Eco design for the retail, professional and domestic markets Judith Evans Refrigeration Developments and Testing (RD&T) Churchill Building, Langford, Bristol, BS40 5DU, UK j.a.evans@rdandt.co.uk
Energy labelling
Aim Aim to provide benefits that outweigh costs Little impact on market size or structure Not negative for business Cost effective measure to deliver energy savings Claim that improve security of EU energy supply Creates jobs Helps achieve climate and energy targets By 2020 yield: 600 TWh/yr of electricity savings (17% of EU total) 600 TWh/yr of heat savings (10% of EU total) 90 billion/yr savings for EU consumers and business
Directives Ecodesign Directive (Directive 2009/125/EC) Energy Labelling Directive (Directive 2010/30/EU) COMMISSION REGULATION (EU) No / of XXX implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for refrigerated commercial display cabinets COMMISSION DELEGATED REGULATION (EU) NO /.. of XXX supplementing Directive 2010/30/EU of the European Parliament and of the Council with regards to the energy labelling of refrigerated commercial display cabinets
To be included in Ecodesign >200,000 units sold annually in the EU Group has significant environmental impact, judged by the number of products in use Has significant improvement potential Process for assessment of product categories Lots Generally responsibility of Directorate General (DG) Enterprise and Industry (ENTR), and DG Energy (ENER)
What is included? Energy MEPS Labelling Environmental impact (throughout life of product) Material, energy and water resources Waste Emissions to air, water and soil Hazardous substances Physical impacts in the use phase Most refrigeration products use phase greatest environmental impact (refrigerant leakage under F-gas)
Theory behind regulation Provides incentive Difference result in market between MEPS and labels
Refrigeration ecodesign products Lot Product groups Regulation/ status Requirements mandatory from: ENTR Lot 1 Refrigerating + freezing equipment Regulations 2015/1095 and 2015/1094, both of 5 May 2015. Condensing units 01.07.15 Low and medium temperature process chillers 01.07.15 Professional cabinets 01.07.16 ENER Lot 1 Boilers, heating + combi systems Working document 2018 Foreseen review of regulations ENER Lot 2 Water heaters Working document 2018 Foreseen review of regulations ENTR Lot 6 Air-conditioning + ventilation Reg. 1253/2014 01.01.2016 systems ENER Lot 10 Residential ventilation Reg. 1254/2014 01.01.2016 ENER Lot 10 Room air conditioners + Reg. 206/2012 01.01.2013 comfort fans ENER Lot 11 Electric motors Reg. 640/2009 12.08.2009 Amendm. 4/2014 ENER Lot 11 Fans Reg. 327/2011 01.01.2013 ENER Lot 11 Water pumps Reg. 547/2012 01.01.2013 ENER Lot 12 Commercial refrigerators Working document Proposed?? + freezers ENER Lot 13 Domestic refrigerators + Reg. 643/2009 01.07.2010 freezers ENER Lot 21 High temperature process chillers Air heaters Comfort chillers Working document Proposed January 2018 Lot 31 Compressors Working document n/a
Domestic Applied from early 1990 s A+++ to D (wine A+++ to G) Updated in 2012 Includes: Refrigerator with one or more fresh-food storage compartments Refrigerator-cellar, Cellar and Wine storage appliances Refrigerator-chiller and Refrigerator with a 0-star compartment Refrigerator with a one-star compartment Refrigerator with a two-star compartment Refrigerator with a three-star compartment Refrigerator-freezer Upright freezer Chest freezer Multi-use and other refrigerating appliances BS EN 62552:2013, Household refrigerating appliances - Characteristics and test methods
Professional Applied from 1 July 2016 A/A+++ to G Includes: Vertical chilled Vertical frozen Counter chilled Counter frozen BS EN 16825:2016, Refrigerated storage cabinets and counters for professional use - Classification, requirements and test conditions Also requirement to supply energy for blast chillers
Commercial Supermarket refrigerators/freezers BS EN ISO 23953-1:2015 Refrigerated display cabinets - Part 1: Vocabulary BS EN ISO 23953-2:2015 Refrigerated display cabinets - Part 2: Classification, requirements and test conditions Beverage coolers EN 16902 Commercial beverage coolers - Classification, requirements and test conditions Small ice cream freezers FprEN 16901 Ice-cream freezers - Classification, requirements and test conditions Scooping gelato cabinets BS EN 16838:2016 Refrigerated display scooping cabinets for gelato Classification, requirements and test conditions Soft scoop ice cream machines EN 16764 Soft ice cream machines - Performance and evaluation of energy consumption Vending machines BS EN 50597:2015 Energy Consumption of Vending Machines
Commercial Draft regulations published in 2014 and 2016 Neither are comprehensive and so have to be used together European Commission Energy Efficiency Unit: further work of substantial nature is required to set the right level of ambition of the label classes and the MEPS requirements number of technical issues to be tackled that were identified in the draft regulations decision to temporarily put on hold further work on commercial refrigeration during 2017
Obligations Legal obligation for manufacturers and suppliers The manufacturer must: Ensure that product is manufactured in accordance with technical documentation file Declaration of conformity Product technical documentation, must include: References to the harmonised standards applied Results of the measurements and calculations for energy performance The supplier must: Provide the printed label and information fiche and also an electronic label and fiche for dealers Include reference to the label class in any advertisement containing energy-related or price information or technical parameters relating to the specific model
Testing No requirement to test every model BUT must label accurately Therefore by inference must have a mechanism to identify how much energy is used under test conditions Level of risk must be decided by manufacturer Compliance checked by Regulatory Delivery Office (ex. NMRO) in UK, part of beis Clear procedure for compliance checks If fail: Cannot sell product in Europe Possible fine
Market surveillance Historically low Across Europe only 5 member states considered to have active surveillance High profile product misrepresentation (e.g. VW) may be changing this higher political priority Test 1 model if: Volume/TDA >3% lower than declared Energy consumption exceed declared by >10% Randomly select 3 additional models for testing if: Average volume/tda >3% lower than declared Average energy consumption exceed declared by >10% The model and all equivalent models considered not to comply with regulation
Impact of energy labelling regulation update Better definition of updates Initial labels should have no A ratings (+ B in fast moving categories) European data base: Public Means for customers to compare products Compliance interfaces Test report or similar conformity assessment documentation
Why impact is not always realised Delays Lack of ambition Skewing of market through standards/methodology used Non compliance Lack of enforcement Benefit Negative
Professional eco-design experience Still after 1 year a level of non conformity Many companies not displaying label Number of companies early stages of testing Regulation in force before standard completed Freezers difficult to achieve good energy label Appears that trim/condensate heaters have effect (did data used to set regulations include them?) Small cabinets and some chillers advantaged
Professional eco-design Small cabinets advantaged, especially chilled counters Chilled counter uses same energy at almost 0 volume as a vertical chilled at 900 litres! Vol. SAEC increase by: Vertical chilled Vertical frozen Counter chilled Counter frozen x2 12% 14% 7% 11% 50-100 litres x2 62% 67% 46% 60% 600-1200 litres
RD&T Churchill Building Langford Bristol, BS40 5DU T: 0117 928 9239 E: rdandt@rdandt.co.uk www.rdandt.co.uk