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Heat Pumps Under ESPR
Heat pumps are a central technology in the EU's decarbonisation strategy and are a priority product category under the Ecodesign for Sustainable Products Regulation (EU 2024/1781). The EU aims to install 60 million heat pumps by 2030. ESPR will set requirements for heat pump energy efficiency, refrigerant disclosure, recycled content, and Digital Product Passports to support this ambition while ensuring sustainability throughout the product lifecycle.
Truth Anchor: Heat pumps are currently regulated under Commission Regulation (EU) 2016/2281 (space heaters and combination heaters). ESPR Article 4 empowers the Commission to adopt new delegated acts that will update and strengthen these requirements. Source: EUR-Lex CELEX:32024R1781
Current Regulatory Framework for Heat Pumps
Heat pumps are currently regulated under Commission Regulation (EU) 2016/2281, which sets minimum seasonal energy performance requirements for space heaters, including air-to-water, ground-to-water, and air-to-air heat pumps. The regulation requires manufacturers to provide product information sheets and technical documentation. The EU Energy Labelling Regulation requires energy efficiency labelling for heat pumps on a scale from A+++ to D.
Heat pumps are also subject to the F-Gas Regulation (EU 2014/517), which restricts the use of high-global-warming-potential (GWP) refrigerants. The F-Gas Regulation is being updated (Regulation EU 2024/573) to phase down the use of hydrofluorocarbons (HFCs) and will significantly affect heat pump refrigerant choices. ESPR will complement the F-Gas Regulation by requiring refrigerant data in the DPP.
Expected ESPR Requirements for Heat Pumps
Energy efficiency: The ESPR delegated act will update the minimum seasonal coefficient of performance (SCOP) requirements for heat pumps. The current requirements under EU 2016/2281 will be strengthened to reflect improvements in heat pump technology. The DPP must include energy efficiency data including SCOP, seasonal energy performance ratio (SEPR) for cooling, and sound power levels.
Refrigerant disclosure: The DPP must disclose the refrigerant type, GWP value, and charge quantity. This data is required for F-Gas Regulation compliance and for end-of-life refrigerant recovery. As the F-Gas Regulation phases down high-GWP refrigerants, manufacturers will need to transition to low-GWP alternatives (R-290, R-32, R-454B). The DPP will enable market surveillance authorities to verify refrigerant compliance.
Spare parts and repairability: Heat pumps are complex systems with multiple serviceable components — compressors, heat exchangers, expansion valves, control boards, fans. The ESPR delegated act is expected to require spare parts availability for a minimum of ten years after the last unit of a model is placed on the EU market. Service manuals must be provided to certified technicians.
Recycled content: Heat pumps contain significant quantities of copper (heat exchangers), steel (casings), and aluminium (heat exchangers, fans). The delegated act is expected to set minimum recycled content requirements for these materials.
Digital Product Passport for Heat Pumps
| Data Category | Required Data Fields | Regulatory Basis |
|---|---|---|
| Energy performance | SCOP (heating), SEPR (cooling), energy efficiency class, rated heating/cooling capacity (kW) | EU 2016/2281 + ESPR |
| Refrigerant | Refrigerant type, GWP value, charge quantity (kg), refrigerant circuit type | F-Gas Regulation + ESPR |
| Sound | Sound power level (dB(A)) indoor and outdoor, sound pressure level at 1m | EU 2016/2281 + ESPR |
| Spare parts | Spare parts list, availability period, service manual access, certified technician requirements | ESPR Annex III |
| Recycled content | Recycled copper %, recycled steel %, recycled aluminium %, total weight | ESPR Annex III |
| Substances of concern | Refrigerant hazard data, lubricant oil type, other substances of concern | REACH + ESPR Annex III |
| Installation | Minimum installation requirements, compatible systems, commissioning data | ESPR Annex III |
| End-of-life | Refrigerant recovery requirements, component disassembly instructions, material recovery | F-Gas + WEEE + ESPR |
F-Gas Regulation Interaction
The F-Gas Regulation phase-down will require heat pump manufacturers to transition from high-GWP refrigerants (R-410A, GWP 2088) to low-GWP alternatives by the late 2020s. The most common low-GWP alternatives for heat pumps are R-290 (propane, GWP 3), R-32 (GWP 675), and R-454B (GWP 466). R-290 has the lowest GWP but is flammable (A3 safety classification), requiring additional safety measures in installation and service. The DPP must disclose the refrigerant type and GWP value, enabling market surveillance authorities to verify F-Gas compliance and enabling service technicians to use appropriate safety procedures.
What Heat Pump Manufacturers Must Do Now
Heat pump manufacturers should prioritise refrigerant transition planning alongside ESPR preparation. The F-Gas Regulation phase-down and ESPR's refrigerant disclosure requirements together create a strong incentive to transition to low-GWP refrigerants before the compliance deadlines. Manufacturers should also begin collecting recycled content data from copper, steel, and aluminium suppliers, and review spare parts supply chain commitments to ensure ten-year availability can be guaranteed.
Heat Pump Categories Covered by ESPR
Heat pumps are already subject to EU Ecodesign and Energy Labelling requirements under the Lot 1 regulation (EU 813/2013 for space heaters and EU 814/2013 for water heaters). The ESPR delegated act for heat pumps will extend these requirements to include Digital Product Passport obligations and enhanced lifecycle data requirements. The categories covered include air-to-water heat pumps (the dominant technology in new EU residential construction), ground-source heat pumps (geothermal), air-to-air heat pumps (reversible air conditioning systems), water-to-water heat pumps, and hybrid heat pump systems that combine a heat pump with a gas or oil boiler. Each category has different performance metrics, refrigerant types, and installation requirements that will be reflected in the DPP data structure.
