eceee's views

eceee: Important to keep IEE type of funding for efficiency programmes

annebe — Wed, 21 Mar 2012 14:55:00 +0100

Following the Multi-annual Financial Framework 2014-2020, the European Commission has abandoned the Intelligent Energy Europe programme (IEE). In the light of this, eceee believes it is of utmost importance that the programmatic approach represented by the IEE programme receives a separate and clear budget line in the new funding regime.

This is the message of a letter from eceee to Mr Robert-Jan Smits, Director General of the European Commission's DG Research and Innovation. "A separate and clear budget line will help ensure that the approach developed in the IEE programmes is maintained and receives the attention that it deserves also in the future", eceee writes. "It is further important that the funding is significantly enhanced in order to help EU address the gap in energy efficiency implementation in relation to the 2020 target." The IEE programme is the only centrally-managed programme devoted to energy efficiency and rational use of energy sources from a non-investment, non-technological but consumer-behaviour and policy-implementation point of view. Several independent reports, released before and after this decision, affirm the conclusion that "the programme is relevant and useful as it replies to the evolving needs, problems and barriers related to sustainable energy issues that Europe is facing." The IEE programme has contributed to increasing energy efficiency and the development of renewable energy by supporting innovative solutions, pilot and demonstration projects, and networking and exchange of experiences among local, regional and national stakeholders at international level. It also promotes behavioural change, effective market development, education to consumers, technical assistance and creation of new jobs. Documenting the usefulness of IEE II, the assessor stated: "the programme is one of a kind, adding high value to have a successor". In eceee's experience the programme has been very useful to support Europe-wide implementation of its energy efficiency policies, which have been designed and approved in order to ensure the EU’s energy-, economy- and environment-related goals. The IEE programme and its approach has thus been instrumental in developing EU policies for energy efficiency and renewable energy, as well as the understanding of how these policies can be effectively implemented. For more information contact: Nils Borg Executive Director nils@eceee.org Mobile: +46 705 853174 See IEE letter

Europe must provide leadership in energy efficiency

admin — Wed, 22 Sep 2010 14:37:13 +0200

Europe must provide leadership in energy efficiency. This is the message of eceee, Europe’s largest membership-based NGO solely focused on energy efficiency, when it today presented its views on the forthcoming EU Energy Efficiency Action Plan.

“The new Action Plan needs to reflect an ‘energy efficiency first’ approach in tackling EU’s energy and climate challenges” said Mr. Nils Borg, Executive Director of eceee, the European Council for an Energy Efficient Economy.

“The Energy Efficiency Action Plan must be ambitious, bold and comprehensive. It is a very important tool to demonstrate EU’s leadership”, Mr Borg said.

eceee points out a number of key issues that should be included in the forthcoming Energy Efficiency Action Plan.

Overall commitment and priority to energy efficiency must be on the top of the agenda, providing adequate resources and giving energy efficiency the place it deserves in the wider energy and climate policy portfolio.

But efficiency is not enough, eceee says. There is a case for shifting our emphasis in energy specifications to progressive efficiency and sufficiency, aiming at achieving absolute reductions in energy use.

The Action Plan also needs to look at how the implementation of and compliance with existing directives initiatives can be improved. “Existing buildings is a key area here”, Mr Borg said. “Buildings represent 40% of the final energy use, but only 1% of the building stock is turned over every year. The challenge is formidable.”

Finally, eceee also points out the need to ensuring that adequate resources are available for better impact: The European Union needs to directly fund as well as act to unlock funding that is available in EU financial institutions and in Member States.

Download the whole position paper here. (pdf)

“Energy efficiency first approach” is needed in the Energy Strategy for Europe 2011–2020

admin — Fri, 02 Jul 2010 12:49:11 +0200

eceee welcomes the flagship initiative to promote a “Resource-efficient Europe” outlined in consultation document for en energy strategy for Europe. However, real innovation for a sustainable energy policy must be built on an energy efficiency first foundation. Without this, achieving a future low-carbon energy demand is likely to prove costly with negative effects for poor households and EU competitiveness alike.

eceee’s response submitted to the European Commission points out several shortcomings in the consultation document, and in particular find that it lacks a comprehensive understanding for the role energy efficiency can play, even if the need for reductions in primary energy consumption is underlined.

