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REGULATORY ASSISTANCE PROJECT THE PERFECT FIT | 47 forth in the proposed new regulation. This objective may not be achieved by the current proposal, which presents a load-based test procedure but only an optional one, which wouldn’t support a full adoption, and wouldn’t allow a fair comparison of products. Delaying the transition to a revised version of the label would hamper heat pump deployment, as the new label is expected to better promote the deployment of heat pumps. Concerning ecodesign, although a delay in the adoption would represent lost savings, a two-tiered approach may be possible, which would make the adoption of ambitious levels more likely. What should Member States do now? While product standards are adopted at the EU level and the European Commission has already prepared a draft proposal, Member States can still push for more ambitious ecodesign and energy labelling measures ahead of the European Commission’s final proposal. Some Member States (Germany, France, Denmark, Austria and Sweden) have already expressed support for a higher ambition, and many others have remained silent for now. Ambitious Member States could thus seek to build a consortium to reassure the European Commission that a more stringent proposal would pass the vote of Member States. Furthermore, the European Commission’s proposal for the EPBD clarifies that national measures to restrict the installation of fossil-fuel boilers would be permissible, allowing Member States to go beyond the minimum performance requirements proposed by ecodesign regulations and building performance requirements under the EPBD. A report by the Öko-Institut clarifies that Member States could legally do that by targeting aspects not addressed by product regulations, such as GHG emissions of certain categories of equipment.64 Regardless of whether ambitious minimum energy performance requirements are adopted under ecodesign, Member States should thus introduce measures to ban the installation of fossil- fuel boilers by 2025. They should implement these measures at earlier dates than requested by the EPBD, as some are already doing, to accelerate the transition to decabonised heating solutions. Once the energy labelling regulation is adopted, Member States should also use it as the backbone of incentive policies, to support the deployment of the most efficient heating solutions. 64 Braungard et al., 2021.PDF Image | RAP Perfect Fit Heat Pump
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