The Energy Saving Trust published its response to the European Commission's call for evidence on ecodesign requirements for air heating and cooling products on 23 April 20261. The charity said it welcomed the revision of the EU rules, numbered EU 2016/2281, and that it would support UK standards aligning to them1.
"we would support standards in the UK aligning to these"
The response sets out several proposed changes. On scope, it suggests extending the requirements to chillers using evaporative condensing and free coolers, and supports including absorption process-based refrigeration chillers, chillers operating within different temperature ranges, products using solid fuels such as biomass, and products that co-produce power or heating as cogeneration or trigeneration1. On labelling, it argues the most used products in scope should carry an energy label, including all products with predicted sales above 50,000 units a year until 20501.
On efficiency and emissions, the Trust recommends aligning requirements with those for similar products such as space heaters (EU 2013/813) and air conditioners and air to air heat pumps (EU 2016/2281), and aligning nitrogen oxide limits for warm air heaters with those for boilers of the same capacity1. It also supports applying the F-gas regulation's global warming potential limits to products in this review, prioritising natural refrigerants and accelerating the phase out of PFAS1.
On testing, the Trust supports the compensation method for air conditioners and heat pumps, and questions the option of a water loop with an inlet temperature on the primary side of 20°C, saying such results are not comparable with lower, more realistic inlet temperatures1. It supports lowering test temperature sets, and for air conditioning supports an indoor test temperature of 24°C rather than the specified 27°C1. It also supports third-party conformity assessment and interoperability with grids1.
On circular economy measures, the Trust supports access to spare parts and repair information within 15 days across an average product lifetime of 17 years, including for non-authorised repairers with the necessary authorisation to work with gas, electricity and heating equipment, and removing the distinction between professional repairers and end-users for such access1. It supports recyclability criteria under which heating technologies containing copper, aluminium, lead and steel would have to contain at least 50% recycled content from manufacturing waste or post-consumer waste from 48 months after entry into force1. It adds that a maximum spare parts delivery time of 15 working days is too long for heating appliances1.
| Area | Energy Saving Trust position |
|---|---|
| Scope | Extend to evaporative condensing chillers and free coolers; include absorption chillers, other temperature ranges, solid fuel products, cogeneration and trigeneration1 |
| Labelling | Label the most used products in scope, including those with predicted sales above 50,000 units a year until 20501 |
| Testing | Support compensation method; lower test temperature sets; 24°C indoor air conditioning test rather than 27°C1 |
| Repairs | Spare parts and repair information within 15 days; 15 working days delivery judged too long1 |
| Materials | At least 50% recycled content for copper, aluminium, lead and steel from 48 months after entry into force1 |
Why it matters for households
Ecodesign rules set the minimum performance a product may be sold at, and energy labels are the ratings a householder sees on a showroom model or a specification sheet. The Trust's call for labels on the most used products in scope, and for test temperatures closer to real operating conditions, bears on whether the efficiency figure on a heat pump or air conditioner reflects how it performs in a home1. Its position on spare parts and repair information, and on the distinction between professional repairers and end-users, bears on how long a household might wait for a repair and who is allowed to carry one out1. The recycled content proposal concerns the materials in the equipment itself rather than its running cost1. The Trust's stated support for UK standards aligning with the revised EU requirements is a position on UK home energy regulation and policy, and the rules sit alongside the wider framework of energy labels and ecodesign rules for household appliances. How far any of this reaches a given home depends on whether the UK adopts equivalent requirements, which the response does not decide.
What happens next
The response is dated 23 April 2026 and was last updated the same day1. The EU revision of EU 2016/2281 is at the call for evidence stage, and no timetable for the Commission's next steps, or for any UK alignment, has been reported1.
Sources1 cited
- Requirements for heating and cooling products - Energy Saving Trust, energysavingtrust.org.uk