Among other things, eceee points out that:

eceee welcomes the statement: “The EU has to realize all the 20 % potential for cuts in primary energy consumption by 2020.” Such verbs give eceee hopes that the Commission will be proposing mandatory targets if the potential “has” to be realized. And it has to.
On making progress towards a low-carbon energy system, eceee agrees it will require the use of various instruments but it also requires a different mindset. The paper mentions innovation many times but eceee does not see this strategy as being innovative. The emphasis is still too focussed on energy supply (including renewables).
Real innovation would reflect that a sustainable energy policy is built on an energy efficiency first foundation without which meeting future CO2 free energy demand is likely to prove costly with significant impacts for the most vulnerable EU households and severe implications for our international competitiveness. While the strategy implies that, it is not reflected in the programmes or the resources made available. eceee wants Europe to provide leadership in technological innovation but we do not see a well-rounded and balanced approach to innovation. Europe could be a world leader if it tackled energy demand more effectively.
The document refers to the success of appliance labelling but says nothing about Eco-design. eceee hopes that the Commission will re-affirm its commitment to this important programme and that it will provide adequate resources to ensure effective implementation.
The document discusses the results from the 2007 Energy Action Plan and we must note that the SET-Plan has no reference to energy efficiency at all. If energy efficiency is to play such a key role, this is not encouraging.
The same must be said for the Economic Recovery Plan and we can only note that anything there is on energy efficiency is largely due to the efforts of decided Members of the European Parliament.
In discussing the remaining gaps and shortcomings, eceee agrees that a number of the National Energy Efficiency Action Plans were disappointing but we fail to see in this document how the Commission intends to address that.
eceee agrees that implementation of energy legislation has largely been poor and eceee particularly worries about the Energy Performance of Buildings Directive.
eceee welcomes the emphasis on ICT technologies, particularly smart meters. eceee believes they can have an important impact, but also wants to caution against a belief that this technology will bring about increased energy efficiency without an integrated approach where synergies are created with other energy efficiency measures.
Concerning transport, eceee would like to see more emphasis on better fleet management, even through ICT, and more emphasis on modal shifts towards less energy-intensive transport systems.
eceee would like more information on how the Commission will monitor and ensure effective implementation of EU legislation. Implementation also has to be stressed in the issues for consideration in the short-term.
eceee welcomes that the Commission is committed to work with Member States to ensure maximum compliance but eceee would like the emphasis on maximum impact.

Download full response as pdf.

eceee comments on a voluntary agreement for imaging equipment

admin — Thu, 25 Mar 2010 16:45:52 +0100

The proposal of 19 February has some improvements compared to the first proposal, but is still not sufficient to satisfy the requirements for a solid and reliable voluntary agreement as a replacement for regulation.

We have the following specific comments:

The market coverage is acceptable.
We believe that at least 90% of the products should meet EnergyStar criteria by 1 January 2012, 80% is not ambitious enough. This is particularly important since some exemptions are also proposed.
The first tier proposed by 1 January 2011 could be removed. It is better to go for the second tier directly in order to make the voluntary agreement less complicated.
We don’t understand why there should be exemptions for recycling of toners from products sold in small numbers. As we understand it, toner recycling is not connected to individual models.
Why would a voluntary agreement need special promotion activities? A voluntary agreement is a replacement for regulation and not a consumer information activity.

See eceee's full comments (pdf)
See eceee's eco-design products pages

Comments on proposed eco-design regulation for fans 125W-500kW

admin — Thu, 25 Mar 2010 15:47:23 +0100

eceee welcomes the proposal for eco-design requirements for fans. However, we cannot support the proposed requirements, which are too weak to achieve the potential savings of 2 TWh linked to this measure.

We welcome that fans integrated into other products are covered by the proposal. The generally low ambition in setting requirements means, however, that the proposed regulation will fail to maximise energy savings in a cost efficient manner. Furthermore, the weak requirements are also likely to penalise the most innovative and quality-oriented part of the European fan industry, and instead stimulate imports of low-cost inefficient products. This regulation should carefully avoid repeating the mistake of the motor requirements, which were far too lax.

