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Preparatory study for Building Automation and Control Systems (GEN – 1191.00)

04 January 2021

6 min read
European Policy

Preparatory study for Building Automation and Control Systems (GEN – 1191.00)

04 January 2021

6 min read

GEN – 1191.00. The second stakeholder meeting on the preparatory study for Building Automation and Control Systems (BACS) was held on 15 December 2020. The study team presented and discussed the deliverables. The proposed Ecodesign requirements for control systems are made separately at the packaged product level and at the installed product level. Written comments on the proposal may be submitted until 19 January 2021.


Along with provisions of the new Energy Performance of Buildings Directive (EU) 2018/844 (articles 14/15 and the Smart Readiness Indicator methodology), the study on building automation (ENER lot 38) is another effort to lay down requirements for minimum energy efficiency and energy labelling for control systems, of which a significant part is related to HVAC sector.

The second and last stakeholder meeting to present and discuss deliverables of the BACS preparatory study was held on 15 December 2020.

Recap of the developments to date

The preparatory study for BACS aimed at providing the European Commission with a technical, environmental and economic analysis of BACS in accordance with the Ecodesign Directive 2009/125/EC.

The study was carried out by a team consisting of VITO (the Flemish Institute for Technological research), Waide Strategic Efficiency Ltd (an Irish based technical and policy consultancy) and RICARDO (a global strategic engineering and environmental consultancy).

A scoping study to define the product scope and the focus areas of the subsequent preparatory study was performed from October 2017 to September 2018. Next, the preparatory study on BACS was launched in July 2019. The first stakeholder meeting took place on 3 March 2020. It was followed by the publication of the draft final report.

General overview of the study approach

The study was carried out in accordance with MEErP methodology and included the following tasks.

  • TASK 1 – Scope (definitions, standards and legislation, first screening),
  • TASK 2 – Markets modelling (volumes and prices),
  • TASK 3 – Use modelling (product demand side),
  • TASK 4 – Technologies (product supply side, Best Available Technology design option),
  • TASK 5 – Environment & Economics (Base Case Life Cycle Analysis & Life Cycle Costing),
  • TASK 6 – Design options to improve LCA + LCC,
  • TASK 7 – Scenarios (Policy, scenario, impact and sensitivity analysis).

Due to the large variety of design options, typologies and architecture of BACS, the study approach was oriented on the functions delivered by BACS and not on individual components. Nevertheless, a distinction was made between the packaged product level and the installed product level. In the first case, the related requirements and responsibility would be directly addressed to manufactures. In the latter case, these would be addressed to system integrators and installers.

Evaluation of functions and energy efficiency class was based on the well-established EN 15232 standard with reference to the 13 modelled base cases (different building types and insulation levels, climate zones and BAC methods / functions examined). The modelling was performed with assumption that in so called ‘primary functional unit (FU)’, which is 1 m² of building floor area, the thermal comfort, sanitary hot water (SHW), indoor air quality (IAQ) and lighting requirements (per EN 16798 1:2019) for health, productivity and comfort of the occupants are maintained.

Relevant findings and conclusions

According to the study authors, the average energy performance of BACS already installed in EU27 buildings is between class D and class C, but the most typical newly installed systems have class C energy performance.

For the study needs it was assumed that as a starting point for defining Best Available Technologies (BAT) for larger buildings with a total useful floor area greater than 1000 m2, the energy saving functionality defined by EN 15232 Class A BACS could be considered. In turn, for smaller buildings with a total useful floor area less than 250 m2, it could be Class B.

However, the results of the Least Life Cycle Cost (LLCC) calculations revealed that for new Low Energy Buildings (LEB), not all BACS BAT design options modelled resulted in LLCC (payback period was over 15 years, whereas 15 years was used as product lifetime in the MEErP tool). Despite of this it was concluded that new LEB often rely on complex TBS and the owner will likely benefit from higher class BACS to avoid a performance gap and support continuous commissioning.

