Response to Comments on Proposal to Regulate Factory-Built Fenestration Products
May 2001
Response to Comments on Proposal to Regulate Factory-Built Fenestration Products
In October 2000, Natural Resources Canada's (NRCan's) Office of Energy Efficiency (OEE) issued a proposal to amend the Regulations of Canada's Energy Efficiency Act to require testing, verification and labelling of factory-built fenestration products that are traded interprovincially or imported into Canada.
The OEE circulated the proposal to more than 300 stakeholders, and a number of industry and related associations distributed it to their members. A presentation on the proposal was given at the CWDMA meeting in November 2000. It was also posted on the OEE's Energy Efficiency Regulations Web site and sent to various trade media. The closing date for comments was January 15, 2001.
The OEE received comments from manufacturers of windows, skylights and door systems; trade associations; test and simulation laboratories; federal departments and provincial governments; and standards-writing organizations. We would like to thank those who took the time to respond, and we encourage respondents to continue their dialogue with NRCan.
The nearly 50 written comments that were received revealed mixed reaction to the initiative. Although there was support for the proposal, many responses raised the issues of limits of the jurisdiction of the regulation, the energy performance descriptor, enforcement, the verification process and harmonization with the United States.
In response to these comments, NRCan is considering the following:
- delaying the implementation of minimum energy efficiency levels;
- requiring labelling for energy efficiency values only;
- modifying the requirement for independent third-party verification of energy efficiency values; and
- introducing a Canadian ENERGY STAR® High Efficiency Program for windows, skylights and sliding glass doors.
Minimum Efficiency Levels
A number of respondents raised the issue of applying the proposed Regulation. They noted that Canada's Energy Efficiency Act pertains to products that are traded across borders and that it does not apply to trade within provinces or territories. As NRCan is committed to finding a solution that treats all manufacturers equitably, it is considering delaying the implementation of minimum efficiency levels. NRCan will also seek to influence current provincial product regulations and building codes in order to ensure uniform application of harmonized requirements in all markets.
Energy Descriptor
Although NRCan is still considering respondents' comments on the Energy Rating (ER), it is NRCan's position that the ER system is the best overall choice for reporting the energy performance of residential windows and sliding glass doors, and that a case for using an alternative has not yet been made. NRCan also supports including a proposed 20-percent Solar Heat Gain Coefficient (SHGC) reduction factor in the ER equation to account for internal and external shading. NRCan understands that this change has been accepted by the CSA A440.2 technical subcommittee and that the Energy Level (EL) table found in the A440.2 users' guide, which groups ER numbers into categories, will be updated to reflect this change.
Mandatory Labelling
NRCan supports consistent and readily understandable labelling that clearly indicates the energy efficiency of windows and other fenestration products. Therefore, NRCan proposes that all products be labelled with a mandatory regulated EnerGuide label with the EL as the main energy descriptor. There will also be an option to display other thermal performance or related values, such as total product U-value and SHGC. It is felt that using the EL will reduce the potential number of labels a manufacturer would need, yet still give the end-user a reasonable idea of the product's energy performance. There will also be marketing efforts to promote any new labelling program and a published database of regulated labelled products. A draft version of the proposed label is attached for your review.
ENERGY STAR High Efficiency Program
NRCan is now in the final stages of signing an agreement to become the administrator of the ENERGY STAR High Efficiency Program in Canada. Over the next several months, NRCan will explore the possibility of having an ENERGY STAR High Efficiency Program for fenestration products.
Harmonization
NRCan continues to support harmonization efforts between the U.S. and Canada of the CSA and NFRC thermal performance standards. NRCan understands that the timetable for implementing the harmonized standard calls for it to be first published in the U.S. and Canada by spring 2003. NRCan will continue to monitor the progress of the harmonization efforts and will consider modifying the labelling implementation date if it appears that a harmonized standard will become a reality within a reasonable time frame. This will give manufacturers the opportunity to implement the mandatory labelling program using the new harmonized standard.
Verification
Canada currently requires that regulated products bear the mark of an energy verification program administered by a certification organization accredited by the Standards Council of Canada. Because of the increasing integration of Canada-U.S. trade in fenestration products, NRCan is considering recognizing the U.S. NFRC certification as a verification equivalent in Canada.
Next Steps
NRCan is planning to issue a revised proposal in early fall 2001 and will continue to review the issues with respect to the ER system and research the form and manner of product labelling. NRCan will also have more information about including fenestration products in the ENERGY STAR High Efficiency Program at that time.
If you would like to comment on the information contained in this update or on any aspect of the proposal, please submit your comments in writing by August 20, 2001, to the address below. A copy of the proposal that was circulated in October 2000 is attached for your reference.
Steve Hopwood
EnerGuide Program Officer
Office of Energy Efficiency
Natural Resources Canada
580 Booth Street, 18th Floor
Ottawa, Ontario K1A 0E4
Telephone: (613) 947-0373
E-mail: shopwood{AT}nrcan.gc.ca
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