Heat pumps: prior approval and modification of EEC bonuses

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Emma Potter

The government’s new requirements in terms of quality and industrial resilience of individual heat pumps took shape with the publication of three texts on May 29, 2026.

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Decree No. 2026-413 of May 29, 2026 relating to theexamination of applications for approval of heat pump models in terms of quality and industrial resilience, a decree of May 29 setting the approval conditions for heat pump models in terms of quality and industrial resilience and a second decree of May 29, all three published in the Official Journal of May 30, 2026, modify the EEC bonuses for heat pumps and submit them for prior approval of the heat pump model used.

Two new important modifications appeared in these three texts of May 29.

The new terms apply to individual air/water, water/water and ground/water PACS. © PP / Viessmann

Ademe establishes the list of approved heat pump models

Firstly, the decree of May 29, 2026 setting the approval conditions for heat pump models in terms of quality and industrial resilience contains six articles, applies the day after its publication – June 1, 2026, therefore – and concerns individual air/water, water/water or ground/water heat pump models. It indicates that theapproval of the heat pump model is issued if:

– the model has certification Heat Pump KEYMARK, NF PAC, Eurovent Certified Performance (ECP) for Liquid Chilling Packages and Hydronic Heat Pumps (LCP-HP) or an equivalent certification issued by an organization established in the European Economic Area and accredited according to the standard NF EN ISO/IEC 17065 : 2012 by the French Accreditation Committee (COFRAC) or any other accreditation body signatory to the relevant multilateral European agreement taken within the framework of the European co-operation for Accreditation (EA), European coordination of accreditation bodies;

– with regard to packaged heat pumpsthe final assembly of the refrigeration circuit takes place in the European Economic Area, while for split type equipment, the final assembly of at least one sub-assembly of the refrigeration circuit takes place in the European Economic Area – article 2 of this decree thus defines the final assembly of a sub-assembly of the refrigeration circuit: “operation consisting of assembling and connecting all the components of the sub-assembly of the refrigeration circuit considered (indoor unit or outdoor unit), whether they are integrated individually or previously grouped together, to constitute a finished product“.

The order specifies that the manufacturer presents a file with technical demonstration of the points above. An exception is, however, provided for to obtain transitional approval if the models do not meet these criteria: the manufacturer can present an investment plan enabling said criteria to be achieved. A platform is provided by the decree of May 29 on which the manufacturer submits all its supporting documents. Naturally, ADEME or an organization mandated by it, can carry out on-site audits, intended to verify the accuracy of the information and supporting documents transmitted by the manufacturer. The information requested includes the refrigerant, the scop, the seasonal energy efficiency (Etas in %), the power at 35°C and the power at 55°C water leaving temperature.

The above decree indicates that theADEME manages the approval process for heat pumps. The text specifies that “Files submitted on the platform are subject to a monthly review. The date of this change is set for the 15th of each month at 12 p.m. When the 15th of the month is a Saturday, Sunday or public holiday or legally non-working day, relief is postponed to the first following working day, at the same time“. But be careful, contrary to custom, non-response within the deadline constitutes refusal: “within one month from the date of submission of the file, the Environment and Energy Management Agency examines the file and communicates its reasoned opinion to the ministers responsible for industry and energy. In the absence of communication of a reasoned opinion at the end of this period, this opinion is deemed unfavorable. Silence maintained by the ministers within a period of two months from the date of review of the file by the Environment and Energy Management Agency constitutes a decision to refuse approval.“.

Same thing in the case of a transitional approval request: no response within the deadline = refusal. The provisions of the decree came into force on June 1, 2026.

The texts go so far as to define the assembly of a subset of the thermodynamic circuit. © PP

CEEs are subject to approval by PACs from September 1, 2026

Finally, the second decree submits theobtaining EEC bonuses in the standardized operation sheets BAR-TH-171 “Air/water type heat pump” and BAR-TH-172 “Water/water or brine/water type heat pump” under two conditions which must both be satisfied:

– the installed equipment replaces an individual coal, oil or gas boiler;

– THE installed heat pump model holds, on the date of initiation of the operation, the approval provided for by the Decree No. 2026-413 of May 29, 2026 setting the conditions for approval of heat pump models in terms of quality and industrial resilience.

If these two conditions are met, for operations appearing from September 1, 2026 and until December 31, 2030, for housing occupied as a main residence, and regardless of the climatic zone, the EECs provided for by the two standardized sheets are multiplied by 5 as part of the Coup de Pouce Chauffage. This device does not apply to heat pumps used only for the production of domestic hot water. And it cannot be combined with the operations covered by the sheets BAR-TH-101 “Individual solar water heater (metropolitan France)”, BAR-TH-124 “Individual solar water heater (Overseas)”, BAR-TH-143 “Combined solar system (metropolitan France)”, BAR-TH-148 “Thermodynamic storage water heater” and BAR-TH-168 “Solar thermal device (metropolitan France)”.

In addition to appearing on the list of approved heat pumps, the heat pumps used as part of the Coup de Pouce Chauffage must reach an Etas of 126% for a low temperature application and 111% for a medium or high temperature application. Finally, everything “type of systems remote from the installed heat pump, allowing the production of domestic hot water by it, is of the same brand as the heat pump. For this type of system, only the heat pump consumes energy for the production of domestic hot water. By way of derogation, remote systems integrating an electrical resistance for emergency purposes or anti-legionella cycles, and for which the regulation prioritizes the heat pump for the production of domestic hot water, are eligible for this operation“.

For example, for an apartment in climate zone H2, equipped with an air/water heat pump whose Etas ≥ 140%, the CEE provided by the sheet are 58,900 x 0.7 x 1 = 41,230. Which gives, with the multiplication by 5 in the context of the Coup de Pouce heating, 206,150 CEE. For a detached house in the same conditions (H2, Etas≥ 140%), the calculation indicates 109,200 x 0.7 x 5 = 382,200 CEE. Which, in both cases, is considerable.

All that’s missing now is list of approved heat pumpsproposed by ADEME and published by Maud Brégeon, the Minister Delegate to the Minister of the Economy, Finance and Industrial, Energy and Digital Sovereignty, responsible for energy. The first version should be published in August at the latest, for consideration on 1er september.

Source: batirama.com / Pascal Poggi / © PP