Position Papers Archives - European Heat Pump Association

EHPA position on the Energy Product Omnibus

ehpa_editor_daniela — Fri, 13 Mar 2026 05:55:12 +0000

Improving the rules around energy-efficient products like heat pumps is crucial.

EHPA sees the Energy Product Omnibus initiative as an opportunity to make the existing legislative framework better.

The legislation should reflect market realities and reduce unnecessary administrative burdens on manufacturers.

In this position paper, the European Heat Pump Association (EHPA) aims to further contribute to the European Commission’s Call for Evidence on the Energy Product Omnibus initiative.

It builds on EHPA’s January 2026 feedback by refining earlier recommendations and introducing additional proposals for consideration.

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EHPA feedback on Ecodesign and Energy Labelling rules

ehpa_editor_daniela — Tue, 27 Jan 2026 11:14:15 +0000

This paper sets out the European Heat Pump Association’s feedback on the draftEcodesign and Energy Labelling Regulations for space and combination heaters, as well as for water heaters and storage tanks (Lots 1 and 2).

EHPA supports the Commission’s efforts to modernise the regulatory framework of Lots 1 and 2 in order to improve energy performance of heaters, strengthen consumer accessibility to information and better reflect technological progress and the EU’s climate and energy objectives.

EHPA also considers that the revision of Lots 1 and 2 represents an important opportunity for the Commission to advance its broader simplification and competitiveness agenda – particularly in the context of the upcoming Energy Product Omnibus – while supporting the roll-out of heat pumps as a cornerstone technology for the decarbonisation of the heating and cooling sector.

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EHPA position on the simplification of heat pump-related product policy

ehpa_editor_daniela — Tue, 20 Jan 2026 16:21:42 +0000

This publication provides feedback from the heat pump industry to the European Commission’s work on the forthcoming Energy-related Products Omnibus proposal, as well as the revision of the New Legislative Framework.

Heat pumps have the potential to deliver REPowerEU objectives, whilst strengthening energy security and boosting industrial competitiveness.

With 2.31 million heat pump units sold in 2024, the sector already makes a substantial contribution to employment across manufacturing, installation and maintenance. Overall, employment is significant, with approximately 433,000 jobs supported directly and indirectly.

The scale and continuity of these annual sales, however, depend not only on market readiness, but also on a coherent, predictable and supportive regulatory framework that enables their rollout.

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EHPA feedback on the European Affordable Housing Plan

ehpa_editor_daniela — Thu, 16 Oct 2025 09:36:28 +0000

Affordable housing is not only a social priority; it is also a cornerstone of the EU’s climate and energy transition.

In 2022, the residential and building sector accounted for over 40 % of EU final energy consumption and roughly one-third of its greenhouse gas emissions.

Tackling housing affordability must therefore go hand in hand with cutting energy use and emissions in homes.

By ensuring that new and renovated affordable housing is energy-efficient and equipped with clean technologies, the Plan can improve living conditions, reduce energy bills, and accelerate decarbonisation.

Read our position paper:

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EHPA position on the EU energy security framework

ehpa_editor_daniela — Mon, 13 Oct 2025 12:10:02 +0000

Heat pumps play a pivotal role in enhancing Europe’s energy security by harnessing natural energy from the air, ground, or water, requiring only a small amount of driving electricity.

Their deployment reduces Europe’s reliance on fossil gas imports for heating and cooling across residential, commercial, and industrial settings.

The European Commission is revising the EU energy security framework to address sectoral fragmentation and the gaps revealed during the energy crisis caused by Russia’s invasion of Ukraine, and to prepare for a more decarbonised, electrified, and integrated energy system.

Read our position paper:

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EHPA position on the Heating and Cooling Strategy

ehpa_editor_daniela — Fri, 10 Oct 2025 12:39:57 +0000

The heating and cooling sector still accounts for over 50% of all energy consumption in the EU.

Although renewable energy sources have gradually increased their contribution over the years, they only accounted for 26.2% of final energy consumption in the heating and cooling sector in 2023, meaning that around 70% still comes from fossil fuels.

To reduce the use of fossil fuels in the heating and cooling sector, several alternatives exist. However, these options come with specific limitations related to cost, scalability, geography, or environmental impact.

The role of heat pumps stands out in this context as, unlike other alternatives, they represent a mature technology capable of providing both heating and cooling, allowing for greater use of renewable energy sources and waste heat, doing so with significantly higher efficiency than conventional fossil-fuel-based systems.

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EHPA position on the Electrification Action Plan

ehpa_editor_daniela — Fri, 10 Oct 2025 12:31:06 +0000

Despite significant progress in making electricity cleaner and more efficient, its share of final energy consumption has grown by less than 3% over the past two decades.

This slow uptake is consistent across sectors and countries, underscoring the need for coordinated, strategic action to fully realise electrification as a cornerstone of a sustainable European energy system.

Heat pumps are a key technology to accelerate this transition, as they reduce energy demand, enable direct electrification, and make use of renewable and waste heat across residential, commercial, and industrial applications.

Moreover, heat pumps play a crucial role in enhancing Europe’s energy security. If 7% of European homes (around 14 million altogether) changed their fossil fuel boiler for a heat pump, it would cut 13 billion cubic metres of gas, which is equivalent to the amount the EU imports for home and water heating from Russia.

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State aid rules revision: our input

ehpa_editor_daniela — Fri, 03 Oct 2025 08:45:37 +0000

EU State aid rules define how Member States can channel public money into specific sectors, such as heat pumps.

The European Commission is now looking to simplify its State aid rules, which is a positive step in the European Heat Pump Association (EHPA)’s view.

In particular, the ‘General Block Exemption Regulation’ (GBER) enables Member States to give public money to certain categories more swiftly, by exempting them from prior notification to the Commission.

This revision represents a valuable opportunity to make full use of state aid instruments to direct national subsidies toward priority industries.

In this context, EHPA recommends that the European Commission ensures the revised GBER is fully integrated within the broader State Aid reforms. The rules must support the EU transition towards climate neutrality, energy security, and economic resilience.

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Joint letter to EU Commission: distribute draft proposals ahead of meetings

ehpa_editor_daniela — Tue, 23 Sep 2025 12:50:01 +0000

Dear Commissioner Dan Jørgensen,

We are writing to respectfully urge the Commission to reinstate the practice of distributing Ecodesign and Energy Label draft Commission proposals well in advance of the Ecodesign and Consultation Forum meetings.

This approach has long been a cornerstone of transparent and effective policy development within the EU legislative process. Timely access to these documents enables industry experts, NGOs, Member State representatives and other stakeholders to prepare thoroughly and provide informed and constructive input during the meetings.

The resulting dialogue has avoided errors, improved the quality of proposed measures and avoided additional delays in the process. Additionally, it helped avoid unnecessary discussions during meetings.

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EHPA position on social leasing for heat pumps

Sarah Azau — Mon, 01 Sep 2025 08:57:58 +0000

‘Social leasing’ means low-income households can rent clean technologies by paying an affordable monthly fee.

The European Commission is due to produce guidance for EU governments on social leasing for heat pumps and other clean technologies in 2025, as part of the Clean Industrial Deal.

To inform policymakers at EU level on this topic and contribute to the guidance, EHPA has prepared this position paper.

It covers the concept of social leasing, explores how it could be applied to heat pumps, and identifies potential barriers and solutions.

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