Since the 1st January 2022, all solid fuel room-heater appliances placed on the market need to adhere to more stringent efficiency and emission performance requirements when burning both biomass and solid mineral fuels in the UK, covered under the Ecodesign regulations.

This legislation is additional to the current requirements within the Construction Products Regulations (CPR), which sets out the methods and criteria for assessing and declaring the performance of construction products and allows manufacturers to affix a CE mark to confirm the appliance is backed by a functioning technical evidence file and factory production control system.

Placing on the market

Ecodesign regulations apply to each new individual product placed on the market after 01/01/2022.

Placing on the market is defined as follows:

Newly placed products on the market are those that are made available for the first time on the open market. i.e., when it is first supplied for distribution, consumption or use on the market in the course of a commercial activity, whether in return for payment or free of charge. This can be either when a newly manufactured product, or a product imported from another country, is made available on the market for the first time and does not necessarily require physical delivery of the product. (i.e., warehouse stock).

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© HETAS 2022

image courtesy of Dik Guerts

Therefore, any individual product that was placed on the market before the 01/01/2022 can still be installed and notified, as long as the installer can confirm the appliance was placed on the market before this date.

Installers’ responsibilities

It is for individual manufacturers to ensure they are meeting the Ecodesign Regulations requirements and legislation is geared towards them doing so. If an installer is unsure of whether the product was placed on the market before 01/01/2022 we recommend further assurances are sought to satisfy yourselves of compliance.

When speaking to surveillance authorities, it is noted that the way in which the Ecodesign Regulations are written, the requirement to comply is placed on them at the time the product is being ‘placed on the market. The Regulation also says there can be a responsibility at the point of installation, or when the appliance is “put into service” but this seems a very unlikely scenario as the first point of compliance is at the point of placing on the market and any other circumstance is highly unlikely when installing a new appliance covered by the Regulations.

Put simply, this means that if a non- Ecodesign compliant product is placed on the market by the manufacturer after the 01/01/2022 the surveillance authorities’ point of view is that the legal aspect of placing on the market has already occurred, and therefore the appliance is legal to install and commission (i.e., put into service).

The easiest way to be sure that consumers are using the cleanest and most effective appliances is to advise them to choose from the Cleaner Choice approved appliance product search available at www.hetas. co.uk which means that any appliance chosen is at least 50% cleaner than any of the regulations require. This is the only list where the test reports for all areas of manufacture have been assessed by a third-party independent certification organisation not relying on self-certification by manufacturers. Manufacturers with Cleaner Choice approved appliances have voluntarily submitted their test reports for comprehensive scrutiny and must be commended for their open approach to compliance.

HETAS recommends however that installers do their due diligence and supply an appropriate product that meets all relevant regulations and legislation. After 01/01/2022 this would mean selecting an Ecodesign compliant stove. This will avoid any future issues or conflicts that may occur with the sourcing of spare parts during service/maintenance scheduling, or any warranty claims made against the manufacturer.