Fabian Demicoli

Eco design and energy labelling of Water Heaters

 MSA has informed the GRTU that discussions on Eco design requirements (minimum energy requirements) and a mandatory Energy label are in advanced stage.  These shall apply to most water heaters and storage water heaters including:


Oil or Gas or Electric Instantaneous;

Oil or Gas or Electric or  Solar Storage or combinations there of;

Heat pump systems;

Storage tanks for hot water;

Solar preheat systems.

The following are exempt:

Water heaters specifically design for bio fuels;

Water heaters using sold fuels;

Large Combustion Plants;

Components and sub-assemblies;

Room heating equipment.

The draft regulation on Eco design equipments may be found at http://www.msa.org.mt/rad/ecodesign/EUP_discussed/boilers%20and%20heaters/water%20heaters%20ecodesign%20regulation%2024%20June.pdf

The draft regulation on energy labeling (including the future energy label) may be found at: http://www.msa.org.mt/rad/ecodesign/EUP_discussed/boilers%20and%20heaters/water%20heaters%20working%20document%20energy%20labelling%2023%20June.pdf

Information on the tests required may be found at: http://www.msa.org.mt/rad/ecodesign/EUP_discussed/boilers%20and%20heaters/Draft%20WH%20Communication%2019%20July.pdf

These requirements are mandatory for newly manufactured and imported water heaters. 

Your attention is drawn to the following points:

Heaters which use electrical energy are discriminated against since the energy efficiency calculations are based on primary energy not site energy.  A European harmonized conversion factor of 2.5 shall be assumed to take into account the conversion of fuel oil or gas to electricity.

The energy efficiency classification (denoted by a letter between A+++ and G) is assigned on the primary energy use (i.e. energy contained in the raw fuel – with out any transformation) and not site energy (i.e. energy consumed at the building).   

Water heaters that use smart control (i.e. adapt water heater performance automatically to user patterns) will be favoured by a factor of about 7%.

Energy efficiency is determined by tests based on performance oriented load profiles which are based on tapping cycles.  The load profile that the product is to follow is the maximum load profile possible for that product.

The tests assume a thermostat setting of 55C.

The energy classification as denoted by letters A+++ to G is applicable to the load profile that the manufacturer has chosen and it is up to the consumer to determine the size of the heater and the load profile that best suits his/her needs.

Hence it is expected that:

A very efficient electric heater that use the Joules effect to heat water should not have an energy label higher than A or C depending on the load profile;

A very efficient gas heater energy would have a  label that varies from A++ to A+ depending on the load profile;

A heat pump water heater with a COP of around 3 could have an energy label of A++ or A+++ depending on the load profile;

A solar heater with a very effective solar collector and a very well insulated storage tank could have an energy label of A+++.

For more information kindly contact Ing. Joseph Micallef- Engineer, Regulatory Affairs Directorate at Malta Standards Authority. T: 23952221 E: ">blocked::mailto:

What we can do for you










The Malta Chamber of SMEs represents over 7,000 members from over 90 different sectors which in their majority are either small or medium sized companies, and such issues like the one we're experiencing right now, it's important to be united. Malta Chamber of SMEs offers a number of different services tailored to its members' individual requirements' and necessities. These range from general services offered to all members to more individual & bespoke services catered for specific requirements.

A membership with Malta Chamber of SMEs will guarantee that you are constantly updated and informed with different opportunities which will directly benefit your business and help you grow. It also entails you to a number of services which in their majority are free of charge and offered exclusively to its members (in their majority all free of charge).