Impact Assessment for Walk in Cold
Rooms
Report for European Commission
AEA/R/ED[Category]
Issue Number 1.2c
Date 9/12/2012
Impact Assessment for Walk in Cold Rooms
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Ref: ED57346 - Issue Number 1.2c
Ref: AEA/ED[Category]/Issue Number 1.2c
ii
Impact Assessment for Walk in cold rooms
Executive summary
Market situation
A ‘walk-in cold room’ is a refrigerated enclosure intended for the storage of chilled and/or
frozen foodstuff or other perishable items, accessible via at least one door, and which is
large enough to let somebody walk into it.
The market can be segmented as in Table S1 and Figure S2. Above 400m3 are only major
industrial installations. The estimates for stock are extrapolated to EU 27 from UK national
estimates.
Table S1. Segmentation of EU27 WICR market (based on 2009 data).
Size of Estimated
cold
stock
–
room
Chilled
>5°C
(% of units)
Estimated
stock
–
Frozen
<5°C
(% of units)
Estimated
stock
–
Total
(units)
Estimated
stock
–
Total
(% of units)
Estimated
Estimated
energy
energy
consumption of consumption of
stock
stock
(TWh)
(%)
Small,
<20m3
Medium,
20
to
100m3
Large,
100
to
400m3
Total
44%
23%
1,020,000
67%
7.47
40%
23%
8%
477,000
31%
9.14
50%
1%
1%
25,000
2%
1.85
10%
68%
32%
1,522,000
100%
18.46
100%
Figure S2. Breakdown of energy consumption by size category.
Large,
10%
Small,
40%
Med, 50%
There are 3 main types of WICR by style of construction:

Ready-made insulated enclosures (very small rooms only, tiny niche market and
reducing).

Prefabricated kits (modular cold rooms) for assembly on site of the insulated
enclosure from pre-packaged set of components (generally for small rooms, lesser
and reducing proportion of market).
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms

Customised cold rooms built on site from insulation panels, joints and other
components (always used for large cold rooms but increasingly used for small and
medium as well – account for the majority of the market and increasing).
The market is increasingly moving towards customised cold rooms cut and built on site, even
for smaller rooms due to price pressures and better customisation
WICR with gross volume over 100 m3 are generally of highly customised designs and
installed by skilled professionals. Some cold rooms have walls that form an external shell of
a building (exposed to weather). These may have specific conflict with building regulations
requirements, but anecdotal evidence implies very few cold rooms of the intended scope of
the regulation have external walls and these will generally only be in the large size category.
No previous EU or specifically relevant national regulations have been identified, though the
USA has minimum requirements established for walk in cold rooms since 2009.
Some test methodologies are established for insulating panels that cover measurement of Uvalue and also for thermal bridges in joints and other features but these require adaptation
and translation into harmonised standards. ETA standards cover many aspects of
construction of prefabricated kits only and one national code of practice (UK) has been
identified that covers installation but is mainly aimed at medium and large cold stores and
almost no content on energy efficiency directly-related issues.
Problems to be addressed in the market
The key problems to be addressed are:
1. Poor quality of installation of cold rooms driven by very high downward pressure
on price. Construction often by unsupervised and low skilled workforce and no
post-installation inspection or functional testing
2. Insulation performance significantly less than economic optimum, particularly in
southern Europe. Typical insulation thicknesses (as a proxy for performance)
appear to be 30% to 40% less in southern Europe than in northern Europe and
Scandinavia for comparable installations - apparently due to cultural differences.
3. Measures to reduce air ingress may not be installed (automatic door closers and
strip curtains etc)
Price pressures have further fragmented the market away from prefabricated kits (which
potentially have better quality control, particularly for joints) and towards ‘customised’ on-site
construction from panels and components bought and assembled by small suppliers. There
is little control of installation quality for many customised cold room, and only a handful of
major manufacturers comply with CE marking in the EU, although there are relevant ETA
guidelines. No certificate of correct installation is generally issued to customers and installers
rarely verify any functional parameters (refrigeration plant is often installed later anyway).
There are accessible and cost-effective savings that the market does not pursue. Insulation
performance is the simplest opportunity and probably the most effective for regulation to
address (most notably thickness, but also use of more thermally effective blowing agents),
with energy savings of 7% for chilled stores and 8% for frozen stores through increasing
insulation from poor practice to good practice levels. Reducing air ingress through open
doors is another significant cause of losses with savings possible from fitting automated door
closers in a typical store.
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
Options for policy action
Whilst the most clear-cut policy option might be to tackle small modular/prefabricated cold
rooms, unfortunately that accounts for a very small and diminishing proportion of the market
and so cannot be recommended in isolation. Tackling the much more significant and
complex market for customised cold rooms presents a number of challenges but options
have been identified to tackle or avoid many of them. All of the measures, however, have to
confront the difficulty of establishing who in the supply chain should take unambiguous legal
responsibility for the quality and performance of the product (designer/architect, component
supplier, installer etc). This has not yet been satisfactorily resolved.
This analysis has reviewed the package of policy proposals included in the Preparatory
study, the package proposed in a Commission working document published in January 2012
and also reviewed a regulation in the USA for possible lessons. In addition, the option of a
voluntary approach to setting a maximum U-value was evaluated. The conclusion has been
that elements of each of the proposals (except the voluntary approach) can be used together
to form a viable regulatory proposal that will act to remedy some important market failures to:




Improve U-values for walls, ceilings, doors and floors across the whole EU to match
current good practice levels already common in Northern Europe and Scandinavia.
Reduce air infiltration by mandating soft door closers to ensure doors are not left
open.
Set specific limits for heat ingress through thermal bridges in the joints of
prefabricated kits for cold rooms (though this could be seen as unfairly penalising
prefabricated cold room producers as thermal bridges are a much more significant
problem in customised cold rooms, but almost impossible to control and police there).
Mandate the supply of certain information about the cold room, most importantly the
U-values of the insulated envelope components.
A particular challenge for this measure is to bring the whole of Europe up to a similar good
practice level for U-value of insulation. Stakeholders have indicated that typical practice in
southern Europe is for insulation with substantially higher U-value than is more typical in
northern Europe and Scandinavia (although this is disputed by some). This
northern/southern generalisation on typical U-value practices will clearly not apply to all
products and businesses, but seemed to be recognised by a majority of stakeholders
consulted. A key challenge is to raise the U-value standards of ‘southern Europe’ at an
economically acceptable rate, whilst ensuring that suppliers in northern Europe do not
backslide down to a worse level of performance due to price pressures. This could be
achieved through a single Tier of requirements introduced with an adequate signalling
period. An alternative of two Tiers only 18 months apart was also suggested at consultation:
the 1st aimed at beginning the improvement for southern Europe and the second to bring
performance as rapidly as practicable up to a good practice level. The period during which a
mandatory requirement below that typical in northern Europe is in force, i.e. until Tier 2, was
designed to be short enough that investment in re-tooling and product redesign to sell
cheaper and less efficient products is not attractive for northern European suppliers. There
are probably more risks in having a two-tier approach, although the single Tier could produce
a major economic shock, particularly to southern Europe.
The fundamental problem of poor quality of installation work will require a concerted effort
over many years working with sector organisations and built around a new harmonised code
of good practice. It can only be proposed at this stage that the commission sets up a
mandate for the production of the harmonised standard, but this should be designed in the
context of a strategic plan for changing the culture of the sector. Secondly, a new standard
would be required to measure the energy performance/efficiency of a cold room and
refrigeration pack system which would then open the possibility of setting standards at
system level as currently being pursued in the USA.
A review of the regulation is proposed in only 3 years in order to assess the effectiveness of
the requirements for U-values across the EU and to assimilate any renewed prospects for
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
tackling quality of installation and system level performance through availability of the
harmonised standards.
Note that several major Industry stakeholders and trade associations were involved very late
in the eco-design process (since February 2012, after the consultation forum). Additional
consultation and meeting would be politically and technically desirable, especially given the
expected need for close industry cooperation to raise quality standards in the sector.
Impact
The measures in the current proposal on improved insulation should result in savings of
between 6% to 10% for chilled rooms and 5% to 11% for frozen rooms as in Table S3. Note:
the far greater savings suggested in the Preparatory study of 24% included an impractical
mix of measures. An initial estimate of EU annual savings potential is 0.8 TWh per year due
to insulation improvements, or around 4% based on 2009 data. The direct impacts of higher
emissions of foam blowing agents are estimated to be significantly outweighed by energy
savings from better insulation. Some indicative analysis suggests that these measure will
increase product prices by 5% to 15% in a highly price sensitive market – the cost of the
improved insulated panels themselves could rise by up to 50% for poor practice level cold
rooms. Stakeholders were almost unanimous that price impacts would be significant,
although this is cost effective to end users over the cold room lifetime.
Table S3. Energy consumption, savings and CO2 equivalents for whole EU from Tier 1
and Tier 2 measures relating to U-value of insulation for walls.
Measure
Annual energy saving
compared to base case
(TWh)
CO2 equivalent annual saving
(energy usage only compared to
base case)
(Million tonnes of CO2)
Tier 1
(January 2015)
Tier 2
(July 2016)
0,4
0,16
0,8
0,31
Savings from measures proposed on thermal bridges will save less than 0.1 TWh per year
and could be seen as penalising only the prefabricated cold room market which generally
has better performing joints than customised cold rooms assembled on site (which have no
such measure imposed due to the almost impossibility of checking conformity).
Savings from measures to reduce air infiltration through doors could save 0.7 TWh per year
and were generally supported by stakeholders.
Significantly higher savings are possible through the longer term improvements to installation
quality but as noted earlier this is a long term objective.
One particular environmental risk has been identified: For the smaller cold rooms, particularly
the prefabricated rooms, the maximum U-value requirements could push some
environmentally benign but less effective foaming agents (water/ formic acid) out of that
segment of the market and encourage greater use of more effective high GWP (HFC)
materials. Evidence is insufficient at present to quantify this impact. Particular market
constraints may occur where HFC foaming agents are already banned, e.g. Austria and
Denmark. For the continuously formed insulation panels, low GWP hydrocarbon foaming
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
agents account for 95% of the market, although the thermal performance is not a good as
with HFC blown panels.
This represents a challenging and complex market for Ecodesign measures that will have to
be tackled in stages but initial measures for insulation U-value and reducing air infiltration
appear practicable, especially given the precedent of similar regulations in the USA. The
biggest savings opportunity is almost certainly in raising the quality standards of installation
work which will require a new harmonised best practice standard and a long term effort to
establish certified work force or similar measures. Another medium term process is
development of the harmonised standards necessary to characterise the performance of the
refrigeration plant with regulation of that a later possibility.
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
Table of contents
1
Introduction .................................................................................................................8
1.1 Project purpose and structure .............................................................................8
1.2 Report structure ..................................................................................................8
1.3 Procedural issues................................................................................................8
1.4 The consultation of interested parties ..................................................................9
2
Problem definition .....................................................................................................10
2.1 Nature and extent of the problem ......................................................................10
2.2 Key players affected ..........................................................................................10
2.3 Baseline Scenario .............................................................................................11
2.4 Existing standards .............................................................................................17
2.5 Related initiatives on European Union and Member State level ........................19
3
Definition of the objectives .......................................................................................20
3.1 Overall objectives ..............................................................................................20
3.2 Specific objectives.............................................................................................20
3.3 Operational Objectives: .....................................................................................20
4
Policy options ............................................................................................................21
4.1 Overview of options...........................................................................................21
4.2 Summary of option assessment ........................................................................29
5
Impacts of retained options ......................................................................................30
5.1 Elaboration of regulatory scope and other aspects applicable to all options ......30
5.2 Option E: Mandatory maximum U-values for insulation and other construction
elements .....................................................................................................................32
5.3 Option F: Mandatory limits on performance of thermal bridges in pre-fabricated
cold room kits ..............................................................................................................43
5.4 Option G: Requirements for specific design and construction elements to
minimise air infiltration and secure other energy efficiency features ............................45
5.5 Timing of implementation ..................................................................................47
5.6 Risks and uncertainties, expected compliance patterns ....................................47
5.7 Review of the regulation ....................................................................................48
5.8 Assessment of regulatory package against Ecodesign Framework Directive
requirements ...............................................................................................................48
6
Outline policy monitoring and evaluation ...............................................................50
6.1 Progress Indicators ...........................................................................................50
6.2 Issues for consideration at regulatory review.....................................................50
7
Update Log ................................................................................................................51
Appendices
Appendix 1: Working document for walk in cold rooms as discussed at 19 January 2012
consultation forum (substantially superseded)
Appendix 2: Preparatory notes for Minutes of industry meeting held 1 March 2012
Appendix 3: Minutes of industry meeting held 1 March 2012
Appendix 4: Additional background information for the implementation of eco-design
requirements for walk-in cold rooms (WICRs), prepared by JRC – IET on June 5th 2012
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
Appendix 5: CLASP report - Overview of USA Regulation on Walk‐In Cold Rooms
Appendix 6: WICF EU-U.S. Collaboration Meeting Minutes (conference call 14 March 2012)
Appendix 7: Refrigerants and related policy options and issues for Lot 1 products
Appendix 8: Assumptions regarding WICR sales, stock and energy consumption
Appendix 9: Results of research interview with INCOLD, May 2012 by JRC, Ispra
Appendix 10: SME questionnaire with summary answers
Appendix 11: Key quotes of feedback from consultation forum and other sources up to 29
June 2012
Appendix 12: Stakeholder questionnaire with answers
Appendix 13: Comments on the first draft of the WICR Impact Assessment report from PU
Europe.
List of Tables
Table 1. Consultation events and numbers of participants / respondents ...............................9
Table 2. Segmentation of EU27 WICR market (based upon 2009 data). ........................14
Table 3. Assumptions underlying the main baseline model inputs ........................................14
Table 4. Summary of walk in cold room energy consumption breakdown by size category at
2009. ....................................................................................................................................15
Table 5. Typical insulation thickness and associated U-value for northern and southern
European cold rooms (based on stakeholder feedback for UK and Italian cold rooms,
although some stakeholders disagreed). ..............................................................................16
Table 6. Screening of policy options for effectiveness, costs and feasibility. ........................29
Table 7. Chilled walk-in cold rooms: Proposed performance levels (for illustration purposes
only assuming lambda value of 0.025 W/mK). ......................................................................32
Table 8. Frozen walk-in cold rooms: Proposed performance levels (for illustration purposes
only assuming lambda value of 0.025 W/mK). ......................................................................33
Table 9. Chilled walk-in cold rooms: Comparison of various performance levels and common
practice in northern and southern Europe, with corresponding thickness of insulation (for
illustration purposes only assuming lambda value of 0,025 W/mK).......................................33
Table 10. Frozen walk-in cold rooms: Comparison of various performance levels and
common practice in northern and southern Europe, with example corresponding thickness of
insulation (for illustration purposes only assuming lambda value of 0,025 W/mK). ...............34
Table 11. Energy consumption, savings and CO2 equivalents for whole EU from Tier 1 and
Tier 2 measures relating to U-value of insulation for walls. ...................................................37
Table 12. Estimated savings for chilled cold rooms based on refrigeration system modelling
using the CoolPack model. Modelling assumed +2°C for chilled and -18°C for frozen. .........37
Table 13. Estimated savings for frozen cold rooms based on refrigeration system modelling
using the CoolPack model. Modelling assumed +2°C for chilled and -18°C for frozen. .........38
Table 14. Evaluation of the proposals against ecodesign framework directive Article 15. .....49
Table 15. Copy of sales and stock data table 2-10 from the preparatory study task 2 report .1
Table 16. Cold room efficiency data underpinning the estimated annual energy consumption
from the UK Market Transformation Programme document BNCR02 ‘Walk in cold rooms
government standards evidence base 2009: reference scenario’ ...........................................2
Table 17. Market base case average annual energy consumption for WICR by temperature
and size category. Most numbers rounded to avoid inappropriate assumptions of accuracy.
Derivation of AEC data is in Table 16. ....................................................................................3
Table 18. Assumed performance levels for WICR after Tier 1 and after Tier 2, showing
estimated savings for southern European cold rooms (results from CoolPack software
modelling)...............................................................................................................................4
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
1 Introduction
1.1 Project purpose and structure
This is the report of the impact assessment for walk in cold rooms as part of DG ENTR Lot 1
ecodesign of professional refrigeration products. It was carried out under contract No –
S12.607940 during January to August 2012. Four separate reports cover the impact of
proposed regulations for industrial process chillers, blast cabinets, professional storage
cabinets and condensing units.
The project commenced in January 2012 coinciding with the consultation forum for these
products on 19th of January in Brussels.
Following stakeholder feedback at a meeting on 1 March 2012, it became apparent that
additional technical work would be necessary to underpin any regulatory proposals. The
Commission’s JRC carried out some research and consultation work to support the impact
assessment and this is provided as Appendix 4.
In addition, CLASP sponsored some research into the US regulations and any possible
lessons that could be learned from that precedent. Their report is provided as appendix 5. A
follow-up telephone conference was held on 14 March 2012 between the impact assessment
contractor and the US DOE team responsible for walk in cold room regulations in the US,
notes from that discussion provided as Appendix 6.
1.2 Report structure
This report includes six sections that cover, respectively, each of the six stages of the Impact
Assessment process, but content is necessarily limited by several particular challenges and
limited market data availability and so cannot fulfil the requirements of a conventional impact
assessment. The report sections are:
1.
Problem identification
2.
Definition of objectives
3.
Policy options
4.
Analysis of impacts
5.
Comparing options
6.
Monitoring and evaluation
1.3 Procedural issues
The starting premise for this impact assessment was the ecodesign preparatory study for DG
ENTR Lot 1 and the working document discussed at 19 January 2012 consultation forum.
The working document is provided in Appendix 1. The main regulatory proposals analysed in
this impact assessment arise from the eco-design standardisation report described in section
1.2.
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
1.4 The consultation of interested parties
In addition to the consultation forum of 19th of January 2012 at which a Commission working
document was presented (Appendix 1), one meeting has been held between the IA
contractor and suppliers as summarised in Table 1. Minutes of the consultation forum are
available through the DG ENTR website1, minutes of the other meeting is included as
Appendix 2.
It became apparent during initial research in January/February 2012 to identify possible
attendees of an industry meeting for 1 March that the number of major EU industry
associations (ECSLA, EPAQ, PU Europe) and manufacturers had not been engaged in the
process of developing the preparatory study and associated evidence to that point. Several
delegates on 1 March expressed disappointment at being involved at such a late stage. This
contributed to the situation undermining the robustness of available evidence at that point
and viability of proposals.
The SME questionnaire with summary replies is given in Appendix 10; the more
comprehensive stakeholder questionnaire with replies is given in Appendix 12.
Key quotes extracted from letters and other submissions received after the consultation
forum, and up to 29 June are included in Appendix 11.
Note: Comments on the 1st draft of this report were received from PU Europe (Representing
the EU polyurethane industry) on 18 September 2012 and some aspects of this were taken
into account, see Appendix 13.
Table 1. Consultation events and numbers of participants / respondents
Consultation event
No. of manufacturer
and
industry
participants
/
respondents
Consultation forum 19 c.
10
January 2012
cabinets
for
No. of government, Comments
NGO
or
other
participants
/
respondents
storage c. 45
Open meeting for all 5 Lot
1 product groups
Meeting
with 8
manufacturers,
4 European
Identified key issues of
manufacturers
1st industry
associations Commission plus 3 concern
March 2012, Brussels represented
technical specialists
Stakeholder
12 manufacturers; 3 4 member states
consultation open 4 industry associations; 3
April to 10 May 2012
independent
technical
experts
Invitations emailed to over
250
registered
stakeholders, 109 of which
had specific interest in
WICR
SME consultation via 5 end users; 9 suppliers nil
the
Commissions of cold rooms or other
Enterprise
Europe refrigeration equipment
Network
Sent out via EEN in 6 EU
languages. See Appendix
10.
1
See http://ec.europa.eu/enterprise/policies/sustainable-business/ecodesign/product-groups/freezing/index_en.htm.
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
2 Problem definition
2.1 Nature and extent of the problem
The key problems to be addressed are:
a) Poor quality of installation of cold rooms driven by very high downward pressure
on price. Construction often by unsupervised and low skilled workforce and no
post-installation inspection or functional testing
b) Insulation performance significantly less than economic optimum, particularly in
southern Europe. Typical insulation thicknesses (as a proxy for performance)
appear to be 30% to 40% less in southern than in northern Europe for comparable
installations (apparently a cultural difference).
c) Measures to reduce air ingress may not be installed (automatic door closers and
strip curtains etc)
Price pressures have further fragmented the market away from prefabricated kits (which
potentially have better quality control, particularly for joints) and towards on-site construction
from panels and components bought and assembled by small suppliers. This puts more
emphasis on the first problem of poor quality installation.
There is little control of installation quality for many customised cold room, and only a handful
of major manufacturers comply with CE marking in the EU, although there are relevant ETA
guidelines. No certificate of correct installation is generally issued to customers and installers
rarely verify any functional parameters (refrigeration plant is often installed later anyway).
There are accessible and cost-effective savings that the market does not pursue. Insulation
U-value (primarily thickness) is the simplest opportunity and probably the most effective for
regulation to address, with energy savings of around 7% for chilled rooms and 8% for frozen
rooms through increasing insulation from poor practice to good practice levels. Reducing air
ingress through open doors is another significant source of losses which could be reduced by
fitting automated door closers in a typical cold room.
2.2 Key players affected
For maximum effect, the regulations would have to affect the following players:







