Commercial Water Heaters

May 2024

Technical bulletin on developing the standards

Webinar – Wednesday, June 5, 1:00-2:30 pm EDT

In April 2024, the Office of Energy Efficiency at Natural Resources Canada (NRCan) updated its Forward Regulatory Plan which identifies its intention to amend Canada’s Energy Efficiency Regulations (the Regulations) to harmonize commercial water heaters with energy efficiency standards, testing standards and labelling requirements in the United States.

This technical bulletin has been released to initiate the consultation process and to collect stakeholder views on the requirements being considered for commercial water heaters and for residential-duty commercial water heaters.

Input received during this stage of the process will inform the development of the next amendments considered. In addition, NRCan will undertake a cost-benefit analysis using the best-available Canadian market data to assess the economic and environmental impacts of these new 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, in 2025.

Background

In Canada, the following commercial water heaters manufactured are subject to the Regulations:

• Commercial gas-fired storage water heaters
• Commercial oil-fired storage water heaters
• Commercial electric water heaters
• Commercial gas-fired instantaneous water heaters

Hot water supply boilers, residential-duty commercial storage water heaters, and large volume commercial gas-fired storage water heaters are included in the current scope of the Regulations but are not specifically defined as energy-using products in the Regulations.

In 2021, NRCan and the United States Department of Energy (U.S. DOE) signed the Memorandum of Understanding Between the Department of Natural Resources of Canada and the Department of Energy of the United States of America Concerning Cooperation on Energy, which acknowledges that both countries will collaborate on new and updated energy efficiency and testing standards where feasible and appropriate.

On November 10, 2016, the U.S. DOE published a final rule that updated the testing standard for commercial water heaters. On June 21, 2023, the U.S. DOE published a final rule that updated the testing standard for residential-duty commercial water heaters.

On October 6, 2023, the U.S. DOE published a final rule that strengthened the energy efficiency standards of commercial water heaters.

NRCan is considering amending the Regulations to harmonize with the scope, energy efficiency standards and testing standards of the U.S. DOE.

Product description

The Regulations include the following definitions:

• A gas-fired storage water heater means a stationary gas-heated water container that uses propane or natural gas for fuel and has a rated volume of at least 76 L (20 US gallons). 
• An oil-fired water heater means a water heater that uses oil for fuel and that has a rated volume of at least 76 L (20 US gallons).
• A gas-fired instantaneous water heater means a flow-activated water heater that uses natural gas or propane for fuel, that has a rated volume that is less than or equal to 38 L (10 US gallons) and has an input rate to rated volume ratio of not less than 309 W/L (4,000 Btu/h/US gallon).
• An electric water heater means a stationary electric storage tank water heater that is intended for use on a pressurized water system and that has a rated volume of at least 50 L (13.21 US gallons). 

NRCan is considering adding the following definitions to the Regulations to align with the scope of the U.S. DOE:

• A hot water supply boiler means a commercial boiler that has an input rate greater than or equal to 87.9 kW (300,000 Btu/h) but less than or equal to 3,663 kW (12,500,000 Btu/h), an input rate to stored water volume ratio greater than or equal to 309 W/L (4,000 Btu/h/US gallon), and that:
  • (a) Has temperature and pressure controls necessary for heating potable water for purposes other than space heating and/or having intended uses which include heating potable water for purposes other than space heating; or
  • (b) The manufacturer's product literature, product markings, product marketing, or product installation and operation instructions indicate that the boiler's intended uses include heating potable water for purposes other than space heating.
• A commercial storage type instantaneous water heater means an instantaneous water heater that includes a storage tank with a rated storage volume greater than or equal to 38 L (10 US gallons).
• A commercial electric instantaneous water heater means an electric water heater with a rated input greater than 12 kW and an input rate to V_r ratio of not less than 309 W/L (4,000 Btu/h/US gallon).
• A residential-duty commercial water heater means any gas-fired storage, oil-fired storage, or electric instantaneous commercial water heater that:
  • (c) For models requiring electricity, uses a single-phase external power supply; and,
  • (d) Is not designed to provide outlet hot water at temperatures greater than 82.2°C (180°F).
  • It does not include:
  • (a) a gas-fired storage type water heater with a rated storage volume (V_r) greater than 454 L (120 US gallons) and a rated input greater than 105 kBtu/h;
  • (b) an oil-fired storage type water heater with a rated storage volume (V_r) greater than 454 L (120 US gallons) and a rated input greater than 140 kBtu/h; or
  • (c) an electric instantaneous water heater with a rated storage volume (V_r) greater than 7.57 L (2 US gallons) and a rated input greater than 58.6 kW.
• An instantaneous water heater means a water heater that uses gas, oil, or electricity, including:
  • (a) Gas-fired instantaneous water heaters with a rated input both greater than 200,000 Btu/h and not less than 4,000 Btu/h per US Gallon of stored water;
  • (b) Oil-fired instantaneous water heaters with a rated input both greater than 210,000 Btu/h and not less than 4,000 Btu/h per US Gallon of stored water; and
  • (c) Electric instantaneous water heaters with a rated input both greater than 12 kW and not less than 4,000 Btu/h per US Gallon of stored water.

