EN    EN EN 
 
EN 1   EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 16.7.2008 
SEC(2008) 2115 
  
COMMISSION STAFF WORKING DOCUMENT 
accompanying the 
Proposal for a 
 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
establishing a framework for the setting of ecodesign requirements for energy related 
products 
IMPACT ASSESSMENT  
{COM(2008) 399 final} 
{SEC(2008) 2116} 
 
EN 2   EN  
Table of Contents 
1. Procedural Issues and Consulta tion of Interested Parties ............................................ 5 
1.1. Consultation and expertise ........................................................................................... 9 1.1.1. Studies................................................................................................................. ......... 9 
1.1.2. Stakeholder Consultations............................................................................................ 9 1.1.3. Academic expertise consulted.................................................................................... 10 2. Problem definition:..................................................................................................... 11 2.1. Problem ................................................................................................................... ... 11 
2.2. EU's right to act......................................................................................................... . 14 
2.2.1. Treaty establishing the European Community........................................................... 14 2.2.2. Policy background...................................................................................................... 1 4 
2.2.3. Subsidiarity and EU added value ............................................................................... 14 3. Objectives:................................................................................................................. . 15 
4. Policy options............................................................................................................. 1 5 
5. Analysis of impacts.................................................................................................... 16 6. Comparison of the options ......................................................................................... 36 7. Administrative costs................................................................................................... 37 7.1. For Member States and the Commission ................................................................... 37 
7.2. For Manufacturers...................................................................................................... 37 8. Cost-effectiveness ...................................................................................................... 39 9. Monitoring and evaluation ......................................................................................... 40 
 
EN 3   EN SUMMARY 
This Impact Assessment accompanies the prop osal for the amendment of the Ecodesign 
Directive for Energy Using Products1. The amendment of the Ecode sign Directive is one of 
the elements of the Action Plan on Sust ainable Consumption and Production and on 
Sustainable Industrial Policy (SCP/SIP) which is  a joint initiative of  DG ENTR, DG ENV and 
DG TREN. The main element of the SCP/SIP is an integrated product policy. The Ecodesign 
Directive is an important build ing block of the Action Plan.  
The current Ecodesign Directiv e covers only ener gy using products (excluding means of 
transport). For these and under the condition that  no self-regulatory mechanism is offering a 
valid alternative, the Direct ive allows the setting of mandatory minimum requirements 
corresponding to the performan ce of the product that has least life cycle cost. Also, the 
Directive specifies a number of criteria and safeguards such that minimum requirements take 
into account competitiveness and social issues . This guarantees that improvements in 
environmental performance are co st-effective. While the purcha se prices of these products 
might rise in the short term, their superior pe rformance more than offsets this over the life 
span of the product by lower usage costs. 
However, the impact assessment of the Acti on Plan mentioned above has shown that the 
limited scope of the Ecodesign Dire ctive represents an important restriction on the potential 
impact that the EU's Integrated Product Poli cy can have. This impact assessment report 
therefore analyses whether the scope of the Ec odesign Directive could be extended and what 
impacts the extension could have. The objectiv e of the report is therefore to provide 
information to policy makers on the po ssible scope of such an extension. 
Three options are considered:  (1) No extension of the scope, thus only energy using products can be covered, 
(2) Extend the scope beyond energy using products  maintaining the exclusion for means 
of transport, and 
(3) Extend the scope beyond energy using pr oducts including means of transport 
Changing the scope of the Ecodesign Directiv e would not have dir ect impacts on products, 
since the Ecodesign Directive is a framework Directive. The environmental, economic and 
social impacts are linked with the implementi ng measures for specific product groups. These 
implementing measures are adopted by the Commission under the re gulatory comitology 
procedure. Before the implementing measures are adopted, stakeholders will be formally 
consulted and a specific impact assessment will be made by Commission services. All impacts mentioned in the report are illustrative examples of the impacts that could be reaped 
by having implementing measures for products of the different options. Moreover, the 
impacts would only be realised in the long r un since the adoption of implementing measures 
is done product by product and afte r a thorough assessment process.  
The analysis of the options takes into account a number of issues. Firs t, the environmental 
impacts are discussed for broad product cate gories. Second, it is reviewed whether the 
Ecodesign Directive would overlap  with existing legislation already addressing environmental 
impacts. Third the environmental improvement potential and the economic and social impacts 
of the options are assessed.  
                                                
 
1 Dir 2005/32/EC  
 
EN 4   EN The analysis of the available data indicates that significant reducti ons of environmental 
impacts are possible while at the same time also allowing economic savings for businesses 
and final consumers. Generally speaking, the potential benefits  are larger the broader the 
scope of products that can be addr essed through implementing measures. 
Although the potential benefits would be highest  in the case of covering all products (option 
3) the report shows that  the Ecodesign Directive does not appear to be complementary to the 
Type-Approval System since much of the potential benefits in the transport sector will already 
be reaped by forthcoming legislation such as  the CO2 in cars legislation and the new Euro 
standards. Within the products screened in Op tion 2 a high environmental impact that can be 
reaped cost effectively would come from energy related products such as construction 
products and water using products . Furthermore, also a number of other product groups may 
offer significant potential for cost efficient im provements, as there is evidence that their 
impact is even more significant than bot h the Labouze 2003 and the EIPRO study have 
demonstrated when looking at products such as : detergent/cleaning prod ucts, footwear/leather 
products, other food products, print-media ( books, journals, newspaper), hygiene paper, 
mattresses, batteries, and toys. Ongoing Co mmission studies will look further into the 
environmental impact and improvement potentia l of these products. Further research could 
also investigate the environmen tal and economic sustainability of  the use of concrete/cement, 
steel, aluminium, plastics and other important  materials. These product groups and materials 
are presented for illustrative purpose only.  
The screening analysis of the cost and benefits  of option 1 and 2 shows that the importance of 
the upfront costs is highly dependant on the nature of the products and even between sub-
categories of the same product type. In the illu strative cases analysed, net benefits increase 
over time with an increased uptake of pr oducts responding to minimum requirements. 
An extended scope will allow introducing implementing measures for those non energy using 
product categories that have the highest potential for imp rovement of environmental 
performance while also leading to the highest savings during the use phase. This would not 
necessarily be possible under the current Dir ective which is restricted to energy using 
products. More detailed analyses will be conducted for the impact assessments that need to be 
prepared for each implementing measure. 
At this stage, it can be recommended based on the available evidence to widen the scope of 
the Directive to energy-related products. Exte nding the scope to means of transport would 
have limited benefits. While there are also st rong indications that widening the Directive 
beyond those products coul d deliver significant benefits, it is recommended to carry out 
further investigations an d further assess the option of includ ing non-energy related products in 
the scope of the Directive following a future review.  
 
EN 5   EN 1. P ROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
The Ecodesign Directive 
This Impact Assessment accompanies the prop osal for the amendment of the Ecodesign 
Directive for energy using products2. This framework directive provides harmonised EU-wide 
rules for ecodesign of products to improve thei r environmental performance and ensure their 
free movement in the EU. The product scope of the Directive is energy using products (EuPs) 
with the exclusion of means of transport. The Directive does not in it self introduce directly 
binding requirements for specific products, but defines conditions and criteria for setting, 
through subsequent implementing measures, minimum requirements regarding environmentally relevant product characteristic s (including energy cons umption) and allows 
to improve quickly and efficiently the perf ormance of the products put on the market. 
Minimum requirements are set aiming at the life-cy cle cost minimum to end-users, taking into 
account the consequences on other environmenta l aspects. Implementi ng measures are only 
considered for products with si gnificant environmental impacts and a significant improvement 
potential through their design.
 The philosophy of the directive is to cover only a limited 
number of products with a significant c ontribution to environmental performance.   
In Art 15 of the Directive the conditions and cr iteria for selecting products for which to set 
minimum requirements through subsequent implem enting measures are e xplained. In Art 15.2 
the necessary three criteria to be fulfilled by any product in order to be included in the 
working plan are presented. Satisfying these criter ia is the first step in the procedure that 
could lead to an implementing measure: 
(i) The product shall represent a significant volume  of sales and trade, indicatively more than 
200,000 units a year within the Community. 
(ii) The product shall have a significant environmental impact within the Community. 
(iii) The product shall present significant po tential for improvement in terms of its 
environmental impact without entailing excessive  costs, taking into account in particular: 
- the absence of other relevant Community legisl ation or failure of mark et forces to address 
the issue properly.  
- a wide disparity in the environmental performa nce of products availa ble on the market with 
equivalent functionality. 
These criteria can be applied to energy using products and non-energy using products 
Moreover, art 15.4 of the Directiv e presents the criteria which the Commission needs to take 
into account in preparing a draft implementing measure: 
(a) The life cycle of the products and its significant environmental impact 
(b) The impact in terms of competitiveness, fo r manufacturers, including SMEs, including on 
markets outside the Community, innovation, market access and cost and benefits. 
(c) Existing national environmental legislation. (d) Consultation with stakeholders (e) The setting of implementing dates, which could include staged or transitional measure or 
periods, taking into account in particular possible impacts on SMEs or on specific product 
                                                
