The calculation scheme Annex IV of the respective regulations is only provided for one solar connector connected to one tank.
In cases where the solar collectors are connected to more than one tank, the sum total of the included volumes can be applied; the volume-weighted 35 standing losses and the worst energy efficiency class of the tanks should be used.
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.
The volume to validate the thermal losses of instantaneous water heaters is the total of domestic hot water volume and buffer volume.
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.
If the electrical resistance is part of the solar hot water storage tank and operates as a backup immersion heater, then the product is a solar-only system.
If the electrical resistance is a heat generator other than a backup immersion heater, this product must be considered as a solar water heater.
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.
It is a solar hot water storage tank, with a pump and a controller as defined by Regulation 812/2013 Annex I, point 39. It cannot be considered as solar only system because solar collectors are missing. In consequence, the product should be labelled as a hot water storage tank.
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.
In the case of heat pump water heaters using indoor air, exhaust air, brine or water as a heat source, there is no possible differentiation according to climate conditions. However, to determine the efficiency, different loads might apply, resulting in different outlet temperatures.
As such, the efficiency for each 43 climate could be different and in this case, data for use of climate zones is needed. In cases where there is no differentiation between climates, all 3 fields can be filled with the same values.
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.
The water heater is in the scope of Regulation 814/2013 and in consequence needs to meet the minimum requirements set. The water heater is to be tested with the highest declared tapping profile (e.g. 4XL).
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.
Boiler space or combination heaters without burners ('heater housing to be equipped with a heat generator') and burners ('heat generators') are both within the scope of the ecodesign regulation according to definition of 'heat generator' in Article 2(5) of Regulation 813/2013 which indicates that "a heat generator designed for a heater and a heater housing to be equipped with such a heat generator shall be also considered a heater". As regard testing, point 2(f) of Annex III requires that "Any heat generator designed for a heater, and any heater housing to be equipped with such a heat generator, shall be tested with an appropriate heater housing and heat generator, respectively."
In addition, according to Annex II point 5(a) penultimate indent of the Ecodesign regulation, information requirements apply: “for heat generators designed for heaters, and heater housings to be equipped with such heat generators, their characteristics, the requirements for assembly, to ensure compliance with the ecodesign requirements for heaters and, where appropriate, the list of combinations recommended by the manufacturer”.
The manufacturers of boiler space or combination heaters to be sold separately from burners ‘heater housings’ will verify and declare the compliance of the 44 boiler to the ecodesign requirements by means of a reference burner of their choice and declare the burner type used for test in the instruction manuals for installers and end-users, and free access websites of manufacturers, their authorised representatives and importers. An appropriate burner can be identified either:
- Based on the matching list provided by the burner ‘heat generator’ and/or boiler space or combination heater ‘heater housing’ manufacturer or,
- By using the technical instructions provided by the burner ‘heat generator’ and boiler space or combination heater ‘heat housing’ manufacturers.
The practical matching is to be based on the procedure established standards EN 267, EN 676, EN 303 and EN 304.
Boiler space or combination heaters without burners and burners are both out of the scope of the energy labelling regulation since the definition of 'heat generator' in Article 2(5) of Regulation 811/2013 does not include the provision quoted above from Article 2(5) of Regulation 813/2013.
In addition, according to Article 1 point 2(g) of Regulation 813/2013, until the 1 January 2018 heat generators designed for heaters and heater housings to be equipped with such heat generators placed on the market to replace identical heat generators and identical heater housings are excluded from the scope of the Ecodesign Regulation. The replacement product or its packaging shall clearly indicate the heater for which it is intended.
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.
A preferential heater is a heater that generates heat in cases where the heat demand is lower than or equal to its rated output.
In general, a preferential heater is a heater which is to be switched on first (usually because it gives the best efficiency). Only if the heat demand exceeds the output of the preferential heater, the supplementary heater is switched on.
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.
As indicated in the transitional methods, water heaters have to be tested in the “out of the box” mode. This means that if the water heater is delivered with the mixing valve or it is indicated that it must be used, the water heater should be tested with the mixing valve.
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.
Water heaters models are to be registered in EPREL in case you are an EU manufacturer so as to obtain an energy label via EPREL.
More information on the energy label regulation including guidelines from 2018 are available under the link below.
