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Setting the limits for water heaters

It's important to understand the potential impact of the Ecodesign of Energy Related Products Directive on specification of water heaters - and the timelines involved, says Jeff House
The Ecodesign of Energy Related Products Directive (2009/125/EC) establishes a framework for setting specific performance requirements for products which consume energy. Since it was announced there have been a number of amendments and this has led to some confusion, particularly in relation to timelines. The purpose of this article is to clarify the current situation.

The implementation of this EU wide directive is split into a series of 'lots', dealing with specific product categories. Commercial water heating products fall into ErP Lot 2, which encompasses water heaters with a rated heat output <400kW and hot water storage tanks <2000 litres capacity. This captures small point of use electric water heaters and showers through to large commercial direct fired water heaters - of both instantaneous and storage type designs - covering, gas, LPG, oil and electricity fuel sources.

The ErP will set minimum efficiency levels for products and prescribed limits for NOx emissions, standing heat losses and noise limits for heat pumps. It covers all products 'placed on the market' or 'put into service' so is equally applicable to new and existing buildings.

Complementary to the ErP Directive is the EU Labelling Directive (2010/30/EU) which requires ErP product groups to display a declared energy efficiency rating and 'grade' on a specifically designed label, as is already the case with domestic white goods.

Technical proposals relating to Lot 2 have been subject to several delays; however, there is now a strong will within Brussels to complete and ratify the directive. Consequently a regulatory vote is scheduled for Q4 2012 which, if positive, would mean that Lot 2 enters the EU statute book in Q1 2013.

From this point the directive would enact a series of minimum product requirements at various points following implementation. With regard to the Labelling Directive, legislation has already been passed - therefore implementation of requirements does not hinge on a vote. However, as the test requirements set out in ErP Lot 2 will inform the content of the mandated labels it is expected that enactment of the two measures will be aligned.

With this in mind the timeline for implementation shown in the table is envisaged, subject to the results of the forthcoming regulatory committee vote.

Based upon latest draft proposals ErP is set to have a marked effect, with many current products not meeting the mandated efficiency or emissions limits. It is envisaged that that non-condensing direct fired water heaters, in the affected output range, will be removed from the supply chain in fairly short order. Additionally, it is expected that current oil fired appliances will struggle to meet NOx restrictions without further development work.

Clearly this will raise a series of challenges for manufacturers, installers and end users. For example, 'like for like' replacement of older product will not be possible once ErP efficiency limits are enforced. Therefore timely and succinct training and market communication will be essential to ensure all parties are prepared for change.

While we wait for the outcome of the regulatory vote it is a case of 'watch this space', however it is worthwhile bearing in mind that, with the current proposed timeline, product standards and labels could be mandated in early 2015.

// Jeff House of Baxi Commercial Division is a member of the ICOM Energy Association technical working group //
1 October 2012

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