Manufacturers of insulation and other insulated enclosure components
Manufacturers of cold room kits
Designers of cold rooms responsible for designing systems and specifying
components including insulated enclosure and refrigeration system
Installation contractors responsible for assembling cold room insulated enclosures on
site, either from kits or from sheet insulation and construction components. Some
contractors will only construct the insulated enclosure; others may also install
refrigeration plant. Some contractors will also specify components, others will work
from a design prepared by a separate specification engineer
Manufacturers and suppliers of preparation plant components
Installation contractors responsible for refrigeration plant (those not involved in
insulated enclosure construction)
End-users and operators of cold rooms
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
2.3 Baseline Scenario
2.3.1 Product Scope
The January 2012 working document used the following definition:
A ‘walk-in cold room’ is a refrigerated enclosure intended for the storage of chilled
and/or frozen foodstuff or other perishable items, accessible via at least one door,
and which is large enough to let somebody walk in it.
Where:



'Operating temperature' means the target storage temperature which is intended to
be maintained within the walk-in cold room
‘Medium operating temperature’ means any temperature above -2°C (see note
below), with reference point at +5°C (M1 temperature class)
‘Low operating temperature’ means any temperature below -2°C (see note below),
with reference point at -18°C (L1 temperature class)
Note: discussions with manufacturers and other stakeholders on 1 March 2012 concluded
that a more appropriate temperature and which differentiate low and medium temperature
cold rooms is -5°C and not -2°C (see appendix 3). It is not certain that using the designations
M1 and L1 is necessarily appropriate for walk in cold rooms, as these designations are
derived from European standard EN441 and EN23953 for retail display cabinets – this
should be confirmed with relevant experts before use in the regulation.
The Regulation proposed in that working document intended to cover any walk-in cold room
of a storage volume smaller than 400m³. This included:




Walk-in cold rooms which are prefabricated kits
Customised walk-in cold rooms which are built from separate insulating panels, and
assembled and charged with refrigerant in-situ by qualified professionals
Walk-in cold rooms which are used as corridors, working rooms or areas where food
and other stuff is processed
Walk-in cold rooms operating at medium and low temperatures
It was intended to include in the scope of the proposed Regulation walk-in cold rooms of less
than 400m³ which “are leant or standing directly against at least one exterior wall (with no
cladding between the refrigerated space and the exterior wall). In this instance, “exterior wall”
means a façade wall in direct contact with the outdoor climate”. It is assumed that the
intention of this was to include cold rooms for which one or more of its walls were exposed to
the outdoor climate through forming part or the entirety of the outer shell of a building. These
cold rooms may thus form part of the building and may have load-bearing walls and it was
noted that these may fall into the scope of national Building Codes.
There are a number of significant issues regarding the scope of products included in this
working document, some of which have not been satisfactorily resolved to the point where a
regulation could be written with confidence. The following issues have been identified;
i.
2
The working document of January 2012 therefore set a very broad scope for possible
inclusion in the regulation. The source for this size limit of 400 m3 is not from any
rational evaluation of type of product or technically feasible scope of regulation. It
simply arose from the slightly arbitrary banding of cold room sizes used in an analysis
for the UK government under their Market Transformation Programme2 which was
used as the basis of preparatory study analysis. The 400 m3 limit in that analysis
arose as being the largest cold store that is likely to be situated within another
This is the quoted source in the preparatory study task 2 report section 2.4.4.3
Ref: AEA/ED[Category]/Issue Number 1.2c
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Impact Assessment for Walk in cold rooms
external building (that report excluded cold stores that were exposed to the outdoor
environment). In the US their regulation covers all walk in cold stores with a storage
area less than 3000 ft2 (which equates to around 800 m3) and specifically aims to
include cold stores that are exposed to the outdoor environment. This limit was
handed down from preparatory rule making work and is not based on detailed
technical analysis, discussion with the technical team responsible for those rules
indicated their feeling that it was indeed challenging to cover such a broad range with
a product based regulation.
Considerable discussion arose during the impact assessment consultation process
about the feasibility of including cold stores which form part of an exterior shell of the
building and the crossover with building regulations that this implies. The debate on
the legal and technical feasibility of including such cold stores was not exhaustively
and conclusively settled during the impact assessment and associated research.
The scope as described would include the refrigeration plant operating the cooling.
The proposed regulation from the working document of January 2012 proposed only
information requirements regarding the refrigeration plant, which would come into
effect in a 2nd tier of requirements in 2016. One of the complications of this aspect is
that some cold rooms may be served by central refrigeration plant that also serves
other cold rooms or cooling demands. The technical implications of that have not
been resolved.
The use of the phrase ‘walk in’ is also potentially misleading. It is assumed that the
intention is to differentiate the products intended to be within scope from refrigerated
cabinets too small for a person to walk into; such cabinets would be included under
regulations for professional storage cabinets or retail display cabinets. Within scope
are cold rooms accessible by pedestrians as well as by forklift truck and other
vehicles.
ii.
iii.
iv.
This impact assessment attempts to quantify the impact of a possible regulation that covers
all of this size range, although there are severe limitations on the data available to do this.
2.3.2 Basis of scenario
Some indicative consumption figures were derived for one baseline scenario which is
continuation of business as usual with no further policies. No time series model has been
constructed for this product group to project future consumption due to absence of data.
The baseline scenario considers continuation without additional policies that relate to walk in
cold rooms. Efficiency levels are assumed to remain constant as despite availability of better
products, the majority of buyers persist in pursuing lowest price purchases.
The preparatory study established a base case for only one size and temperature category of
cold room (storage at +2°C and volume of 25 m3, as per Table 4-71 of Annex 4-1 of the Task
4 report). This is not useful for assessing policy priorities and feasibility of tackling any subcategories with specific measures and hence simplistic calculations that allow breakdown by
size and temperature category were attempted for this impact assessment analysis.
There are many severe limitations on the analysis possible under this product group. These
are discussed in section 2.3.6.
2.3.3 Types of walk in cold room
There are 3 main types of WICR by style of construction:

Ready-made insulated enclosures (very small rooms only, tiny niche market and
reducing).
Ref: AEA/ED[Category]/Issue Number 1.2c
12
Impact Assessment for Walk in cold rooms

Prefabricated kits (modular cold rooms) for assembly on site of the insulated
enclosure from pre-packaged set of components (generally for small rooms, lesser
and reducing proportion of market).