 
2 Dir 92/75/EEC 
 
EN 6   EN groups manufactured primarily by SMEs. Fo r example, the Commission is preparing 
implementing measures on set to p boxes and standby/off mode of  electric equipment. For 
both implementing measures, staged minimum requirements will be introduced to allow 
industry to adapt to the legislation. 
These criteria can be applied to energy using products and non-energy using products 
Finally, art 15.5 contains crit eria that implementing meas ures need to satisfy: 
(a) There shall be no significant negative im pact on the functionality of the products 
(b) Health, safety and the environmen t shall not be adversely affected 
(c) There shall be no significant negative impact on consumers in  particular as regards the 
affordability and the life-cycle cost of the product 
(d) There shall be no significant nega tive impact on industry’s competitiveness 
(e) In principle, the setting of an ecodesign re quirement shall not have the consequence of 
imposing proprietary te chnology on manufacturers 
(f) No excessive administrative burden  shall be imposed on manufacturers. 
These criteria can be applied to energy using products and non-energy using products 
Besides, Annex I and Annex II of the Eco- design Directive identify a wide list of 
environmental parameters must be considered when studying the setting of minimum 
requirements. The methodology used for deve loping implementing measures considers, 
(among others) the following environmental imp acts: energy, water, waste, global warming 
potential, ozone depletion potential, acidif ication, the emission of volatile organic 
compounds, persistent organic pollutants, heavy me tals and particulate matter into the air. The 
current methodology for setting implementing m easures identifies the aspects of products 
having environmental impacts throughout thei r lifecycle, analyses  the potential for 
improvement and identifies best available t echnology. On the basis of this information, 
minimum requirements are set to tackle the most relevant impacts. Typically, only 3-5 
parameters would be identified because they account for a very high proportion of the total 
environmental impact of the product. The methodology for setting implementing measures 
does not weigh the environmental impacts. In practice, the European  Commission decides, 
taking into account all evidence,  what the most important envi ronmental impacts of a product 
are. The list of environmental parameters can be  used to reduce the environmental impacts of 
energy using and non-energy using products. 
Procedural steps before any impl ementing measure is adopted  
Before the Commission proposes an implementing measure, several steps have to be carried 
out.  
First, there is a need to define a working plan  with candidate products to be studied. The first 
batch of products was included in the Directive. Currently, the Commi ssion is identifying 
product groups to be tackled in the following three years. The work plan is made after 
consultation of the stakeholders and analysi ng whether the products satisfy the requirements 
of art 15.2.  
Second, it is necessary to launch preparatory studies for the products identified in the work 
plan to identify which eco-design requirement s should be set for a particular product to 
improve the environmental performance of th e product. The preparatory study provides the 
necessary information to prepare for the next phases to be carried out by the Commission.  
 
EN 7   EN Third, as requested by Art 18 of the Direc tive, a group of interested parties called 
“Consultation Forum” is set up to allow stake holders to be informed and provide their 
positions on the possible measures. The task of the Forum is to contribute, in particular to the 
definition and review of the implementing meas ures, to monitoring the efficiency of the 
established market surveillance mechanisms and to the assessment of voluntary agreements and other self-regulatory measures taken in the context of the Directive. The Forum is also 
consulted by the Commission during the peri odic modification of the working plan.  
Fourth, an impact assessment is necessary fo r each proposal for an implementing measure. It 
will assess the environmental, economic and soci al impacts and submitted to the European 
Commission’s impact assessment board. 
Fifth, the Commission shall be assisted by a Committee operating under the regulatory 
procedure with scrutiny by the European Parliament. 
Sixth, the Commission adopts a proposal for an implementing measure following the normal 
procedures, including in terservice consultations. 
In summary, the procedures that  are specified in the Ecodesign Directive guarantee that all 
concerned parties are heard and all evidence is considered when setting implementing 
measures. Even if at the time of being devel oped, these provisions were drawn up to address 
mainly energy-using products, they can equa lly be applied to non- energy using products. 
Regulatory Dialogue 
It should be mentioned as well that the European Commission is involved in formal 
regulatory dialogues with its main trading partne rs and with international organisations on 
such issues as the ha rmonization of measurement methods/s tandards, benchmarking and other 
crucial elements directly linked to the setting of implementing measures of the Eco-design 
Directive. The draft measures are notified to the World Trade Organisa tion/Technical Barriers 
to Trade to ensure that no barriers to trade are introduced. Additionally the draft implementing 
measures are discussed with the relevant mini stries from third countries in the frame of 
regulatory cooperation. Manufactur ers from outside the EU ar e encouraged to actively 
provide input when implementing measures ar e developed and the all process is made 
extremely transparent from the outset. 
Transposition 
The Ecodesign Directive is being transposed in to Member States legislation and there are 
currently 7 MS that are late in their tr ansposition and confronted with infringement 
procedures. This is not an unusual situation fo r a new Directive. Furthermore the delays did 
not have yet any practical consequences, as ther e is no effective application of the Directive 
until Implementing Measures on specific products  have been adopted and are applied. The 
development of such Implementing Measures  is under way and the first ones could be 
adopted by the end of 2008.  
Conclusion 
The different criteria, procedures  and other safeguards assure th at economic and social issues 
are taken into account when setting minimum re quirements. Therefore, the Directive is a good 
framework for reducing negative environmenta l externalities while  taking into account 
potential negative economic or social impacts.  
Since the same policy goal is aimed at for non-energy using products, the same criteria, 
procedures and other safeguards that already exist for energy using products should be in place to guarantee the policy goal. 
 
EN 8   EN The current impact assessment 
The Action Plan on Sustainable Consumption and Production and on Sustainable Industrial 
Policy (SCP/SIP), a joint initiative of DG  ENTR, DG ENV and DG TREN, will propose 
actions to solve market and regulatory failu res which prevent improving the environmental 
performance of a large scope of products in Eu rope. The main element of the SCP/SIP is an 
integrated product policy. The Ecodesign Directiv e is an important building block thereof.  
This impact assessment is one layer in the anal ytical framework of three levels of impact 
assessments related to product policy.  
First, the impact assessment of the Action Plan focused on delimiting the problem definition 
and the remaining problems. In the Impact Asse ssment of the Action Plan it was clearly stated 
that the Action Plan would only look at existing policy instru ments and how to coordinate 
them better. The Impact Assessment of the Acti on Plan discussed the options of business as 
usual, a voluntary approach or a mandatory a pproach. The main conclusion of the impact 
assessment of the action plan was that a mandato ry approach could solv e the identified market 
failures. Moreover, the impact assessment of the action plan concluded that a specific impact 
assessment was needed to look at the extensi on of the scope of the Ecodesign Directive.  
Second, this impact assessment focuses on the id entification of the need for and the most 
adequate extension of the scope of the Ecode sign Directive. It will start addressing the 
environmental, economic and social trends and im pacts of the different options to the extent 
possible. The extension of the scope could be dealt with through a sepa rate legal instrument, 
such as a sister directive that could contai n similar provisions as the current eco-design 
directive but be applicable onl y to non-energy using products. This option has been discarded 
because two separate directives with exactly the same material content but different scope 
would not only pose an unnecessary burden for the Community legislator and the national 
Parliaments. It would also m ean adding to the volume of the acquis communautaire  and 
creating confusion for enterprises that have to understand which of the directives is actually 
relevant for them. This is fully in line with  better regulation prin ciples, in particular 
simplification. 
Third, where an implementing measure will be  proposed for a product , a specific impact 
assessment will identify the specific problems and analyse the specific environmental, economic and social impacts of setting minimum requirements. In the impact assessment for 
the specific product group, the Co mmission will set out how it respected the safeguards of Art 
15. 
The impact assessment principle of proportionality should be seen in light of these three 
layers of impact assessments and notably the guarantees and safeguards stipulated in the Ecodesign Directive for the implementing measure stage.  
This document is prepared as a basis for comm ents and does not pre-judge the final form of 
any decision to be taken by the Commission. Mo reover, all products categories mentioned in 
this document are only included for analytical  purposes and do not prejudge any decision on 
the inclusion of products on the working plan fo r the Ecodesign Directiv e. Finally, all figures 
and numbers quoted in this Impact Assessm ent are of an indicative nature only.  
 
