Guidance Note Solid Fuel Boilers

Solid Fuel Boilers

Ecodesign and Energy Labelling Guidance Note
November 2020

Introduction

This guidance note is intended to assist suppliers (i.e. manufacturers, importers or authorised
representatives1) of solid fuel boilers in meeting their obligations relating to ecodesign and
energy labelling.

It provides a general overview of the current ecodesign and energy labelling requirements for
solid fuel boilers and guidance on the measurements and calculations that should be applied
in determining the values displayed on the product energy label, the product information
sheet, and as required in the technical documentation demonstrating the compliance of the
product with the energy labelling and ecodesign requirements.

The relevant legislation

The requirements for ecodesign and energy labelling for products being placed on the market
are set out in the following European regulations and discussed further in the following
sections.

 Regulation (EU) 2015/1187 with regard to energy labelling of solid fuel boilers and
packages of a solid fuel boiler, supplementary heaters, temperature controls and solar
devices (in force since 2017 and applicable to products with a nominal heat output of
less than or equal to 70 kW) – these regulations can be found here: https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02015R1187-
20170307&from=EN

 Regulation (EU) 2015/1189 with regard to the ecodesign requirements for solid fuel
boilers (in force since January 2020 and applicable to products with a nominal heat
output of less than or equal to 500 kW) – these regulations can be found here:
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02015R1189-
20170109&from=EN

It is important for suppliers to be familiar with these regulations, to ensure that products you
place on the market are compliant with the regulations.

DISCLAIMER

SEAI has developed this guidance to help relevant entities understand and fulfil their obligations
under the ecodesign and energy labelling regulations. The specific requirements for ecodesign and
energy labelling are contained in the above-mentioned delegated acts and this guidance document
should not be used as a sole resource for demonstrating compliance. It is the individual supplier’s
responsibility to ensure compliance with the relevant regulatory requirements.

1 further described in Appendix 1.

Guidance Note Solid Fuel Boilers

ENERGY LABELLING

Regulation (EU) 2015/1187 requires that suppliers of solid fuel boilers with a nominal heat
output of ≤ 70 kW provide the following product information.

Energy Label

A copy of the energy label in accordance with Section 1 of Annex III of Regulation (EU)
2015/1187 must be provided. The format of the energy label depends on the configuration of
the product in question – as supplied by the supplier and after any applicable date.

Some of the current formats for solid fuel boilers and solid fuel boiler packages 2 are shown in
the examples provided below – refer to Annex III of the regulation to confirm which format
applies to your specific models.

Solid fuel boiler label Solid fuel boiler package label

The energy label must be provided with each unit sold. In addition, suppliers must also make
an electronic version of the label available to retailers.

A copy of the energy label should also be provided to the market surveillance authority (MSA)
when requested.

2 a package offered to the end-user containing a solid fuel boiler combined with one or more supplementary
heaters, one or more temperature controls or one or more solar devices – therefore a boiler with a temperature
control device, for example, is considered a package.
Guidance Note Solid Fuel Boilers

Product Information Sheet

Suppliers must provide a copy of the product information sheet (also referred to as the
‘product fiche’) with each unit sold, in accordance with Section 1 of Annex IV of Regulation
(EU) 2015/1187 and which must contain the information below, in the following order.

a) supplier's name or trademark

b) supplier's model identifier
c) the energy efficiency class of the model
d) the rated heat output (X,X kW)
e) the energy efficiency index
f) the seasonal space heating energy efficiency in (X%)
g) any specific precautions that shall be taken when the solid fuel boiler is assembled,
installed or maintained
h) in the case of solid fuel cogeneration boilers, the electrical efficiency (%)

The product information sheet must be provided in the product brochure or other product
literature. One product information sheet may cover a number of boilers marketed by the same
supplier. An example product information sheet is shown below.

