1 st AHWG MEETING ON HYDRONIC CENTRAL HEATING SYSTEMS. 28 nd June 2011, Sevilla, DG Joint Research Centre, IPTS. Minutes.

Transcription

1 1 st AHWG MEETING ON HYDRONIC CENTRAL HEATING SYSTEMS 28 nd June 2011, Sevilla, DG Joint Research Centre, IPTS Participants List Minutes First Name Last Name Organisation Country Karl-Heinz Backhaus Vaillant GmbH DE Alicia Boyano European Commission, JRC, IPTS Alenka Burja European Commission Annelise Capon EPEE (association) company Daikin BE Mauro Cordella European Commission, JRC, IPTS Luis Delgado European Commission, JRC, IPTS Peter Eder European Commission, JRC, IPTS Michele Galatola European Commission Jose Luis Galvez European Commission, JRC, IPTS Aurelien Genty European Commission, JRC, IPTS Renata Kaps European Commission, JRC, IPTS René Kemna VHK NL Frank Kienle HKI Industrieverband DE Florian Kohl Albermarle Europe BE Jiannis Kougoulis European Commission, JRC, IPTS Kepa Larruzea Fagor electrodomesticos, s. coop. ES Tony Newson Eurofer BE Thomas Nowak European Heat Pump Association BE (EHPA) Gunnar Olesen EEB/BEUC Elena Rodriguez European Commission, JRC, IPTS Riccardo Rompari RIELLO S.p.A IT Alberto Sabido OECC ES Colin Timmins BEAMA UK Luigi Tischer Robur, Heat pump heating and IT cooling systems Jens Schuberth Umweltbundesamt DE Anne Stein Ifn Anwenderzentrum GmbH DE Roy van den Boorn VHK UK Cuno van Geet NL Agency NL Dirk van Hessche PlasticsEurope BE Piet van Luijk Ministry BKZ/DGWWI NL Paul Vaughan UK Ecolabel Delivery UK Charlotte Vincentz Fischer Ecolabelling DK DK Standards DK Foundation Oliver Wolf European Commission, JRC, IPTS Lukasz Woźniacki EEB/BEUC 1

2 Introduction The European Commission explained the background and the political context of the criteria development process for Ecolabel and the link between Ecolabel criteria and Green Public Procurement (GPP) criteria development. A draft technical report and the draft working document including a proposal for criteria areas, available at the project website ( constituted the key inputs to the meeting. The Commission explained that the main purpose of this meeting was a discussion on the proposed criteria areas and not on the precise values or formulations of the criteria. The discussions at the 1st AHWG meeting and the resulting feedback will form the input into development of the draft final criteria proposal for Ecolabel and GPP, which will be discussed in the 2nd AHWG meeting, which is planned in late November this year in Brussels. General overview on hydronic central heating systems First, an overview of the background information on hydronic central heating systems was presented, including: the definition of the product group and its scope, economic and market data, and a base-case environmental assessment. The feedback received in these areas is summarized below. Scope of the product group There was general agreement on the product scope, and especially because of its consistency with the product scope of the draft Ecodesign implementing measures (May 2011) for boilers. A number of stakeholders expressed and supported their preference for the use of the term 'heating generators' or 'heat generation' rather than 'heating systems'. Otherwise, the word 'system' might be confused with its possible meaning as "combination of the heating generator with other heating distribution components in a building". Rather, the approach of the present 2

