Federal Institute for Material Federal Environment

Research and Testing, Germany Agency, Germany

23 October 2012

Eco-design Directive (2009/125/EC)

Energy labelling directive (2010/30/EU)
Preliminary comments on the Working Document on Draft Commission
regulation with regard to ecodesign requirements for and Draft Commission
delegated regulations for energy labelling of
local space heaters
(delivered by June 12th 2012)

1 Procedure
Consistency of ecodesign standards and energy labelling requirements (e.g. aligned scope,
consistent technical definition and parameters) is essential for the success of the two
instruments and presupposes procedural consistency.
In our view the best procedural alignment of the ecodesign adoption process (comitology) and
the labelling adoption process (delegated acts) can be achieved if the ecodesign
requirements for a certain product group are adopted first under the comitology procedure
and before a final proposal on energy labelling is submitted by the Commission under the
delegated act procedure. We highly welcome the announcement of the Commission to change
the procedure and adopt the ecodesign requirements first before a final proposal on energy
labelling.

2 Lot 20

2.1 General comments

We welcome the commitment of the Commission to set regulations with regard to ecodesign
requirements and for energy labelling of local space heaters (LSH). The proposal should be
improved. Our main issues are:
- usage of European standards (for definitions, pollutant measurements, correction
factors),
- taking safety issues into account for energy efficiency requirements on solid fuel LSH,
- more ambitious timing for emission requirements,
- review of the label proposal and limitation to solid fuel LSH. LSH have too different
usage patterns and the label classes are not distinguishable after BAT tier 3
requirements entered into force.

1
2.2 Scope and definitions
Use of wording and standards
In many cases the working document uses terms which are not clearly defined (e.g. “closed
stove”). European standards have introduced well-known definitions. If further distinction is
needed, references to European standards may still be possible (like “closed stoves comprise
appliances according to EN...“).
We recommend using established definitions from European standards as far as
possible.
Electric heaters
The improvement potential of electric heaters is limited as no losses occur if electricity is
converted into heat. We do not see the necessity to include these products in the scope.
Nevertheless there may be little improvement potential through controls. Controls could
ensure that the produced heat is actually useful heat (knowing that a heater without control is
switched off when not needed whereas a heater with control may continue to be operated and
consume more energy). This could be achieved by simple generic requirements instead of
calculating seasonal efficiency.
In Germany we might cause contradictions with national legislation: According to the Energy
Saving Ordinance for buildings (Energieeinsparverordnung), electric storage heaters are to be
taken out of operation after 30 years of operation as it is a very inefficient heating technology.
We ask the Commission to omit electric heaters from the scope.
Open fireplaces
As for open fireplaces deviating requirements exist, the relevant appliances should be clearly
defined (is a fireplace that can be operated with doors open an open fireplace?). In this context
we would like to point out that EN 12229 comprises open and closed fireplaces.
Decorative fires
Decorative fires should be excluded from the scope. The main issue is safety, not efficiency.
These appliances are not meant as the only heat source for a room.

2.3 Ecodesign requirements

Energy efficiency
We welcome BAT as requirement in tier 3. We also welcome the principle for the
determination of seasonal energy efficiency, including auxiliary energy (see comments on the
method in chapter 2.5). However, due to uncertainties when applying correction factors, it
would be helpful to provide the factors used for the calculation of efficiency requirements
(calculation from NCV to GCV, together with BCC and, if applicable, controls and auxiliary
electricity consumption). This would exclude an important source of errors that may occur if
everyone calculates back standard efficiencies.
Stakeholders have pointed out, that the requirements for solid fuel LSH proposed in tier 3
(efficiency above ~80 % NCV according to the relevant standards) can lead to safety
problems for installations with natural draught as temperatures in the chimney may not
always be sufficient for a safe evacuation of flue gases, except for pellet LSH.

