Testing – what will be required once eco-design and labelling is in force?

Once again the date for implementation of commercial refrigeration (refrigeration with a direct sales function) eco-design and labelling has been changed. The new implementation date is 1 March 2021. The latest draft Regulations include a number of significant changes:

Products no longer excluded:

1. Custom made appliances made on a one-off basis.
2. Built-in cabinets.
3. Vertical static air cabinets.
4. Back wall cabinets in assisted service placed behind the serving personnel.

Products that are now excluded:

1. Frozen vending machines.
2. Serve-over fish counters with flaked ice.
3. Refrigerated drum vending machines.
4. Professional refrigerated storage cabinets, blast cabinets and process chillers (this is primarily a clarification as these cabinets are part of existing eco-design and labelling Regulations which are already a legal requirement).

Others changes:

1. Some clarifications to definitions and obligations have been applied.
2. Further clarifications on tolerances for compliance testing are added for net and gross volume and total display area (TDA).
3. Circumnavigation is better described and clearly banned.

The method to calculate the energy label has not been changed and the inputs used to calculate standard annual energy consumption are all the same.

The latest draft eco-design and labelling requirements for commercial cabinets includes information on how cabinets shall be ‘specifically tested and approved’. This means that the product must comply with the following requirements:

1. it has been specifically designed and tested for the mentioned operating condition or application, according to the European legislation mentioned or related acts, relevant Member State legislation, and/or relevant European or international standards;
2. it is accompanied by evidence, to be included in the technical documentation in the form of a certificate, a type approval mark or a test report, that the product has been specifically approved for the mentioned operating condition or application;
3. it is placed on the market specifically for the mentioned operating condition or application, as evidenced at least by the technical documentation provided for the product and any advertising or marketing materials;

Previous eco-design and labelling requirements for other products have been far less prescriptive and have not included a specified need for technical evidence and reports on the performance of products. The reason for this new requirement is that products must be listed on a European product database for energy labelling (EPREL, see previous news article at https://www.rdandt.co.uk/news/labelling  for more information). Such evidence can be obtained by independent testing such as that carried out by RD&T. Alternatively manufacturers can self-certify products and in this case witness testing (where self-certified test data is independently checked and validated) can be a useful means to ensure that standards are correctly applied and information is correctly interpreted. RD&T can currently independently test or witness test according to the following standards:

Commercial cabinets:

• BS EN ISO 23953 (part 1 and 2):2015 or BS EN ISO 23953:2005+A1:2012
• BS EN 16902:2016. Commercial beverage coolers. Classification, requirements and test conditions
• BS EN 16901:2016. Ice-cream freezers. Classification, requirements and test conditions
• BS EN 16838:2016. Refrigerated display scooping cabinets for gelato. Classification, requirements and test conditions
• BS EN 16754:2016. Artisan Gelato and ice cream machinery. Performance characteristics and energy consumption
• BS EN 16764:2016. Soft ice cream machines. Performance and evaluation of energy consumption

Vending machines:

• BS EN 50597:2018. Energy consumption of vending machines

Professional cabinets

• BS EN 16825:2016. Refrigerated storage cabinets and counters for professional use. Classification, requirements and test conditions
• BS EN 17032:2018. Blast chillers and freezers cabinets for professional use. Classification, requirements and test conditions
• BS EN ISO 22041. Refrigerated storage cabinets and counters for professional use. Performance and energy consumption

We can also consider testing or witness testing to other standards. Please do contact us if you think we can help. For more information contact Judith Evans at RD&T (j.a.evans@rdandt.co.uk).

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