An energy using functional system consists mostly of a particular combination of various products tailored to the situation at hand by the contractor or installer. Every installed system is unique, and the installers are responsible for their creation – effectively they are the system’s “manufacturers”. The only exception to this rule would be when a system is sold as a “product package”, such as a closed pump unit consisting of an electrical motor, a VSD (Variable Speed Drive) and the pump itself.
Consequently, energy efficiency labelling or regulation addressing the system will have to make installers responsible for compliance. This leads to the question of whether they are ready to take on such complex responsibilities. One risk is that installers will lack the means to carry out this task, which could lead to poor implementation of the regulation in the field. Another risk is that only adequately large contractor companies will be well-enough equipped, leading to market distortion at the expense of small independent installers.
There have been a few cases where installers have been held responsible for individual installation compliance with EU regulations, but most of these cases were related to safety and not so much to energy efficiency.
The following solutions could provide the necessary support to installers if they are made responsible for the system compliance:
- Limiting the associated administrative burden;
- Providing training and educational programmes, preferably leading to certification;
- Introducing positive incentives, such as applying a label stating the total energy savings an installer helped to achieve in the previous year through installing compliant systems;
- Ensuring international standards with clear and pragmatic calculation methodologies are available;
- Assuring easy access to manufacturer component data;
- Providing technology and manufacturer-independent design tools free of charge;
- Providing insurance products tailored to supporting installers with their responsibilities;
There are precedents for EU regulation putting compliance responsibility on installers, mostly related to safety. Broadening to energy efficiency is possible with appropriate support.