Hywel Davies describes some of the standards that support the Eco Design Framework Directive and the European Energy Performance of Buildings Directive.
There are an increasing number of British and European Standards and other EU rules relating to the design of building engineering products and systems.
They may not make for the most exciting reading, but they are increasingly important in determining what products can be placed on the market. Manufacturers and services engineers need to show that their products and their work are up to the standards.
The Ecodesign Framework Directive, 2009/125/EC, commonly known as the ErP Directive, sets minimum environmental performance requirements for dozens of product groups.
Its primary focus is on energy performance in use, whether that is the energy the product uses or the impact the product has on energy use where it is installed.
All energy-using products sold in the domestic, commercial and industrial sectors are covered by this Directive, apart from means of transport, which are covered by other legislation.
The Directive also covers all energy-related products that can influence energy used in a building, including windows, insulation materials, and shower heads or taps.
The ErP Directive is supported by the Ecodesign labelling framework Directive, which sets rules for labelling and providing standard information on the energy and other resources used by energy-related products.
It is generally acknowledged that the energy used over the life of a product is strongly influenced at the design phase of the product and by the system into which the product is installed.
So the ErP Directive aims to improve the environmental performance of products throughout their life by considering the raw materials used and the manufacturing, packaging and distribution processes, installation and maintenance, as well as use and final disposal at the early stages of product design.
It seeks to remove disparate national environmental performance rules that create obstacles to trade within the European market.
It is intended to benefit both businesses and consumers, by facilitating free movement of products and by enhancing product quality and environmental protection.
The “framework” Directive sets out overall performance criteria rather than prescribe specific measures, standards or overall energy saving targets for individual product groups, which are given in “implementing measures” that set specific requirements for each product group, often as EU Regulations which have direct effect in all Member States.
Conflicting laws are superseded by the EU Regulation, so that the new rules come into effect across the EU at the same time.
Manufacturers must meet the requirements of the Regulation in order to legally place their product on the market.
Requirements for product energy labels to give consumers energy and environmental information are being adopted alongside the Ecodesign measures, and these labelling requirements are mandatory across the EU.
The Commission has identified a long list of product groups to be covered by the Directive, including many domestic appliances (standby power use amounted to some 10 per cent of total domestic energy demand in 2005).
Implementing measures are introduced following initial study and discussion of the proposals with key stakeholders and national regulators.
Manufacturers who market a product covered by an implementing measure in the EU must ensure that it conforms to the energy and environmental standards set out by the measure.
Commercial and industrial air-conditioning and ventilation systems as well as refrigeration and freezing systems were covered under the workplan from 2009-11, which resulted in a number of preparatory studies being undertaken by the Commission to inform the specific measures for those products.
As a result of this work, a new EU Regulation was adopted in March 2012 to implement the ErP Directive for mains-operated air conditioners with a rated capacity of <–≤ 12 kW for cooling, (or heating if there is no cooling function), and comfort fans with a power input <–≤ 125W.
Regulation EU 206/2012 introduces specific eco-design requirements for these products, setting out values for minimum energy efficiency, maximum power consumption in off-mode and stand-by mode, and maximum sound power level and product information requirements.
The regulation covers three product groups: air conditioners, except double duct and single duct air conditioners; double duct and single duct air conditioners, and comfort fans. It requires manufacturers to provide the information that shows that the product meets the standards either in product technical documents or on their website. The requirements came into effect on 1 January 2013.
It is worth noting that air conditioning systems over 12 kW rated output have been subject to regular inspections under the Energy Performance of Buildings Directive (EPBD). Sadly, these are proving difficult to implement due to a systemic failure of enforcement.
The EPBD also sets requirements for calculating and certifying the energy performance of buildings.
This Directive is the reason why Building Regulations require whole building calculations and also the reason for having Energy Performance Certificates.
Article 3, “Adoption of a methodology for calculating the energy performance of buildings”, requires Member States to “apply a methodology for calculating the energy performance of buildings in accordance with the common general framework set out in
This may be “adopted at national or regional level”, which allows for separate rules in England, Wales, Scotland and Northern Ireland. This is just as well, as it allows for separate regulations and standards in the four parts of the UK (and in Federal States such as Germany and Austria and Belgium.
Annex I sets out a “Common general framework for the calculation of energy performance of buildings”, which covers heating, cooling and domestic hot water as well as lighting, insulation, internal loads and airtightness.
It stipulates that the Member States’ methodology should take into account both European Standards and “relevant EU legislation, including [the Renewables Directive]”.
The Directive does not require Member States to adopt European Standards, but there is an increasing tendency for the EU to use standards to support the implementation of European legislation. Although Member States currently have scope to adopt their own methods, that scope is increasingly constrained by emerging standards.
As well as adopting the EPBD in 2003, the Commission instructed the European Standards body, CEN, of which the British Standards Institution (BSI) is the UK member, to develop a set of standards on the calculation of energy performance.
The first instruction was issued in 2004, and the standards were published in 2007-8. In 2010, when the recast EPBD was adopted, CEN was issued further instructions to revise the original standards.
This took the form of a “Standardisation mandate for the elaboration and adoption of standards for a methodology calculating the integrated energy performance of buildings and promoting the energy efficiency of buildings, in accordance with the terms set in the recast of the Directive.”
Since then, CEN has been busy working on the revised standards, and the first drafts are now out for public enquiry.
Under public procurement law, public purchasers are expected to specify by reference to standards. And since BSI has to adopt all European Standards as British Standards, they find their way into public purchasing.
Under the Construction Products Regulation, CE marking against a European Standard or Technical Approval is now mandatory.
So for all the talk of standards being voluntary, they are unavoidable for construction products.
And the Mandate for the energy performance standards says clearly that standards “increase the transparency, accessibility and objectivity of energy performance assessment in the Member States, facilitating the comparison of best practice and supporting the internal market for construction products”.
This sets out a clear direction of travel for the EPBD related standards.
Standards are written by committees which are drawn from all of the CEN members, with input from each of the participating standards bodies.
They are also open to public enquiry, when anyone is allowed to review the standard and suggest improvements or changes.
Once the comments are collected, the technical committee has to work through them and address each one before producing a final draft. Until recently, that would then go for a formal, and final, vote.
But now, if there are no significant technical changes at the enquiry stage, that formal vote may not be required. The public enquiry stage is therefore very much a case of “speak now, or forever hold your peace”.
There are a number of drafts dealing with Energy Performance of Buildings, at various stages of public comment.
These are all parts of EN 16798, covering various aspects of ventilation and calculations relating to building performance.
This is a chance to influence what goes into the standards. Miss it and the next chance could be a little while coming.
More generally, it pays for trade bodies to keep an eye on the relevant standards committees, to see what is coming down the line, and to contribute while the opportunity is offered.
Otherwise, the standards will arrive and have to be met, regardless.
Hywel Davies is technical director at CIBSE - www.cibse.org