Lot 20 - The end?
Luke Cronshaw
Smiling to the left whilst manufacturing Controllable Low Carbon, Electric Heating and Hot Water for Housing Associations, Local Authorities and House Builders.
Did Lot 20 - Catch you off guard on the 1st January? Were you prepared? - Here's my summary of this new legislative change that's sweeping the EU.
On January 1st the electrical heating industry experienced one of the biggest transformations in decades, the adoption of Lot 20 - part of the eco-design directive 2009/125/EC. This directive is already changing the landscape of available products throughout the European Union.
Lot 20 dictates that all local space heaters for sale in the EU must comply with the rules set out in the directive or become obsolete, even if manufactured outside the EU. So how will this affect the customer and the industry as a whole?
Eco Design Directive
What must be understood is that the Eco-design directive and Lot 20 come from a drive to improve energy consumption in any and all energy-using products, it's forcing progress and innovation. This directive provides a framework of basic requirements to make products as efficient and environmentally friendly as possible. When we consider how much energy is used per day in each household it’s easy to understand why we need to improve efficiency.
Take a look at your house, think of how many things use energy; gas boilers, washing machines, vacuum cleaners, TVs, computers, lighting, phone docking stations, EV Car chargers, microwaves you name it! Practically everything uses energy, whether it be electricity, solid fuel or gas. If each of these products aren’t improving in efficiency and governments are struggling to hit carbon reduction commitments what can we do? Have the equivalent of an energy hosepipe ban? I doubt it.
In our view the Eco Design directive is a good thing, and Lot 20 is certainly long overdue. Many a time have we faced competition from cheap inefficient products and clients have opted for the cheapest option for them, sadly it ends up being the most expensive option for their tenants, causing a sustained level of fuel poverty. The option of inefficiency has now been removed and has opened up a whole new market of efficient technologies.
Lot 20 specifically applies to electrical space heating such as storage heaters, electrical panel heaters and infra red heaters etc. Hence why I’m writing this article, our EconoRad? falls within this legislation.
How will Lot 20 affect electric heating?
All local space heaters manufactured after 01.01.18 will have to meet a minimum efficiency rating displayed as a percentage. The percentage is different for each specific heater category, however, the majority of electric heaters will begin with a base rating of 30%.
The efficiency rating is determined by how many energy saving features are incorporated into the product. Products without any functions won’t be compliant and are prohibited for sale within the EU, manufacturers that create cheaper, low end heaters may disappear from the market or have to drastically improve the quality of their products. So, simply put, 750W rocker switches, mechanical thermostats, basic dial controls are a thing of the past! The loss of these clunky, expensive to run heaters will help to promote innovation, encouraging manufacturers to develop new ways of improving product efficiency and control.
Products classed as ‘fixed electrical local space heaters’ must have a minimum of a 38% efficiency rating if they have a heat output above 250 Watts. Products that fit into this category are electric radiators, infra red heaters and panel heaters. Products such as portable electric space heaters, storage heaters and heaters below 250 watts have separate targets.
Price hike for the customer?
Although this legislation is a seismic change in our industry, the price of heating products to purchase shouldn’t rocket to 10 times the price of a heater purchased at Christmas, there are only a few changes that manufacturers need to make in order to bring their products in line with the legislation. Yes there may be a slight increase but nothing drastic – in fact the Eco Design Directive explicitly states that it “should not affect the functionality or affordability of local space heaters from the end-user's perspective and should not negatively affect health, safety or the environment.”
This however may be a concern for those of you who are committed to maintenance contracts where you have to replace like for like units - if legislation dictates that the old products are no longer available and the manufacturers have had to make improvements who will bear the increase in cost? - Hopefully you will have found a clause which states that changes in legislation may affect the agreement.
What we will hopefully see towards the end of this year is the acceptance of paying for higher end products which deliver superior results to traditional methods. Indeed the increase in storage heater prices which are now compliant, now fall within our EconoRad? price bracket meaning we don’t have to compete on price, we compete on all areas of products and service which is great for our industry.
What are the efficiency measures to look out for?
Fixed electric local space heaters gain a 7% bonus to its rating if it comes equipped with electronic room temperature controls and a weekly programmer. Our EconoRad? units come with these as standard due to our exclusive relationship with Honeywell. With this feature alone, many electric heaters will already be within range of hitting their efficiency target.
Correction factor F(1) for electric storage local space heaters
If the product is equipped with (only one option may apply): F(1) is increased by
- Manual heat charge control, with integrated thermostat = 0,0%
- Manual heat charge control with room and/or outdoor temperature feedback = 2,0%
- Electronic heat charge control with room and/or outdoor temperature feedback or controlled by energy supplier = 3,5%
In case the heat output of the electric storage local space heater is assisted by a fan, an additional 1,5 % shall be added to F(1).
If the product is equipped with (only one option may apply): F(2) is increased by
- Single stage heat output, no room temperature control 0,0%
- Two or more manual stages, no temperature control 0,0%
- With mechanic thermostat room temperature control 1,0%
- With electronic room temperature control 3,0%
- With electronic room temperature control plus day timer 5,0%
- With electronic room temperature control plus week timer 7,0%
If the product is equipped with (multiple options may apply) F(3) is increased by
- Room temperature control with presence detection 0,0%
- Room temperature control with open window detection 1,0%
- With distance control option 1,0%
- With adaptive start control 1,0%
- With working time limitation 0,0%
- With black bulb sensor 0,0%
As I said earlier – rocker switches are a thing of the past. Further improvements in functionality and efficiency add bonus points
Heaters that include an open window detection feature, Wi-Fi compatibility, or an adaptive start system will be over the 38% efficiency line. If they feature two or more of these features, they’ll be offering above the requirements set out by the new legislation. Just like the EconoRad? which comes out at a staggering 40%
Overall
Lot 20 is a great move for our industry, however due to it's unknown nature many maintenance contracts, supplier contracts and purchasing commitments are hurriedly being reviewed now due to slight increases in cost for replacement like-for-like units. Once the dust has settled for the organisations that were unprepared, the focus on innovative technologies should push us all to do better.
I’ve mainly focused on fixed electric space heaters for this article but the legislation also encompasses gaseous and liquid fuel based heaters, as well as storage heaters, electric underfloor heating and radiant heaters.
When looking to upgrade your heating make sure that you get the best and most appropriate Lot 20 compliant system for you.