During the Consultation Forum of the 10th of September 2019, a discussion paper from the European Commission on the combination of the energy label for local space heaters (Lot 20 products) and air-to-air heat pumps (Lot 10 products) was discussed ;
We believe that Lot 10 and Lot 20 products should remain in separate energy labelling schemes as :
1) local space heaters and air-to-air heat pumps can both provide heat but have distinct sets of functionalities for which distinct performance criteria have been set ;
2) keeping Lot 20 and Lot 10 products on separate energy labels is necessary in order to implement the flexible grid management that local space heaters allow for and that is necessary for RES development ;
3) merging the two energy labelling schemes would make it more difficult for consumers to make informed purchase decisions as it would lessen the quality of the information they are provided ;
4) a common energy labelling scheme would discourage innovation and investment by making it impossible for local space heaters to ever reach the highest categories of this new larger energy label class.