Refrigerant Disclosure and F-Gas Compliance
Heat pumps use refrigerants to transfer heat. The EU F-Gas Regulation (EU 2024/573) is progressively phasing down the use of high-GWP (Global Warming Potential) refrigerants, including R-410A (GWP 2088) and R-32 (GWP 675). The ESPR heat pump DPP will require manufacturers to declare the refrigerant type, GWP value, and charge quantity in kilograms. This data is essential for F-Gas compliance — technicians servicing heat pumps must be certified under the F-Gas Regulation, and refrigerant recovery is mandatory at end of life. Manufacturers transitioning to low-GWP refrigerants such as R-290 (propane, GWP 3), R-32, or R-454B should document this transition in their DPP data as a positive environmental attribute.
Seasonal Performance and ESPR Heat Pump Data
The key performance metric for heat pumps is the Seasonal Coefficient of Performance (SCOP) for heating and the Seasonal Energy Efficiency Ratio (SEER) for cooling. These values are determined through testing to EN 14825 under the climate conditions specified in EU 813/2013. The ESPR heat pump DPP will require manufacturers to declare SCOP and SEER values at the specified test conditions, the rated heating capacity in kW, the sound power level in dB(A), and the Energy Efficiency Class under the EU Energy Label. Manufacturers should ensure that the performance values declared in the DPP are consistent with the values on the Energy Label and in the product fiche — any discrepancy will constitute non-compliance under both ESPR and the Energy Labelling Regulation (EU 2017/1369).
| Heat Pump Type | Typical SCOP (A7/W35) | Common Refrigerant | ESPR DPP Expected |
|---|---|---|---|
| Air-to-water (monobloc) | 3.5–5.0 | R-290, R-32, R-454B | 2026–2027 |
| Air-to-water (split) | 3.8–5.5 | R-32, R-454B | 2026–2027 |
| Ground-source (brine-to-water) | 4.5–6.5 | R-290, R-407C | 2026–2027 |
| Air-to-air (reversible) | 3.5–5.0 (SEER 5.0–8.0) | R-32, R-410A (phasing out) | 2026–2027 |
| Hybrid heat pump | Combined system — varies | As per heat pump component | 2027–2028 |
Frequently Asked Questions
The ESPR delegated act for heat pumps is expected in 2026–2027, with mandatory compliance likely from 2028–2029. The F-Gas Regulation phase-down creates additional urgency for refrigerant transition planning.
The DPP must disclose the refrigerant type (e.g., R-410A, R-32, R-290), GWP value, and charge quantity in kilograms. This data is required for F-Gas Regulation compliance and end-of-life refrigerant recovery.
ESPR's refrigerant disclosure requirements complement the F-Gas Regulation phase-down. Together, they create strong incentives to transition to low-GWP refrigerants (R-290, R-32, R-454B) before the compliance deadlines.
The delegated act is expected to require spare parts availability for a minimum of ten years after the last unit of a model is placed on the EU market.
Yes. Any heat pump placed on the EU market must comply with ESPR. Non-EU manufacturers must appoint an EU-based Authorised Representative who is legally responsible for ESPR compliance.
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Current Ecodesign Requirements for Heat Pumps
Heat pumps are currently subject to ecodesign requirements under EU Regulation 813/2013 (space heaters and combination heaters) and energy labelling requirements under EU Regulation 811/2013. These regulations set minimum seasonal space heating energy efficiency requirements (expressed as the Seasonal Coefficient of Performance, or SCOP) and require manufacturers to provide product information including the rated heat output, SCOP, and sound power level. The ESPR delegated act for heat pumps will build on these requirements and add DPP data disclosure, refrigerant information, and recyclability requirements.
Heat pumps contain refrigerants — substances that can have a significant global warming potential (GWP) if released into the atmosphere. The most common refrigerants in heat pumps are R-410A (GWP = 2,088), R-32 (GWP = 675), and R-290 (propane, GWP = 3). The EU's F-Gas Regulation is phasing down the use of high-GWP refrigerants, and the heat pump industry is transitioning to lower-GWP alternatives. The ESPR DPP for heat pumps is expected to include information on the type and quantity of refrigerant used, its GWP, and instructions for safe handling at end-of-life.
Frequently Asked Questions
The ESPR delegated act for heat pumps is expected to be adopted in 2025–2026, superseding EU Regulation 813/2013. Manufacturers should plan for compliance by 2027–2028. The existing regulation remains in force until the ESPR delegated act takes effect.
Yes. The ESPR delegated act for heat pumps is expected to cover all types of heat pumps, including air-to-air, air-to-water, water-to-water, and ground-to-water heat pumps. The specific requirements may differ between heat pump types to reflect differences in performance characteristics and installation requirements.
The F-Gas Regulation restricts the use of high-GWP refrigerants in heat pumps. ESPR complements the F-Gas Regulation by requiring disclosure of refrigerant information in the DPP. Manufacturers must comply with both regulations independently. The ESPR DPP will make refrigerant information accessible to service technicians and end-of-life treatment facilities.
The delegated act is expected to require manufacturers to make available spare parts for heat pumps for a minimum period after last sale. Key parts include: compressors, expansion valves, heat exchangers, circulation pumps, electronic control boards, and refrigerant circuit components. The DPP must disclose spare parts availability and pricing.
The EU aims to deploy 60 million heat pumps by 2030 as part of the REPowerEU plan. ESPR will ensure that these heat pumps are manufactured sustainably and can be serviced and recycled efficiently. Manufacturers who can demonstrate compliance with ESPR requirements will be better positioned to supply the rapidly growing EU heat pump market.