Colin Timmins, H&V Portfolio Manager at BEAMA, considers what the likely impact of leaving the EU will have on the Ecodesign Directive and ErP.
Energy labels for boilers were introduced in 2015 and are now part of the landscape for heating installers given that manufacturers and wholesalers are required to display the label in any advertising. The legislation requiring this are the EU Directives for Ecodesign and Energy Labelling of Energy Related Products (commonly referred to together as ‘ErP’.)
Given that the UK officially left the EU on 31 January 2020, there will be some questioning the future application of such regulations which apply in all EU countries when the UK is no longer a member state.
The first thing to note is that the terms of the withdrawal deal include a transition period through to the end of December, during which time the UK will continue to comply with EU regulations, so little should change this year. In fact, many of the Ecodesign and energy labelling regulations currently in force have already been put into UK law, so will remain in place for the foreseeable future.
The real uncertainty is over what happens when these are reviewed or new product regulation introduced. The UK will have to decide whether to adopt these or not, and the current indications are that this could be looked at on a product by product basis to see whether these regulations are appropriate for the UK.
One thing that does seem clear is that both Ecodesign, which sets minimum energy performance standards for products, and energy labelling, which provides consistent information on energy performance to customers, are a good thing in the context of the government’s drive to reduce energy consumption. The Ecodesign Directive, for example, aims to drive manufacturers to produce products that consume less energy while delivering the same function, and without significant additional cost implications to those manufacturers or their customers. It seems unlikely that the UK government would wish to do away with such standards and, if they did, the downside could be less efficient products that can’t then be sold in the EU being ‘dumped’ on the UK market.
The Ecodesign and energy labelling requirements for boilers and heat pumps are currently under review and therefore it will be illuminating to see how any changes from the review translate through to the UK. Some of the areas being looked at by the consultant carrying out the review are changes to the testing process, rescaling of efficiency classes, and the introduction of bonus scores for ‘hydrogen-ready’ boilers. Given that the SAP calculation methodology and Building Regulations standards have been made consistent with the EU methodology, it would be a backward step to risk introducing inconsistency in the future, unless alternative UK standards come into place.
Heating controls form part of the energy labelling regulation for boilers, under the terms of the ‘package label’ where it is a legal requirement for installers to provide customers with a label showing the ‘as installed’ efficiency where a boiler has been fitted with a temperature control.
This should be a standard process, given that the Boiler Plus changes introduced in 2018 made it more explicit that all replacement boilers should be installed with a temperature control. Unfortunately, anecdotal evidence shows that this part of the regulation is largely ignored, so it will be interesting to see if the UK has any appetite to enforce this more fully in the future.
The review of the boiler regulation talks about looking more widely at controls and emitters to optimise system efficiency. The decision of the UK on whether to implement what falls out of this could be interesting.
There is also work under way on the development of potential Ecodesign and energy labelling measures for building automation and control systems (BACS). This would cover the whole realm of controls within buildings, both residential and non-residential, but given that the preparatory period before implementation will take about two years, it is difficult to know how receptive the UK government will be to implementing what promises to be a quite complex regulation, particularly for larger buildings.
Leaving the EU will bring many potential changes, but there is a long way to go before any of these come into play, hence the heating industry must continue to comply in the meantime. One thing to remember is that anyone placing products on the market in EU countries will still have to make sure that their products meet these regulations, so UK exporters will have to meet the standards whether the regulations apply or not in the UK.
Hence EU product regulations will continue to influence the products available in the UK, both directly and indirectly, whether the UK adopts the same regulations or something different.
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