CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT
Title of the initiative	Ecodesign - glandless standalone circulators and glandless product-integrated circulators (review of the requirements)
Lead DG (responsible unit)	DG ENER – B3 – Buildings and Products
Likely Type of initiative	Commission implementing regulation (Ecodesign)
Indicative Planning	Adoption expected by 3rd quarter 2026
Additional Information	https://energy-efficient-products.ec.europa.eu/product-list/circulators_en
The inception impact assessment is provided for information purposes only. It does not prejudge the final decision of the Commission on whether this initiative will be pursued or on its final content. All elements of the initiative described by the inception impact assessment, including its timing, are subject to change.

A. Political context, problem definition and subsidiarity check

Political context

Ecodesign contributes to deliver on the Clean Industrial Deal 1 and Affordable Energy Action Plan 2 . Ecodesign has long supported a circular economy and strengthened the EU single market for energy-related products. Its implementation has significantly reduced consumer energy bills, enhanced the EU’s energy security by lowering primary energy consumption and decreasing reliance on imports It has also helped reduce greenhouse gas emissions, mitigating climate change cost-effectively thanks to the avoided energy costs outweighing the investments needed.

Existing measures have to be reviewed regularly to ensure they remain relevant, efficient and effective in the light of technological and market developments, and of simplification. The Commission’s latest Ecodesign Working Plan 3 includes a review of the existing ecodesign measure for glandless circulators (Regulation (EU) No 641/2009). As a general consideration, the working plan also underlines that ecodesign and energy labelling should contribute more to the circular economy, for example by more systematically tackling material efficiency issues such as durability, reparability and recyclability.

Evaluation

As part of the review of the current ecodesign measure for circulators, the evaluation will assess how successful it has been in achieving or progressing towards its objectives. The focus will be on three evaluation criteria as envisaged by the ‘Better Regulation’ guidelines, i.e. whether the measures have been effective, efficient and relevant. The relationship between the resources used and the impacts of the Regulation will also be investigated, looking at both the cost and benefits for different stakeholders. Subsidiarity and EU added value will not be looked at in detail: since the measures being evaluated are secondary legislation, these aspects are considered to have been addressed when the main act was prepared.

The scope of the evaluation will be EU-wide and will run from the Regulation’s entry into force to the current state of play.

Problem the initiative aims to tackle

In 2009 the EU adopted an ecodesign measure on circulators, which set stringent energy efficiency requirements for circulators placed on the EU market. This has resulted in a market transformation that enabled significant energy savings: in 2020, new circulators consumed about 50% less energy than their inefficient predecessors, generating annual electricity savings of about 23 TWh, corresponding to 11 Mt CO2-eq per year. A review study was initiated in 2016, which identified scope for further strengthening the energy efficiency requirements (i.e. reducing limit value of the circulator’s energy efficiency index - EEI) with modest potential additional savings of about 3 TWh/y by 2030 in the best case, and financial savings for end users corresponding to 0% to 5% of the product’s life cycle cost 4 . The results of the study were presented at the Ecodesign and Energy Labelling Consultation Forum in June 2019. Several stakeholders considered that, despite the relatively modest estimated additional savings, this potential should not be neglected. On the other hand, industry stakeholders raised concerns, e.g. on the impact on circulators integrated into products, which in some cases may lead to redesigning products (heating appliances). Some consultation forum members also stressed the need to reduce possible circumvention to the rules, such as the loophole associated with a possible exemption for circulators supplied as spare parts. The need to improve information requirements was also stressed, in order to provide more transparency on parameters that influence circulators’ energy efficiency, such as head, flow, hydraulic power and electric power at full and part load.

The Impact Assessment was initiated following the Consultation Forum to further analyse these options. However, progress slowed in 2019 due to other competing priorities (and was further delayed by the COVID-19 pandemic). Despite these challenges, a continuous dialogue with stakeholders was maintained throughout the process. Additional considerations were also integrated in the draft Impact Assessment based on input from industry and Member State representatives, including:

-Setting circular economy requirements, beyond the limited measure proposed in the review study (i.e. availability of spare parts or information requirements to facilitate recovery of critical raw materials, e.g. rare earth elements in permanent magnet motors).

