Ecodesign Directive for Heat Pumps

The Ecodesign Directive for heat pumps is the common name for European rules that set minimum environmental and energy-performance requirements for heating products before they enter the market. In German-speaking markets, it is often called the Ökodesign-Richtlinie or ErP-Richtlinie. For hydronic heat-pump space heaters and combination heaters, the current product-specific requirements are mainly contained in Commission Regulation (EU) No 813/2013. This regulation covers products with a rated heat output of up to 400 kW.

What it does: Ecodesign sets the minimum performance level that a heat pump must achieve. It addresses seasonal space-heating efficiency, heat-pump sound power, product information and conformity documentation. Combination heat pumps must also meet water-heating requirements. Products that do not meet the applicable minimum requirements may not be placed on the EU market.

How it is applied: The manufacturer or importer first classifies the product and identifies the applicable regulation. The product is then tested or calculated with prescribed methods. The responsible economic operator prepares technical documentation, issues a Declaration of Conformity and affixes the CE marking. Energy-labelled models must also meet the separate labelling and EPREL requirements.

Why it matters: Ecodesign creates a common market-access standard. It prevents very inefficient products from competing only through a low purchase price. It also gives manufacturers, installers, building planners and customers a common technical language. However, Ecodesign compliance alone does not guarantee that a heat pump will operate efficiently after installation.

Current legal status: Directive 2009/125/EC was repealed on 18 July 2024 and replaced at framework level by the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, commonly called ESPR. Existing product-specific measures continue to operate during the transition. The European Commission still lists Regulations 813/2013 and 811/2013 as the measures in application for space and combination heaters, while a revised measure remains under legislative development.

What is the Ecodesign Directive in a heat-pump environment?

The Ecodesign Directive was a European framework for setting mandatory environmental requirements for energy-related products. It did not contain one universal efficiency limit for every product. Instead, the European Commission adopted product-specific regulations for defined product groups. Heat-pump space heaters are covered through one of these product-specific measures.

In a heat-pump environment, Ecodesign mainly controls the product before it is placed on the market. It does not design the building, calculate the building heat load or approve the final installation. Those tasks remain part of system planning, national building rules, electrical regulations, refrigerant rules and local noise requirements.

Core purpose of the Ecodesign Directive

The core purpose of Ecodesign is to improve the environmental performance of products through common, mandatory requirements. For heat pumps, the current requirements focus strongly on energy use during operation. They also address sound power because noise is a significant environmental aspect of heat-pump heaters. Product information requirements support verification and informed system design.

The rules have four practical objectives:

1. Remove low-performing products from the market.
2. Create one technical basis for market access across the EU.
3. Make declared performance measurable and verifiable.
4. Encourage better product design and technical innovation.

This common structure reduces market fragmentation. A manufacturer does not need a completely different product-efficiency method for Austria, Germany, Italy, Spain, Poland and Finland. The same EU product regulation applies, although national installation and building rules can still differ.

Ecodesign is therefore a market-access instrument. It is not a premium-performance certificate. A product can meet the minimum requirement and still be less suitable than another product for a particular climate, flow temperature, building or noise-sensitive location.

Why Ecodesign requirements are needed for heat pumps

Heat-pump performance changes with operating conditions. Outdoor temperature, heat-source temperature, heating-water temperature, part load, defrosting, domestic hot-water demand and supplementary heating can all affect electricity use. A single laboratory COP value cannot describe an entire heating season.

Without a common method, one manufacturer could declare performance at favourable conditions while another uses more demanding conditions. The values would appear comparable even when they are not. Ecodesign reduces this problem by defining common terms, reference conditions, measurement methods and calculation procedures.

Problems that Ecodesign helps address

• High lifetime energy costs: An inexpensive product can create higher operating costs over many years.
• Inconsistent declarations: Different test conditions can make technical data misleading.
• Poor market comparability: Buyers cannot compare products without common metrics.
• Noise conflicts: An outdoor unit can create planning and neighbour problems when acoustic data is incomplete.
• Hidden backup-heater use: Electric or fuel-based supplementary heating can reduce seasonal performance.
• Market-access risk: Missing documentation or unsupported declared values can delay a launch or lead to corrective action.
• Tender risk: Developers and public buyers need verifiable information for specifications and procurement.
• Reputation risk: Incorrect labels or efficiency claims can damage installer and manufacturer credibility.

