Raising product standards for space heating - Part 3: Ensuring Effectiveness - Department for Energy Security and Net Zero

Part 3: Ensuring Effectiveness

Within part 3 of this consultation, we are seeking to ensure compliance whilst minimising costs faced by businesses and, ultimately, consumers. As such, to maximise the effectiveness of ecodesign (813/2013), we propose:

to update performance benchmarks for space and combination heaters, to encourage technological developments in high-performing products
to allow boiler manufacturers to be able to self-certify their products
to narrow product verification tolerances and implement new standards to reduce circumvention – ensuring products perform as tested
to seek views on whether the scope of ecodesign (813/2013) should be expanded to space and combination heaters up to 1MW capacity, in order to address the range of unregulated products

50. Do you agree with the proposed benchmarks?

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Please provide evidence or reasoning to support your answer.

51. Should boiler manufacturers be permitted to self-certify their products against the three clearly identified new measures – on boiler modulation, open protocols and default low-flow temperatures – whilst still undergoing third-party testing to comply with the current standards?

Yes No Don't Know

Please provide evidence or reasoning to support your answer in the box below.

52. What potential cost rises would be incurred by (a) double testing for CE marking goods (b) adding testing requirements to receive a UKCA marking from UK-based Conformity Assessment Bodies?

Please provide evidence or reasoning to support your answer in the box below.

53. Do you agree with our intention to review compliance with the boiler regulations after 18 months and to revert to third-party testing for the new requirement if the compliance, as evidenced by the OPPS is inadequate?

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Please provide evidence or reasoning to support your answer in the box below.

54. Do you agree in practice that manufacturers will dual mark their products with both UKCA and CE markings?

Please provide your response in the box below.

55. Is there anything government should consider to support manufacturers to continue dual marking their products?

Please provide your response in the box below.

56. Do you agree with our proposal to limit the verification tolerance on seasonal space heating energy efficiency for fossil fuel boilers to 4%?

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Please provide evidence or reasoning to support your answer in the box below.

57. Do you agree that the verification tolerance for seasonal space heating energy efficiency for other space heaters and combination heaters, including heat pumps, should remain at 8%?

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Please provide evidence or reasoning to support your answer in the box below.

58. What are the potential benefits and drawbacks of reducing the amount of additional testing for space and combination heaters required for the OPSS to take enforcement action?

Please provide a response in the box below.

59. Do you agree that we should update our legislation to reduce opportunities for circumvention?

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Please provide evidence or reasoning to support your answer in the box below.

60. Do you agree with the proposed drafting of this in regulation 10 and regulation 15 of the draft SI?

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61. Are there any barriers to extending seasonal space heating energy efficiency levels for space heating to heaters between 400kW and 1MW in capacity?

Yes No Don't Know

Please provide evidence or reasoning to support your answer in the box below.

62. Will any of the proposals set out in this consultation result in disproportionate impacts on SMEs?

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If so, how might these be mitigated? Please provide evidence or reasoning to support your answer.

63. Do you agree that the legislation, as drafted, achieves our ecodesign objectives and reflects our proposals, as set out in this consultation?

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Please provide evidence or reasoning to support your answer in the box below.

64. Are there are additional policies, not covered in this consultation, you would like to see adopted under ecodesign for space heaters?

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If yes, please explain why they should be prioritised in the box below.