Archive for category: Standardization and national requirements

From July 1, 2025, Regulation (EU) 2024/1103 will apply, which has been in force since May 9, 2024. This sets out the requirements for the environmentally friendly design of local space heaters. This also means that the provisions of Regulation (EU) 2015/1188, which have been in force since January 1, 2018, will no longer apply. The regulation specifically covers local space heaters designed for operation with gaseous or liquid fuels or electrical energy. Those that access a fluid via an indirect heating function through heat transfer are also affected. The future development of solid fuel single-room heaters can also be seen from the changes.

The scope of the new Regulation (EU) 2024/1103 has been extended compared to the previous one. Single-room firing installations for domestic use up to 50 kW and for commercial use up to 300 kW (instead of the previous 120 kW) are now covered.

Not affected are

– local space heaters that generate heat in a cold steam or sorption circuit process and are operated electrically or with fuels,

– local space heaters that are designed, tested, marketed and declared exclusively for outdoor use

– local space heaters whose direct heat output at rated heat output is less than 6% of the combined direct and indirect heat output

– Air heating products

– sauna heaters

– cooking appliances

Changes to the requirements for the seasonal space heating energy efficiency

From July 1, 2025, the annual space heating efficiency of at least

– 40.3 % for local space heaters with an open combustion chamber and local space heaters with an open flue gas duct

– 63.6 % for local space heaters with a closed combustion chamber and open combustion

– 63.6 % for balanced flue local space heaters

Changes to the resource efficiency requirements

This section has been added and under Annex II, point 5, the list of spare parts that manufacturers, importers or authorized representatives of electric local space heaters must make available to professional repairers is given for each product type.

The following requirements also apply to all space heaters. Especially for

– all models placed on the market from July 1, 2025, manufacturers must make at least the remote control available as a spare part for professional repairers and users

– spare parts (such as remote controls) must be available for at least 10 years after the last appliance of the model in question was placed on the market

– manufacturers ensuring that spare parts (remote controls) can be replaced using standard tools and without causing permanent damage to the heater

– during the period in which spare parts are available, the manufacturer, the importer or his authorized representative shall ensure that the spare parts are delivered within 10 working days of receipt of the order. Software and firmware updates shall be made available free of charge for a period of at least ten years after the product has been placed on the market.

Also included are:

– Requirements for the manufacturer. Granting professional repairers access to the appliance’s repair and maintenance information under certain conditions

– Requirements for the manufacturer to ensure that the lone space heater is designed in such a way that the materials and components listed in Annex VII of the Waste Electrical and Electronic Equipment Directive (WEEE – 2012/19/EU) can be removed with standard tools and compliance with the obligations set out in Article 15(1) (WEEE)

Changes to the specific ecodesign requirements for emissions

From July 1, 2025, nitrogen oxide (NOx) emissions from local space heaters for liquid or gaseous fuels must not exceed 120 mg/kWh input instead of the previous 130 mg/kWh input. This applies to local space heaters with an open combustion chamber, local space heaters with an open flue gas duct, local space heaters with a closed combustion chamber and open combustion, room-sealed local space heaters and local space heaters without a flue gas discharge.

It should be noted that a weighted NOx value is determined in the standards. The regulations, on the other hand, refer to the nitrogen oxide emissions (NOx) at nominal heat output, which can be taken from the test report.

Regulation EU 2015/1188 does not specify for which fuel the NOx emissions and efficiency must be stated. The 2017 guidelines state that the requirements must be met for all fuels for which the appliance was developed.

Changes to the requirements for product documentation and information

The product information to be included in the instructions for installers and users and on the freely accessible websites of manufacturers, their authorized representatives and importers is set out in Annex II, point 4.

Included are:

– any special precautions to be taken during assembly, installation or maintenance of the local space heater

– Information on dismantling, recycling and/or end-of-life disposal

– Depending on the product type, further product information requirements apply, which are listed in Tables 1 to 7 of the Regulation

– The instruction manuals may also contain additional information about the product that may be useful to installers and users, including information on the compatibility of heaters and controls

– Separate controls for which a list of control functions must be included in the operating instructions according to the format in Table 7.

In addition, for local space heaters without flue gas ducting and local space heaters with open flue gas ducting, the sentence “This product is not suitable for primary heating purposes” must be indicated on the cover page of the user manual, on the manufacturer’s website and on the packaging.

Technical documentation

Regarding the conformity assessment and verification procedure, a list of all equivalent models must be included for fixed space heaters and separate associated controls, if applicable. These are explained in more detail in Annex II, point 6, as further elements and values must be listed depending on the product type.

By 2029, the ecodesign requirements will be reviewed by the EU Commission, considering technical progress in terms of energy efficiency, pollutant emissions, correction factors, scope of application and resource efficiency. It is expected that the ecodesign requirements will then be raised accordingly.

