Electric water heaters
July 2022
Technical bulletin on amending the standards
On April 1, 2022, 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 align household electric water heaters with the energy efficiency and testing standards 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 household electric 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 updated energy efficiency and testing 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 2023.
Background
In Canada, household electric water heaters manufactured as of February 3, 1995, are subject to the Regulations.
Household water heaters use a significant portion of total residential building energy consumption. The energy efficiency standards for household electric water heaters save energy and reduce energy costs for Canadians. The efficiency standards also reduce energy-related greenhouse gas emissions and help encourage manufacturers to adopt efficient product designs.
In 2018, the Memorandum of Understanding between the Treasury Board of Canada Secretariat and the United States Office of Information and Regulatory Affairs Regarding the Canada–United States Regulatory Cooperation Council was signed to move forward on energy efficiency and foster alignment of federal regulations where feasible and appropriate. 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 July 11, 2014, the U.S. DOE published a Federal Register final rule pertaining to residential and commercial water heaters, which updated the testing standard (79 FR 40541 ). On December 29, 2016, the U.S. DOE published a Federal Register final rule pertaining to residential and commercial water heaters, which established energy efficiency standards using the uniform energy factor test procedure (81 FR 96204 ).
NRCan is considering amending the Regulations to align with energy efficiency and testing standards of the U.S. DOE.
Product description
An electric water heater is defined in the Regulations as a stationary electric storage tank water heater that is intended for use on a pressurized water system and that has a nominal storage tank volume of at least 50 L (13.21 US gallons).
A household electric water heater is defined in the Regulations as an electric water heater with an input rate of less than 12 kW (40,982 Btu/h).
Testing standard
NRCan is considering referencing the following testing standard, using an ambulatory incorporation by reference:
- Appendix E to Subpart B, 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 household electric water heaters are summarized in the table below.
| Product rated storage volumea (Vr) | Draw patternb | Energy efficiency standardc (Uniform Energy Factor) |
|---|---|---|
| ≥50 L and ≤454 L | Very Small | 0.8808 − 0.000211 Vs |
| Low | 0.9254 − 0.000079 Vs | |
| Medium | 0.9307 − 0.000053 Vs | |
| High | 0.9349 − 0.000026 Vs | |
| a Vr represents the nominal volume, expressed in litres, of a water heater’s storage tank. b Represents the number, flow rate, length and timing of hot water removal from a water heater during testing. c Vs represents the measured storage volume, expressed in litres, of a water heater’s storage tank. |
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Text version
The table title is “Energy efficiency standards being considered for household electric water heaters”. This is the only product in the table. There are three vertical columns, with the left-hand column providing the product rated storage volume, the middle column providing the draw pattern, and the right-hand column providing the energy efficiency standard. The energy efficiency standard is labelled as having units called the uniform energy factor.
Below the table, there is an explanatory note providing information for the left-hand, middle, and right-hand columns. Each column has an explanatory note labelled “a”, “b”, and “c” respectively. Explanatory note “a” for product rated storage volume, states that this column uses the symbol V subscript r, and represents the nominal volume, expressed in litres, of a water heater’s storage tank. Explanatory note “b” for draw pattern states that this column represents the number, flow rate, length and timing of hot water removal from a water heater during testing. Explanatory note “c” for energy efficiency standard, states that this column uses the symbol V subscript s, which represents the measured storage volume, expressed in litres, of a water heater’s storage tank.
The product rated storage volume for household electric water heaters is greater than or equal to 50 liters but less than or equal to 454 liters.
There are four draw patterns which are very small, low, medium, high. For a very small draw pattern, the energy efficiency standard is greater than or equal to 0.8808 minus the product of 0.000211 and the measured storage volume, expressed in liters, of a water heater’s storage tank. For a low draw pattern, the energy efficiency standard is greater than or equal to 0.9254 minus the product of 0.000079 and the measured storage volume, expressed in liters, of a water heater’s storage tank. For a medium draw pattern, the energy efficiency standard is greater than or equal to 0.9307 minus the product of 0.000053 and the measured storage volume, expressed in liters, of a water heater’s storage tank. Finally, for a high draw pattern, the energy efficiency standard is greater than or equal to 0.9349 minus the product of 0.000026 and the measured storage volume, expressed in liters, of a water heater’s storage tank.
Important dates
These modifications to the Regulations would come into force six months after the date of publication in the Canada Gazette, Part II.
NRCan is considering applying the updated energy performance and test standards to household electric water heaters manufactured on or after January 1, 2025.
Labelling requirements
NRCan is not considering labelling requirements for household electric water heaters. Voluntary labelling requirements may be considered in consultation with industry.
Verification requirements
NRCan is not considering any changes for the verification requirements for household electric water heaters.
These products will continue to carry a third party verification mark indicating that the product meets the energy efficiency standard and that the 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 household electric water heaters would be updated to include the following additional product specific information:
- Input rate in kW (Btu/h)
- Annual energy consumption in kWh
- First-hour rating in L
- Vs the measured storage volume, expressed in litres,
- Uniform Energy Factor
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
There is no change being considered to import reporting.
Comments invited
The purpose of this bulletin is to provide stakeholders with the technical detail required to comment on the requirements under consideration for household electric water heaters.
NRCan is specifically interested in getting feedback on:
- The feasibility and effectiveness of alternative household electric water heater testing approaches focused on insulation performance (e.g., R-value) and water heater construction;
- The benefits of greater Canada-United States regulatory alignment for electric water heaters; and
- The date of manufacture to which the regulatory amendments under consideration for household water heater would apply.
It is important to NRCan that we engage the public and stakeholders on amendments to the Energy Efficiency Regulations. If you are aware of any dealer, 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 the representative this bulletin. Please email equipment-equipement@nrcan-rncan.gc.ca to be added to the email distribution list (emails are used to notify stakeholders of upcoming amendments, technical bulletins, webinar registrations, and official publication in the Canada Gazette).
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 15, 2022. All correspondence should be forwarded to:
Natural Resources CanadaOffice of Energy Efficiency
580 Booth Street
Ottawa, ON, K1A 0E4
E-mail: equipment-equipement@nrcan-rncan.gc.ca
Email subject heading to be:
Bulletin – Electric Water Heaters – Chauffe-eau électriques – July 2022 juillet
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