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ErP One Year On

Mike Foster, CEO at Energy Utilities Alliance (EUA) says that the UK may well have voted to leave the EU but as Andrew Keating, Chair of the Heating and Hotwater Industry Council (HHIC) describes in this article, the EU is still having an impact in people’s homes; protecting the consumer and working for the environment.

Mike said: “Our industry has been good at adapting to change. We did it in 2005 and as Andrew points out in his article here, we are poised for more change.

“Our challenge is to ensure that future changes are developed by working with professionals in the heating industry, and that they are supported by us, so we will all have a better chance of succeeding.”

Article by Andrew Keating:
2015 was a year of change in the heating industry. Regulations implementing the Eco-design of Energy Related Products Directive (ErP) came into force, setting specific requirements for space heating products across the EU. Coupled with this, the associated Labelling Directive introduced mandatory energy efficiency labels for products together with package labels for combinations of products at the point of installation, with the intention of driving consumer behaviour to choose higher rated options.

By 2020, it is estimated that the ErP provisions related to space heating will result in annual emissions savings in the order of 110Mt CO₂ across the EU, in comparison to “business as usual”. Much of this saving will be realised by minimum boiler energy efficiency requirements, which effectively ruled out standard efficiency boilers up to 400kW rated output from September 2015. In many countries this meant a significant change to normal practice, in the UK, however, condensing boilers have been a requirement in domestic Building Regulations for over 10 years so the transition was far simpler.

2015 was the first step on the ErP journey, with more changes set to come. In September 2018, NOx emission limits will come into force which set a maximum value of 56mg/kWh for gas/LPG fired boilers and 120mg/kWh for oil boilers. Some products on the market today will not meet these limits therefore will require redesign or must be discontinued.

An earlier ErP regulation relating to heating circulators impacted the market in 2015. Since 2013, it has been a requirement that glandless standalone heating circulators with a rated hydraulic output of up to 2500W, have a maximum Energy Efficiency Index (EEI) of 0.27. This was tightened to an EEI of 0.23 in 2015 and integrated circulators, such as those built into combi and system boilers, were bought into scope, with huge energy and emissions savings when aggregated across the entire EU.

More change is on the way, with a review of the directive for circulators due next year and space heating to follow in short order, it is expected that these reviews will pave the way for further product requirements into the 2020s. For manufacturers, it is clear that innovation and product development will continue to be critically important in meeting future requirements of both regulators and increasingly tech-savvy customers.

For installers, the requirement for package labels under the Labelling Directive was expected to be the main impact resulting from last year’s changes, many manufacturers and suppliers developed calculation tools and training content to assist with the generation of package labels, making the process as easy as possible and reducing additional time needed. Extensive research with homeowners and the wider supply chain in the UK indicates that, although the creation of labels is simple and installer awareness is high, consumer awareness is low, take up has been limited and demand for higher package ratings is yet to manifest.

A slow start for sure, but not a missed opportunity. So far, the ErP and Labelling Directives have been implemented in relative isolation to the rest of the UK regulatory framework, policy development is underway which will see a degree of integration.

Minimum requirements for boiler replacements
The change to building regulations in 2005 remains one of the most successful government interventions into the residential energy market. By mandating that all new domestic gas boiler installations should use a condensing boiler, the government improved the energy efficiency of the residential heating sector at little cost additional cost to consumers. Using the principle of low cost, incremental improvements to system efficiency and some elements of the ErP Directive, the stage is set to revisit minimum requirements for boiler replacements within Building Regulations.

As detailed in the 2013 Domestic Building Services Compliance Guide, current Building Regulations require a minimum SEDBUK 2009 boiler efficiency of 88 percent, in terms of control, a room thermostat, timer and TRVs are recommended. By and large, this minimum set of requirements and recommendations has not changed since 2005, yet technology has moved on apace. Under the ErP Directive, proven technology, such as modulating and compensating boiler control, are recognised and offer improved package efficiency ratings when applied. Furthermore, the old boiler efficiency rating systems still embedded within Building Regulations do not align and are not directly comparable, with the efficiency metric used in ErP; this is confusing to consumers but a great opportunity for well-trained and skilled Installers to offer consumers advice on how they can get the best solution for their homes.

There is room for improvement and a definite case for action here; we anticipate that government will consult on possible changes to minimum requirements later this year, with a view to implementation next year.

Reduced emissions and higher fuel savings
Expected proposals include altering the boiler efficiency metric to refer to an ErP seasonal space heating value, thereby aligning with product labels and data fiches. Minimum levels of heating controls are also expected to come under scrutiny with a key proposal being to mandate weather compensation for all installations, together with effective time and temperature control. This will help ensure that condensing boiler installations will operate at optimum efficiency levels throughout the year, resulting in reduced emissions and higher fuel savings. Furthermore, the effectiveness of other measures such as TRVs, automated optimisation and TPI control are likely to form part of a call for evidence

Regulations surrounding energy, emissions, heating systems and product standards will continue to evolve over time to support the wider decarbonisation and energy efficiency agenda, irrespective of potential changes in the UK’s relationship with the EU.

It is critical that the entire industry engages to support good policy-making, providing feedback and evidence into consultations, with the ultimate aim of securing the best deal for our customers. Training and awareness will be key to embedding change, and manufacturers will continue to push the agenda here to make it easy.

Baxi Group UK is a CIPHE Industrial Associate. For more information visit:

The Energy and Utilities Alliance (EUA) is a not-for-profit trade association that provides a leading industry voice to help shape the future policy direction within the energy sector. It acts to further the best interests of its members and the wider community in working towards a sustainable, energy secure and energy efficient future.