EN 9   EN  
1.1. Consultation and expertise 
An inter-service steering group was consulted on the impact assessment. The meeting has 
taken place on 28 February 2008. ECFIN, ENV, ENTR, TREN, SG and RTD were present. 
After the meeting the DG’s present have been informally consulted on a draft impact assessment. The suggestions of the different dire ctorate generals have been taken into account 
in drafting this impact assessment. 
1.1.1. Studies 
The results of a number of studies  have been considered. Some of the most important are: the 
EIPRO project
3, Labouze et al (2003)4, McKinsey (2007)5 and the preparatory studies on 
implementing measures. The results of the diff erent studies are not necessarily consistent 
because of the very different methodologies used  to evaluate the externalities and potential 
impacts. Yet, in general the results of th e studies point out in  the same direction. 
1.1.2. Stakeholder Consultations 
DG ENTR and DG TREN are in regular contact with their stakeholders.  
Two consultations on the Action Pl an were organised: The firs t one was business oriented: a 
questionnaire was sent to around 4000 companies pa rticipating in the European Business Test 
Panel. The consultation took place from the 15th of September to the 15th of October 2007. 
354 companies responded. 69% of the businesse s surveyed where in favour of applying 
minimum standards to improve energy and resour ce efficiency to a broad number of products. 
The second consultation was done jointly with DG ENV and concerned the Sustainable 
Consumption and Production and the Sustainable Industrial Polic y Action Plan. The Internet 
consultation on the basis of the questionn aire and a 10 pages background document was 
launched on “Your voice in Europe” and took place between the 27th of July and the 23rd of 
September. It addressed both stakeholders (n ational ministries, industries, associations, 
NGOs) and the general public. Participants to th e consultation were also  invited to provide 
position papers. 479 answers were submitted. Enhanced use of eco-design instruments was generally recognised as the first best action ( 67.3%). 83% of the res pondents strongly agreed 
with extending the product scope  of the Ecodesign Directive. There was a slight preference 
for concentrating on products improving resource  and energy efficiency (79.1%). A majority 
of the respondents (70%) indicated  that actions need to tackle  environmental problems in a 
cost-efficient way and need to minimise the so cial impacts. Eleven Member States, three 
Universities and forty-two associations and companies also provided position papers. See 
Annex I for a more detailed accoun t of the stakeholder consultation. 
Stakeholders have been generally very posi tive to the philosophy of the Directive and the 
possibilities it gives to manuf acturers, in terms of self-regulation an d cooperating on the 
development of implementing measures. However, some stakeholders
6 have recently raised 
                                                 
3 http://ec.europa.eu/environment/ipp/identifying.htm 
4 The full reference for Labouze et al (2003) is La bouze, E., V. Monier, Y. Le Guern and J.-B. Puyou. 
(2003), Study on external environmen tal effects related to the lifecycle of products and services – Final 
Report Version 2, European Commission, Dir ectorate General Environment, Directorate A – 
Sustainable Development and Policy support, BIO In telligence Service/O2 Fran ce, Paris, France. See 
Annex I for some detailed statistics from Labouze et al (2003). 
5 http://www.mckinsey.com/clientservice/ccsi/p df/costs_and_potentials_of_geenhouse_gas_ 
full_report.pdf 
6 Orgalime letter to Vice President Verheugen dated on the 11th of April. Also the position by Business 
Europe. 
 
EN 10   EN some concerns about the revision of the Ec odesign Directive. The main objections are the 
period of legal uncertainty for the mechanical engineering industry that would be induced by 
the revision as well as the strong resistance fr om other industries. The European Commission 
would take into account the comments of thes e industry associations by proposing only a 
limited recast to the Ecodesign Di rective to modify only its scope  without altering its other 
provisions. This should not rais e legal uncertainty for the indu stries whose products currently 
fall under the scope of  the Directive. 
1.1.3. Academic expertise consulted 
DG ENTR has drawn on the expertise of several academic institutions for the elaboration of 
this impact assessment. The Institute of Enviro nmental Science of the University of Leiden 
has shared its expertise and databases for th e life cycle assessment of the environmental 
impacts of products. The “Zentrum für Europäis che Wirtschaftsforschung“ (ZEW) assisted by 
providing input-output analysis on the environmental databases. 
1.2. Opinion of the Impact Assessment Board 
This impact assessment report was drafted following the remarks in the request for 
resubmission of the Impact Assessment Board of 21 April 2008 and the Final Opinion of the 
Board on the final draft issued on 6 May 2008. The following improvements have been made: 
A comprehensive section on the current eco-desi gn directive has been included. This section 
focuses on explaining that the provisions of th e Eco-design Directive are suitable to cover 
non-energy using products. It sets out clearly th at the goal of the Eco- design Directive is to 
reduce negative environmental externalities ta king into consideration the social and 
competitiveness impacts. It is explained that the goal is realised by a list of criteria and procedures for setting implementing measures included in the Directive. Two examples 
(construction products and water using products) of the value added of an extended scope of 
the Directive are included. These two examples have an illustrative purpose and do not limit 
or prejudge any decision by the Commission. 
This final draft makes clear that all products a nd impacts in this report are for illustrative 
purpose only. Moreover, it has been clarified to which extent specific product groups listed in 
the table could be potentially c overed by the extension taking into account existing legislation 
and how existing voluntary measures and indu stry standards would be taken into account 
when designing implementing measures. Also, ar t 1.4 of the Directive has been taken into 
account when selecting products.  
A number of methodological issues have been clarified. It has b een clarified that the energy 
and climate package is not taken up in the ba seline since this would require a complicated 
modelling exercise. Also, it is expl ained that some thresholds used in this impact assessment 
are purely for illustrative reasons and that for future implementing measures no such thresholds would be used. Also, it is clarifie d that the thresholds used could be higher or 
lower and that this would alter the enviro nmental improvement potential but not the 
comparison of the three options. The text and Annex VII clarify the weightings used in this 
impact assessment. Moreover, it is clearly stated that the weightings are for illustrative purposes and that the European Commission does not use weightings to determine the most 
significant environmental impacts in the implementing measures.  
This draft elaborates on the in ternational context of the Eco-Design Directive. It clarifies the 
role of existing mechanisms on international standards and regulator y dialogues with main 
trading partners, and confirms that the impact on third countri es will be addressed when 
designing implementing measures. 
 
EN 11   EN The Impact Assessment Board requested that ne t benefits would be di sentangled into both 
costs and gross benefits. This has been done for illustrative purposes for water heaters and 
windows. The more aggregate anal ysis that was initially in th e main body of the report has 
been explained more thoroughly in Annex II,  explaining underlying assumptions more 
carefully. 
2. P ROBLEM DEFINITION :  
2.1. Problem 
As explained in the impact assessment of th e SCP/SIP Action Plan, the way in which products 
are made, used, consumed and disposed of can  have negative impacts on the environment. 
The aim of policy action is not to reduce pollution and CO2 emissi ons to zero. The aim is to 
have a socially desirable level of cons umption and production on the one hand and 
environmental impacts on the other. The SCP/SIP impact assessment identified several market failures and imperfections that current ly prevent society from reaching the social 
optimum
7. The most important are:  
• Environmental externalities that result from  prices that do not reflect the negative 
environmental impacts of the production or consumption of products. 
• Information asymmetries that result from  high transaction costs for consumers to 
obtain relevant information on product char acteristics. Consumers can often not 
tell whether a product is more  resource efficient during it s use phase than another. 
• Bounded rationality that can explain w hy even well-informed consumers do not 
act rationally when making purchasing decisions. Even if consumers have 
sufficient information, they can be faced with high upfront costs when buying a more performing product, while the benef its accrue over a l onger period of time 
(i.e. during its use-phase). Consumers may not  take into account the use cost of a 
product but focus on the purchase price only.  
• Principal-agent problems that occur where there is a misalignment of incentives of 
those purchasing the product (e.g. landlor ds) and those using it (e.g. tenants) 
• The above market failures have nega tive effects on innovation of better 
performing products since they limit the demand for products with lower 
environmental impacts.  
The market failures identified in the impact a ssessment of the SCP/SIP Action Plan result in 
products that are not designed su ch that environmen tal impacts of pro ducts over their life 
cycle are optimal from a social point of view.  
This is confirmed in reality. Based on a comprehensive list of environmental impacts for the 
EU, Labouze et al (2003)
 calculated the total external cost of 25 products which are 
commonly seen as having a significant enviro nmental impact over the life cycle. For each 
environmental impact Labouze et al report a minimum and maximum monetary value which 
corresponds to the cost of that  environmental impact to societ y. The monetary values are 
based on the lower and higher esti mates found in the lite rature and are report ed in Annex VII. 
In Table1 below the monetary values for the environmental impacts are aggregated to one monetary value which represents  the cost of all environmenta l impacts studied by Labouze et 
al for that product group. As th e authors stress the given extern al cost figures are clearly 
                                                
 
7 Impact Assessment of the SCP/SIP Action Plan, EC (2008) forthcoming 
 
EN 12   EN conservative estimates as many mechanisms and imp acts that result in ex ternal costs could not 
be included. The true impact and potential is hence clearly higher. Al so, and as a found more 
below, the numbers for non-energy using produc ts are a systematic underestimate, due to 
limitations in data, assumptions of the study an d a certain focus on energy-related emissions 
in the inventory data and impact assessment. Th e aggregated monetary value is mainly used 
for presentational reasons. For setting imp lementing measures no aggregation of 
environmental impacts will be done and the European Commission can decide, taking into 
account all evidence, which environmental imp acts it deems most important. These minimum 
and maximum environmental impacts are repres ented per capita, for the EU-27 and ranked 
per importance.  
Table1 External costs of en vironmental impacts per year 
  per capita (€) EU-27 (bn €) Rank 
Product min max Min max min max 
Space heating 41.3 186 20.3 91.7 1 1 
Personal cars 32.2 90 15.8 44.1 2 4 
Goods transport8 20.4 100 10 49.2 3 3 
EuP domestic appliances 15.6 101 7.7 49.5 4 2 
Appliances and lights 12.7 58 6.2 28.4 5 6 
Textiles  11.6 67 5.7 32.9 6 5 
Building structure12 11 51 5.4 24.8 7 7 
Water heating 8 38 3.9 18.9 10 10 
Transport services 5.1 28 2.5 13.6 14 11 
Water supply12  3.5 42 1.7 20.5 15 8 
Cooking 3.5 16 1.7 7.6 16 16 
Furniture 3.3 14 1.6 6.9 17 17 
EuP IT 3.1 17 1.5 8.5 18 15 
Non eco-designable products 47.7 138 22.4 68.8   
Total 219 946 106.4 465.4   
Source: Labouze et al (2003) 
                                                 
8 Although these are not products, there are product design measures which can reduce the environmental 
impact of this category. 
 
