Water Technology List Criteria Review 2016/17
04/06/2016
Criteria Review Questionnaire for Efficient showers
a) Introduction
The Government’s Water Technology List (WTL) promotes products that encourage sustainable water
use and rewards businesses for investing in them through the Enhanced Capital Allowance (ECA)
scheme. Claiming ECAs for buying water efficient equipment enables businesses to reduce investment
costs and their environmental impact. Manufacturers and suppliers with products included on the
WTL can use a symbol to promote their products and offer their customers a unique financial benefit.
The WTL is managed by Defra and HM Revenue & Customs (HMRC) in partnership with Ricardo Energy
& Environment who manages the WTL on behalf of Defra.
b) Reason for the review
Each year the eligibility criteria for a number of technologies on the WTL are reviewed. The criteria
sets out the performance standards that products are required to meet in order to be admitted onto
the WTL. Therefore it is vital that the criteria are at the forefront of water efficiency and that it reflects
any advances in the technology while continuing to be relevant, clear and workable.
This stakeholder consultation will help us to understand how stakeholders value the scheme and
collect market information which is essential for assessing what impact the ECA scheme has on
encouraging businesses to invest in water efficient products. It is also vital in allowing us to inform HM
Treasury of the expected value of the tax incentive.
We have already consulted with a Technology Working Group which raised a number of key points.
These discussion points raised are provided in Section C below and we invite you to provide your
feedback highlighting your thoughts and opinions. We also ask you to consider the current eligibility
criteria (see Appendix 1) and provide any other comments you may have on their relevance and clarity.
This consultation period will remain open until Friday 29th July.
Manufacturer and supplier feedback is essential to this review process and without it Government
may take the view that the scheme is not valuable to the sector and consequently remove the
technology from the WTL.
All responses must be received by Friday 29th July 2016 at the latest. Please email your completed
questionnaire to: [email protected]. All responses received will be anonymised. If you have
any questions, please do not hesitate to get in contact.
c) Key discussion points
The following discussion points were raised during the initial stages of the criteria review. We ask that
you review the comments and respond to the questions provided in the table below.
1
Water Technology List Criteria Review 2016/17
Company name
04/06/2016
[Insert company name]
1) Demonstrating compliance with the Regulations - ISO 9001
The suitability of a self-conformity declaration for companies accredited to ISO 9001 was discussed.
ISO 9001 is a certified quality management system (QMS) for organisations who want to prove their
ability to consistently provide products and services that meet the needs of their customers and other
relevant stakeholders. The representatives from WRAS and Thames Water advised that ISO 9001 would
not be accepted by them as proof of compliance with the Water Supply (Water Fittings) Regulations.
a) Should the self-conformity
provision be removed from
the criteria?
b) Can some more requirements
be added for products that
use the self-conformity
method of proving
compliance, such as
appropriate CE marking
where applicable?
2) Flow rate requirements - minimum flow rate
The current criteria for all sub-technologies under the efficient showers category specifies “a fully
formed spray pattern, with a flow rate of no more than 8 litres/minute when operated at dynamic
pressures up to 5 bar (for all spray settings).”
The consensus from the TWG stakeholders was that the maximum flow rate provided in the criteria is
correct, however some stakeholders suggested that a minimum flow rate should also be specified
within the criteria. The stakeholders advised that the benefit of introducing a minimum flow rate to
the efficient showers criteria would help avoid poor quality products being included on the WTL,
reduce maintenance and hygiene issues with pipes getting blocked and to avoid ‘cheats’ within the
market. A similar approach has recently been adopted by the European Water Label.
a) What are the implications of
introducing a minimum flow
rate in the criteria?
3) Relevant changes to regulations and standards - Regulators’ Specifications
The TWG suggested that some areas in the Regulators’ Specifications which are currently referenced
in the criteria for efficient showers had changed. It has been agreed that relevant stakeholders will be
consulted during the wider consultation to ensure that any necessary updates are taken into
consideration.
a) Are there any updates to the
Regulators’ specifications
that should be made to the
criteria?
4) Mechanical and pneumatic push systems – flow duration - Termination of flow rate
The current criteria for mechanical and pneumatic push systems specifies that “The system must
allow the user to turn on the flow through the mechanical or pneumatically operated shut off valve
and the flow rate must be terminated after a maximum of 2 minutes.”
