BSJ preview the Energy-using Products Directive

Changes are coming in the way many energy-using products are designed – and specified – thanks to the upcoming Energy-using Products Directive (EuP) from Brussels.

For building services engineers it is early days to be concerned about what will be agreed among the European Union, national governments and trade associations. But agreements might reduce the number of products on the market. Also, regulations arising from the EuP could mean a move towards services engineers having to give energy ratings for the complete systems that they install.

Exactly what shape the EuP regulations will take is not yet clear. They may stipulate that it is not the individual product which is rated but the entire heating system. Some people and organisations are in favour of this, notes Hywel Davies, technical director at CIBSE. But, he warns, the devil will be in the detail – “People will ignore this directive at their peril.”

The Market Transformation Programme (MTP), the UK government body entrusted with ensuring the marketplace offers products in line with national sustainable policies, has targeted 19 product groups, or “lots”. These range from laptops and lawn mowers to commercial boilers and street lighting.

The EU believes that EuP can reduce Europe’s energy consumption by about 10%. Since the EuP was published in July 2005, the MTP has been organising product analysis – completing preparatory studies – to see where energy savings can be designed in, or “eco-designed” according to EU parlance.

For some months now manufacturers have been huddled with their consultants, technical directors and EU groups to set the criteria their products must begin to meet by the end of 2009 (see graph overleaf). Final details will be decided by the MTP, DEFRA and the Department for Business, Enterprise and Regulatory Reform (BERR).

But to get there, a series of consultations, proposals based on production possibilities, and technical performance must be navigated.

There is, however, a clear intention for the EuP to avoid in-depth legislation on design. Rather, it should encourage voluntary action by manufacturers to eco-design their products.

Implemention could be through amendments to the Building Regulations. Or, if the EU thinks it could save time and political hassle, says CIBSE’s Davies, Brussels could issue a European regulation that must be implemented with no national debates. That could come hard and fast and catch people off guard.

Pumps

Looking at the wider system could hold energy saving answers, says Steve Schofield, technical director at the British Pump Manufacturers Association (BPMA). The EuP process for electric motors, that includes among other items water pumps, is likely to reach the EU-wide Consultation Forum stage by early spring. Within the forum, Schofield is the nominated representative for Europump, the umbrella body for all major pump manufacturer organisations across Europe.

The preparatory studies have focused mainly on the wet end of the pumps, the hydraulics, explains Schofield – an area where efficiency gains can be at most 4%. He says focusing on the pumping system itself could yield gains as high as 37%.

For the pump sector in the UK, the total electricity consumption is estimated to be 361TWh (terawatt hours) a year, of which pumps consume 47TWh. About 41% of that is accounted for by water pumps in public and commercial buildings. Tweaks to the hydraulics would save only around 4TWh.

However, if the entire pump system is considered for regulation, much more energy could be saved. “Most public and commercial buildings are closed systems and so pumps could use variable speed drives that operate the pump much more efficiently and save electricity. Savings across Europe if this approach was adopted could be as high as 35TWh,” says Schofield.

The way it stands, if hydraulics is the main focus of the MTP, about 40% the current range of pumps will cease to be manufactured by 2020 because of a phase-in period for makers to meet efficiency and CE requirements. Of course other products will supersede them, says Schofield. But it will cost pump manufactures within Europe around ¤370m in redesign and new product costs to achieve this.

Schofield is hopeful that the tables will turn within the year and the commission will review the potential of a systems approach. The BPMA recently visited Joan Ruddock, minister for

climate change, biodiversity and waste within the DEFRA. She endorsed a future systems approach within the pump industry as a method of saving energy.

Fans

Fan makers were a bit uneasy at first about the EuP, says Geoff Lockwood, technical director of ebm papst UK and chairman of the Fan Manufacturers Association. Any regulations can cost manufacturers money to implement. To focus on the fan itself means an energy saving of only 10% or less.

Lockwood says the MTP is coming around to the idea that more savings – up to 30% – can be achieved if regulations focus on better installation. Manufacturers of large air-handling units might install a very efficient fan, but it will be run at less-than-optimum temperatures and speeds. Therefore, the fan is not the best product to move that particular amount of air against that particular amount of resistance.

Lighting

The three lighting lots – office, public (street) and domestic – are furthest towards EuP regulations, notes Nic Mallinson, marketing manger at the Lighting Industry Federation. The lighting sector welcomes energy-saving initiatives and the phasing out of incandescent bulbs is part of the regulations that meet the EuP Directive. In particular, retailers will stop selling 150W bulbs this year, 100W bulbs next year and 60W bulbs in 2010.

Boilers

“There is a problem with extrapolating data from domestic products into commercial applications,” says Yan Evans, technical director of Baxi Commercial Heating. So far the focus has been on domestic boiler products of 20kW. The rationale is that most heating appliances are for the domestic sector – 70% of all homes use central heating boilers. Therefore, domestic use must account for the majority of energy consumed and the resulting carbon emissions.

However, Evans argues that the ratio between emissions from commercial and domestic applications is in fact 50:50 and the EuP model should reflect this.

The final effect of the EuP may be to discourage innovation and lengthen the launch of new products to market.

Only now are the EU consultants beginning to fully understand that the issue is much more complex for large commercial boilers, says David Hughes, technical director at Icom Energy Association. “It is not likely that a manufacturer will be able to sell a product without some form of solar or ground source heating system within the next five years. This is not necessarily a bad thing, but not many manufacturers are ready for that now.”

Hughes also believes service engineers could be lumbered with having to rate entire systems for energy efficiency, something they are typically not trained to do. Otherwise, the rating will be done by product manufacturers through their collaborations with each other. Their recommendations of what products to use in a complete heating system would give an energy efficiency rating.

There lies the rub, says Cedric Sloan, director- general of the Federation of Environmental Trade Associations (FETA). “The EuP is a monster that is getting out of control. It was always intended to be a product-related directive and it should remain just that. But there has been regulatory drift from consumer products into commercial products and now into systems.”

This approach means there would be ratings for entire systems, for example, when renewable technologies such as solar hot water and ground-source pumps are coupled with gas boilers. Building services engineers would have to install complete systems and not be able to choose different brand components.

Also, says Sloan, the MTP does not appear very interested in looking at whole-life costs of products as required in the EuP. The coming year will see a struggle to focus the consultation forms on product-related regulations, while the government will be trying to increase the number of lots.