HHIC Boiler Technical Panel Meeting Summary
The HHIC Boiler Technical Panel meeting held on August 24th at Camden House covered various important topics including compliance with The Competition Act, discussions on RoHS 2 Directive, and updates from Regulatory Delivery on RoHS 2 and WEEE 2. Actions were outlined, and insights shared to address industry concerns and ensure regulatory compliance.
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Boiler Technical Panel Thursday 24thAugust HHIC, Camden House
1. Welcome and Apologies Apologies received from: Darran Smith Alpha, Mike Hook Biasi, Andy Dabin Ideal, Louis Pickersgill Ravenheat, Alister Maclachlan Vokera, John Thomason Atmos, Derek Warren - Ariston
2. The Competition Act Members are reminded of the requirements of The Competition Act: As a reputable trade association, HHIC s meetings must comply with the requirements of The Competition Act. This means that we must avoid any discussion that could be construed as being anti-competitive and in particular there must be no discussion about pricing of products and services. By attending this meeting and having your names included in the minutes, all participants confirm that they agree to comply with this policy.
3. RoHS 2 Directive background SS advised he was aware from RoHS discussions with BEIS several years ago that there could be an impact on installers from the RoHS Directive. EH responded that in 2013, it had been suggested that an installer bringing a system package together might need to declare and CE mark an installation as compliant, which was felt to be unmanageable by the group. It was agreed that HHIC should also seek clarification from BEIS (Mike Rimmer initially) on this point. ACTION: HHIC HHIC held a call to discuss with Regulatory Delivery (RD - Huw Jones) on Friday 19thMay The legal text of the Directive, its intended interpretation and application were discussed at length, although RD indicated that they are minded to adopt a common sense approach here. RD view this as a low-risk area, and RD are not inclined to burden installers with the obligation to CE mark installed systems, prepare DoC etc. when the individual products are expected to be compliant themselves
3. RoHS 2 Directive background RD have been invited to the next 11TP meeting in August, and in the interim have expressed a willingness to produce a draft paper, outlining their thoughts/views on these issues in writing. HHIC will monitor developments here and provide updates when and where possible.
3. RoHS 2 / WEEE 2 RoHS 2 Regulatory Delivery send apologies and the following statement: .Unfortunately we have been unable to make the progress that I think HHIC would have hoped, and I have not been able to find a colleague that is available to attend the meeting due to annual leave. However I do want to offer some reassurance with regard to our approach to the issue that HHIC have raised .
3. RoHS 2 / WEEE 2 Regulatory Delivery (RD) is the appointed Market Surveillance Authority responsible for the implementation and enforcement of the RoHS Directive in the UK. The team undertakes strategic and sector specific risk assessments in order to identify operators and products on which to focus, and employs a regime of engagement, product purchase and verification testing to improve compliance. Whilst RD enforcement officers investigate offences and bring these to resolution using a range of interventions, the work of the team is underpinned by the principles of better regulation and proportionality. Based on our assessment of risk and proportionality RD do not feel that domestic heating systems and the specific situation of UK installers making available a package of goods in what we consider to be a compliant market, presents risk and as such we will not be focusing this issue. As this is a domestic issue and limited to installers of such systems we do not feel that this will have an adverse effect on UK manufacturers that are operating outside of the UK. I hope that the above is sufficient to reassure your members and we will happily continue this dialogue with HHIC as an organisation or with individual businesses ..
3. RoHS 2 / WEEE 2 WEEE 2 HHIC email correspondence with the Evironment Agency ..Your email has been passed to the Environment Agency for response. I think there may be a little wider confusion regarding open scope and how this affects the equipment that is currently out of scope of the WEEE Regulations. They key point to consider with open scope is does the piece of equipment meet the definition of EEE? If it does, then that piece of equipment MUST fall within one of the 6 open scope categories, unless it falls within one of the specific exclusions or exemptions. If it does not meet the definition of EEE then it will continue to remain out of scope from 2019. Therefore items that are currently out of scope for not meeting the definition of EEE will remain out of scope.
