Orgalime comments on the Commission Proposal for a New Energy Labelling Framework

Orgalime supports an EU wide framework for the energy efficiency labelling of products and also supports improving the existing shortcomings of energy labelling of products. The past and present success of the Energy Labelling Framework is primarily due to its simplicity. We acknowledge the present proposal for a new Energy Labelling Framework, but draw attention to the need for a better design in several critical areas to preserve the success and credibility of the existing Energy Labelling Framework for both consumers and affected European product manufacturers. 

The proposal is motivated to further exploit the potential of energy efficiency for the moderation of energy demand and consequent reduction of energy dependency of the EU. Orgalime is a supporter of the new 2030 Energy and Climate Change Framework and the increased energy efficiency target in particular. We would even like to see a 30% target to be set in place earlier than later. This is because the sector agrees that main energy efficiency savings potentials throughout different market segments remain untapped today. However, the new energy efficiency target can in our view not be realised at the level of standalone appliances but requires a systems approach, such as via the Energy Efficiency or Energy Performance of Buildings Directives. The Energy labelling and ecodesign frameworks appear less suited for tapping these further system potentials. 

Second, improving market surveillance and its effectiveness and securing fair competition is indeed necessary, though it is not an issue specific to energy labelling: a horizontal solution is needed. In particular, a product registration database will in our view, not solve the identified shortcomings of market surveillance, including the lack of human resources and physical checks, nor the estimated loss of 10% of energy savings. Real improvements and better market surveillance results depend primarily on carrying out physical checks to spot and sanction free-riders and cheats. The issue therefore appears much more an issue of pooling (limited) resources and better coordinating Member States enforcement activities to increase efficiencies, save costs and secure energy savings.