Final eco-design regulation for refrigerating appliances with a direct sales function
As we previously reported (https://www.rdandt.co.uk/news/new_eco-design_regulations) the final eco-design regulation for refrigerating appliances with a direct sales function (terminology for commercial appliances) was published on 1 October 2019. The eco-design regulation is almost identical to the draft regulation published in March 2019 and so there is little new for manufacturers to have to deal with.
Minimum energy performance standards (MEPS)
The MEPS have not changed from the last draft produced, but are lower than in the early drafts of the regulation produced by the Commission. The MEPS are:
- From 1 March 2021:
- Ice-cream freezers: EEI <80
- All other refrigerating appliances with a direct sales function: EEI <100
- From 1 September 2023:
- Ice-cream freezers: EEI <50
- All other refrigerating appliances with a direct sales function: EEI <80
The MEPS and energy labels will be reviewed 4 years after implementation of the regulation. It is stated that this will include: energy efficiency index levels, the energy efficiency formula, tolerance levels, potential further segmentation of product categories, inclusion of new categories, potential change to the use of volume or area as a metric for efficiency and a greater emphasis on the circular economy and inclusion of spare parts.
What is included?
The regulation does not apply to all commercial appliances. The following are excluded from the regulation:
- Appliances powered by energy sources other than electricity.
- Remote components, such as the condensing unit, compressors or water condensed unit, to which a remote cabinet needs to be connected in order to function.
- Food processing refrigerating appliances.
- Refrigerating appliances for the storage of medicines or scientific samples.
- Refrigerating appliances without an integrated system for producing cooling, and which function by ducting chilled air that is produced by an external air chiller unit.
- Professional refrigerated storage cabinets, blast cabinets, condensing units and process chillers (covered by the professional eco-design/labelling regulations).
- Wine storage appliances and minibars.
- Refrigerating appliances that do not use a vapour compression refrigeration cycle.
- Refrigerating appliances for the sale and display of live foodstuffs, such as refrigerating appliances for the sale and display of living fish and shellfish, refrigerated aquaria and water tanks.
- Saladettes.
- Horizontal serve-over counters with integrated storage designed to work at chilled operating temperatures.
- Corner cabinets.
- Vending machines designed to work at frozen operating temperatures.
- Serve-over fish counters with flaked ice
Measurement requirements
The regulation state that relevant product parameters should be measured using reliable, accurate and reproducible methods. Although specific test standards are not stipulated the regulation states that test methods should take into account recognised state-of-the-art measurement methods including, where available, harmonised standards adopted by the European standardisation bodies. The methods specified to calculate the energy efficiency index (EEI) make it clear by inference that appropriate test standards should be applied. Products must be 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. Products must be placed on the market specifically for the mentioned operating condition or application, as evidenced at least by the technical documentation, information provided for the product and any advertising, information or marketing materials.
Equivalent models
Within the regulation, equivalent models are allowed. These are defined as: ‘a model which has the same technical characteristics relevant for the technical information to be provided, but which is placed on the market or put into service by the same manufacturer, importer or authorised representative as another model with a different model identifier’.
Within the conformity assessment it is required that if information for a product is obtained from a model that has the same technical characteristics or by calculation or extrapolation from another model, the technical documentation shall include details of how the calculations/assessments were made. Any technical documentation shall include a list of all equivalent models, including the model identifiers.
Circumnavigation
Circumnavigation is now highlighted in the regulation and is specifically banned. Circumnavigation is when a manufacturer or their agent places on the markets a product that is capable of detecting when it is undergoing a test and applies software to alter (favourably) the performance of the appliance. It also applies to software or firmware updates that may result in the deterioration of the product compared to the original declaration of conformity.
Resource efficiency requirements
The new regulation has an emphasis placed on spare parts and re-use of components. From 1 March 2021 certain spare parts must be available for a minimum of 8 years after the last unit of the model is placed on the market. The listed items must be able to be replaced with commonly available tools without permanent damage to the appliance and instructions for fitting the items must be readily available. The items must also be publicly available on the free to access website of the manufacturer, importer or authorised representative at the latest 2 years after the first unit of the model is placed on the market. Spare parts must be delivered within 15 working days of an order for the component being received. Certain components should be fitted by professional repairers and there is a process for repairers to register with manufacturers, importers or authorised representatives to be able to access maintenance information.
Information to be provided by manufacturers
From 1 March 2021 instruction manuals shall include the following:
- Recommended setting of temperatures in each compartment for optimum food preservation.
- Estimation of the impact of temperature settings on food waste.
- Maximum operating conditions for beverage coolers and ice cream freezers.
- Instructions for correct installation and end-user maintenance, including cleaning.
- For integral cabinets the impact on efficiency of not cleaning the condenser.
- Access to professional repair such as internet webpages, addresses, contact details.
- Information on ordering spare parts and the minimum period during which spare parts are available.
- Minimum duration of the guarantee offered by the manufacturer, importer or authorised representative.
- Information on how to find model information in the product database.
Verification and market surveillance
Market surveillance activities are similar to those prescribed for other similar products. Initially a single unit will be tested by the market surveillance authority in a country. If the result exceeds the eco-design MEPS or the results are greater than the published product information by more than the verification tolerances shown below, the products will be deemed to have failed. In this case a further 3 additional units of the same model or equivalent models will be tested. If the arithmetical mean of the determined values from the 3 units exceeds the tolerances, the unit will fail and all equivalent models shall be considered not to comply with the regulation. As part of the verification the compliance authority will also check compliance with the resource and information requirements.
|
Parameters |
Verification tolerances |
|
Net volume, and net compartment volume, where applicable |
The determined value shall not be more than 3 % or 1 L lower – whichever is the greater value – than the declared value |
|
Gross volume, and gross compartment volume where applicable |
The determined value shall not be more than 3 % or 1 L lower – whichever is the greater value – than the declared value |
|
TDA, and compartment TDA where applicable |
The determined value shall not be more than 3 % of the declared value |
|
Edaily |
The determined value shall not be more than 10 % higher than the declared value |
|
AE |
The determined value shall not be more than 10 % higher than the declared value |
For further details on eco-design regulation for refrigerating appliances with a direct sales function contact Judith Evans at RD&T (j.a.evans@rdandt.co.uk).