1. ECODESIGN & LABELING DIRECTIVE Lots1 & 2 Heaters/Water-heaters Where are we? (Nov. 2013) Prepared by Jean Schweitzer DGC MARCOGAZ Standing Committee Gas Utilisation meeting

2. Context To minimize the impact of heaters/water heaters on energy consumption & emissions in the EU Directive 2009/125/EC Ecodesign = minimum requirements on Efficiency, NOx etc. Directive 2010/30/EU Labelling = indication by labelling of energy consumption

3. General context Heating in Europe 12000 PJ (2005) = 16% of gross energy in EU-27 = annual consumption of France Scope – Efficiency – Emissions – NOx, CO, unburned hydrocarbons; noise Expectation – Consumption after 15 years reduced by ca 25% For the next revision (< 5 years)

4. Appliances parameters subject to minimum requirements SCOPE & REQUIREMENTS Lot 1 = Heating appliances (water based central heating) Lot 2 = Sanitary hot water appliances Condensing mCHP Gas heat pump Boiler

5. Label: Appliances and Systems The labeling system divided in two parts: appliance label and system label Combinations possible with solar energy or other appliances The manufacturer is responsible for the first label (appliance), while the dealer is responsible for the second label (system). Fig. From Vaillant

6. Appliances parameters subject to minimum requirements Requirements in two steps with more stringent requirements Minimum Efficiency 1)AFTER 2 YEARS (all appliances) 2)AFTER 4 YEARS (mCHP, GHP etc.) NOX 1)AFTER 5 YEARS Implementation work 2013 Sept. 2014 2015 2015 Sept. 1st Measures implemented Minimum requirement: Efficiency of all appliances Labelling of appliances Labelling of system 2016 2017 2016 Sept. 2018 Measures adopted for the 2 directives Nothing new in 2016 ….. 2017 Sept. New Measures implemented New minimum requirement: Efficiency mCHP, HP 2018 Sept. New Measures implemented Minimum requirement: NOx all (combustion based) appliances. Revision of the measures? (CO, CxHy, etc..?) Label extended from A++ to A+++? Time Line 19

7. APPLIANCE Label + F & G 2 years 2015? Heat pumps Cogeneration CH boilers 6 years 2019 E F G review five years after the entry in force CH boiler label from green to yellow

8. Minimum Seasonal space heating energy efficiency ApplianceAFTER 2 YEARSAFTER 4 YEARS Fuel boilers ≤ 70 kW86 % unchanged Fuel boilers > 70 kW and ≤ 400 kW Full load 86 % Part load 94 % unchanged Type B11 boilers75 % unchanged Cogeneration space heaters 86 %100 % Heat pumps100 %.110 % Low-temperature heat pumps 115 %125 %

9. Max NOx emissions (all given on GCV*) ApplianceAFTER 5 YEARS Gas boilers 56 mg/kWh Fuel oil boilers 120 mg/kWh Cogeneration space heaters or Heat pumps with external combustion using gaseous fuels 70 mg/kWh Cogeneration space heaters or Heat pumps with external combustion using liquid fuels 120 mg/kWh Cogeneration space heaters or Heat pumps with internal combustion using gaseous fuels 240 mg/kWh Cogeneration space heaters or Heat pumps with internal combustion using liquid fuels 420 mg/kWh * Gross calorific value

10. Overall impact on the market + F & G 2015 Heat pumps Cogeneration CH boilers 2018 E F G review Philosophy: A++ and higher are reserved to renewables Severe NOx limits will apply in 2018 and will be challenging for several products currently on the market). Gas boilers combined with thermal solar energy can achieve an A+ label /possibly more: we may be able to make A++ solutions cheaper than EHP (to be investigated) Micro CHP will only achieve an A+ label. Trad. boilers banned (2015) Gas heat pumps should be able to achieve A++ or A+++ later. Electrical heat pumps will reach the same labels. Package label Minimum requirements: Appliance label: Condensing boilers will be A & B

11. Overall impact on the market for gas appliances Philosophy: 1)Best condensing appliances can only reach A on a G to A+++ scale/range. 2)A++ and higher are reserved to renewables Gas boilers meeting the efficiency requirements will be labeled “B” and “A” Value of efficiency = on Hs. (Calculated as 0,85% PL+ 0,15% FL + corrections) Severe NOx limits (challenging for several gas products currently on the market). Gas boilers combined with thermal solar energy can achieve an A+ label / possibly more (for the package boiler + solar device, not for the boiler as stand- alone) Gas heat pumps should be able to achieve A++ or even A+++ (not from start). Engine based compression heat pumps may have difficulties to meet the NOx limit without the use of a catalyst. Electrical heat pumps will reach the same labels. Micro CHP with Stirling engines will only achieve an A+ label. Same should apply to fuel cells

