct impact on products’ access to the market, as well as on consumer perceptions.
Ecodesign regulations define the minimum performance that a product must guarantee before it can be released onto the European market. Energy labelling meanwhile, provides an informative tool, guiding purchasing choices via an efficiency classification system.
In the current energy transition scenario, these tools are not mere beaurocratic measures, but rather key levers for steering investment towards low emission technologies. It is precisely for this reason that REHVA’s coordinated contribution emphasises the need for a balance between environmental targets, technological neutrality and technical workability.
A systemic perspective: beyond the ‘stand alone’ product
One of the key points in the report is its implicit criticism of an approach which views a generator as a ‘stand alone’ product. According to the organisation, heating equipment can no longer be regarded as an isolated element, it should be considered an integral part of a complex plant system.
Energy performance depends on many factors: correct design, adequate sizing and installation quality, as well as integration with renewable sources, regulation and actual operating conditions. Standardised tests (necessary to ensure comparability), are based on pre-determined conditions which rarely coincide with those present during actual operation.
REHVA’s coordinated contribution therefore highlights the need to maintain coherence between product trialling methods and system level calculation standards used in building regulations. Only in this way is it possible to avoid divergences between declared performance and actual operational results.
This aspect is particularly relevant in energy requalification procedures, when integration between pre-existing systems and new technologies requires flexible, adaptable solutions. Excessively rigid minimum requirements could limit opportunities for hybrid configurations or integration with renewable energy sources.
Ecodesign: technological neutrality and design flexibility
Regarding ecodesign requirements, the Federation recognises their value as a tool for defining minimum performance thresholds. Nevertheless, the report suggests avoiding an approach that may indirectly penalise certain technologies which, if appropriately integrated into a system, can contribute to creating efficient, sustainable solutions.
Technological neutrality is indicated as a key principle. This means that regulations should set performance goals, but leave the market and sector professionals the freedom to choose the most suitable solutions on a case by case basis. Especially in hybrid configurations, such as the combination of heat pumps and high efficiency boilers, overall performance depends on the interaction between components rather than on the specific generator itself.
Another key element regards methodological coherence. There must be communication between the testing criteria and the methods used to calculate building energy efficiency set out in European regulations, including the Energy Performance of Buildings Directive (EPBD). A disconnection between product level and system level risks causing regulatory inconsistencies and practical issues.
Energy labelling: clarity and differentiation capacity
As far as energy labelling is concerned, REHVA’s coordinated contribution welcomes the Commission’s intention to recalibrate the energy efficiency classes. Over time, technological advances have led to many products being grouped in the higher classes, reducing the labelling system’s ability to differentiate between them.
The Federation of European Heating, Ventilation and Air Conditioning Associations has however highlighted some issues with the proposed thresholds. The risk is that technologies which vary considerably in terms of functioning, emission levels and seasonal behaviour will be collocated in the same energy class. This compression of information could limit the label’s ability to guide purchasers towards well-informed choices.
Another focus point regards the possible introduction of an ‘empty’ class A, which would not contain any products currently available on the market. This choice could cause confusion among consumers and have a negative impact on public incentivisation schemes which often involve products in the highest energy classes.
The report therefore proposes that the classification thresholds are redefined to more closely reflect the actual performance ranges of products which are currently available, while continuing to act as a stimulus for innovation.
The public consultation ended on 23rd January 2026 and the delegated and implementing acts are expected to be introduced in the coming months. The organisation will continue to monitor the process and to communicate with European institutions to ensure that the final regulatory framework is balanced and results-focused.
