Comments on the final ECOFYS report on the evaluation of the Energy Labelling and EcoDesign Directives
Published: 19 December 2014
Policies & Issues: Energy & Climate
In view of the Commission´s further proceedings on the ECOFYS technical report evaluating the Energy Labelling (ELD) and Ecodesign Directives (ED), Orgalime would like to provide its comments and recommendations on areas of the report that we support as well as areas that we urge the Commission to reject.
Orgalime agrees with the ECOFYS report findings and recommendations that:
- It is premature to revise the Ecodesign Directive. Orgalime remains convinced that the identified shortcomings can be addressed through improved implementation of enforceable, measurable requirements and does not require an opening of the framework directive itself.
- The Energy Labelling and Ecodesign Directives should not be merged. A merger of the Ecodesign and Energy Labelling Directives should be contingent on practical and political feasibility, and does not seem conclusive at this stage.
- Uniform market surveillance procedures are important. Market surveillance is a horizontal issue, and rules should not be developed for the specific purpose of ED/ELD alone.
- Transparency on planning of the regulatory process, including a target date for publication, is imperative. Industry needs regulatory predictability.
However, contrary to the ECOFYS report, Orgalime recommends:
- Not to establish a product registration database. A product database is neither feasible nor appropriate from a cost benefit perspective. The database would entail significant legal obligations and administrative burdens for manufacturers, and is no replacement for proper market surveillance and physical checks.
- To ensure that any further product requirements are measurable and enforceable. Resource efficiency requirements in EU product policy should not be widely addressed at this stage through the Ecodesign Directive, as the necessary data, underlying methodologies and standards to ensure measurable and enforceable requirements are lacking.
- To tackle the energy saving potential of product systems on a case-to-case basis. We recommend caution in addressing systems savings through the Ecodesign Directive due to its inherent limitations. Potential system savings should be looked into on a case to case basis, with in-depth studies at the level of individual product groups.
- Not to extend energy labelling to B2B products. Orgalime finds that the Energy Label is not fit for B2B/installer-label purposes, considering that professional users have different information needs than what the Energy Label is designed for or able to give.
Orgalime acknowledges the efforts made by ECOFYS in setting up its final evaluation study and thanks the contractors for tabling an, in our view, widely comprehensive final report. We are especially appreciative of the transparent and inclusive consultation process. Nevertheless, we would like to point out that Orgalime has been misquoted several times in the ECOFYS report, notably on pages 162, 164, 167 and 171.