Comments on draft ECOFYS interim report on the evaluation of the Energy Labelling and Eco-design Directives

Orgalime thanks the contractor for the transparent and inclusive consultation process on its evaluation study of the Energy Labelling Directive and specific aspects of the Ecodesign Directive and for tabling an in our view a widely comprehensive draft interim report. 

Orgalime particularly supports the following findings and recommendations of the draft report: 

• The confirmation of the earlier 2012 CSES study findings that an expansion of the Ecodesign or Energy Labelling to Non-ErP remains premature at this stage 
• The need for better transparency of the planning of the regulatory process and evidence base 
• The finding that a merger of Ecodesign and Energy Labelling Directives does not seem conclusive at this stage 
• The confirmation that market surveillance and enforcement require improvement 
• The relevance of exploiting systems savings in the future while acknowledging the inherent limitations of the Ecodesign Directive to deal with system savings 
• The relevance of a well-coordinated overall policy framework and coherence of EU legislation for the success of the 2 Directives

We yet remain to be convinced or require more information for a final assessment regarding the following findings/recommendations of the draft report: 

• The general statement that the Ecodesign Directive would be capable of generating substantial savings in a cost effective manner considering the still early stage of implementation and remaining uncertainty about the realisation of savings potentials in practice 
• The recommendation to use a single PEF factor

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