Ecodesign and Energy Labelling of electrical heat pumps

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Two European Directives - the Ecodesign and Energy Labelling Directives - and their accompanying regulations have introduced new minimum requirements for heating appliances, as well as a label to inform about their performances. This article presents these requirements and the foreseen label in respect to electrical heat pumps.

The Ecodesign Directive for electrical heat pumps
The Ecodesign Directive 2009/125/EC (sometimes called the ErP Directive) requires that energy-related products fulfil ecodesign minimum levels of energy efficiency and environmental performance. The Directive is implemented through Commission Regulations, for various specific products.

For example, Commission Regulation N° 813/2013 refers to space heaters up to a heat output of 400 kW, i.e., devices that provide heat to a building `s water-based central heating system, up to a heat output of 400 kW. The regulation also applies to combination heaters, which provide domestic hot water in addition to space heating.

The regulation covers heat pumps, as well as gas and oil boilers, electric boilers, cogeneration (CHP, combined heat and power) boilers. It also applies to “packages” (for example, space heater + supplementary space heater + solar thermal device + temperature control). Its requirements apply since 26 September 2015.

For electrically driven heat pumps (air-to-water, water-to-water and brine-to-water heat pumps), this regulation includes the following requirements:
Example of label for a heat pump for medium- and low-temperature application until 26 September 2019 Example of label for a combination heat pump until 26 September 2019

• For both heat pumps providing space heating and combination heat pumps:
• a minimum seasonal space heating energy efficiency, for an "average" European climate;
• a maximum noise level, indoors and/or outdoors.
• For combination heat pumps: a minimum water heating energy efficiency according to the declared load profile (i.e., a given sequence of domestic hot water draw-offs).
The specific thresholds, for seasonal space heating energy efficiency and water heating energy efficiency, will become higher from 26 September 2017 onwards.

The required level for the seasonal space heating energy efficiency of low-temperature heat pumps (i.e., designed to deliver their declared capacity at a water temperature of 35 °C, and which cannot go up to 52 °C when outdoor air temperature is -7 °C) is also higher than for other heat pumps.

The regulation also lists which data must be published in the products ` technical documentation.

In addition, the regulation defines the way to assess the energy efficiency for of space heating and water heating. For example, the seasonal space heating energy efficiency of heat pumps, declared in terms of primary energy, is derived from the seasonal coefficient of performance based on part-load performance data, and corrected by contributions accounting for temperature controls and, if applicable, for the electricity consumption of ground water pump(s).

Transitional measurement and calculation procedures are listed in a Commission Communication (referenced 2014/C 207/02), until harmonised European standards are published that define how to measure and test the relevant parameters for the performance assessment. These standards are developed as required by a Commission Implementing Decision on a standardisation request (Mandate M535), approved by the European Committee for Standardisation (CEN). A standard for the energy performance of electrical heat pumps was published in March 2016 (EN 14825:2016) and should be listed in the Official Journal of EU as a harmonised standard.

The Ecodesign Directive requires that manufacturers keep and make available EC declarations of conformity, and affix CE markings. For electrical heat pumps, the implementing Regulation N° 813/2013 defines rules for the conformity assessment: this can depend on manufacturer decisions concerning internal design control or management systems – as described in the annexes to the Ecodesign Directive. Regulation N° 813/2013 also describes the verification procedure for market surveillance by Member States.

Guidelines have been published by the European Commission, including related Frequently Asked Questions.

The Energy Labelling Directive for electrical heat pumps
The Energy Labelling Directive 2010/30/EC imposes mandatory labelling and information requirements that indicate the consumption of energy and other resources by energy-related products.

A Commission Delegated Regulation supplementing Directive 2010/30/EC has been published for space heaters and combination heaters up to 70 kW (Commission Regulation N° 811/2013). The Regulation defines energy efficiency classes, the contents of the label and the product information that should be made available to consumers.

Note that space heaters between 70 and 400 kW must fulfil Ecodesign requirements even though they are not covered by the energy labelling regulation.

For electrical heat pumps, the label must include the following information:

• the supplier`s name or trademark;
• the appliance name (supplier `s model identifier);
• the rated output under three European climates (average, colder and warmer), for medium- and/or low-temperature applications (55 °C and 35 °C respectively);
• the seasonal space heating energy efficiency class for medium- and/or low-temperature applications (from A++ to G until September 2019 and from A+++ to D after this date);
• a European map displaying the three indicative temperature zones;
• for combination heat pumps, the water heating energy efficiency class for the declared load profile (from A to G until September 2019 and from A+ to F after this date);
• the sound power level indoors and/or outdoors;
• for combination heat pumps able to work only during off-peak hours, a pictogram showing this.

For medium temperature heat pumps, the regulation requires provision of a label with energy efficiency classes for both low- and medium-temperature applications. For combination heat pumps, only the medium temperature energy class is mentioned, along with the energy class for water heating energy efficiency (See Image 1, Image 2 at the slildeshow above).

If a heat pump is made available on the market or put into service with additional devices (temperature controls, supplementary boiler, solar device), a supplementary label shall indicate the energy efficiency of the package.

The Energy Labelling Directive requires that suppliers produce technical documentation which is sufficient to assess the accuracy of the information contained in the label. The supplementing Regulation N° 811/2013 describes the verification procedures for market surveillance purposes.

In May 2013, the European Commission launched the review process of the Energy Labelling Directive. The report of this review and its accompanying document were published in July 2015.

Impact of these two Directives on heat pumps
The Ecodesign and Energy Labelling Directives have significant implications for heat pumps:

• they rely on new methods to assess product energy efficiency, based on seasonal energy performance rather than on standard rating conditions;
• they have created a need for revision of the corresponding European standards;
• they define requirements that phase less energy-efficient products out of the market, with more ambitious thresholds entering into force from September 2017;
• they govern the labelling of products for better information of consumers.

The European Commission published Guidelines that summarise the most relevant information which would help stakeholders (including industry and public authorities) to implement these regulations. A Consumer`s Guide presenting the label is also available in several languages.

Several stakeholders have also published documents providing guidance, e.g., the Danish Energy Agency and the Federal Association of German Heating Industry (Bundesverband der Deutschen Heizungsindustrie - BDH).

NOTE: A first article in this BUILD UP series presented the overall impact of the Ecodesign and Energy Labelling Directives on HVAC products, while a second article focused on gas and oil boilers. The present article covers electrical heat pumps, while future articles will focus on water heaters and ventilation units.


By François Durier, Michèle Mondot (CETIAT, France)

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