SEAI has been undertaking market surveillance relating to the compliance of solid fuel local space heaters available on the Irish market and we would like to inform you of our findings from this work. We will also discuss the introduction of new Ecodesign requirements relating to solid fuel local space heaters which enter into force on the 1st January 2022.

1. Ecodesign and energy labelling
requirements for solid fuel local space
heaters
14th December 2021

2. Agenda
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Introduction
Background to market surveillance
Findings from market surveillance activities to date
Ecodesign requirements from 1st January 2022
Future activities in 2022 and Compliance guidance
Questions

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Impacts:
• 1/3 of EU's 55% emissions
reduction target for 2020
• 500 Mt CO2 equivalent less
greenhouse gas emissions
• Above assumes 100%
compliance!
REGULATION

4. Market surveillance – what and why?
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Compliance
advice
Enforcement
(civil and
criminal)
Upload to
ICSMS
Follow-up and
enforcement
Inspections
Technical
documentation
checks
Screening
testing
Laboratory
testing
Monitoring &
verification
Published
guidance
Advice
Stakeholder
engagement
Compliance
promotion
• To maintain a level playing
field
• An international ‘game'
• Vital component of the EU
product harmonisation
system

5. Responsibility for implementation of ecodesign and energy labelling
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• Minister is currently Market Surveillance Authority for EU ecodesign, energy labelling and
tyre labelling legislation – MSA to be transferred to SEAI
• Responsible for Energy Labelling policy and legislation
Department of Environment, Climate and Communications
• Responsible for Ecodesign legislation and policy
Department of Enterprise, Trade and Employment
• Supports the MSA through organising market surveillance
Sustainable Energy Authority of Ireland
• Provides advocacy on behalf of Irish business in relation to development of EU ecodesign
and energy labelling regulations
Enterprise Ireland

6. Products covered by Ecodesign and Energy Labelling
• Air conditioners/comfort fans
• Air heating and cooling products
• Circulators
• Computers
• Domestic cooking appliances
• Electric motors
• External power supplies
• Household dishwashers
• Household tumble dryers
• Household refrigerating appliances
• Household washing machines
• Enterprise servers
• Industrial fans
• Light sources
• Local space heaters
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• Power transformers
• Professional refrigeration
• Refrigerating appliances with direct sales
function
• Simple set top boxes
• Solid fuel local space heaters
• Solid fuel boilers
• Space heaters
• Standby and Networked Standby
• Televisions and electronic displays
• Vacuum cleaners
• Ventilation units
• Water heaters and hot water storage tanks
• Water pumps
• Welding equipment

7. SEAI’s approach to market surveillance
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Collaboration (nationally, internationally, stakeholders)
Strong emphasis on compliance promotion
Monitoring/deterring non-compliance
Technical engagement – seek to understand

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• 110 retail outlets inspected annually for energy labelling compliance
• 85 websites and 20 advertisements assessed annually – labelling
compliance
• Around 130 products per annum subject to detailed compliance
assessment across 15 – 20 product categories
• 30 to 40 products tested per annum
• Meetings with industry stakeholders (5 to 10 per annum)
• 1:1 meetings with individual economic operators
• Compliance guides, this year:
– Guide to energy labelling in advertisements
– Tyre labelling guide
– Statement on provision or display of UK energy label
• Marketing campaigns e.g. energy labelling rescaling
SEAI activities (typical)

