This was to be expected. The EPBD does not contain precise criteria for determining which boilers and furnaces are classified as fossil fuel installations and which are not.
The matter is simple when we are talking about furnaces fueled by coal or eco-pea coal. These, according to the provisions contained in the EPBD, must be withdrawn, and EU subsidies for their purchase and installation have long been cut off.
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A much more complicated legal situation is related to energy-saving natural gas boilers. Why?
The EPBD directive will allow the use of energy-saving natural gas (i.e. fossil fuel) boilers in a hybrid system, i.e. as an additional heating installation if we have, for example, a heat pump in newly built houses from 2030.
The transformed Directive on the energy performance of buildings (EPBD) adopted in March contains a number of concepts open to interpretation, on which the European Commission has undertaken to develop guidelines for Member States – emphasize experts from the Polish Organization of Liquefied Petroleum Gas (POGP). – In the second quarter of 2024, The Commission will consult with Member States and business representatives on the concept of stand-alone fossil fuel boilers, the installation of which in new and renovated buildings will not be allowed from 2030.
And here the problem arises whether gas boilers can be classified as stand-alone fossil fuel boilers or not, according to the definition of the EPBD directive.
The problem is defining what a fossil fuel furnace is
The essence of the problem is that currently, energy-saving natural gas heating boilers can use mixtures of renewable fuels, such as hydrogen or biomethane. The EPBD directive does not regulate at all what types of boilers include energy-saving gas boilers that are able to heat a house using hydrogen or biomethane.
The question remains unanswered in the case of fuel oil boilers. Since 2008, biological fuel oils made from biocomponents have been produced, for example by Shell. Biological fuel oils are more ecological, and their combustion in the heating process produces less exhaust gases and soot.
The EPBD directive does not indicate which category of boilers should include installations that partly use fossil fuels for heating and partly use renewable fuels, such as biomethane or hydrogen.
Of course, it is worth mentioning that German manufacturers, e.g. Viessmann, have long produced and tested 100% hydrogen-powered heating boilers. Moreover, it is possible to modify current natural gas boilers and adapt them to heating using hydrogen or biomethane. The cost of such modification is low.
As Janusz Starościk, president of SPIUG, emphasizes, from 2030, it is planned that all gas boilers introduced to the market will either be adapted to burn 100% hydrogen, or they will be easily adapted to this fuel using a "retrofitting" kit, the cost of which should not exceed EUR 150-160 (approx. PLN 700).
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What about heating houses with natural gas? How to bypass the EU ban?
Therefore, even if there is a ban on total heating with natural gas from 2040, energy-saving "gas" boilers will have long been adapted to work on renewable fuels based on biogas (biomethane) and hydrogen.
In Poland, a much bigger problem is the lack of appropriate infrastructure for transmission networks adapted to transport hydrogen.
There are also no regulations specifying what type of biomethane can be used to heat homes.
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Why can't biomethane be used to heat homes?
What is the European Commission doing about this problem?
In the face of very diverse approaches of Member States to the issue of fossil fuel boilers, the European Commission only proposes to exclude from the scope of fossil fuel boilers heating devices that use a significant share of renewable fuels – emphasize POGP experts.
The European Commission wants to focus on withdrawing subsidies for fuel cats from mines rather than banning their use
Unfortunately, as POGP experts note, the EU's failure to independently define what fossil fuel boilers are has prompted some Member States, such as Italy, to temporarily suspend work on the transposition of the EPBD – until the terms contained in the directive are more clearly defined.
However, the Commission intends to issue guidelines for Member States to withdraw support for this type of heating devices. In principle, according to the EPBD directive, support for self-contained fossil fuel boilers should be discontinued by Member States from 2025 – but with the proviso that it may continue until 2027 if the installed gas or biomass boiler replaces the so-called "Cinderella" (an old coal or eco-pea coal stove – POGP experts note.
What about natural gas boilers that are H2 ready and can burn biogas?
To our knowledge, the draft guidelines clearly exclude from the definition of gas boilers hybrid systems using gas boilers as one of the components, provided that such systems use a significant share of renewable fuels – emphasize POGP experts.
As POG experts emphasize, the European Commission shifts the burden to the Member States to define a significant share of renewable fuels in the mixture, which would exclude the boiler from the definition of fossil fuel boilers.
This means that it will be up to the Ministry of Environmental Protection and the Polish government to specify in separate regulations whether gas boilers burning a mixture based on biomethane or hydrogen will be considered renewable energy boilers. Will, for example, a 20% share of hydrogen in the gas mixture be considered as qualifying a natural gas boiler as a renewable fuel boiler in accordance with the EU nomenclature? This will be decided by the Ministry of Environmental Protection in separate regulations, which it will have to introduce by 2030. However, this will also involve additional responsibilities.
Member States are also to determine how to monitor heat sources in a way that ensures that boilers that are not considered fossil fuel boilers use the appropriate fuel mixture both at the time of installation and throughout their life cycle – summarize POGP experts.
