For the best part of three years, representatives from leading UK refrigeration manufacturers, their counterparts in other EU markets and members of trade bodies such EFCEM — which includes CESA — have been making regular trips to the heartland of European policy-making in a bid to establish the energy performing parameters by which commercial refrigeration appliances must conform to in the future.
As anyone who has attended one of these meetings or consultation forums will tell you, developing a set of standards is a painstaking affair that has involved every technical and practical element of the refrigeration manufacturing and sales process being meticulously explored, from operational temperatures and equipment configurations to cabinet capacities and R&D activity.
The refrigeration market set out on this journey after European Commission decision-makers identified the product category as possessing “high potential” for energy savings — as much as 60% in some cases — due to high energy consumption and long operating times.
Under the framework of the Ecodesign Directive, the EC has divided refrigeration into five categories: condensing units; industrial process chillers; blast cabinets; walk-in cold rooms; and non-household refrigerated storage cabinets. For each product category, implementing measures will eventually be adopted under ‘Ecodesign Directive 2009/125/EC’, in addition to one energy labelling regulation for storage cabinets under Directive 2010/30/EU.
There are two standards-making bodies in Europe — CEN and CENELEC — with refrigeration suppliers part of ‘CEN TC 44 Working Group 2’, which is specifically concerned with commercial storage cabinets.
UK representatives from brands such as Adande, Gram, Foster Refrigerator, Liebherr and Williams are members of this group, along with their counterparts from companies in mainland Europe, such as Asskuhl, Epta and Haglund Industri.
Proposals for the combined minimum requirements and energy labels have met with widespread support from the refrigeration industry.
But exactly how far away from EU-wide minimum performance requirements and energy labels are we?
“The convenor of Working Group 2 is Fabio Gargantini, who is the EFCEM general secretary, and he was very clear at the outset of this standards-making process for commercial storage cabinets that he thought it could go through in 18 months,” says Keith Warren, who has been part of the consultation forums on behalf of CESA and EFCEM. “That would take it to the end of 2013, so that is what everyone is still very much working to.”
Last year, EFCEM produced a position paper asking for a two-year extension on the timing of mandatory minimum requirements, giving the industry an opportunity to align itself with the criteria on a phased basis.
The most important thing to bear in mind, adds Warren, is that the standards work that continues to take place must align with the regulation, which hasn’t been published yet.
“Like all standards-making processes, what tends to happen is everybody will come to the table with their own view, and what the standards process should do is bring about some compromise between those points of view and make the important decisions on what should be included in the standard.
“That has certainly been the case over the meetings that have taken place thus far, although there are still issues to be ratified in terms of the frequency and duration of door openings and also the load levels within the equipment. It is, in effect, a funnelling process and at the point at which the regulation is published that will define what the standard will need to comply with. The two elements are running in parallel.”
Adande’s Catarina Marques, who has participated in Working Group 2 meetings, notes that unlike the domestic refrigeration market, commercial refrigeration has a vast array of cabinet models adapted to specific customer requirements. This, she says, poses a major challenge in developing a test standard that effectively addresses how each product is used.
“There are also significant differences among the products sold in each European country and not enough data on how each type of cabinet performs,” she says. “Significant differences between cabinet volume, usage patterns and ambient conditions defy the development of a harmonised standard and there is a risk that special cabinet variants, which use different technology, might be jeopardised in the need to reach a consensus. The costs involved in testing and development will have a larger impact on small companies.”
While Working Group 2 may have a test methodology ready by the end of 2013, work on the other product areas won’t be completed until much later.
With blast chillers, for example, the process hasn’t even really got going yet as national food requirements for the temperature and time specified for bringing food down to a temperature varies greatly between member states. There will need to be an agreed time and temperature process across Europe before European energy efficiency measures can be put in place.
Last month, CESA hosted a DEFRA presentation in which Mike Rimmer, head of DEFRA’s Sustainable Energy Using Products Team, provided an update on the findings of an Impact Assessment study for each refrigeration product category. Warren says that CESA is working closely with DEFRA in the UK and through EFCEM with the Commission directly.