The European Commission’s impact accounting for central hydronic heating products estimates that Ecodesign and energy-labelling measures produced 136 TWh of primary-energy savings in 2020 compared with a scenario without the measures. Its model projects savings of 306 TWh in 2030. These figures cover the wider central-heating product group and should not be interpreted as heat-pump-only savings.

Key features of Ecodesign rules for heat pumps

The current framework uses several connected features. Each feature answers a different compliance or product-selection question.

Detailed explanation of the key features

Product scope and classification

Definition: Regulation 813/2013 covers space heaters and combination heaters with a rated heat output of no more than 400 kW, including heaters used in defined packages. A heat-pump space heater under this regulation supplies heat to a water-based central-heating system.

Purpose: The classification establishes which legal test and information requirements apply.

Benefit: Correct classification prevents the use of the wrong efficiency method or label.

Example: A 12 kW air-to-water heat pump supplying underfloor heating normally falls within this scope, while an air-to-air system or a dedicated heat-pump water heater follows a different product-specific route.

Products that require separate assessment include:

• Dedicated heat-pump water heaters
• Air-to-air heat pumps
• Central air-heating products
• Local space heaters
• Solid-fuel heaters
• Products above the applicable rated-output limit
• Custom systems that do not meet the regulated product definition

The product’s heat source does not decide the legal route on its own. Air-source, ground-source, water-source and waste-heat systems can all fall under Regulation 813/2013 when they supply a water-based central-heating system and meet the other scope conditions.

Seasonal space-heating energy efficiency, ηs

Definition: Seasonal space-heating energy efficiency, written as ηs, is the ratio between the space-heating demand supplied during a defined heating season and the annual energy required to provide it. For an electrically driven heat pump, the calculation derives ηs from SCOP, the current conversion coefficient and specified correction factors.

Purpose: It creates a market-access metric that reflects seasonal rather than single-point operation.

Benefit: It provides a more representative compliance measure than one COP value.

Example: A product with SCOP 4.0 would have a simplified pre-correction value of about 160% when divided by the current conversion coefficient of 2.5; the final regulated ηs value also includes the required adjustments.

An ηs value above 100% does not mean that the heat pump creates energy. A heat pump transfers environmental heat and uses electricity to operate the cycle. The regulatory calculation also expresses electricity in primary-energy terms through the conversion coefficient.

Under the current requirements:

• A legally defined low-temperature heat pump must achieve at least 125% ηs.
• Other covered heat pumps must achieve at least 110% ηs.
• The applicable declaration temperature depends on the product classification.

These are minimum market-access values. They are not recommended design targets, annual electricity guarantees or evidence that the installation is correctly sized.

Low-temperature and medium-temperature applications

Definition: A low-temperature application uses a 35°C reference temperature, while a medium-temperature application uses a 55°C reference temperature. The legal category “low-temperature heat pump” has a narrower meaning: it refers to a heat pump that cannot deliver heating water at 52°C under specified cold reference conditions.

Purpose: The distinction prevents products designed only for low-temperature systems from being compared incorrectly with products that can serve higher-temperature systems.

Benefit: Planners can match declared performance to the building’s actual heat emitters.

Example: A heat pump that can provide 55°C water may publish strong 35°C data, but this does not automatically make it a legally classified low-temperature heat pump.

This distinction matters in renovations. A product can achieve a high efficiency class at 35°C but operate at a lower seasonal efficiency when it must supply radiators at 50°C or 55°C. Product selection should therefore use the declared temperature condition that represents the planned heating system.

Use the following rule:

• Use 35°C data for genuinely low-temperature emitters such as correctly designed underfloor heating or large low-temperature radiators.
• Use 55°C data when the system is expected to operate near medium-temperature conditions.
• Do not use the 35°C class alone to predict a radiator retrofit.
• Check the required flow temperature at the building’s design outdoor temperature.

Seasonal climate and part-load calculation

Definition: The Ecodesign methodology evaluates heat-pump operation across a defined heating season with temperature bins and part-load conditions. The average-climate reference is based on conditions associated with Strasbourg.

Purpose: The method represents the fact that a heat pump operates at full output for only part of the year.

Benefit: It rewards products that maintain efficient operation at common partial loads.