In general, we believe that there are too many categories of fans in the proposal, but realise that this cannot be fixed now. It should be considered when this measure is up for review.
eceee proposes that:

By 2012, the requirements should be those proposed for 2015.
By 2015, the requirements should be those of the benchmark levels presented in Annex IV.
Motors intended to operate above 40°C or below -15°C, should not be excluded
Fans integrated in box-fans and roof-fans should also be required to fulfil the ecodesign requirements for the respective fan type (this is a similar approach that motors integrated into other products also need to fulfil the motor requirements);
For box-fans and roof-fans, the minimum efficiency requirement should be made independent of the type of fan integrated, and that the level of the requirement should be the one for backward curved fans.
For fans above 500 W, the minimum requirements for forward and backward curved fans should be the same, and be set at the level of the requirements for backward curved fans (the more stringent level).

After informal contacts with several fan manufacturers, the more stringent requirements proposed by us appear to be realistic and also desired by manufacturers focusing on quality and energy efficiency.

See eceee's full comments (pdf)
See eceee’s eco-design products pages

Proposed TV label does not reflect the rapid market development

admin — Tue, 02 Mar 2010 12:56:17 +0100

eceee welcomes the revised proposal for TV label requirements, but notes that the current proposal fails to fully reflect the rapid market developments of TV energy efficiency. Requirements for class A should be more stringent and the label should contain level A+ already when it is introduced.

“We are very happy about the proposal and hope that we will soon have a EU labelling scheme established”, says Nils Borg, Executive Director of eceee, the European Council for an Energy Efficient Economy. “It is important, however, that the label reflects the rapid market developments as adequate as possible and as a minimum, the A+ class must be on the label already”.

eceee concludes that market research by TopTen as well as the Swedish Energy Agency shows that there would be A+ models on the market already with today’s proposal. Yet, the label would not reflect this development when it is introduced. Therefore, the label must include A+ as the best class.

As an alternative, the requirements for attaining class A should be made stricter, according to eceee.

In short, eceee would like to see the following changes

The requirements for achieving class A should be made stricter than in the Commission’s current proposal.
As an alternative, if stricter requirements for attaining class A is not acceptable, the label should contain the A+ band already at the time of introduction instead of 2013, since there are TVs already meeting the proposed A+ requirement today.
The bands between A and A+++ should be made more narrow, without compromising the level of A+++. This should be combined with an introduction of A+++ which is earlier than currently proposed. This would fit well with stricter requirements for attaining class A.

Overview of label updates: Commission and eceee’s two proposals

	Commission	eceee alt. 1	eceee alt. 2
A	2010	Stricter requirements to reach class A than today	Keep A Class requirements but introduce A+ on the label 2010
A +	2013–2015	2012–2014	2010–2012
A++	2016–2018	2015–2016	2012–2014
A+++	2019	2017	2015

See eceee’s full comments (pdf)
See eceee’s eco-design pages on Televisions
See eceee’s pages on labelling
See TopTen's recommendations
See comments from the Swedish Energy Agency

Eco-design requirements for non-professional displays: Comments from eceee on the amended proposal

admin — Fri, 22 Jan 2010 15:24:57 +0100

eceee welcomes the proposal to make monitors compliant with higher Energy Star specifications earlier than previously proposed, and that the scope has been extended to screens beyond 30 inches. However, we regret that energy labelling requirements are not introduced at this stage, given the trend for computer displays and TVs to converge into the same products. For a more detailed statement on eceee’s views, please see our comments from October 2009.

Summary of eceee’s comments on eco-design requirements for displays

We welcome the proposal for eco-design requirements of displays.
We support that the proposal is aligned with Energy Star and that these requirements are proposed to be introduced earlier, thus increasing the ambition level.
We support the coverage of digital photo frames.
Given the trend for computer displays and TVs to converge into the same products, we particularly welcome that the scope of the requirements have been extended to products beyond 30 inches, which will lead to greater savings and make the regulation more in line with Energy Star specifications. (The requirements for TVs cover screen sizes above 30 inches.)
We suggest that the revision period time is changed from four to three years.
We regret that energy labelling for displays will not be introduced. We encourage the Commission to present a proposal for energy labelling of electronic displays; the proposal should be based on a “progressive efficiency” approach where the energy efficiency index (power/surface area) becomes relatively stricter with larger screen size.
We welcome that the 1W sleep mode requirement for all displays will be introduced earlier but still suggest that the Commission should aim to set requirements of sleep mode at maximum 0,5 W, even if this requirement would be introduced later.
We support the requirement of mercury content to be indicated in the technical data.
We regret that the new proposal does not include non-energy aspects. We suggest that the Commission should inform the working group revising the RoHS Directive that it is possible (technically and economically) to remove CCFL (cold cathode fluorescent light sources) used in LCD screens from the RoHS exception list, from January 2012, with high energy efficiency benefits.

