The changing face of solid fuel
The world changes and our sector must change with it. Unfortunately, there are some legacy issues that must be dealt with and change can be difficult for some. Turning an industry is like turning an oil tanker, it takes planning, energy and time. We are now starting to see changes happening at legislative level, the new Air Quality (Domestic Solid Fuels Standards) (England) Regulations 2020 are just one example of changes our industry is facing. We have also seen the introduction of Ecodesign and Energy Labelling in recent years and there are changes coming to the Environment Bill that will also impact how we all operate.
Industry sectors face the same overall challenges but from different perspectives, and the detailed issues can cause different challenges for different stakeholder groups. Installers and consumers face similar challenges in some ways. Retailers, Installers and manufacturers want to give the best quality advice to help consumers choose an appliance and fuel, and the consumer relies on them to be the ‘font of all knowledge’. This is then backed up by the guidance given by chimney sweeps and servicing technicians on their regular visits following an installation.
Working across the supply chain
HETAS works across the supply chain with our interests in the safe and environmentally responsible use of solid fuels, wood, biomass and associated technologies. We cover the supply chain from fuels through appliances, chimneys and flues, ancillary equipment, training of installers and retailers, appliance and system maintenance right through to chimney sweeping. We are a not-for-profit company limited by guarantee without share capital. We are not a trade association and so are not influenced by commercial matters. Recently our organisational purpose was updated and simply states:
Working together for a cleaner and safer environment.
View the HETAS Mission and Purpose at www.hetas.co.uk/about-hetas
It is our role to give independent and impartial advice and HETAS, along with Woodsure, are the only specialist UK organisations working across the supply chain in this way.
As a UKAS Accredited certification body much of our work is ensuring compliance with standards such as the Competent Persons Scheme, MCS appliances and installers are all UKAS Accredited activities and other non-accredited activities are conducted using the same principles of certification and registration. We are annually audited to ensure we meet these standards and are proud of our ongoing accreditation, demonstrating that we run our schemes in the right way.
Our industry does face some challenges and HETAS is leading the way in working with various government departments to overcome these challenges.
Transparency in testing and product approval
The current test regime for CE marking and for the future Ecodesign Regulations (for stoves) is based on the European system of attestation – system 3. Whilst gas appliances have to go through rigorous third-party testing and test labs make decisions on whether gas appliances meet the manufacturing standards, the solid fuel system is different and includes more self-certification by the manufacturer. That is the way the system works at the moment and many manufacturers are very good at designing and making highly engineered, clean and efficient appliances.
Solid fuel appliances have to be tested by accredited labs which provide a report to the manufacturer who considers the report and if satisfied with the test results, self-certificate their own appliances. The manufacturer has input into which tests are carried out and which are not.
The HETAS Appliance Approval scheme (and website listing with easy search function) gives manufacturers an opportunity to have those decisions and test reports examined and verified by an impartial organisation. Those who take that up are demonstrating confidence in their decisions and a willingness to be challenged. If there are areas of ambiguity or where HETAS believes more needs to be done, the manufacturers go ahead and make changes or provide extra supporting information. The product will not be listed by HETAS if these requirements are not met. HETAS approval goes further and checks that the appliance is suitable for installation in the UK against local Building Regulations; and that installation and use instructions are in English and don’t encourage any illegal installation practices that may be accepted in other countries. Only the HETAS Approval scheme deals with CE marking this way. Changes are also imminent with CE marking as we transition from the EU, find out more about the UKCA mark here.
With three different appliance approval schemes in operation, it is fair to ask what is the purpose of each and why are there three? If all appliances were made equal, then there would be no need for any schemes like these. The MCS scheme was designed to support the Government’s Renewable Heat Incentive Scheme and the SIA ClearSkies scheme is designed to look at the emission expectations within the wider Ecodesign Regulations due in 2022 for stoves and already here for boilers. The HETAS appliance and product certification scheme is designed to help consumers, retailers, installers, specifiers, architects etc support in choosing the right appliance for the particular customer. It answers questions about compliance with various regulations including whether the appliance is suitable for use in a smoke control area. The scheme details the performance figures so that a wise choice can be made at the time of purchase. This is critically important as new environmental Regulations (initially in England) coming into force in May 2021 will limit the type of fuel that can be sold and used to dry wood and smokeless fuels. Customers must be fully informed to ensure they are making the right choice – they can call the HETAS consumer helpline on 01684 278170.
Compliance with Ecodesign, CE Marking and general Regulation Requirements
The less robust attestation system (system 3 self-certification) extends to the future Ecodesign Regulation requirements for stoves in 2022, and it covers the sales, purchase and installation of appliances. As we move ever closer to January 2021 it is more important than ever to verify that the appliance being purchased meets all the requirements of Ecodesign and other regulations covered by HETAS Appliance Approval.