Example: A modulating heat pump that follows the building load can achieve a better seasonal result than a product that frequently starts, stops or relies on supplementary heating.

The calculation considers more than compressor performance. Depending on the product, it can account for:

• Part-load operation
• Temperature-bin hours
• Capacity at defined outdoor temperatures
• Standby and off-mode consumption
• Crankcase or auxiliary energy
• Degradation during cycling
• Supplementary-heater energy
• Water- or brine-pump contributions
• Temperature-control corrections

The result is still a standardised value. It is not a simulation of one specific building or one specific year of weather.

Supplementary heaters

Definition: A supplementary heater provides additional heat when the preferred heat generator cannot meet the required load. It can be an electric resistance element or a fuel-driven heater.

Purpose: Ecodesign includes relevant supplementary-heater operation so that declared performance does not ignore backup energy.

Benefit: Buyers receive a more realistic seasonal assessment.

Example: An undersized heat pump may meet peak demand with an electric heating element, which can reduce the real annual efficiency even though the compressor has a strong COP.

The presence of a backup heater is not automatically a defect. It can support emergency operation, hygiene cycles or rare peak loads. The important questions are how often it operates, at what power and whether the system controls prevent unnecessary use.

Sound power level

Definition: Sound power level, LWA, describes the total A-weighted acoustic power emitted by a product. It is expressed in dB(A) and is different from the sound-pressure level measured at a particular distance.

Purpose: The requirement creates a standardised acoustic declaration and supports maximum product-level sound requirements.

Benefit: Designers can compare units and start site-specific acoustic planning with consistent source data.

Example: The declared outdoor sound power of an air-source heat pump can be entered into a location calculation that also considers distance, reflections, barriers and night-time limits.

Ecodesign sound compliance does not prove that every installation will satisfy local noise law. Site planning must also consider:

• Distance to neighbouring windows
• Building-corner reflections
• Courtyards and narrow passages
• Tonal characteristics
• Night-time operating modes
• Multiple outdoor units
• Mounting structure and vibration transmission
• National or municipal noise requirements

A sound-power value is therefore a product input. It is not a property-boundary prediction.

Water-heating energy efficiency, ηwh

Definition: Water-heating energy efficiency, ηwh, is the ratio between useful energy delivered in domestic hot water and the energy required to produce it. It applies when the regulated product is a combination heater.

Purpose: It separates domestic-hot-water performance from space-heating performance.

Benefit: Customers can identify products that are efficient in both functions rather than relying on the space-heating class alone.

Example: Two heat pumps may have similar ηs values but different hot-water performance because of cylinder design, storage losses, control logic or required hot-water temperature.

Domestic-hot-water demand should be checked independently during system selection. Important factors include:

• Declared tapping or load profile
• Cylinder volume
• Recovery time
• Standing losses
• Maximum hot-water temperature
• Hygiene strategy
• Electric-heater contribution
• Simultaneous space-heating and hot-water demand

Nitrogen-oxide requirements for combustion components

Definition: Nitrogen oxides, or NOx, are combustion-related air pollutants. They are relevant to fuel-driven heat pumps and products with fuel-based supplementary heaters.

Purpose: The requirements prevent a combustion component from escaping emissions controls simply because it is part of a heat-pump product.

Benefit: Hybrid systems can be assessed using consistent product-emission limits.

Example: An all-electric heat pump has no direct combustion NOx emissions, while a gas-engine heat pump or fuel-based backup heater must address the applicable NOx provisions.

Refrigerant emissions are a different issue. They are mainly addressed through separate refrigerant and F-gas legislation rather than the present energy-efficiency calculation under Regulation 813/2013.

Product information requirements

Definition: Product information requirements define the technical values and instructions that must accompany the product or be included in its supporting documentation.

Purpose: They make declared performance traceable and usable by authorities, designers, installers and customers.

Benefit: Complete information reduces specification errors and supports efficient commissioning.

Example: A planner should be able to find rated output, seasonal efficiency, temperature application, sound data and supplementary-heater information without relying on an unsupported marketing claim.