EN 13   EN Products to which eco-design measures can be applied make up between 80 and 88% of 
environmental impacts studied by Labouze et al. Total externalities are in the range of €219-
€946 per capita per year. For the EU-27 as a whole these externalities amount to between 
€106.4-465.4 billion per year. In relative terms, th is is between 1.1% an d 4.9% of EU GDP at 
the time of publishing the study, keeping in  mind the already mentioned systematic 
underestimation of the real leve l of external costs. CO2 account s for an important share of 
total externalities: in the minimum scenario CO2 accounts for 77% of the externalities, in the 
maximum scenario CO2 accounts for only 44%9. As CO2 related impacts are rather well 
covered in the external cost calculation while others are not, the true relevance of CO2 is 
however lower.  
Remaining Problems, taking account of existing policies 
The problem definition of the impact assessment of the Action Plan SCP/SIP demonstrated 
that a number of policies are already in place. It identified the climate package (Emission Trading Scheme (ETS), renewa bles, sectors not covered by ETS ), the directive on industrial 
emissions, waste legislation, the directive on Ambient Air Quality and Cleaner Air for 
Europe, the eco-label, the energy action plan (e nergy performance of buildings directive, 
energy efficiency label and Ecode sign Directive), EMAS and ETAP
. However, the impact 
assessment of the Action Plan  already pointed out that: 
• Internalisation policies such as ETS w ill not necessarily result in consumers 
buying more environmentally efficient products  that are optimal from a social- or 
even consumer perspective. Informati on asymmetries, bounde d rationality and 
principal-agent problems are not resolved by inte rnalisation policies.  
• The best way to foster environmentally e fficient products is to complement price 
signals with an eco-design framework. Th e eco-design framework can assure that 
manufacturers produce products with envir onmental externalitie s that are optimal 
over the life cycle from a social perspe ctive. Information asymmetries can be 
resolved by providing more informati on on the environmental performance of 
products. Yet, bounded rationality, principal agent problems and environmental externalities require a mandatory  approach for product policy.  
• Intervention on the environmental performa nce of products at Member State level 
might erect barriers for the free movement  of products in the internal market. 
Therefore, public intervention at the EU  level is justified for product policy. 
Based on the definition of the problem and th e results of the Impact Assessment of the 
SIP/SCP action plan, the Ecodesign Directive is identified as a useful mandatory tool to 
address environmental externalities of products.  
However, currently the Ecodesign Directive co vers only energy using products. But, energy 
using products are only respons ible for 31-36% of the environmental impacts studied by 
Labouze et al (see Table 2). Thus the identified market failures are currently not necessarily 
adequately addressed for other products that cau se the majority of environmental impacts. 
                                                
 
9 Based on Labouze et al (2003) 
 
EN 14   EN Table2 External costs of en vironmental impacts per year10 
  per capita (€) EU- 27 (bn €) % of total 
  min max min max Min max 
Energy using  
Products 69.6 341.6 33.2 167.9 31% 36% 
Other products 149.3 604 73.7 297.9 69% 64% 
Source: Labouze et al (2003) 
2.2. EU's right to act 
2.2.1. Treaty establishing the European Community  Article 94 & 95 of the EC Treaty state that the Council shall adopt the measures for the 
approximation of the provisions laid down by law, regulation or administrative action in 
Member States which have as their object the establishment and functi oning of the internal 
market. This applies to all aspects of pr oduction, products and consumption in the EU.  
2.2.2. Policy background 
The possible amendment of the Ecodesign Direct ive is part of the SIP/SCP Action Plan.  
2.2.3. Subsidiarity and EU added value  
The subsidiarity principle applies insofar as  the proposal does not fa ll under the exclusive 
competence of the Community.  
The objectives of the proposal ca nnot be sufficiently achieved by the Member States for the 
following reason: 
To leave the setting of ecodesign requirements fo r products to the Member States would lead 
to divergent national provisions  and procedures having similar objectives that would generate 
undue costs for industry and constitute obstacles  to the free movement of goods within the 
Community.  
Community action will better achieve the objectives  of the proposal for the following reasons: 
Acting at the Community level is  the only way to achieve the obj ective of the proposal while 
ensuring that the requirements for products pl aced on the market are equal in all Member 
States, thereby ensuring the free move ment of goods in the Community. 
The scope of the proposal is limited to new products placed for the first time on the 
Community market.  
Action at the Member States level is unlikel y to address environmental problems either 
efficiently or effectively. The impacts of clim ate change and air and water pollution are of a 
global or at least a cross border nature. Member States may fail to take into account the 
                                                
 
10 EuP are the grouping of space heating, EuP domestic appliances, appliances and lights, water heating, 
cooking and EuP IT. Since space heating impacts can be solved both by improving the energy 
efficiency of heaters and by impr oving the energy effici ency of the insulation, the environmental 
impacts of space heating have been divided in 60% for EuP and 40% for non-EuP. The division is based 
on the estimation that up to 40% of the heating requirements can be saved by installing better insulation 
source:Ecofys (2002) 
 
EN 15   EN effects of domestically generate d pollution that creates impact s outside national borders and 
therefore carry out insufficient abatement. 
3. O BJECTIVES :  
The General objective of this proposal is the same as the overarching one for the SIP/SCP 
Action Plan: To allow industry to transfor m environmental challenges into economic 
opportunities by fostering sustaina ble production and consumpti on on the basis of a strong 
framework for product policy. 
This proposal seeks to contribu te to the general objective by aiming to reduce environmental 
externalities through broadeni ng the scope of produc ts covered by an integrated product 
policy (Specific objective). 
As the impact assessment on the Action Plan on SCP/SIP has shown, the preferred way to 
implement an enhanced Integrated Product Polic y is to extend the sc ope of the Ecodesign 
Directive to cover additional product groups. Th e operational objective is therefore to extend 
the Ecodesign Directive such that  products can be included which present signific ant potential 
for improvement in terms of their environmen tal impact without entailing excessive costs 
(Based on the article 15 of Ecodesign Directive) 
4. P OLICY OPTIONS  
The policy options analysed in this impact assessment only look into the most appropriate 
product scope for the Ecodesign Directive. Th e only amendment proposed to the directive 
will be related to the product scope. No cha nges are necessary for the procedures of the 
implementation of the Ecodesign Directive.  
The impact assessment does not need to consider a voluntary approach or self-regulation as an 
option: Article 17 and annex VIII of the Ecodesi gn Directive obliges the Commission to look 
into the option of a voluntary a pproach or self-regulat ion in the process of the adoption of an 
implementing measure for a specific product. In deed, annex VIII of the Ecodesign Directive 
sets out the criteria for the admissibility of self-regulatory initiatives as an alternative to 
implementing measures. Criteria are ope nness of participation, added value, 
representativeness, quantified a nd staged objectives, involvement  of civil society, monitoring 
and reporting, cost-effectiveness of administering a self-regulat ory initiative, sustainability 
and incentive compatibility. In general, the im pact assessments of the implementing measures 
will also consider whether labelling the product category could be a valid alternative to minimum requirements.  
Regardless of the option taken, the Directive, as  do New Approach related Directives provides 
for the use of mandated harmonised standard s giving presumption of conformity to 
requirements of the Directive. The EU encourages  that standards are developed at global level 
(Vienna and Dresden agreements) and there is sc ope for making use of ad equate international 
standards. However, the need for such standa rds is determined at the time of developing 
implementing measures for specific products. 
The three options identified for extending the scope are: Option 1 : No Policy change (baseline) 
Under this option, the scope of the Ecodesign Directive would re main as it is. The work to 
develop implementing measures for the priority  products identified in the directive will be 
continued. For street lighting products, office lig hting products, stand-by and off-mode losses, 
external power supplies and simple set top boxes  implementing measures would be adopted in 
 
EN 16   EN 2008. For the other priority products  identified in the directive the technical studies preparing 
the implementing measures woul d be completed as planned.11 The working plan that brings 
together and complements available informati on and arguments as to which products should 
be included among the indicative prio rities would be adopted swiftly. 
Option 2 : Extend the Ecodesign Directive beyond ener gy using products but the exclusion for 
means of transport would be maintained (art. 1.3) 
Under the second option, the scope of the Ec odesign Directive would be extended beyond 
energy using products but the current exclus ion for means of transpor t, specified in art 1.3, 
would be maintained. This impact assessment  presents the availabl e evidence to inform 
policymakers on which product groups could be envisaged under such extension. As this is 
based on preliminary screening exercises, this  must not exclude other product groups that 
need to be evaluated as well. As this is base d on preliminary screening exercises, this does not  
exclude further product groups to be evaluated a nd to be considered under this, or a following, 
extension . 
The implementing measures and the working pl an of the baseline scenario would be 
implemented without delay. 
After the adoption of the amended Ecodesign Dir ective by the EU the working plan would be 
updated or extended to cover products beyond en ergy using products while maintaining the 
exclusion of means of trans port. Based on this working plan, technical studies for 
implementing measures per product group woul d be launched. Based on these technical 
studies the Commission would prepare implementing measures for specific products. 
(4) Option 3 : Extend the scope beyond energy using products including means of 
transport 
The justification to include means of transport would be that means of transports have very 
significant environmental impacts.  
Under this Option the scope of the Ecodesi gn Directive would be extended beyond energy 
using products and the exclusion of means of transport, curren tly specified in art 1.3, would 
be deleted.  
The implementing measures and the working pl an of the baseline scenario would be 
implemented without delay. 
After the adoption of the amended Ecodesign Dir ective by the EU the working plan would be 
updated or extended to cover products beyond  energy using products. Means of transport 
could also be taken up in the working plan. Ba sed on this working plan, technical studies for 
implementing measures per product group woul d be launched. Based on these technical 
studies the Commission would prepare implementing measures for specific products. 
5. A NALYSIS OF IMPACTS  
To analyse the expected impacts of extending the scope of the EuP, first the environmental 
impacts of the options are identified based on available information. The analysis is carried out at the level of broad product categories for which ecodesign can be applicable. The aim is 
to identify whether an extension of the scope of the framework directive could be beneficial 
or not. Second, it is investigated whether the Ecodesign Directive could apply to the product 
category. This is done by looking at the comple mentarity of the Ecodesign Directive with 
                                                