Ecodesign Regulations are ambiguous and open to misinterpretation. HETAS strongly recommends that purchasers, specifiers, retailers, installers seek evidence of genuine compliance with all parts of the regulation. There are differing approaches to CE marking and Ecodesign as well as some conflicts between Ecodesign and smoke control requirements. The HETAS Appliance Approval scheme is the only scheme that takes away the doubt and gives reassurance that listed appliances can be purchased with confidence in all of these areas of compliance.
It must be said that most manufacturers put a huge amount of time, effort and money into design and testing to ensure products are compliant and innovative in respect of their use in the environmentally responsible combustion of solid fuels. The HETAS listing on its website at https://www.hetas.co.uk/consumer/services/products/ makes it easy to find the right appliance for each different installation, be it a stove, boiler or biomass system, with filters to search for Defra exempt and MCS appliances.
These complex and technical matters don’t help manufacturers, retailers, installers and their customers. The complexity on one hand, with ambiguity on the other, only serves to confuse. How can industry make real claims about ever better and more advanced, efficient and environmentally responsible appliances when there is ambiguity in Regulation. We want to work across industry to overcome these challenges in a transparent way. It may help to understand the available product schemes and what they indicate:-
ClearSkies brought about by the Stove Industry Alliance utilises the following requirements:
- Seasonal efficiency
- Particulate emissions (carbon particles etc)
- OGC Organic gaseous compounds
The measurements for each appliance are grouped together and they produce a rating from level 2 – 5, an easy way for consumers to see which appliances overall, using the ClearSkies maths, are cleanest. Although the customer cannot see how the final rating was made up. Of course, each appliance complies in respect of individual measurement, but is this particular appliance higher in particulate emissions and lower in NOx or higher in NOx and lower in OGC and so on? The scheme does the thinking for the consumer in a general sense but for those with a more inquisitive mind there is no detail to look at. Furthermore, these 5 measures are only part of Ecodesign requirements, not the whole.
The MCS biomass appliance approval scheme only considers whether an appliance is manufactured consistently and to the right standard; also checking factory production controls with a UKAS Accredited Scheme. Hence it is robust in the areas that it covers, although this is mainly biomass boilers for central heating and hot water.
With so much ambiguity and possible confusion it can be hard to make the right purchase decision. This is why independent and impartial HETAS Approval exists. It gives a way to provide trust and transparency from an impartial organisation, allowing retailers, installers, servicing technicians and chimney sweeps to have trust and impartial information for their customers. HETAS lists both stoves and boilers that meet full Ecodesign Compliance here. The process of approval is straightforward, click here for more details.
Guidance Note 3 is available in the Technical Hub of the website and provides detailed guidance for installers, retailers and manufacturers on the details of Ecodesign legislation.
HETAS has already received many enquiries across industry and from consumers confused about approval schemes.
It is HETAS that operates the Defra stove exemption process on behalf of Defra (since December 2018, read more here) and as we have the contract with Defra only we can accept applications for exemption. We also operate the fuel exemption scheme where fuels are “authorised” by Defra for use in smoke control areas. No other organisation can do that. In addition to running our own product approval scheme, HETAS runs an MCS product scheme for biomass and administers the RHI Emissions Certificate List website, a search facility that helps locate RHI Emissions Certificates for biomass appliances, for support in the application process of the Non-Domestic RHI and the Domestic RHI. HETAS has a long standing record in running and administering approval and certification schemes.
How HETAS supports the industry
Our website and consumer helpline are incredibly busy. We have search facilities from find an appliance, through find a retailer, installer, sweep and servicing. At every stage consumers are guided to HETAS Registered and approved products and services – they can feel confident that there is an independent organisation that has impartially provided third party certification. We are currently discussing the need for extra staff to answer the volume of customer enquiries which grows every month as we market our services ever more and more effectively. Consumers value this impartial advice.
Our website visits grow every year and even this year we are seeing more visits than last year (despite periods of lockdown) – huge numbers search for appliances, retailers, installers, sweeps and servicing businesses.
HETAS has key relationships with Government Departments as an independent third-party organisation independent of trade associations and impartial. That is a very different relationship than can be had by a trade association. Trade Associations represent the views of commercial and sales organisations like manufacturers and quite rightly so. But Government Departments recognise the difference in perspective between an organisation giving independent impartial advice and those whose job it is to represent commercial members and increase sales as their primary function. This is the same for any sector.
HETAS operates an open and transparent scheme and pricing structure that is open to appliance manufacturers of all sizes. A single appliance can be approved by HETAS from as little as £450 and the scheme covers stoves, boilers, biomass heating and extends right through to ancillary equipment, covering a wider range of products. Find out more about our wide range of product approvals at https://www.hetas.co.uk/trade/scheme/product-approval-scheme/.
When purchasing an appliance or advising others on their choice it is wise to do some research seeking as much information as possible, the HETAS Technical Helpline is available to support our registrants, along with the support documents available in the Technical Hub of the website. Recently HETAS published guidance on the ‘Selection and Identification of Solid Fuel Appliances in a Smoke Control Area’ – see HTBG061 and Construction Products Regulations & CE Marking , HTBG066, both of which are available via the Technical Hub of the website.