Customised cold rooms built on site from insulation panels, joints and other
components (always used for large cold rooms but increasingly used for small and
medium as well – account for the majority of the market).
The market is increasingly moving towards customised cold rooms cut and built on site, even
for smaller rooms due to price pressures and better customisation.
WICR with gross volume over 100 m3 are generally of highly customised designs and
installed by skilled professionals. Some cold rooms have walls that form an external shell of
a building (exposed to weather). These may have specific conflict with building regulations
requirements, but anecdotal evidence implies very few cold rooms of the intended scope of
the regulation have external walls and these will generally only be in the large size category.
2.3.4 Sales and stock by category, importance in energy terms
Segmentation of the EU market is summarised in Table 2. The categories of cold room used
in this analysis are those adopted by the preparatory study which drew them from UK Market
Transformation Programme (MTP) analysis:



Small cold stores up to 20 m3
Medium cold stores 20 to 100 m3
Large cold stores 100 to 400 m3
That MTP report covered only cold stores that are situated within a building or other
weatherproof envelope. Chilled stores were defined as those operating between +1 and
+10°C; frozen stores between -20°C and -25°C. Those temperature regimes have not been
mirrored in the proposed regulation.
And to obtain an estimate of EU 27 stock in the reparatory study: “The total figures for sales
and stock are extrapolated to the EU-27 from UK MTP data, estimating that the UK market is
13.5% of the EU market”.
The main assumptions underlying the estimates are given in Table 3.
Table 4 summarises the breakdown of energy consumption by size category of cold room.
These are derived from the preparatory study figures and data given in Table 17. In the
absence of other data, it has been assumed that proportion of stock is equal to proportion of
sales, as used in the preparatory study.
Frozen rooms account for of 31% stock and 39% of annual energy consumption.
Small rooms account for 67% of stock and 40% of consumption; medium for 31% of stock
and 49% of consumption. See Figure 1, Figure 2 and Figure 3.
EU annual energy consumption was estimated from these rough estimates as 18.5 TWh in
(based on 2009 data) from a stock of 1.5 million units.
Ref: AEA/ED[Category]/Issue Number 1.2c
13
Impact Assessment for Walk in cold rooms
Table 2. Segmentation of EU27 WICR market (based upon 2009 data).
Size of Estimated
cold
stock
–
room
Chilled >5°C
(%
units)
Small,
<20m3
Estimated Estimated Estimated
stock
– stock
– stock
–
Frozen <- Total
Total
5°C
(units)
(%
of
of (%
of
units)
units)
44%
Estimated
energy
consumption
of stock
Estimated
energy
consumption
of stock
(TWh)
(%)
23%
1,020,000
67%
7.47
40%
Medium, 23%
20
to
100m3
8%
477,000
31%
9.14
50%
Large,
1%
100
to
400m3
1%
25,000
2%
1.85
10%
Total
32%
1,522,000
100%
18.46
100%
68%
Table 3. Assumptions underlying the main baseline model inputs
Aspect
Assumption
Total sales
Adopted from the
study, task 2 report
Comments
preparatory These figures are scaled up from a Preparatory
UK estimate, assuming that the UK Study Table 2-10
accounts for 13.5% of the EU
market
Sales and stock None
growth over time
Sales and stock Adopted from the
breakdown
by study, task 2 report.
type
Source
(no time series
constructed)
model
was -
preparatory This is derived from UK analysis
Preparatory
Study Table 2-10
Total stock
Adopted from the
study, task 2 report
Lifetime
17 years
Adopted from the preparatory study Preparatory
task 2 report
Study Table 2-5
Usage
8,760 hours per year
Full-time operation
Average
efficiency
No product efficiency estimates
were made – only annual
consumption and savings
Change
efficiency
time
preparatory These figures are scaled up from a Preparatory
UK estimate, assuming that the UK Study Table 2-10
accounts for 13.5% of the EU
market
in None
over
Annual
consumption
(kWh per year)
Annual energy consumption
figures adopted from the UK
MTP analysis in BNCR02, see
Table 16.
Ref: AEA/ED[Category]/Issue Number 1.2c
(no time series
constructed)
model
was
These estimates were derived from UK Government
independent refrigeration expert publication
analysis based on typical UK BNCR02
working practice
14
Impact Assessment for Walk in cold rooms
Table 4. Summary of walk in cold room energy consumption breakdown by size
category at 2009.
Small Medium
Large
Total
<20
m3
Chilled and frozen, total % of EU consumption
Chilled and frozen, total EU energy consumption
(TWh)
20 to 100 100 to 400
m3
m3
40%
50%
10%
100%
7.5
9.1
1.8
18.5
Figure 1. Breakdown of energy consumption by size category.
Large,
10%
Small,
40%
Med, 50%
Figure 2. Breakdown of stock of walk in cold rooms by number, which is identical to
sales breakdown.
Frozen
Medium
Frozen
Large
Frozen
Small
Chilled
Small
Chilled
Large
Chilled
Medium
Ref: AEA/ED[Category]/Issue Number 1.2c
15
Impact Assessment for Walk in cold rooms
Figure 3. Energy consumption (TWh per year) of walk in cold rooms.
Frozen Large,
0.8, 4%
Frozen
Medium, 3.3,
18%
Chilled Small,
4.5, 24%
Frozen Small,
3.0, 16%
Chilled
Medium, 5.8,
32%
Chilled Large,
1.0, 6%
2.3.5 Efficiency levels
No data were available for efficiency profile of the stock, but annual energy consumption
(AEC) estimates are given in Table 17.
The preparatory study established a base case for only one size and temperature category of
cold room (storage at +2°C and volume of 25 m3, as per Table 4-71 of Annex 4-1 of the Task
4 report). This is not useful for assessing policy priorities and feasibility of tackling any subcategories with specific measures. Hence fresh but simplistic calculations were made for this
Impact Assessment analysis.
Stakeholder feedback, in particular discussions from 1 March 2012 stakeholder meeting in
Brussels (see Appendix 3) indicated that Northern European cold rooms were typically better
insulated than those of southern Europe, this being a largely cultural issue – see Table 5.
Although stakeholder feedback from the questionnaire (Appendix 12, Q6) was split almost
equally between agreement and disputing this. No attempt has been made to estimate the
energy efficiency differences due to this differential, but the consequences are discussed
regarding the different impacts a regulation might have on these regions.
Table 5. Typical insulation thickness and associated U-value for northern and
southern European cold rooms (based on stakeholder feedback for UK and Italian
cold rooms, although some stakeholders disagreed).
Chilled
Frozen
Northern
Europe
Southern
Europe
Northern
Europe
Southern
Europe
Typical insulation thickness,
millimetres
100
60
150
100
Typical
W/m2K
0.25
0.42
0.17
0.25
insulation U-value,
Ref: AEA/ED[Category]/Issue Number 1.2c
16
Impact Assessment for Walk in cold rooms
2.3.6 Sources of uncertainty for the base case
The estimates used in this analysis have significant uncertainties:






Sales and stock are extrapolated from UK estimates, assuming that the UK accounts
for 13.5% of EU stock and sales. There are significant uncertainties associated with
the UK figures, which are compounded by this assumption of the proportion of EU
market that the UK accounts for. The size of this uncertainty has not been assessed.
There is no data on which to base estimates that differentiate the levels of
performance in the marketplace, i.e. differentiating between the levels of insulation
used in southern Europe versus those used in Northern Europe.
There is no data showing the profile of different performance levels apparent in the
market, whether based on insulation thickness, efficiency of refrigeration plant,
standards of installation or any other aspect that affects performance.
There is no data that allows the calculation of the effect on total consumption
associated with operating plant in northern European climates versus Southern
European climates.
It is not known whether the estimates of annual energy consumption take account of
air ingress due to door openings.
No account is taken of the effects of quality of installation on consumption for an
average cold room, and therefore no account is taken for this in the total EU
consumption.
2.4 Existing standards
The working document of January 2012 proposed the following approach to measurement
methods:
1. As regards the method for measuring the U, ψ and χ values of walk-in cold rooms which
2.
3.
4.
5.
are prefabricated kits, the Commission intends to publish the references of ETAG021 in
the Official Journal, C series, once it is updated and translated into an EN standard for
the purpose of the present Regulation
As regards the method for measuring the U values of customised walk-in cold rooms, the
Commission intends to publish the references of ETAG016 and EN14509 in the Official
Journal, C series, once these are updated and translated into EN standards for the
purpose of the present Regulation. [Note that during stakeholder consultation, one
Belgian expert pointed out that EN 14509 and ETAG 016 are not adapted to cover
panels specifically intended for cold storage rooms. They need to be adapted prior to
them being referred to in the OJEU (very few cold storage room panels are not double
metal faced anyway)].
As regards presumption of conformity with generic requirements on proper installation of
customised walk-in cold rooms, the Commission intends to mandate a new harmonised
standard for the purpose of the present Regulation. The French standard DTU45-1
covers the construction of the insulated envelope of the cold room and may serve as a
basis. [A significant amount of work would be required to develop an EU standard to
cover installation quality. The EU ETA guidelines do not cover customised cold rooms.
This is considered to be a medium to long-term objective.]
As regards the method for measuring the energy consumption of electrical components
integrated into the insulated envelope of the walk-in cold room such as anti-sweat
heaters, the Commission intends to mandate a new harmonised standard.
As regards the method for measuring the cooling capacity, power input and coefficient of
performance (COP) of the refrigeration unit or system serving the walk-in cold room, the
Commission intends to mandate a new harmonised standard. EN13215/ EN13771
Ref: AEA/ED[Category]/Issue Number 1.2c
17
Impact Assessment for Walk in cold rooms
(remote condensing units) and PAS 57:2003 (refrigeration systems) may serve as a
basis.
There are very many European and other national standards that apply to the components of
walk in cold rooms, and a few that apply to the system as a whole. The JRC report on
additional background information discusses some of these, and many of the most important
are described in detail in the preparatory study3. The most important are:
a) European
Technical
Approval
Guideline
(ETAG)
021
and
016.
ETAG 016 Guideline for European technical approval of self-supporting composite
lightweight
panels
Edition
February
2005
ETAG 21 Guideline for European technical approval of cold storage premises kits
part
1:
cold
storage
room
kits,
Edition
September
2005.
These guidelines provide a framework for design of cold storage kits, but do not cover
customised cold rooms. See extensive description in preparatory study section
1.3.3.2, extract below:
The ETAG 021 Cold storage premises kits is divided into two parts: Part 1
“Cold storage room kits” and Part 2 “Cold storage building envelope and
building kits” covering specific aspects related to different intended uses. Part
2, covering products that might be constructed outdoors, has additional
elements mainly relating to the need to weather-proof the structure.
This guideline was established in the context of Directive 89/106/EEC on
construction products (ref provided). European technical approvals are used
to assess the suitability of a product for its intended use in cases where there
is no harmonised standard, no recognised national standard and no mandate
for a European standard and where the Commission feels, after consulting the
Member States within the Standing Committee on Construction, that a
standard cannot or cannot yet be prepared....The scope of the guideline
covers cold storage kits whose components are pre- designed and
prefabricated by one (or various) manufacturer(s) to be produced in series
and three-dimensional prefabricated transportable rooms. In the context of the
guideline, thermally insulating products are those with a declared thermal
conductivity of less than 0.06W/m.K at +10°C. Components put on the market
separately are not covered by ETAG 021, although much of the data on
technical characteristics is provided on a component basis.
b) EN 14509:2006 Self-supporting double skin metal faced insulating panels. Factory
made products: Specifications is used to assess insulation properties of sandwich
panels. Again, from the Preparatory study:
This standard includes the specifications, evaluation and monitoring of
factory- made, self-supporting, double skin metal faced insulating panels. Due
to the great variety of sandwich panel applications, profiles, adhesives,
insulation core materials and production lines, different levels of mechanical
performance can be achieved. The main parameters of interest measured in
respect to energy performance of the cold rooms is the thermal conductivity, λ,
and thermal transmission, U-value, as described.
c) ISO 10211:2007 Thermal bridges in building construction -- Heat flows and surface
temperatures -- Detailed calculations4. The standard was identified by experts at 1
3
4
See section 1.3.3 preparatory study task 1 report, page 75 to page 93.
See http://www.iso.org/iso/catalogue_detail.htm?csnumber=40967
Ref: AEA/ED[Category]/Issue Number 1.2c
18
Impact Assessment for Walk in cold rooms
March 2012 stakeholder meeting as appropriate as the basis for calculating the
performance of thermal bridges.
CEN has set up working group 4 under TC44 for their work item on definition of performance
characteristics and energy consumption for walk in cold rooms, and appointed Mr Mauro
Freguglia as the convenor.
Regarding U-values of doors and windows, these would be covered by CEN committee
number TC33. Development of standards for cold storage room or building doors and
windows are not believed currently to be on the working plan of this committee.
On one specific point, it was made very clear by stakeholders during consultation and at the
meeting of 1st of March 2012 that U- values for insulation panels must be based upon the
aged lambda value, and not the value determined initially in the panel’s life. This is in order to
comply with the requirements under EN14509 and provide the market with accurate
information on the long-term performance of the panel
2.5 Related initiatives on European Union and Member
State level
The JRC report on additional background information (Appendix 4) reports on research on
this. It highlights the construction products directive (89/106/EEC) and the construction
products regulation (305/2011/EU). Both of these effects components that are used in cold
rooms, but do not have any provision specifically for those products.
No specific national or regional regulations directly addressing walk in cold rooms could be
identified in EU member states.
National building regulations that could be applicable to large size in cold rooms which are
part of a building have been identified in Italy and Germany. These do specify maximum Uvalues for opaque vertical and horizontal structures but do not appear specifically aimed at
cold storage facilities.
A code of practice for cold store design was identified in the UK, published by the Institute of
refrigeration, based in Carshalton. An update to this document was announced in March
2012.
Walk in cold rooms are also subject to the F-Gas regulations which do not directly address
energy efficiency. A short report about refrigerants issues has been prepared which is
equally applicable to each of the products under Lot 1. This is included as Appendix 7.
Ref: AEA/ED[Category]/Issue Number 1.2c
19
Impact Assessment for Walk in cold rooms
3 Definition of the objectives
3.1 Overall objectives
The overall objective is therefore to develop a policy which will address the market failures,
and which will:

Reduce energy consumption and related CO2 emissions by walk in cold rooms
following EU environmental priorities;

Promote energy efficiency and so contribute to security of supply in the framework of
the EU objective of saving 20% of the EU's energy consumption by 2020.
3.2 Specific objectives
The specific objectives are:
1. To reduce the proportion of wasteful heat gain that occurs in the operation of walk in
cold rooms
2. To increase the efficiency of refrigeration plant used to cool walk in cold rooms
3. To generate cost savings for end-users.
3.3 Operational Objectives:
The more detailed operational objectives are:
1. To raise the quality of installation of walk in cold rooms (in the longer term),
2. To ensure EU-wide adoption of a highly cost effective performance of insulation
material used in the insulated envelope for walk in cold rooms and measures that
effectively reduce ambient air ingress to the cooled space
3. To facilitated the availability of comparable performance information and so foster an
effective competitive market in which real-use performance improvements can be
justified to buyers.
Ref: AEA/ED[Category]/Issue Number 1.2c
20
Impact Assessment for Walk in cold rooms
4 Policy options
4.1 Overview of options
The following options are reviewed in this section:
1.
2.
3.
4.
No action (business as usual)
Option A: Adopt existing policy from elsewhere in the world
Option B: Regulatory requirements as preparatory study recommendations
Option C: Regulatory requirements as proposed in the Working Document of January
2012
5. Option D: Voluntary requirements for maximum U-value for insulation
6. Option E: Mandatory maximum U-values for insulation and other construction
elements
7. Option F: Mandatory limits on performance of thermal bridges in pre-fabricated cold
room kits
8. Option G: Requirements for specific design and construction elements to minimise air
infiltration and secure other energy efficiency features
9. Option H: Mandatory performance requirements for refrigeration systems used for
cold rooms
10. Option J: Voluntary industry initiative to raise standards of installation, backed by a
harmonised standard or code of practice.
4.1.1 No action (business as usual)
There is no directly applicable eco-design or energy efficiency related EU-level policy
currently in force applying to WICR and so there is no option to amend or cease existing
policy. Regulations do, however, apply separately to fans5 and a regulation is under
consideration for condensing units (see section 4.1.9). Whilst these regulations will achieve
marginal improvement in performance of the components used, they will not achieve the
energy savings accessible to a dedicated regulation.
If no EU action is taken the problems defined in Section 2.1 will persist.
The basic technologies in use in walk in cold rooms have hardly changed in 20 years. Whilst
some suppliers have developed highly efficient products, the market is mainly driven on
purchase price and the potential for improvement lies largely unexploited. Rising energy
prices will assist the case for change but in the short and medium term this will not on its own
turn the situation around due to proportionately much larger costs (other than energy) and
other priorities of user businesses.
Rising pressure on prices, combined with greater desire for tailored solutions, is driving this
market towards higher proportions of customised cold rooms built on site from insulation
material sheets. In the absence of effective quality control and industry good practice
standards for quality of installation work is likely to further decline. This will probably lead to
an increasing proportion of the market suffering excessive heat ingress through inadequate
and poorly jointed insulation panels and poorly insulated doors that can be left open for
extended periods.
5
COMMISSION REGULATION (EU) No 327/2011 of 30 March 2011, with regard to ecodesign requirements for fans driven by motors with an
electric input power between 125 W and 500 kW.
Ref: AEA/ED[Category]/Issue Number 1.2c
21
Impact Assessment for Walk in cold rooms
If any customers are interested in longer term costing, suppliers do not have a widely
accepted means to demonstrate better efficiency in real use situations. If the advantages of
such investment cannot be clearly communicated then no free competitive market can exist
on efficiency, and lowest price will persist as the main driver.
4.1.2 Option A:
Adopt policy from elsewhere in the world
The only significant policy relating specifically to walk in cold rooms that was assessed in
detail is that from the USA. That is described in detail in Appendix 5, and also in section 5 of
Appendix 4. Additional comments on this policy and its background given by the US DOE
team that developed it are included in appendix 6.
The requirements in the USA regulation are (quoted from the CLASP report):







