1、 Regulatory framework and core directives
Electric water heaters entering the EU market must meet the requirements of the ErP (Energy related Products) directive system. This system consists
of the following core regulations:
The Ecological Design Directive (2009/125/EC) stipulates that products must comply with environmental standards throughout their entire life cycle,
from design and material selection to recycling, prioritizing the use of recyclable materials and limiting the content of harmful substances.
Energy Efficiency Labeling Regulation (EU 2017/1369): It is mandatory to affix energy efficiency labels, specifying label information and size
specifications. All regulated products must be registered in the EPREL database (European Product Registry for Energy Labeling) before they can
be marketed.
Regulation (EU) No 814/2013 on Ecological Design of Water Heaters applies to storage type electric water heaters (with a capacity of 5-500L), instant
electric water heaters, heat pump water heaters, and solar assisted water heaters, regulating minimum energy efficiency thresholds, ecological design
requirements, and information disclosure obligations.
New regulations on standby power consumption (EU) 2023/826: Mandatory implementation from May 9, 2025, significantly tightening power
consumption limits and prohibiting products that do not meet standards from entering the market.
2、 Scope of application
ERP certification for electric water heaters covers all household and commercial electric water heaters planned to enter the EU market, including:
Storage type electric water heater (storage type): rated heating output power ≤ 400kW, water storage capacity ≤ 2000 liters
Instant electric water heater
Heat pump water heater (air/water source)
Solar assisted electric water heater (requires additional certification for collectors)
Mixing system with water storage tank
Attention: The testing standards for storage and instant water heaters are completely different, so it is important to distinguish them clearly before
sending samples.
3、 Classification of energy efficiency levels
Starting from 2021, the European Union has implemented a new version of energy labels and made significant adjustments to energy efficiency levels
Cancel the old level: abolish the "A+++" to "D" level system that consumers find difficult to understand.
New A-G Level: Adopting a clear seven level scale from A (most efficient) to G (least efficient) again. High rated products under the old standards need
to be re evaluated to determine their position under the new scale.
Water storage products: rated based on seasonal performance factor (SEFF) or energy efficiency index (η wh). At present, the mainstream compliance
threshold requires that the energy efficiency index of storage type electric water heaters should generally not exceed 95%, and the annual energy
efficiency ratio is usually required to be ≥ 90%.
Minimum Energy Efficiency Limit (MEPS): For example, for storage type electric water heaters with a capacity of ≤ 300L, the SEFF must not be lower
than 34%.
4、 Core technical performance requirements
4.1 Energy Efficiency and Heat Loss
24-hour heat loss: assess the insulation capacity of the water tank. Based on a capacity of 200L, the 24-hour heat loss needs to be controlled
within ≤ 3.5kWh to reduce standby losses.
Hot water output rate: Evaluate the actual heating efficiency and energy utilization efficiency of the product.
Temperature control accuracy: The restart temperature difference should be controlled within ± 2 ℃ to ensure precise temperature control and
avoid energy waste.
4.2 Standby/Shutdown Power Consumption (Key Point of 2025 New Regulations)
The new regulation (EU) 2023/826, which will be implemented from May 9, 2025, will significantly tighten the power consumption limit
Normal model: Power consumption in shutdown mode ≤ 0.50W
Internet connected intelligent models: standby mode power consumption ≤ 2.0W
This is the project that companies are most prone to "stepping on" recently, as the aging of the internal control circuit design of the product can
easily lead to non-compliance.
4.3 Noise Limitation
Some models require control of operating noise, typically with a sound power level not exceeding 65 dB (A).
4.4 Ecological Design Requirements (Circular Economy)
In addition to energy efficiency, regulations also introduce resource efficiency requirements:
Manufacturers must ensure long-term supply of spare parts
Provide maintenance and repair information
Submit the product disassembly and recycling guide
Product design must be easy to disassemble and recycle, improving material recycling efficiency
5、 Testing standards
The energy efficiency test of electric water heaters is mainly carried out according to the following standards:
EN 50440: "Performance testing methods for household storage electric water heaters" - Core energy efficiency testing standards, assessing energy
efficiency index, 24-hour heat loss, hot water output rate, etc.
EN 50564: Standard for standby power consumption testing.
EN 16147: Performance testing methods for heat pump water heaters.
EN 60335-2-35: Special safety requirements for electric water heaters (electrical safety, mechanical safety, and thermal safety).