Typical technical information includes:

• Manufacturer and model identifier
• Rated heat output
• Seasonal space-heating efficiency
• SCOP or other required performance values
• Declared temperature application
• Output at defined outdoor conditions
• Sound power levels
• Supplementary-heater capacity
• Auxiliary electricity consumption
• Water-heating data for combination heaters
• Installation and maintenance instructions
• Details needed for package calculations

Product data should remain consistent across the technical sheet, website, energy label, EPREL entry, Declaration of Conformity and sales material.

Conformity assessment, technical documentation and CE marking

Definition: Conformity assessment is the process used to demonstrate that the product meets the applicable EU requirements. The manufacturer prepares supporting technical documentation, issues the applicable Declaration of Conformity and affixes the CE marking.

Purpose: The process places legal responsibility for the declared product on an identifiable economic operator.

Benefit: Authorities and customers receive an auditable basis for the performance claim.

Example: A manufacturer launching a new heat-pump model must retain the test and calculation evidence that supports its ηs, output and sound declarations.

Current Ecodesign regulations allow manufacturer assessment through internal design control or an equivalent permitted management-system route. Mandatory third-party certification is not the general Ecodesign conformity route under the present framework. However, the declared values still need reliable, accurate and reproducible supporting evidence.

CE marking should not be confused with an energy-efficiency award. It indicates conformity with the applicable EU harmonisation legislation that requires CE marking. It does not mean that the product has the highest energy class or is ideal for every building.

Energy label and EPREL

Definition: The EU energy label is a separate comparison instrument for covered space and combination heaters with a rated heat output of up to 70 kW. EPREL is the European Product Registry for Energy Labelling.

Purpose: The label helps buyers compare efficiency and other declared product characteristics, while EPREL provides model-level information.

Benefit: Customers can distinguish products that all meet the Ecodesign minimum but have different performance levels.

Example: A heat-pump label can show separate performance information for 35°C and 55°C operation, together with rated output and indoor or outdoor sound data.

The distinction is important:

• Ecodesign decides whether a covered product may enter the market.
• The energy label helps compare products already permitted on the market.
• EPREL stores information for products covered by EU energy-labelling registration.
• CE marking addresses broader legal conformity and is not a comparison label.

A high energy class is useful, but it does not replace heat-load calculation, acoustic planning or evaluation at the required flow temperature.

Package labels for controls and solar devices

Definition: A regulated package can combine a space or combination heater with a temperature control and a solar thermal device. The package can be assembled by a manufacturer or, under the applicable rules, by an installer.

Purpose: The package calculation recognises that controls and solar thermal components can change the performance of the complete heating solution.

Benefit: A more efficient system configuration can be distinguished from the standalone heater.

Example: Weather-compensated control and solar thermal support can improve the calculated package result when they are declared and combined according to the prescribed method.

The package label generally uses the medium-temperature 55°C class. The 35°C class is used in the special cases defined for legally classified low-temperature heat pumps.

Photovoltaics are not part of the present heater package-label calculation. A PV system can reduce purchased electricity or increase self-consumption, but it does not alter the heat pump’s regulated standalone ηs value.

Market surveillance

Definition: Market surveillance is the official verification of product compliance after or around market placement. Authorities can inspect documentation, compare declarations and arrange product testing.

Purpose: It prevents unsupported values and non-compliant products from undermining responsible suppliers.

Benefit: Effective surveillance creates fairer competition.

Example: If laboratory verification does not support a declared value, authorities can require corrective action and, where necessary, restrict, withdraw or recall the product.

Manufacturers and importers should therefore treat technical documentation as an active compliance system. Product changes, software changes, component substitutions and equivalent-model declarations should be controlled and documented.

The future role of ESPR

Definition: Regulation (EU) 2024/1781 creates a wider framework for future Ecodesign requirements covering sustainable products. It can support product-specific requirements relating to energy, durability, repairability, resource efficiency, recycled content, substances of concern and digital product information.

Purpose: The framework extends Ecodesign beyond the traditional focus on use-phase energy consumption.

Benefit: Future requirements can address more of the product life cycle.

Example: A future heat-pump measure could require additional repair, spare-parts or digital-product-passport information, but such obligations only apply when the relevant product-specific measure establishes them.

This distinction prevents a common compliance error. ESPR creates the legal framework, but it does not automatically impose every possible ESPR parameter on every heat pump. Businesses must follow the requirements in the product-specific legal act that is in force and applicable on the relevant date.

