The scope of the study is such that all types of furnaces and ovens are covered – even large custom designed industrial installations. The final draft report was published on 1 March 2012 and the final stakeholder meeting was organised on 26 March.
In a letter to Commissioner Tajani, industries using such furnaces state that they believe custom designed industrial furnaces and kilns are not eligible under the criteria given in the Eco-Design Directive and that installations covering activities regulated by the EU Emissions Trading Scheme and the Industrial Emissions Directive should by definition not be subject to the Eco-Design Directive.
In a position paper, they point out that industrial furnaces cannot be considered in isolation to the rest of the process as their performance is governed by such factors already designed to improve efficiency such as hot charging and capture of waste heat for use in the process or heating of buildings.
They fear that given the high importance of eco-design and energy efficiency in European policy, once finalised, this report will lead to unjustified conclusions and unattainable measures not only with regards to the Eco-Design Directive but also with regards to future policy initiatives related to energy efficiency.
They conclude that custom designed industrial furnaces and kilns are not eligible under the criteria given in the Eco-Design Directive and that installations covering activities regulated by the EU Emissions Trading Scheme and Industrial Emissions Directive should by definition not be subject to the Eco-Design Directive.
Twelve associations representing industries using such furnaces have signed the letter, including Eurofer representing the steel industry, The European Committee of Industrial Furnace and Heating Equipment Associations, the European Association of Metals the Association of European Ferro-alloy Producers and the European Lime Association.
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