Gas-fired storage 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 gas-fired storage 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 gas-fired storage 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 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 gas-fired storage 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 gas-fired storage 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 the energy efficiency and testing standards of the U.S. DOE.
Product description
A gas-fired storage water heater is defined in the Regulations as a stationary gas-heated water container that uses propane or natural gas for fuel and has a nominal storage tank volume of at least 76 L (20 US gallons).
A household gas-fired storage water heater is gas-fired storage water heater with an input rate of less than or equal to 21.97 kW (75,000 Btu/h).
Testing standard
NRCan is considering limiting the testing option by 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 gas-fired storage water heaters are summarized in the table below and require energy efficiency performance in terms of uniform energy factor.
| Product type | Energy efficiency standard (Uniform Energy Factor)a |
|---|---|
| Household gas-fired storage water heaters that have a first-hour rating of < 68 L (18 US gallons) | ≥ 0.3456 – 0.00053 Vs |
| Household gas-fired storage water heaters that have a first-hour rating of ≥ 68 L (18 US gallons) but < 193 L (51 US gallons) | ≥ 0.5982 – 0.00050 Vs |
| Household gas-fired storage water heaters that have a first-hour rating of ≥ 193 L (51 US gallons) but < 284 L (75 US gallons) | ≥ 0.6483 – 0.00045 Vs |
| Household gas-fired storage water heaters that have a first-hour rating of ≥ 284 L (75 US gallons) | ≥ 0.692 – 0.00034 Vs |
| a Vs represents the measured storage volume, expressed in litres, of a water heater’s storage tank. | |
Text version
The table title is “Energy efficiency standards being considered for household gas-fired storage water heaters”. There are two vertical columns, with the left-hand column providing the product type and the right-hand column providing the energy efficiency standard. The energy efficiency standard is labelled as having units called the uniform energy factor. There is an explanatory note stating that a symbol used in the energy efficiency standard is V subscript s, and that the symbol represents the measured storage volume, expressed in liters, of a water heater’s storage tank.
There are four products listed. The first product type is “household gas-fired storage water heaters that have a first-hour rating of less than 68 liters, which is equivalent to about 18 United States gallons”. The energy efficiency standard for the product type is greater than or equal to 0.3456 minus the product of 0.00053 and the measured storage volume, expressed in liters, of a water heater’s storage tank.
The second product type is “household gas-fired storage water heaters that have a first-hour rating of greater than or equal to 68 liters (18 United States gallons) but less than 193 liters (51 United States gallons)”. The energy efficiency standard for the product type is greater than or equal to 0.5982 minus the product of 0.0005 and the measured storage volume, expressed in liters, of a water heater’s storage tank.
The third product type is “household gas-fired storage water heaters that have a first-hour rating of greater than or equal to 193 liters (51 United States gallons) but less than 284 liters (75 United States gallons)”. The energy efficiency standard for the product type is greater than or equal to 0.6483 minus the product of 0.00045 and the measured storage volume, expressed in liters, of a water heater’s storage tank.
The fourth product type is “household gas-fired storage water heaters that have a first-hour rating of greater than or equal to 284 liters (75 United States gallons)”. The energy efficiency standard for the product type is greater than or equal to 0. 692 minus the product of 0.00034 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 gas-fired storage water heaters manufactured on or after January 1, 2025.
Labelling requirements
NRCan is not considering labelling requirements for household gas-fired storage water heaters. Voluntary labelling requirements may be determined in consultation with industry.
Verification requirements
NRCan is not considering any changes for the verification requirements for household gas-fired storage 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 gas-fired storage water heaters would be updated to reflect the changes considered for the standards. The following product specific information would be required:
- Vr expressed in litres, of a water heater’s storage tank
- Type of fuel used
- Input rate, in kW (Btu/h)
- Recovery efficiency
- Annual energy consumption, in kJ
- 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 in regard 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 gas-fired storage water heaters.
NRCan is specifically interested in getting feedback on:
- The date of manufacture to which the considered regulatory amendments for household gas-fired water heaters would apply; and
- The benefits of greater Canada-United States regulatory alignment for household gas-fired storage water heaters.
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 – Household Gas-fired Storage Water Heaters – Chauffe-eau à réservoir alimentés au gaz domestiques – July 2022 juillet
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