9. • Applicable legislation:
• Solid Fuel Boilers:
– Commission Regulation (EU) 2015/1187 - energy labelling of solid fuel boilers (and
packages) – in force since 2017
– Commission Regulation (EU) 2015/1189 – ecodesign requirements for solid fuel
boilers – in force since 2020
• Solid Fuel Local Space Heaters:
– Commission Regulation (EU) 2015/1185 – ecodesign requirements for solid fuel
local space heaters – in force from 2022
– Commission Regulation (EU) 2015/1186 - energy labelling of local space heaters –
in force since 2018
Market Surveillance of Solid Fuel Appliances
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10. • Market surveillance activities to date:
– Stakeholder meeting in September 2019 identified intention to undertake market
surveillance
– January 2020, technical documentation requested for:
• Solid fuel boilers: 5 manufacturers, 7 products – energy labelling & ecodesign
• Solid fuel local space heaters: 12 manufacturers, 17 products – energy labelling
Market Surveillance of Solid Fuel Appliances
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11. • Covid-19 impact – somewhat disjointed engagement and responses
• Solid fuel boilers:
– Broadly satisfied with extent of technical documentation from most manufacturers–
some aspects corrected through engagement
– Potential to look at further products and consider testing
• Solid fuel local space heaters:
– Level of engagement generally poor:
• 4 manufacturers provided no responses
• 6 manufacturers provided partial responses
• Only 1 manufacturer provided a complete response
Market Surveillance of Solid Fuel Appliances
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12. • Solid fuel local space heaters - issues observed:
– Provision of calculations supporting seasonal space heating efficiency/EEI
– Contents of the product fiche
– Provision of technical information – ‘Table 2’ of Annex V of Regulation 2015/1186
– EPREL registration
– ‘Re-badged’ products and obligations in this regard
– ‘Type’ testing (boilers also)
Market Surveillance of Solid Fuel Appliances
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13. • Undertake conformity assessment to produce a Declaration of Conformity before
placing a product on the market
• Placement on the market:
– “making a product available for the first time on the Community market with a view
to its distribution or use within the Community, whether for reward or free of charge
and irrespective of the selling technique”
– Manufacturer or importer only - applies to each individual unit of a product
– Requires an offer or agreement between two entities for transfer of ownership, after
manufacture has taken place
Ecodesign requirements for SF Local Space Heaters (from 2022)
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14. • If a solid fuel local space heaters is placed on the market before the 1st January 2022,
the ecodesign requirements do not apply.
• Conformity assessment: the process carried out by the manufacturer of demonstrating
whether specified requirements relating to a product have been fulfilled – ‘internal
design control’ or ‘management system’
• Declaration of Conformity: manufacturer ‘declares’ that the product complies with the
applicable legislation; specific content (Art. 5, Annex VI of Directive 2009/125/EC);
correlation with Construction Product Regulation requirements
Ecodesign requirements for SF Local Space Heaters (from 2022)
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15. • Ecodesign requirements – performance related parameters:
Ecodesign requirements for SF Local Space Heaters (from 2022)
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16. • Ecodesign requirements – information requirements – in manuals, on websites etc:
Ecodesign requirements for SF Local Space Heaters (from 2022)
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Table 1, Annex II
Regulation 2015/1185

17. • Other items of note:
– Review process – to consider stricter limits for efficiency and emissions, to be
completed by 1 January 2024
– Appropriateness of 3rd party certification (along with solid fuel boilers) - at draft final
report stage; recommendation to apply 3rd party certification:
• For local space heaters, in line with notified body provisions under the Construction Products
Regulation
• For boilers, use of accredited 3rd party labs
(https://www.3rdpartysolidfuel.eu/)
Ecodesign requirements for SF Local Space Heaters (from 2022)
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18. • Other items of note:
– Energy Labelling – UK Labels
– EPREL – new requirements on
registration (tbc)
– Advertising requirements - suppliers
(manufacturers, importers) and dealers
(retailers)
– Online sales requirements
Ecodesign requirements for SF Local Space Heaters (from 2022)
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19. • Intention to further examine solid fuel local space heater compliance in Q1 2022
• What will we be looking for to assess compliance – ecodesign and energy labelling:
Future Market Surveillance Activities
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20. • Guidance available:
– Solid Fuel Local Space Heater - Ecodesign and Energy Labelling Guidance Note:
https://www.seai.ie/publications/Solid-Fuel-Local-Space-Heater-Guidance.pdf
Advertising Guide:
https://www.seai.ie/publications/SEAI-Advertising-Guide.pdf
– Retailer Guide to Online Energy Labelling:
https://www.seai.ie/publications/A-Retailers-Guide-to-Online-Energy-Labelling.pdf
– Retailer Guide to Energy Labelling:
https://www.seai.ie/publications/A-Retailers-Guide-to-Energy-Labelling-In-Store.pdf
Guidance Available
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21. Questions