3. RoHS 2 / WEEE 2 The producers who will be affected by open scope are those who produce equipment which meets the definition of EEE, but currently does not fit within any of the categories of EEE and are therefore currently out of scope (stair lifts being an example) With regards to boilers you should consider the primary function element of the EEE definition. In cases where boilers do not need electricity for the primary function they will remain out of scope. If there are boilers that do need electricity for the primary function then they will fall within scope. Apologies I cannot be more specific. However, as you are in the boiler industry yourself you may be in a better position to make a determination of the different types and functions of boilers.
3. RoHS 2 / WEEE 2 Exclusions - You can find items of EEE that are excluded from scope in Part 2, Regulation 8. Further information on EEE scope and the definitions of exclusions can be found in the European Union WEEE frequently asked questions document. Fixed installations; Large scale fixed installations are excluded from scope. Other fixed installations are out of scope until 1 January 2019. A fixed installation is: a combination of several pieces of equipment, systems, products and/or components (or parts) assembled and/or erected by a professional assembler or installer at a given place to operate together in an expected environment and to perform a specific task not intended to be placed on the market as a single functional or commercial unit Elements of a system that are not distinct EEE products in their own right or that do not have a direct function away from the installation are excluded from scope.
4. Previous minutes (24thMay) For approval
5. Matters arising HHIC boiler servicing guide - ACTION: HHIC to circulate draft guide once produced COMPLETE First draft circulated, HHIC are in the process of redrafting. Installer Committee members have some concerns around rigid compliance with manufacturers instructions in all instances, e.g. replacement of water gaskets. Also, the practicalities of tracking tiered servicing schedules (e.g. change of provider, no Benchmark record). Accuracy of smart gas-meters - ACTION: Members to advise if they have had any similar experiences, HHIC to consult IST group and enquire further with relevant parties (Gas-Safe- Register and/or gas-meter manufacturers suggested) COMPLETE An IST member was aware of only one site where the meters were replaced due to inaccuracy
5. Matters arising Circulators (Lot 11) - No concerns were raised by members over potentially pursuing a safety argument, with members feeling this was a legitimate, factual course of action, given the ongoing uncertainties raised by EHI over impact on existing appliance certifications (e.g. GAD, LVD, EMC) where a part (e.g. integrated circulator) which differs to the design specification is required to repair an installed appliance. ACTION: HHIC to update Mike Rimmer (BEIS) COMPLETE, awaiting EHI progress and position following EU review study BRE paper Predicting the performance of domestic electrical heat pumps in UK homes 55 C flow temperature assumption for HW storage T17 0087 circulated in advance of the meeting by HHIC. After discussion, the group feel that different standards and criteria are being applied to heat pumps when compared with boilers, which seems unfair. ACTION: SS to write to Will Griffiths (BRE) for clarification ?
6. Status of UK Notified Bodies post-Brexit Directives such as GAD/GAR, and Boiler Efficiency Directive derived elements of ErP, require third-party certification Whilst much concerning Brexit is unknown at this time, is the pursuit of mutual recognition (as exists now between EU member states) something the UK heating industry wants to see?
7. BRE request Will Griffiths (BRE) has written to HHIC regarding a potential technical auditing test procedure for appliances, based on market intelligence, and also randomly. BRE would appear to have a framework in place, although BEIS have no funding for this exercise, so they have suggested HHIC may consider a funding pot, also dependant on BRE winning the contract for the SAP/SBEM work, which is up for tender. Will has advised that product performance data held in the PCDB is manufacturer declared (and owned), and is interested to know whether HHIC might be interested in managing some form of fund, potentially via subscription, for use during technical audits, and based on feedback from certain manufacturers that are disappointed in perceived over-reporting by others (as well as random testing). There is likely to be a cross-over with other trade associations who may wish to be involved, and it may or may not be appropriate that a single fund is created, although this would likely need apportioning appropriately per technology type. BRE would not wish to handle this fund.
7. BRE request BRE s initial thoughts are that this fund would be used to fund their time (if their bid is successful) in administering technical audits, i.e. selecting products, liaising with stakeholders, processing test results, and amending product data records. To avoid conflicts of interest, BRE would also use a third-party contractor to commission test laboratories (who would then purchase samples), based on a competitive tendering process and with reference to the funds available. They have stressed that this is just a concept at this time, but would welcome HHIC s view?
8. BEIS proposal costs of PCDB listing HHIC have been contacted by BEIS concerning their contract with BRE, and the listing of new appliances on the PCDB. BEIS advise that they have been subsidising the full cost of product listings since PCDB inception in 1999, and are now considering making changes so that the manufacturer bears the full cost, e.g. 125 for new boiler listing would become 400, MCHP listings would rise from 300 to 700 BEIS feel this situation (cost-sharing) may not be common knowledge, and are looking to gauge some opinion from industry as to whether these changes would represent a fair approach?
9. Hybrids Five manufacturers have now agreed to proceed with the SAP methodology for Hybrids. BRE are in the process of revising the documents to include costs . ( costs per manufacturer) HHIC to invoice manufacturers accordingly. Methodology to include series and parallel systems.
10. Heat in Buildings Government consultation, full title Heat in Buildings The future of Heat Ran from 8thDecember 2016 to 27thJanuary 2017 Considered several policy options which might form the basis of new regulation to drive energy and carbon savings at the time of appliance replacement Considered mandatory weather-compensation, alongside other options HHIC met with BEIS in early March at the Domestic Heat Strategy Group, to consider and discuss their initial appraisal of consultation feedback, and potential next steps
10. Heat in Buildings Latest thinking by BEIS (show document)
10. Each Home Counts final report recommendations The introduction of a new Quality Mark The review proposes to establish a quality mark for all energy efficiency and renewable energy measures, and for all companies operating in this sector. Those who wish to use the quality mark will need to adhere to three key elements which, together with the quality mark, make up the new framework: A Consumer Charter which ensures that all consumers receive excellent levels of customer service, a clear redress process and guarantee protection; A Code of Conduct which sets out how companies behave, operate and report, the requirements of which must be met or exceeded for the company to operate; and Codes of Practice which are relevant to the installation of each measure under consideration so that the risk of poor quality installation is minimised. This will enable the consumer, who seeks to have retrofit work done to their property, to know instantly what to look for to receive high-quality installations or advice.
10. Each Home Counts Review of HHIC letter to Greg Clark MP (Secretary of State - BEIS) & rationale for drafting Stewart Clements (HHIC Director)
10. Each Home Counts Dear Alison, I have received a reply from Margot James MP, a copy is attached for your convenience. I must point out that the Minister may have jumped the gun regarding HHIC s engagement given that we said at the meeting, if we had in writing from BEIS that; Manufacturers were excluded from new accreditation schemes for their products Installers would not have to pay for the Each Home Counts Quality Mark to install products We would recommend to our members that they re-engage. Two weeks from our meeting, we have received no such confirmation, consequently we are not able to make any recommendations to our members. I look forward to hearing from you in due course. Yours sincerely Stewart Clements Director
12. IGEM gas pressure WG See HHIC meeting notes
13. Opening up the Gas Market 90% of appliance test standard checks are carried out on G20 gas. If headroom is to be lost, as with any potential move to 53.25 MJ/m3, the test standards should first be amended or new ones developed to reflect this. There was comment that many appliance test standards (e.g. EN 15502 suite) are European standards, used by the likes of Spain and France, who operate with a higher WI than the UK. However, it was not known what their CO incident statistics are in comparison, with the UK felt to have an excellent track record here. It was also said that countries such as Spain may not necessarily have national legislation pushing product efficiency as much as the UK, and so perhaps the appliances may be manufactured and/or commissioned with greater excess air to offset the higher WI? Factors such as the mandatory gas registration scheme operated in the UK might also be considered to have raised standards in safety and incident reduction in comparison to other EU countries As work within the EU continues to assess changes to the WI (under EC mandate) then potential changes to CEN standards may equally be as relevant for other countries
14. Hydrogen & Gas Quality 14.1 HyDeploy HHIC facilitated a recent meeting for manufacturing members at KIWA Gastec (technical consultants to project). Some key topics of discussion, with lab testing set to begin in August: - - - - G24 test gas to be used (lab testing)? lower CO2 levels (increased water vapour) higher temperatures (components & seals) ODS operation? 14.2 Frazer-Nash (FNC) meeting - FNC commissioned by BEIS to consider the options, and necessary steps, for the development of domestic appliances to burn Hydrogen. A broad range of discussion, encompassing the drivers (inc. Govt. policy decisions) for Hydrogen R&D, and consumer considerations. Technical discussion focused on the specific components for appliances, and the level of difficulty and evolution required in adapting or re-engineering these for Hydrogen.
14. Hydrogen & Gas Quality 14.3 BEIS 25m project fund tender process for project manager now complete (work package 1). Awaiting announcement of successful applicant. 14.4 Siloxanes HHIC have requested the full project report from DNV GL & project stakeholders, which was taken as an action at the last IGEM Gas Quality WG meeting. It was said that sharing is possible given that the project was NIA funded. At the IGEM meeting, it was noted that the apparent suggested maximum value of 0.23 mg Si/m3 is at the limits of commercially available detectability, and this may pose problems. There is currently no clear plan for the industry stakeholder event referred to in the project submission document, to disseminate project findings, and gain acceptance of these by industry. HHIC can feedback any comments or questions members may have on this topic, through the IGEM group
15. Standards update 15.1 BS 7593; BSI are currently convening a panel to revise this standard (Code of practice for treatment of water in domestic hot water central heating systems). HHIC will participate on behalf of members, to have sight of drafting and contribute as appropriate. We will keep members informed on this important topic 15.2 UP/17; secretariat (IGEM) draft circulated, some comments received, HHIC will join the committee once it convenes 15.3 EN 437; CEN Enquiry draft (update of national situations approved) 15.4 TC 109 - review of CEN consultants comments on EN15502-1. Work on going on intelligent combustion controls and. Discussions at next meeting regarding changes to Wobbe. Adhoc group still reviewing potential test standard where the boiler is the lead appliance.
16. Benchmark / Gas-Safe-Register partnership Talks continuing between HHIC, HSE, Gas-Safe-Register & Capita HSE have confirmed a 150,000 funding contribution to the project HHIC Benchmark Steering Group to meet on 5th September
17. Energy Labelling rescale The European Commission has now published the new Energy Labelling Framework Regulation in the Official Journal. The Regulation came into force on 1 August 2017, directly applicable in all Member States, and a copy can be found at: http://eur-lex.europa.eu/legal- content/EN/TXT/PDF/?uri=CELEX:32017R1369&from=EN
17. Energy Labelling Rescale The Commission should review the label for heating products within 8 years after the entry into force of this new framework Regulation (2025), with a view to rescaling them. Where appropriate, adopt the rescaling delegated acts by 9 years after the entry into force of the new Framework Regulation (2026). Adopt rescaling delegated acts no later than 13 years after the entry into force of the new Framework Regulation (2030). Once heating products are rescaled, only the top class (A) should be left empty (In the initial Commission proposal, both classes A and B would be left empty after rescaling) Subsequent rescaling: the Commission should review product groups with a view to rescaling them when it estimates that their top classes are overpopulated. This happens when 30% of the products sold are in efficiency class A or 50% of products sold are in classes A and B.
17. Energy Labelling Rescale Database Only some parts of the technical documentation have to be uploaded in the confidential part of the database. These include: Measured technical parameters of the model; Calculations performed with the measured parameters. The final set up of the database will be determined by an Implementing Act (stronger role of Member States than in Delegated Acts). The database should be set up by 1 January 2019. Equivalent models are not included in the public part of the database any longer; they will be included in the confidential part.
18. A.O.B. Any other business? Erp Lot 5 EcoDesign requirements for electronic displays see HHIC email UP/17 Do UK manufacturers produce and supply C4 (CFS) & C8 (CFS-EO) appliances for the UK market, specifically twin-flue product options? Date of next meeting: Wednesday 15th November (HHIC, 10:30)
