Should the SEPR value of process chiller include the energy consumption of the pump, even if the process chiller is not placed on the market with a pump?

Yes, the pump should be included in the SEPR value of process chillers even if the process chiller is placed on the market without a pump.

_{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.}