 
11 http://ec.europa.eu/energy/demand/legislation/doc/planning.pdf 
 
EN 17   EN existing legislation and by looking at the appl icability of the concepts of the Ecodesign 
Directive to the product group. Finally, indicative potentials in terms of environmental 
improvement and economic and social im pacts are assessed for the 3 options. 
Changing the scope of the Ecodesign Directive does not have direct impacts since the 
Ecodesign Directive is a framework Directive.  The environmental, economic and social 
impacts are linked with the implementing me asures for specific product groups. These 
implementing measures are adopted by the Co mmission in a comitology procedure. As the 
current Ecodesign Directive already mentions , before implementing measures are adopted 
stakeholders will be consulted and a specific impact assessment will be made by Commission 
services. All results presented in this document are illustrative of the impacts that could be 
reaped by having implementing measures fo r products of the different options. 
Moreover, it is worth stressing that the impact s of the implementing m easures would only be 
realised in the long run. It takes time to de velop implementing measures because it is done 
product by product and are only adopted af ter a thorough policy making process.  
Finally, it should be emphasised that for any im plementing measures that  could be adopted in 
the future, a much more detailed analysis will be  carried out, as is already now the case for 
implementing measures under the Ecodesign Directive.  
Option 1: No Policy change (baseline) 
In this section evidence is presented on th e environmental impacts of energy using products, 
then the potential of energy using products to reduce CO2 emissions is discussed, finally an 
assessment is given of the environmental impact of energy using products beyond CO2 
emissions. The assessment of the environmenta l improvement potential and the economic and 
social impacts of the three opti ons is undertaken in a later sect ion and summarised in Table 8 . 
The baseline does not include th e expected impact of the Energy and Climate change package 
on the improvement of the energy efficiency. 
The Emission Trading Scheme (ETS) forces producers to buy emission rights for their 
production related CO2 emissions. It is likely th at producers would at least pass through some 
of these costs to consumers. These increased co sts will to some extent change the behaviour 
of consumers. To model these pass through e ffects and their impact on consumer behaviour 
requires very complicated modelling and is bey ond the scope of this impact assessment. One 
of the most likely direct effects is a higher electricity price. This electricity price will make energy savings products even more beneficial . Consumers would rationally react to higher 
electricity prices by saving en ergy by for example buying more energy efficient appliances. 
However, as demonstrated in the problem  section (and in the impact assessment 
accompanying the SCP/SIP action plan) and also recognised in, for example, the Stern Report, product policy can complement the ETS since it solves some market failures not 
directly addressed by ETS, in particular relating to information asymmetries, bounded 
rationality and principal agent problems. For th e comparison of the different options it seems 
that not including ETS in the baseline does not  change the comparis on between Option 1 and 
Option 2. For both a higher electricity price seems the most significant impact of ETS. However, some means of trans port under option 3 are not directly  affected by the electricity 
price. Therefore, Option 3 seems less affected by ETS than option 1 and 2.  
The renewable energy targets of the Energy and Climate Package will decrease the CO2 
content of electricity producti on. This will make the CO2 sa vings of energy efficiency 
measures smaller. However, there seems again no difference for the comparison of option 1 and 2 concerning the impact of the renewable energy targets.  
 
EN 18   EN Based on Labouze et al (2003), th e environmental impact of en ergy using products is between 
31% and 36% of all impacts studi ed. See table 3. It is to be stressed that due to the pre-
selection, as done by the La bouze study, of product groups th at are commonly understood to 
have a high environmental impact, many of  which are energy using products, these are 
overrepresented. Important meta groups of pr oducts including food ar e under-addressed. That 
means that the true contribution of EuPs to the overall environmental impact is lower than approximated, i.e. the importance for extendin g the EuP Directive to non EuP products is 
higher than found by that study. Fu rthermore, the study of Labouze does not differentiate 
between different production processes. This is obviously especially re levant for non-energy 
related products, which are dominated by the production phase. Considering this additional argument it can be concluded that the relativ e share of non energy using products among the 
overall impact is much higher than the stated ca. 66%. 
Table 3 Environmental impacts of en ergy using products, yearly values 
  per capita (€) EU-27 ( bn €) % of total impact 
Product Min max min max min max 
Space heating12 24.6 111.6 12.18 55.02 11% 12% 
EuP domestic appliances 16 101 7.7 49.5 7% 11% 
Appliances and lights 13 58 6.2 28.4 6% 6% 
Water heating 8 38 3.9 18.9 4% 4% 
Cooking 4 16 1.7 7.6 2% 2% 
EuP IT 3 17 1.5 8.5 1% 2% 
Total EuP 68.6 341.6 33.18 167.92 31% 36% 
Source: Labouze et al (2003) 
Energy using products are responsible for a subs tantial share of greenhouse gas emissions and 
have a demonstrated improvement potential. The preparatory studies for the implementing 
measures of specific products have largely c onfirmed the environmental savings potential and 
have demonstrated that the minimum requirement s could lead to signif icant monetary savings. 
Indeed, the studies for the implementing meas ures of the Ecodesign Directive have shown 
that for boilers and water heaters a mix of ec odesign, installation and labelling requirements 
would result in yearly net sa vings of €45 billion as of 202013. In addition, extrapolations based 
                                                 
12 Since space heating impacts can be reduced both by th e improving the energy e fficiency of heaters and 
by improving the energy efficiency of the insulation, the environmental impacts of space heating have 
been divided in 60% for EuP and 40% for non-EuP. The division is based on the estimation that up to 
40% of the heating requirements can be saved by  installing better insulation source:Ecofys (2002). 
13 See p 32. of R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of 
Boilers (2007), Task 7, p. 39 and R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of Water Heaters (2007), Task 7. And see p 39 of R. Kemna, M. van Elburg, W. Li, 
R. van Holseijn. Preparatory study on the Ecodesign of Boilers (2007), Task 7, p. 39 and R. Kemna, M. 
van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of Boilers (2007), Task 7 
 
EN 19   EN on a recent study by McKinsey di scussed in Annex II seem to  confirm that significant 
amounts of CO2-equivalents can be saved while saving money to the consumer.  
For other significant environmental parameters  the reduction potential for energy using 
products is less significant. Table 4 below shows the share of CO2-equivalent related costs in 
the cost of total exte rnalities for energy using products. Th e share of cost related to CO2-
equivalents in total environmental cost is between 44% and 86%. It could reach 90% for 
specific energy using products such as space heating and water heating.  
Table 4 Share of Greenhouse gases in enviro nmental impacts for energy using products, 
yearly values 
  Per capita (€) % of total external costs for 
considered products14 
Product Min Max min max 
Space heating 22.2 56.6 90% 51% 
EuP domestic appliances 13 32.4 83% 32% 
Appliances and lights 11 28.9 87% 50% 
Water heating 8 19.5 99% 51% 
Cooking 3 7.9 86% 51% 
EuP IT 2 6.1 65% 35% 
Total EuP 59.2 151.4 86% 44% 
Total Products 169 416 77% 44% 
Source: Labouze et al (200 3) 
Conclusion 
The main conclusion of this section is that the current possible coverage of the Ecodesign 
Directive has a significant pot ential to reduce CO2 and other greenhouse gas emissions, by far 
the most significant environmental impacts of energy using products. In the section on 
environmental impacts below, summarized in Table 8, it will be demonstrated that the 
potential of ecodesign for en ergy using products to reduce other environmental impacts 
beyond CO2 is more limited. 
                                                 
14 It is to be stressed that the calculation of extern al costs necessarily overestimates the relevance of CO2 
as many other environmental impacts are not included, e.g. land use (e.g. for agriculture, mining, 
transport, housing) opposed to nature, which is in between understood to be of similar relevance as 
climate change. 
 
