Message 001
Communication from the Commission - TRIS/(2023) 2192
Directive (EU) 2015/1535
Notification: 2023/0456/BE
Notification of a draft text from a Member State
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MSG: 20232192.EN
1. MSG 001 IND 2023 0456 BE EN 19-07-2023 BE NOTIF
2. Belgium
3A. FOD Economie, KMO, Middenstand en Energie
Algemene Directie Kwaliteit en Veiligheid - Dienst Verbindingsbureau - BELNotif
NG III – 2de verdieping
Koning Albert II-laan, 16
B - 1000 Brussel
be.belnotif@economie.fgov.be
3B. Vlaams Energie- en Klimaatagentschap
Koning Albert II-laan, 20
Bus 17
B - 1000 Brussel
4. 2023/0456/BE - B00 - Construction
5. Ministerial Decree amending various provisions of the Ministerial Decree of 28 December 2018 laying down general provisions on energy performance regulations, energy performance certificates and certification of contractors and installers
6. The Ministerial Decree provides for adjustments to the EPB calculation method. The calculation method and the inspection protocol for the formatting of the EPC, measurement protocol and calculation method NR are also amended.
7.
8. Article 4 introduces a number of improvements to the Annex 13 of the MD of 28 December 2018, which sets out how to substantiate the design return temperature. The following clarifications were added:
• reference to the latest version of the standard;
• establishing a number of minimum temperatures per room type;
• clarifying what is meant by 'space not for human occupation';
• increasing the lower limit of the exception from 10 W/m² and 100 W to 20W/m² and 200 W, respectively.
Article 5 introduces a number of amendments to Annex 18/3 of the MD dated 28 December 2018, the inspection protocol for EPC residential, small non-residential and common parts.
The most significant amendment is the modified inspection and import of ventilation systems (part IX of the inspection protocol). To date, inspection and imports have been very brief. With the modification, more ventilation facilities shall have to be present in a higher proportion of rooms for this to be validated in the EPC residential as a ventilation system.
Additional minor adjustments have been made.
Article 6 makes some changes to Annex 18/4 of the MD of 28 December 2018, the formula structure of the calculation methodology for EPC residential, small-non-residential and common parts.
The most important ones are:
• Calculation of ventilation systems:
• Adjusting the default coverage ratio if the heat pump is the preferred generator.
Article 7 makes a number of changes to Annex 18/5 of the MD dated 28 December 2018, the formula structure of the calculation methodology for non-residential EPC. The most important ones are the following:
• Validation of residual heat
• The list of renewable energy technologies that are eligible to improve the label corresponds to the list in European regulations.
• A number of adjustments/improvements to the calculation of energy consumption for sanitary hot water and ventilation, and the energy production by a solar boiler.
Article 8 makes a number of changes to Annex 18/6 of the MD dated 28 December 2018, the inspection and measurement protocol for non-residential EPC. Initially, the changes made to the formula structure were translated into a modified way of inspecting and measuring. In addition, a number of smaller optimisations were carried out.
9. The present draft Ministerial Decree adapts Annex 13 that defines how the draft return temperature should be substantiated. Since since early 2023, this substantiation has been linked to an obligation (low-temperature heating requirement), this methodology is being used more often, and so questions and ambiguities arise more frequently. As a result, a number of clarifications were added.
The inspection protocol and the calculation methodology for EPC residential, small non-residential and common parts are also subject to a change as regards the import and inspection of ventilation systems. To date, inspection and imports have been very brief: it is sufficient to have one supply grid in at least one dry room and one drain grid in at least one wet room to designate a ventilation system in the EPC residential. That is not enough to guarantee the air quality in thoroughly renovated buildings. Therefore, the inspection and import into the EPC has been adapted and expanded.
In addition, a number of minor improvements were added to the inspection protocol and calculation methodology.
A number of adjustments are made to the formula structure of the calculation methodology for non-residential EPC:
• validation of residual heat: The label is no longer determined on the basis of renewable energy share alone, but on the basis of the long-term target indicator. In addition to renewable energy, this indicator also contains residual heat (via a heat grid or recovered locally).
• A new Annex VII (EU) 2018/2001 was recently published, which considers cooling with a sufficiently high performance (SPF > 3.5) to be renewable or not in part. This adjustment was also implemented in the formula structure of the EPC non-residential.
• A number of adjustments/improvements to the calculation of energy consumption for sanitary hot water and ventilation, and the energy production by a solar boiler.
Finally, a number of changes are also made to Annex 18/6, the inspection and measurement protocol for non-residential EPC. Initially, the changes made to the formula structure were translated into a modified way of inspecting and measuring. In addition, a number of smaller optimisations were carried out on the basis of questions and comments received from energy experts during the first half year that the EPC is in place.
10. Numbers or titles of basic texts: There are no basic texts
11. No
12.
13. No
14. No
15. No
16.
TBT aspects: No
SPS aspects: No
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European Commission
Contact point Directive (EU) 2015/1535
email: grow-dir2015-1535-central@ec.europa.eu