Heating

The European Geothermal Energy Council (EGEC) welcomes the European Commission’s review of the energy labelling and Ecodesign requirements for space and combination heaters. These revisions are both timely and necessary to reflect technological progress and ensure consistency with EU climate objectives. EGEC considers the review a key opportunity to correct long-standing shortcomings affecting geothermal heat pumps (GHPs), whose performance has historically been misrepresented due to outdated and unrealistic testing assumptions. Under the current framework, geothermal heat pumps are assessed using inlet temperature assumptions set in 2013 that rely on unrealistically low brine temperatures. This has resulted in systematic underestimation of geothermal performance compared to other heat pump technologies, despite geothermal proven seasonal efficiency, stability and system value. We therefore welcome the Commission’s proposal to adjust the reference inlet temperature to 5 °C, which better reflects average operating conditions across Europe and restores fairness between technologies. This correction also aligns geothermal testing conditions with the way average conditions are already used for air-source heat pumps. We consider the proposed 5 °C reference temperature a pragmatic and robust compromise that improves representativeness without adding unnecessary complexity to the regulatory framework. It should be clearly defined as an average seasonal condition, not a conservative design extreme. While supporting a more differentiated testing approach in the longer term, we believe this revision is an essential step towards a level playing field and an accurate recognition of geothermal heat pumps within EU energy policy. Read EGEC's response to the consultation