3 Ecolabel/GPP criteria development is to address heating generators encompassing a diversity of heating technologies, being simultaneously evaluated under the same overall process of Ecolabel/GPP criteria development. Stakeholders raised a point regarding a potential overlap between the current Ecolabel/GPP criteria development exercise for 'heating systems/heating generators', and the existing EU Ecolabel criteria for heat pumps. The European Commission proposed to split the EU Ecolabel for heat pumps into air-based and water-based heat pumps, and let the latter ones move into the generic 'heating systems/heating generator' label. Feedback is welcome from stakeholders regarding this or alternative proposals. There was wide support for the "systems approach" of the study, meaning that the study compares different heating technologies under the same methodology, following a technology neutral approach where no technology is excluded a priori from the analysis. As was the case with Ecodesign discussions on boilers, it was mentioned that the maximum power capacity of the scope should be expressed not in terms of input power as in the current draft, but in terms of output power instead. This is because output power is the parameter of interest from the point of view of the purchaser of a heating generator. Some experts supported a modular approach in Ecolabel of heating systems, where this Ecolabel can be integrated into the Ecolabel for buildings. A question was raised whether, in addition to a single heating generator, also "combinations of heating generators offered by a manufacturer" or "combinations of heating generators as installed by an installer" would be part of the scope. Indeed, combinations of heating generators (hybrid products) are part of the scope as long as they are sold as a package in the market. As will be seen later, the life-cycle analysis includes among the 9 base cases some hybrid generators (combinations of heating technologies in one sold product). There were questions whether district heating should be part of the scope. However, several reasons discourage the idea of including district heating as part of the scope. First, there are no Ecodesign studies for district heating. Second, district heating is usually not an option available to final consumers of heating generators, but instead it may or may not be available as a heating option to a given building depending on the building location. Finally, the heating capacity of district heating is designed to service a large number of buildings or a neighborhood; 3

4 therefore, the heating capacity and the intended application of district heating are of much larger size than the scope of the present Ecolabel/GPP criteria development. Stakeholders pointed out that it is also important to take the fuel type into account. For example, when addressing biomass boilers, sometimes the environmental performance of the heating generator could be mainly contributed by the specific properties of the biomass fuel (e.g. pellets, briquettes, etc.). Regarding the power capacity maximum limit of 400 kw in the scope, it was mentioned that this limit was considered in Ecodesign but not in Energy Label. Our approach in selecting 400 kw as the maximum power capacity limit is because it is consistent with Ecodesign of boilers and with the Boiler Directive. Therefore, the current scope follows Ecodesign for boilers, but not the Energy Label for boilers in this case. At the same time it was mentioned by stakeholders that the Energy Label is focused on private consumers (domestic sector). However, the current Ecolabel/GPP criteria development will cover both domestic and non-domestic sectors (as is the case in the scope for the Ecodesign of boilers). According to GPP representatives from member states, it will be necessary as one of the next steps to gather information about how heating generators are procured in practice, so as to be in a better position to develop the GPP criteria. It was also mentioned that sometimes public procurers are faced with a restricted number of choices regarding heating generators. For GPP we are at an early stage and we appreciate any feedback from stakeholders on requirements for procurements in practice. Economic and market data The economic and market data presented were generally agreed. However, it was suggested to try to use more recent data if available, and to take technology change and innovation into account. Base-case environmental assessment There were concerns that the 9 base cases do not represent all possible heating systems within the scope. However, the 9 base cases were selected in an attempt to cover a comprehensive 4

5 number of heating technologies including hybrid systems that are representative of typical packages sold in the market. In addition, even if a specific technology (e.g. a particular type of heat pump technology) is not included in the base cases evaluation, it does not mean that it is not eligible for Ecolabel/GPP criteria; it only means that the analysis of the 9 base cases was considered sufficiently representative to develop the criteria for the whole group of 'heating generators'. Also, the Ecolabel/GPP criteria will be valid for a few years, and therefore the criteria will be revised later on. At that point, new technologies will be taken into account in the scope revision. Some concerns were raised that if we do not include the most innovative technologies (even if not widely existing in the current market) then we risk not giving incentive for procurers to choose new, innovative technologies. The Commission responded that the Ecolabel will in fact encourage new technologies because it provides a signal to the market regarding excellent environmental performance, and the best environmentally performing products available in the market. Some stakeholders asked for revising some of the values of the LCA analysis. Some values on efficiency for certain technologies were regarded as questionable and should be checked. It was pointed out that some types of air pollution parameters (e.g. dioxins) should also be taken into account. Further analysis was suggested is needed on: solar heating systems: including a revision of their environmental impact analysis, the assumptions regarding recycling of solar panels, on heavy metal emissions, hazardous waste emissions, etc. biomass boilers: some questions were raised regarding the accuracy of efficiency values (these were adapted from the Ecodesign Lot 15 study conducted by BIO and these numbers and assumptions will be checked); questions were also raised relative to why automatic biomass boilers appear to be less efficient than manual biomass boilers, and on some questionable values on air emissions; it was also suggested that a conversion factor for biomass could be introduced in order to exclude the worst environmentally performing products. cogeneration: questions were raised as to whether the LCA analysis included a bonus for electricity generation, and if not then how the analysis will differ by including the 5

