Canada to Increase Water Heater Efficiency

Higher Efficiency Requirements for Water Heaters
Bulletin on Developing and Amending Standards
June 2010

Revised and New Regulations

The Office of Energy Efficiency (OEE) of Natural Resources Canada (NRCan) is proposing to amend Canada's Energy Efficiency Regulations (the Regulations) under which dealers in Canada would be required to comply with higher efficiency requirements for gas and oil water heaters and new reporting requirements for electric water heaters. For the first time in Canada, commercial water heaters and tankless water heaters will have minimum efficiency requirements. These proposed revisions would apply to water heaters that are imported or shipped across provincial boundaries for sale or lease in Canada.

The purpose of this document is to provide stakeholders with background information for meaningful consultation on the content of the new regulation before proceeding with pre-publication in the Canada Gazette. This bulletin attempts to address key issues that may be raised. It is not intended to provide a definitive representation of the proposed regulation.

Background

Water heating accounts for a large portion of residential and commercial energy use and has potential for significant energy and greenhouse gas (GHG) reductions.

NRCan last updated the EE Regulations for electric and gas storage water heaters in 2004. At present in Canada, there are no energy efficiency regulations for commercial water heaters or for tankless gas water heaters.

Storage water heaters continue to dominate the market. Sales of residential water heaters in Canada are about one million per year, with approximately 80% as replacement and 20% going into new houses. Sales of commercial water heaters are about 21,000 per year with about 13,000 gas storage water heaters and about 7000 electric storage water heaters. Commercial water heaters have larger storage capacity or greater energy inputs to meet greater hot water demands.

This bulletin outlines federal changes that are proposed for a variety of water heaters types. Some proposed changes coincide with future requirements in the United States.

This proposed amendment will have the greatest impact on the efficiency of gas water heaters, both residential and commercial. The efficiency of most residential fossil-fuel storage water heaters lies in the range of Energy Factor (EF) from 0.55 to 0.60. In 2008, the ENERGY STAR specification was introduced and this has led to increased number of higher efficiency storage models, up to EF 0.70 (non-condensing). Tankless gas water heaters with higher efficiency are making gains in the market, partly as a result of recent incentives and programs. Efficiency of most tankless models meets or exceeds EF 0.80 (non-condensing) and EF 0.90 (condensing). Most gas-fired commercial water heaters comply with the US minimum thermal efficiency of 80% and there are many condensing commercial storage models having TE of 92% and above.

NRCan’s analyses show the proposed changes are economic over the life of the equipment.

Product description

For the purposes of the Regulations, water heaters include gas, propane, and oil-fired water heaters and electric water heaters. Storage and tankless (instantaneous) water heaters are included in this proposed amendment.

Minimum performance levels

Note: V & V_r are in litres

For all water heaters, the proposed amendment requires that CSA Plus 1200 be used as the methodology for reporting ratings.

Energy performance test procedures

The test methods used to determine efficiency are:

CSA P.3-04: "Testing Method for Measuring Energy Consumption and Determining Efficiencies of Gas-Fired Storage Water Heaters"

CSA P.7-10: "Testing Method for Measuring Energy Loss of Gas-Fired Instantaneous Water Heaters"

CSA C191-04: "Performance of electric storage tank water heaters for domestic hot water service"

CSA B211-00: "Energy Efficiency of Oil-Fired Storage Tank Water Heaters"

CSA 4.3 / ANSI Z21.10.3-2004: "Gas Water Heaters Volume III, Storage Water Heaters, with Input Ratings above 75,000 Btu per hour, Circulating and Instantaneous"

The standards are available from:

Some test methods are undergoing revisions. When changes to test methods are made, future amendments to the EE Regulations are expected to include reference to revised test methods.

Effective dates

These requirements will be brought in over a period of several years in order to provide time for the industry to increase availability of higher efficiency models. This amended regulation is expected to come into effect from January 1, 2012 to January 1, 2016 as indicated in the table.

Labelling requirements

As required now, all regulated water heaters must have efficiency verification labels that indicate a third party has verified the ratings.

Efficiency labelling of water heaters is being considered.

Verification requirements

Third party verification will be required on energy efficiency ratings (EF, standby loss, thermal efficiency), tank capacities (measured, diffusion test, and rated volume), standby power, and whether Plus 1200 has been used for ratings.

Importing reports

A dealer who imports these products into Canada must include the following information on the Customs release document:

• Type of product
• Model number
• Brand name
• Name and address of the dealer importing the product
• Purpose for which the product is being imported (i.e. for sale or lease in Canada without modification; for sale or lease in Canada after modification to comply with energy efficiency standards; or for use as a component in a product being exported from Canada)

Harmonization

The Province of British Columbia has recently introduced higher minimum efficiency levels for water heaters and expects to advance those requirements further. Other provinces may also be planning to introduce regulations for higher efficiency for water heaters. The US DOE has recently published a final rule for water heaters with somewhat higher efficiency requirements for 2015.

The proposed changes as outlined above have significant differences from requirements in the US. The intent is to develop consistent requirements for all of Canada.

Comments Sought

Initial discussions have taken place with water heating stakeholders. Those discussions will continue and this bulletin should generate greater interest with those stakeholders. A webinar will be held and notice will be sent to stakeholders.

Any comments and questions should be forwarded to: