Energy UK response to Smart and Secure Electricity Systems Programme: First Phase Energy Smart Appliances Regulations

Executive Summary

Energy UK strongly supports the outcomes of the Smart and Secure Electricity Systems programme. 

Energy UK members have outlined some key issues to the implementation of the regulations which should be addressed ahead of finalisation, namely:

• Government should cross-reference its regulations with NESO teams to ensure that device requirements are linked to the requirements of entering flexibility markets,  enabling customers to access a greater range of flexibility offers.
• Clarity is needed on Phase 2 device regulations, which are subject to further review and are currently not yet published.
• As air-to-air source heat pumps are in scope of the Boiler Upgrade Scheme, the impact on the current uptake assumptions therefore needs to be monitored.
• The guidance pack should focus on outlining how to safely operate and optimise the asset, as the manufacturer will not be best placed to provide up-to-date information on the right tariffs available.
• Energy UK would suggest an outcomes-based requirement to meet 2% device metering accuracy, but to not require the full Measuring Instrument Regulations (MIR) compliance to ensure disproportionate product costs are not passed onto the consumer. 
• The Government needs to publish their response on the MIR requirement for a physical display as soon as possible to ensure manufacturers can prepare in a cost-effective way for the introduction of new regulations.  
• Government should be mindful of manufacturing timeframes to ensure the realistic implementation of smart appliances.
• Key learnings from the introduction of smart charging regulations (including resourcing of OPSS, and clarity of regulations ahead of implementation) should be followed to ensure that industry can implement the changes swiftly to help support the Government’s targets.