6 bonus for electricity generation (further checks will be made to detail the assumptions behind the LCA analysis of cogeneration units). boilers: some experts suggested that, while the current technical analysis treats oil and gas boilers in the same way, in fact these two should be treated separately. Regarding the electricity mix used in the analysis, it was suggested using a more updated value. In principle, it would be possible, but only as long there are official updates available and agreed. It was also suggested to use the updated ErP methodology. Process leading to criteria areas & Common benchmark approach The JRC presented the process leading to the selection of the relevant criteria areas for ecological criteria development for heating generators. The process is based on analysis of the results from the base case analysis, together with analyzing the criteria developed in Ecodesign, Energy Label and other national environmental labels. In addition, the common benchmark approach followed in this study was introduced. The criteria areas are grouped in key and additional criteria areas, and include: (1) key criteria areas: energy efficiency, based on the "seasonal space heating energy efficiency" greenhouse gas (GHG) emissions (2) additional criteria areas: other air emissions: NOx, particle matter (PM), organic carbon (OGC), carbon monoxide (CO) indoor/outdoor acoustical noise criteria related to design of materials: preventing the use of hazardous substances and materials criteria related to design of materials: promotion of reuse, recycling and generally a sound end-of-life management corporate criteria (including user information) 6

7 The common benchmark approach was proposed as a weighted combination of the key criteria areas: energy efficiency and GHG emissions. The common benchmark approach was generally supported, although some concerns were also expressed regarding potential difficulties in its practical implementation. For example, while energy efficiency and GHG emissions are agreed to be the key criteria and part of the common benchmark, additional requirements (other criteria areas including other air emissions, installation instructions, etc.) could be different from technology to technology; in this regard, a suggestion was received to structure the Ecolabel/GPP criteria with a general body of criteria (applicable to all technologies), and appendices dedicated to different technologies. A stakeholder suggested a possible minimum energy efficiency level of 80% for the common benchmark, and a maximum GHG emissions threshold of 200 g CO 2 /kwh heat output. Stakeholders at the meeting suggested that an 80% efficiency goal is almost the same as that of Ecodesign and therefore not ambitious enough for an Ecolabel. Most experts agree that the energy efficiency requirement of a possible common benchmark needs to be higher than 80%. Since the common benchmark approach is one of the core parts of this Ecolabel/GPP project, the European Commission proposed to set-up a dedicated working group of experts within the AHWG who could specifically focus on this aspect; this idea received support at the workshop from different stakeholders. Key criteria areas energy efficiency and GHG emissions The Commission presented the key criteria areas: energy efficiency and GHG emissions Energy efficiency Most stakeholders see energy efficiency as a first criteria area to look at, a kind of filter to pass before looking at other environmental criteria. There was wide support to using the concept of "seasonal space heating energy efficiency" as developed in the draft Ecodesign implementing measures for boilers. However, while it was agreed to be consistent with the energy efficiency measurement as developed in Ecodesign, the Ecolabel should be more ambitions in order to target the top 20% of products. 7

8 A suggestion from some experts regarding energy efficiency is that it might not be necessary because products are covered already by e.g. Energy Label. A possibility to reduce additional burden from the Ecolabel is to require a certain energy efficiency level expressed as one of the ratings of the Energy Label (e.g. a minimum A++ required). In principle we cannot easily imagine Ecolabel criteria not explicitly including energy efficiency criteria (they exist in all environmental labels). But it is also an interesting suggestion to incorporate the Energy Label which will increase consistency with existing product policy schemes. Further feedback on this issue is welcome. It was suggested also to follow the development of the smart grid, that is, to define energy efficiency so that it can be measured in equipment that is able to turn on/off as part of a smart grid system. Other experts suggested that smart grids are not currently available in the market and therefore not really in the scope of the present Ecolabel criteria development. A stakeholder perceived some difficulties in trying to set energy efficiency criteria for renewable and non-renewable sources together. The argument between renewable and non-renewable is often a political discussion, and different opinions on the advantages of renewable vs. nonrenewable technologies are dependent on which aspects are looked at: for example, renewable technologies often show less energy efficiency, however also advantages because of reduced GHG emissions. Experts mentioned that the energy efficiency in different national labels is calculated under different definitions and different testing methods. Therefore it is important to understand and take into account how these different efficiencies are expressed, so that the comparison between different ways to calculate energy efficiency is accurate. Several stakeholders supported the idea of picking perhaps the two top energy label classes for energy efficiency, and then introduce criteria for other environmental areas. Several stakeholders suggested that the energy efficiency threshold should be set so that the gas condensing boilers are included. It was pointed out that there is a technical link between NOx emissions and energy efficiency, so maybe an alternative to setting energy efficiency criteria could be to set a limit on NOx emissions instead. 8

