BEAMA Association Director Colin Timmins discusses the issues concerning regulations and energy labelling with regards to heating.

 

The installation of wet heating systems is due for a bit of a shake up next year when the long awaited EU Ecodesign and energy labelling regulations for space heaters and water heaters come into force. Or at least that’s the intention.

 

From September 2015 every space heater, a definition covering pretty much all domestic central heating appliances from fossil fuelled boilers to heat pumps, will be required to have an energy label indicating how efficient it is. In addition, there will be progressive measures to ban the worst performing appliances from the market with the intention that only the most efficient remain.

 

The EU Commission has long recognised that the fastest and simples way to improve efficiency of technology is to set minimum energy efficiency standards. Its research shows that on average 80% of efficiency improvement potential is achievable through design regulations and in the case of heating technologies, much of this is down to in use energy consumption.  Alongside minimum efficiency standards, the Commission identified the importance of labelling to ensure consumers ‘buy up’ the efficiency chain.  We are all familiar with labelling on white goods and light bulbs; now attention is turning to heating.

 

The supply chain question

 

The problem with putting energy labels on boilers is that they are very different from products such as refrigerators or washing machines which were the original targets for EU energy labels. It will rarely be the case that a consumer goes into a shop to choose a boiler and therefore can compare the energy labels at the same time.

Instead it will be down to the installer to take a key role.

 

During the consultation phase for this legislation, industry made it clear to the European Commission that the specific characteristics of the heating supply chain would require a slightly different approach. One of the changes that resulted was a clarification that the definition of the ‘dealer’ in the energy labelling directive could be a heating installer, and they would become responsible for showing the label to the end customer. This is something that installers will definitely need to be aware of!

 

A bigger issue with energy labelling of boilers was the fact that their ultimate energy performance depends to a very large degree on their installation, and, particularly, the characteristics of the overall heating system that they form part of. This new legislation for space heaters attempts to cover this aspect through the creation of a package label that can address boilers installed with controls and other items such as solar thermal.

 

There remain some significant question marks over how this package label will be implemented in practice, particularly since installers will be expected to produce the label; but it is still only a small step towards taking full account of the need to ensure that efficient systems are installed so that the overall energy use is minimised. Just having an efficient appliance does not guarantee this.

 

System approach

 

It shouldn’t be forgotten that this first step by the Commission towards a system approach in their regulatory framework was very nearly a disastrous step for the heating industry, particularly in the UK. When it was first proposed to deal with controls as part of the boiler legislation the suggested approach was to include an efficiency benefit from controls only when they were delivered as part of the package with the boiler.

 

It was forcefully pointed out to the Commission that this was not common practice in many parts of Europe, including the UK, and such a distortion of the supply chain would have negative effects on many parts of the heating industry. Fortunately, the Commission acknowledged the problem and worked with industry to find an agreeable solution, although this is far from perfect.

 

Hopefully the lessons learned should help the development of legislation for heating and other systems in the future. There is currently a lot of debate in Brussels at the moment about how to put in place appropriate and effective regulation to drive the uptake of better systems and a growing realisation that both the building and the user can be part of the overall system. BEAMA will be heavily involved in this debate through our European controls industry counterpart eu.bac (European Building Automation and Controls.)

 

One of the key things that should come out of this is that the installer is absolutely the key player in making sure that heating systems are designed and installed correctly, and that they are suitable for the user so that they meet their needs for comfort and can be used with as little waste heat as possible.

 

We believe that ultimately we need a framework where installers are empowered to make the right choices for their customers and are given the right level of support so that they are comfortable integrating new technologies where these can deliver additional benefits.

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