12. Label on actual condensing boilers on DK market Minimum requirement for efficiency (no actual DK boiler banned) Label A B C

13. NOx ECO DESIGN REQUIREMENT 56mg/kWh Hs ECO DESIGN REQUIREMENT 56mg/kWh Hs

14. Practical issues & questions with implementation 1)Labelling of systems & installers (are they able to make the system labelling?) 2)Market surveillance 1)Overall bad experience with MS of ECO design products 2)Gas appliance (third part test) 3)Other appliances (self declaration) 4)Notified bodies? 5)Use of tolerances (  discussion with EU August sept 2013) 3)Hi/Hs end user information (eg. 102% Hi  to 92% Hs) 4)Appliances cost / Appliance label: 1)Boilers ”only” ca 30% less effective compared to HP, but cost 3 times less  affordability issue 5)Hybrid technologies (gas boiler + EHP). How are they treated? 6)Etc.

15. B B Written consultation on the use of verification tolerances set out in the implementing measures of both the Ecodesign and Labelling Directive for market surveillance purpose (summer 2013) “Measurements and calculations of the relevant product parameters should be performed through reliable, accurate and reproducible measurement and calculation methods, which take into account the recognised state of the art measurement and calculation methods including, where available, harmonised standards adopted by …etc “ Tolerances for efficiency Several inter-comparison test have been conducted by European accredited laboratories during the last 20 years, and according the results obtained, CH boiler nominal efficiency can nowadays be measured with an accuracy of +/- 1,5% or 2% (source LABNET). Electrical appliances testing are less challenging (no gas flow, temp, pressure, calorific value to measure) and should be possible with a similar or better accuracy. For market surveillance, the 8% tolerance is too high and we suggest fixing a more appropriate tolerance closer to the current measurement state of the art (4% to 5% could be envisaged). Tolerance on NOX According to all test laboratory experts, a NOx tolerance of 10% is not realistic especially for the low level of emissions considered. In this case 30% will be more appropriate according the same inter-comparison tests carried out by accredited laboratories (source LABNET). Measure proposed (DGC/Marcogaz) Adoption of realistic tolerances Requirement on Accreditation of the testing Use of NBs Measured value (Manuf. Declaration) A A 85% c c Measured value (+ EU tolerance) 93% 90% 82% Measured value (- EU tolerance) 78% EU tolera nce Eff = 8% La bs = 4%

17. Package labelling

18. DK Infoblad EU ECO designComments Nox minimum requirements Very severe requirementsThe ECO design requirements will improve the NOX level of gas boilers coming on the market. Nevertheless the requirement should be based on a more realistic criteria (annual emission taking into account the modulation) Other aspects 735-51 Database Nox16

19. Lack of differentiation within a same type of appliances The EU label target is to compare technologies of very different efficiencies: from boilers to heat pumps  the coverage from 30% to 150% (= 12% avg range for one class) makes that all appliances of one type are mostly in 1 or two categories…….thus no differentiation within the same technology A A A+ A++ B B C C D D CH boilers + solar CH boilers + solar mCHP Heat pumps

20. Conclusion (1) Good results obtained thanks to MARCOGAZ (& GERG) work (mCHP & GHP in scope, third part testing for gas, etc.) NOx requirement can be a issue when entering in force (2008) Markets have to learn to live without traditional boilers A lot of uncertainties still (implementation questions) Condensing boilers only ”A” but much cheaper than A+, A++, A+++ technologies System label, how can it be used to better profile gas appliances?

21. Conclusion (2) MARCOGAZ SCGU planed activities for the next 2years Following of the implementation in the different Countries & mutual information – Market surveillance how will it be organised? – Installers role: how will they be able to produce package labeling? Gaining experience with the package label method (rather complicated) Hybrid technologies (gas boiler + EHP). How are they treated in the package label? Optimizing high package labels with gas hybrid technologies (gas + solar) Appliances cost / Appliance label: Boilers are ”only” ca 30%/40% less effective compared to A+++ technologies, but cost 2 or 3 times less  affordability issue. (Campaign with Eurogas?) NOx argumentary: what are the indirect NOx emissions of electrical heating appliances – analyze by country

22. Annex

23. GAS Boilers are very cost effective despite Having only the ”A” label!!! GAS Boilers are very cost effective despite Having only the ”A” label!!!

27. + look at gas heat pump for Commercial Utilisation