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Give us clarity on energy labelling and ErP

A little knowledge is a dangerous thing, according to Chris Goggin
The scale of the climate change challenge has forced a rapidly changing European Union policy agenda and, subsequently, the introduction of several directives targeted at the built environment. These policies and directives are designed to accelerate the greening of industry through increasing the uptake of new energy efficient technologies.

One EU directive in particular that is set to have major impact on the building services sector is the Eco-design of Energy Related Products (ErP). The directive has been designed to ensure manufacturers meet energy labelling and eco-design requirements.

The trickle-down effect of the Kyoto protocol and consequent Climate Change act of 2008 have ensured that the UK has committed to legally binding and ambitious carbon emission reduction targets. These targets which are set against a 1990 benchmark are a 34 per cent reduction in greenhouse gas emissions by 2020 and 80 per cent by 2050.

The aim is to improve the product's ecological performance throughout its lifecycle. Eco-design is a legal requirement if you manufacture certain energy-related products. If your organisation is involved in the manufacture, supply or import of energy-related products within the scope of ErP you must ensure that the products meet specific design requirements.

If you manufacture or sell products within the scope of ErP within the European Union, it is a requirement to clearly label your products with their energy efficiency ratings. The labelling Directive will require products to have energy performance labels, rated from 'G' to 'A+++' similar to those that can be found on domestic white goods.

The ERP directive covers a vast array of products with implementation split into individual product Lots. Lot 1 covers heat pumps, CHP and boilers. Whereas Lot 2 covers gas-fired water heaters up to 69kW and electric water heaters, both Lots indicate minimum NOx and product efficiency levels within their scope.

Affected products will be required to abide by tiered efficiency deadlines set at one, three and five years after the introduction of the directive. In short suppliers and manufacturers that do not meet these criteria will not be able to supply products within the EU.

Driving change in sector
The ErP is designed to drive change throughout the building services sector, accelerating the uptake of condensing water heating appliances and energy efficient boiler systems to support the climate change act 2008.

The main concern for manufacturers and suppliers of water heating equipment is that it will potentially be a legal requirement to label products by summer 2012, and the guidelines and measurement criteria to establish the efficiency of products are still to be finalised, meaning manufacturers are in the dark over how to effectively and accurately label their products and achieve the required criteria.

The manufacturers and suppliers of water heating products have a duty to educate their distributors and installer base so they in turn can offer expert advice to their customers. Consumers need to be encouraged to 'ask the expert'. The worry is that consumers skim the internet for information and a little knowledge can become very questionable.

One helpful information source for the UK is H2Otechnology at, a new website that carries all the information contractors, specifiers and end users need to know about hot water for all applications. The website shows how hot water can be delivered in the most cost effective and energy efficient manner.

The site covers the technology of hot water provision - including continuous flow water systems along with other methods, it also reviews renewables technology, giving the latest news on legislation and regulations, and discusses overall system design.

The author is operations manager at Rinnai UK
6 August 2012


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