Amendment 17 to Canada’s Energy Efficiency Regulations: Update
As members may recall, on June 11, 2022, HRAI and AHRI submitted its final round of joint comments (attached below) on Amendment 17 to Canada’s Energy Efficiency Regulations.
In Canada Gazette, Part I, NRCan proposed to make the optional -15oC (5oF) test point in the U.S. DOE Appendix M1 test procedure mandatory in Canadian regulations to reflect cold climate conditions in Canada.
Following recent discussions with senior officials at NRCan, HRAI can report to members that NRCan is considering deferring mandatory cold climate testing for single-phase central air conditioners and central heat pumps to a later date.
HRAI and AHRI strongly urged NRCan to limit low temperature testing to variable speed products only with a January 1, 2025 enforcement date and that manufacturers be permitted to begin shipping M1-tested product into Canada effective immediately. While NRCan has not committed to a date, the associations expressed appreciation for NRCan’s willingness to explore solutions to this longstanding concern.
Members can consult the comments, through this link, for a full breakdown of industry’s rationale for deferring mandatory cold climate testing. The link also contains HRAI-AHRI’s previous set of comments on Amendment 17.
The main issue on the table right now is industry’s proposal that manufacturers be permitted to begin shipping M1-tested product as soon as possible. Until Amendment 17 comes into force, members cannot ship M1 product into Canada. However, given supply chain concerns and the fact that members have already completed much of their testing to M1, industry is seeking an immediate resolution.
While NRCan said that it is exploring immediate entry into force upon publication in Canada Gazette, Part II (as opposed to a typical 6 month coming into force period) to eliminate or to minimize U.S.-Canada regulatory misalignment, NRCan informed us that the only way to get M1 product moving into Canada right now is to find a pathway under the current regulatory framework, i.e., Amendment 16.
In other words, how do we translate the US DOE Appendix M1 test procedure to Amendment 16? Over the coming weeks, HRAI-AHRI will meet with NRCan officials again to discuss this urgent dilemma and hopefully have an update for members.
If you have any questions or concerns, contact Stephen Chartrand at 1-800-267-2231 ext. 276 or email schartrand@hrai.ca.
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