EN 20   EN Option 2: Extend the Ecodesign Directive beyond energy using  but the exclusion of 
means of transport would be maintained (art. 1.3) 
In this section evidence is presented on the ap plicability of the eco-d esign directive for non-
EuP and the environmental impact of all products, except means of transport. The assessment of the environmental improvement potential and the economic and social impacts of the three 
options is undertaken in a later se ction and summarised in Table 8.  
Table 5 shows the products that, based on a pr eliminary screening in Annex III, satisfy the 
requirements of art 15.2 of the Ecodesign Direc tive. These product groups are presented for 
illustrative purpose only and do not imply that the European Commission would take them up 
in the Working Plan. Indeed, the analysis done here is proportionate for this impact assessment. To select the products for the Working Plan the Eur opean Commission would 
consult stakeholders and check the requirements of art 15.2 in much more detail before taking 
a policy decision on which products  to include in the Working Plan. For example, the product 
groups referred to in the below table are quite broad. For the working plan the product 
definition would be narrower such that a much  more precise judgment could be made whether 
to include a product in the Working Plan or not . Moreover, the inclusion of a product in the 
Working Plan does not necessarily imply that an implementing measure would eventually be 
adopted for that product by the European Commission. 
Based on a preliminary screening , the products that satisfy  art 15.2 of the Ecodesign 
Directive would be construction products, textil es, water using products and furniture. These 
products account for 22-25% of the environmen tal impacts studied by Labouze et al (2003). 
As already discussed this is however underest imated (see in above section on Option 1).  
Table 5 Environmental impacts of non-en ergy using products excluding means of 
transport, yearly values 
  per capita (€) EU-27 ( bn €) % of total impact 
Product15 Min max Min  max min  Max 
Space heating16 16.5 74.4 8.12 36.68 8% 8% 
Textiles  11.6 67 5.7 32.9 5% 7% 
Building structure 11 51 5.4 24.8 5% 5% 
Water supply17  3.5 42 1.7 20.5 2% 4% 
Furniture 3.3 14 1.6 6.9 2% 1% 
Total 45.9 248.4. 22.5 121.8 22% 25% 
Source: Labouze et al (2003) 
                                                 
15 To avoid double counting water heating has been omitted from this list although more resource efficient 
water using apparatus also impact on the water heating requirements. 
16 See footnote above on how space heating has been divided in an EuP part and a construction part. 
17 Although water supply is not a product, eco-design measures on water using products could reduce the 
demand for water and thus alleviate the environmental impact of water supply. 
 
EN 21   EN Important impacts can be expected from the inclusion of construction products such as 
windows and insulation for refurbishings no t covered by the Energy Performance of 
Buildings Directive. For construction products , implementing measures could improve the 
insulation capacity for example by setting a maximum U-value according to the intended 
purposes. U-values summarise the capacity of a material to retain heat, the lower a U-value 
the better the insulation capacity. 
Also other categories can have significant impact s. For water using products examples of eco-
design measures are:  
• Sensors such that the water stops fl owing in the absence of movement.  
• Infusion of air into water to decrease the wa ter content per volume un it. Infusing air into 
water allows saving water w ithout changing the functionali ty of water using products. 
• Toilettes with a dual flush such that the consum er can choose to flush 4 or 6 liters of water. 
• The main benefits of ecodesign for water us ing products would be a reduction in total 
water use of 5.2%. Moreover, less hot water spent by shower implie s also less energy 
needed to heat it, which would save 0.20-0.23%  of total final energy consumption in the 
EU-25 which corresponds to 18.2 - 21.7 Mt CO2 emissions saved per year. Reducing water use would also lead to the reduction of  environmental impacts of water supply. This 
reduction potential would be reap ed at a rate of 3% a year
18, at low or no extra costs.19 See 
Annex IV for more details. 
Unfortunately is the Labouze study is limited in scope; while more advanced studies such as 
EIPRO find other relevant non- energy related products with very high impacts . Some 
environmental impacts are not ap propriately covered as the data  used by Labouze et al (2003) 
was limited e.g. regarding a number of releva nt emissions (e.g. human and ecotoxicity; as 
stated by the authors). As a result; products wi th a higher relevance in  these areas are poorely 
represented in the overall results (e.g. paper produc ts). Due to lack of data or incomplete data 
(especially for the production stag es as can be seen in the an nex of the study), the impact of 
non-energy using products is a dditionally underestimated.  
Possible large improvement potentials in this ar ea will require further investigation of these 
products.  The Ecodesign Directive encourages self regul ation as an alterna tive to implementing 
measures (art 17). The indicative criteria for th e admissibility of self-regulatory initiatives as 
an alternative to an implementing measure in th e context of this Directive are: Openness of 
participation; Added Value; Representati veness; Quantified and staged objectives; 
Involvement of Civil Society; Monitoring and re porting; Cost-effectiveness of administering a 
self-regulatory initiative; sustainability and in centive compatibility. Several sectors could be 
interested in self-regulation.  
Conclusion 
In summary, this section shows that there are non-energy using products  that would meet the 
requirements of art 15.2 of the Ecodesign Direct ive. Moreover, for many t of these products 
there is a clear potential for ecodesign measures th at appear to be cost effective. Below, see 
Table 8, evidence will be presented that overa ll environmental improvements are substantial 
as well. 
                                                
 
18 A replacement rate of 3% is the rate commonly us ed for construction products. This replacement rate 
assumes that all construction products ha ve an average life time of 33 years. 
19 See annex IV and footnote 75. 
 
EN 22   EN (5) Option 3: Extend the scope beyond energy usin g products including means of 
transport 
This section presents evidence on the environmen tal impact of means of transport. Then the 
potential of these products for reducing CO 2 emissions is discussed. In addition, it is 
discussed whether the Ecodesign Directive is the appropriate framework to regulate the 
environmental impacts of means of transport. This exercise is done separately for road 
transport and other means of transport. The assessment of the environmental improvement 
potential and the economic and social impacts of  the three options is undertaken in a later 
section and summarised in Table 8.  
Table 6 shows that the environmental impact of  means of transport is between 23% and 26% 
of all impacts studied.  
Table 6 Environmental impacts of me ans of transport, yearly values 
 per capita (€) EU-27 (bn €) % of total 
impact 
Product min max Min max min max 
Personal cars 32 90 15.8 44.1 15% 9% 
Goods transport 20 100 10.0 49.2 9% 11% 
Transport services 5 28 2.5 13.6 2% 3% 
Total means of transport 58 217 28 107 26% 23% 
Source: Labouze et al (2003) 
These figures show that the environmental impacts of means of transport are sizeable. 
Passenger cars account for most of the environmental impacts.  Ecodesign measures can be 
taken for the overall vehicle or for the engine  and transmissions. For the overall vehicle one 
can improve the aerodynamics, optimise the weight of the car or reduce the rolling resistance 
of the tyres. For the engine and transmissions improvements th e most promising technologies 
that exist today reduce the internal friction in engines and improve thermal management. 
Goods transport also has an important share of  environmental impacts. Ecodesign measures in 
light commercial trucks, reduction of internal  engine friction and improved aerodynamics are 
the two most cost effective ones. For medium  to heavy commercial vehicles (trucks and 
busses) the main design lever is improvements of the power train.For trains, measures to 
improve the energy recovery when breaking, li ghtweight modular construction and two-level 
carriages are available design improvements that  would abate CO2. In air transportation one 
needs to further optimise the construction of planes as regards materials application and 
engine efficiency. To improve the environmen tal performance of existing planes one can 
retrofit them with winglets or reduce the weight  of the seats used. Finally, transport services 
have a small contribution to environmental impacts.  
In the next stage it is investigated whether the cost effective level of abatement will be 
reached by forthcoming legislation and whethe r the Ecodesign Directive is the appropriate 
legislative tool for means of tr ansport. This is done for vehicl es first and then for the other 
means of transport. 
 
EN 23   EN Vehicles 
Road transport accounts for 73% of tota l energy demand for means of transport20. 
The proper functioning of the Internal Market for vehicles is based on the EC Type-Approval 
System. This system provides for market access throughout the EU for new vehicles 
complying with technical requirements relating to  health, safety and environmental protection 
provided by a wide range of Directives and Re gulations. Compliance with the legislation is 
assessed before the vehicles are placed on the market.  
With regard to the environmental performance of motor vehicles existing Community policies 
largely address two main issues:  
• Pollutant emissions from vehicles  (including Nitrogen Oxid es, Particulate Matter, 
Carbon Monoxide, etc) are regulated thr ough the so-called Euro standards, 
providing limit values for the emission of  these pollutants fro m new vehicles. The 
Euro standards are becoming more stringe nt over time to reflect the increasing 
need for environmental protection and to adapt to technical progress. The latest 
adopted standards are the Euro 5 and 6 standards21 for light duty vehicles and the 
Euro V standards22 for heavy duty vehicles. The pres ent Euro standard for mopeds 
and motor bikes23 is currently reviewed and th e Commission is preparing more 
stringent limit values for these vehicles. 
• CO 2 emissions from cars  are addressed in an integrated approach. A proposal for 
the main regulation of that approach was adopted in December 2007 and is 
currently being discussed in Council and Parliament. The regulation would 
introduce CO 2 emission limits for manufacturers of 120 g CO2 per km for the 
average new passenger car fleet in 2012.  Several other pr oposals further 
contributing to reduced CO 2 emissions are in prepara tion. One example is the 
upcoming proposal on rolling resistance of  tyres and tyre pressure monitoring 
systems, expected to be adopted by th e Commission during the second quarter of 
2008.24 Other types of vehicles (such as li ght commercial vehicles, trucks and 
busses and motorbikes) do not have bindi ng CO2 targets yet. The Commission is 
in the process of evaluating suitable m easures and test methods but no decisions 
on the principles have been taken so fa r. In principle, the Ecodesign Directive 
could regulate this. 
In addition to these two ma jor groupings, there are severa l other community policies 
addressing the environmental impact of motor vehicles. These include the Directives on end-
of-life-vehicles (recycling)25 and the use of certain refriger ants in air-conditioning systems26.  
With regards to pollutant emissions, existing t ype approval legislation is already forcing 
manufacturers to take environmental impacts in to consideration when designing the vehicles. 
With regard to CO2 emissions, manufacturers alrea dy take this aspect in to consideration when 
designing the vehicles, and will give it even more attention in the future following the 
                                                 