Space and water heaters | European Commission (europa.eu)
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.
If the combination heater and the domestic hot water tank are sold under two different model identifiers, then the domestic hot water tank is considered as a hot water storage tank and the two components shall be labelled separately. They also need to be tested as individual products and meet the minimum requirements set for them.
For solid fuel combination boilers, the water heating efficiency is not regulated. The label of a combination boiler should include the symbol for the water heating function, see Annex III of Regulation 2015/1187. Hot water storage tanks sold under different model identifiers and combined with these 32 heaters are regulated under Regulations 814/2013 and 812/2013. They should meet the minimum requirements and be labelled separate accordingly.
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.
A “hybrid” put on the market consisting of two or more technologies integrated in one casing would be considered a single “product”. A hybrid consisting of a heat pump and a gas boiler is to be considered a heat pump as boiler space heaters are defined as space heaters that generate heat using the combustion of fuel and / or the Joule effect.
In the absence of a calculation methodology for heat pumps integrating a fossil fuel supplementary heater, suppliers can use the same methodology proposed by EN 14825 for electrical supplementary heaters by replacing performances of electrical supplementary heater with the performances of fossil fuel 33 supplementary heater. It is up to the standardisation process to develop specific standards for these hybrid products.
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.
The hybrid heat pump can be labelled as a heat pump combination heater, in which the water heating performance has been tested according to gas boiler combination heater methodology.
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.
Cogeneration space heaters are defined as space heaters that simultaneously generate heat and electricity in a single process. In principle, they can also be designed to also provide heat to deliver hot drinking or sanitary water at given temperature levels, quantities and flow rates during given intervals and be connected to an external supply of drinking or sanitary water.
In such cases, information about their water heating energy efficiency shall also be provided in the energy label, by using one of the following two options:
- Use the labels foreseen in Regulation 811/2013 for cogeneration space heaters and for combination heaters.
- Use the label foreseen in Regulation 811/2013 for combination heaters including the pictogram corresponding to the electricity function. It is to be noted that the seasonal space heating energy efficiency of combination heaters needs to be determined according to point 3 of Annex VII of Regulation 811/2013. In the case of their water heating energy efficiency, point 5 needs to be applied, which mean that their electrical efficiency is only taken into account for the determination of their seasonal space heating energy efficiency. When the review of the Regulations is carried out, this point is to be taken into account.
For solid fuel boilers, the water heating efficiency is not regulated. It is sufficient for solid fuel cogeneration combination boilers to use the pictogram corresponding to the water heating function and the electricity function as indicated in Annex III of Regulation 2015/1187.
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.
A solar hot water storage tank is a subcategory of a hot water storage tank and has therefore to meet the relevant requirements under the Regulations.
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.
The water heater is in the scope of the energy labelling Regulation and therefore needs to be labelled. The load profile to be used is one of the load profiles provided in the Energy Labelling Regulation.
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.
A natural circulation system consists of a solar hot water storage tank specifically designed to be connected to one or more solar collectors. The product is only able to work in this specific configuration and is sold using a single model identifier.
The natural circulation system is a solar only system. If the tank is never sold as a single device, it does not need to be labelled as a hot water storage tank. The necessary information for issuing the package label shall be provided.
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.
The format of the label shall be respected, the symbol cannot be removed. The transitional methods (2014/C 207/3) provide information about the determination of the sound power level of different types of water heaters.
If no sound power level is applicable then a dash (-) must be inserted as the value for this symbol.
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.
Energy label classes are only provided for storage tanks with a capacity up to 500 l. Packages incorporating a storage tank with a volume larger than 500 l and a space heater or water heater with a capacity below 70 kW are in principle covered by the definitions of the Regulations.
In order to properly calculate the solar contribution, the tank rating can be calculated according to the standing loss S using table 4 of Regulation (EU) 811/2013.
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.
In this case, indoor sound power level is not applicable; it is sufficient to fill in a dash in the label and the product fiche for the indoor sound power level. The product should be marketed as heat pump for outdoor installation only. On the energy label where the value for the indoor sound power needs to be added, a dash should be filled in.
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.
Single market rules establish that products can move freely through the EU, it is in consequence necessary to provide information for the different climate conditions independently of where the product will be placed on the market. The Regulations do not establish that any climate condition is optional.
