ErP and product compliance

Energy Labelling of Space Heaters (ERP)

It is important that installers are aware of the regulatory requirements that apply to them following the introduction of the EU energy labelling requirements in 2015.

From the 26 September 2015 all space heaters up to 70kW should be supplied with an energy label showing the energy rating of the product on a scale from A++ down to G. This label allows customers to directly compare the efficiency of gas or oil boilers and heat pumps, and it is the responsibility of whoever sells the appliance to the end customer to inform them of this efficiency rating. In many cases this will be the installer, who will also have the responsibility to provide the customer with a further label indicating what the system efficiency will be when this space heater is combined with a temperature control or solar heating.

The regulation for space heaters includes a ‘package’ label that applies when the product is combined with other system components such as solar thermal or temperature controls. The package label must be produced even if the products are simply combined by an installer as part of an installation.

This means that installers need to produce a ‘package label’ when they install a temperature control with a boiler replacement (and the new Boiler Plus amendments to the Building Regulations require the installation of a temperature control with a combi boiler in an existing property.)

Heating installers, merchants, manufacturers, and imports of space heaters are affected.

  • Heating installers are often the ones who sell heating products to the end customer. This means that they take on labelling responsibilities as the ‘dealer' which include displaying the labels to their customers. Installers are now legally required to produce a ‘package label' when selling certain combinations of heating equipment to customers. This can be as simple as fitting a room thermostat with a boiler, and as this is required under the UK building regulations it could mean that you need to produce a package label every time you fit a boiler. 
  • Merchants or other retailers of heating products also take on labelling responsibilities as the ‘dealer' but only when they are selling to end customers. This means that they are required to display the labels with space heaters and to produce a ‘package label' if they sell space heaters to an end customer along with other items of heating equipment such as a separate temperature control. 
  • Manufacturers of heating controls need to indicate the ‘product class' of any temperature controls they place on the market so that they can be incorporated into a ‘package label'.
  • Importers of space heaters take on the responsibilities of ‘suppliers' which means that they need to produce the product label. This requirement is not limited to manufacturers but to anyone who places the product on the market.

The full regulation can be read at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0811

These regulations apply to all within scope space heaters placed on the market or put into service within the European Union and, before the terms of Brexit are known, this remains the case in the UK. The regulation itself is currently under review, with this likely to be complete in 2021.


Product Compliance

Non-compliance comes in many forms, from the deliberate launch into a marketplace of a cheaper, technically inferior product which does not meet the locally applicable standards, to intentional deception by exaggerating performance benefit claims.

The risks and consequences associated with non-compliant electrical products can be wide-reaching and include:

- Injury or death (possibly leading to legal action, fines or imprisonment)

- Damage to property

- Loss of business (ranging from an individual customer to an entire business)

- Damage to reputation (for selling or installing a product which has failed)

- Commercial implications (the cost of replacing the failed product)

- Inconvenience (due to lack of product performance or reliability)

Installers must be aware that these products present significant risks to people and property and carry serious consequences for the distributor and installer of such products, notable that non-compliant products will not ensure protection against fire or electrocution. You should choose your electrical products with care!

This check-list outlines simple measures to help you to safeguard against being deceived into buying non-compliant and/or counterfeit products.

General Quality indicators

* Imperfections in moulded case finish?

* Presence of poorly moulded excess material / jagged edges on the outer casing of mouldings?

* Visible corrosion of metal components (terminal clamps / screws)

* Is the product CE marked? (Indicates conformity   with all relevant European legislation)

 * Illegible, poorly aligned or smudged graphics, symbols or markings?

 Other Factors to Consider

* Purchasing Channel – do you know and trust the person / organisation offering you this product?

 * How does the weight of the product compare to similar products with which you are possibly      more familiar? (A lightweight product could indicate the absence of critical components).

 * Can your supplier provide you with a copy of a Type Test Certificate to prove compliance?

 * Does the Type Test certificate come from a recognised laboratory / authority?

*  Extreme care must be exercised if you are offered previously used electrical products as the service of these devices will be unknown.

 If you have any concerns or suspicions about the authenticity and/or the claims being made in respect of a product you should ask your supplier for documentary evidence of compliance and check with relevant test authorities if necessary. These actions are important to safeguard your customers and your business.