ELVHIS Statement - Hydrogen for decentralized heating
Years 2025-2029 *
´20% hydrogen appliance´ : appliance designed and approved to operate
safely and efficiently using a gas that has a fluctuating hydrogen content between 0% and 20% by volume
´100% hydrogen-ready appliance´ : gas appliance designed and approved
to be installed and ti operate on natural gas and, following a conversion and recommissioning process, can operate safely and efficiently using 100% hydrogen. *
all decentralized heating appliances placed on the EU market:
• from 2025 shall be capable to process up to vol-% H2
• from 2029 shall be ready to be retrofitted from natural gas to 100% hydrogen
Statement to “Discussion paper: Should the consumer be able to compare the energy efficiencies of local space heaters ≤ 50 kW and air-to-air heat pumps ≤ 12 kW by means of the energy label?” (PDF 709 KB)
Commercial local space heaters are and will be excepted from energy labelling. Independently of this fact we reject clearly the idea of a comparability in energy labelling of the products mentioned for the following reasons:
- The scope of Ecodesign Regulation (EU) 2015/1188 resp. former lot 20 is “Local Space Heating” – not “Air Heating”. Due to this scope products with different technologies using different heat transfer mechanisms including infrared radiation are covered to achieve space heating – or room heating. Subsequently Regulation (EU) 2015/1188 includes terms and calculations to determine energy efficiency of space or room heating – in particular also for large commercial rooms.
- Definitions, terms and calculations of energy efficiency determination for air conditioners and air-to-air heat pumps are not identical to the analog items of local space heaters – especially not identical to the analog items of commercial local space heaters. Therefore a direct comparison in energy labelling leads to faults and misinterpretations.
- We contradict the allegation that air conditioners/heat pumps <=12 kW are “serving the same purpose” as commercial local space heaters. Gas fired radiant heaters - called “commercial local space heaters” in the Regulation and in the market also called “overhead radiant heaters” - are operating in rooms/buildings with ceiling heights of more than 4 meters up to 20 meters or even more. They are installed under the roof or angled in the upper area of the walls. Their important feature is heat transfer by infrared radiation to heat the working area or the floor of the room/building by radiation and keeping the large air volume of the building rather cool. This energy efficiency behavior is assessed by a combined calculation of thermal and emission efficiency in the calculation scheme for commercial local space heaters in Regulation (EU) 2015/1188.
- In many cases of large commercial and industrial rooms gas fired radiant heaters are by far the most energy efficient heating solution – it would be completely incomprehensible, if these appliances by inadequate comparison could only reach bad efficiency numbers or a “D” or “E” in a common energy labelling together with domestic air conditioners.
- Obviously air conditioners and some types of local space heaters in particular gas fired radiant heaters are representing different heating systems in different rooms/buildings. Calculation and assessment of different heating systems in buildings is an issue of EPBD and EPBDstandards – not of Ecodesign Regulations.
One of the main responsibilities of ELVHIS is to raise the awareness of the key European standards, directives and regulations as well legislation bodies for the significance of innovative gas-fired radiant heating and to continue to engage their interest. Actual examples of the diverse national and international activities conducted by ELVHIS to promote the positive ecological and economic effects of luminous heaters and overhead radiant tube heaters can be found here:
- Resolution of 56th ELVHIS Plenary Meeting in Berlin September 11th 2017: Current draft standards gas-fired radiant heaters CEN TC 180
> Download PDF: Physikalisch-Technische-Bundesanstalt "Development and Specification of an Accurate Cosine-behaviour Responsivity Radiometer Head for Infared Temperature Radiation"
> Download PDF: Resolution of the 56th ELVHIS Plenary Meeting on 11th September 2017 in Berlin
The aim of this Resolution is to recommend and encourage ELVHIS members to use the new draft standards of CEN TC 180 to prove compliance of products with the current GAD 2009/142/EC or the future GAR (EU) 2016/426 and also compliance with the Ecodesign Regulation Local Space Heaters (EU) 2015/1188 as long as the official EN standards are not yet published and as long as the standards are not harmonized.
The recent documents of CEN TC 180
- Doc N856 (WI 00180096) prEN 416:2017
Gas-fired overhead radiant tube heaters and radiant tube heater systems for non-domestic use - Safety and energy efficiency (dated 2017-04-11)
- Doc N857 (WI 00180097) prEN 419:2017
Gas-fired overhead luminous radiant heaters for non domestic use - Safety and energy efficiency (dated 2017-04-23)
- Doc N848 (WI 00180098) prEN 17175:2017
Gas-fired overhead radiant strip heaters and multi-burner continuous radiant tube heater systems for non-domestic use — Safety and energy efficiency (dated 2017-05)
are reflecting the recent "state of the art" of gas-fired infrared heating appliances concerning technology, safety and energy efficiency. In particular – based on a scientific study of the German Metrology Institute PTB (Physikalisch-Technische Bundesanstalt) - the three draft standards incorporate uniformly a detailed description of the significantly improved method to determine the radiant factor (radiant output) of infrared heating appliances giving reliable and better reproducable results compared to the methods in the standards EN 416-2:2006 and EN 419-2:2006.