How to comply with Ecodesign requirements

Manufacturers and importers can use the following compliance sequence.

Step 1: Define the target market

Identify whether the product will be placed on the EU, EEA, Swiss or another market. Do not assume that one declaration automatically covers every country.

Step 2: Classify the product

Determine:

• Space heater or combination heater
• Hydronic or air-based heat delivery
• Electrically driven or fuel driven
• Standalone product or package
• Dedicated water heater or combined function
• Legal low-temperature heat pump or standard heat pump
• Rated heat output
• Presence of a supplementary heater

Step 3: Identify every applicable legal act

Check Ecodesign, energy labelling, electrical safety, electromagnetic compatibility, machinery or pressure requirements, refrigerant legislation and any other product-specific law. Use the applicable version and transition date.

Step 4: Test and calculate the required parameters

Use the prescribed measurement methods, calculation rules and applicable standards. Record the test configuration, software version, component configuration and declared operating conditions.

Step 5: Verify the minimum requirements

Confirm that the product meets the applicable thresholds for:

• Seasonal space-heating energy efficiency
• Water-heating efficiency
• Sound power
• NOx emissions where relevant
• Product information
• Other regulated operating modes

Step 6: Prepare the technical file

The file should demonstrate how the declared values were obtained. It should connect test evidence, calculations, drawings, model identifiers and production controls.

Step 7: Issue the Declaration of Conformity and apply CE marking

The declaration should identify the applicable legislation and product. CE marking is applied only after the required conformity work is complete.

Step 8: Complete energy-labelling and EPREL duties

For covered models, prepare the label and product information sheet. Register the model in EPREL before the applicable market-placement deadline.

Step 9: Prepare package information where relevant

Provide the product data required by manufacturers, dealers and installers to calculate package efficiency. Ensure the control and solar-device data use the prescribed classes and methods.

Step 10: Monitor changes

Track amendments, replacement regulations, harmonised standards, Commission guidance and national implementation. A compliant product can require updated documentation when its design, software or legal basis changes.

Types of heat pumps and their Ecodesign treatment

The term “heat pump” covers several product functions. The correct legal route depends on heat delivery, output and intended use.

The European Commission currently lists Regulations 813/2013 and 811/2013 for space and combination heaters, and Regulations 814/2013 and 812/2013 for dedicated water heaters. Air-heating and cooling products are treated under separate measures.

Practical use cases

Low-temperature new building

Definition: A low-temperature new building uses emitters designed for low heating-water temperatures.

Purpose: The design reduces the temperature lift required from the heat pump.

Benefit: Lower flow temperatures usually support stronger seasonal efficiency.

Example: A correctly sized underfloor-heating system operating near 35°C can use the heat pump’s low-temperature data as a relevant planning reference.

Ecodesign helps shortlist suitable products. The final design must still verify the room-by-room load, hydraulic balance, minimum flow and control strategy.

Existing building with radiators

Definition: A radiator retrofit uses an existing or partly upgraded heat-distribution system.

Purpose: The assessment determines the flow temperature required on the coldest design day.

Benefit: The installer avoids selecting a heat pump only from favourable 35°C information.

Example: If the building needs 52°C water at design conditions, the 55°C performance data is more relevant than the 35°C class.

Emitter upgrades, insulation work and hydraulic balancing can reduce the required flow temperature. This can improve real heat-pump performance without changing the Ecodesign rating of the product.

Multifamily and commercial heating

Definition: A larger system can use one heat pump, multiple heat pumps in cascade or different heat sources.

Purpose: The design must meet variable loads, domestic-hot-water peaks and resilience requirements.

Benefit: Modulation and cascade control can keep more units within efficient operating ranges.

Example: A system may use one lead unit during low demand and add further units only as the building load increases.

The 400 kW limit applies to the regulated heater product. Large projects can also contain multiple regulated products, storage, controls and building-management interfaces. The project designer must distinguish product-level compliance from system-level engineering.

Product launch or import

Definition: A product launch places a model on a regulated market for the first time.

Purpose: The manufacturer or importer verifies legal market access before sale.

Benefit: Early classification prevents late redesign, relabelling or documentation work.

Example: An importer should verify technical evidence, the Declaration of Conformity, CE marking and EPREL status before offering a labelled heat pump in the EU.