Must install automatic door closers, except for those with very large doors;
Must incorporate strip doors, spring‐hinged doors or other methods of minimising air
infiltration while the door is ajar;
Wall, Ceiling and Door insulation of at least U-value 0.227 for coolers and U-value
0.177 for Freezers, except for glazed portions of doors or structural parts of the room
Floor Insulation for Walk‐in Freezers (U-value 0.203)
Evaporator Fan Motors – for those under 1 hp and <460V, must use one of two types
that tend to be more energy‐efficient than other less‐expensive motors
Condenser Fan Motors – for those under 1 hp, must use one of three types that are
more efficient than other less‐expensive motors
Interior lights – must have system efficacy of 40 lm/W or have a timer to switch off
automatically after 15 minutes
In principle, all of these could be considered for inclusion in an EU regulation but the detail of
these depends upon U.S.-based test methodologies which do not simply translate directly
into an EU equivalent. In addition, the context of EU construction products regulations and
existing standards for these and related components means those requirements must be
carefully reviewed for EU applicability.
Initial technical review draws the following key lessons from this US initiative:



Requirements should be non-prescriptive as far as possible and allow freedom to
select a technical solution which is applicable to that particular installation.
The requirements for U-value of insulating doors and windows could be significantly
more stringent than in the current draft of the EU requirements.
Minimum efficacy levels and automatic off switches for lighting should be considered
for inclusion
Whilst lessons can be learnt, option A to adopt US regulations in their entirety is not viable.
4.1.3 Option B: Regulatory minimum requirements as preparatory study
recommendations.
In summary, the proposed requirements recommended in the preparatory study are6:
1. Development of harmonised standards for testing of components and energy
performance of systems
2. The certification approach combining components and installation practices
(modelled on some of the US requirements)
6
See preparatory study task 7 report, section 7.2.3.4, page 38.
Ref: AEA/ED[Category]/Issue Number 1.2c
22
Impact Assessment for Walk in cold rooms
3. The proposed EU requirements for condensing units would apply to systems used on
walk in cold rooms
4. Short term (Tier 1) Component-based requirements as follows:
o strip-door curtains (or other device or structure designed to reduce ingress of
ambient air into the refrigerated space)
o wall, ceiling, and door insulation of a maximum U value (U ≤ 0.25 W/m2.K for
storage spaces above 0°C and U ≤ 0.2 W/m2.K for products with storage at or
below 0°C);
o floor insulation of a maximum U value for freezers (U ≤ 0.2 W/m2.K);
o solid doors of maximum U value (U ≤ 1.0 W/m2.K);
o fully transparent doors and display panels of maximum U value (U ≤ 1.4
W/m2.K); and
o banning of shaded pole motors, hence use of PSC or ECM motors only, for
fans in condensing and evaporating units (or, when a harmonised test
procedure be developed, motors with an equivalent efficiency).
It was estimated that these measures together would lead to a saving of 24%.
The study also made a tentative proposal for the following longer term (Tier 2) requirements:
 slam-type doors to reduce ingress of ambient air into the refrigerated space;
 automatic door closers to fully close doors left ajar;
 wall, ceiling, and door insulation of a maximum U value (U ≤ 0.2 W/m2.K for storage
spaces above 0°C and U ≤ 0.15 W/m2.K for products with storage at or below 0°C);
 floor insulation of a maximum U value for freezers (U ≤ 0.15 W/m2.K);
 floor insulation of a maximum U value for refrigerators (U ≤ 0.2 W/m2.K);
 solid doors of maximum U value (U ≤ 0.75 W/m2.K); and
 fully transparent doors and display panels of maximum U value (U ≤ 1.1 W/m2.K).
This package was estimated to lead to a saving of 50% over the base case.
Taking these items in turn:




7
Harmonised standards for sandwich panels and thermal bridges are proposed. (The
harmonised sandwich panel standard EN14509 is approved and published; the
Unique Acceptance Procedure for its first revision will start at the end of 20127).
Performance of the cold room refrigeration system is discussed in section 4.1.9.
An enormous amount of preparatory work would be necessary to develop a
certification scheme incorporating components and installer practice. This is far
beyond the feasibility of options to be considered in this analysis as no such work has
been done to date. A short to medium-term option would be to mandate the
production of a harmonised European standard on installation good practice. A
French standard was identified that could possibly form the basis of this; 7
respondents to the SME stakeholder questionnaire indicated that this could be a
useful starting point; 15 out of 17 stakeholders supported a measure to mandate a
new harmonised standard on installation good practice, with 5 supporting a
certification scheme for installers and 4 supporting a quality label similar to BREEAM
in the UK (Appendix 12 Q16).
The requirements for condensing units will indeed be applicable to these systems.
Regarding the component based requirements, strip curtains cannot be mandated as
this is impractical for some installations and is particularly not recommended for any
installations where food items may be transported through the doorway without being
fully wrapped since strip curtains are known as significant sources of microbial
contamination, with food safety risks. The stringency of proposed U-values is
Source: PU Europe (see Appendix 13).
Ref: AEA/ED[Category]/Issue Number 1.2c
23
Impact Assessment for Walk in cold rooms
reviewed in section 5.2.2. It may be more appropriate to define refrigeration system
efficiency requirements and so allow engineering freedom to meet requirements in
the most effective means for that installation, rather than specifying the use of a
certain type of high-efficiency motor in fans. One particular objection raised by a
stakeholder was that the price of these high-efficiency motors could significantly
increase with increasing demand due to the use of rare earth metals.
There are therefore some aspects of Option B that should be considered, but it cannot be
adopted in its entirety.
4.1.4 Option C: Regulatory minimum requirements as proposed in the
January 2012 working document.
The January 2012 commission working document and made the following basic proposals
for requirements that are applicable to all types of walk in cold room with an internal volume
of less than 400 m3:
1. A general requirement to be designed to reduce the ingress ambient air into the
storage space through doors and any other opening
2. A general requirement that the construction of the insulated envelope of customised
walk-in cold rooms shall be subject to proper installation according to generally
recognised state-of-the-art practices
3. Specific requirements for maximum U-value for the following elements, with separate
requirements for medium temperature and low-temperature applications:
 Walls and ceilings
 Floor
 Doors
 Windows and fully transparent or translucent doors
4. Specific requirements for thermal bridges appearing in prefabricated kits
5. Information requirements from 2014 for all walk in cold rooms to specify in the
product documentation the following items:
 Intended storage temperature in degrees centigrade
 Storage volume in cubic metres
 U-value for walls, floor, ceiling, doors and windows
 For prefabricated kits only: Thermal characteristics of thermal bridges
 The selected method for reducing ingress of ambient air into the internal
storage space
6. Information requirements from 2016:
 Energy consumption of electrical components integrated into the insulated
envelope
 Cooling capacity and power input of the refrigeration unit or systems serving
the cold room
 The coefficient of performance of the refrigeration unit
7. Mandating the production of harmonised standards as described in section 2.4: for
measuring the U-values and thermal bridge properties of insulation panels, developed
from ETAG 21; for measuring the U-values of insulating panels for customised cold
rooms, developed from ETAG 16 and EN 14509; the proper installation methods,
perhaps based upon the French standard DTU45-1; energy consumption of electrical
Ref: AEA/ED[Category]/Issue Number 1.2c
24
Impact Assessment for Walk in cold rooms
components; measuring the cooling capacity, power input and coefficient
performance of the refrigeration system, developed from EN 13215/EN 13771.
There was significant stakeholder feedback and debate about the feasibility of applying these
component and system based requirements to products that were also subject to the
construction products directive. The balance of evidence from experts, however, indicated
that this should not in itself be a problem. There are already many products that are subject
to the requirements under the construction products directive and under eco-design
requirements.
A review of these requirements combined with feedback from stakeholders led to the
conclusion that items 1 and 2 are too vague to produce any marked improvement in these
aspects. The consensus of stakeholders at 1 March 2012 meeting was that the current
wording is “likely to be highly ineffective”.
The stringency of proposed U-values (item 3 above) is reviewed in section 5.2.2.
No specific feedback was returned from stakeholders on the stringency or applicability of the
thermal bridge requirements. It will be necessary, however, to review the possible inclusion
of some exemptions or exceptions to those requirements, in line with the findings reported in
Appendix 4, section 2. This regards the fact that certain bridges are essential for the safe
operation of the cold room such as pressure relief valves; door heaters that ensure doors in
frozen rooms do not themselves become frozen and prevent safe exit; ceiling suspension
bolts etc. These issues will require careful review.
The information requirements for 2014 appear sound. The information requirements for 2016
will require harmonised standards and significant additional work to ensure they are properly
specified. It may be premature to attempt to include this, although further expert advice could
be sought to determine this.
Stakeholder feedback and other evidence supports the mandating of the mentioned
harmonised standards and so should proceed as stated.
Overall, there are several elements of option C that should be taken forward but some are
not feasible or require additional work.
4.1.5 Option D:
Voluntary requirements for maximum U-value.
This option should be considered as part of the impact assessment as an alternative for
mandatory requirements. It is well known and confirmed by the stakeholder feedback that
this sector is primarily driven by price pressure in the way the work is carried out. This has
led to the trend towards more walk in cold rooms being constructed on site from components
and standard panels with minimum of supervision and using labour with limited specific skills
and involving no post installation testing of any description in most cases. The cost of raising
standards and particularly in specifying more effective (and often thicker) insulation
represents a substantial additional cost: the price of an 80 mm panel is about 20% to 30%
higher than the price of 60 mm panel once material, transport and additional jointing costs
are taken into account. There exists for this sector no strong industry association operating
Europe-wide through which to develop and enact a voluntary approach. There are also few
national industry associations with a sufficient focus on this product to act as a proxy for
Europe. Given these market circumstances, it is almost impossible to believe that any
voluntary approach would result in any substantial change in the market.
Option D is therefore not considered viable.
Ref: AEA/ED[Category]/Issue Number 1.2c
25
Impact Assessment for Walk in cold rooms
4.1.6 Option E:
Mandatory maximum U-values for insulation and other
construction elements
This option isolates the proposal for maximum U values that was included in the working
document of January 2012. Specifically, requirements for maximum U-value for the following
elements, with separate requirements for medium temperature and low-temperature
applications:




Walls and ceilings
Floor
Doors
Windows and fully transparent or translucent doors
The basic proposal in terms of stringency is aiming to ensure that good practice levels of Uvalue that are already common in parts of northern Europe and Scandinavia are mandated
across the whole of Europe.
Key challenges to be addressed include who in the supply chain takes responsibility for
compliance to any requirements under this regulation. This is straightforward in the case of
prefabricated cold room kits, but for customised cold rooms which constitute the majority of
the market, it could be more complicated for anything other than a ‘turnkey’ solution (for
which a single contractor supplies all components, assembled and ready to start operation):



The panel supplier will not necessarily know at the point of sale whether any given
panel will be used for a cold room and so whether it should comply with the
regulation. (Insulation panels used in cold rooms constitute a very small proportion of
the output from panel manufacturers).
The installation contractor may have nothing to do with the specification or design of
the cold room elements and simply be given the job of assembly.
The designer of the cold room may not have any specific responsibility for its
construction.
There are both contractual and legal issues to be investigated and resolved before a definite
solution can be proposed. Minimum requirements for the U-value of windows and doors for
cold rooms would be more straightforward to set and enforce.
The principle of a minimum level of performance for insulation panels, windows and doors
used in the construction of cold rooms is worthy of more detailed consideration given the
potential savings and the fact that a regulation was deemed workable for the US market.
4.1.7 Option F: Mandatory limits on performance of thermal bridges in prefabricated cold room kits
As with option E, this is an element isolated from the working document of January 2012 to
set a maximum thermal leakage rate through the linear joints between wall panels, wall to
ceiling, wall to floor and wall to door. The limit is expressed per linear metre of joint to a
recognised calculation methodology contained in a harmonised standard. This option can be
considered separately as it is applicable only to prefabricated cold room kits which are
supplied complete with panels and joints. Requirements in this regard would complement Uvalue requirements for the panels which are also contained in the kits. Whilst only applicable
to a small part of the market, this option appears feasible and useful and should be further
considered.
Ref: AEA/ED[Category]/Issue Number 1.2c
26
Impact Assessment for Walk in cold rooms
4.1.8 Option G: Requirements for specific design and construction elements
to minimise air infiltration and secure other energy efficiency features
There is a menu of possible options under this heading that could be picked from the
preparatory study, January 2012 working document and from the WICR regulation in the
USA. The main items for consideration are:





Automatic door closers (applicable to all except very large doors);
Strip curtains, spring‐hinged doors or other methods of minimising air infiltration while
the door is ajar;
High efficiency evaporator fan motors
High efficiency condenser fan motors
Interior lights must have system efficacy of 40 lm/W or have a timer to switch off
automatically after 15 minutes
As discussed above, soft door closes would be appropriate for inclusion as well as requiring
some means to reduce air infiltration whilst a door is open, without being prescriptive.
Requirements for high efficiency motors etc would require justification for economic and
availability reasons. These may also be more appropriate to consider alongside requirements
for the refrigeration system itself, rather than being bundled with a regulation that otherwise
deals only with the insulated enclosure.
Requirements for lighting systems could be considered at this stage, although evidence for
the economics and technical scope would be needed.
4.1.9 Option H: Mandatory performance requirements for refrigeration
systems used for cold rooms
The commission has noted its intention (in the January 2012 Working Document) to mandate
a new harmonised standard for a method for measuring the cooling capacity, power input
and coefficient of system performance (COSP) of the refrigeration system serving the walk-in
cold room.
EN13215/ EN13771 (remote condensing units) and PAS 57:2003 (refrigeration systems)
may serve as a basis for this. US DOE is already looking to develop a standard to address
this for walk in cold rooms8 which could serve as a useful precedent for the EU.
It is noted that an EU Regulation for condensing units9 is also being developed in parallel
with this one for WICR. Whilst the condensing units used for WICR will fall within the scope
of that regulation, there is a strong argument for also having a regulation for entire WICR
systems (i.e. covering the insulated enclosure and refrigeration system). This is because
performance requirements for the entire WICR system can ensure appropriate sizing and
combined efficiency of the condensing unit, evaporator, controls and any other refrigeration
system features. It is the sub-optimal matching of condensing unit, evaporator and enclosure
that often results in poorer efficiency than necessary, even if the basic components are
highly efficient in themselves when used with notional (ideal) other components.
It is the understanding of the impact assessment contractor that the condensing unit
regulation will directly affect suppliers of condensing units but will not incur any additional
burden on WICR suppliers; nor will the WICR regulation incur additional burden on
condensing unit suppliers. This is because WICR suppliers will simply buy products placed
on the market by others, and if they make their own condensing units supplied with cold
rooms, then only the WICR regulation will apply as the product that is placed on the market is
a WICR and not a condensing unit.
8
9
See http://www1.eere.energy.gov/buildings/appliance_standards/commercial/wicf.html.
Also under ecodesign DG ENTR Lot 1, commercial refrigeration.
Ref: AEA/ED[Category]/Issue Number 1.2c
27
Impact Assessment for Walk in cold rooms
The regulatory option to cover the entire WICR system is not currently available, but once a
suitable standard is established and market performance data, consideration can be given
for regulatory requirements for system efficiency. Option H is not viable at present.
4.1.10 Option J: Voluntary industry initiative to raise standards of installation,
backed by a harmonised standard or code of practice
The quality of installation was acknowledged as a significant reason for less than optimum
energy performance in the preparatory study, in meetings with manufacturers and also
through the back from stakeholders. It is also the most intractable challenge to be overcome,
requiring a significant cultural change in the supply sector combined with an acceptance by
users that a fair price must be paid for a good quality job. A good quality job can have
significantly less energy consumption over the lifetime of the cold room and will almost
certainly be a sound investment. Installation problems predominantly affect customised cold
rooms which are cut from insulating panels on site.
The problems of poor quality installation include that joints between insulating panels are not
accurately cut or sealed allowing both heat and moisture to penetrate. The former raises
energy costs; the latter can give rise to premature failure of the insulating material and
excessive ice formation on the evaporator (which also raises energy consumption).
Weaknesses in the whole system design, such as poorly matched enclosure and
refrigeration system (too much or too little refrigerating capacity), can give rise to poor
efficiency and/or inability to maintain the required temperatures.
Given that the majority of customised insulated enclosures are erected by SME organisations
and furthermore that there are few national and no Europe wide professional bodies
representing them, it is unlikely that regulation can effectively resolve this challenge.
Compliance will continue to be a major issue as long as the majority of sales are decided on
the basis of absolute minimum price.
The challenges of raising the quality of installation were acknowledged in the preparatory
study and in the commission working document of January 2012 through the suggestion of
developing a harmonised European standard for installation work10. This is a necessary
prerequisite to address this challenge. However, this will also require the full backing of the
supply industry to bring about the cultural changes necessary and deliver the training and
verification that would be essential to secure better standards.
Examples of the sort of initiative that might be examined for useful lessons may be found in
the UK certification scheme for refrigerant handlers11, and in the parallel Refcom ‘Register of
companies competent to manage refrigerants’12.
The preparatory study and the January 2012 working document did not attempt to analyse
any comprehensive means to address this problem, and a long term strategy would be
required to do so.
Whilst a valuable first step might be to mandate a harmonised standard for installation, it
would be important to set this first in the context of a wider plan to ensure it is fit for purpose.
It is therefore too early to consider Option J as a viable regulatory option and it is not
recommended for further consideration at this time.
10
The January 2012 working document stated: “[regarding] conformity with generic requirements on proper installation of customised walk-in cold
rooms, the Commission intends to mandate a new harmonised standard for the purpose of the present Regulation. The French standard DTU45-1
covers the construction of the insulated envelope of the cold room and may serve as a basis”.
11
See http://www.cskills.org/supportbusiness/trainingandassessment/bes/refrigerants.aspx and http://www.acrib.org.uk/acribskillcard
12
See http://www.refcom.org.uk/.
Ref: AEA/ED[Category]/Issue Number 1.2c
28
Impact Assessment for Walk in cold rooms
4.2 Summary of option assessment
The results of the screening process are summarised in Table 6. Section 5 elaborates on
Options E, F and G.
Table 6. Screening of policy options for effectiveness, costs and feasibility.
Option
Effectiveness
(i.e. delivery of
objective)
Cost
(i.e. net cost of
implementation)
Feasibility
(i.e. of
implementing the
changes)
No action
0
0
0
Option A: Adopt existing policy from
elsewhere in the world



Option B: Regulatory requirements as
preparatory study recommendations
0

 / 
Option C: Regulatory requirements as
proposed in the Working Document of
January 2012
(in part)
0
(by part)

(in part)
/
(by part)
Option D: Voluntary requirements for
maximum U-value.



Option E: Mandatory maximum Uvalues for insulation and other
construction elements



Option F: Mandatory limits on
performance of thermal bridges in
pre-fabricated cold room kits



Option G: Requirements for specific
design and construction elements to
minimise air infiltration and secure
other energy efficiency features









Option H: Mandatory performance
requirements for refrigeration systems
used for cold rooms
Option J: Voluntary industry initiative
to raise standards of installation,
backed by a harmonised standard or
code of practice
(at this time)
Scoring key:  = large positive,  = small positive, 0 = neutral,  = small negative,  =
large negative.
Ref: AEA/ED[Category]/Issue Number 1.2c
29
Impact Assessment for Walk in cold rooms
5 Impacts of retained options
Very limited evidence was available to quantify the impacts of the various options but
indicative figures are developed in the following sections. Each of these options can be
separately considered and savings achievable can be added together as they are mutually
exclusive. Section 5.1 covers aspects that are relevant to all of the retained options.
5.1 Elaboration of regulatory scope and other aspects
applicable to all options
5.1.1 Definition of scope
The definition used in the working document of January 2012 is considered applicable:
A ‘walk-in cold room’ is a refrigerated enclosure intended for the storage of chilled
and/or frozen foodstuff or other perishable items, accessible via at least one door,
and which is large enough to let somebody walk in it.
Where:



'Operating temperature' means the target storage temperature which is intended to
be maintained within the walk-in cold room
‘Medium operating temperature’ means any temperature above -5°C (see note
below), with reference point at +5°C
‘Low operating temperature’ means any temperature below -5°C (see note below),
with reference point at -18°C (L1 temperature class)
This includes:





All walk in cold rooms with internal volume less than 400 m3.
Walk-in cold rooms which are prefabricated kits
Customised walk-in cold rooms which are built from separate insulating panels, and
assembled and charged with refrigerant in-situ by qualified professionals
Walk-in cold rooms which are used as corridors, working rooms or areas where food
and other stuff is processed
Walk-in cold rooms operating at medium and low temperatures
14 out of 21 respondents to this question (appendix 12) agreed with this general scope.
Exempted from the regulation:
13

Cold rooms for which one or more insulated sections of the enclosure are exposed to
weather (i.e. where part of the cold room is an external wall of a building and is
therefore subject to additional building related regulations, See section 5.1.2)

Wording should be considered that enables exemption for beer cellars13 (noninsulated space below public house used to store beer at above +8°C, common in the
UK). An appropriate temperature range could be imposed along with a maximum
gross internal volume limit to ensure that this potential loophole is constrained. Note
This was requested by the UK delegate at the consultation forum on 19 January 2012.
Ref: AEA/ED[Category]/Issue Number 1.2c
30
Impact Assessment for Walk in cold rooms
that 13 out of 20 respondents to a stakeholder question on this disagreed with such
an exception – see Appendix 12 Q18).
5.1.2 Volume range of cold rooms
Regarding the scope of the proposal in terms of covering all walk in cold rooms less than 400
m3 (whether of prefabricated kit or customised type): no concerted, convincing or specific
feedback was received from stakeholders that would preclude this scope being used. It
should be borne in mind that the 400 m3 figure is to a certain extent arbitrary and was
originally intended in the UK analysis to exclude free standing cold stores that are exposed to
the outdoor environment.
Stakeholder feedback confirmed that cold rooms above 100 m3 internal volume generally
tend to be built by specialist contractors with significantly higher levels of skill and better
quality of materials. This is driven by the much higher investment cost and running costs for
such facilities and the much increased reliance on structural integrity to present a safe and
effective environment for working, combined with the much higher intrinsic value of stock that
would be contained in a facility of that size. It is therefore reasonable to assume that the
marginal energy efficiency gains from regulating this larger end of the market would be much
lower as good practice would be more widespread anyway. The cost to suppliers and users
(and inconvenience) of implementing regulation would be minimal where this is already
carried out by the majority of the market. A regulation including these larger stores over 100
m3 would therefore serve to secure the maintenance of good practice in these larger cold
rooms and protect the market for those businesses already providing energy efficient
solutions.
A compromise step to reduce regulatory, legal and technical complications could be to
exclude from the proposed regulation any cold rooms for which one or more walls from the
outside of a building are exposed to the weather. In this case, the 400 m3 per volume
threshold could be retained with minimal resulting complications. It is therefore concluded
that small and medium-sized cold rooms (less than 100 m3) should be the main focus of
policy effort to achieve energy savings. But the inclusion of larger cold rooms does not in
itself appear to present technical, legal or economic challenges - except perhaps with
regards cold rooms that form part of an external building exposed to the outdoor
environment, due to the crossover with building regulations but these could be excluded from
the scope to avoid those issues. 14 out of 22 respondents to this question (Appendix 12, Q2)
thought that cold rooms exposed to weather should be included, although many queried the
practicality of this in comments and noted duplication with building regulations.
5.1.3
Proposed information requirements
Information requirements as proposed in the January 2012 working document are retained.
These are that all walk in cold rooms are to specify in the product documentation the
following items by January 2014:



Intended storage temperature in degrees centigrade
Storage volume in cubic metres
U-value for walls, floor, ceiling, doors and windows
Ref: AEA/ED[Category]/Issue Number 1.2c
31
Impact Assessment for Walk in cold rooms


For prefabricated kits only: Thermal characteristics of thermal bridges
The selected method for reducing ingress of ambient air into the internal
storage space
And for January 2016:



the energy consumption of ancillary electrical equipment integrated into the
insulated envelope of the cold room, expressed in kWh/ day and rounded to two
decimal places
the cooling capacity and power input of the refrigeration unit or system serving the
cold room, expressed in kW and rounded to two decimal places
the coefficient of performance (COP) of the refrigeration unit or system serving
the cold room, rounded to two decimal places
A question was asked of stakeholders on these information requirements (Appendix 12 Q13).
16 of 19 felt that the tier 1 requirements on the insulated envelope could be met. 12 out of 17
felt that those for Tier 2 on the refrigeration system could be met.
5.1.4 Harmonised standards
Mandates for harmonised standards were described in section 2.4: for measuring the Uvalues and thermal bridge properties of insulation panels, developed from ETAG 21; for
measuring the U-values of insulating panels for customised cold rooms, developed from
ETAG 16 and EN 14509; the proper installation methods, perhaps based upon the French
standard DTU45-1; energy consumption of electrical components; measuring the cooling
capacity, power input and coefficient performance of the refrigeration system, developed
from EN 13215/EN 13771.
5.2 Option E: Mandatory maximum U-values for insulation
and other construction elements
5.2.1 Elaboration of proposed option E
Proposed specific requirements for maximum U-value are shown in Table 7 for chilled rooms
and Table 8 for frozen cold rooms. These values were developed from evidence in the
preparatory study, from the US regulation and from stakeholder feedback between February
and June 2012. They are designed to bring the whole of Europe up to a good practice level
over an economically viable timescale through two Tiers of requirements that are 18 months
apart. The timing aims to avoid interim back-sliding for regions or particular suppliers who
have already adopted good practice performance. Further details of the rationale and
evidence on which these levels are based are given in section 5.2.2.
Table 7. Chilled walk-in cold rooms: Proposed performance levels (for illustration
purposes only assuming lambda value of 0.025 W/mK).
Source
Maximum U-value
Example
corresponding
2
W/m K
minimum
Ref: AEA/ED[Category]/Issue Number 1.2c
32
Impact Assessment for Walk in cold rooms
thickness (mm)
Walls
ceiling
/ Floor
Door Glazed Walls / ceiling
Tier 1 (January 2015)
0.35
none
0.35
1.1
71
Tier 2 (July 2016)
0.25
none
0.25
1.1
100
Table 8. Frozen walk-in cold rooms: Proposed performance levels (for illustration
purposes only assuming lambda value of 0.025 W/mK).
Source
Maximum U-value
Example
corresponding
W/m2K
minimum
thickness (mm)
Walls
ceiling
/
Floor
Door Glazed Walls / ceiling
Tier 1 (January 2015)
0.20
0.4
0.2
1.1
125
Tier 2 (July 2016)
0.17
0.2
0.17
1.1
147
5.2.2 Relative stringency of U-value requirements
Table 9 and Table 10 compare proposed minimum requirements from the January 2012
working document, US minimum requirements (2009, converted to EU units), minimum
requirements proposed in the preparatory study, minimum requirements proposed by an
Italian manufacturer stakeholder and common practice in northern and southern Europe.
The lower two rows on each of those tables show the figures that were proposed in the May
2012 consultation document, which were judged based on stakeholder feedback and the
figures above in those tables. Some explanation of the rationale for each of those is given in
the following sections.
Table 9. Chilled walk-in cold rooms: Comparison of various performance levels and
common practice in northern and southern Europe, with corresponding thickness of
insulation (for illustration purposes only assuming lambda value of 0,025 W/mK).
Source
Maximum U-value
Example
corresponding
2
W/m K
minimum
thickness (mm)
Walls
ceiling
/ Floor
Door Glazed Walls / Floor
ceiling
EU Working document MEPS (for 0,35
Jan 2014)
0,55
1
US MEPS(2009)
0,227
n/a
0,227 n/a
110
Preparatory study proposed MEPS
0,25
0,25
0,25
100
100
Italian stakeholder proposed MEPS
0,38
0,56
1
66
45
Ref: AEA/ED[Category]/Issue Number 1.2c
1,1
1,1
71
45
33
Impact Assessment for Walk in cold rooms
UK (Northern European) common 0,25
practice
100
Italy (Southern European) common 0,42
practice
60
Tier 1 proposed by PU Europe (see 0,35
Appendix 13)
0.35
1.1
71
Tier 2 proposed by PU Europe (see 0,30
Appendix 13)
0.30
1.1
83
Tier 1 (January 2015)
0,35
none
0,35
1,1
71
Tier 2 (July 2016)
0,25
none
0,25
1,1
100
Table 10. Frozen walk-in cold rooms: Comparison of various performance levels and
common practice in northern and southern Europe, with example corresponding
thickness of insulation (for illustration purposes only assuming lambda value of 0,025
W/mK).
Source
Maximum U-value
Example
corresponding
W/m2K
minimum
thickness (mm)
Walls
ceiling
/
Floor
Door Glazed
Walls /
Floor
ceiling
EU Working document MEPS (for
Jan 2014)
0,20
0,40
0,70
1,1
125
63
US MEPS(2009)
0,177
0,203
0,177
n/a
141
123
Preparatory study proposed MEPS
0,2
0,2
0,2
125
125
Italian stakeholder proposed MEPS
0,23
0,42
0,7
109
60
UK (Northern European) common
practice
0,17
150
Italy (Southern European) common
practice
0,25
100
Tier 1 proposed by PU Europe (see
Appendix 13)
0,23
0,5
0,35
1.1
109
50
Tier 2 proposed by PU Europe (see
Appendix 13)
0,2
0,5
0,3
1.1
125
50
Tier 1 (January 2015)
0,20
0,4
0,2
1,1
125
Tier 2 (July 2016)
0,17
0,2
0,17
1,1
147
5.2.2.1
1,1
Walls and ceiling
A key consideration in the setting of U-values for walls and ceiling is the difference in typical
practice between northern and southern Europe. The objective in the setting of these levels
is for Tier 1 to prompt an improvement in the southern European typical performance levels
without causing market shock, recognising that this is actually at a level below typical
practice in northern Europe. There was a consensus amongst manufacturers at the
Ref: AEA/ED[Category]/Issue Number 1.2c
34
Impact Assessment for Walk in cold rooms
stakeholder meeting in March 2012 that a regulatory level set worse than typical practice
would inevitably result in a backsliding of performance towards the minimum requirement
level which would be significantly cheaper.
Two possibilities to avoid this back-sliding:
a) In the consultation a 2nd tier is proposed only 18 months later that brings the whole of
Europe up to the level that is already difficult for Northern Europe. The thinking is that
it would not be worth the investment in retooling etc for Northern European suppliers
to adjust to the less demanding minimum requirement of January 2014 before the
more demanding Tier 2 requirement comes into force. But this effectively gives the
southern European suppliers a period of 2 ½ years to adjust to the more stringent
Tier 2 requirement.
b) A second possibility is to only have one Tier set at the good practice level, but allow
longer for suppliers to meet it. This is simpler and possibly most effective.
The Tier 2 levels coincide with the levels commonly used in Northern Europe which in the
case of chilled cold rooms coincide with those of the preparatory study document. The levels
also closely correspond with the minimum requirements applicable in the USA which have
been exhaustively checked for cost effectiveness by US DoE (cost effectiveness for Europe
should be better than this as electricity prices are generally higher).
When asked about the proportion of cold rooms that would fail Tier 1 proposals, stakeholders
estimated from less than 5% to over 50%, with an average of 30% across the 20 replies
(Appendix 12 Q7), with some asserting that medium temperature would mostly pass and low
temperature would mostly fail. For Tier 2 failures, stakeholders also guessed between less
than 5% and over 50% but the average guess was 50% for Tier 2 across the 15 answers to
this question.
5.2.2.2 Floor
Stakeholder feedback on 1 March 2012 indicated that it is not appropriate to set minimum
requirements for U-value of chilled cold rooms. Requirements are not set for these in the
USA either. The Tier 1 requirements for frozen rooms coincide with those proposed in the
working document of January 2012 which are recognised as not particularly demanding, but
Tier 2 brings them in line with the levels proposed in the preparatory document and similar to
those in the USA. 14 out of 19 respondents to a question on this (Appendix 12 Q10) agreed
with the proposals.
Note comments from PU Europe (see Appendix 13):
Requirements for floor panels do not seem to exist in many countries today. The
proposed requirements are considered too high even by Nordic manufacturers. Floor
panel structures often consist of at least 20mm plywood plate and reinforcement
pieces fixed through the bottom to the plywood panel. In certain cases, due to heavy
performance needs, the plywood needs to have a thickness of 30mm and many
reinforcement pieces need to be integrated. More research is recommended before
moving to lower U-values.
5.2.2.3 Doors
US requirements for doors are identical to those required of the walls. It is assumed that the
cost effectiveness of this has been fully evaluated for the US regulations, but should be
checked for the EU. The US DoE team admitted that it is possible that this quite stringent
requirement for doors has limited technical innovation in some cases: rapid closing doors
that significantly reduce air ingress arising during access and so achieve significant energy
savings have to be designed to be lightweight. A demanding thermal performance
requirement should result in lower losses when the door is closed but also mean higher
Ref: AEA/ED[Category]/Issue Number 1.2c
35
Impact Assessment for Walk in cold rooms
weight and rapid action doors may not be able to meet this higher requirement. It is possible
that the savings are higher by reducing air ingress than they are by less heat flow through
the closed door.
13 out of 17 stakeholder respondents agreed with Tier 1 for doors; but only 8 out of 15 for
Tier 2. Comments suggested that these are quite demanding and would lead to substantial
price rises.
It is recommended that further consultation with suppliers and independent experts is
undertaken before this figure is finalised, the figures used in the May 2012 consultation could
be too demanding.
Note comments from PU Europe (see Appendix 13):
The U-values for the doors must only refer to the door itself (door leaves + insulation
core), and not to the door structure (door leaves + insulation core + door gaskets +
door frame etc.). Otherwise, it would not be possible to achieve these performance
levels. The proposed U-values are problematic. Doors cover only a small surface in
the WICR and thicknesses above 100mm cause technical problems. 150mm thick
doors are only used in the Nordic countries for temperatures below -20°C. For all
other applications, thicknesses of 100mm or below are used.
5.2.2.4 Glazed doors
The requirement for glazed doors is at a nominal level and recognised as not demanding.
Feedback received from door manufacturer stakeholders (reported in appendix 4) indicates
that:


Typical practice for frozen cold room glazed doors with 95% market share have a U
value of around 1,73 but the best doors achieve a U-value of 0.9 and account for the
remainder of the market but cost up to twice as much.
Typical practice for chilled cold room glazed doors achieved U-values around 2.1 with
98% market share; the best doors achieve U-values around 1.
13 out of 18 respondents to a question on the U-values for transparent panels agreed with
the proposals.
These requirements do represent a significant improvement over current standard practice
but could certainly be made more stringent. Some economic analysis and discussion with
suppliers would be valuable to support a decision on any more stringent requirements.
5.2.3 Energy consumption impacts
The potential savings identified in the preparatory study of 24% (a generic figure covering
medium and low temperature applications of all sizes) from the proposed package of
measures are considered to be significantly overstated. Particularly given the scaling back of
the range of requirements in the likely policy package, far lower savings are judged
reasonable and conservative.
Energy modelling using CoolPack calculation software14 for cold rooms indicates that the
savings for increasing wall and ceiling insulation from levels typical of southern Europe to
those of Tier 1 and Tier 2 would result in the energy savings shown in Table 12 and Table
13.
Results of estimates on what effect this may have on the EU stock are shown in Table 18.
These simple calculations assume that half of the stock is southern European and half is
14
The CoolPack software was used, available free of charge from the Department of Mechanical Engineering, Technical University of Denmark,
www.et.du.dk/CoolPack.
Ref: AEA/ED[Category]/Issue Number 1.2c
36
Impact Assessment for Walk in cold rooms
Northern European. All southern European cold rooms align with the U-value of Table 9 and
Table 10 typical of southern Europe, and similarly for Northern Europe. They assume that no
savings are made in northern Europe, and the whole southern European stock of cold rooms
move up to the Tier 1 then Tier 2 performance levels. This is not a realistic stock change
scenario but gives an impression of long term scale of savings.
The requirements bring the whole of Europe up to levels that are currently typical practice in
northern Europe anyway and so whilst some savings would be made from eliminating poor
practice in northern Europe, the scale of those extra savings would be far less and have not
been calculated.
The total savings shown in Table 18 thus represent a rough conservative indication of the
total savings that could be achieved by the U-value requirements in the longer term (when all
stock has met the requirements).
The savings by this approach compared with base case are shown in Table 11.
Table 11. Energy consumption, savings and CO2 equivalents for whole EU from Tier 1
and Tier 2 measures relating to U-value of insulation for walls.
Measure
Annual energy
usage
(TWh)
Annual energy
saving compared
to base case
CO2 equivalent annual
saving (energy usage only
compared to base case)
(TWh)
(Million tonnes of CO2)
Tier 1
(January 2015)
Tier 2
0,4
0,16
0,79
0,31
18.5
(July 2016)
Table 12. Estimated savings for chilled cold rooms based on refrigeration system
modelling using the CoolPack model. Modelling assumed +2°C for chilled and -18°C
for frozen.
Chilled cold rooms
Category
Small
Med
Large
AEC, kWh/yr
6.665
16.357
59.278
Sales %
44%
23%
1%
15
50
200
Load at 0,42, kW
0,768
1,271
3,292
Load at 0,35
0,748
1,223
3,151
Load at 0,25
0,719
1,155
2,948
Estimated % saving for improving U2,6%
value 0,42 to 0,35
3,8%
4,3%
3,0%
Resultant Annual consumption after
6.491
Tier 1 kWh/yr
15.739
56.739
10.358
Estimated % savings for improving U- 6,4%
9,1%
10,4%
7,4%
Assumed
modelling
average
volume
for
Ref: AEA/ED[Category]/Issue Number 1.2c
All
chilled,
weighted by
sales
proportion
68%
37
Impact Assessment for Walk in cold rooms
value 0.42 to 0.25
Resultant Annual consumption after
6.240
Tier 2 kWh/yr
14.864
53.084
9.846
Table 13. Estimated savings for frozen cold rooms based on refrigeration system
modelling using the CoolPack model. Modelling assumed +2°C for chilled and -18°C
for frozen.
Frozen cold rooms
Category
Small
Med
Large
All
frozen
weighted by
sales
proportion
AEC, kWh/yr
8.627
27.293
113.224
16.562
Sales %
23%
8%
1%
32%
50
200
Assumed
modelling
average
volume
for 15
Load at 0,25, kW
1,068
1,877
5,071
Load at 0,20
1,017
1,758
4,717
Load at 0,17
0,986
1,687
4,505
Estimated % saving for improving U- 4,8%
value 0,25 to 0,20
6,3%
7,0%
5,2%
Resultant Annual consumption after 8,215
Tier 1 kWh/yr
25,563
105,320
15,586
Estimated % savings for improving U- 7,7%
value 0,25 to 0,17
10,1%
11,2%
8,4%
Resultant Annual consumption after 7.965
Tier 2 kWh/yr
24.530
100.586
15.000
5.2.4 TEWI impacts
5.2.4.1 Energy related impact
CO2 impact from energy savings is given in Table 11.
5.2.4.2 Direct impact
There are no measures included in the proposal that would affect refrigerant leakage from
the refrigeration plant during use or at disposal and so the net impact of this measure on
refrigerant leakage is zero.
A direct impact is possible, however, as the measure would alter the amount of insulation
foam used in the sector which would alter the volume of blowing agents released from the
insulation foams during and after their usage (all will eventually be released). Some of the
blowing agents have global warming potential (GWP) of 1000 or more times that of CO2. A
fourth generation of blowing agents, the so-called HFOs or unsaturated HFCs should
become commercially available over the next five to ten years and offer an insulation
performance similar to that of current HFCs but with a GWP of less than 1015.
15
Source: PU Europe – see Appendix 13.
Ref: AEA/ED[Category]/Issue Number 1.2c
38
Impact Assessment for Walk in cold rooms
Around 95% of continuously produced insulation panels, which are those made by large
manufacturers, use hydrocarbon blowing agents which have very low GWP (less than 11).
The majority of custom made cold rooms will be made from this type of panel. Around half of
discontinuously produced panels, which are made in smaller quantities by SME suppliers
and commonly used for prefabricated kits, use HFC blowing agents with GWP around 1000.
(The rest of discontinuously made panels use water or formic acid which have low GWP).
The HFC blown panels tend to be more effective (better U-value) than hydrocarbon blowing
agents; which in turn are more effective than water/formic acid blown panels16. A greater
emphasis on U-value could push the market towards higher GWP blowing agents for
continuously formed panels and for discontinuously produced panels.
It is assumed that all of the blowing agent contained in the insulating foam would eventually
be released to the atmosphere. Thus if more insulating foam is used, more blowing agent will
be released and a higher direct impact will result. The total impact of this has not been
modelled, but an example evaluation has been carried out to indicate whether the overall
impact is likely to be positive or negative:
The GWP impact of this higher release of blowing agent could be weighed against the CO2
impact of energy savings for a particular example cold room. Taking a worst case analysis:
i.
ii.
iii.
iv.
v.
vi.
vii.
viii.
Assume HFC based blowing agent with GWP 1000
A small sized chilled cold room (volume of foam would be higher per unit energy
consumption than for a medium or large room and chilled has lower consumption
than a frozen room, meaning less energy savings against which to offset GWP
emissions).
For a small cold room of typical volume around 15 m3, dimensions could be 2 m x 2 m
x 4 m. Surface area of foam would be (4 + 4 + (4 x 8)) = 48 m2; the regulation would
require an increase in thickness for chilled rooms in southern Europe from 71 mm to
100 mm (Tier 2, see Table 9), say 0.03 m increase. So extra volume of foam required
to meet the new levels is 48 x 0.03 = 1.5 m3
One source was found to indicate approximate mass of blowing agent per m3 of
foam17, and a figure of 700 g/m3 is used in this estimate. 1.5 m3 of foam would
therefore release 1.5 x 0.7 = 1 kg of HFC with GWP 1000, or 1 tonne CO2 equivalent.
From Table 12, this same action for the small cold room would save 6665 – 6240 =
425 kWh per year; over a 15 year life total saving is 6375 kWh.
This is equivalent to around 2500 kg CO218.
Thus in this worst case analysis, the extra foam gives rise to 1 tonne CO2 equivalent
direct emissions, compared to 2,5 tonnes CO2 equivalent savings in electricity.
The CO2 equivalent savings therefore favour the use of more insulating foam in order
to save energy, despite total loss of a high GWP foam blowing agent at end of
product life.
This is a worst case analysis. The real balance would be far greater in the favour of using the
insulation because a high proportion of cold rooms use low GWP blowing agents. Also larger
cold rooms and rooms at colder temperatures would make proportionately better ratio due to
higher energy consumption.
5.2.5 Impact on competitiveness and innovation
The measures as proposed in the retained option will have limited impact on innovation since
the main thrust is to apply more widely a more effective insulation panel. The technologies
16
Source: PU Europe (see Appendix 13).
Specific blowing agent consumption per unit of polyurethane foam manufacture, data from supplier for a 60 mm thick PUF panel for HFC 134a:
3
621 g/m .
18
Using carbon factor around 0.39 kg CO2/kWh, projected value half way through cold room life.
17
Ref: AEA/ED[Category]/Issue Number 1.2c
39
Impact Assessment for Walk in cold rooms
and techniques are already in the market to achieve this, but it will encourage more focus on
the most cost-effective way of delivering that.
The pressure on prices felt by the suppliers and installers is unlikely to greatly influence the
major suppliers of insulated panels as cold rooms account for only a small proportion of their
market. On the other hand, cold room suppliers who cast their own panels tend not to have
the investment, chemists and development engineers necessary to produce new lower cost
higher efficiency foam technologies to tackle that challenge. A few stakeholders felt that
suppliers of smaller cold rooms, particularly prefabricated ones, would suffer as a result of
these requirements with more customers opting for customised cold rooms (Appendix 12
Q8). 14 out of 20 respondents felt that there would be significant impact on the profitability of
the sector resulting from these requirements, with significant price increases mentioned in
almost all comments, including installation price increases.
One beneficiary is the insulated doors and automated door closer mechanism sector.
There is a significant challenge for enforcement in this walk in cold room market which relies
heavily on a low cost, low skills workforce and which has operated to date largely without
regulatory controls. But enforcement will be necessary to retain competitiveness and avoid
the market and investment of reputable suppliers being undermined.
One particular risk to be considered is where the minimum requirement for U-value of a door
might preclude the use of a fast-action door. Fast action doors open rapidly to allow entry
and close rapidly afterwards to minimise the period for which the door is open. These doors
must necessarily be light weight to achieve rapid movement without a large motor size and
also to avoid having a dangerous momentum if a collision occurs. Given the weight and bulk
of insulation materials, these doors are rarely well insulated, but may be used in conjunction
with a secondary door for use in ‘silent hours’.
5.2.6 Direct economic impact
Very limited data is available on the economic impact of the proposals and on the costs of
products and components. The following direct and indirect economic impacts are
considered:
5.2.6.1 Product price increases
Product price rises could be significant: The price of an 80 mm panel is about 20-30% higher
than the price of a 60 mm panel once material, transport and additional jointing costs are
taken into account according to specific stakeholder feedback reported in Appendix 9.
If this is taken as a 25% increase for adding 20mm thickness to a 60mm panel and if the
proportional increase remains consistent for changes between different thicknesses, then:
Introduction of Tier 1 might increase the cost of panels for a chilled cold room in southern
Europe by 15% and frozen by 20%; Tier 2 might increase the cost of panels from today’s
typical level by 50% and 40% respectively. If the cost of panels accounts for around 20% of
the total cost of the installed cold room19 then the overall price increase from today’s typical
southern Europe levels may be less than 5% for Tier 1 and less than 15% for Tier 2.
The preparatory study only gave an estimated price for the base case of a chilled
prefabricated 25 m3 internal volume cold room at €8.80020. Price increase for a small chilled
room of that size might then be €440 for Tier 1 performance and €1.300 for current to Tier 2
performance (for typical southern European cold rooms).
19
No specific evidence is available for this proportion, but installation cost may be around 35%; refrigeration plant perhaps 25% and door and
other components 20%, with panels accounting for 20%.
20
Preparatory study Lot 1 Task 4 report, table 4-28.
Ref: AEA/ED[Category]/Issue Number 1.2c
40
Impact Assessment for Walk in cold rooms
Also reported in appendix 9 is feedback explaining that costs for medium size panels (60
(thick.) x 800 (large) x 1600 (height) mm) are around 200 euro. Costs for small size panels
(60 (thick.) x 200 (large) x 1600 (height) mm) are around 160 euro. Transportation costs are
driven by volume rather than by weight and so increased panel thickness will increase
transportation costs which is taken into account in the figures used.
Note comments from PU Europe (see Appendix 13):
The cost of making very thick boards increases disproportionally. Most manufacturers
cannot go beyond 150mm today and would have to invest in new technologies.
Furthermore, a 100mm element has to cure for approximately 30 minutes, while a
150mm panel needs 1h to 1h15 curing time. Hence, when using the same presses,
producers have less than half of the output when making 150mm panels but with the
same labour costs.
5.2.6.2 Costs and net cost impacts for users
The cost impact of Tier 1 is to put up to 5% on a chilled room price and up to 15% for a
freezer room, due to increased insulated panel costs. Tier 1 lifetime savings on energy costs
for a 25m3 cold room can be calculated indicatively from Table 12 and Table 13 as €560 for a
chilled room and €1.500 for a frozen room21, versus an extra cost of less than €440 for the
chilled room (no product cost data for a frozen room). Tier 2 would achieve lifetime savings
of around €1.500 for a 25 m3 chilled room versus an extra investment of up to €1.300. These
indicative estimates suggest that the investments are probably cost effective, which is
certainly supported by evidence of these thicknesses being typical practice in Northern
Europe. Cost effectiveness should be better in Southern Europe due to higher ambient
temperatures (if electricity costs are the same).
5.2.6.3 Cost of testing
There should be no impact on cost of testing as aged lambda is (or at least should be) the
established metric (although it involves a more expensive test than that for initial lambda)22.
5.2.7 Other environmental impacts
One particular environmental risk has been identified in consultation (and is reported in more
detail in Appendix 4): for discontinuously produced panels, HCs are rarely used as blowing
agents and HFCs produce thermally better panels than the (low GWP) alternative of water or
formic acid blown panels. Hence for this type of panel, used for small and often prefabricated
cold rooms, the requirements could possibly encourage more HFC blowing agents. No
detailed assessment has been made as to whether this is in fact technically or economically
likely, but this risk is for a small (and diminishing) part of the overall market. Also pertinent for
this is that a possible ban on HFCs is being discussed in the framework of the F-Gas
regulation and HFCs have already been banned in some EU Member States, e.g. Austria
and Denmark.
The most common polyurethane foam blowing agent, accounting for over 95% of the
continuously produced panels, is pentane. The price to the end user for pentane panels ends
up at roughly the same as the cost of HFC blown continuous panels, despite pentane
production lines costing significantly more to set up. Pentane, with low GWP, unfortunately
has a worse thermal performance than HFCs as a blowing agent.
21
A 25 m3 chilled room might use around 9.400 kWh per year (interpolated from Table 12) and so Tier 1 would save 250 kWh per year or 3.750
kWh over the product life, worth around €560. A 25 m3 frozen room might use around 14.000 kWh per year (interpolated from Table 13) and so
Tier 1 would save 700 kWh per year or 10.500 kWh over the product life, worth around €1.500 (energy cost of €0.15 /kWh).
22
Source: PU Europe (see Appendix 13).
Ref: AEA/ED[Category]/Issue Number 1.2c
41
Impact Assessment for Walk in cold rooms
No other specific environmental impacts have been identified.
5.2.8 Option for U-values based upon temperature differentials
An option was proposed and discussed during stakeholder consultation as an alternative to
having fixed U-value requirements for chilled and for frozen cold rooms on the basis that the
effectiveness of insulation in any given situation is dependent upon the temperature
differential across it. The colder a room is operated at, the thicker the insulation that is costeffective. Requirements could be based upon a maximum heat transmission rate instead of
on a maximum U-value, as can be demonstrated in Figure 4. In that figure a maximum heat
transmission rate of 10 W/m2 is already identified as a good practice figure and results in a
required U-value of 0.39 if the temperature differential across the panel is 25°C, but a U
value of 0.25 if the temperature differential is 40°C, which will reflect the cost effectiveness of
the panels.
This approach was supported by the Polyurethane manufacturers’ trade association PU
Europe (see Appendix 13) which also noted that Spain has set requirements based on
temperature differentials.
It could become complex to evaluate if this requirement has been met or not, particularly if
the storage temperature is changed after the initial specification or during subsequent use of
the facility. This approach would require some technical evaluation of cost effectiveness,
ease of implementation and applicability before it could be adopted into a regulation and so
is not proposed for inclusion in this stage. 14 out of 21 respondents on this question in the
consultation suggested that this was worth further investigation. This should therefore be
considered at review of the regulation.
Figure 4. Extract from Kingspan brochure23 showing heat transmission rates for
different temperature differentials and insulation thicknesses, based on a fixed
lambda value.
23
ModularZone: High Performance Modular Cold Rooms and Freezer Rooms, November 2011.
Ref: AEA/ED[Category]/Issue Number 1.2c
42
Impact Assessment for Walk in cold rooms
5.3 Option F: Mandatory limits on performance of thermal
bridges in pre-fabricated cold room kits
5.3.1 Elaboration of proposed option F
Specific requirements for thermal bridges were proposed for prefabricated kits only in the
January 2012 working document. Thermal bridges were not mentioned in the preparatory
study. No evidence was available to this Impact Assessment on the rationale or values
selected. It is assumed that these are based upon ensuring that a level of good practice is
maintained and that joints are not the cause of excessive heat leakage into the cooled space
– no comments were received in consultation to dispute the selected values.
The proposed maximum ψ values allowed for placing on the market are (expressed as heat
loss per unit length per degree temperature difference, in W/mK):




