ErP Regulation update
The Energy related Products Directive, is a mandatory piece of legislation, proposed by the European Union, which aims to bring in minimum standards for heating and hot water systems. Here, Martyn Bridges, Director of Sales and Marketing at Worcester, gives his thoughts on the updates to the Regulation.
The Directive, under Lot 1, proposes a number of new standards including NOx limits and efficiencies for oil-fired boilers, new system & product labelling requirements and differing efficiency points for different controls.
We have seen various amendments to the ErP Directive and as a whole the UK heating industry has had a number of concerns about several of aspects of the new Directive.
But it is fair to say that the NOx limits required have caused the most controversy.
However, more recently, and more positively, I believe, after lots of to and fro-ing, the Commission is starting to listen to the heating industry.
Two or three years ago the Commission put some extreme propositions forward, particularly in respect of the requirements for boiler models, which as an industry we believed were definitely unworkable, in the UK market.
In fact it even reached a stage where one particular trade association walked away from the discussions - which is very unlike them - as they believed that what the Commission was trying to implement was unachievable.
As a result the Commission took note and went back to the drawing board and through suggestions from mainly the UK’s industry bodies and trade associations, a new model has been proposed which is a lot simpler and essentially works on the full and part-load efficiencies of a boiler.
As mentioned, the NOx emissions of boilers has been one of the most controversial. The first draft of the ErP Directive called for boilers to achieve NOx emissions of an extremely low value.
Originally the figures we were expected to achieve were as low as 35mg/kWh for both gas and oil-fired boilers.
This was an absolute deal breaker for oil as, as an industry, we felt we wouldn’t have been able to put onto the market another oil-fired boiler.
However after much negotiation, the latest figures presented to us in April have indicated that we are now expected to reach a level of 70mg/kWh for gas-fired boilers and 120mg/kWh for oil.
The low NOx emissions for gas-fired boilers isn't a problem for manufacturers in the UK, as we’re already designing and producing only condensing boilers, which achieve this.
However, the case for oil is still a challenge, but it's certainly not impossible.
The last draft that we were asked to comment on suggested a level of 120mg/kWh which is acceptable to the UK.
However there have been a certain number of countries in Europe, particularly smaller countries, who have opposed the figure, believing it could be reduced further.
Seasonal energy efficiency
The Directive also looks at the seasonal energy efficiency requirements of a boiler. From an efficiency perspective, the latest model proposed has been a good deal simplified.
For gas-fired boilers, whilst we believe it's still a challenge we don't see it as being unachievable, as we are quite optimistic that our gas-fired products will get to the 90% Band A baseline required.
The UK already has regulations in place which prevent us fitting anything other than condensing, so we are ahead of the game to a certain degree unlike many other countries, particularly in Southern Europe who have yet to make condensing mandatory.
However with oil-fired boilers there again appears to still be an issue, with vigorous correspondence flying backwards and forwards between the UK and other European countries affected by these latest amends.
The modulation of oil-fired boilers
The major stumbling block is on the modulation of an oil-fired boiler. Generally speaking, certainly in the UK, a domestic oil-fired boiler typically has a fixed burner, a non-modulated burner.
It simply cycles on and off when it reaches its required temperature.
However in the current proposals, manufacturers would incur a penalty of 7% on the overall efficiency of the boiler.
We consider this notion to be very unfair as we don't see any great difference in efficiency between an on/ off burner and a modulating burner.
As a result we believe, a penalty which takes 7% off the efficiency of, for example, one of our oil-fired boiler will make it difficult, if not impossible, for oil-fired boiler to continue in the UK without changing to a modulating burner.
A modulating burner would cost almost double the price of the present burner used in oil burners and also require an increase in controls complexity.
All of which are relatively untried and tested so as a result we think it could signal the end of oil-fired boiler.
In what is generally a price-sensitive market, the price of an oil-fired boiler would increase significantly, thereby reducing accessibility and meaning homeowners would probably be forced to look for other means of heating their homes.
It's not good news at present, but we are optimistic and we are lobbying hard using facts and laboratory evidence which would prove that a modulating burner and an on/off burner has virtually no difference in efficiency.
All of the comments on the ErP Directive's sections related to gas and oil-fired boiler have to be in to the Commission by the 22nd May.
We believe this is likely to be the final submission and it will be unlikely a further document for consultation will be issued.
The final draft is expected to be published in June and the severity of it is set to be implemented in stages.
We will keep you posted on any changes as and when we know them.
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