20 IEA (2006) Energy Technology Perspectives. 
21 Regulation (EC) No 715/2007 
22 Directive 2005/55/EC. The Commission adopted a prop osal for the Euro VI standards in December 
2007, currently discussed in Council and Parliament. 
23 Provided for by Directive 97/24/EC 
24 These two tyre related aspects of CO2 emissions from cars will be included in a wider proposal also 
covering safety aspects of motor vehicles. 
25 Directive 2000/53/EC 
26 Directive 2006/40/EC 
 
EN 24   EN adoption of the legislative proposals under discussion in Council and Parliament. For 
example, the impact assessment for a regulati on to reduce CO2 emissions from passenger cars 
specified that 600 M/tonne CO2 emissions wo uld be saved by the regulation between 2010 
and 202027. The regulation would also reduce fine particulate matter (P M) by at least 3%, 
SO2 by at least 14% and NOX by at least 4%. More over, the Euro 5 and Euro 6 standards will 
substantially reduce the quant ity of PM in the EU.  
In summary, given i) the existing regulatory requirements, ii) the measures proposed by the 
Commission but not yet adopted and iii) the balance between  environmental and safety 
criteria that are inherent to the Type-Approva l System it seems that including motor vehicles 
under the Ecodesign Directive would have a somewhat limited complementary abatement potential. Due to the complexity of existing le gislation related to environmental performance 
mentioned above it was not possible to determine further improvement potential resulting from applying ecodesign principles  to road transport vehicles. 
Other means of transport 
The potential benefits of covering other means of transport are smaller compared to road 
transport but still significant. Air transpor t accounts for 11% of total energy demand for 
means of transport, water transport for 9% and rail for 3%.
28 
There is however a number of reasons why it will be difficult to apply the Ecodesign 
Directive to means of air-, wa ter- and rail transport. The volumes sold in EU-27 for these 
products are below the threshold of 200,000 specified in art 15.2 (a) of the Ecodesign 
Directive29. Moreover, airplanes and ships are continuously entering and exiting the EU. The 
international nature of these products makes it difficult to regul ate the design in a European 
legislation. . In addition, in Air Transport the main operational co st is and will increasingly be 
fuel consumption. Thus, less fuel - and hence less CO 2 emissions - is already the main market 
driver for aircraft design. Finally, for all othe r means of transport de sign is often customer 
specific which also renders the applicability of the eco-design approach difficult. 
Conclusion 
In summary, this section shows that means of transport have a sizeable impact on the 
environment and that there is a potential to  reduce CO2 emissions. However, the potential 
abatement in the transport sector seems to be largely addressed and the limited potential benefits of applying the ecodesi gn approach to regulate means of  transport seems not to be 
proportionate in view of the difficu lties that that would engender. 
Analysis of environmental, economic and soci al trends and impacts of the three options 
In this section the environmental, economic and social impacts of the three options are further 
assessed.  
                                                
 
27 Table 5 on p 85 of SEC(2007) 1723 
28 IEA (2006) Energy Technology Perspectives. 
29 See annex IV for the statistics. Howeve r, this threshold is only indicative. 
 
EN 25   EN Environmental impacts 
To assess the potential of the options to impr ove on the significant environmental parameters, 
a simulation has been undertaken based on the EIPRO database for the EU-2530. The EIPRO 
database contains information on the environmen tal impact of 480 sectors that span the total 
economy in the EU-25. The EIPRO database cons iders the environmental impact parameters 
of abiotic depletion, global warming, ozone la yer depletion, human t oxicity, freshwater 
aquatic ecotoxicity, marine a quatic ecotoxicity, terrestria l ecotoxicity, photochemical 
oxidation, acidification and eutr ophication. Finally, these impact s are weighed and condensed 
by EIPRO into one environmental impact parame ter. The weighted cumulative environmental 
impact is primarily for presentational purpos e and for easy comparison of the options. As 
already mentioned, the methodology for setting im plementing measures allows the European 
Commission to decide which environmental im pacts it deems important and it is by no means 
bound to the analytical approach taken here. 
The simulation imposes an exogenous improveme nt in the environmental performance of 
10% or 15%. The 10% or 15% appear conser vative based on the efficiency improvement 
potential between average produc t performance and suggested minimum requirements in the 
preparatory studies currently undertaken for the Ecodesign Directive. For the worst 
performing products in a product range the improve ment potential will off course be much 
higher. Nonetheless, this simulation should be seen as illustrative. For some products, the 
10% or 15% can be assumed to be too low or too high.  
In the Directive, implementing measures are on ly considered for products with significant 
environmental impacts. Therefore, for the purp ose of the example, the simulation considered 
improvement only in the cases of products whos e environmental impact are higher than 0.5% 
of the total environmental impacts in Europe. This  is an arbitrary cut-off used for illustrative 
purposes for this impact assessment.31 Another illustrative threshold, e.g. 1% or 2.5%, could 
have been used. Other thresholds would alter the environmental improvement potential but it would not have significantly altered the compar ison of the three options . For the purpose of 
selecting the products for which implementi ng measures are considered the European 
Commission does not intend to use th is kind of quantitative threshold. 
Since the environmental impact of the agricultur al phase of the life cy cle of food is already 
covered by the principle of cross compliance under the Common Agricultural Policy, this 
stage has been excluded from the analysis.  
Based on these selection criter ia, there are 7 product categori es that qualify under option 1 
(Table 7). These product categories represent 12.6% of weighted cumulative environmental 
impacts. There are 11 additional product categorie s under option 2 that represent an additional 
15.0% of weighted cumulative environmental impacts. As argued above this is an 
underestimation. ,. Finally, one product catego ry under option 3 represents an additional 
18.8% of weighted cumulative environmental im pacts. The weights used for the aggregation 
are the ones utilised in the EIPRO study, which were reviewed by the JRC. 
                                                
 
30 The EIPRO database is probably the most comprehensive IO-table of environmental impacts of sectors 
in Europe. It contains 480 sectors and 283 consump tion sectors. It was built up by adapting US data to 
EU’s context and production structure and was calibrated to ensure that the sum of the individual 
impacts sum up to EU-25 estimated total environmental impacts, in particular in terms of CO2 
emissions. For each broad product cat egory, the whole life-cycle costs are included. The EIPRO data is 
an approximation to the quantification of the environmental impacts, which can be useful to identify major trends due to policy change s. The reference year is 2000 
31 Since this simulation is for illustrative purposes, no information is given on which product groups are 
included and which are not.  
 
EN 26   EN Table 7 Summary statistics for the products used in the simulation 
 Option 1 Option 2 Option 3 
% of total current environmental imp acts covered 12.6% 27.6% (+15%) 46.4% (+33.8%)
Number of product categories 7 18(11) 19(12) 
In brackets the differences to the baseline option are represented. 
The results of the simulation are shown in Tabl e 8 below. These results are illustrative.  
Table 8 Annual environmental effect of improvi ng the environmental impact of selected 
products by 10% in 202032 33 relative to current products 
Category Option 1 Option 2 Option 3 
Abiotic depletion 0.0% -9.5% -9.9% 
global warming  -2.5% -5.5% -7.4% 
ozone layer depletion  -0.1% -2.4% -2.5% 
Human toxicity  -0.3% -2.5% -5.4% 
Freshwater aquatic ecotoxi city  -0.1% -0.6% -0.8% 
Marine aquatic ecotoxici ty  -0.1% -3.8% -4.0% 
Terrestrial ecotoxicity  -0.2% -0.8% -1.1% 
photochemical oxidation  -0.4% -3.0% -5.5% 
acidification  -4.2% -5.2% -6.3% 
eutrophication  -1.2% -2.1% -3.7% 
Weighted sum -1.5% -4.0% -5.8% 
As can be deducted from Table 8 above, a nd under the mentioned restrictions of an 
underestimation for non energy-using products, Option 1 reduces the weighted cumulative 
environmental impact of the economy by 1.5% co mpared to the status quo today. The main 
impacts are on global warming (-2.5% of tota l) and acidification (-4.2%). For other 
environmental parameters, the impacts of option 1 are smaller. Option 2 reduces the weighted 
                                                 
32 Since the use phase of products is also assumed to be improved by 10 or 15%, the results implicitly 
assume that all products are new products. Therefor e, the results need to be interpreted as annual 
environmental improvements in 2020. The forecast  do not take into accoun t changes in economic 
structure or the climate change package.  
33 See Annex V for a definition of technical terms used in this table. 
 