Wall-to-wall linear thermal bridges: 0.6
Wall-to-floor linear thermal bridges: 0.6
Wall-to-ceiling linear thermal bridges: 0.6
Wall-to-door linear thermal bridges: 0.7
In addition, punctual thermal bridges are not permitted with a χ value (W/K) higher than 0.3.
5.3.2 Energy consumption impacts
No data is available on the current typical performance of thermal bridges, nor how much
improvement the proposed values would achieve. This makes assessing the savings
challenging, but an indicative assessment could be made of the possible savings potential:
These requirements only apply to the prefabricated cold rooms which are a subset of small
cold rooms. If prefabricated cold rooms account for half of the small rooms (no evidence on
this proportion was available), then the EU energy consumption of prefabricated cold rooms
is around 3.7 TWh (half of the figure shown in Table 2). Around 20% of the heat load of a
cold room enters through the insulation and perhaps 15% of that 20% enters through thermal
bridges. Thermal bridging in prefabricated cold rooms might therefore account for less than
0.2 TWh of energy consumption in the EU – and perhaps an optimistic 50% of that might be
saved by this measure – or 0.1 TWh per year.
5.3.3 TEWI impacts
Energy related savings might achieve a reduction of 0.04 million tonnes CO2 equivalent24.
This requirement would have no effect on direct emissions.
24
Indicative carbon factor of 0.4 kg/kWh.
Ref: AEA/ED[Category]/Issue Number 1.2c
43
Impact Assessment for Walk in cold rooms
5.3.4 Impact on competitiveness and innovation
The measure is aiming to ensure better quality installation of readily available technologies
and so will have little or no effect on innovation, but would slightly benefit competitiveness of
end users through reduced energy costs.
Some stakeholders pointed out that this measure only applies to prefabricated cold rooms, it
effectively penalises that sector when no such requirement is applied to customised cold
rooms. This was felt particularly unfair as it is the prefabricated cold rooms that have factoryprepared joints that are more likely to be accurate and better-performing.
5.3.5 Direct economic impact
If the indicative savings of 0.1 TWh per year were costed at €0,15 /kWh then this would be
worth around €15.000 per year across the EU.
No data is available on the marginal cost of joints made to this level of effectiveness but the
assumption is that this measure aims to ensure that joints are made properly that are already
included in the product price and so marginal price could be close to zero.
There could be a marginal price increase, however, if the supplier has to carry out infra-red
survey of the cold room after it has been commissioned to prove compliance. This would
often require a return visit to the site at a later date as the cold room would need to achieve a
steady state cold condition first and also because the insulated envelope contractor may not
be the one installing the refrigeration plant.
5.3.6 Other environmental impacts
None identified.
Ref: AEA/ED[Category]/Issue Number 1.2c
44
Impact Assessment for Walk in cold rooms
5.4 Option G: Requirements for specific design and
construction elements to minimise air infiltration and
secure other energy efficiency features
5.4.1 Elaboration of proposed option G
The proposal is that this measure imposes general requirements that:
a) Doors must have ‘soft-closers’. These are features that automatically bring the door
close to a closed position if left wide open. Note: this would not require that the door
is automatically latched firmly closed as this could represent a more significant and
potentially non-economic investment. Wording would have to be carefully developed
to avoid loopholes (US regulation examples could be useful).
b) Measures are included in the design that minimise air infiltration when the door is
open. Options to achieve this would be those most appropriate to the installation and
might include strip curtains; automatically switching of the circulation fans when the
door is open; an air curtain over the opening; secondary door(s) or vestibule; use of a
rapid action door; etc.
Note comments by PU Europe (see Appendix 13):
As regards the soft door closers, certain door manufacturers stated that the proposal
would lead to installation problems. The models on the market (for examples those
available in the US) are designed for doors which are level with the panel. In Europe,
however, most cold room doors are overlapping or partially-housed doors. Soft door
closers do not seem to be available for this kind of doors at least in Southern Europe.
To be checked with the door manufacturers.
14 of 20 respondents to a question on this proposal (Appendix 12, Q4) agreed that the
wording is appropriate for reducing air infiltration.
The additional requirements for high efficiency motors for evaporator and condenser fans
may be more appropriate to consider alongside requirements for the refrigeration system
itself, rather than being bundled with a regulation that otherwise deals only with the insulated
enclosure. The preparatory study25 evaluated that an ECM (electronically commutated motor,
i.e. variable speed) evaporator fan would save 13% over the base case consumption and
pay back in 0,8 years; ECM motor for the condenser would save 3% and pay back in 1,4
years. Both are therefore economically attractive but their cost effectiveness must be set into
the perspective of the refrigeration system performance as a whole. It is not appropriate for
this aspect of the refrigeration system to be alone in the currently proposed measure. 14 out
of 19 respondents to a question on high efficiency motors agreed that this measure is worth
further investigation (Appendix 12 Q17).
Requirements for lighting systems were examined in the preparatory study as far as
potentially mandating LED lighting with a saving of 4% and a payback in 3,4 years. Any
requirement could not be technology specific and a ‘lumens per Watt’ limit would be more
appropriate. The US level could be adopted of 40 lm/Watt, together with a timer to switch off
after 15 minutes. Cost effectiveness of this under EU electricity and product prices should be
verified, as well as any safety implications from automatic switching off. This could therefore
be considered at stage of first regulatory review.
25
Preparatory study Lot 1 Task 6 report, table 6-4.
Ref: AEA/ED[Category]/Issue Number 1.2c
45
Impact Assessment for Walk in cold rooms
5.4.2 Energy consumption impacts
Anecdotal evidence from suppliers implies that a significant proportion of the available
savings are from reducing air infiltration. Respondents to the consultation indicated that
around 30% of cold rooms sold today already incorporate automated door closers (simple
average of the indicated percentages from 18 respondents).
If 30% of the heat load is from air through doors, and the measure succeeds in increasing
the proportion of cold rooms with automated door closers from 30% to 90%; and those door
closers plus any other reduction measures can cut losses by 20% in each case (door
opening is not stopped of course, just reduced):
Indicative possible savings = (90% - 30%) x 30% x 20% x 18.5 TWh = 0.7 TWh per year.
5.4.3 TEWI impacts
Energy related savings might achieve a reduction of 0.3 million tonnes CO2 equivalent26. This
requirement would have no effect on direct emissions.
5.4.4 Impact on competitiveness and innovation
The measure involves wider deployment of well established technology and so will have little
or no effect on innovation, but would slightly benefit competitiveness of end users through
reduced energy costs.
5.4.5 Direct economic impact
If the indicative savings of 0.7 TWh per year were costed at €0,15 /kWh then this would be
worth around €105.000 per year across the EU.
The door closers were estimated to cost €110 each in the preparatory study with a payback
of 0,63 years.
5.4.6 Other environmental impacts
None identified.
26
Indicative carbon factor of 0.4 kg/kWh.
Ref: AEA/ED[Category]/Issue Number 1.2c
46
Impact Assessment for Walk in cold rooms
5.5 Timing of implementation
The proposed start date of January 2014 could be considered too ambitious, particularly
given the need for harmonised standards to be developed in every significant area of the
regulation. Consultation should be held with the convenor of TC 44 working group 4 to
confirm feasible timescales. Since one year will have to be allowed between publication and
start of measures, January 2015 is a more realistic start date.
Timing of implementation for U-values is crucial due to the need to move typical southern
European practice ahead more quickly than northern European typical practice. This will
have to be achieved in rapid succession to avoid better suppliers backsliding to low
mandatory requirements. 18 months has been proposed as the gap between Tier 1 and Tier
2; further consultation on the feasibility and appropriateness of this would be very useful if
not essential.
There are very many SMEs involved in this industry and communication of requirements will
be complex and demanding, especially in the absence of a strong European industry
Association that covers products of these sizes. There are several major associations at the
national and European level that represent manufacturers of polyurethane insulated panels
and associated products. But the suppliers of cold rooms do not have any specific
representation. The means to roll out awareness of these requirements should be factored
into the timing of the regulation and cooperation with the most appropriate industry groups.
5.6 Risks and uncertainties, expected compliance patterns
Compliance is expected to be poor for the majority of suppliers which are small and mediumsized enterprises using staff with low skills operating to very tight cost constraints.
Implementation will need a significant effort on communication, training and cooperation with
industry associations. The Italian Association ANIMA could be a useful ally in reaching out to
the sector.
Other specific risks include:





The feasibility and technical complexity of developing a code of practice on the
installation of cold rooms, including identifying who should take responsibility for the
resultant quality.
It will be necessary to make clear who is responsible for the compliance of the
components used in any given cold room. Since manufacturers of insulation panels
legitimately produce panels of very many thicknesses for various uses and that cold
rooms account for a very small proportion of the use of their products, it may well be
that the panel manufacturer does not know whether any particular panel will be used
for a cold room or not. Hence it may be difficult to hold the manufacturer responsible
for compliance. One or more other players in the supply chain could be held
responsible for this, once the end-use becomes clear.
Given that the construction of most small and medium-sized cold rooms is currently
largely unsupervised and the results are not quality checked it will be a significant
challenge even for manufacturers to verify performance.
Verification of whether products comply or not is a significant risk and potential cost to
enforcement authorities. As with other building regulation compliance, the sanctions
for products that do not comply are limited, short of insisting on demolition and
rebuilding. It has been argued that on-site checks of insulation and jointing quality
could be carried out using thermal imaging cameras, but the feasibility of this has not
been investigated.
There is a risk that during the initial stage of the regulation, Northern European and
other better performing suppliers could reduce their typical insulation levels down to
Ref: AEA/ED[Category]/Issue Number 1.2c
47
Impact Assessment for Walk in cold rooms
the lower tier 1 value, resulting in additional energy consumption for such products.
This risk should diminish after Tier 2 takes effect.
5.7 Review of the regulation
It is proposed that the regulation is reviewed in the short-term due to the many uncertainties
associated with its implementation and the impact they might have on the market. Also
because the development of harmonised standards for good practice on installation and on
energy performance of the combined insulated enclosure and refrigeration system may by
then be available to address other aspects of the market failure. A review date no later than 3
years after entry into force is highly recommended – i.e. by 2017, taking into account the
issues identified in section 6.2.
5.8 Assessment of regulatory package against Ecodesign
Framework Directive requirements
Assessment of compliance with article 15:
Further consultation is appropriate with major manufacturers, industry associations,
independent experts and Member States regarding the detail of proposals to confirm the
appropriateness and workability of measures.
Sales of WICR alone, at around 88,000 units per year in 2009, fall short of the indicative
200,000 units per year suggested in the directive article 15. However, their long average life
of 17 years, intensive usage (8,760 hours per year) and high average energy consumption
(sales weighted average of 12,000 kWh per year) means that they give rise to an
environmental impact proportionately larger than their sales might indicate. This average
consumption per WICR is comparable to the typical annual consumption of around 55
household dishwashers (at 220 kWh per year each).
Ref: AEA/ED[Category]/Issue Number 1.2c
48
Impact Assessment for Walk in cold rooms
Table 14. Evaluation of the proposals against ecodesign framework directive Article
15.
Aspect of Article 15
Comment
Conclusion
Indicative sales over 200,000 88,000 per year estimated in Probably OK if high impact
2009. The 17 year life and 24 per unit is taken into account
hour/365 days usage, give an
average annual consumption
of 12,000 kWh per year for
cold
rooms.
(This
is
equivalent to 55 household
dishwashers each).
Significant
impact
environmental Impact is significant because OK
of high energy usage
Significant
potential
improvement
Impact on functionality
Health,
safety
environment
and
for Potential
confirmed
Preparatory study
None
in OK
OK
the No adverse impacts identified OK
Impact on consumers
Significant energy savings, no OK
loss of functionality
Impact on competitiveness
Positive on innovation and Some adverse
competitiveness
but competitiveness
significant costs of testing etc overall
Imposition
technology
of
costs but
improved
proprietary All foreseen requirements can OK
be met by a wide range of
technologies and products.
Administrative burden
Manageable within current OK for most; adverse impact
product economic framework on some smaller suppliers
for all major suppliers; could
be tough on smaller suppliers
Comparison with international None identified
standards
Ref: AEA/ED[Category]/Issue Number 1.2c
OK
49
Impact Assessment for Walk in cold rooms
6 Outline
policy
evaluation
monitoring
and
6.1 Progress Indicators
Coordination with member states’ enforcement authorities would also be useful, particularly
once a testing programme is initiated.
Specific indicators to monitor the evolution of the policy will be:
1. Availability of the harmonised test methodologies necessary for Tier 1 by end of
2013.
2. Review of supplier literature for reference to the requirements and compliance of
offered products
3. Survey of installed products for compliance in southern and in northern Europe. A
baseline survey would be necessary in 2013/2014 to ensure that any progress is
shown
4. Initiation by mandate of the installation good practice standard by mid 2014; progress
to deliver that in time for the regulation review in 2017.
5. Initiation by mandate of the standard for energy performance of the insulated
enclosure and refrigeration system by mid 2014; progress to deliver that in time for
the regulation review in 2017.
6.2 Issues for consideration at regulatory review
The following issues are particularly recommended for consideration when the regulation is
reviewed after 3 years:








Review of how effectively the appropriate supply chain players are taking
responsibility for compliance with the regulation and whether allocation of
responsibilities needs to be strengthened in the regulation
Addition of a requirement for lighting to meet a minimum efficacy and feature
automatic switching off after a given period
Incorporation of the installation good practice standard(s) into a regulation
Review of the impact of the insulation U-value requirements in northern versus
Southern Europe
Potentially making U-value requirements for doors more stringent, supported by
economic analysis
Incorporation of requirements both for the insulated enclosure and performance
(COSP) of the refrigeration system, perhaps learning from US experience on this
issue
Review whether performance requirements based upon the temperature differential
across the insulation panel in a particular application provides a more effective basis
for standards
Refurbishment accounts for between 5% and 30% of business for suppliers consulted
– consideration should be given to whether this can be addressed in a future update
Ref: AEA/ED[Category]/Issue Number 1.2c
50
Impact Assessment for Walk in cold rooms
7 Update Log
Issue 1.2c: Corrected statements in 2 places that had implied that thermal performance of
hydrocarbon foam blowing agents was better than that for HFCs – it is not. Corrected in
section 5.2.7 Other environmental impacts and in the executive summary – other sections
that mention this had the correct information.
Ref: AEA/ED[Category]/Issue Number 1.2c
51
Impact Assessment for Walk in Cold Rooms
Appendices
Appendix 1: Working document for walk in cold rooms as discussed at 19 January 2012
consultation forum (substantially superseded)
Appendix 2: Preparatory notes for Minutes of industry meeting held 1 March 2012
Appendix 3: Minutes of industry meeting held 1 March 2012
Appendix 4: Additional background information for the implementation of eco-design
requirements for walk-in cold rooms (WICRs), prepared by JRC – IET on June 5th 2012
Appendix 5: CLASP report - Overview of USA Regulation on Walk‐In Cold Rooms
Appendix 6: WICF EU-U.S. Collaboration Meeting Minutes (conference call 14 March 2012)
Appendix 7: Refrigerants and related policy options and issues for Lot 1 products
Appendix 8: Assumptions regarding WICR sales, stock and energy consumption
Appendix 9: Results of research interview with INCOLD, May 2012 by JRC, Ispra
Appendix 10: SME questionnaire with summary answers
Appendix 11: Key quotes of feedback from consultation forum and other sources up to 29
June 2012
Appendix 12: Stakeholder questionnaire with answers
Appendix 13: Comments on the first draft of the WICR Impact Assessment report from PU
Europe.
Ref: AEA/ED[Category]/Issue Number 1.2 Page 52
Impact Assessment for Walk in Cold Rooms
Appendix 1 - Working document for walk in
cold rooms as discussed at 19 January 2012
consultation forum (substantially superseded)
Ref: AEA/ED[Category]/Issue Number 1.2 Page 53
Impact Assessment for Walk in Cold Rooms
Appendix 2: Preparatory notes for Minutes of
industry meeting held 1 March 2012
Ref: AEA/ED[Category]/Issue Number 1.2 Page 54
Impact Assessment for Walk in Cold Rooms
Appendix 3: Minutes of industry meeting held 1
March 2012
Ref: AEA/ED[Category]/Issue Number 1.2 Page 55
Impact Assessment for Walk in Cold Rooms
Appendix 4: Additional background information
for the implementation of eco-design
requirements for walk-in cold rooms (WICRs),
prepared by JRC – IET on June 5th 2012
Ref: AEA/ED[Category]/Issue Number 1.2 Page 56
Impact Assessment for Walk in Cold Rooms
Appendix 5: CLASP report - Overview of USA
Regulation on Walk‐In Cold Rooms
Ref: AEA/ED[Category]/Issue Number 1.2 Page 57
Impact Assessment for Walk in Cold Rooms
Appendix 6: WICF EU-U.S. Collaboration
Meeting Minutes (conference call 14 March
2012)
Ref: AEA/ED[Category]/Issue Number 1.2 Page 58
Impact Assessment for Walk in Cold Rooms
Appendix 7: Refrigerants and related policy
options and issues for Lot 1 products
Ref: AEA/ED[Category]/Issue Number 1.2 Page 59
Impact Assessment for Walk in Cold Rooms
Appendix 8 – Assumptions regarding WICR sales, stock and energy
consumption
Table 15. Copy of sales and stock data table 2-10 from the preparatory study task 2 report
Ref: AEA/ED[Category]/Issue Number 1.2 Page 1
Impact Assessment for Walk in Cold Rooms
Table 16. Cold room efficiency data underpinning the estimated annual energy consumption from the UK Market Transformation
Programme document BNCR02 ‘Walk in cold rooms government standards evidence base 2009: reference scenario’
Ref: AEA/ED[Category]/Issue Number 1.2 Page 2
Impact Assessment for Walk in Cold Rooms
Table 17. Market base case average annual energy consumption for WICR by temperature and size category27. Most numbers rounded
to avoid inappropriate assumptions of accuracy. Derivation of AEC data is in Table 16.
Chilled cold rooms
Frozen cold rooms
Grand Total
Category
Small
Med
Large
All chilled
Small
Med
Large
All frozen
Stock %
44%
23%
1%
69%
23%
8%
0%
31%
677,000
356,000
17,000
343,000
122,000
Stock numbers
Total
7,000
1,050,000
472,000
AEC, kWh/yr
6665
16357
59278
8627
27293
113224
Annual consumption EU TWh/yr
4.5
5.8
1.0
3.0
3.3
0.8
Total
11.4
% of total consumption
27
24%
31%
Source data from Preparatory Study table 2-10 or from UK Government MTP document BNCR02.
Ref: AEA/ED[Category]/Issue Number 1.2 Page 3
6%
61%
1,522,000
18.5
7.1
16%
18%
4%
1,522,000
39%
18.5
100%
Impact Assessment for Walk in Cold Rooms
Table 18. Assumed performance levels for WICR after Tier 1 and after Tier 2, showing estimated savings for southern European cold
rooms (results from CoolPack software modelling).
Chilled cold rooms
Frozen cold rooms
Grand
Total
Category
Small
Med
Large
All chilled
Small
Med
Large
All frozen
Stock %
44%
23%
1%
69%
23%
8%
0%
31%
EU stock
677,138
355,539
17,199
1,049,876
343,059
121,912
7,306
472,277
1,522,152
Assumed % of total stock that
is present in southern Europe
50%
50%
50%
50%
50%
50%
Therefore stock numbers for
southern Europe
338,569
177,770
8,599
171,529
60,956
3,653
236,138
761,076
AEC, kWh/yr - Base case
6,665
16,357
59,278
8,627
27,293
113,224
Annual consumption Southern
EU TWh/yr
2.257
2.908
0.510
1.480
1.664
0.414
3.557
9.23
AEC, kWh/yr - Tier 1
6,491
15,739
56,739
8,215
25,563
105,320
Annual consumption Southern
EU TWh/yr
2.198
2.798
0.488
1.409
1.558
0.385
3.352
8.84
AEC, kWh/yr - Tier 2
6,240
14,864
53,084
7,965
24,530
100,586
Annual consumption Southern
EU TWh/yr
2.113
2.642
0.456
5.211
1.366
1.495
0.367
3.229
8.44
Savings Tier 1, TWh
0.059
0.110
0.022
0.190
0.071
0.105
0.029
0.205
0.40
Savings Tier 2, TWh
0.144
0.265
0.053
0.463
0.114
0.168
0.046
0.328
0.79
Ref: AEA/ED[Category]/Issue Number 1.2 Page 4
524,938
5.674
5.484
Impact Assessment for Walk in Cold Rooms
Appendix 9: Results of research interview with
INCOLD, May 2012 by JRC, Ispra
Ref: AEA/ED[Category]/Issue Number 1.2 Page 1
Impact Assessment for Walk in Cold Rooms
Appendix 10: SME questionnaire with summary
answers
Ref: AEA/ED[Category]/Issue Number 1.2 Page 2
Impact Assessment for Walk in Cold Rooms
Appendix 11: Key quotes of feedback from
consultation forum and other sources up to 29
June 2012
Ref: AEA/ED[Category]/Issue Number 1.2 Page 3
Impact Assessment for Walk in Cold Rooms
Appendix 12: Stakeholder questionnaire with
answers
Ref: AEA/ED[Category]/Issue Number 1.2 Page 4
Impact Assessment for Walk in Cold Rooms
Appendix 13: Comments on the first draft of the
WICR Impact Assessment report from PU
Europe
Ref: AEA/ED[Category]/Issue Number 1.2 Page 5
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