Their original policy has been amended to balance the need for assured product performance whilst keeping additional burdens on business to a minimum. Their approach will rely on existing legislation and maintain standards as far as possible. By adopting this option, and not requiring new testing and certification for all products, will avoid additional costs to manufacturers estimated to be in the region of £24m. DECC will require (in the Green Deal Code of Practice) that all products installed through the Green Deal must meet existing legal obligations, for example, those set out in Building Regulations. In addition, products covered by EU legislation on CE marking must have the CE mark.
DECC will require system testing (that the components work together and on the wall type in question) and third party certification from a UKAS accredited (or equivalent) facility for measures which are made up of a series of components such as external wall insulation. The systems testing requirements will cover External Wall Insulation Systems, Internal Wall Insulation Systems and Cavity Wall Systems. Annex D of the Code of Practice makes clearer who can certify products and in which circumstances this is needed. Products will also be “spot checked” for compliance with the Code by the Green Deal Oversight Body. The provisions in Annex B relating to the guarding against certain risks associated with installations have been strengthened for example, in relation to ventilation requirements. In addition, we have included a new requirement in Annex B of the Code of Practice to require that Green Deal Providers confirm with their suppliers that the products to be installed in a Green Deal property are a type capable of – or designed to - deliver the level of fuel bill savings estimated for the “measure” during the Green deal Assessment. Whilst DECC cannot guarantee savings, this will help to increase confidence for consumers and promote the installation of fit for purpose products. In light of this change to Annex B, it has been decided to remove the formal requirement for manufacturers to confirm compliance with the Code of Practice and to register their products with the Oversight Body. This is because, DECC believe that compliance with the Code of Practice is sufficient for product assurance purposes, and will operate alongside other customer protections in the framework including the PAS 2030 and the warranties framework. There was also a significant risk that such a proposal would be contrary to European Union (EU) laws which sets the rules for what testing and certification requirements can be imposed before a product is traded on the EU market, and would add an unnecessary cost to entering the Green Deal market.
From DECC Responses to Consultation 11th June 2012