I am sorry but I believe the whole sorry saga of the WER and the BFRC stinks. It is a relatively good idea in theory but the formula has been hijacked to enable some old low E glass to be seen to be good enough to meet tighter regs.
Can anyone in the industry tell me how an 'average' orientation can provide 218.6 Kwhrs of solar gain per square metre? absolute boloney , yet the whole system relies on that simple number!!

Part L .... the CLG appear to be a little late coming out of consultation , are they not supposed to have come to some conclusion by now? Maybe they are begining to see a issue with the scheme.

I have been trying to address the points raised so brilliantly by Steve Massy myself for the best part of the past year,
I am have both bs en1279 and CMS 1016 and am a registered energykare manufacturer,
i beleive i have done all i can to prepare my company to handle the changes which are being forced upon us with very little consultation (at least at small to medium enterprise level)
I only manufacture and supply to sme joinery shops as i find the upvc window installation companies local to myself are generally not worth the hassle of trading with.
The new energy rating scheme is going to totally kill the SME side of the joinery market,
as i understand it every different combination of frame they manufacture and different type of wood they use needs to be tested, e.g mahogony sliding sash window, then an oak sash window,then every other form of wood etc all made exactly the same way in the same conditions using the same tools but each style needs testing and more importantly paying for.
the costs involved in testing every option for energy ratings are simply ridiculous.
so all my work and money spent in achieving the BS EN etc is for nothing.
I understand the intentions of reducing the carbon footprint but surely by reducing U values to a lower level is going to be far less restricting than making our customers send off for vast numbers of calcs for energy ratings on their own products.
a lower U value can be applied to alluminium, timber and Upvc window manufactures and all IGU manufacturers are in a postion to trade freely, as to my mind the new system will see a total restriction of trade, you either get in with a major frame manufacturer now or (despite exchangeabillity as there is so much you will need to do to win that business) you will not get the chance to supply them.
I also struggle with the idea of manufacturing extremely insulated sealed units and then the window installers are forced to put trickle vents (for air flow purposes) in the frame near the these super IGUS which creates a draught thus meaning the home owner will be turning up their heating any way

I have spoken to my BS EN1279 consultant who does my testing for me and another sme Unit manufacturer and we all share the view that we are pretty much finished when the energy ratings are implemented and will have to evolve our businesses to do other things,

Any one got a polisher or bevelling machine for sale???????? as i wont be able to do much more than that come oct 2010

Exchangeability doesn't hurt as long as 'similar' products have been through the same rigorous testing as the specified product.

Dear all

I read with interest your emails regarding Doc L, WERs and the issue of replacement of thermally improved products . Being a large manufacturer of sealed units , we have our own thoughts on the regulation changes.

We agree that the future will mean an improvement to the thermal efficiency of windows including their sealed units and that gas filling and warm edge spacer systems together with improved emissivity glass, will have to be used to achieve the proposed new efficiency gains.

We went along to the GGF seminar at Wembley last year and although we agree that the BFRC WER scheme will help move thermal efficiency measures along, having the WER route as the only method of demonstrating compliance worried us. The current whole of window U-Value of 2.0 or less could be lowered to reflect the gains desired by the government and this would help all parties in the short term, giving the BFRC and the market more time to get up to speed.

There are other issues that concern us too and we are assured that the BFRC/GGF are currently looking into them. The main concern being that once a window company has applied for and been issued with a WER label for their windows, any improvement in these windows becomes stifled by the issue of cost in replacing current labels with new labels from BFRC. The label cost together with any simulation cost, IA cost and additional factors associated with implementing a change to an accredited system, add up to a barrier to progress.

e.g. several of our customers have achieved WER labels for A – C bands with more than one window type. Thus, they may have say 3 different windows which means 9 different labels. These cost £200 or so from the BFRC + additional costs – simulations, printing, etc. Then, a new development in glass or warm edge spacer system becomes available allowing more thermally efficient windows to be manufactured. The cost of replacing existing labels for a company with 3 windows in 3 bands can be up to £2-3K each time a new development comes along. For our top 30 customers or so the combined cost is approaching £100k for a new development to be adopted by fabricators and installers. This could happen several times a year. Indeed, we have been approached by 3 flat glass manufacturers and 2 warm edge spacer bar manufacturers within the last two months to use their products. For our customers to be WER accredited on all the products (retaining some control of what we produce) would mean an investment of up to £500k for all the label combinations to be simulated and issued by BFRC. We have asked all parties if they are willing to support the label change and it is clear that this does not figure in their budgets.

None of the relevant stakeholders – component suppliers, profile suppliers, glass suppliers, window companies or the BFRC are willing to pay these fees. Thus the advancement of windows is stifled as once an A has been achieved, the window company sees no value in spending further cash achieving the same A, even if the index may have improved by 5 points or so. This needs sorting out as soon as possible.

We may find ourselves in a vulnerable position where a simulated product manufacturer be it glass, sealant type or warm edge system, may increase prices knowing that the certified labels are expensive and administratively a hassle for the label owner to change.

For it to be suggested that IGU manufacturers are not a main party to this process when its our products that are the most affected by these changes is an insult to all of us who have invested literally hundreds of thousands of pounds to enable all profiles to gain WER bands. The first thing that profile companies and fabricators tell their customers is that they will need better IGUs. They bear no responsibilty for this and their profiles are largely unchanged. IGU manufacturers need to be fully considered and treated as equal partners in this process.

Another issue that we have lobbied for is the insistence that the BFRC Independent Agencies (IAs) specifically ask the WER applicant, for an EN1279 part 3 pass certificate where Argon is used as part of the window combination to achieve a relevant WER band. Previously and probably still occurring is that IAs were only instructed to ask for EN1279 part 5, which I am sure you will know is a self certified declaration from a sealed unit company. Not an independent UKAS accredited laboratory result. Need I say more?

This could mean that many of the WER labels where Argon is used to achieve them are actually a band below. We have asked the GGF to instruct Fensa to gas test units that have a WER label and need gas to achieve it. We have a gas testing machine that we have to have by law to fulfil our EN1279 part 6 testing requirements. These are readily available and although they are expensive, they will ensure that the consumer is getting what they paid for and just as important, the whole point of WER and reducing carbon emissions at great cost to all parties, is actually achieved.

Currently we know that many consumers are paying more for WER rated products believing that they are saving energy and purchasing in a way that will help their environmental aspirations, when in actual fact they are getting neither.

I would be interested in hearing your comments.

Iam puzzled by the fact WER`s appear to have been accepted into the revised document L when i cannot find any published rules that apply to the scheme?
It also seems to me that any new products will cost a fortune to launch if they all have to be re-simulated?