Commercial electric water heaters

July 2017

Technical bulletin on developing the standards

Webinar – August 2017

On March 4, 2017, the Office of Energy Efficiency at Natural Resources Canada (NRCan) issued a Notice of Intent to amend Canada’s Energy Efficiency Regulations (the Regulations) to adopt  minimum energy performance standards (MEPS) for commercial electric storage water heaters. This technical bulletin has been released to initiate the consultation process and to collect stakeholder views on the requirements being considered for commercial electric storage water heaters.

Input received during this stage of the process will inform the development of the Amendment 15 proposal.  In addition, NRCan is undertaking a cost-benefit analysis using the best-available Canadian market data to assess the economic and environmental impacts of these updated standards and to ensure Canadian consumers and businesses benefit from their implementation.

The Government of Canada intends to pre-publish a regulatory proposal in the Canada Gazette, Part I, within approximately two years of this bulletin.

Background

Through the Pan Canadian Framework and Energy and Mines Minister’s Conference the federal, provincial and territorial governments have committed to working together to achieve climate change goals. Through this collaboration, governments agreed that standards for some space and water heating products, such as commercial water heaters could, for climatic and market reasons, differ from those in the U.S.

In Canada, commercial water heaters are not subject to the Energy Efficiency Regulations (the Regulations). NRCan is considering introducing MEPS for commercial electric storage water heaters. NRCan has undertaken a market study to look at the potential costs and benefits of introducing standards for commercial water heaters at different benchmark levels, including:

• current regulated levels in the U.S.; and
• the May 31, 2016 U.S. NOPR levels.

A preliminary cost benefit analysis suggests that introducing standards beyond the current U.S. DOE levels for all sizes of commercial electric storage water heaters is not economical at this time. NRCan is therefore considering proposing MEPS for all commercial electric storage water heaters at current U.S. DOE levels.

Product description

A commercial electric water heater heats water for use in cooking, cleaning, and bathing, using electricity as the fuel source. Commercial electric storage water heaters have input rates of ≥12 kW.

Energy performance testing standard

NRCan is considering referencing the following energy performance testing standard:

• ANSI Z21.10.3-2015/CSA 4.3-2015 – Gas-fired water heaters, Volume III, storage water heaters with input ratings above 75,000 Btu per hour, circulating and instantaneous.

The CSA testing standard can be ordered from:

CSA Group
Toll Free Phone: 1-800-463-6727
In Toronto, call 416-747-4044
E-mail: sales@csagroup.org
Website: http://www.shop.csa.ca

Some CSA energy efficiency testing standards are also available at no cost on their website. To access free standards you will first need to create an account to join the CSA Communities of Interest.

Energy performance standard

Minimum energy performance standards being considered for commercial electric storage water heaters
Product type	Heating capacity (kW)	Minimum efficiency requirement
Electric storage water heater	≥12 kW	Standby loss ≤ (0.3 + 27/Vm)

Vm is measured volume (gal)

Important dates

These regulations would come into force six months after the date of publication in the Canada Gazette, Part II.

NRCan proposes that for commercial water heating products, the standards would apply to products that have been manufactured on or after January 1, 2020.

Verification requirements

NRCan would require that these products carry a third party verification mark indicating that the product mets the MEPS and that information to be reported has been verified.

The verification mark is the mark of a Standards Council of Canada accredited certification body that operates an energy efficiency certification program for the product.

Reporting requirements

Energy efficiency report

The energy efficiency report required for commercial water heaters would include the following information:

• name of product (i.e. commercial water heater)
• brand name
• model number
• name of the manufacturer
• name of the certification body whose verification mark would be affixed to the product
• input rate
• standby loss
• measured volume of storage tank

The Regulations apply to products imported or shipped inter-provincially for sale or lease in Canada. This report must be submitted, by the dealer, to NRCan before the product is imported into Canada or traded inter-provincially for the first time.

Import report

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

• name of product
• model number
• brand name
• 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)

Comments invited

The purpose of this bulletin is to provide stakeholders with technical detail required to comment on the requirements under consideration for commercial electric water heating. 

Additional information on Canada’s Energy Efficiency Regulations including a current list of Standards Council of Canada accredited certification bodies can be found in the Department’s website.

We welcome your comments by September 7, 2017. All correspondence should be forwarded to:

Natural Resources Canada
Office of Energy Efficiency
580 Booth Street
Ottawa, ON, K1A 0E4
E-mail: nrcan.equipment.rncan@canada.ca