Joint industry letter on EPBD and labelling of the installed stock of boilers

Jun. 06, 2017

To Members of the European Parliament’s ITRE Committee 


Dear Member of the European Parliament, 

We are writing to you as a coalition of industry associations, working in the heating and cooling sector, to support the idea of introducing a provision on labelling the installed stock of boilers in the Energy Performance of Buildings Directive (EPBD), which is currently under review.

The implementation of the current EPBD has not resulted in an increased replacement rate of inefficient boilers, which have outlasted their intended technical life. This is a major problem, as 80 million of the 120 million space heaters installed in the EU’s existing buildings are inefficient. The review of the EPBD offers an opportunity to develop dedicated policies to address this issue with a view to accelerating the necessary transition towards a highly efficient and carbon- emission free building stock in the EU by 2050.

The EPBD with its focus on informing consumers about the energy performance of their buildings lends itself perfectly to take on this challenge. One of the main obstacles to modernise heating systems remains the lack of awareness among consumers about how inefficient their current heating system is. Consumers pay their energy bills without reflecting on the potential energy savings that could be made by switching to high-efficiency and renewable heating technologies. Until their boiler breaks down ...

The European Commission’s ‘EU Strategy on Heating and Cooling’ correctly identified the challenge that “[d]ecisions on replacing old appliances are typically made under pressure, when the heating system breaks down”. In such situations, typically during a cold winter day, consumers do not have the time to compare prices, research financial incentives and inform themselves about what heating (and hot water) system and energy source is technically feasible for their home.

So, how can the EU best engage consumers about a planned switch to a more efficient and renewable heating system? In our view, the EU policies on Ecodesign and Energy Labelling have a proven track record of pushing the market to adopt the most efficient products. Member States can build on these policies, e.g. by starting to label the installed stock of old boilers. Awarding an energy label to an old boiler informs consumers in easy-to-understand language that their appliances are inefficient compared to the heating technologies that are currently on the market. In addition, information can be distributed about the public or private financial instruments available to deal with the upfront cost of an investment in a modernised heating system.

To be clear, the challenge is not a technological one. A wide range of heating technologies exists that can replace these inefficient boilers: solar thermal collectors, heat pumps using ambient and geothermal heat, condensing boilers, (micro-) combined heat and power, biomass boilers, fuel cells, smart home-technologies, etc. Although they vary in nature and potential, some of these technologies will always be able to fit the needs of any building in Europe. Furthermore, with the right level of integration and timely replacement cycles, they will be the essential components of a decarbonised future.

This explains why the idea of labelling the installed stock of boilers is catching on. Germany already introduced such a scheme in 2017. Italy and France are studying such a labelling scheme. The heating industry in the UK and Austria already launched such a scheme. Support from public authorities across the EU will scale up these initiatives and increase their effectiveness.

In closing, labelling the installed stock is an idea whose time has come. The review of the EPBD offers a window of opportunity that shall not be missed.

Yours sincerely,

Jean-Marc Jossart. Secretary-General - European Biomass Association (AEBIOM)

Hans Korteweg, Managing Director - COGEN Europe

Philippe Dumas, Secretary-General - European Geothermal Energy Council (EGEC)

Federica Sabbati, Secretary-General - Association of the European Heating Industry (EHI)

Thomas Nowak, Secretary-General - European Heat Pump Association (EHPA)

Pedro Dias, Secretary-General ESTIF

Jorgo Chatzimarkakis, Secretary-General - Hydrogen Europe