Changes to Energy labelling and minimum performance requirements

7th Aug 2017


Martyn Griffiths, Technical Consultant to the HWA, talks about the latest ERP changes and what they mean for the hot water industry.

In September 2015 the UK implemented European Legislation with regard to the labelling and energy performance of water heaters and hot water storage tanks. This first phase of the legislation required that all manufacturers of hot water tanks and water heaters had to provide energy labels and relevant technical information in the form of a product technical fiche at the point where the product was first placed on the market.

In the case of hot water tanks, the energy label was simply based on the standing heat loss of the product. The products were rated on an A to G scale with A being the best insulated. The label used specific colour bands according to the energy rating with the A band allocated dark green and the G band Red. In the case of hot water tanks, there were no minimum performance requirements in 2015 thus it was perfectly legal to sell tanks in any band as long as they were labelled correctly.

For water heaters including hot water tanks sold with fitted immersion heaters then the energy label was based on actual energy efficiency with the product being tested against specified draw off cycles, the most common being the so-called ‘M” or medium cycle providing 100 litres of hot water a day or the “L” (large) cycle at 200 litres a day. The labels have A to G colour bands and look similar to those for hot water tanks but it should be remembered that the bands are based on efficiency, not heat loss so are not directly comparable.

Unlike hot water tanks, there were minimum efficiency standards set for water heaters back in September 2015.

To make matters more difficult the EU decided that electricity should have a carbon factor of 2.5 regardless of its means of generation. Bearing in mind this factor then even if it were possible to make a simple resistance heated water heater 100% efficient it would only be rated at 40% thus limiting the available bands. The legislation does make some provision for the fitting of “smart” control to the water heater which can boost efficiencies by up to three percentage points.

As from September 2015, the minimum efficiency for water heaters rated on the both the “M” and “L” profiles was 30% signified by Band E.

On 26th September 2017, we enter phase two of the legislation this will introduce minimum requirements on the heat loss of hot water tanks and more stringent efficiency requirements for water heaters.

Hot water tanks will have to meet at least the Band C heat loss requirements, in most cases, this is already the case since they are already meeting quite stringent and separate UK Part L Building Regulation requirements.

Water heaters will have to meet higher efficiency requirements with a minimum of 36% (Band C) for the “M” profile and 37% (Band C) for the “L” profile.

In addition to the changes in minimum requirements then the labels for both hot water tanks and water heaters will be changed.

In effect, the lower Band G will be dropped and an additional band designated A plus (A+) will be added at the top end.

It is important to note that the actual values of the bands do not change. In other words, a product that was, say Band C in 2015, will still be Band C following the change. There will, however, be a change in the colour designation for the bands so the Band C will change from pale green to yellow.

Inevitably, due to production changeover logistics and stocking of products in the supply chain, there will be period of several months where both labels are in circulation. As the actual values have not changed this should not cause a problem. It should be remembered that the legislation is applied at the point where the product first enters the market which in effect is when it leaves the factory. This means that it is perfectly OK for a merchant to sell and an installer to fit a product with the 2015 label provided it left the factory prior to September 2017.

As ever members of the Hot Water Association will be happy to answer any questions you may have. Contact us;