Manufactured Fenestration Products

May 2024

Technical bulletin on developing the standards

Webinar – Wednesday, June 19, 2024, 1:00-2:00 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 include manufactured fenestration products as a new energy-using product, including labeling and reporting requirements.

This technical bulletin has been released to initiate the consultation process and to collect stakeholder views on the requirements being considered for manufactured fenestration products.

Input received during this stage of the process will inform the development of the next amendments considered. In addition, NRCan will assess the economic and environmental impacts of these new standards 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

Manufactured fenestration products are not currently defined as an energy-using product in the Regulations. However, these products directly affect a home’s energy consumption and are a vital component of a high-performing building envelope.

Manufactured fenestration products make a significant contribution to total residential building energy consumption. More efficient manufactured fenestration products could save energy and reduce energy costs for Canadians. An efficient building envelope is critical for reducing energy-related greenhouse gas emissions, and the requirements under consideration would encourage manufacturers to improve product designs.

The Government of Canada is committed to reducing energy consumption from consumer, commercial and industrial products and support the goal of net-zero emissions by 2050.

The considered labelling and reporting requirements would support and compliment existing energy efficiency standards at the provincial or municipal levels, such as in Ontario, British Columbia, Vancouver, and Yellowknife. It would also provide product efficiency information to the public, technical professionals, and building code authorities.

Product description

A manufactured fenestration product  is defined as a manufactured or pre-assembled window, door, or skylight that separates a conditioned space from the unconditioned space or the exterior, that is intended to be installed in a building that is partially or entirely used for residential occupancy and has an area not exceeding 600 m2 and a height of 3 stories or less.

It includes:

• Windows and sliding glass doors
• Hinged and bi-folding doors, including glazing in doors, transom windows, and sidelites
• Skylights including unit skylights, roof windows, and tubular daylighting devices

Testing standard

NRCan is considering referencing the following testing standards using ambulatory incorporation by reference (as amended from time to time):

• CSA-A440.2-22 – Fenestration energy performance
• ANSI/NFRC-100-23 – Procedure for Determining Fenestration Product U-factors
• ANSI/NFRC-200-23 – Procedure for Determining Fenestration Product Solar Heat Gain Coefficient and Visible Transmittance at Normal Incidence

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

ANSI/NFRC testing standards can be ordered from the NFRC website.

Energy efficiency standard

NRCan is not considering any energy efficiency standards for manufactured fenestration products.

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 making these new regulatory requirements applicable to products manufactured on or after January 1, 2028.

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 a mandatory labelling requirement for manufactured fenestration products.

Each individual model would bear an information label in a form prescribed by NRCan. Mandatory information on the prescribed label would include:

• Manufacturer
• Date of manufacture
• Model type and class
• Model Identification code or National Fenestration Rating Council Certified Product Directory (NFRC CPD) code
• Mark of certification body responsible for testing
• U-factor of the total assembly in W/m²K, where the assembly is comprised of individual units (composite unit), the U-factor of the individual units can be reported
• Solar Heat Gain Coefficient (SHGC) of the total assembly, where the assembly is comprised of individual units (composite unit), the SHGC of the individual units can be reported
• Visible Transmittance (VT) of the total assembly, where the assembly is comprised of individual units (composite unit), the VT of the individual units can be reported

The label may also include the following optional information:

• Tested air leakage SI units (L/s·m²)
• Tested air leakage in IP units (cfm/ft²)
• Calculated Energy Rating (ER) value
• U-factor in IP units (Btu/h·ft²·F)
• Program participation and certification badges (ENERGY STAR, etc.)
• Information to direct reader to secondary sources (i.e. URL, QR code, etc.)

Verification requirements

NRCan would require that manufactured fenestration products carry a third-party verification mark indicating that the information reported has been verified.

Manufactured fenestration products would carry:

• An energy efficiency verification mark authorized by a certification body accredited by the Standard Council of Canada indicating that the product has been tested and certified according to the required testing standards, or
• The energy efficiency verification mark of the National Fenestration Rating Council (NFRC) indicating that the product has been tested and certified according to the required testing standards.

The energy efficiency verification mark would only be placed on the exterior of the product or on a temporary label affixed to the exterior of the product.

Information to be reported in the energy efficiency report would have been verified by a certification body accredited by the Standards Council of Canada, or by the National Fenestration Ratings Council (NFRC).

Reporting requirements

Energy efficiency report

The energy efficiency report for manufactured fenestration products would include the following information:

• Name of product (i.e. casement window, sliding glass door, etc.)
• Brand name
• Model number/identification code
• Product gateway model size
• NFRC CPD number, if applicable
• Name of the manufacturer
• Name of the certification body whose verification mark would be affixed to the product
• U-factor of the total assembly in W/m²K, where the assembly is comprised of individual units (composite unit), the U-factor of the individual units can be reported
• SHGC of the total assembly, where the assembly is comprised of individual units (composite unit), the SHGC of the individual units can be reported
• VT of the total assembly, where the assembly is comprised of individual units (composite unit), the VT of the individual units can be reported

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 the technical detail required to comment on the requirements under consideration for manufactured fenestration products.

NRCan is specifically interested in getting feedback on:

• The scope and extend of regulated product classes. Are there potential issues from inclusion of certain classes (e.g., skylights, doors, basement windows)
• Will there be additional burden, financial or administrative, arising from product testing by SCC accredited certification bodies.
• If NFRC accredited certification bodies are also permitted, in addition to SCC accredited certification bodies, will this reduce the burden of compliance with the proposed Regulations.
• Any concerns related to not requiring certified air leakage or Energy Rating (ER) values as mandatory fields on a standardized label. These values would be optional but not required for all regulated products.

It is important to NRCan that we engage the public and stakeholders on amendments to the 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 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

Email subject heading to be: Bulletin – Manufactured Fenestration Products – Produits de fenêtrage manufacturés – May 2024 mai