2
We ask the commission to recalculate the requirements to a full load efficiency of 80%
(NCV) for wood fuelled heaters except pellet heaters. Moreover, a stepwise increase of
the efficiency requirements by ca. two percentage points seems to be feasible.
More ambitious energy efficiency requirements for LSH with indirect heating function
We share the opinion of the Commission to apply the requirements also to appliances with a
direct heat output of more than 6 %, putting every room heater with water heat exchanger in
this group. If requirements are considerably more stringent for boilers than for room heaters,
this may be used as a loophole for solid fuel boilers. There are appliances with the full
function of a boiler on the market which are designed for a use in the living area and which
have a direct heat output of more than 6 %.1 Shifting the requirements by 6 % for LSH with
indirect heating functionality does not make sense because the indirect heat is already
considered in the energy efficiency measurement of EN 13240 and EN 14785.
We propose to establish requirements for appliances with a high share of indirect heat
output (e.g. > 75%) and/or with a high combined heat output (e.g. > 15 kW) similar to
the level of ambition of lot 15 solid fuel boilers.
Emissions of liquid and gaseous fuel LSH
For liquid and gaseous fuel LSH no emission requirements have been proposed although the
preparatory study identified pollutant emissions as significant parameters. At least for gas
fired LSH the limit values of the 2002 Blue Angel RAL UZ 71(2) requirements may be used as
a first indication for limit values:

Label: UZ 71 Rated output NOx (mg/kWhinput) CO (mg/kWhinput)

based on NCV based on NCV

Gas-room heaters ≤11 100 80

Gas fired inserts ≤ 22 130 60

Emissions of solid fuel LSH

Solid fuel room heaters together with solid fuel boilers are one of the most important sources
for particulate matter (PM) emissions in Germany and many other European countries. As
these emissions cause significant health concerns, national reduction requirements have been
adopted under the Gothenburg protocol and will be included into the NEC directive for all EU
member states. Besides, the air quality directive (2008/50/EU) requires compliance with air
quality limit values for PM that are exceeded in many European cities. Hence emission
reduction for PM from solid fuel boilers is of great importance in order to fulfill EU and
international obligations. The proposed timeframe is very lenient.
We welcome the use of German limit values for tier 2 and tier 3 for the emissions of solid
fuel room heaters and propose to directly start with the proposed tier 2 requirements
and leave out tier 1.

1
See http://www.kuenzel.de/168-0-kamin-holzvergaserkessel-hv-w.html or
http://www.windhager.com/at/produkte/pelletsheizungen/firewin/
2
Withdrawn in 2010

3
For member states that already have emission requirements it is important to give them the
opportunity to keep stricter limit values in the transition period before the last tier comes into
force or to introduce tiers at an earlier stage than required in the implementing measure.
We ask the Commission to introduce transitional provisions similar to those proposed
for lot 1.
In Germany limit values for CO and PM as proposed in tier 3 have been decided for
installations going into operation from 2015 onwards.
The use of standards is especially important where measurement methods are concerned as
results depend largely on the used measurement method, but also on operation conditions at
measurements. So for each requirement, a specific method or standard needs to be clearly
defined.
Future emission requirements
It would be useful to change operation conditions at emission measurements for small
combustion installations. Emissions should also be measured at conditions that are not
considered ideal, e.g. with wood with different water contents, with different amounts of
wood. Such measurements could make the advantages of advanced automatic (combustion
air) controls and similar developments visible. However such concepts need some
development, currently emission values are not known to a sufficient extent for different
operation conditions.
We propose to develop more realistic measurement procedures for the next review of
the implementing measure in the context of a standardization mandate.
Product information
The proposed information requirements could lead to contradictory information: Efficiency
has to be indicated according to the corresponding standards on the type plate. This efficiency
deviates from information according to the label, and may hence cause confusion.

