Regulations can have a major impact on manufacturers in the building services industry. Dr Lee Herbert, Engineering Manager at Powrmatic, discusses the issues with reference to warm air heaters.
It is no exaggeration to say that regulatory changes which impact our industry have been coming thick and fast in recent years – at least in the context of product development cycles. Whilst some of these changes have only required relatively minor ‘tweaks’ to existing products, there are more significant changes in store that will have far-reaching effects.
In some respects these may be seen as a nuisance, not least for relatively small manufacturers in a relatively small industry – which characterises many heating manufacturers. However, from a manufacturer’s perspective the more significant changes also provide an impetus to completely re-visit the way we do things. Not just in terms of product design but also how we manufacture the products – taking advantage of the latest technologies at every opportunity.
For that reason, whilst the main drivers for these changes are clearly to minimise environmental impact, I believe they will also drive innovations that have wider-ranging benefits for all stakeholders. For that reason, I believe that most UK manufacturers will continue to align themselves with European regulations beyond Brexit.
From the perspective of a company that manufactures warm air heaters in the UK, there are two key regulations being introduced through the Ecodesign Directive that will make their presence felt in a few years. These illustrate how some regulations are relatively easy to accommodate, while others are more challenging.
“The Ecodesign Directive allows the Commission to regulate the minimum performance of products. As a consequence, it ”pushes” the market away from the worst performing products. In addition, the Energy Label classifies products remaining on the market according to their efficiency, with an A to G scale (A being the most efficient and G the least efficient). It thus “pulls” the market towards more efficient products by better informing consumers. For some product groups, the most efficient products are identified through the Ecolabel “flower.”
The graphic below shows the integration of several policy instruments to generate a “push and pull” effect on the market.
The first of these takes effect from 2018 and will require that gas fired warm air heaters have a seasonal efficiency of at least 72% with NOx levels not exceeding 100mg/kWh The majority of warm air heaters on the market are already capable of meeting this NOx target but the seasonal efficiency limit may well rule out the use of single stage burners on some models.
A later change in 2021 will introduce more significant changes with seasonal efficiencies increasing to at least 78% and with allowable NOx levels falling to 70mg/kWh.
A major impact of this 2021 regulation is that warm air heaters will need to be condensing and some models will need to deploy pre-mix burners. There are both pros and cons to this.
An advantage is that gas fired pre-mix burners offer more compact flame patterns, thereby enabling use of smaller combustion chambers. On the other hand, the heaters will become slightly larger and heavier due to the use of secondary stainless steel heat exchangers.
From the contractor’s perspective, the switch to condensing will necessitate arrangements for removal and disposal of condensate, increasing costs for the end user. However, there will also be a faster return on investment due to improved energy efficiency.
Alongside these changes relating to combustion, there are also new regulations relating to the efficiency of motors (2017) and fans (2020). These too will serve to increase the overall cost of warm air heaters.
Such profound changes mean that minor adjustments are no longer sufficient to achieve compliance. As indicated earlier, this has given manufacturers a strong incentive to completely re-think their approach to product design and manufacture, working closely with component suppliers to identify innovative, value engineering solutions that help mitigate potential cost increases. We are already looking at some radical developments that will enable our products to take advantage of more current technologies.
Whilst most of the onus of compliance falls on manufacturers it is important not to lose sight of the potential impact on installers as changes in design will inevitably influence installation procedures. In the case of warm air heaters these changes will predominantly relate to controls, which will need to be more sophisticated.
For these reasons, any extensive changes to products also require manufacturers to undertake training and education, ideally before the new regulations come into force so that compliance is assured from the outset. This is another pressure on manufacturers but cannot be ignored. For example, it is our intention to introduce products that will comply with the 2021 regulations by 2018, backed by extensive training of approved installers.
In using warm air heaters as an example, this article has sought to highlight the impact of regulatory change and the pressure it puts on manufacturers. In the longer term, though, these changes will benefit all stakeholders and justify the effort and financial investment that manufacturers are making now in readiness for the future.