The supplier of the heat pump, placing the heat pump on the market, is responsible for establishing a single declaration of conformity for the heat pump and its integrated products. The declaration of conformity should include all the required information for both the heat pump and all the integrated products. The single declaration of conformity can be made up of a dossier containing all relevant individual declarations of conformity.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
In the case of a package, both the classes of the heater and of the package have to be indicated. If multiple classes have to be indicated in advertisements, it is necessary to indicate which class refers to what.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Regulation (EU)813/2013 does not exclude synthetic fuels, which are thus in the scope, although there are not any specific provisions for those combustibles in the current Regulation (EU) 813/2013. The standards that could be used are, for gas fired boilers EN15502-1, and for liquid fuel fired boilers EN304. Such standards could be amended to include provisions for synthetic fuels, if needed.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The seasonal space heating energy efficiency class for the medium-temperature application (55°C) should always be displayed on the combination heater package label.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The seasonal space heating energy efficiency class for the medium-temperature application (55°C) should always be displayed on the space heater package label, except for low temperature heat pumps, i.e. when the package label is accompanied with the label of section 1.1.4 or 1.2.4 of Annex III.
In those cases, but only then, the seasonal space heating energy efficiency class for the low-temperature application shall be displayed. If both seasonal space heating energy efficiency classes are shown on the product label (section 1.2.3 or 2.2.3) the one for the medium-temperature application should be displayed on the package label.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Since the medium temperature applications is the most common one, it is the intention of the legislation that for this application the energy class should be displayed in advertisements and technical promotional material. Also both classes may be indicated if it is clearly indicated which class belongs to which temperature application.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Low and medium temperature applications should not be confused with the requirements for low temperature heat pumps. Low temperature heat pumps are specifically designed for low temperature application and are NOT able to deliver heating water with an outlet temperature of 52 °C at an inlet dry (wet) bulb temperature of – 7 °C (– 8 °C) in the reference design conditions for average climate. The seasonal space heating energy efficiency of low temperature heat pumps shall not fall below 125 %. For low- temperature heat pumps, parameters shall be declared for low-temperature application.
For all other heat pumps, the seasonal space heating energy efficiency shall not fall below 110 %. Parameters shall be declared for medium-temperature application. Manufacturers can declare values for low temperature application on a voluntary basis, but there is no requirement attached to this declaration.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The supplier of the heat pump, placing the heat pump on the market, is responsible for establishing a single declaration of conformity for the heat pump and its integrated products. The declaration of conformity should include all the required information for both the heat pump and all the integrated products. The single declaration of conformity can be made up of a dossier containing all relevant individual declarations of conformity.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
If the combination heater and the domestic hot water tank are sold under two different model identifiers, then the domestic hot water tank is considered as a hot water storage tank and the two components shall be labelled separately. They also need to be tested as individual products and meet the minimum requirements set for them. For solid fuel combination boilers, the water heating efficiency is not regulated.
The label of a combination boiler should include the symbol for the water heating function, see Annex III of Regulation (EU)2015/1187. Hot water storage tanks sold under different model identifiers and combined with these 32 heaters are regulated under Regulations (EU) 814/2013 and 812/2013. They should meet the minimum requirements and be labelled separate accordingly.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
A “hybrid” put on the market consisting of two or more technologies integrated in one casing would be considered a single “product”. A hybrid consisting of a heat pump and a gas boiler is to be considered a heat pump as boiler space heaters are defined as space heaters that generate heat using the combustion of fuel and / or the Joule effect.
In the absence of a calculation methodology for heat pumps integrating a fossil fuel supplementary heater, suppliers can use the same methodology proposed by EN 14825 for electrical supplementary heaters by replacing performances of electrical supplementary heater with the performances of fossil fuel 33 supplementary heater. It is up to the standardisation process to develop specific standards for these hybrid products.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The hybrid heat pump can be labelled as a heat pump combination heater, in which the water heating performance has been tested according to gas boiler combination heater methodology, while the space heating performance has been evaluated.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The regulation does not refer to 'installer', but it does refer to 'dealer'. A package label has to be provided by the dealer defined in the Energy Labelling Regulation as “a retailer or other natural or legal person who offers for sale, hire, or hire purchase, or displays products to customers or installers in the course of a commercial activity, whether or not in return for payment”. If the person installing the product is doing any of these, he/she will be considered the “dealer” and the package label is required.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
If more than two heat pumps are installed together, it is sufficient that the separate space heaters are labelled with a product label. The dealer can of course calculate the expected performance of the package and include that in the offer (but not on a package label as this combination is not covered by its definition).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Cogeneration space heaters are defined as space heaters that simultaneously generate heat and electricity in a single process. In principle, they can also be designed to also provide heat to deliver hot drinking or sanitary water at given temperature levels, quantities and flow rates during given intervals and be connected to an external supply of drinking or sanitary water.
In such cases, information about their water heating energy efficiency shall also be provided in the energy label, by using one of the following two options:
- Use the labels foreseen in Regulation (EU)811/2013 for cogeneration space heaters and for combination heaters.
- Use the label foreseen in Regulation (EU)811/2013 for combination heaters including the pictogram corresponding to the electricity function.
It is to be noted that the seasonal space heating energy efficiency of combination heaters needs to be determined according to point 3 of Annex VII of Regulation (EU) 811/2013. In the case of their water heating energy efficiency, point 5 needs to be applied, which mean that their electrical efficiency is only taken into account for the determination of their seasonal space heating energy efficiency. When the review of the Regulations is carried out, this point is to be taken into account.
For solid fuel boilers, the water heating efficiency is not regulated. It is sufficient for solid fuel cogeneration combination boilers to use the pictogram corresponding to the water heating function and the electricity function as indicated in Annex III of Regulation (EU) 2015/1187.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.