It was highlighted by some members of the TWG that 2 minutes as the maximum for the flow to be
terminated seems high. There is a likelihood that this could result in water being wasted depending
2
Water Technology List Criteria Review 2016/17
04/06/2016
on the situation and user, for example, if someone presses the button and walks away after 20
seconds. There was a suggestion that termination of the flow rate after 1 minute may have a better
water saving potential, however concerns were raised that this may prove to be a nuisance for the
end-user.
a) What proportion of
mechanical and pneumatic
push showers have
adjustable settings to control
termination time?
b) What is the impact on
usability if reducing the
termination time of the flow
rate on mechanical and
pneumatic push showers?
5) Does ECA drive investment in water efficient showers?
The feedback from the TWG members was that the WTL may do very little to drive investment into
the efficient showers technology area. Whilst the manufacturers in the room were commenting
anecdotally, they did advise that they receive very infrequent requests from purchasers looking for
products that qualify for ECA. It was also noted that the manufacturers tend to deal directly with
specifiers rather than end-users.
a) Does ECA drive investment in
water efficient showers?
6) Technology developments
a) Are you aware of any
innovations or technological
advances that would impact
on the current WTL criteria
for efficient showers?
b) Does the Enhanced Capital
Allowance scheme still
provide an incentive to
purchase efficient showers?
c) Why has there been a
significant reduction in
product applications under
the efficient showers
technology area in recent
years?
d) Are there any barriers
preventing manufacturers
from submitting applications
to have products included on
the List?
7) Standards
Are there any recent legislative
changes or any relevant
standards that would affect the
current WTL criteria for efficient
showers?
8) Key drivers
3
Water Technology List Criteria Review 2016/17
04/06/2016
If you currently have products on
the List, what were your key
drivers for getting them listed?
9) Any other comments
Do you have any other comments
on the current eligibility criteria
shown in Appendix 1?
10) Market data
Market information is essential for assessing the impact of the ECA scheme in encouraging businesses
to invest in water efficient products and to inform HM Treasury of the expected value of the tax
incentive. The data provided is used to estimate the current size of the UK market, the potential value
of WTL equipment and estimated growth in the market.
All stakeholder responses received are treated as confidential and all industry data will be reported in
an aggregated format that maintains individual stakeholder anonymity. This technology may be
removed from the WTL if market data is not provided by stakeholders.
Please complete the questions below. The table allows you to enter actual data where known, or your
best estimate where specific data are not available.
Efficient showers
Data where known
(number / cost)
Estimated data
(number/ cost)
Where estimated please
state your assumptions
a)
b)
c)
d)
a)
b)
c)
d)
a)
b)
c)
d)
a)
b)
c)
d)
a)
b)
c)
d)
a)
b)
c)
d)
a)
a)
How many units did you sell in the UK in the
last 12 months?
a)
b)
c)
d)
Aerated Showerheads
Auto Shut Off Showers
Low Flow Showerheads
Thermostatic Controlled Showers
What is the price range of the equipment
you sell?
a)
b)
c)
d)
Aerated Showerheads
Auto Shut Off Showers
Low Flow Showerheads
Thermostatic Controlled Showers
What is your share of the UK market?
a)
b)
c)
d)
Aerated Showerheads
Auto Shut Off Showers
Low Flow Showerheads
Thermostatic Controlled Showers
What proportion of your sales is equipment
sold for business use?
a) Aerated Showerheads
4
Water Technology List Criteria Review 2016/17
b) Auto Shut Off Showers
c) Low Flow Showerheads
d) Thermostatic Controlled Showers
04/06/2016
b)
c)
d)
b)
c)
d)
a)
b)
c)
d)
a)
b)
c)
d)
a)
b)
c)
d)
a)
b)
c)
d)
What proportion of your sales is equipment
sold for business use and meet the WTL
criteria?
a)
b)
c)
d)
Aerated Showerheads
Auto Shut Off Showers
Low Flow Showerheads
Thermostatic Controlled Showers
What are your main client sectors for
purchases of flow controller equipment, e.g.
hospitality?