- Ecodesign Directive and Ecodesign
The aim of this Directive is to define ecodesign requirements for energy-related products such as heating products or insulating materials.
The Ecodesign Directive being in force since October 2009 establishes the European legal framework for the setting of environmental requirements for energy-related products (ErP). Gas-fired radiant luminous and radiant tube heaters for commercial and industrial use are covered under Commission Regulation (EU) 2015/1188 of 28 April 2015 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for local space heaters. Regulation (EU) 2015/1188 came in force on 1st of January 2018 in all Member States of the EU.
Actually (August 2018) the European Commission has launched a study to revise Regulation (EU) 2015/1188. ELVHIS as stakeholder represents the product range of commercial radiant heaters in the revision process.
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- European product and installation standardizsation for gas-fired overhead radiant heaters (CEN/TC 180 Decentralized Gas Heaters)
CEN is an international association whose objective is to remove trade barriers by means of standardisation. European standards and technical specifications are developed in Technical Committees (TCs).
ELVHIS is active in the following working groups (WG) of Technical Committee 180 (CEN/TC 180):
CEN/TC 180 WG 1: Non-domestic gas-fired overhead radiant tube and luminous heaters – Safety and energy efficiency
CEN/TC 180 WG 3: Non-domestic gas-fired overhead radiant strip heaters and continuous radiant tube heater systems – Safety and energy efficiency More...
- Energy performance of buildings directive (EPBD)
This Directive requires that Member States set minimum standards for the energy performance of new or refurbished buildings and to introduce energy performance certificates.
The EPBD Directive was introduced to help improve the energy performance of buildings in the European Union, taking into account climatic and local conditions as well as the indoor climate environment and cost-effectiveness.
The revised Energy Performance of Buildings Directive (EU) 2018/844 has been published in the EU Official Journal (L156) and enters into force as of 9 July 2018. EU countries will have to transpose the new elements of the Directive into national law within 20 months. The new Directive has huge potential for efficiency gains in the EU building sector, the largest single energy consumer in Europe. It includes measures that will accelerate the rate of building renovation towards more energy efficient systems and strengthen the energy performance of new buildings, making them smarter.
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- Energy efficiency, thermal comfort and indoor air quality of gas-fired overhead radiant heaters in modern factories and warehouses
In a joint research project, the ITG Institute for Building Systems Engineering Dresden/Germany and the University of Applied Sciences Zittau/Görlitz/Germany demonstrated that gas-fired overhead luminous radiant heaters can also generate extremely energy-efficient, comfortable space heating in modern factories and warehouses. Direct thermal radiation proved to be of great energy advantage here, providing high thermal comfort even at the lower air temperatures found in the production hall. This energy advantage increases as the efficiency (radiation factor) of the overhead luminous heaters improves. The heaters also fulfil stringent requirements where indoor air quality is concerned. More...
- Method to determine radiant efficiency
(PTB R&D project to determine radiation efficiency (DVGW R&D project)
So far the radiant factor of gas-fired radiant heaters has been determined on the basis of standards DIN EN 416-2 [1] and DIN EN 419-2 [2] with two equally recognized methods (Method A and Method B) under these standards, whereby Method B has become established as the de facto standard due to its ease of use.
In cooperation with the German Metrology Institute PTB (Physikalisch-Technische Bundesanstalt /Berlin/Germany) ELVHIS has realised a scientific study to improve the radiometric method including its calibration to give more reliable and better reproducible results of radiant factors with one unique method. Within the PTB-study an accurate cosine-behaviour responsivity radiometer head for radiant heaters has been developed and validated including its manufacturing specification.
The scientific results of the PTB research project have been incorpoarated in the new draft standards prEN 416, prEN 419 and prEN 17175.
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- European harmonisation of gas properties (gas quality)
The supply of natural gas in the Member States of the European Community so far is regulated in national laws and provisions. The representatives of the European manufacturers of gas devices welcome the initiative to harmonise the natural gas supply in Europe and at the same time not only to guarantee a reliable supply to the consumer but also to include new and forward-looking energy sources such as gas from biogenic materials or synthetically produced gases from renewables. An increasingly important role in this respect will be played by global trade with natural gas, for example through the import of liquid natural gas (LNG) from other regions in the world. More... More...
