Opinion of the Regulatory Scrutiny Board
Date: 2024-04-18
Institutions: European Commission, Regulatory Scrutiny Board
Subjects: ecodesign, energy consumption, energy efficiency, energy saving, heating, market approval, reduction of gas emissions, technical specification

EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
RSB 

Opinion 

Title: Impact assessment / Ecodesign requirements for local space heaters 

Overall opinion: POSITIVE 

(A) Policy context 

Ecodesign  provides  rules  at  the  product  design  stage  to  improve  the  environmental 
performance of products placed on the EU market. Existing ecodesign measures must be 
reviewed  regularly  to  ensure  they  remain  relevant,  efficient,  and  effective  in  the  light  of 
technological and market developments.  

The product specific legislation for local space heaters  aims to ensure the placing on the 
market  of  technologies  that  reduce  the  life-cycle  environmental  impact  of  local  space 
heaters.  The  eco-design  working  plan  2022-2023  sets  out  the  revision  of  measures  for 
specific  product  groups,  including  local  space  heaters.  Accordingly,  this  report  assesses 
possible ways to update ecodesign requirements for local space heaters.   

(B) Summary of findings 

The Board notes the additional information provided in advance of the meeting and 
commitments to make changes to the report. 

The Board gives a positive opinion. The Board also considers that the report should 
further improve with respect to the following aspects: 

(1)  The  specific  objectives  are  too  prescriptive,  pre-judging  the  solutions  to  the 
problems.  The  report  does  not  consider  possible  trade-offs  between  the 
objectives. 

(2)  The report does not allow for the clear identification  of impacts for each policy 
option, measure and stakeholder group affected. It does not present costs related 
to the one in, one out approach. 

(C) What to improve 

(1)  The  specific  objectives  should  be  framed  in  a  sufficiently  broad  way  so  as  not  to 
prejudge  the  policy  solutions  to  the  problems.  The  objectives  should  allow  for  proper 
consideration of alternative policy options. The report should identify potential trade-offs 

  ________________________________   

This opinion concerns a draft impact assessment which may differ from the final version. 

Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: regulatory-scrutiny-board@ec.europa.eu 

 
 
 
 
 
 
and conflicts between the objectives. Such trade-offs should be part of the analysis in the 
comparison of policy options.  

(2)  The  report  should  improve  the  presentation  of  the  impacts  so  that  it  is  structured  in 
such a way that allows clear identification of impacts for each policy option, measure and 
stakeholder  group  affected,  including  industry,  SMEs  and  consumers.  In  particular,  it  
should  further  explain  and  justify  the  increased  industry  turnover  and  how  this  increase 
was  calculated.  It  should  explain  whether  the  turnover  increase  takes  into  account  the 
increased compliance costs as a result of the initiative. The report should be clear about the 
net  impact  on  industry  stakeholders  and  on  consumers;  for  the  latter  by  clarifying  the 
expected  level  of  cost  pass-through.  The  analysis  of  impacts  on  SMEs  should  be 
strengthened. The report should present the available evidence base, the SMEs feedback in 
the stakeholders’ views and the outcome of the SME test. Costs related to the one in, one 
out approach should be calculated and clearly presented in the report.  

(3)  As  the  report  is  going  to  include  a  new  specific  objective  on  burden  reduction,  it 
should set out a full intervention logic related to this area. The potential for simplification 
and burden reduction for businesses and authorities should be further analysed, also to be 
reflected in the problem analysis and options. 

(4)  The report should improve the presentation of the discarded options. It should further 
explain the reasons these were not deemed as comprehensive and high performing as the 
preferred option, and, consequently, rejected.  

The Board notes the estimated costs and benefits of the preferred option in this initiative, 
as summarised in the attached quantification tables. 

Some more technical comments have been sent directly to the author DG. 

(D) Conclusion 

The  DG  must  take  these  recommendations  into  account  before  launching  the 
interservice consultation. 

If  there  are  any  changes  in  the  choice  or  design  of  the  preferred  option  in  the  final 
version of the report, the DG may need to further adjust the attached quantification 
tables to reflect this. 

Full title 

Ecodesign requirements for local space heaters 

Reference number 

PLAN/2019/5387 

Submitted to RSB on 

13 April 2022 

Date of RSB meeting 

11 May 2022 

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ANNEX – Quantification tables extracted from the draft impact assessment report 

The  following  tables  contain  information  on  the  costs  and  benefits  of  the  initiative  on 
which the Board has given its opinion, as presented above.  

If the draft report has been revised in line with the Board’s recommendations, the content 
of  these  tables  may be  different  from  those  in  the  final  version  of  the  impact  assessment 
report, as published by the Commission. 

I. Overview of Benefits (total for all provisions) – Preferred Option 

Description 

Amount 

Direct benefits 

Energy efficiency savings 

1,97 Mtoe by 2030 and 20,78 Mtoe by 2050 

GHG emissions savings 

1,76 Mt CO2eq by 2030 and 10,97 Mt CO2eq by 
2050 

Additional business turnover  408,5 million € extra by 2030 and 173,92 million € 

extra by 2050 

Decreased consumer 
expenditure 

748,41 million € less by 2030 and 18.323,19 million 
€ less by 2050 

Increased employment 

1.551 jobs extra by 2030 and 292 by 2050 

Comments 

II. Overview of costs – Preferred option 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent  One-off 

Recurrent 

One-off  Recurrent 

Costs of 
complying 
with the 
clarification 
and 
extension of 
the scope 

Direct adjustment 
costs 

Direct administrative 
costs 

Direct regulatory 
fees and charges 

Direct enforcement 
costs 

Indirect costs 

133 mio. €/year 
or 10,3 € per 
unit 

1.269.760 € 

Electronically signed on 13/05/2022 11:31 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

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