Kiwa s ErP Newsletter
How will the ErP Directive Affect your Business? Welcome to the Kiwa ErP Newsletter. As you may know, the ErP legislation for lots 1 and 2 was passed in August 2013 and comes into force on 26 th September 2015. The Directive defines the minimum permissible efficiency for nearly all boilers and water heaters on the European market. We are closely involved with the UK Government and the European Commission and often advise on policy. In fact we participated in the recent new BEDAC meeting at which we engaged with the European Commission officers charged with managing the ErP. It was confirmed that while BED will be repealed, the new Ecodesign regulations still call up those clauses requiring third party testing of boilers for efficiency and also for ongoing surveillance. The implications for the heating industry is significant, not just for manufacturers but also for domestic installers who assume the burden of becoming package assemblers and will be obliged to inform householders of predicted performance of the package. The Commission will be producing draft guidance on this shortly. Kiwa will continue to provide a full set of ErP tests, issue you a certificate and even print the Ecolabel you need to display on your appliance. Has the ErP Got Teeth? Whilst the ErP requires self-declaration, the penalties for incorrect claims may be quite draconian, with the possibility of product recall and very substantial fines. The NMO has been appointed by HMG to conduct market surveillance in the UK, partly because it has powers of prosecution. In addition to a calculated seasonal efficiency, it also declares values for NOx and noise emissions. Surveillance authorities will consider all these aspects. ErP Minimum Efficiency Values: Actual minimum values to be enforced are (as per regulation 813) are presented below. It should be noted that these seasonal efficiencies take account of the main factors (including electricity use corrected to primary fossil fuel i.e. kw X 2.5) and may provide some serious challenges to achieve.
Fuel boiler space heaters with rated heat output 70 kw and fuel boiler combination heaters with rated heat output 70 kw, with the exception of type B1 boilers with rated heat output 10 kw and type B1 combination boilers with rated heat output 30 kw: The seasonal space heating energy efficiency shall not fall below 86 % Type B1 boilers with rated heat output 10 kw and type B1 combination boilers with rated heat output 30 kw: The seasonal space heating energy efficiency shall not fall below 75 %. This includes DHW Fuel boiler space heaters with rated heat output > 70 kw and 400 kw and fuel boiler combination heaters with rated heat output > 70 kw and 400 kw: The useful efficiency at 100 % of the rated heat output shall not fall below 86 %, and the useful efficiency at 30 % of the rated heat output shall not fall below 94 % Electric boiler space heaters and electric boiler combination heaters: The seasonal space heating energy efficiency shall not fall below 30 % Cogeneration space heaters: The seasonal space heating energy efficiency shall not fall below 86 % Heat pump space heaters and heat pump combination heaters, with the exception of low-temperature heat pumps: The seasonal space heating energy efficiency shall not fall below 100 % Low-temperature heat pumps: The seasonal space heating energy efficiency shall not fall below 115 % What Kiwa Can Do For You Kiwa is a Notified Body and UKAS-accredited testing laboratory with expertise in measuring and reporting efficiencies and emissions for heating appliances. We offer a complete set of ErP services: Documentation Review We can review your documentation and test data, bearing in mind the concept of materiality. There are some inconsistencies between European regulations and the standards they call up. These can only be addressed on a case by case basis, by discussion between Notified Bodies and manufacturers. As your Notified Body we are ideally positioned to do this. Declaration of Conformity We can work with you to obtain the correct Declaration of Conformity. Come and see us with your product and we can advise which, if any, steps you need to take.
Reporting Format Reporting the minimum efficiency for appliances comes with certain complications, largely because the measurements must be reported in a set format. If your product has been fully tested and approved, you will have a lot of the data already but this data must be transposed into an ErP-specific format. Pulling together all of the requisite information in order to calculate the seasonal efficiency of your product or package is not simple. We have a range of highly specialised computer programs that can convert boiler and heat pump data to comply with the report specification. Testing Because of the complexity of measurement and reporting, Kiwa Gastec is providing a series of assistance packages to heating appliance manufacturers:- Measurement of efficiencies to the latest standards for DHW and CH at both 100% and 30% load Measurement of noise and electrical power consumption Assessment of categorisation of controls Assessment of categorisation of appliance families Confirmation of ErP declarations including production of the certificate Certification Kiwa will be offering sign off on certification of ErP declarations. Are All Heating Appliances Included? Some products are not yet included, for example: Heaters within the scope of Directive 2010/75/EU Cogeneration space heaters with a maximum electrical capacity of 50kW or above Kiwa is also active in other areas and would advise manufacturers to engage with the legislation at the earliest opportunity. Solid fuel appliance manufacturers are advised to book their lab session now. Understanding how your appliance performs in terms of the
ErP will allow time for necessary enhancements before the Directive is extended to include solid fuel appliances. NOx and hydrocarbons emissions are not tested for CE Marking, so manufacturers may not know whether their product complies with the ErP limit for these. If you require clarification on whether your products are included, please contact us. A final word We would welcome your feedback on this newsletter. If you would like to comment or require further information, please email jamesverlaque@kiwa.co.uk or call 01242 677877