On 25 June 2025, the European Commission presented further developments of the proposal for the revision of the Ecodesign Regulation for solid fuel-fired local heating appliances, including the arguments for the emission limit values.

The Association for Ecological Wood Heating (AEVD) appreciates that the Commission has decided to discuss the proposal in an open consultation forum with the participation of representatives of the expert community and industry, and that it acknowledges the need to discuss the feasibility of some of the requirements, in particular the testing methods. However, we believe that many of the proposals require further consultation, particularly in view of their potential (in our view significant) impact on affordability and the actual environmental impact of indoor heating as a whole.

It is not possible to combine emissions from burning wood and coal

The AEVD points out that wood and wood briquette heaters should not be confused or combined with coal heaters in the assessment of emissions. The emission characteristics of coal and wood heaters are fundamentally different! The CO emissions of coal-fired heaters are three to five times higher than those of modern wood heaters. Dust particle production is also higher for coal combustion than for wood biomass combustion. Therefore, if the aim of regulation is to make a real improvement in air quality, the European Commission should primarily focus on the coal combustion sector, where the effect can be multiplied.
Pareto's rule applies here - a small number of measures can bring the majority of the result. It is also important to recall that wood is considered a renewable resource in European legislation.

Technical rules should correspond to real traffic

One of the most discussed proposals is the introduction of new test modes - e.g. testing at partial power or at higher than rated load (overload). The AEVD understands the Commission's desire to bring testing closer to normal use. However, care must be taken to ensure that the resulting requirements remain technically feasible in the context of heater affordability. Especially for consumers in regions where wood heaters play a crucial role in providing thermal comfort, the proposed changes and the resulting escalation in heater prices would undoubtedly lead to end users not changing their appliances.

Fair rules and rigorous market controls are essential

At the same time, the AEVD points out that fair competition in the European market is only possible if the rules are equal for all and are effectively enforced. According to the European Commission, only a fraction of the heaters placed on the market in Eastern European markets are registered in the EPREL database. Therefore, the AEVD considers it crucial that national control authorities rigorously monitor compliance with these obligations, especially for imports from non-EU countries.

The existing measurement methodology is sufficient

The proposed change to the emissions measurement methodology appears to be redundant. Stoves can continue to be tested according to the well-established EN 16510 standard, which is already proven to reflect the ability of the plant to achieve stringent and still acceptable emission limits. Even a better stove will not achieve the desired result without good quality fuel and an educated operator, so we recommend that the focus should be on educating the users operating these appliances. An informed consumer means lower emissions in practice.

Priority should be given to replacing old equipment

Tightening the limits for newly manufactured indoor heaters should not be a priority. The AEVD stresses that substantial progress can be made more quickly and cheaply by replacing old heaters - even wood heaters that have been in use for more than 15 or 20 years and do not meet the current limits. Encouraging their replacement, for example through subsidy programmes, will have a greater and quicker benefit for air quality than any future regulations for newly marketed products. Their eventual development would require substantial investment and would certainly reduce the portfolio. The result would be a major price jump and an associated extreme drop in sales of new heaters.

Maintaining energy self-sufficiency is key

The proposal to introduce mandatory electronic regulation of combustion raises concerns about the energy independence of households. For many households, especially in less urbanised areas, the possibility of operating stoves without being connected to the electricity grid - for example in the event of power cuts - is an advantage.

Today, home wood heaters serve not only as a main or supplementary source of heating, but also as an important safety net in crisis situations. It is important that future rules preserve this role.

Conclusion: we seek a balance between ambition and reality

The AEVD is ready to work with the European Commission, technical committees and other partners to develop rules that will lead to real improvements in air quality while taking into account the economic and social impacts in each Member State.

We all want cleaner air. But the path to it must be environmentally friendly, technically feasible and acceptable to society.