NRCan is considering amending the current definition of electric water heater in the Regulations to align with the scope of the U.S. DOE:

• An electric storage water heater means a stationary water container heated exclusively by electric resistance and that is intended for use on a pressurized water system and that has a rated volume of at least 50 L (13.21 US gallons). It does not include an instantaneous electric water heater.

Testing standard

NRCan is considering incorporating by reference the following testing standards (as amended from time to time):

For commercial gas-fired storage water heaters:

• Appendix A to Subpart G of Part 431 of Title 10 to the U.S. Code of Federal Regulations, entitled Uniform Test Method for the Measurement of Thermal Efficiency and Standby Loss of Gas-Fired and Oil-Fired Storage Water Heaters and Storage-Type Instantaneous Water Heaters

For commercial electric instantaneous water heaters:

• Appendix D to Subpart G of Part 431 of Title 10 to the U.S. Code of Federal Regulations, entitled Uniform Test Method for the Measurement of Standby Loss of Electric Instantaneous Water Heaters (Other Than Storage-Type Instantaneous Water Heaters)

For commercial gas-fired instantaneous water heaters (including hot water supply boilers):

• Appendix C to Subpart G of Part 431 of Title 10 to the U.S. Code of Federal Regulations, entitled Uniform Test Method for the Measurement of Thermal Efficiency and Standby Loss of Gas-Fired and Oil-Fired Instantaneous Water Heaters and Hot Water Supply Boilers (Other Than Storage-Type Instantaneous Water Heaters)

For residential-duty commercial electric, gas and oil-fired storage water heaters

• Appendix E to Subpart B to Part 430 of Title 10 to the U.S. Code of Federal Regulations, entitled Uniform Test Method for Measuring the Energy Consumption of Water Heaters

Energy efficiency standard

The energy efficiency standards under consideration for commercial water heaters other than residential-duty commercial water heaters are listed in:

• Table 1 to Section 431.110(a) Subpart G, Title 10 to the U.S. Code of Federal Regulations, entitled Commercial Water Heater Energy Conservation Standards

The energy efficiency standards under consideration for residential-duty storage commercial water heaters are listed in:

• Table 2 to Section 431.110(c) Subpart G, Title 10 to the U.S. Code of Federal Regulations, entitled Residential-Duty Commercial Water Heater Energy Conservation Standards

Important dates

NRCan is considering applying the new energy efficiency standards to commercial water heaters and to commercial residential-duty water heaters manufactured on or after October 6, 2026.

Regulatory pathway

NRCan is considering amending the Regulations through Governor in Council amendment.

The considered changes would be pre-published in the Canada Gazette, Part I, followed by a public comment period. The exact date for final publication in the Canada Gazette, Part II will depend on the number and nature of comments received during the public comment period. Final publications are typically within a year of their initial public comment period. These changes and the timing of publication are subject to decision-making authorities under the Energy Efficiency Act.

Labelling requirements

NRCan is considering removing the replacement unit/non-replacement unit labelling requirement for commercial water heaters to harmonize with the United States.

Verification requirements

NRCan would require that the products carry a third-party verification mark indicating that the product meets the energy efficiency standards 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 for commercial instantaneous water heaters and hot water supply boilers would include the following information:

• Name of product
• Brand name
• Model number
• Name of the manufacturer
• Name of the certification body whose verification mark would be affixed to the product
• Rated storage volume in litres
• Measured storage volume in litres, when applicable
• Maximum flow rate in litres per minute (US gallons per minute), when applicable
• Recovery efficiency in percent (%), when applicable
• Uniform Energy Factor, when applicable
• Input power in kW (Btu/h)
• Thermal Efficiency in percent (%), when applicable
• Standby Loss in percent per hour or watts per hour (Btu/h), when applicable
• Annual energy consumption consumption, in kilojoules (kJ), when applicable

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 the technical detail required to comment on the requirements under consideration for Commercial Water Heaters.

It is important to NRCan that we engage the public and stakeholders on amendments to the Regulations. If you are aware of any manufacturer, importer, retailer, utility provider, small business, consumer group, organization, or representative of a specific group(s) of the population (including, but not limited to, women, 2SLGBTQQIA+ people, persons with disabilities, visible minorities, socio-economic status, residency, housing status, etc.), Indigenous peoples/communities, and/or other person or group that may be interested in participating in the amendment discussion and/or may be negatively impacted by this proposal, please forward them or their representative this bulletin. Please click here to register to our mailing list which is used to notify stakeholders of upcoming amendments, technical bulletins, webinar registrations, official publication in the Canada Gazette, etc.

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

We welcome your comments by September 13, 2024. All correspondence should be forwarded to:

Natural Resources Canada
Office of Energy Efficiency
580 Booth Street
Ottawa, ON, K1A 0E4

E-mail: EEregulations-reglementEE@nrcan-rncan.gc.ca

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Bulletin - Commercial water heaters – chauffe-eau commerciaux – May 2024 mai