Product Information Sheet (Fiche) – Solid fuel boiler

In addition, for packages of solid fuel boilers, supplementary heaters, temperature controls
and/or solar devices , a product information sheet providing the information listed in Section
2 of Annex IV of Regulation (EU) 2015/1187, is to be provided by the supplier with each
package. This information must include the supplementary data as shown in the following
figure.

A product information sheet must be provided with each boiler unit or package that is sold. In
addition, suppliers must also make an electronic version of the product information sheet
available to retailers.

A copy of the product information sheet should also be provided to the Market Surveillance
Authority (MSA) when requested.
Guidance Note Solid Fuel Boilers

Product Information Sheet (Fiche) – supplementary information to be provided for packages of

a solid fuel boiler, supplementary heater, temperature and/or solar devices
Guidance Note Solid Fuel Boilers

Technical Documentation

Suppliers of solid fuel boilers must prepare specific technical documentation in accordance
with Section 1 of Annex V of Regulation (EU) 2015/1187. This includes the specific information
outlined in the Table 4 of Annex V, to be provided in the tabular format specified – Table 4 is
shown in Appendix 2.

For packages of solid fuel boilers, supplementary heaters, temperature controls and/or solar
devices, the specific technical documentation requirements are outlined in Section 2 of Annex
V. Such technical documentation should be accompanied by evidence supporting the
information presented in Table 4, such as test reports, calculations etc.

EPREL

The European Product Database for Energy Labelling (EPREL) has been set up under EU
Regulation 2017/1369 to provide important energy efficiency information to consumers and
to facilitate market surveillance activities and enforcement. Note that, while there is no direct
reference to EPREL in Regulation (EU) 2015/1187, it is now a legal requirement for suppliers of
products covered by the EU Energy Labelling Regulation and placed on the market since
August 2017, to upload information about their products onto the database before placing
these products on the market in the EU.

EPREL also has a useful feature allowing the supplier to generate a product energy label and
product information sheet once the product information has been populated in the EPREL
database. SEAI has prepared a guidance document that provides some further information in
relation to EPREL which can be found at the following link:
https://www.seai.ie/publications/EPREL-Supplier-Guidance_Final-5.pdf

Other Energy Labelling Requirements

There are a number of further requirements that also apply to suppliers of solid fuel boilers
and/or packages of solid fuel boilers, supplementary heaters, temperature controls and/or
solar devices:

 any visual advertisement or technical promotional material relating to a specific model

or package (which may be, for example, online or in hard copy) must make reference
to the energy efficiency class and the applicable range of energy efficiency classes

 if a supplier also offers solid fuel boilers or packages for sale either online or in a
physical sales outlet (therefore also acting as a retailer), then the specific energy
labelling requirements as per Annex VII of Regulation (EU) 2015/1187 must be
followed.

More detailed descriptions of supplier obligations are outlined in Articles 3, 4 and 6 of the
Energy Labelling Regulation (EU) 2017/13693.

3 available here: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R1369&from=EN

Guidance Note Solid Fuel Boilers

ECODESIGN

Regulation (EU) 2015/1189 requires suppliers of solid fuel boilers with a nominal heat output
of ≤ 500 kW to ensure the products they supply meet minimum ecodesign requirements in
terms of seasonal space heating efficiency (ηs) and emissions (PM, OGC, CO, NOx), and
requires suppliers to provide specific ecodesign product information. The minimum ecodesign
requirements are outlined in Annex II of Regulation (EU) 2015/1189.

The ecodesign requirements, while related to those of energy labelling in terms of energy
efficiency performance, are separate and distinct aspects that must be addressed by
manufacturers.

In ensuring that products are compliant, suppliers must undertake a conformity assessment
process to demonstrate that the specific ecodesign requirements have been fulfilled.

When this process is complete, suppliers4 must prepare a Declaration of Conformity (DoC), in
accordance with Article 5 and Annex VI of the Ecodesign Directive 2009/125/EC and then affix
the CE mark to the product.

