Regulatory bodies in the region are back in full steam to revise existing regulations for air conditioners after two more quiet years owed to the pandemic. Markus Lattner, Managing Director of Eurovent Middle East, shares insights into discussions, developments and the association’s positions.
Currently, regulations for both small and large-capacity air conditioners (GSO 2630, SASO 2663, SASO 2874, UAE.S 5010-1, UAE.S 5010-5) are under revision by the respective bodies and technical committees, which are working in full steam. To fully understand the implications of regulatory developments, it is important to dissect a technical regulation into its major parts.
Normative references
For one, normative references ultimately determine under which standards and test methods a product is allowed to enter a market. The references commonly used internationally in the HVAC sector are ISO, EN and ANSI standards. The decision of which one specifically to apply is a challenging one. In this globalised time, products and components are manufactured and shipped around the world. For instance, most air conditioning equipment for IT cooling sold in the Middle East is produced by European factories. However, that doesn’t mean they are European companies.
Most of the big international players from Asia, Europe and America have production lines all over the globe and produce for local and regional markets, but also beyond. The industry is not divided along political borders but rather bound to what the markets demand. Inclusivity in terms of normative references thus is preferred by manufacturers to allow flexibility in regards to their supply chain. As long as the standards referenced reflect the latest versions and are comparable in terms of testing methodology and results, it provides much-needed fairness in market access.
For some products, ISO standards have been agreed to by most of the players and became the preferred option, while for other products EN or ANSI standards still prevail, mostly due to weaker or lacking ISO coverage. Additionally, environmental conditions demand regional adjustments of international standards to reflect the increased requirements for energy performance and durabilites in the region.
Normative references also have significant impact on market surveillance and regulatory compliance. In itself a crucial point for a closer look, which I will get back to in a bit. Overall, it is important to address such references on a product-by-product basis, to clearly understand the origins of equipment and avoid interruptions of supply chains.
Minimum energy performance requirements
Minimum energy performance requirements (MEPS) are core and purpose of such regulations. They define minimum efficiency values for products in the market and are the basis of any energy labelling. In the current revisions, authorities are set to change from EER to SEER (Seasonal Efficiency) calculations. The industry fully supports this transition as SEER provides a more realistic calculation of energy consumption, especially with more variable speed technology in place.
As SEER is based on weather bins, it can be fully adjusted to local requirements. Eurovent has looked at various weather bins in the region and concluded, from sample calculations, that the differences among weather bins of Saudi Arabia, Kuwait and UAE lead to only marginally different SEER values, opening the door for a regional unified weather bin and harmonisation of regulations across the GCC, even for Kuwait.
In terms of defining minimum requirements, the discussion is ongoing. While split units have taken a leap with the inverter technology, the region still holds on to window-type ACs, widening the possible range of energy efficiency labels. Here the question stands if an energy label which starts at a SEER value of 8 and rises in steps up to above 19 is really effective. After all, it would do little to push the market to better performances.
As an industry association, we believe a bolder push to raise efficiency levels is possible. Not taking any side for or against technology, but some manufacturers have shown that also window types can be fitted with inverters, improving their efficiency significantly over non-inverters. The technology is freely available and would allow also local producers to adjust. Increasing the minimum requirements would therefore be feasible. But this, ultimately, is a decision the government has to take.
Compliance
Compliance requirements make the third major part of a regulation and the part which can inflict the highest costs on suppliers. The Middle East depends a lot on pre-market testing of imported products. This means that before a unit is shipped, manufacturers must apply, register and get their products approved by the authorities, or else shipments would be denied entry into the country. This adds substantial administrative, testing, and certification costs.
In a price-sensitive and highly competitive environment, one can imagine that the interpretation and execution of regulatory requirements can make a huge difference. The industry needs a fair and level playing market. Every manufacturer wants to ensure that his competitor follows the same rules. Thus, ensuring that all products are fully in line with the laws and regulations is absolutely critical.
Owing to the lack of local testing capabilities, market surveillance is not a strong point in the region. Furthermore, it only really works for consumer goods, not custom-made, larger equipment. This aspect underlines the advantage of independent third party certification as offered by organisations like AHRI and Eurovent. Both have established certification programmes in cooperation with the industry, allowing an independent, objective and neutral certification of product performances, which a majority of manufacturers already use.
These certifications are requested by planners and consultants and are, therefore, already in wide use. And such certificates are also in place for customised equipment, which otherwise wouldn’t be possible to assess if not for a unit by unit testing, for which neither enough testing capacities exist, nor would it make any financial sense. So, why are we not using these already existing certifications to prove compliance with regulations?
Eurovent for instance, has already adapted its certification to Middle East requirements, reflecting the need for T3 conditions in testing methods. It would allow governments to bring up to 80% of the market under regular surveillance, as both AHRI and Eurovent are based on recurrent testing, and allows that limited budgets for market surveillance can be used to focus on non-certified products.
It also would relieve manufacturers from the requirement of having their products tested again and again, with no added benefits. All it would need is a directive to notifying bodies that such certificates are recognised as proof of equipment performance, based on which these bodies are allowed to establish compliance. It again requires flexibility in the normative references to make room for ANSI and EN standards and the respective testing standards of Eurovent and AHRI.
Country-specific requirements and harmonisation
Other critical aspects of regulations usually refer to country-specific requirements, which equally can become very costly. Kuwait’s understandable insistence on specifying T4 conditions or the UAE requirement for a 20-degree cut-off limit for ACs, or the need to accommodate varying voltage declarations on name plates and country-specific energy labels, are making life difficult for manufacturers.
Harmonisation would substantially reduce air conditioning costs in the region while increasing the number of available options in the market. The T4 requirement in Kuwait is prohibitive for many suppliers, as the low market volume renders investment in extra testing and certification not feasible. The 20-degree temperature limitation, while in itself a very worthwhile and valuable political consideration, brings about a number of concerns. As only applied in the UAE, it requires extra stockholding and costly processes to fulfil. Additionally, its effectiveness in achieving the original intention of implementation is doubtful, as Eurovent Middle East has outlined in another article. (See the article “Setting the Limits”)
Harmonisation is the top priority for the industry and could unlock more energy-saving potential through regulatory intervention as is currently achieved in the bespoke regulations. It would reduce unit prices considerably making room for more ambitious performance requirements. After all, what is the point of different requirements in each GCC country if ultimately the products sold are exactly the same?
Stakeholding – the importance of working together
Eurovent Middle East is involved in all current technical committees providing inputs by the industry. Within several open meetings in the past months, we called upon members and non-members to provide us with their comments and we have established the main positions of the industry, which we will bring forward to each committee. But if the industry wants to see more harmonisation and be heard by regulators, it is crucial to show support and work together.
Stakeholding processes are complicated and take their time. Equally, authorities need to understand that due process is vital to better regulations and that an industry association needs time to discuss and consent on positions with manufacturers. There is room for improvement on either side, but overall I see many steps in the right direction. It is a long way to go, but at least we are on the right road.