“Industry engagement is key in terms of identifying what the test methodology should be to evaluate the performance of equipment and that is the issue that is going on with the process at the moment,” he comments. “What we won’t know until the regulation is published is where the Commission is going to set the barriers, and I really couldn’t second guess how they will play it.”
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With commercial storage cabinets, the Impact Assessment study recommends that the proposed mandatory minimum requirement timings are retained. This would mean Tier 1 requirements being introduced from January 2015, Tier 2 from January 2016 and Tier 3 from January 2018.
Requirements are estimated to potentially increase prices by up to 20% after Tier 3 but move the market towards more value-added products. Or in other words, the legislation will raise the price of the lowest-performing product on the list versus the cheapest option that is available in the market today.
“It will be a staged approach to improving the efficiency of the equipment that is placed on the market through a tiered approach. But nobody knows where those figures are because it depends on how stringent the Commission wants to be,” says Warren.
“Also, what they don’t want to do is prevent a lot of product that is produced by European manufacturers from being able to be sold, so they have got to find a balance between what they want to do to improve the energy efficiency of the industry and the availability of product.”
In essence, it won’t just be as simple as saying a manufacturer’s product falls one side of the efficiency line or the other. Energy labelling means they will be graded A-G in much the same way as domestic appliances are at present. However, after a low point they will be deemed to have failed and would be prohibited from sale.
Warren concludes: “This whole measure will effect what manufacturers can put on the market, so certainly there is a case that after this has all gone through some products that distributors are buying today, or that the end-users are buying today, won’t be available once the implemented measures come into force. That is the commercial aspect of it, but what that will do is improve the efficiency of refrigeration that is in Europe.”
Ecodesign directive: Ready or not?
New harmonised test methodology for commercial refrigeration cabinets is being developed by CEN TC 44 Working Group 2, with the end of 2013 set as the target date for the standard to be published. Although the industry has proposed that the first mandatory minimum requirements are introduced from January 2015, we asked leading stakeholders in the UK refrigeration market whether they were taking any specific operational or strategic measures at this stage to prepare for the Ecodesign Directive’s introduction. Here’s what they said…
Chris Playford, Foster Refrigerator
“Foster is part of the Working Group for the new standards that underpin the EuP directive and prides itself on offering products that are highly efficient and, at the same time, offer value for money, so maintaining this position is of prime importance. Foster considers this legislation to be a significant step forward in providing customers with clearer information to support their buying decisions.”
Glenn Roberts, Gram
“We believe that it is vital that the European market place takes a firm stance on the control of energy consumption across the whole foodservice market place. Clearly the directive will initially place demands on all manufacturers and importers in the refrigeration sector. As dedicated, professional manufacturers we are constantly in a process of continuous improvement of our products and clearly will need to focus our development to not just meet, but exceed, any targets that will be set by the directive, both in the short and long term. Therefore, we firmly believe that we are absolutely ready for what will come our way in the years ahead.”
John Lilly, True Manufacturing
“True always strives to manufacture units which combine heavy-duty refrigeration, energy efficiency and sustainable materials. These core values have been manufactured into each and every True cabinet. Once the test parameters have been clearly defined, we will review and research what aspects, if any, we must evolve to meet the Ecodesign Directive.”
Malcolm Harling, Williams Refrigeration
“Williams Refrigeration is a member of the EU Technical Committee that will set the new regulations. We know it is coming and can prepare certain areas of the business for that, but specific operational measures will be addressed when the framework is finalised and put in place. Williams Refrigeration always uses ‘best available technology’ within our developments and ongoing product improvement.”
Stephen Ongley, Liebherr
“The procedure is not yet defined, so testing cannot begin. Liebherr appliances are very energy efficient and reductions in consumption are part of the continuous development process, so the directive will only impact in regard to testing to the finalised test procedure.”
Steve Goldsmith, Precision Refrigeration
“Precision is represented on CEN TC 44 WG 2, the European Standards group that will develop a new commercial test standard for the Ecodesign Directive. Precision has a continuous product improvement plan in place, meaning we are constantly developing products and utilising new technologies which are more energy efficient and minimise impact on the environment. This has recently led to major component changes, allowing us to gain maximum energy efficiency while still ensuring our products are reliable. The key focus over the last two years has been to develop new equipment to comply with any future pending regulations.”