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46 | THE PERFECT FIT REGULATORY ASSISTANCE PROJECT How would these proposals affect heat pumps? The ecodesign proposals in their current draft form would not significantly accelerate heat pump market penetration, as they keep inefficient fossil-fuel heating systems on the market with no intention to phase them out over time. Moreover, the promotion of ‘hydrogen ready’ boilers suggested by those drafts could be seen as a reason to maintain the status quo and keep installing gas boilers. In a letter addressed to NGOs on 19 November 2021, the European Commission seems to indicate a preference for leaving it to Member States to ban the sales of heating equipment that relies on fossil fuels. Recent and potential future increases in the price of fossil fuels may however justify a reconsideration by the Commission of the proposed levels for ecodesign. Indeed the proposals are required to be based on an analysis of their economic impacts, and a significant change of the energy prices would modify the conclusion of the least life-cycle cost analysis. As for the regulation of heat pumps themselves, the new regulations would increase the minimum seasonal space heating efficiency of heat pumps from 125% to 155% for low-temperature heat pumps and from 110% to 130% for medium-temperature heat pumps. Those represent very modest increases as they mainly reflect a change in the primary energy factor. The proposed revised label would support the deployment of heat pumps by allowing a better comparison of the relative efficiencies of the available heating solutions and downgrading condensing gas boilers from an average A class to an average F class. What should the EU do to make the policy proposals better? The draft regulations do not provide a path for the EU to prohibit the sale of inefficient, carbon-intensive heating systems, something which may be required to drive the clean heating market at scale. The single most important improvement to support the uptake of heat pumps in the ecodesign proposal would be to include a minimum 110% minimum seasonal heating efficiency. This would lead to the phaseout of non-hybrid fossil-fuel boilers and would be a gamechanger for the market penetration of heat pumps and hybrid boilers. This could enter into force as early as 2025, or start with a less stringent level and set this level as a second tier that would apply a few years later. The minimum efficiency standards for hybrid boilers are also not stringent enough to guarantee a sufficiently high contribution from heat pumps to the total heat output. The minimum requirements for this type of equipment should be more ambitious, with a minimum seasonal heating efficiency of 130% and/or a much higher (to be defined) contribution of the heat pump to the seasonal heating energy output. Concerning the revised energy label, the EU should be consistent with its hydrogen strategy62 and not promote hydrogen readiness in residential heating systems. A mandatory load-based test procedure63 should also help ensure that the actual efficiency in real life of heat pumps sold on the European market truly reflects the efficiency requirements set 62 European Commission. (2020d). Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – A hydrogen strategy for a climate-neutral Europe. https://eur-lex.europa.eu/legal-content/EN/ TXT/?uri=CELEX:52020DC0301 63 A load-based method effectively tests the equipment for a range of load levels to measure its behaviour and efficiency across a sample of operating conditions that will be met in real life, rather than extrapolating from a few test points defined by the manufacturer. It ensures a better representativeness and allows independent testing.PDF Image | RAP Perfect Fit Heat Pump
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