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Energy Efficient Products

The product has to be classified as a solar water heater or a solar only system?

A product, consisting a solar collector connected with, a hot water storage tank and an  electrical resistance that is only activated manually and used for a few times annually is put on the market as one single unit.  

The definition of a solar-only system in Regulation (EU) 812/2013:

‘solar-only system’ means a device that is equipped with one or more solar collectors and solar hot water storage tanks and possibly pumps in the collector loop and other parts, which is placed on the market as one unit and is not equipped with any heat generator except possibly one or more back-up immersion heaters;

‘back-up immersion heater’ means a Joule effect electric resistance heater that is part of a hot water storage tank and generates heat only when the external heat source is disrupted (including during maintenance periods) or out of order, or that is part of a solar hot water storage tank and provides heat when the solar heat source is not sufficient to satisfy required comfort levels;

According to the definitions this product is a solar-only system.

Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.