Please provide the proportion of each buyer
type ( % )
What do you expect the likely growth of the
market (or your sales) to be in the next 1
year / 5 years / 10 years?
a)
b)
c)
d)
Aerated Showerheads
Auto Shut Off Showers
Low Flow Showerheads
Thermostatic Controlled Showers
To ensure the data we provide to the Government is as robust as possible, we are also interested in
collecting data from other sources, e.g. trade associations, market research companies. If you are
aware of any other sources of information relating to the UK market for Efficient Showers that would
help Defra assess the impact of the WTL please provide details below.
Contact name:
Telephone number (if known):
Email address (if known):
5
Water Technology List Criteria Review 2016/17
04/06/2016
Appendix 1: Current criteria for Efficient Showers
Efficient showers deliver less water than ordinary showers without compromising shower
performance. Through their unique design and/or particular way of delivering the water, efficient
showers save not only water but also reduce energy consumption due to the amount of energy
required to heat the water for a hot shower. Investment in efficient showers qualifies for an ECA
provided the equipment is named in the Water Technology List.
The following sections set out the criteria that the individual components of efficient showers must
meet in order to be eligible to be included in the List.
The following showerheads and shower sets are supported:




Low flow showerheads
Aerated showerheads
Thermostatic controlled shower sets
Auto shut off showers
o Electromagnetic systems
o Mechanical and pneumatic push systems
Aerated Showerheads
To be eligible for inclusion on the Water Technology List the device must meet the following criteria:
Show evidence of compliance with the following sections of the Water Supply (Water Fittings)
Regulations 1999:



Part II Requirements – Paragraph 4 ‘Requirements for water fittings etc’
Schedule 2 – Requirements for water fittings, paragraph 2 ‘Materials and substances in
contact with water’
Note: This would be demonstrated by approval through WRAS (or equivalent independent
product certification body) or a declaration that all non-metallic materials in contact with
the water comply with BS 6920
Schedule 2 – Requirements for water fittings, paragraphs 3, 4 and 5 ‘Requirements for water
fittings’
Note: This would be demonstrated by approval through WRAS (or equivalent independent
product certification body) or a declaration of compliance with the following regulators’
specifications
6001.1 - Identification
1112.1 – Porosity test (pressure resistance)
1113.1 – Joint effectiveness (mechanical strength)
Compliance with the regulations may be demonstrated by approval through WRAS. Alternatively
companies accredited to ISO 9001 may provide a declaration of conformity with the Regulations.
An efficient aerated showerhead is defined as a showerhead that mixes air and water and delivers a
fully formed spray pattern, with a flow rate of no more than 8 litres/minute when operated at
dynamic pressures up to 5 bar (for all spray settings).
Aerated showerheads must also meet the following requirements:
Hydraulic Characteristics - when tested using test apparatus generally in accordance with BS 63404:1984 the measured flow rate shall not exceed 8 litres/minute under pressures up to the maximum
6
Water Technology List Criteria Review 2016/17
04/06/2016
operating pressure specified by the manufacturer or at pressures up to and including 5 bar where no
maximum is specified.
The manufacturer shall also supply details of either, the minimum dynamic pressure at which the
showerhead starts aerating, or the minimum dynamic pressure at which the spray pattern is fully
formed, whichever is the greater.
Manufacturers should apply to Defra with evidence that their products meet these criteria in
order to appear on the Water Technology List.
Auto Shut Off Showers
To be eligible for inclusion on the Water Technology List the device must meet the following criteria:
Show evidence of compliance with the following sections of the Water Supply (Water Fittings)
Regulations 1999:



Part II Requirements – Paragraph 4 ‘Requirements for water fittings etc’
Schedule 2 – Requirements for water fittings, paragraph 2 ‘Materials and substances in
contact with water’
Note: This would be demonstrated by approval through WRAS (or equivalent independent
product certification body) or a declaration that all non-metallic materials in contact with
the water comply with BS 6920
Schedule 2 – Requirements for water fittings, paragraphs 3, 4 and 5 ‘Requirements for water
fittings’
Note: This would be demonstrated by approval through WRAS (or equivalent independent
product certification body) or a declaration of compliance with the following regulators’
specifications
6001.1 - Identification
1111.1 – Closure test (watertightness)
1112.1 – Porosity test (pressure resistance)
1113.1 – Joint effectiveness (mechanical strength)
1211.14 – Endurance test (mechanical endurance of shower shut off valves)
1211.21 – Endurance test (mechanical endurance of solenoid valves)
Compliance with the regulations may be demonstrated by approval through WRAS. Alternatively
companies accredited to ISO 9001 may provide a declaration of conformity with the Regulations. All
automatic shut off showers must also meet the following requirements:
Hydraulic Characteristics - when tested using test apparatus generally in accordance with BS 63404:1984 the measured flowrate shall not exceed 8 litres/minute under pressures up to the maximum
operating pressure specified by the manufacturer or at pressures up to and including 5 bar where no
maximum is specified.