Technical Documentation

When requested by a market surveillance authority (MSA), suppliers should provide the
following documentation, related to the conformity assessment process, to demonstrate
product compliance:

 the Declaration of Conformity

 the information required by Section 2 (c) of Annex II of Regulation (EU) 2015/1189,

including the Table 1 information as shown in Appendix 2 - note that this information
can be combined with the information required in Table 4 relating to energy labelling,
outlined previously

 evidence supporting the information presented in Table 1 such as test reports,

calculations, etc.

 evidence of the information required by Section 2 (a) and (b) of Annex II of Regulation
(EU) 2015/1189 being presented on free access websites and in instruction manuals.

Note also that it is a requirement that suppliers retain all documentation related to the
conformity assessment process of a product so that it is available for inspection by an MSA for
a period of 10 years after it was last placed on the market.

4 Note that importers do not need to undertake the conformity assessment process or prepare a Declaration of
Conformity – rather they need to be able to provide a copy of the Declaration of Conformity prepared by the
manufacturing company and the relevant conformity assessment documentation.
Guidance Note Solid Fuel Boilers

Measurements and Calculations for Ecodesign and Energy

Labelling

The parameters laid down in both Regulation (EU) 2015/1187 and Regulation (EU) 2015/1189
and their means of calculation are similar, given that they are interrelated.

Regulation (EU) 2015/1187 requires the determination of the energy efficiency index (EEI), in
order to identify the relevant energy efficiency class, which is informed by the seasonal space
heating efficiency.

Regulation (EU) 2015/1189 requires the determination of the seasonal space heating efficiency,
while also requiring the determination of the seasonal space heating emissions.

Methodologies related to the calculation of these parameters are outlined in the

‘Measurements and Calculation’ annexes of both regulations, as summarised in the following:

The energy efficiency index (EEI) is calculated as:

EEI = ηson × 100 × BLF – F(1) – F(2) × 100 + F(3) × 100

The seasonal space heating energy efficiency (ηs ) is calculated as:

ηs = ηson – F(1) – F(2) + F(3)

where (in both calculations):

ηson is the seasonal space heating energy efficiency in active mode (%), calculated as set out
in each regulation

F(1) accounts for a negative contribution due to adjusted contributions of temperature

controls: F(1) = 3%

F(2) accounts for a contribution by auxiliary electricity consumption, calculated as set out in
each regulation

F(3) accounts for a contribution by the electrical efficiency of solid fuel cogeneration boilers,
calculated as set out in each regulation
Guidance Note Solid Fuel Boilers

Seasonal space heating emissions (Es) are calculated as:

Es = 0.85 x Es,p + 0.15 x Es,n

(for manually stoked solid fuel boilers that can be operated at 50 % of the rated heat output in
continuous mode, and for automatically stoked solid fuel boiler)

or

Es = Es,n

(for manually stoked solid fuel boilers that cannot be operated at 50 % or less of the rated heat
output in continuous mode, and for solid fuel cogeneration boilers)

where:

Es,p are the emissions of respectively particulate matter, organic gaseous compounds, carbon
monoxide and nitrogen oxides, measured at 30 % or 50 % of the rated heat output, as
applicable

Es,n are the emissions of respectively particulate matter, organic gaseous compounds, carbon
monoxide and nitrogen oxides, measured at the rated heat output

Energy Efficiency Classes

The energy efficiency classes for a given EEI are specified in Table 1, Annex II of Regulation
(EU) 2015/1187 and shown in the following.

