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eceee comments on the consultation document on the revision of the Energy Labelling Directive 92/75/EC

(06 Feb 08)

eceee is strongly in favour of keeping this valuable instrument. The Labelling Directive has strong merits and a full use of its present potential can soon deliver significant energy and carbon dioxide savings. The main asset of the EU energy label is its mandatory lay-out (especially the A–G scale, the coloured arrows), the display of the label at point of sale, and the simple message it gives.

However, the label scheme has become obsolete for many products and has lost its informative value to the consumer. Therefore it urgently needs an update and a revision to resume its role in transforming the market towards more efficient appliances. Furthermore, a revised energy label scheme is needed to complement minimum efficiency standards (implemented via the Eco-design Directive).

Facing the challenges of realising the EU energy savings potential, the EU Commission and Member States must act now by way of short term and medium term actions. Therefore we ask the Commission to take the following actions:

In the short term (adoption by the Commission before summer 2008):

  • Upgrade the label for cold appliances (based on the results of the eco-design study lot 13).

  • Revise Directive 2003/66/EC by removing the A+ and A++ classes and redefining the A–G scale so that appliances in the A class must have a market share not exceeding 20 %.

  • Introducing a label for televisions (based on the results of the eco-design study lot 5).

  • Introducing a label for water heaters and boilers (based on the results of the eco-design study lot 1 and 2).

In the medium term:

  • Upgrade the label for air conditioners (based on the results of eco-design study lot 10).

  • Automatic review of the labelling to be built in to the revision of the Directive and where appropriate, the labels updated in the light of technological progress and/or market shares in the A class

  • Tighten the tolerances for products in terms of the classification between adjacent bands of the label in any future revision of the Labelling Directive.

  • Extend labelling to additional household appliances and other consumer electronics and to non-electrical appliances.

  • Extend labelling to non-household energy using products which consume considerable energy such as HVAC and refrigeration equipment.

  • Extend labelling to cover products which in themselves do not directly use energy but which have significant impact on energy consumption e.g. windows, vehicle tyres etc.

In addition to these actions, the EU Commission and Member States have to agree on the best way to cover other appliances currently outside the scope of the Labelling Directive. This is likely to require an exploration of how the energy label and the information instruments under the Eco-design Directive can be better co-ordinated. A follow-up study resulting in concrete proposals could start in the beginning of 2009, based on the results of recent Commission labelling studies.. The results could then be used both in the first revisions of the Eco-design implementing measures and revisions of the implementing measures for the energy label.

eceee is also conscious that for the EU Commission to act with the urgency that we believe is warranted on strengthening the Labelling Directive, then staff and resources within the Commission need to be increased to match the important task ahead.

Download the full response (pdf)

The EU Commission's consultation on energy labelling


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