This process is especially important for private-label products. A company selling the product under its own name can assume manufacturer responsibilities under EU product rules.

Installer-created package

Definition: An installer-created package combines a heater with an eligible temperature control and, where applicable, a solar thermal device.

Purpose: The installer calculates and communicates the package performance.

Benefit: The customer sees the effect of the complete declared configuration.

Example: A heat pump combined with advanced weather compensation and solar thermal support can receive a different package result from the standalone heat pump.

The package calculation does not replace hydraulic design or commissioning. It also does not include every possible system component.

Benefits of the Ecodesign Directive

Benefits for building owners

Ecodesign removes products that fail to meet the minimum regulated performance. It also creates standardised information for comparing products. The main owner benefits are reduced information risk and better access to technical data.

Practical benefits include:

• More consistent efficiency declarations
• Access to seasonal rather than only single-point values
• Standardised sound-power information
• Better comparison of space-heating and hot-water functions
• Reduced risk of selecting an obsolete low-performing product
• More transparent product documentation

Ecodesign cannot promise a particular electricity bill. Energy use still depends on the building, weather, tariffs, user settings and installation.

Benefits for manufacturers and importers

Common EU requirements support access to multiple national markets. A single technical compliance structure can serve many EU countries. Clear requirements can also guide product development and component selection.

Business benefits include:

• A common market-access framework
• More predictable product-development targets
• Reduced national regulatory fragmentation
• A documented basis for technical claims
• Improved tender readiness
• Lower risk of corrective action
• Stronger protection against unsupported competitor claims

Benefits for installers and planners

Ecodesign data supports product comparison and initial system design. Standard terms such as ηs, SCOP, rated output and LWA reduce ambiguity. The data also helps installers explain why purchase price alone is not a sufficient selection criterion.

The main operational benefit is a better starting point. The installer must then add building-specific calculations.

Benefits for the environment and energy system

The requirements encourage lower use-phase energy demand and more efficient product design. They also support the replacement of low-performing heating products. The wider ESPR framework can extend future requirements to additional life-cycle and resource-efficiency topics.

How to select a heat pump using Ecodesign information

Ecodesign compliance should be the first filter, not the final decision. A suitable product must meet the legal minimum and match the building.

Heat-pump selection criteria

Product-selection warning signs

Treat the following claims with caution:

• Only one COP value is shown.
• Performance is shown only at 35°C for a radiator project.
• Sound pressure is quoted without sound power or measurement conditions.
• Backup-heater consumption is omitted.
• The efficiency class conflicts with the technical data.
• A covered EU model cannot be identified in EPREL.
• “Eco-friendly” is used without a defined technical basis.
• A product is called a low-temperature heat pump only because it performs well at 35°C.
• An annual electricity-saving claim has no building, climate or tariff assumptions.

Ecodesign comparisons

Ecodesign versus the energy label

The two systems work together. Ecodesign removes products below the minimum. The energy label differentiates the products that remain.

ηs versus SCOP versus COP

COP can be technically correct but commercially misleading when used alone. SCOP provides more seasonal context. ηs converts the seasonal result into the regulatory framework used for market access and labelling.

Ecodesign versus CE marking

A heat pump does not receive CE marking because it has a high ηs value. CE marking indicates that the manufacturer declares conformity with all relevant EU legislation requiring the mark.

Ecodesign versus installed system performance

An Ecodesign-compliant product can perform poorly when oversized, incorrectly commissioned or connected to an unsuitable high-temperature system. A good installation can also help the same product operate much closer to its intended seasonal performance.

Ecodesign versus the F-gas Regulation

Ecodesign primarily addresses energy and specified product-performance parameters. The current F-gas Regulation, Regulation (EU) 2024/573, addresses fluorinated greenhouse gases, including containment, recovery, certification, placing products on the market and HFC controls. A heat pump may need to comply with both frameworks.

A natural refrigerant does not remove the need for Ecodesign compliance. Likewise, strong ηs performance does not remove refrigerant-safety or F-gas obligations.

Ecodesign Directive versus ESPR

For heat pumps, the active product-specific measure remains the practical starting point until it is formally replaced.

Regional application in Austria, Germany, Switzerland and the wider EU

Austria, Germany and EU Member States

Regulation 813/2013 is an EU regulation and is directly applicable in EU Member States. This includes Austria, Germany, Italy, Spain, Poland and Finland. German-speaking regions of Italy therefore use the EU product framework.