Energy Efficiency classes of solid fuel boilers

Guidance Note Solid Fuel Boilers

Standards

The following standards/test methods are identified by the European Commission for use in
determining the parameters outlined above, as per Commission Communication 2017/C
076/01 and are available here5:

Commission Communication 2017/C 076/01

Parameter Reference/title Notes

General EN303-5:2012 Heating boilers Condensing boilers are to be
conditions for for solid fuels, manually and tested in condensing mode.
testing automatically stoked, nominal
heat output of up to 500 kW The applicable part load (30 % or
— Terminology, requirements 50 %) is to be used instead of the
and marking, 5.7 Conducting minimum heat output.
the boiler performance test
Useful efficiency EN303-5:2012, 3.15 boiler Corresponds to ηK measured at
at rated heat efficiency, 5.10.3.1 Direct rated heat output Pr, but with Q
output ηn method and QB expressed in gross calorific
value.
Useful efficiency EN303-5:2012, 3.15, 5.10.3.1 Corresponds to ηK measured at
at applicable part applicable part load (30 % or 50
load ηp %), but with Q and QB expressed in
gross calorific value.
Useful heat EN303-5:2012, 3.6 heat output Corresponds to heat output Q
output at rated measured at rated heat output Pr,
heat output Pn but expressed in gross calorific
value.
Useful heat EN303-5:2012, 3.6 Corresponds heat output Q
output at measured at applicable part load
applicable part (30 % or 50 %), but expressed in
load Pp gross calorific value.
Rated heat EN303-5:2012, 3.7 nominal Corresponds to nominal heat
output Pr heat output, 5.8.2 Determining output QN (when measured with
the nominal heat output the preferred fuel), but expressed
in gross calorific value.
Electrical power EN303-5:2012, 5.8.5 Electrical Corresponds to Paux 100 in clause
requirement at consumption 3.4.1 of EN15456:2008, but any
maximum heat electricity consumption from a
output elmax EN15456:2008, Heating boilers back-up heater and from
— Electrical power incorporated secondary emission
consumption for heat abatement equipment is not taken
generators — System into account.
boundaries — Measurements

5 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52017XC0310(03)&from=EN
Guidance Note Solid Fuel Boilers

Electrical power EN303-5:2012, 5.8.5 Corresponds to Paux, g in clause

requirement at 3.4.1 of EN15456:2008 measured at
minimum heat EN15456:2008 applicable part load operation (30
output elmin % or 50 %), but any electricity
consumption from a back-up
heater and from incorporated
secondary emission abatement
equipment is not taken into
account.
Standby mode EN303-5:2012, 5.8.5 Corresponds to Paux sb, but any
power electricity consumption from
consumption PSB EN15456:2008 incorporated secondary emission
abatement equipment is not taken
into account.
Gross calorific EN 14918:2009 Solid biofuels Corresponds to qV, gr, d
value moisture — Determination of calorific
free GCVmf value, 10.4 Expression of
results
Moisture content EN 14918:2009, 10.4 Corresponds to Mar, but expressed
of the fuel M as fraction instead of as
percentage
Characteristics for EN303-5:2012, Table 7 — test Refer to ‘Notes’ for blended fossil
[fuel type] fuels, water content and ash fuel/biomass briquettes
content for [fuel type]

Technical documentation (such as laboratory test reports) provided to the MSA to

demonstrate the energy labelling and ecodesign compliance of a relevant product, should be
conducted in accordance with the above standards.
Guidance Note Solid Fuel Boilers

Appendix 1:

Definition of a supplier

A ‘supplier’ is defined as “a manufacturer established in the Union, the authorised

representative of a manufacturer who is not established in the Union, or an importer, who
places a product on the Union market”.

These entities are further defined as follows:

A ‘manufacturer’ is “a natural or legal person who manufactures a product or has a product

designed or manufactured and markets that product under its name or trademark”.

An ‘importer’ is “a natural or legal person established in the Union who places a product from
a third country on the EU market”.

An ‘authorised representative’ is “a natural or legal person established in the Union who has
received a written mandate from the manufacturer to act on its behalf in relation to specified
tasks”.
Guidance Note Solid Fuel Boilers

Appendix 2:

Energy Labelling -‘Table 4’ Technical parameters for solid fuel boilers and solid fuel
cogeneration boilers
Guidance Note Solid Fuel Boilers

‘Table 1’ Information for solid fuel boilers