Proposed eco-design requirements for boilers and water heaters: eceee comments
(21 Mar 08)
We welcome the Commission’s intention to introduce higher energy efficiency performance through the Eco-design Directive and are impressed by the detailed and thorough analysis undertaken by the consultants for Lot 1 and Lot 2. While we fully support the Commission’s desires to improve energy security and lower carbon dioxide emissions from boilers and electric water heaters, we do not entirely agree with their current proposed procedures to achieve this.
Our objections are based on the practicalities of the market place and the very distinct difference between the replacement market (which tends to dominate in terms of numbers installed each year) and the new build or first installation market. We believe that for the new build and first installation market, there clearly is a wide range of choice in both the equipment and choice of fuel to deliver the required heating and hot water services. We believe that the revision of the EPB directive might be a better approach to encourage the optimum fuel choice which will vary in MSs. However, we still need a method to ensure that all the products are as efficient as possible within their size range and fuel usage. In replacement situations, householders look to replace the failed component with something similar and we believe that it is the objective of any EuP regulation to make sure that the “something similar” is as efficient as possible over time.
At the forum held on 29 February 2008, we were impressed by the more positive attitude taken by the heating and hot water industry and noted in particular, their offer to phase out certain products on a timescale faster than had been proposed by the Commission’s consultant. We strongly believe that these offers should be taken up by the Commission as we feel the first step, as currently proposed, is far too modest in removing the worst performing products from the market place.
In what follows we have tried to follow the order of presentations that took place at the forum last month.
Residential scale boilers
We believe that the European heating industry suggestion of separating the controls into two is eminently sensible, i.e. those concerned with time and temperature and those associated with the control of individual radiators such as thermostatic radiator valves. The former are strongly linked to the manufacturer whereas the latter are only weakly linked and much more heavily dependent upon the installers’ skills.
eceee are not in favour of a common label for all fuels as the 6.6 million boilers installed each year are over 80% in the retrofit market. Instead, we think separate minimum efficiency levels should be set for each energy source We recognise that this would require further action to make sure that householders were aware of the different carbon content of fuels and the overall energy efficiency and carbon dioxide emissions. However because of the variations between Member States (e.g. in terms of carbon content of electricity, infrastructure etc.), we believe this is best done at either the Member State or regional Government level.
We would also like to see the minimum performance requirements introduced before 2011. We believe there needs to be better coordination between the energy labelling and minimum performance for boilers as we believe currently the intention would be to introduce a new energy label in 2011 but which would have three classes of that label phased out in 2013.
We are concerned that the proposed specific efficiency increase from 56 % to 96 % in two years looks a bit ambitious. Again we would fully support the introduction of the proposed performance standards for new build and first installations as part of the strengthening of the EPBD.
We are also conscious of the tremendous difference in initial capital cost between the water heating systems currently available and the currently best available technology to improve the situation via heat pump technology. Again, we would favour much tougher standards being introduced first of all in revisions to the EPBD thus affecting new build and first installations. This would also help with the problems of having new technologies available in sufficient quantities and at competitive prices for the retrofit market which could be regulated at a later date.
We would support a ban of electrically heated water storage above 150 litres in capacity as soon as possible.
We were pleased to see that there was widespread agreement at the forum that there is a need for verification procedure to ensure that the consumer was obtaining a solution which is really in their interests, and also to ensure that industry is competing on a level playing field. The Commission’s proposals in this area are similar to those used in the white good models and we fully support this approach.
We would also advocate that the Commission ensures that it has the powers to pool the results from the individual Member States and so make a more robust and transparent analysis of the actual performance available to EU citizens and organisations.
Download statement (doc).
See also eceee's dedicated pages on the eco-design Directive.