Comments on the study for the amended ECO DESIGN working plan

As producers of all equipment regulated or currently assessed under the Eco design Directive, Orgalime industries are by far the most affected sector. Orgalime fully supports the cradle to grave approach of the Eco design Directive, which addresses all environmental aspects of Energy related Products throughout their whole life cycle. The upcoming Working Plan should, in our view, be built upon the experience gained with the implementation of the Eco design Directive to date, taken into account the first Working Plan.

The following core principles should, therefore, be taken into account when issuing the Working Plan 2012-2014:

* The Working Plan establishes an indicative list of Energy related product groups and should not pre-empt the results of the study and impact assessment phases.

* Product group classification has to be more sensible, including a proper definition of product groups and a clear distinction between domestic and commercial products.

* Product groups already included in the first Working Plan or the Transitional Period should not be further studied.

* Product groups should be targeted independently from the energy source used.

* A very careful approach should not be adopted when assessing potential energy savings in the area of professional goods, in particular for standard industrial equipment and industrial processes: the latter are not products.

* Any aspect of the environmental performance of a product should be taken in isolation from other environmental aspect.

* A coherent and consistent EU legislation is crucial to secure the competitiveness of EU industries.