The sheer volume of feedback received from BEAMA members indicates these regulations cannot be implemented in their current form, the body says.
In its 28 pages of technical feedback to the DESNZ consultation – spanning EV charging, heat, storage, and smart energy technologies – BEAMA has urged the Government to take on board lessons learned from the introduction of similar regulations for EV charge points in 2022. Otherwise they risk facing the same challenges to implementation they found but for all energy smart appliances in scope like electric heating appliances and battery energy storage systems that are essential to the success of Clean Power 2030.
BEAMA highlighted a number of policy pit falls that must be addressed to ensure these regulations are a success including:
Removing randomised delays for home heating – We do not support the proposal to include randomised delays into domestic smart heating devices. This proposal is impractical for these always-on devices and puts consumers at unnecessary risk during extreme temperatures when demand for heating or cooling is likely to be at its peak.
Realistic implementation – The proposed 18-month compliance window for implementing new heating, EV and storage product regulations is not deliverable; risking higher costs, reduced innovation, and delayed investment in UK manufacturing. A more measured implementation period would align with product development cycles of 24–32 months. We recommend DESNZ implementing a two-year voluntary period before mandating compliance to minimise risks of inflating electrical product prices for UK consumers or slowing economic growth.
These recommended policy adjustments have been developed in consultation with BEAMA members, including a diverse range of the UK’s leading EV charging, heating and cooling, and smart energy devices.
Stuart Callow, new technologies standards expert, Worcester, Bosch Group said: “To deliver products that meet consumers’ needs and are proven, reliable and long-lasting, manufacturers need time to develop, test and bring these new solutions to market. The requirements proposed under Energy Smart Appliance policy are considerable, and still unconfirmed, which means development work cannot start. The likely circa 18-month window between Government’s confirmed requirements and the deadline for compliance is simply not enough, given most manufacturers require 2 – 3 years for new product developments. The risk is that existing products may have to be removed from the market before new compliant versions are available because of this compressed timeline. This will only serve to restrict consumers’ choice and slow-down the transition to electrification. We hope Government listen to the significant concerns raised across the varied sectors BEAMA represent and choose to engage constructively on a pragmatic, more secure, way forward.”