On 14 October 2025, Solar Heat Europe (SHE) hosted a dedicated workshop with its members to discuss the future of solar thermal technologies within the EU Energy Labelling (EL) and Ecodesign (ED) framework. This topic is highly sensitive, as the upcoming revision of the regulations for space and water heaters (Lot 1 & Lot 2) could significantly impact the visibility and market positioning of solar thermal solutions.
Changing framework
The European Commission has announced that the revised regulation will remove the installer-issued package label, a mechanism that previously allowed solar thermal systems to be included in energy labelling when combined with other heating products. This shift raises concerns about reduced visibility for solar thermal and potential exclusion from support schemes that rely on energy efficiency classes.
Workshop Highlights
The workshop covered the evolution of the Regulation and SHE’s proposals for improved methodologies.It also included a reflection on pros and cons of Energy Labelling for Solar Thermal, including links to the Construction Products Regulation (CPR) and Energy Performance of Buildings Directive (EPBD). In addition, there is the presentation of survey feedback and discussion on next steps.
SHE reiterated its proposal for a simplified calculation method (TSM) for solar thermal systems, which was previously accepted in draft versions of the regulation. The concept of a dedicated solar thermal label was also introduced, aiming to better reflect the technology’s contribution to renewable energy and consumer benefits.
Survey Insights: What Members Think
Ahead of the workshop, SHE conducted a consultation survey to capture members’ views. Key findings include feedback on the solar thermal representation in the current framework, potential benefits of remaining in scope, the main concerns from embers and potential positions in terms of advocacy.
Most respondents believe solar thermal is not well represented under the existing labelling rules, citing methodology limitations that underestimate performance. Furthermore, members highlighted visibility and comparability, access to subsidies, and market competitiveness as major advantages. Energy labelling is seen as essential for eligibility in national support schemes (e.g., France’s MaPrimeRéno).
On the other hand, some of the main concerns included the administrative burden (documentation, EPREL registration), the high compliance costs (testing, certification) and the risk of misrepresentation due to calculation methods.
Some fear that without an energy label, solar thermal could lose relevance in building projects and subsidy programs.
Still, a clear majority supports SHE advocating for solar thermal to remain within the scope of EL/ED, provided the framework is simplified and fair. In this regard, some of the suggestions put forward include: Streamlined procedures to reduce administrative load; Clearer methodologies that reflect solar thermal’s renewable nature; Better communication and training for installers and manufacturers, a label covering solar thermal collectors.
Next Steps
SHE will use these insights to shape its position in the ongoing regulatory discussions with the European Commission and in the consultations about Space and Water Heaters regulation.