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Water Heaters and Storage Tanks Ecodesign and Energy Label Water Heaters and Storage Tanks Ecodesign and Energy Label Review Study Task 1 Scope – Policies & Standards FINAL REPORT Review study Commission Regulation (EU) No. 814/2013 [Ecodesign] and Commission Delegated Regulation No. (EU) No. 812/2013 (Energy Label) Prepared by VHK for the European Commission July 2019 The information and views set out in this study are those of the author(s) and do not necessarily reflect the official opinion of the European Commission. Prepared by Study team: Van Holsteijn en Kemna B.V. (VHK), The Netherlands, Authors: René Kemna, Martijn van Elburg, Sanne Aarts (all VHK) Study team contact: René Kemna ([email protected]) Contract manager: Jan Viegand, Viegand Maagøe Project website: http://www.ecohotwater-review.eu Specific contract: no. ENER/C3/SER/FV 2016-537/08/FWC 2015-619 LOT2/03/SI2.753935 Title: Review Study existing ecodesign & energy labelling Water Heaters & Tanks Contract date: 9.6.2017 Consortium: Viegand Maagøe, VHK, Wuppertal Institute, Armines, Oakdene Hollins Cover: DHW storage tank with coil [picture VHK 2016-2017] _______________________ This study was ordered and paid for by the European Commission, Directorate-General for Energy. The information and views set out in this study are those of the author(s) and do not necessarily reflect the official opinion of the Commission. The Commission does not guarantee the accuracy of the data included in this study. Neither the Commission nor any person acting on the Commission’s behalf may be held responsible for the use which may be made of the information contained therein. This report has been prepared by the authors to the best of their ability and knowledge. The authors do not assume liability for any damage, material or immaterial, that may arise from the use of the report or the information contained therein. © European Union, July 2019. Reproduction is authorised provided the source is acknowledged. More information on the European Union is available on the internet (http://europa.eu) II EXECUTIVE SUMMARY This is the final Task 1 report of the preparatory review study on the Ecodesign Commission Regulation (EU) No. 814/2013 and Energy Label Commission Delegated Regulation (EU) No. 812/2013 for (dedicated) water heaters and hot water storage tanks. Task 1 not only describes the scope of the study, and the policies and test standards that apply to the products within the scope, but also reviews specific aspects mentioned in Article 7 of the regulations and evaluates the effectiveness of the current regulations in as much as can be derived from available data. Chapters 1 and 2 describe background and methodology of the study as well as the current product scope. Chapter 3 gives a comprehensive update of relevant policies and measures that interface with the water heater regulations. In that sense it addresses the following issues that are potentially relevant for a revision of said regulations: - Over 17 generic pieces of EU legislation relating to energy efficiency, environment and safety issues that have changed since 2007 and relate to water heaters (sections 3.2 and 3.3). Indoor/outdoor sound power limits are discussed separately in section 3.4. - Ecodesign and Energy Label regulations, including the amendments on labelling of internet sales and on verification of tolerances, the transitional methods, standardisation mandates and Commission guidelines ("FAQ") in section 3.5. - Per Member State the legislation in the field of the energy performance of buildings (EPB) and the role of heating appliances therein, as well as the national incentives for specific heating solutions in section 3.6. - The energy policy for water heaters in non-EU countries (US, China, etc.) in section 3.7. - Voluntary endorsement labels and certification schemes in section 3.8. Chapter 4 gives a comprehensive overview of 24 test standards, most of which following the Commission mandates to the European Standardisation Organisations (ESOs). Also the ongoing work on verification tolerances is briefly discussed. Finally, chapter 5 gives a summary of issues identified from the previous chapters, the first stakeholder meeting, position papers of industry associations and other stakeholders, bilateral meetings, etc.. Main items relate to: - The regulation and energy labelling of solar thermal devices, where o Installers are having trouble with the installer package label, i.e. where the installer has to determine the energy label rating from a combination of III components, e.g. a conventional water heater and a solar device from different manufacturers. 