EME Newsletter MEssage #01/2023

NEWSLETTER
INSIGHTS
Regulatory developments in the GCC
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
Markus Lattner
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 custommade,
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 noncertified
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
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