Implementation of Ecodesign Regulation in 2022

This article was first published in HETAS Technical Bulletin #24 (login required).

HETAS over the last couple of years have been raising awareness to industry stakeholders in relation to the impending regulatory changes stipulated within Ecodesign. Responsibilities for both HETAS registered installers and approved retailers can be found in guidance notes GN003I and GN003R in the technical hub of the HETAS website, and back in the July 2021 Technical Bulletin (edition #22), HETAS covered the topic surrounding responsibilities for installers of installing and commissioning second hand appliances. 

With the legislative changes coming into force next month, below is a reminder of those responsibilities and information on changes which may impact the sale and sale of solid fuel burning products. 

Ecodesign Requirements 

From 1^st January 2022, any newly manufactured roomheater stoves under 50kW placed on the market will be required to meet the minimum seasonal efficiency and maximum permitted emission limits stipulated within Ecodesign. “Placed on the Market” covers any product made available for the first time from the manufacturer production line, either for distribution, consumption or when placed into the supply chain in exchange for either payment or free of charge.  

Products verified as already being placed on the market before the 1^st January 2022 are not encompassed by the regulations, meaning they are eligible for installation, even if the installation date comes after the enforcement date on the 1^st January. 

Manufacturer Responsibilities 

HETAS approved manufacturers will need to ensure those products manufactured for both the UK and EU markets meet the more stringent limits for efficiency and emission stipulated within the regulation. 

Minimum efficiency limits have been strengthened against those currently stipulated within UK Building Regulation Part L requirements, requiring roomheaters to meet a minimum efficiency limit of 68.3% gross (75% net). 

New maximum emission limits have now been introduced for Particulates (PM), Organic Gaseous Compounds (OGC), Carbon Monoxide (CO) and Nitrogen Oxides (NOx), and all newly manufactured will need to meet these requirements and have independent testing verifying this. 

Installation & operating instructions provided by the manufacturer will need to clearly reference the performance criteria under test for both efficiency and emissions, alongside any accompanying technical material, including declaration of performance and/or product fiche. 

Retailer Responsibilities 

Any retailers or importers of manufactured products will again need to ensure that if the product has been placed on the market after the 1^st January that it meets the newly required efficiency and emission limits. As stated above, simple checks can be made on the performance via technical documentation accompanying the product, including instructions or the products declaration of performance. 

Alongside this, it is important for any retailer marketing websites and literature to make reference to both the emissions and efficiency limits verified, alongside additional details on the products design under operation. All sales websites shall ensure this information included to allow for ease of choice by consumer looking to purchase solid fuel burning appliances. 

Installers Responsibilities 

Registered installers will likely have a host of queries upon enforcement of Ecodesign on 1^st January 2022. It is important to know that Ecodesign encompasses all space heating devices, essentially any appliance which provides heat into the room in which they are installed as a means of providing thermal comfort to the user. This will include roomheater stoves, roomheater stoves with a boiler (those providing mains central heating for the property), as well as traditional open fired heating appliances. 

If the appliance being installed has been newly placed on the market from 1^st January 2022, then it will need to meet Ecodesign requirements. All approved products listed on the HETAS website have been independently verified as meeting the requirements of Ecodesign, a list of which can be found here 

For those appliance verified as being placed on the market before 1^st January, then these can legally be installed, even after the enforcement date of Ecodesign. If the installer is unsure of the date in which the product was placed on the market, then declaration from the manufacturer can be obtained directly. It is advised that these declarations are obtained in writing for due diligence purposes and should any future queries arise relating to the product installed. 

Further Guidance – contact the HETAS Technical Helpline

Further information on Ecodesign can be found via guidance notes hosted in the Technical Hub of the HETAS website or by contacting the helpline team here at HETAS, either via email at technical@hetas.co.uk or via call on 01684 278170.

HETAS Registered businesses can access Technical Bulletin #24 along with all of the previous editions of HETAS Technical Bulletins in the dedicated HETAS Technical Hub of the website.