1 Reportedly the reason is that it is too complex and/or training is not an installer’s priority. Several Member States and industry associations are facilitating training sessions and set up installer certification; overall these stakeholders don’t seem to be ready to give up the installer package label, also because of its unique merits in promoting solar devices and other hybrids. Industry association Solar Heat Europe proposes a simplification of rating of the solar thermal contribution. o In several Member States the governments do not require applicants for solar thermal subsidies to use the EU labels and/or they require other qualifications (e.g. Solar Keymark). This, and the fact that subsidies for solar thermal have been reduced in several Member States, does not help the uptake of the EU label in the heating market. o As solar devices are particularly suited for warmer climates (e.g. South of France, Spain, Italy, Greece, Portugal) there are voices advocating to show not only the performance in an Average (and Cold) climate on the label but also in the Warm climate zone (compare Energy Label Room Air Conditioners), also because labelled performance is lower than achieved in reality for these customers. o In certain Southern-European countries and especially in holiday homes, small low-cost instantaneous gas-fired water heaters are still popular and it is possible to obtain an ‘A+’ rating without any renewables. At the same it is often difficult to obtain more than an ‘A’ in a water heater package with solar thermal. This does not promote the uptake of solar thermal solutions. o Solar thermal systems are particularly suited as a retrofit to boost existing heating systems. Solar Heat Europe proposes to allow installers to rate and label such a retrofit situation. - There are several proposals to improve/change the solar performance (contribution) calculation method : o Proposals from Solar Heat Europe , Abrecht and mIO are introduced in the report and more details can be found in documents on the project website. o CETIAT proposes a correction to the solar contribution in the regulation (figure 1 of the 8012/2013 regulation). o Solar calculations include distribution losses, whereas efficiency assessments for other water heaters do not include these losses. This reportedly leads to significant differences and should be looked into in a revised regulation. - The current transitional method mentions 4 different test standards that can be used to measure the standing (heat) loss of storage tanks . At least 2 out of 4 standards are converging. For the revision it would be highly beneficial if there were more clarity e.g. on the storage temperature for testing. - A new Primary energy factor (PEF) for EU electric power generation is now established at EU-level at 2.1 instead of the current 2.5. This will have consequences 1 Compare the manufacturer’s package label, where one manufacturer offers combinations of components already supplied with a (pre-calculated) Energy label rating. No problems are reported on the manufacturer’s package label. IV for e.g. the efficiency calculation of electrical appliances. For EPB building codes, Member States can choose their own PEF and this may create confusion in the market in the years to come; - Dedicated conventional water heaters can form ‘hybrids’ with solar devices but also ‘hybrids’ with heat-pumps where e.g. the heat pump preheats –at relatively high COP– to lukewarm (35-40 °C ) conditions. The efficiency of such solutions, which also relate to the definition of ‘ preferential heater’ cannot be properly assessed today. - The Ecodesign water heater regulation will have its share in the steadily decreasing air pollution through NO x -limits, but –following latest insights—abatement of other emissions may be considered. - NOx emission correction factors or specific limits are probably due for third family gases (Liquefied Petroleum Gas LPG, propane, etc.). Currently the NO x limits are identical to those of second family gases (e.g. natural gas). Another issue, not signalled as a problem but rather a point for good housekeeping and level playing field, is that the NO x -emission testing of combi-boilers (cf. (EN 15502-1 ) is different from that of dedicated water heater versus (EN89 and EN 26 standards, with different part loads and different weighting factors). - The issue of third-party verification and compliance in general cover a large part of chapter 5, intended to inform policy makers on the various aspects and stakeholder positions involved. Traditionally fossil fuel fired products are tested through third parties and electric boilers/heat pumps through self-declaration. Interestingly also a leading heat pump manufacturer indicated to be in favour of (some form of) third- party verification. A group of German heat pump manufacturers remains against, because of the costs, time-to-market and other burdens expected. Several Member States and industry associations
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