Orgalime comments on the Discussion Paper 'Ecodesign for energy related products integrated into other energy related products'

Orgalime thanks the Commission for the possibility to comment on the Discussion Paper on 'Ecodesign for energy related products integrated into other energy related products' as tabled for the horizontal Ecodesign Consultation Forum meeting on 29 April 2015. 

We fully agree that this is an important issue meriting debate and would welcome the building up of a common understanding for the sake of providing legal certainty for manufacturers and market surveillance authorities, and for securing the credibility of this critical piece of legislation. 

Moreover, we hope that the debate on this Discussion Paper can generate a more comprehensive understanding of the relationship between the various implementing measures, the appropriate design of the next Working Plan and the approach to pursue for the pending reviews of existing implementing measures. 

Against this background, we would like to provide our comments on the Discussion Paper. These are twofold: first, we assess its conclusions based on the current situation created by the approach taken in the past for the existing Ecodesign implementing measures and, second, we compare the Paper to the standing New Legislative Framework (NLF) principles and provide recommendations for the way forward.

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