Download eceee’s comments as a pdf

See the summary page on displays on eceee's eco-design pages

Eco-design requirements for computers: Comments from eceee to the revised proposal

admin — Fri, 22 Jan 2010 15:21:40 +0100

eceee welcomes that requirements at the Energy Star 5.0 levels are proposed to be introduced directly at an earlier stage and that servers are now included in the scope. For a more detailed statement, please see our comments from October 2009.

eceee’s main comments in summary

eceee supports Energy Star Alignment in general and welcomes that the mandatory requirements at the Energy Star 5.0 levels are introduced directly at an earlier stage instead of going through a two-staged approach.
We support that servers are included in the scope, although only by requirements on the internal power supplies.
We support strong sleep and off mode requirements.
We support that the requirements will be revised after three years instead of five years.
We regret that requirements for mandatory power management set by default and mandatory display of energy consumption have been delayed by six months and propose that the earlier time limits should be kept.
We repeat that there is a particularly strong energy efficiency benefit by removing computers from the mercury exemption list of the RoHS Directive. Laptops that use light-emitting diodes (LEDs) as backlight instead of cold-cathode fluorescent lamps (CCFL) use no mercury and are more energy efficient. The Commission should inform the working group revising the RoHS Directive that it is possible (technically and economically) to remove CCFL (cold cathode fluorescent light sources) used in LCD screens – e.g. in notebooks and integrated computers - from the RoHS exception list, from January 2012, with high energy efficiency benefits.

Download eceee’s comments as a pdf

See the summary page on computers on eceee's eco-design pages

eceee's comments on the proposed self-regulatory initiative (SRI) for machine tools

admin — Tue, 17 Nov 2009 14:30:43 +0100

eceee appreciates the initiative of the European Machine Tool Industries interest organisation CECIMO to propose a so-called self-regulatory initiative (SRI) well ahead of any results from the preparatory study. However, CECIMO’s proposals must be integrated with the process of the preparatory study to find solutions to many of the problems involved in regulating a group of products as complex as machine tools.

eceee wishes to make the following specific comments:

Machine tools represent an extremely complex group of products with differing size and configurations. Several of the product characteristics are determined by the configuration and system set-up and will vary greatly among individual machines and systems. It is likely, however, that there are common features for all or groups of machine tools that could be more easily regulated or agreed upon. We envisage stand-by energy consumption to be such a feature.
The strength of CECIMO’s proposal is the outlined process and the suggested methodologies as to how different machine tools can be assessed and evaluated from a life-cycle perspective. The Commission is about to launch a preparatory study to determine this and other questions. It is our hope that CECIMO and the machine tools industry will contribute to find answers to some of the open issues.
A number of components used in machine tools are or will be regulated under separate eco-design requirements. Given the complexity of machine tools as systems, it is important that components are strictly regulated with stringent energy performance criteria.
The greatest energy saving potential for machine tools can be achieved within the area of system integration, which makes it difficult to reach full potential through policy instruments. More knowledge about the characteristic use of the most important types of machine tools is needed. Furthermore, the most typical energy efficiency measures should be documented and visible in a calculator.
CECIMO represents a large share of the market (reportedly 86% of machine tool manufacturers). This is an important precondition for a successful self-regulation, but this is in itself not a necessary condition for a successful agreement. Lacking results of the study, eceee does not want to rule out binding eco-design requirements for machine tools, or for specific tools, system or features in the future.

Download eceee’s comments as a pdf

See the summary page on machine tools

Go to eceee’s eco-design pages

eceee's comments on the self-regulatory initiative (SRI) for medical imaging equipment

admin — Tue, 17 Nov 2009 14:17:37 +0100

In the light of relatively low aggregate energy consumption of medical imaging equipment, and the importance to safeguard the primary function of these products, eceee welcomes the self-regulatory initiative as a good intention to contribute to energy efficient product development.