2.4 Comments on energy labelling requirements

We cannot support the suggested labeling requirements for mainly two reasons:
First, we have doubts if there is enough room for differentiation. When the energy efficiency
requirements of tier 3 will have come into force, there won’t be significant differences in the
energy efficiency of products of the same category. So each of the remaining product
categories will be in one single efficiency class, and the label will result in a primary energy
rating of the fuel, except for wood LSH.
Second, LSHs are used for very diverse purposes which cannot be considered as
interchangeable and which are as consequence not comparable on a common label: electric
heaters can be used where heat is only needed for a short time (e.g. in bathrooms), as freezing
protection etc. Solid fuel heaters are often used as a secondary heating device and for
generating a nice atmosphere. Gas heaters (residential, luminous, warm air) are used as “full
heating”. Decorative fires do not have a heating functionality but offer only a cosy
atmosphere. Hence it seems questionable to introduce one energy label for all room heaters.
We could imagine an approach like the following:
There will remain space for differentiation on the label for wood LSH as open fires have a
much lower energy efficiency than pellet stoves. This approach would work with a classic

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label scale A…G and without using BCC. As some closed fires or stoves can be operated with
wood and coal, a dual fuel label could also make sense; this requires either use of BCC or
separate efficiency classes for wood and coal to show differences of the fuels (we expect only
minor differences in the energy efficiencies), and it would be possible to include gas LSH,
too, if considered as appropriate.
We ask the Commission to develop one label scale for local room heaters using fossil
fuels (coal, gas, oil) and one scale for biomass fuels. This would remove the need for a
BCC. It shall be stated on the label which fuel is used and appliances that can use both
fossil and biomass fuels shall bear a dual scale label.
(Please note: In contrast to LSH, the products of lots 1 and 15 are fully comparable as they
have the same purpose. We generally support a common label for products using different
fuels. It should however only be introduced where appliances serve the same purpose.)

2.5 Calculation and testing

Calculation method
- The proposed weighting of ηrated and ηpart leads to different average loads:
0.2x full load + 0.8x 30 % part load = 44 % (warm air units)

0.2x full load + 0.8x 50 % part load = 60 % (luminous and tube heaters)
As a result the seasonal efficiencies are not comparable. Does this different weighting
come from different usage patterns?
- It does not make sense to apply F(1) on capacity control and F(2) for room
temperature controls for manually fueled wood LSH (except pellet LSH). Controlling
the heat output automatically would mean reducing combustion air and worsening
combustion conditions significantly. Only emission control is necessary for those
wood LSH, not capacity and room temperature control.
- For the other technologies, meaning and origin of correction factors are not clear.
Have they been derived from European standards?
- If a 10 % bonus is applied for electric LSH it is 3 % (10% of 30 %), not 10 %.
- F(4) option 1 should be “+1 %”. Why is a calculation proposed if the figure is fixed?
Testing
The use of standards is crucial where testing is concerned. The results of measurements
deviate to a large extent if different methods are used. Please make clear that for dust
measurements the relevant product standards and TS 15883, Annex A is to be used.
Market surveillance
Measurement- and operation tolerances for solid fuel stoves are considerable. Applicable
tolerances for the measurement of energy efficiency and emissions may be defined in the
European standards.. In consequence, the 10 % tolerance used for market surveillance will not
be enough where emissions of solid fuel stoves are concerned.
We recommend checking on the applicable tolerances.

5
Comments on the verification procedure
The procedure for market surveillance is very costly as 3 additional local space heaters have
to be acquired if the first one fails the test, which is not always possible, as many products in
this lot are built-to-order, especially larger ones. In order to facilitate market surveillance we
propose that if a local space heater does not comply with the requirements, only one
additional product is tested and that the average of the 2 local space heaters has to comply
with all requirements.
Regarding the tolerances it is important to ensure that sufficiently accurate measurements are
available, especially for emission values.

Contact:
Federal Institute for Materials Research and Testing (BAM)
Floris Akkerman, Department S Working group Product Requirements
Phone: +49-30-8104-3810, floris.akkerman@bam.de

Federal Environment Agency (UBA)

Jens Schuberth, Section I 2.4 Energy Efficiency
Phone: +49-340-2103-2450, jens.schuberth@uba.de
Anja Behnke, Section III 2.1 Generals aspects, Chemical Industry, Combustion Plants
Phone: +49-340-2103-3801, anja.behnke@uba.de
Ines Oehme, Section III 3.1 Eco-design, Environmental Labelling, Environmentally Friendly
Procurement
Phone: +49-340-2103-2585, ines.oehme@uba.de