In 2018, HETAS released details of the recently published testing standard BS EN 16510-1 General Requirements and test methods for residential solid fuel burning appliances. The new requirements have been developed over a number of years through the relevant European Standards committee, with the intention of providing an updated and more robust means for testing solid fuel heating appliances, whilst also aligning with upcoming future European legislation within the Energy Labelling & Ecodesign regulations.
To further support HETAS approved manufacturers in understanding their future responsibilities for testing UK marketed products, HETAS has provided responses to some of the more common queries received on what effects the application of BS EN 16510-1 will have.
What regulations/directives do manufacturers need to meet to sell products on the UK market?
As it stands currently, the main regulatory requirements to be met by manufacturers of solid fuel burning appliances include the Construction Products Regulations (CPR), Energy Labelling Regulations and UK Building Regulation requirements for efficiency and safe use. Manufacturers of independent boiler appliances (those appliances with a heat loss of less than 6% of its rated heat output) are required to meet the Machinery Directive (MD), and if the product contains any electrical components for control, the low voltage directive (LVD).
From 1st January 2022 (1st January 2020 for independent boilers), appliances will also be required to meet the recently published Ecodesign regulations, which sets new efficiency and emission criteria for appliances to be legally sold on the UK market.
What is standard BS EN 16510-1?
The standard contains the newly developed general provisions relating to the design, manufacture, construction, safety and performance of appliances fired by solid fuel. To meet compliance with the appropriate regulations detailed above, manufacturers are required to verify the safety of their products through testing to the applicable test standard aligned with the regulation.
This standard is under development with the purpose of superseding the current set of test standard in publication (i.e. BS EN 13229 (inset roomheaters & open fires), BS EN 13240 (freestanding roomheaters, BS EN 12815 (cookers) & BS EN 12809 (up to 50kW independent boiler appliances)).
Are manufacturers required to test to the new standard currently?
No, the current agreed mandate aligned with the CPR calls for manufacturers to test their appliances to the current BS EN test series of standards. Until a new official mandate is agreed and harmonised (comes into official law) at European level which calls on manufacturers to test the BS EN 16510-1, then the document only serves a purpose as a reference and future compliance document.
If the standard isn’t harmonised, why was it published?
The European committee took the decision to release the current non-harmonised version of BS EN 16510-1 to allow industry to come to terms with the new technical caveats contained within the document, and allow manufacturers to prepare future research and development processes around the new standard.
Some national countries do call on the current standard as a transitional method for the measurement of the new Ecodesign emission limits, in the absence of any finalised test methodology being available to confirm compliance with national country requirements.
Will testing and subsequent CE marking mean the product is fit for purpose when installed in the UK?
Not necessarily, testing and affixing of the CE mark is only a manufacturer self-declaration process that they have done what is necessary of them to show compliance with the legal provisions of the CPR. There are a whole host of other requirements to fully comply with UK law, including energy labelling, building regulations and additional safety criteria not necessarily covered by the CPR.
HETAS product approval offers a more in-depth safety verification and approval that the product meets all current UK legal requirements, ensuring manufacturer documentation makes claims reflective of what was tested and installation guidance to the installer reflects UK building regulation requirements.
What appliances does BS EN 16510-1 cover?
The scope of BS EN 16510-1 currently covers solid fuel roomheaters, inset appliances, open fires, cookers, independent boiler up to 50kW, slow heat release appliances and pellet appliances. These items are covered under the subsequent sub parts to the standard parts 2-1 to 2-6.
What’s changing in this standard?
The new caveats within BS EN 16510-1 call up additional requirements not currently contained within the set of appliance test standards. Some of these updated requirements include;
- Testing for performance, including efficiency and emissions at nominal output, and if declared by the manufacturer at minimum heat output
- Additional safety temperature testing distances above the appliance to ceiling, if claimed below 750mm
- New room-sealed appliance classifications for direct air appliances, and how to test to confirm air tightness
- Inclusion of emission testing methodology reflecting Heated Filter and Dilution Tunnel methods
- Flue gas outlet temperature calculation based on measured flue gas temperature
- Appliances with boilers suitable for installation on sealed system, instruction to contain details of control devices to avoid temperature exceeding 110°C
- Additional installation and operating instruction criteria
How will this relate to the new Ecodesign Regulations?
The Ecodesign regulations are a separate set of legal requirements to the CPR, however are aligned in terms of the methodology in measuring emissions to confirm compliance, certainly in terms of Particulate Matter (PM). Currently Ecodesign allows to confirm compliance with minimum PM emission limits by one of 3 methods, either via heated filter, dilution tunnel or electrostatic precipitator.
Within the Annex of BS EN 16510-1, the methodologies for the heated filter and a variant of the dilution tunnel methodology are included, however for those manufacturers wishing to confirm compliance by the electrostatic precipitator can still use TS15883 (PD 6434) methodology in line with UK Clean Air Act requirements.