However, eceee has a few additional specific comments:

Would it be possible to introduce SRI:s for the other modalities at a faster pace than the proposal suggests?
COCIR:s intention is to start with ultrasound products in 2009. Targets for this modality have been set to 6% reduction in energy consumption for new ultrasound products placed on the market between 2010 and 2012. According to the proposal, this corresponds to a reduction of 25% compared to 2005. The target of 6% appears to be modest, but without a reference to best available technology (BAT) or a definition of an index, it is not possible to assess the ambition level of the proposal. The answer also depends on whether this is an average for the industry, or an average for each manufacturer.
Medical imaging equipment is often operated in a system with other standardised products, such as displays and computers. It is important that ambitious and well-defined targets be set and maintained for those standardised energy-consuming products, to ensure that all medical equipment will benefit from advances made in these areas.
eceee believes that the stand-by energy consumption of these products may be an important aspect of their total energy consumption. The possibility to reduce stand-by consumption while ensuring rapid reactivation should be investigated.

Download eceee’s comments as a pdf

See the summary page on medical imaging equipment

Go to eceee’s eco-design pages

Eco-design proposals for computers and monitors could be more ambitious

admin — Thu, 08 Oct 2009 15:37:18 +0200

eceee welcomes the proposed eco-design requirements for computers as well as the proposal for computer displays. Both lack ambition, however, and risk to have very little practical effect on the market. The proposed requirements for computer displays also have an insufficient scope. eceee further suggests that computer displays should be included in the European energy labelling scheme.

eceee’s comments on computer requirements in summary

eceee supports Energy Star Alignment in general. By applying the regulation early, EU creates room for influencing upcoming Energy Star specifications in the near future.
The mandatory requirements are thus introduced far too late: Tier II requirements should take effect 31 July 2011 instead of January 2013. projected market penetration rates in the Working Document show that 89 % of the products are expected to meet Tier I requirements when it comes into force in January 2011 and 95 % of the products to meet Tier II requirements when it comes into force in January 2013. This is not cost effective from either a consumer or environmental perspective and will not deliver enough energy savings.
The Commission may also wish to consider skipping Tier I requirements completely, which would also make the regulation easier to apply since the definition of efficiency differs between Tier I and Tier II.
The requirements should be revised after three years instead of five years in view of the rapidly improving nature of this industry.
Chapter 4 proposes to exclude computers from the list of energy-using products in the Regulation (EC) No. 1275/2008 (stand by). The Wake up on Lan (WOL) function belongs to a networked standby requirement. Until implementing measure for networked standby has been prepared, WOL requirement could be included in the eco-design requirements for computers.
There is a particularly strong energy efficiency benefit by removing computers from the mercury exemption list of the RoHS Directive. Laptops that use light-emitting diodes (LEDs) as backlight instead of cold-cathode fluorescent lamps (CCFL) use no mercury and are more energy efficient. The Commission should work towards removing computers from the list of exemptions before the end of 2011 and require clear information on mercury to consumers.

Comments on computer requirements in summary

We support that the proposal is aligned with Energy Star.
We support the coverage of digital photo frames.
The proposal to limit the scope to screens of maximum 30 inches is not justified. We propose that the display screen size is aligned with the Energy Star definition to include displays with a viewable diagonal screen size of less than or equal to 60 inches. Requirements for TVs also cover larger screen sizes and displays and TVs should be harmonised in this respect.
Tier II should be moved forward from October 2012 to January 2012.
The revision period time is changed from four to three years.
We propose that the Commission presents a proposal for energy labelling of electronic displays; the proposal should be based on a “progressive efficiency” approach where the energy efficiency index (power/surface area) becomes relatively stricter with larger screen size.
The Tier I sleep mode shall not exceed 1 W and that the Tier II sleep mode shall not exceed 0,5 W. It has been shown that all displays can easily fulfil the standby and off mode regulation (1275/2008) and it should thus apply.
Information requirement on mercury content should be clearly available when marketing the product. The information required is the total amount of mercury in the product in mg.
The Commission should inform the working group revising the RoHS Directive that it is possible technically and economically to remove CCFL (cold cathode fluorescent light sources screens) used in LCD screens from the RoHS exception list, from January 2012, with substantial energy efficiency benefits.

