OPINION: REGULATIONS WHAT ECODESIGN MEANS FOR HOT-WATER SYSTEMS New European rules on the manufacturing and labelling of a wide range of products that influence energy use have been extended to cover hot-water systems. Hywel Davies explains Hywel Davies, technical director of CIBSE www.cibse.org Requirements for water heaters came into force on 26 September Honest mistakes will be treated appropriately, while those, who have no intention of complying, will be targeted Much of the focus on energy saving in the building services sector is on energy use in operational buildings, and how to design buildings that will use less energy. Indeed, the current target for our Building Regulations is to achieve nearly zero energy buildings within the framework of a cost optimal approach to setting minimum energy efficiency standards. Significant energy use in buildings and elsewhere, however, is caused by the products that are used or installed in them from personal entertainment devices and kitchen appliances to equipment permanently installed in a building, such as air handling units, boilers, pumps, hot-water producing equipment and lighting. To reduce the environmental impact of these energy-using products, the European Commission proposed, in 2005, a framework directive setting Ecodesign requirements for all energy-using products (EuP 2005/32/EC). This enabled the Commission to develop product-specific Ecodesign specifications that would apply at the design phase of the product, and set minimum energy efficiency standards for the products. In all, 57 different product groups, or lots, were identified, and specifications have been adopted or are being developed for many of them. In 2008, the Commission proposed extending the directive to cover energy-related products (ErP) such as windows, doors and insulation materials which do not directly use energy, but have a significant impact on its consumption. The recast directive (2009/125/EC) was adopted in 2009. The EU Labelling Directive on the indication by labelling and standard product information of energy consumption and other resources by energy-related products (2010/30/EU) provides a framework for EU labelling requirements for all the products covered by the Ecodesign Framework. This directive is currently being reviewed by the Commission and a draft revision has been proposed. The Commission estimates that adopting these labels and standards will save, overall, around 166 million tonnes of oil equivalent (MTOE) by 2020 which is roughly equal to the annual primary energy consumption of Italy. Consumers are predicted to save around 315 a year on household energy bills and the measures are expected to create 40bn in extra revenue for European companies. And these figures do not take account of the avoided investment in and subsidies for the generating capacity that will no longer be required. The Ecodesign Framework directive does not set binding requirements on products. It creates a legislative framework enabling the adoption of implementing measures on a case-by-case basis for each product group or lot. The list of product groups to be addressed through these implementing measures is set out in the periodic Working Plan. The directive is the joint responsibility of DG Enterprise and Industry (DG ENTR) and DG Energy (DG ENER). By setting the minimum energy efficiency standards for products at an EU level, and using EU-level implementing measures, the framework not only reduces aggregate energy demand across Europe, but does so using common standards, avoiding the potential for separate standards in different member states. This helps manufacturers wishing to sell building services products across the EU by avoiding multiple standards and compliance requirements. This is particularly relevant in the case of replacement windows, for which there are already a number of national voluntary schemes, which could hinder crossborder trade. A major milestone for building services was marked on 26 September, when the regulations relating to the design and labelling of water heaters, hot-water storage tanks and packages of water heater and solar devices, came into force (see panel at the end of the article). There are several regulations covering a range of products, including space heaters, combination heaters and packages of either of these, together with temperature controls and a solar device. They cover electric, liquid fossil-fuelled and heat pump systems. Separate regulations covering the specifications for solid-fuel systems have recently been published, although the labelling requirements have yet to be finalised. This means that all of these products will now have to meet the design requirements of the relevant regulation, and be labelled. One consequence of this is that the current Compliance Guides for domestic and non-domestic building services published by the Department for Communities and Local Government (DCLG) as supporting guidance under Part L of the Building Regulations will need to be updated to reflect the various Ecodesign regulations that have been published since the compliance guides were produced in 2013. DCLG acknowledges the need for an update, but with a spending review under way, we will have to await further announcements. This particular set of product requirements has been a long time coming, and the leading manufacturers and their trade bodies have been heavily involved in the development of the regulations. Specifiers and contractors will now need to become familiar with the new specifications, especially in relation to labelling and the associated test requirements, which may not be identical to the current test requirements for all products. Enforcement The National Measurement and Regulation Office (NMRO) is responsible for the enforcement of the Ecodesign directives. It offers business support to increase compliance, alongside market surveillance and product testing, and provides comprehensive guidance on a government website. NMRO policy states that enforcement should be proportionate, intelligence-led and risk-based, with minimum form-filling and information requests, with forms and required data provided electronically, if convenient. NMRO states that it will assist industry to comply with the regulations by working with stakeholders, and providing the best information and advice possible. In all cases of non-compliance, the full suite of possible actions will be considered, and the most appropriate selected to help those aiming to comply and pursue vigorously those that intend to flout compliance, including possible prosecution. In other words, honest mistakes will be treated appropriately, while those who have no intention of complying will be targeted an approach that might well be adopted by other enforcement bodies. CJ Published implementing regulations under the Ecodesign Directive Electric motors Commission Regulation (EC) No 640/2009 ecodesign requirements for electric motors (Text with EEA relevance) Local space heaters Commission Regulation (EU) 2015/1188 of 28 April 2015 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for local space heaters Commission Regulation (EU) 2015/1185 of 24 April 2015 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for solid fuel local space heaters Impact Assessment [SWD(2015) 90] Executive Summary of the Impact Assessment Summary [SWD(2015) 91] Solid fuel boilers Commission Regulation (EU) 2015/1189 of 28 April 2015 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for solid fuel boilers Space heaters and combination heaters Commission Regulation (EU) No 813/2013 ecodesign requirements for space heaters and combination heaters Impact Assessment [SWD(2015) 92] Commission Delegated Regulation (EU) No 811/2013 energy labelling of space heaters, combination heaters, packages of space heater, temperature control and solar device and packages of combination heater, temperature control and solar devices Executive Summary of the Impact Assessment Summary [SWD(2015) 93] Water heaters, hot water storage tanks and packages of water heater and solar devices Commission Regulation (EU) No 814/2013 ecodesign requirements for water heaters and hot water storage tanks Commission Delegated Regulation (EU) No812/2013 energy labelling of water heaters, hot water storage tanks and packages of water heater and solar devices Air conditioners and comfort fans Commission regulation (EU) No 206/2012 ecodesign requirements for air conditioners and comfort fans Commission Delegated Regulation (EU) No 626/2011 energy labelling of air conditioners