However, when TOL is higher than -15°C for technical reasons, the rated heat output cannot be declared as per the regulation. In this case, it is sufficient to fill in a dash on the label for the rated heat output under cold climate and state clearly in the fiche that this heat pump is not designed for cold climate conditions. For heat pump combination heaters, this also applies to the water heating energy efficiency and the corresponding annual electricity consumption.
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.
It is possible for the manufacturer (supplier) to prepare a package label for different combinations of the heat pump space heater and different types of control and distribute them with the space heater. Then the dealer can select and fill in the appropriate number on the package label and fiche for the control system he/she sells or offers the consumer together with the heat pump space heater. The appropriate number and type of sensors and/or thermostats for the selected temperature control class shall be included in the package. If the manufacturer or supplier fill in and finalize the package label and fiche, the appropriate number of sensors must be sold together with the space heater and temperature control.
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.
If more than two heat pumps are installed together, it is sufficient that the separate space heaters are labelled with a product label. The dealer can of course calculate the expected performance of the package and include that in the offer (but not on a package label as this combination is not covered by its definition).
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.
No, different ventilation exhaust rates can be used if the heat pump has been tested for them and if they apply to the different operation modes.
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.
The seasonal space heating energy efficiency class for the medium-temperature application (55°C) should always be displayed on the combination heater package label.
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.
An assessment of the contribution from the discharged air from the ventilation unit (after the passive heat exchanger) is not defined in the regulations.
As such, the combined unit needs to be tested as prescribed by the Regulations on space heaters, water heaters and ventilation units and the relevant standards. If the mentioned contribution is not considered in the Regulation or harmonised standards, then it cannot be taken into account.
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.
According to Regulation (EU) 813/2013, all the items applicable under Articles 7(2) and 8 and of Annexes III to V of the Boiler Efficiency Directive 92/42/EEC (BED) shall be identical to the scope of Council Directive 92/42/EEC. In effect, this means that third party certification only applies to the energy efficiency of boilers fired by liquid or gaseous fuels which were previously covered by the BED.
Third party certification should therefore only apply to the efficiency values like the values declared in the BED, so that the existing conformity assessments delivered by Notified Bodies under the BED – i.e. calculated 41 value out of the measured full load efficiency and part load efficiency – are still valid (or default values can be applied as stated in the transitional methods).
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.
Clause 8 and Annex V of Council Directive 92/42/EEC continue to apply and therefore Notified Bodies continue to exist under Council Directive 92/42/EEC. Applications of new Bodies looking to become a Notified Bodies shall be based upon clause 8 & Annex V of Council Directive 92/42/EEC. Member states repealing Council Directive 92/42/EEC (with the exception of Articles 7(2) and 8 of and Annexes III to V), shall continue the notification of Notified Bodies under Directive 92/42/EEC. For this, Notified Bodies shall comply with the minimum criteria as given in Annex V of 92/42/EEC.
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.
A Notified Body notified under Directive 92/42/EEC is authorized to perform: The conformity procedure in accordance with module B as described in Annex III of Directive 92/42/EEC. Where the type meets the efficiency requirements of Regulation 813/2013 the Notified Body issues an EC type-examination certificate using Regulation 813/2013 as the reference (instead of 92/42/EEC).
The conformity procedure in accordance with module C, D or E as described in Annex IV.
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.
Tanks are not in scope of 2015/1189. Hot water storage tanks sold a under different model identifier and combined with solid fuel boilers are regulated under Regulations 814/2013 and 812/2013. They should meet the minimum requirements and be labelled accordingly.
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.
If the functionality of the electric heat generator is only to take over heating when the pellet boiler is out of order, and during maintenance periods, it is a back-up heater.
If the functionality of the electric heat generator is in addition to deliver extra heat if the heat demand is greater than the heat output of the primary solid fuel boiler, it is a supplementary heater.
In this case, the product is a “hybrid” put on the market consisting of two or more technologies integrated in one casing would be considered a “product”.
The declared energy efficiency values should be the combined energy efficiency of the pellet boiler and the electrical boiler. The product should only have one energy label integrating both the efficiency of the pellet and electrical boiler.
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.