Proposed changes to the Ecodesign regulations are likely to impact the manufacturers of combustion equipment and those who install them.
The Ecodesign Directive is designed to provide consistent EU-wide rules for improving the environmental performance of energy related products through Eco-design. It prevents disparate national legislations on the environmental performance of these products from becoming obstacles to the intra-EU trade. This should benefit both businesses and consumers, by enhancing product quality and environmental protection and by facilitating free movement of goods across the EU.
As such, the directive covers a wide range of energy-consuming products and in September 2013 the EC published Ecodesign regulations for space heating and water heaters. Regulations on energy labelling, through the Energy Labelling Directive, which are designed to create a league table to inform end users, were published at the same time.
The main driver for such regulations, in terms of appliances, is to maximise energy efficiency, reduce harmful pollutants and to promote recycling. Consequently, the regulations include requirements for minimum efficiencies to be achieved by September 2015, with further limitations on NOx emissions by 2018. It is the implications of these changes that we, as an industry, need to be aware of.
In December 2013, a draft of the Transitional Methods of Calculation was circulated. However, to date the official document remains to be published and the industry holds its breath. This document is important as it informs manufacturers of the ‘how to test’ requirements of the forthcoming regulations.
For residential oil heating, hot water production and cooking in the UK and Ireland, the majority of appliances in use burn kerosene, which is different from mainland European countries, that use gas oil. However, the real challenge for the domestic market will be NOx legislation, which will have significant implications for installers. Essentially the UK and Ireland oil market will move from a “No NOx” to “Low NOx” limit in one move.
In the commercial and Industrial sectors, routine testing of NOx levels is common but installers dealing with residential oil appliances will be faced with new requirements. For example, they will be required to carry out additional commissioning checks to ensure the lower levels of NOx (120 mg/kWh) are being achieved. Similarly, service technicians will need to carry out additional tests using NOx analysers to ensure acceptable levels .
Clearly, there are also implications for manufacturers and, to some extent, one key obstacle faced by UK and Irish oil boiler and burner manufacturers is the fact that European legislation does not fully recognise the uniqueness of our market and the residential fuel in use. In particular, as noted earlier, a major difference is our use of kerosene as a residential heating fuel, whereas other European countries use gas oil. This fact is being highlighted by DECC to the Commission and it is hoped that the EC will give recognition to this in the Transitional Methods and NOx calculations when it is finally published – and that it will assist in the challenge as the regulations come into force.
Barry Gregory is managing director at Riello