-Extending the scope to drinking water circulators (used for domestic/sanitary hot water, and which represent about 10% of the sales market for circulators), with dedicated energy efficiency requirements.

Basis for EU intervention (legal basis and subsidiarity check)

Legal basis

The Ecodesign Directive (Directive 2009/125/EC) is based on Article 114 of the Treaty on the Functioning of the European Union, the legal basis for measures on the functioning of the single market. Under the Ecodesign Directive, the European Parliament and the Council gave the Commission a legislative mandate to regulate the environmental performance of energy-related products and in particular their energy efficiency.

Practical need for EU action

The EU legislation for these products requires the Commission to review the legislation in light of technological progress. Action to update these rules can only be taken at EU level. There may be aspects not covered by the current legislation for which Member States might wish to take action. If the EU did not take action in these areas, Member States could set their own rules for non-regulated aspects and products, which would inevitably vary due to the complexity of the technical aspects. This would disrupt the functioning of the single market.

B. Objectives and policy options

The main objective is to contribute more to energy efficiency and CO2 emissions abatement, as well as to achieve a high level of environmental and consumer protection in a cost-effective way.

More specifically, the impact assessment will look at the relevance and feasibility of the following options:

·stricter requirements for circulators in the current scope of the Regulation in order to induce additional energy and financial savings for end users (e.g. EEI ≤ 2,0s);

·expanding the scope by establishing ecodesign requirements for drinking water circulators (e.g. EEI(DW) ≤ 1,10);

·expanding information requirements (including head, flow, hydraulic power and electric power at full and part load);

·additional measures to contribute to circular economy objectives including through the inclusion of requirements on spare parts availability;

·reducing loopholes, such as the loophole associated with a possible temporary exemption for spare part circulators (e.g. through a better definition of the latter, and by setting an appropriate duration).

C. Likely impacts

If more stringent ecodesign requirements are put in place, they may lead to increased product costs, higher prices and increased turnover for manufacturers, wholesalers and retailers. These changes in economic activity are likely to lead to comparable changes in employment.

The main environmental impacts for this product arise from use-phase energy consumption. Lower energy use will lower associated environmental impacts, consumer costs and energy supply industry turnover. Energy efficiency requirements will aim to achieve the lowest lifecycle consumer cost level, so cost savings will tend to offset the product price rises.

Other environmental requirements could increase upfront costs. Economic impacts of requirements affecting product life will depend on consumers choosing to prolong product life, for example by repair, and the cost of doing so. Extended lifetimes will lead to lower product sales and turnover.

Competitiveness for manufacturers in the same market segment and at the same price point is not expected to be affected. This is because the requirements will apply to all equivalent products. Impacts could occur if there is a specialisation in a specific product segment or at a specific price point. Turnover changes are not expected to alter businesses’ profitability.

D. Better regulation instruments

Impact assessment and evaluation

An evaluation and impact assessment will be carried out back to back for this initiative, and will feed into the Commission’s decision. These will build on an extensive review study already carried out. The Regulatory Scrutiny Board is expected to review the evaluation and impact assessment in the third quarter of 2025.

Consultation strategy

The Consultation aims to inform the public and stakeholders and to ask for feedback on the intended initiative.

The review study extensively consulted stakeholders and experts (national authorities, consumer groups, manufacturers, standardisation organisations and environmental NGOs).

The review study was presented and discussed with the Ecodesign and Energy Labelling Consultation Forum in June 2019, with participation from Member States, industry associations and representatives of civil society. All relevant documents, including minutes, presentations and stakeholder inputs to meetings, have been made available online, along with the final report.

Why we are consulting?

To give stakeholders an opportunity to:

·comment on their experience of implementing the current rules for glandless circulators,

·provide their views or concrete suggestions on the main options identified for the impact assessment; and

·provide further input on any market or technological developments since the previous analysis.

Target audience

Experts and representatives of any relevant interested parties, including (but not limited to) manufacturers, consumer or environmental organisations, retail or repair businesses, national authorities and private individuals.