Agreement reached: Focus needed now on practical & enforceable implementation
The European Institutions have reached a political agreement on a new Energy Labelling Framework Regulation. The new Framework legislation is set to enter force later this year and will bring major changes to the existing and future energy labels, currently applied to many home appliances. We foresee that new labels for the first home appliance products under the new legislation - Washing Machines, Dishwashers and Refrigerators – will be displayed in shops around 2020.
Energy labelling | Photo credit: Fotolia
Says CECED Director-General, Paolo Falcioni: “Now that the agreement has been reached between the EU institutions, attention must turn to ensuring that practical implementation and enforcement of the label, on the ground, is successful. Appliances continue to have the potential to make a strong contribution to the EU’s energy efficiency target. Consumers can be further empowered to make a contribution: that also means that consumers need to understand what has changed and what the energy label is actually indicating”.
Mr Falcioni continues: “Communication about the revised energy label is, in fact, the key challenge now. Each rescaling creates the potential for confusion among consumers and market surveillance authorities. Future communication campaigns run by the EU and Member States must make clear that it is the label that has been rescaled and not the product that has become less efficient.”
CECED’s views on the agreement reached:
1. Recognition of need for a product-by-product approach and a stable transition
Throughout the revision process, CECED has maintained that any changes must be based on a thorough product-by-product impact assessment analysing the potential future technological development to ensure the new label fulfils its aims. CECED welcomes that policymakers have recognised this by introducing a staggered timescale that appreciates the different market and technical conditions between product groups and by also outlining a clear distinction between the conditions to be set for the first rescaling and future rescaling of the label. The expected validity of the label of at least 10 years, if implemented effectively, can also provide clarity for consumers and fosters investment in energy efficiency innovations to reward consumer choice.
2.Transition phase concern
Delivering two labels, old and new, for each product during a transition phase is challenging for practical implementation. It will require disproportionate efforts in retail shops to relabel, it risks giving rise to confusion for market surveillance and shop-owners and adds significant burden to the manufacturer where double testing may be needed. In addition, setting constraints on when and how products, which were legally placed on the market before and during the four-month “two-label transition period,” can be sold, places a further disproportionate burden on both suppliers and dealers.
3. Product database
CECED remains concerned on the introduction of the product database. Even if all numbers that are in the database appeared to be correct, this would not mean that all the products sold on the EU market were compliant. Some products may have not even been entered in the database deliberately. How this will be effectively controlled remains an open question to date. In addition to product testing to assess compliance, Member States should also verify that products sold in shops are indeed also registered in the database.
Requiring manufacturers to upload technical documentation to a central database is also particularly sensitive. Compiling all European energy efficiency and other product intelligence in one central place makes European industry highly vulnerable and exposed to the risk of losing confidential business data, technological know-how and excellence to the detriment of Intellectual Property Rights through potential hacking and unfair practices by unscrupulous players. Responsible market operators need to be supported and a level playing field ensured.
CECED reiterates that actual laboratory testing of appliances is the only way of ensuring product compliance with energy label requirements. Pan-European market surveillance needs to be supported.
Mr Falcioni concludes: “The EU Energy Label has successfully supported the drive for greater energy efficiency in home appliances. As manufacturers continue to invest in energy efficiency, consumers should be clearly informed of the benefits of new appliances and the label enables consumers to make informed purchases. The revised energy label must continue to incentivise energy efficiency innovation, be clear to consumers and be implementable and enforceable.”
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