Ecodesign and Labelling – Review of ENER Lots 1 & 2
26 January 2026
MARCOGAZ has published its response to the consultation on the revision of the Ecodesign and Energy Labelling Regulations for space and water heaters under ENER Lots 1 and 2.
In this response, MARCOGAZ provides a technical review of the proposed updates, focusing on efficiency thresholds, calculation and measurement methods, labelling provisions and their combined impact on different heating technologies. The analysis highlights the importance of technically sound, proportionate and technology neutral requirements that are aligned with harmonised standards and validated methodologies.
The response also draws attention to potential risks arising from the cumulative effect of the proposed requirements, including market exclusion of certain technologies, challenges for hybrid systems and renewable gas ready appliances, and unintended impacts on affordability and energy security. MARCOGAZ recommends that Ecodesign and labelling rules should be based on robust impact assessments and transparent methodologies to preserve consumer choice and support an effective energy transition.