National requirements can still control:

• Building energy performance
• Heat-load calculations
• Electrical installation
• Refrigerant work
• Drilling and groundwater use
• Planning permission
• Acoustic protection
• Installer qualifications
• Subsidy eligibility

A product can comply with EU Ecodesign rules but still require additional national or local approvals.

Switzerland

Switzerland is not an EU Member State and uses its own Energy Efficiency Ordinance. The Swiss Federal Office of Energy states that minimum requirements apply to space and combination heaters up to 400 kW, while the energy label applies up to 70 kW. Swiss requirements are often aligned with EU methods, but Switzerland can introduce stricter provisions.

Manufacturers and importers should therefore maintain a separate Swiss market check. An EU label or declaration should not be treated as automatic proof of complete Swiss compliance.

Integration with other heat-pump systems

Heat emitters and flow temperature

Definition: Heat emitters transfer heating water energy into rooms through underfloor heating, radiators, wall heating or fan coils.

Purpose: Correct emitter sizing allows the heat pump to operate at the lowest practical flow temperature.

Benefit: A lower temperature lift usually supports higher seasonal efficiency.

Example: Enlarging selected radiators can reduce a renovation system’s required flow temperature from 55°C to 45°C.

Ecodesign provides 35°C and 55°C reference information. Detailed design should calculate the actual temperature required in each room.

Hydraulics and thermal storage

Definition: Heat-pump hydraulics control water flow between the heat generator, emitters and storage.

Purpose: The design maintains minimum flow, supports defrosting and separates circuits where necessary.

Benefit: Stable hydraulics reduce cycling and operating faults.

Example: A correctly sized buffer can provide hydraulic stability where many room zones close independently, although unnecessary storage volume can add heat loss.

A buffer tank is not automatically required in every system. The decision should follow the heat-pump manufacturer’s hydraulic requirements, emitter volume, control strategy and building load.

Weather-compensated and room control

Definition: Weather compensation adjusts heating-water temperature according to outdoor conditions.

Purpose: The control supplies only the temperature needed to maintain comfort.

Benefit: Lower average flow temperatures can reduce compressor work.

Example: The controller can reduce flow temperature during mild weather instead of operating continuously at the design-day setting.

Control quality also influences the regulated package calculation. Real benefits depend on commissioning, heating-curve settings and coordination with room controls.

Photovoltaics and energy management

Definition: PV integration coordinates heat-pump operation with locally generated electricity.

Purpose: The system shifts flexible heating, cooling or storage loads toward periods of solar generation.

Benefit: It can increase self-consumption and reduce purchased electricity.

Example: A controller can raise a hot-water or thermal-storage setpoint when excess PV generation is available.

PV integration does not change the product’s Ecodesign ηs value. It changes how and when the system purchases electricity.

iDM’s NAVIGATOR energy manager provides a system-level control layer for iDM heat pumps and supports interfaces with photovoltaic systems. This is an operational integration function, while Ecodesign remains the underlying product-compliance baseline.

Solar thermal systems

Definition: Solar thermal collectors transfer solar heat into domestic-hot-water or heating storage.

Purpose: They reduce the heat that must be generated by the main heater.

Benefit: Eligible solar thermal components can improve the regulated heater-package result.

Example: A combination heater, control and declared solar thermal system can receive a package label calculated from the component data.

Solar thermal and photovoltaic systems should not be treated as the same entity. Solar thermal enters the current heater-package calculation. PV does not.

Building-management systems and cascades

Definition: A building-management or cascade controller coordinates several generators and building loads.

Purpose: It selects the number and type of heat pumps needed at each operating condition.

Benefit: Units can operate closer to efficient part-load ranges while maintaining redundancy.

Example: A commercial building can run one heat pump during mild weather and add further units as space-heating or hot-water demand increases.

The controller does not alter the compliance status of each product. It determines how the compliant products operate together.

Refrigerant systems

Definition: The refrigerant circuit transfers heat through evaporation, compression, condensation and expansion.

Purpose: Refrigerant selection and circuit design provide the required temperature range safely and efficiently.

Benefit: A suitable refrigerant can support performance, serviceability and long-term regulatory compatibility.

