Good question..   Since replacing mine with an eheim, i have used some of the eheim clips to keep the top just outside the water, as it had been when in the juwel filter housing.  Although there was somebody on here that said they have had thiers fully submersed for over a year.  I always thought i had read that it was not!  but i am keen to see other replies here.
Squid
		
		
	 
After further investigation on the Juwel Website..   i found this:
Installation of the heater without the JUWEL Filter System
In order to allow the installation of the JUWEL Aquarium Automatic Heater we have
provided suction cups together with the heater.
First of all please attach the suction cups to the heater tube.
Thereafter, fasten the heater to the glass pane of your aquarium and check that it is
safely positioned.
You achieve the best result if you remove some of the water from the aquarium
beforehand and clean that part of the glass pane to which you wish to fasten the
heater. Please ensure that the heater is positioned in such a way that the heater head
is above the water level.
Having installed the heater in your aquarium you may refill it again and connect the
heater to the power supply.
Please observe that the heater may be damaged irreversibly, if it is operating without
or in an insufficient level of water.
Recommendation:
The JUWEL automatic heater warms the water of your aquarium up to 28°C
depending on a nomal room temperature of 18°C. If you keep your aquarium in
rooms below this or your fish need a higher temperature, we recommend to
purchase a second heater.
Safety instructions:
Only connect the heater once the aquarium is filled with water at least to the
minimum water level of the heater.
Never use the heater outside the aquarium.
Operate the heater indoors only.
Hope that helps..
Squid