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Energy Efficient Products

Are warm air heaters using gaseous fuels and intended to complement the heating of a rooftop heat pump in the scope of this regulation?

Yes. According to Art. 2(1), an air heating product can be equipped with one or more heat generators. Therefore, when warm air heaters are sold as a single package with the rooftop heat pump, they are in the scope and the reasoning in question 4 applies.

When warm air heaters are not sold as a single package and when the intended use of its air based heating system is space heating for the thermal comfort of human beings or when it is marketed as such, they are in scope of the regulation.

More info here.

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.