Example: A product using a natural refrigerant still needs appropriate charge control, safety design, installation instructions and qualified handling.

Ecodesign efficiency, refrigerant law and safety standards must be assessed together. None replaces the others.

Building energy regulation

Definition: Building energy rules control the energy performance of the building or technical system rather than only the factory-made product.

Purpose: They connect product performance with insulation, controls, renewable energy and system design.

Benefit: The building is evaluated as an operating whole.

Example: A national building rule may require a renewable-heating share even though the selected heat pump already meets Ecodesign requirements.

This creates a clear hierarchy:

1. Ecodesign: Can the product enter the market?
2. Energy label: How does the product compare with similar products?
3. Building regulation: Can the proposed system satisfy the building requirements?
4. Installation standards: Can the system be installed safely and correctly?
5. Commissioning: Does the actual system operate as designed?

Ecodesign provides the legal and technical starting point. It confirms that a product meets the applicable minimum product requirements. It does not determine whether the product is correctly sized, correctly positioned or correctly controlled in a particular building.

A complete heat-pump assessment should connect:

• Building heat load
• Environmental heat source
• Required flow temperature
• Space-heating and hot-water demand
• Seasonal efficiency
• Acoustic conditions
• Hydraulic design
• Storage strategy
• Control and zoning
• PV integration
• Refrigerant requirements
• Commissioning and service

iDM Energiesysteme develops heat-pump systems that use environmental energy from air, ground and water. Its portfolio also includes system controls and energy-management functions through NAVIGATOR. This allows product-level performance data to be connected with the operational requirements of the complete heating system.

The correct positioning is therefore clear:

Ecodesign establishes the compliance baseline. System planning converts that baseline into efficient, quiet and reliable building operation.

Frequently asked questions

Is the Ecodesign Directive still in force?

Directive 2009/125/EC was repealed in 2024 by Regulation (EU) 2024/1781. However, the term “Ecodesign Directive” remains widely used. Existing product-specific measures remain relevant during the transition, and Regulation 813/2013 is still listed as the measure in application for space and combination heaters.

Does the Ecodesign Directive apply to every heat pump?

No. Regulation 813/2013 covers defined space and combination heaters supplying water-based central heating and having a rated heat output up to 400 kW. Dedicated water heaters, air-to-air heat pumps and other product categories use different rules.

Does every Ecodesign-compliant heat pump need an energy label?

No. The Ecodesign scope for current space and combination heaters reaches 400 kW, while the corresponding energy-label scope reaches 70 kW. Products can therefore fall within Ecodesign requirements without falling within the heater energy-label scope.

Can heat-pump seasonal efficiency exceed 100%?

Yes. ηs is a regulatory metric derived from seasonal performance, primary-energy treatment and required corrections. A heat pump also transfers environmental heat rather than converting only its electrical input into heat. An ηs above 100% does not violate energy conservation.

Is ηs the same as SCOP?

No. SCOP compares seasonal useful heat with seasonal electricity input under a defined method. ηs uses SCOP as part of a regulatory calculation and applies the conversion coefficient and specified corrections.

Is a 35°C energy class suitable for comparing radiator systems?

Only when 35°C represents the planned radiator operating condition. Many existing radiator systems require a higher design flow temperature. In those cases, 55°C data or detailed performance tables provide a more relevant comparison.

Does Ecodesign regulate the refrigerant?

The current heater Ecodesign rules focus mainly on energy performance, product information and heat-pump sound. Refrigerant containment, placing-on-market controls and related obligations are addressed separately, including through Regulation (EU) 2024/573.

Does Ecodesign compliance guarantee low operating costs?

No. It confirms that the product meets the applicable minimum requirements under standard conditions. Operating costs depend on building heat demand, flow temperature, climate, electricity tariff, control settings, domestic-hot-water use and installation quality.

Does Ecodesign apply directly in Switzerland?

No. Switzerland has its own Energy Efficiency Ordinance. Swiss requirements use many concepts familiar from EU rules, but they must be checked separately and can be stricter.

Who is responsible for Ecodesign compliance?

The manufacturer is normally responsible for conformity assessment, technical documentation, the Declaration of Conformity and CE marking. Importers and companies selling products under their own name can also have substantial responsibilities. Dealers and installers have separate duties relating to labels, product information and packages.