Download eceee’s comments on eco-design requirements for computers. [pdf]
Download eceee’s comments on eco-design requirements for displays. [pdf]
See also eceee’s eco-design pages

"Weak voluntary agreement no substitute for eco-design requirements"

admin — Thu, 08 Oct 2009 15:24:03 +0200

eceee today presented its views on the two voluntary agreements on complex set top boxes and imaging equipment, to be discussed in the eco-design consultation forum. Whereas the proposed voluntary agreement for complex set to boxes may become successful, the proposal on imaging equipment is unacceptable.

The European Commission has proposed voluntary agreements on complex set-top boxes and imaging equipment as an alternative to regulation under the eco-design Directive. It is hoped that a voluntary agreement can ideally be set up quicker than regulation and would thus start saving energy sooner and generate larger savings. eceee believes that this may only be true for a limited number of products.

“ We find the proposal for imaging equipment very weak and totally unacceptable” Nls Borg, Executive Director of eceee said. “With 80 % market coverage and a 50 % compliance rate, the effective coverage may only be 40 % of the products on the market. Such a weak voluntary agreement is no substitute for a solid eco-design regulation where everyone must comply”.

eceee also points to other weaknesses in the proposal regarding the scope and the inconsistent alignment with Energy Star specifications.

Complex set-to boxes

The proposed voluntary agreement for complex set-top boxes is given cautious support by eceee.

“The backing from the industry is much better. Still, we need to see that the commitments from industry partners really cover the relevant products to a significant degree, around 80 percent is needed” said Nils Borg.

eceee outlines a few conditions that need to be met in order to make the agreement truly successful:

Industry signatories must represent a significant share of the EU market to avoid free riders and maintain the credibility of a voluntary agreement instead of regulation.

Tier II values are draft values. If final tier II values are weaker than those now discussed, it should be discussed in a new consultation forum and not delegated to the industry or the steering group.

It is important that the power consumption is defined in a transparent way. The measured Typical Energy Consumption (TEC) value should show the break-down power consumption values that make up the total quota. This is important information for consumers who may have different usage patterns than those on which the TEC value is based, and it is also important for monitoring and evaluation of the agreement.

Download eceee’s comments on the proposed voluntary agreement on imaging equipment. [pdf]
Download eceee’s comments on the proposed voluntary agreement on complex set-top boxes. [pdf]
See also eceee’s eco-design pages

Beyond energy efficiency

admin — Tue, 01 Sep 2009 13:02:59 +0200

eceee presents its input paper for the new EU Energy Efficiency Action Plan. "Instead of just creating a long wish list, we have tried to focus on fewer, but very important issues" said eceee's Executive Director Nils Borg.

The paper underlines the importance of issues such as minimum energy performance standards, mandatory efficiency targets, the need for clear and manageable objectives, incentives, and capacity building in EU Member States.

The paper has been developed by participants at the eceee 2009 Summer Study and was further refined through a consultation among eceee's members.

The paper's conclusions are in short:

The new EEAP should contain a finite number of clear and manageable high level objectives.
These should include: 1. mandatory energy efficiency targets; 2. an agreed and strict measuring system on energy savings; 3. capacity building aiming to improve implementation and enforcement in MS; and 4. improved financing of energy efficiency in all end use sectors.
In addition to focusing on energy efficient technologies, policies should also aim at avoiding the unnecessary use of (even very efficient) energy technologies.
More incentives should be created for consumers and manufacturers to change their ways and save energy. The necessary technologies and ideas are (largely) there, the challenge is putting them into practice.

Download eceee input paper for the new EU Energy Efficiency Action Plan (pdf)

eceee key issues on the EP vote on EPBD

admin — Thu, 25 Jun 2009 10:25:38 +0200

eceee welcomes the proposal published by the European Commission on 13 November 2008 which lays out a framework for the long-term improvement in the energy performance of buildings, the sector with high untapped potential for energy efficiency improvements. eceee also welcomes amendments provided by the European Parliament, in its vote on 23 April 2009.

The recast proposal confirms the importance of effective implementation at the Member State level, the importance of Community-wide cooperation and the strong long-term commitment and role of the Commission itself to support such effective implementation.

The key issues are summarised in a document available at eceee buildings pages.

Download (pdf)

Labelling position

admin — Thu, 19 Jun 2008 11:40:42 +0200

In a letter to the European Commission, eceee expresses support for the
current A–G scale as opposed to a numerical scale. The numerical scale has
been proposed by stakeholders in the Commission's working group on a
possible redesign of the energy label.

Download letter to the European Commisson (pdf).