Overview of ecodesign requirements from 01.07.2025

Gaseous (liquid gas, natural gas)	Efficiency	NOx	PM-dust	OGC	CO
Closed combustion chamber and open combustion, as well as room-sealed single-room heaters	63,6 %	120	k. A.	k. A.	k. A.
Open combustion chamber, flue gas connection and open flue gas routing	40,3 %	120	k. A.	k. A.	k. A.
Closed combustion chamber and open combustion, as well as room-sealed single-room heaters	Info: “This product is not suitable for primary heating purposes”
Open combustion chamber, flue gas connection and open flue gas routing	Info: “This product is not suitable for primary heating purposes”
Liquid (oil, paraffin, petroleum)	Efficiency	NOx	PM-dust	OGC	CO
Closed combustion chamber and open combustion, as well as room-sealed single-room heaters	63,6 %	120	k. A.	k. A.	k. A.
Open combustion chamber, flue gas connection and open flue gas routing	40,3 %	120	k. A.	k. A.	k. A.
Closed combustion chamber and open combustion, as well as room-sealed single-room heaters	Info: “This product is not suitable for primary heating purposes”
Open combustion chamber, flue gas connection and open flue gas duct	Info: “This product is not suitable for primary heating purposes”

We were one of the first European laboratories to receive notification in relation to the new EN 16510 series of standards. The notification certificate was sent to us by the Deutsches Institut für Bautechnik, which means that we are now authorized to issue test reports in accordance with EN 16510.

The notification concerns the following construction products:

EN 16510-2-1	Roomheaters
EN 16510-2-2	inset appliances including open fires
EN 16510-2-3	Cookers
EN 16510-2-6	Mechanically by wood pellets fed roomheaters, inset appliances and cookers

The notified bodies have submitted a draft on the use of historical data related to part 2-1 (room heaters) to the European Commission. The decision will be communicated within the next 14 days.
The proposal for the use of historical data for the other parts of the standard EN 16510 2-2 to 2-6 will be processed by the notified bodies in the coming week.

The EN 16510 series of standards replaces the standards EN 13240, EN 13229, EN 12815, EN 12809, EN 14785 and thus the majority of standards for small fireplaces. From 09.11.2025, the fireplaces concerned must be placed on the market with a test report in accordance with the corresponding part of EN 16510. The standard for storage fireplaces EN 15250 will be harmonized at a later date and is not yet acutely affected.

Further information on EN 16510 can be found here: Harmonization of EN 16510 – RRF (rrf-online.eu)

You are welcome to contact us about tests in accordance with EN 16510 or the use of historical data from your fireplaces.

10 years ago, the revision of the old standards for residential solid fuel burning appliances were decided.

Due to administrative barriers and legal requirements for harmonized standards according to the Construction Products Regulation the release has been continually delayed. The new standards should reflect the state of art and replace the following predecessor standards:

New		Replaced
EN 16510-1:2022	General requirements and test methods	EN 16510-1:2018 a	Residential solid fuel-burning appliances – Part 1: General requirements and test methods
EN 16510-2-1:2022	Roomheaters	EN 13240:2001	Roomheaters fired by solid fuel – Requirements and test methods
EN 16510-2-2:2022	Inset appliances including open fireplaces	EN 13229:2001	Fireplace inserts including open fireplaces fired by solid fuel – Requirements and test methods
EN 16510-2-3:2022	Cookers	EN 12815:2001	Cookers fired by solid fuel – Requirements and test methods
EN 16510-2-4:2022	Independent boilers for solid fuels – Rated output up to 50 kW	EN 12809:2001	Boilers fired by solid fuel – Rated output up to 50 kW – Requirements and test methods
EN 16510-2-5:202x b	Slow heat release appliances fired by solid fuel	EN 15250:2007	Storage-fired appliances fired by solid fuel – Requirements and test methods
EN 16510-2-6:2022	Mechanically by wood pellets fed roomheaters, inset appliances and cookers	EN 14785:2006	Roomheaters for pellets firing – Requirements and test methods

^a 16510-1:2018 was only used for measurements of PM, OGC, and NOx

^b Part 2-5 has not yet been published

In addition to parts 2-1 to 2-6, the part 2-7: “Mechanically by wood pellets fed and wood logs roomheaters, inset appliances and cookers” is being worked on.

The standard series EN 16510-x residential solid fuel burning appliances consists of several parts. Part 1 specifies general requirements for appliances and the applicable test methods. Parts 2 describe device-specific requirements (essential and descriptive features) and define information for the performance declaration according to the European Construction Regulation. All Parts 2 are to be applied in connection with Part 1. Annex A (test methods) of Parts 2 must always be considered.

New requirements haven been established. It is now required to measure the emissions of the appliances and to determine the seasonal space heating energy efficiency as well as energy efficiency class. In addition, the emission limits for PM, NO_x, OGC and CO have been adapted to the requirements of the Ecodesign Regulation (EU) 1185/2015. The emission limits for the seasonal space heating energy efficiency per type of appliance have also been adapted to the requirements of the Ecodesign Regulation (EU) 1185/2015. In the course of the safety test, additional distances compared to the predecessor standards must be measured. A risk assessment must be carried out for certain devices.

