Clarifying eligibility requirements for commercial and industrial heat pump water heater activity (activity 44)

18 February 2025

We have received enquiries about the eligibility of the following types of upgrades under the Victorian Energy Upgrades (VEU) commercial and industrial heat pump water heater activity (activity 44), which require additional heating to heat water above the temperature the products can achieve (for example, for pasteurisation and sterilisation of other industrial processes):

• Upgrades where installers are only decommissioning some of the electrical capacity, but leaving some heating elements in place and installing a new registered heat pump product (partial decommissioning upgrade).
• Upgrades where installers are decommissioning the whole heater and installing a new registered heat pump product and an additional finishing tank (modification upgrade)

Clarifying eligibility of upgrades under activity 44

The commission’s position is that:

• Partial decommission upgrades (as described above) are not eligible under activity scenarios 44A(i) and (ii). These upgrades may be eligible under activity scenario 44A(iii) where accredited persons and installers are able to satisfy the installation requirements of the product, including those stated in Table 44.3 of the VEU Specifications. For example, the product must be installed as modelled, except that an existing storage tank may be used as storage in place of a modelled component if evidence is provided to the commission as set out in the table.
• Modification upgrades (as described above) are not eligible under any scenarios under activity 44.

Updated activity guide

We have updated the Commercial and Industrial Heat Pump Water Heater Activity Guide to clarify eligibility requirements as stated above.

Compliance and enforcement

The commission may take compliance and enforcement action against accredited persons who create Victorian energy efficiency certificates (VEECs) that do not comply with the VEU program rules, including:

• Requiring surrender of certificates for activities deemed by the commission to be ineligible.
• Suspending, cancelling or not renewing accreditation.
• Imposing conditions on accreditation.

We also note that any actions taken by accredited persons or scheme participants to modify an upgrade after VEECs have been created for the upgrade may also result in compliance and enforcement action by the commission for breaches of the code of conduct. The code regulates the behaviour of accredited persons, including requiring accredited persons and scheme participants to:

• Ensure their work is carried out in a professional and ethical manner.
• Protect the interests of energy consumers and promote confidence in the VEU program.
• Meet high standards of conduct in their dealings with energy consumers and others.
• Comply with the program’s regulatory framework.

Where to get help

If you have any questions about this update, please contact the Victorian Energy Upgrades program support team on (03) 9032 1310 or veu@esc.vic.gov.au.