9 GHG emissions The TEWI methodology was considered a good approach, and there was wide support for it. One stakeholder expressed that it could be interesting if we could add to TEWI some criteria concerning ensuring the long-term maintenance of the high performance of the heating generating product. In addition, it could be required from the manufacturers to provide information on how their products have ensured a long-term performance (e.g. in heat pumps that there is no refrigerant loss, or otherwise that alternative approaches are followed to guarantee the long-term performance of the heat pump). Additional criteria areas other air emissions, noise Experts agreed that other air emissions are important parameters that need to be part of the Ecolabel/GPP criteria; the question is how to take them into account to avoid discrimination of some heating technologies vs. others. Different technologies have emissions of different substances, so it will be difficult to set a single set of criteria common to all technologies. Experts provided information regarding the connections between some air emissions and others. These connections are important to be considered when developing the air emissions criteria. One of the open issues was identified regarding what is the link between NOx and SOx emissions. NOx is much more harmful for the environment, so that the focus should be on NOx. At the same time, the SOx emissions have been solved to a large extent (the main reason that a SOx limit was introduced in the past is because of safety reasons). Some links were identified between CO and VOC emissions. CO emissions could be used as an indicator: e.g. if CO emissions are low, then often VOC emissions are also low (and if only CO needs to be measured, this will result in lower testing costs). Some links were also identified between CO and NOx. If NOx emissions are high (high environmental impact), then CO emissions tend to be low (CO is considered mainly a safety issue); so there is a trade-off between these two types of emissions. Some experts suggested that CO should not be a criterion. CO is more of a safety issue and not the scope of Ecolabel criteria development. Instead of CO, what should be measured are other parameters such as 9

10 organic carbon (OGC). Other stakeholders said that CO contributes to ozone depletion (especially in summer), so it is not only a safety issue but also an environmental issue. Finally, it was also mentioned that a CO emissions limit should be part of the criteria for biomass boilers. Noise was also discussed at the Ecodesign regulatory committee. The conclusion was that there is too limited data, and therefore threshold values could not be set. Nevertheless, noise could be a relevant criterion e.g. for cogeneration boilers which can make quite noise. Some of the data (e.g. Blue Angel for cogeneration) are somewhat outdated and will be revised soon. It was added that noise is becoming an important issue for customers, but until now it has not been part of a certification process; much data still missing for many product groups. For larger scale appliances, higher limit values would be necessary. The noise level would also depend on the location in the building where the heat generator is installed. Other experts mentioned that sound measurements are conducted already according to EN Additional criteria areas criteria related to design of materials The Commission presented additional criteria areas concerning design of materials, in particular: - material composition (preventing the use of hazardous substances and materials), - recycled material content, - design for repair / warranty and spare parts, - design for recycling. For some stakeholders, the criteria on hazardous substances and materials are "lower weight" criteria. In their view, a horizontal mandate already includes the same topics and will become an element of designing products. As a result, it seems like existing policies on limiting hazardous substances would overlap with the development of Ecolabel criteria regarding hazardous substances. It was mentioned that Technical Committee 299 will work on environmental criteria such as material, consideration on the use of products, etc.; this project has a time horizon of about 2 years. 10