Interrelationship with the EPBD

The Ecodesign BACS policies are perceived as potentially supporting the current EPBD measures. From this perspective, the ecodesign requirements would impose minimum limits on energy performance or minimum information requirements (e.g. which EN 15232 functions are supported). In turn, the Energy labelling requirements would impose performance labelling and information declaration. In support to this view, the study team identifies the following BACS related gaps in the EPBD:

  • BACS are not mandatory below 290kW nor in residences,
  • Performance specification for >290kW non-residential BACS is open-ended,
  • Art 8 optimizing the performance of Technical Building System i.a. with controls is open-ended,
  • BACS system performance is not explicitly linked to EN 15232 classes and there is no requirement to use EN 15232.

Summary of potential Ecodesign measures for BACS

In Task 7, the study team put forward a tentative proposal for Ecodesign measures. It was noted that the requirements are subject to further discussion and evaluation. The requirements are specified separately at the package product level and for the installed product level.

A general outline of the proposal is given below. For more detailed information refer to the related documents (Task 7 report and 2nd stakeholder meeting presentation).

Packaged product level

Devices considered as candidates to be covered in the packaged product level requirements include for instance: room temperature controllers and schedulers, air flow sensors, room humidity controllers, room air quality controllers but also packaged building energy management systems.

Responsibility for the compliance of these product would lie with BACS and HVAC manufacturers.
The market surveillance approach in this case would be the same as for other Ecodesign products.

The following groups of requirements are proposed.

Specific minimum performance limits

This group would include requirements regarding the accuracy limits and internal power consumption limits per function and/or per I/O point.

Specific minimum functionality requirements

The nature of requirements would consist, for example, in demonstrating minimum compatibility with classes of EN 15232, sufficient memory to allow for upgrading or modularity and interoperability to support repairs (e.g. a standard protocol). For the packaged Building Energy Management Systems, a set of key performance indicators (KPI) would need to be developed.

Information requirements

The information proposed to declare include compatibility of a product with EN 15232 BACS solutions, low power mode wattage, interoperability capabilities, lifetime, upgradability or power consumption for auxiliary power calculation.

Installed product level

Requirements at this level would apply either to any installed BACS, or installed BACS differentiated by application (e.g. building type).

Responsibility for the compliance would lie with system integrators and installers. 
The market surveillance approach would be different compared to the packaged BACS products. It would be rather a matter of verifying that the design/installation complies with the conformity assessment tool (to be developed), which is a similar process to verifying that an Energy Performance Certificate (EPC) of the building has been issued correctly.

The following groups of requirements are proposed.

Specific energy performance limits

Requirements for the BACS minimum energy performance class (according to EN 15232).  

Specific internal power consumption limits

Requirements for BACS internal power consumption limits. Due to lack of information and analyses on power levels of installed BACS products, this option is marked as currently not viable. It could be assessed in a future study if data is available.

Specific minimum functionality requirements

The nature of these requirements would include key performance indicators (to be developed), as well as interoperability and lifetime.

Information requirements

The requirements would include information on energy performance, information on demand response, information on interoperability and other factors.

Next steps

The study team awaits writing comments on the presented tentative proposals for BAC ecodesign requirements by 19 January 2021.The study team one week after the comments are received to amend the reports. The report would then be submitted to the European Commission (EC) at the beginning of February in order to be approved and uploaded. Then EC would need to elaborate a working document for the Consultation Forum. This, together with the invitations would need to be sent one month before the meeting. This indicates a possible meeting in Q2 2021. However, this is indicative, due to internal coordination with other Lots.

Recommended actions

It is pointed out that at package product level responsibility for the compliance is not clearly defined. It would lie with BACS and HVAC manufacturers, but it is not specified how this would be shared or which manufacturer would be the responsible one.

The installed products level does would not include a responsibility from the HVAC manufacturer. Members of the concerned Product Groups and associations are recommended to analyse the proposed design options and provide possible comments either directly to the study team or to the Eurovent Secretariat in order to develop a consolidated Eurovent position.   

Related documents and links

All related documents and articles can be found in the respective sections in the right sidebar.


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