POSITION PAPER – Review of ENER Lot 38 (BACS) after the Consultation Forum of 15 November 2021

15 / 12 / 2021

15/12/2021 – The European Commission is assessing the possibility of introducing ecodesign requirements for building automation and control systems (BACS). The full ENER Lot 38 study on introducing such legislation for BACS was presented and discussed at a Consultation Forum on 15 November 2021.


EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, supports the EU ecodesign and energy labelling policies, and agrees with the need to keep the legislation up-to-date and in line with the latest technological developments. Ecodesign is a tool that has delivered considerable energy efficiency savings across Europe. Nonetheless, we have strong concerns regarding the policy options that have been proposed for regulating BACS.


This paper provides EPEE’s position following the Consultation Forum of 15 November 2021. In the first part, we highlight general concerns on the study’s proposals. In the second part, we elaborate our views on the ecodesign policy options for BACS. The third part continues with our comments to the energy labelling proposals.

CHAPTER I: GENERAL

  1. Avoid double regulation of products.
  2. Adopt vertical approach for vertical systems.
  3. Ensure a scope that is supported by the BACS standards.
  4. Ensure a technology neutral approach.

CHAPTER II: ECODESIGN

  1. Clarify definition for BACS and take product-specific concerns into account.
  2. Clarify the unclear policy options for material and resource efficiency.
  3. Avoid regulating sensor accuracy in ecodesign.
  4. Avoid regulating internal power consumption of BACS incorporated in technical building systems.

CHAPTER III: ENERGY LABELLING – CURRENTLY INAPPROPRIATE FOR BACS