11 Regarding WEEE, this Directive concerns only electrical and electronic products (even not all of them, with the scope of WEEE under revision), certainly not gas appliances. Under the WEEE Directive, products connected to hydronic systems are not covered by WEEE. Regarding hazardous substances, a suggestion was mentioned regarding terminology: to use the term "criteria for chemicals", rather than criteria for heavy metals, or criteria for flame retardants. It was mentioned by stakeholders that lead is not a plasticizer but a stabilizer for PVC and that it will be ceased in a few years time. Imposing criteria on small chemical contents seems irrelevant for this kind of product (if you compare with air emissions from use along the lifetime of the heating products). Nickel is classified as a suspect carcinogen. Nevertheless in stainless steel it is not, and therefore stakeholders require derogation for Ni in stainless steel (it is already given in other products such as toys). Some levels of impurities are also allowed for Hg, Pb and Cd, so that the phrase total ban is not correct. Ni is bioavailable but the products have very low levels of release. Flame retardants are a very diverse group of chemicals. Regarding the 6 chemicals given, not all of them are banned from now on, but they will be banned only after a certain date. Blue Angel criteria for example restrict flame retardants, and some stakeholders at the meeting gave support for restricting flame retardants. Halogenated flame retardants have been banned, but the ban is not effective until a few years from now. Some stakeholders suggested referring to the RoHS Directive instead of adding criteria independently by the Ecolabel, while other experts perceived difficulties in listing RoHS Directive in Ecolabel. The Blue Angel criteria for example contain some requirements on plastics, and it was suggested that these could be transferred to EU Ecolabel criteria development. There was support for having criteria on manufacturing. In Blue Angel for example there are some requirements on horizontal issues like recyclability, requirements on plastics, etc. 11

12 Additional criteria areas corporate criteria The Commission presented the corporate criteria: packaging, consumer information/user instructions, and information to appear on the Ecolabel. Some experts believe that corporate criteria are rather a topic for a quality label, but of no environmental relevance. One criterion not mentioned in the working document that could be relevant was suggested: how to ensure the constancy of performance of a product (e.g. how to guarantee that the efficiency is maintained over the lifetime of the product). It was also suggested that the Ecolabel criteria should take into account external factors (e.g. infrastructure which must be put in place). One possibility is to require an extended guarantee of e.g. 5 or 10 years. Regarding accredited installers, it could be required to have installers from the EU-27. Due to the long lifetime of the product group, a point was raised regarding whether the criterion on packaging should be dealt with or not, as it does not appear to pose a large life-cycle environmental impact. Some stakeholders expressed that the working paper emphasizes too much the importance of packaging. It was also pointed out that halogenated plastics are not used for this kind of product. For some experts, packaging should be considered a horizontal issue. Regarding installation requirements, many stakeholders supported it, but some diverging views were also expressed. In support, it was said that information for consumers on how to use the product correctly should be included, because a correct installation can have a very large impact on the overall environmental performance of the product. In opposition, for example, it was said that installation requirements are the member states responsibility, and therefore they are not an appropriate issue for Ecolabel, as this is already covered by other policy instruments. Others supported this position, saying that information for a customer should be given, but the information should refer how to choose the right product for the right installation. It was also suggested that, instead of having consumer and installation information printed, it could be made available online. Our AHWG needs to decide what to include in the Ecolabel logo (what will be written on the label after the criteria are set). The information to appear on the label is an issue that should be discussed at a later stage in the process. 12

13 Hydronic central heating systems and Green Public Procurement (GPP) As mentioned before, the GPP work is still at an early stage. We appreciate feedback after this meeting, and we encourage stakeholders who have access to the procurers to submit any information to us with contact details so that we can gather relevant information that will help designing useful GPP criteria. Some overall suggestions - Do not introduce new testing requirements. As much as possible use the existing product policy criteria and the existing testing methods. - Installation guidelines are a very important issue, because a correct installation can have a large impact on the overall environmental performance of the heating product. - On certification of testing, there was general agreement with third-party certification. There was also support for using only test and calculation standards based on existing European standards. Nevertheless, these different standards are not 100% comparable among each other and among different product groups; thus, the methods should be assigned explicitly per product group, keeping in mind that they are not entirely comparable. - Small working groups will be set up: e.g. for the common benchmark approach, and for testing and verification. 13