Automatic Shut off showers fall into two categories:
Electromagnetic systems
This is defined as a complete shower set (or equivalent) consisting of the following parts: the
showerhead, rail or holder, a flexible hose or fixed riser pipe and a shut off valve linked to an
electromagnetic sensor. There are two types of electromagnetic sensor systems:
7
Water Technology List Criteria Review 2016/17


04/06/2016
Presence detection systems should only operate when user presence is detected and water
should stop in any instance of failure of the detection system. The flow rate must be
terminated within three seconds of user departure.
Time flow operated showers must allow the user to turn on the flow through the sensor
device and the flow rate must be terminated after a maximum of 2 minutes.
Mechanical and pneumatic push systems
This is defined as a complete shower set (or equivalent) consisting of the following parts: the
showerhead, rail or holder, a flexible hose or fixed riser pipe and a mechanical or pneumatically
operated shut off valve. The system must allow the user to turn on the flow through the mechanical
or pneumatically operated shut off valve and the flow rate must be terminated after a maximum of 2
minutes.
Manufacturers should apply to Defra with evidence that their products meet these criteria in order
to appear on the Water Technology List.
Low Flow Showerheads
To be eligible for inclusion on the Water Technology List the device must meet the following criteria:
Show evidence of compliance with the following sections of the Water Supply (Water Fittings)
Regulations 1999:



Part II Requirements – Paragraph 4 ‘Requirements for water fittings etc’
Schedule 2 – Requirements for water fittings, paragraph 2 ‘Materials and substances in
contact with water’
Note: This would be demonstrated by approval through WRAS (or equivalent independent
product certification body) or a declaration that all non-metallic materials in contact with
the water comply with BS 6920)
Schedule 2 – Requirements for water fittings, paragraphs 3, 4 and 5 ‘Requirements for water
fittings’
Note: This would be demonstrated by approval through WRAS (or equivalent independent
product certification body) or a declaration of compliance with the following regulators’
specifications)
6001.1 - Identification
1112.1 – Porosity test (pressure resistance)
1113.1 – Joint effectiveness (mechanical strength)
Compliance with the regulations may be demonstrated by approval through WRAS. Alternatively
companies accredited to ISO 9001 may provide a declaration of conformity with the Regulations.
A low flow showerhead is defined as a showerhead that delivers a fully formed spray pattern, with a
flow rate of no more than 8 litres/minute when operated at dynamic pressures up to 5 bar (for all
spray settings). The manufacturer shall supply details of the minimum dynamic pressure at which
the spray pattern is fully formed.
Low flow showerheads must also meet the following requirements:
Hydraulic Characteristics - when tested using test apparatus generally in accordance with BS 63404:1984 the measured flowrate shall not exceed 8 litres/minute under pressures up to the maximum
8
Water Technology List Criteria Review 2016/17
04/06/2016
operating pressure specified by the manufacturer or at pressures up to and including 5 bar where no
maximum is specified.
Manufacturers should apply to Defra with evidence that their products meet these criteria in order
to appear on the Water Technology List.
Thermostatic Controlled Showers
To be eligible for inclusion on the Water Technology List the device must meet the following criteria:
A thermostatic mixing valve that enables the control of water flow and temperature, either via a
single control device or separate control devices, and is approved by the TMV3 scheme with E
designation.
The applicant must supply details of suitable shower sets to ensure safety and functionality for use
with the TMV3 thermostatic mixing valve for which the application is made. Details of the range of
sets will be included with the valve’s description on the Water Technology List. A complete shower
set (or equivalent) consists of the following parts: the showerhead, rail or holder, a flexible hose or
fixed riser pipe and a shut off thermostatic mixing valve.
Manufacturers should apply to Defra with evidence that their products meet these criteria in order
to appear on the Water Technology List.
9