In emission tests for fireplaces fired by wood logs, three cycles must be considered for calculating the average emission, two of them must be consecutive. For all other fuels, two consecutive cycles must be considered to calculate the average emission in the course of the emission test.

To determine the efficiency of fireplaces fired by wood logs, three cycles must be considered for calculating the average, two of them must be consecutive. For all other fuels, two consecutive cycles must be considered for calculating the average in the course of efficiency tests.

With the harmonization of the standards series, the EN-PME method according to Annex F of EN 16510-1:2022 becomes mandatory for type testing. Furthermore, the content and requirements of Annex ZA change significantly, so the Declaration of Performance must be adjusted accordingly.

Use of historical data

The Sector Group SG03/WG2 of designated test laboratories for roomheaters for solid fuels discussed the application of the new standards and further use of test results from previous tests (historical data). This was presented using EN 13240 and EN 16510-2-1. A common position shall be published as an approved guide by GNB-CPR. The development of separate documents as position papers of SG03/WG2 for the use of historical data for other parts such as EN 14785 and EN 16510-2-6 will follow later.

The final evaluation of whether historical data from an existing type test report can be adopted will be made individually by the notified bodies. After approval of the guideline, we will publish details on the evaluation and use of historical data.

Due to the high demand and the high administrative effort, we recommend conducting new tests now and reviewing your test reports early.

With this year, the implementation for the requirements of the Eco-Design Regulation (EU) 2015/1185 in 2022 is getting closer and closer. At the turn of the year, the meeting of the German technical heads of laboratories took place. There, the implementation of Eco-Design requirements in practice with regards to the test reports and the manufacturers documents were clarified between industry, German standardization bodies and German notified bodies. 

At this meeting, it was discussed, which documents apply. It should be noted that many manufacturers only pay attention to average values shown in the test reports and compare them with the Eco-Design requirements. However, in addition, further requirements must be met. These emerge both from the regulation itself and from an associated official journal of the European Commission (see below).

What is the legal bases?

• The general requirements and value limits are specified in the Eco-Design Regulation (EU) 2015/1185. In addition, the Official Journal of the European Commission “2017/C 076/02” applies.

ATTENTION

Many manufacturers only pay attention to the average values ​​shown in test reports and compare them with the eco-design requirements. In addition, there are further requirements mentioned in the Official Journal “2017/C 076/02” need to be met!

So that no invalid declarations are created, we would like to give you specific information on how to meet the requirements:

• The declaration is made by the manufacturer, not by the test laboratory.
• Currently, the declaration is made by the manufacturer in the technical documentation listed in the regulation, not in the declaration of performance according CE marking.
• A test report of the current EN standards (EN 13240, 13229, 14785, 12815, 15250, etc.) is not sufficient for the declaration.
• CO, NOx and OGC content must have been determined in accordance with EN 16510-1.
• This also applies to the heat output and efficiency (with the exception of EN 14785 and EN 15250).
• The dust content must have been determined in accordance with CEN/TS 15833 or EN 16510-1.
• If the manufacturer requests confirmation from the test laboratory, this must not appear as a notified body in the document (the Notified Body Number is not mentioned).
• If the manufacturer declares compliance with Eco-Design, he bears the sole responsibility.

What does this mean in practice?

• Confirmation letters from test laboratories, such as certificates, lists, letters of confirmation, in which the test laboratory appears as a notified body – as they are currently published by some manufacturers are for marketing purposes – may not serve as a base for the declaration.
• The measurements of the above-mentioned parameters must have been performed in accordance with EN 16510-1. This applies to new test as well as performance tests. The requirements of EN 16510-1 are, for example:
  • At least 2 continuous burning cycles in a row
  • For EN 13229 fireplaces 3 burning cycles instead of 2
  • Different minimum burning cycle times
• The fuels used in the test must correspond to the fuel specification of EN 16510-1. This also applies to new test as well as performed tests.
• If the manufacturer wants to know whether his test report, for example according to EN 13240, is compliant to the above-mentioned requirements, the test laboratory carry out an evaluation of the raw data if necessary. An alternative is that the measurement method EN 16510-1 is listed for the corresponding parameters in the current test reports.
• The manufacturer can also declare compliance with the Eco-Design requirements based on their own measurements and calculations. Based on this, however, no official confirmation / certificate can be created by our laboratory.

What kind of support does the RRF offer you:

• Issue of certificates for publication
• If necessary: re-evaluation of raw data or re-examination of the missing parameters on the test bench
• Issue of letters of confirmation of the fulfilment of the requirements for internal use

If you have OEM products in your portfolio, you should have the test report, which serves as the basis, checked by the owner of the original test report.

We are happy to offer you the opportunity to discuss further details on this topic in a personal meeting. If you send us a list of your fireplaces / test reports, we can make you an offer for the evaluation effort and the above-mentioned services for you.

Link to the Regulation: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015R1185

Link to the Journal: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1613464324868&uri=CELEX%3A52017XC0310%2804%29

Even during the corona pandemic, standardization work does not stand still. Therefore, the RRF is still active in the standardization committees like currently for the topic of exhaust systems (TC 166) and takes part in the web meetings on your behalf.