Last week BEAMA submitted its response to the Energy Smart Appliances Regulations Consultation, part of the Smart and Secure Electricity Systems work being undertaken by DESNZ.  The sheer volume of feedback received from our members tells us these regulations cannot be implemented in their current form

We urge the Government to take on board lessons learned from when they introduced similar regulations just for EV charge points in 2022, otherwise they risk facing the same challenges to implementation they found but for all energy smart appliances in scope like electric heating appliances and battery energy storage systems that are essential to the success of Clean Power 2030.

 Paul Lee Pschierer-Barnfather, EV Charging Solutions Expert , Zaptec says” the SSES regulations are an important milestone on the road to decarbonising the UK economy. It’s essential we get this right, and I’m grateful to BEAMA for their efforts to help equipment manufacturers deliver on this vision”

BEAMA highlight a number of policy pit falls that must be addressed to ensure these regulations are a success:  

• Having two sets of regulations in 18 months for EV Smart Charge Point manufacturers creates an undue burden. Government must align the regulations so all EV SCP requirements come into force at the same time.  This will create less confusion for the customers of these manufacturers.

• Manufacturers across heat, EV, and storage need clear requirements and realistic timelines. With product development cycles of 24–32 months, the proposed 18-month compliance window is not deliverable and risks higher costs, reduced innovation, and delayed investment. 

• Ongoing amendments required and areas of uncertainty means the regulations should begin with a two-year voluntary period before compliance is mandated. 

• We urge the Government to take the opportunity to make randomised delay work; ensure it acknowledges consumer behaviour is random; and ensure randomised delay is only required where there is a risk of herding.  Otherwise, the Government risks putting consumer comfort and confidence in ESAs at risk, as this is not something consumers are used to.
• For heat appliance manufacturers can Government expect heating to randomly switch off? Randomised delay is not feasible for smart heating devices as they are by nature always on, and in extreme temperature variations puts consumer comfort at risk.

Stuart Callow, New Technologies Standards Expert, Worcester, Bosch Group  said” In order to deliver products that meet consumers’ needs and are proven, reliable and long-lasting, manufacturers need time to develop, test and bring these new solutions to market.  The requirements proposed under Energy Smart Appliance policy are considerable, and still unconfirmed, which means development work cannot start.  The likely circa 18-month window between Government’s confirmed requirements and the deadline for compliance is simply not enough, given most manufacturers require 2 – 3 years for new product developments.  The risk is that existing products may have to be removed from the market before new compliant versions are available because of this compressed timeline.  This will only serve to restrict consumers’ choice and slow-down the transition to electrification.  We hope Government listen to the significant concerns raised across the varied sectors BEAMA represent and choose to engage constructively on a pragmatic, more secure, way forward.”

 Matt Adams Head of Electrical Transport Systems for BEAMA said “These regulations have the potential to play a crucial role in ensuring uptake of Smart Energy Appliances, protecting our grid and supporting consumers through the transition to electrification and lowering energy bills. It’s vital then that the regulations are workable. BEAMA calls for industry members to be vocal and join us in support of the principles and push for changes to the implementation to ensure what is delivered creates a positive change for industry, the grid and consumers.  “

BEAMA continue to offer our support to Government and work alongside them to ensure SSES is practical, deliverable, and provide the real-world insight that will make SSES a success.