6、 Certification Process (Six Step Method)
Electric water heaters belong to products with high complexity, and their registration process strictly follows the "technical document system". Usually,
there is no need to issue a paper certificate, but rather relies on self declaration and official database registration:
Step 1: Data Preparation and Evaluation
Enterprises are required to provide product specifications, circuit diagrams, a list of key components (such as heating tubes and thermostats), and
information on the EU authorized representative (EU representative).
Step 2: Sample testing
Provide 2-3 complete prototypes of the same model to a laboratory with CNAS/CMA/ISO 17025 qualifications, and conduct actual measurements of
heat loss, energy efficiency index, and standby power consumption according to standards such as EN 50440.
Step 3: Prepare technical documents
Integrate test data and product information, prepare technical files that comply with the requirements of the ErP directive, including product descriptions,
test reports, energy efficiency parameter calculation tables, risk assessment reports, etc.
Step 4: EPREL database registration
Non EU manufacturers must authorize "economic operators" within the EU as representatives to upload technical documents, enter product models,
energy efficiency levels, capacities, test data, etc. in the official EPREL system of the EU, and upload label drawings.
Step 5: Generate registration number and energy efficiency label
After the system review is approved, a unique registration number (such as DE-XXXX) must be assigned, which must be printed on the product nameplate
or instruction manual. Simultaneously generate standardized energy efficiency labels.
Step 6: Label and sign DoC
Clearly attach the energy efficiency label to a prominent position on the product body (size ≥ 110mm × 220mm) and outer packaging (size ≥ 36mm × 72mm),
and sign the EU Declaration of Conformity (DoC/EC Declaration of Conformity), declaring that the product
complies with ERP related regulatory requirements.
7、 Specification for Energy Efficiency Label Content
The energy efficiency label must be produced strictly in accordance with the format specified in EU 2017/1369, and it is strictly prohibited to modify
the color, font, or icon ratio on one's own. The label must include:
Energy efficiency level (A-G level)
Annual electricity consumption (kWh/year)
Energy efficiency of hot water output (%)
Supplier name or trademark
Product Model
QR code: Scan and directly link to the detailed information page of the product in EPREL database
Intelligent control icon (if applicable)
Noise level scale (newly added in the 2026 new regulation proposal)
8、 List of required registration documents
Product Specification and User Manual
Circuit diagram and structural diagram
List of key components (heating tubes, temperature controllers, etc.)
Trademark registration certificate (or authorization letter)
EU authorized representative (EU representative) information (mandatory for non EU enterprises)
ERP energy efficiency test report issued by a recognized laboratory
Product nameplate photo and appearance diagram
Manufacturer information, copy of business license
9、 Key precautions and common misconceptions
9.1 Non EU companies must have a European representative
Non EU manufacturers are unable to register directly in the EPREL system and must complete account creation and product registration through
authorized representatives within the EU. Not specifying a European representative will result in the registration process not being completed.
9.2 Multiple models need to be registered separately
If the parameters of the same product series are different (such as capacity and power differences), they need to be registered separately, and one
registration number cannot cover multiple energy efficiency levels.
9.3 Prototype must be consistent with mass production
If the certified prototype undergoes special optimization and the mass-produced product fails to meet the standards, it will trigger market spot
checks and face delisting, fines, or even sales bans.
9.4 Synchronous Display on E-commerce Platforms
When selling through cross-border e-commerce platforms, energy efficiency label information must be displayed synchronously on the product
details page to avoid delisting due to missing information.
9.5 Retention period of technical documents
Manufacturers are required to keep technical documents, test reports, compliance statements, etc. for 10 years, in preparation for spot checks by
EU market regulatory agencies.
9.6 Dynamic regulatory risks
Market regulatory agencies in EU member states will regularly conduct spot checks on online and offline products. Unregistered, mislabeled, or
falsely labeled energy efficiency products will face severe penalties, and customs may also detain non compliant products.
10、 Regulatory Reform Trends in 2026
In 2026, the EU's energy efficiency regulatory framework for water heaters will undergo further upgrades:
Simplifying energy efficiency labels: Continuously promoting the A-G rating system and modernizing label design.
Mandatory third-party qualification assessment: Water heater products will gradually be required to undergo third-party qualification assessment
(rather than just self declaration).
New noise scale: The label will include a noise level scale for consumers to compare.
Climate friendly refrigerant labeling: Heat pump water heaters must be labeled with whether they use climate friendly refrigerants.
Compatibility labeling for smart home appliances: whether the newly added icon labeling complies with the EU Code of Conduct for Smart Home
Appliances.
Energy consumption display function: Future water heaters should be able to measure and display actual energy consumption.
Spare parts and maintenance information: Strengthen ecological design requirements, manufacturers must provide spare parts supply years,
maintenance manuals, and disassembly guides.
