Circumvention of EU Ecodesign and Energy labelling regulation and standards: Impacts, mitigation measures and recommendations for policy and standardisation

Panel: 9. Products, appliances, ICT

This is a peer-reviewed paper.

Authors:
Kathrin Graulich, Germany
Ina Rüdenauer, Oeko-Institut e.V. - Institute for Applied Ecology, Germany
Rainer Stamminger, University of Bonn, Germany
Juraj Krivosik, SEVEn - The Energy Efficiency Center, Czech Republic
Christian Praher, Austrian Energy Agency, Austria
Sonia Martin, Fundacion para el Fomento de la Innovacion Industrial (FFII-LCOE), Spain
Nerea Ruiz Fuente, ECOS, Environmental Coalition on Standards, Belgium
Milena Presutto, Agenzia Nazionale per le nuove Tecnologie, L'energia e lo Sviluppo Economico Sostenibile (ENEA), Italy

Abstract

Whereas reasons for and remedies against non-compliance under EU ecodesign and energy labelling legislation have already been well analysed, the general topic of suspected manipulation of test results or circumvention received a lot of policy attention only recently, not only for car emissions (dieselgate resp. emissionsgate scandal) but also regarding potential negative effects for other legislation.Among the reactions the European Union’s Horizon 2020 research and innovation programme funded the project “ANTICSS – Anti-Circumvention of Standards for better market Surveillance”.

This paper provides a further developed definition and examples of ‘circumvention’ in the context of EU ecodesign and energy labelling legislation and relevant harmonised standards. Further, an estimation of the magnitude of possible energy saving losses due to ‘circumvention’ is given based on collected cases and independently tested products. Finally, recommendations for policy makers and standardisation bodies to prevent future circumvention under EU ecodesign and energy labelling are given.

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