EUROPEAN LEGISLATION HEATING PRODUCTS
EU LAW HOTS UP
The Ecodesign of Energy Related Products Directive and the EU Labelling Directive are set to have a signifi cant impact on the specifi cation of heating equipment, says Jeff House
T
It is likely that non- condensing, direct-fi red water heaters and boilers in the affected output range will disappear
he Ecodesign of Energy Related Products (ErP) Directive (2009/125/ EC) sets specifi c performance requirements for products that
consume energy. Product groups are split into a series of ‘lots’. To many building services practitioners,
the Ecodesign Directive will not be a new concept. For example, heating circulators (covered by ENER lot 11) face mandated effi ciency limits from January 2013. Implementation of ENER lot 1 (space heaters and combination heaters) and ENER lot 2 (water heaters and hot water storage tanks) will also be of interest. The scope of lot 1 encompasses hydronic
space heat, producing appliances such as boilers, heat pumps and CHP, with a gross rated thermal output up to 400 kW, or 50 kWe for combined heat and power (CHP). Heaters of 70 kW rated output and below are subject to slightly different requirements than 70 kW to 400 kW- rated outputs, representing the different approaches to boiler effi ciency declaration in the domestic and commercial markets. Lot 2 covers water heaters and storage
tanks with up to 400 kW input or 2,000 litres capacity, with requirements split by size profi le, from ‘3XS’ (single outlet heaters) to ‘4XL’ (large communal systems). Lots 1 and 2 will dictate minimum
Jeff House is applications manager at Baxi Commercial Division and represents the ICOM Energy Association
effi ciency, NOx emissions and, for heat pumps, noise limits. They will introduce tiered mandatory requirements at two, four and fi ve years after implementation of the Directive. Suppliers will be unable to sell products within the EU that fall short of these limits. To ensure compliance, the Directive enacts market surveillance checks and fi nancial penalties for non-compliance. The Directive’s detail has changed several
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times and this is one source of confusion – compounded by delays. However, there are now strong indications – subject to a regulatory vote in late 2012 – that lots 1 and 2 could become law in early 2013. The Directive would then enact a series of minimum product requirements. Implemented alongside ErP is the complementary EU Labelling Directive (2010/30/EU), which requires ErP product groups to display an energy effi ciency rating and ‘grade’, as now found on domestic white goods. This legislation has been passed, but the test requirements set out in ErP ENER lots 1 and 2 will form the basis of the label content, so the two measures will be aligned. The most likely timeline for implementation in relation to commercial water heaters is as follows, subject to the results of the vote: ● 2015: Effi ciency limits set, SPL limit set for heat pumps, legal requirement for product label and fi che
● 2016: NOx limits set (gas and liquid fuelled products)
● 2017: Higher effi ciency limits, maximum standing losses for stores set, lower effi ciency ratings removed from label
● 2018: Higher effi ciency limits (larger water heaters). NOx limit set (CHP, heat pump and solar products with fuel burners).
Lots 1 and 2 cover products ‘placed on the market’ or ‘put into service’, so apply to installations in new and existing buildings, unlike the split approach of Approved Document L of the Building Regulations. It is clear the ErP will have a marked effect
as many current products will not meet mandated effi ciency or emissions limits. It is likely that non-condensing, direct-fi red water heaters and boilers in the affected output range will disappear, and that many current designs of oil-fi red appliances will struggle to meet NOx restrictions. So there are clearly implications for product replacement, such as fl ue system suitability and condensate disposal arrangements. With this in mind, building operators and facilities management organisations would be advised to consider eventual replacement with condensing products. Until we know the outcome of the regulatory vote we can only sit and wait. However, with the possibility of mandatory standards and labels by early 2015, it does no harm to plan for the future. CJ
● The history, process and terminology used in the Ecodesign Directive is discussed in this month’s CPD article on page 65.
November 2012 CIBSE Journal 61
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