EN 27   EN cumulative environmental impact by at least 4.0% compared to the status quo. Compared to 
Option 1 the additional improveme nt potential of Option 2 is  at least 2.5%. The main 
additional impacts are on abiotic depletion, global warming and marine depletion. Option 3 
reduces the weighted cumulative environmenta l impact of the econom y by 5.8% compared to 
the status quo. The additional improvement pot ential of Option 3 over option 1 is -4.3% and 
the main additional impacts compared to Option 1 are on abiotic depletion, global warming, 
human toxicity, marine aquatic ecoto xicity and photochemical oxidation.  
The environmental improvement potential of the products, regardless of the option, will be 
realised over the life cycle of the product. This implies that this improvement potential is 
gradual and for durable produc ts will only be reaped over the somewhat longer term. 
The conclusion of this section is that Op tion 3 could have the biggest environmental 
improvement potential. However, since most of the additional improvement potential of 
Option 3 compared to option 2 is already addr essed by forthcoming legislation, Option 2 and 
Option 3 would have similar environmental improvement potential. 
Competitiveness  
This section looks into the competitiveness aspe ct of extending the Ecodesign Directive. A 
general discussion is followed by a discussion of the internal competitiveness aspects and the 
competitiveness impacts for SMEs. 
Art 15.5 (d) imposes on the European Commissi on that implementing measures for products 
cannot have a significant negative  impact on industry’s competi tiveness. This implies that the 
European Commission needs to assure that impl ementing measures are only set such that this 
condition is respected. Art 15.4 (b) clarif ies that the following dimensions of 
“competitiveness” need to be looked at: SMEs, innovation, market access and other international competitiveness aspects, and cost and benefits.  
Cost and benefits 
It is not straightforward to conduct an analysis of the co st and benefits of potential 
implementing measures without knowing in deta il which products would be covered and how 
minimum requirements would be set. Besides,  the portion of the im pacts of ecodesign in 
option 3 (transportation means) not covered by  existing or planned legislation are not 
differentiable in the current datasets
34.  
However, to provide some indication of the natu re of the costs and be nefits over time of 
options 1 and 2, the same case studies (water he aters, windows) used in the SCP/SIP Impact 
Assessment, using the same sources of inform ation, were analysed in greater detail. The 
results are presented in  Tables 9, 10 and 1135 below. This analysis is illustrative only, but 
deemed appropriate for the purpos e of the current impact assessm ent. Full blown analysis of 
the costs and benefits of all potential implem enting measures is neith er proportionate nor 
feasible at this stage. A more detailed an alysis will be done when identifying the minimum 
requirements for the product groups . 
To analyse potential impacts in the two cas e studies, the period between 2010 and 2019 was 
selected. For this peri od of time, discounted upfront cost s of least life-cycle costs products 
were compared with the discounte d upfront cost of products cons idered to be the “baseline”. 
                                                 
34 For example, the case of more performing tyres, a product that could be covered by Ecodesign, is 
already considered in the Propos al for a Council and Parliament Regulation on Advanced Vehicle 
Safety and Tyres. 
35 For a detailed presentation of the analysis, see Annex VIII 
 
EN 28   EN In the simulation, it was estimated that water heaters are replaced ev ery ten years and that 
windows36 are replaced every 25 years. This implies that 4% of all windows are replaced in a 
given year. These payment flows and the benefits  (differences in energy consumption) over 
time were discounted at a rate of 4%. The resu lts are presented in terms of net flows (cost-
benefits) (Table 9). The detailed flow of poten tial cost and benefits is presented in Annex 
VIII.  
Table 9 Present value of net benefits from  the inclusion of minimum performance for 
one example of products in options 1 and 2 (in 2007 Euros) 
 Year 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Total
Water 
heaters 
"extra 
small" -195 -99 -18 49 104 148 184 211 233 248 865 Option 
1 
Products 
Water 
heaters 
"extra large" 684 1563 2277 2848 3297 3640 3894 4072 4185 4244 30704
Windows 
(50% 
double 
glazing) - 
1,020  - 708  - 418 - 150 98  327 539 734  913  1,077 1392 Option 
2 
Products 
Windows 
(only 
double 
glazing) -
2040 -
1416 -837 -300 196 655 1078 1468 1826 2154 2784 
Source: own estimations from the same sources  used in the SCP/SIP Impact Assessment 
In the case of water heaters, it appears that there are already appl iances in the market that are 
not only more attractive from a life-cycle persp ective but also from the up-front costs (the 
“extra-large” case). This implies that benefits  would be derived from  the beginning of the 
application of the implementing measure. In the other case (extra small water heaters and 
windows with different proportions  of double glazing in the refurb ishment) the up-front costs 
are higher than the ones of less efficient produ cts, implying that the aggregate investment 
would pay-off only in the longer term.  
In terms of energy savings, the penetratio n of more performing products would induce 
important savings in all the cases (Table 10). 
                                                 
36 It is estimated that half of the existing windows have already been replaced by more performing ones. 
Therefore the analysis concentrates only on the proportion s till to be refurbished. This analysis is done 
only for illustrative purposes. In order to simplif y the analysis, only double glazed windows are 
associated with more efficient insulation performance. However, the Commission is aware that double 
glazed windows are not need ed for every intended purpose in th e EU for the purpose of improving 
insulation. Single glazed windows have also improve ment potential in terms of insulation, which can 
contribute to energy savings. The estimates pres ented consider two replacement shares with double 
glazed windows: 50% and 100% of  yearly refurbishment.  
 
EN 29   EN Table 10 Energy savings per year in GWh 
 Year 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Total 
Water 
heaters 
"extra 
small" 891 1782 2673 3564 4455 5346 6236 7127 8018 8909 49001 Option 
1 
products 
Water 
heaters 
"extra large" 4007 8014 12022 16029 20036 24043 28050 32058 36065 40072 220396
Windows 
(50% 
double 
glazing) 1669 3337 5006 6674 8343 10011 11680 13348 15017 16685 91769 Option 
2 
products 
Windows 
(only 
double 
glazing) 3337 6674 10011 13348 16685 20022 23359 26696 30034 33371 183538
Source: own estimations from the same sources  used in the SCP/SIP Impact Assessment 
In terms of CO2 emissions, each of these pr oducts would increasingly reduce the emissions 
associated with their use (Table 11). 
Table 11 emissions savings per year (M t of CO2) 
 Year 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Total
Water 
heaters 
"extra 
small" 1 1 2 2 3 4 4 5 5 6 33 Option 
1 
Products 
Water 
heaters 
"extra large" 3 5 8 11 14 16 19 22 25 27 150 
Windows 
(50% 
double 
glazing) 1 2 3 5 6 7 8 9 10 11 63 Option 
2 
Products 
Windows 
(only 
double 
glazing) 2 5 7 9 11 14 16 18 21 23 126 
Source: own estimations from the same sources  used in the SCP/SIP Impact Assessment 
It is clear that addressing both energy-usi ng and non-energy using products could improve 
their performance and would complement th e Climate and Energy package adopted by the 
 
EN 30   EN Commission in January 2008. As menti oned above, these are only examples37 of the potential 
direction of the impacts and do not imply any commitment to introduce implementing measures for these products. A more thorough an alysis would be undert aken in the impact 
assessment of each implementing measure. 
In addition, it needs to be reminded that the provi sions of Art 15.5 (d) require such analysis by 
the European Commission in the Impact Assess ment of the implementing measures. The kind 
of analysis that would be unde rtaken at the product level:  
• The Commission will look at how  costly it is to redesign th e manufacturing process for 
those producers whose products would not meet  the minimum requirements. Based on this 
information it will take a decision on the timing of the phasing in of the minimum 
requirements. 
• The Commission will look at the variable cost of adjusting the product in question when 
determining the level of the minimum requirements. 
• The Commission will look at th e amount of existing stock of products. This information 
will be taken into account when deciding the timing of the phasing in of the minimum requirements.  
Some general competitivene ss aspects of the options 
The extension of the Ecodesign  Directive should allow th e introduction of implementing 
measures for products with signi ficant environmental impact and significant potential for the 
improvement of that environmental impact at  the lowest economic cost to society. By 
maintaining the product scope of Option 1, the full reduction potential which can be reaped at 
no extra cost or even at a gain to private indivi duals, is not reached. If one would try to reduce 
certain environmental impacts with the curren t product scope nothing guarantees that this 
happens in a cost effective way. For example, water efficient appliances such as showers, taps, washing machines and dish washers all offer households possibilities for water saving
38, 
equally diminishing the energy required to h eat the water. Installing water efficient 
appliances, e.g. by eco-design, for all of them  can reduce the use of a household from 280 
l/day today to 167 l/day, represen ting total savings of 41% of household water use. Yet, under 
the current scope of the eco-design directive, only the water use of washing machines and 
dish washers can be regulated. Installing water efficient appliances for energy using products 
only has a potential to reduce the water use of a household by 12 l/da y, representing total 
savings of 4% of household wa ter use. If one would need to go beyond 4% savings for 
households and the scope of the Ecodesign Di rective would be only energy using products, 
the current technology would not suffice and it w ould be very costly to reach this higher 
target. On the other hand, with an extende d scope one can go beyond 4% reduction with 
existing technologies at lo wer additional cost.  
International Competitiveness 
As already stated before, a re gulatory dialogue with the main trading partners is ongoing on 
the implementing measures of the Eco-design  Directive. Moreover, manufacturers and 
countries from outside the EU can participate in the consultation forum for implementing 
measures of specific product groups.  
                                                 
37 Another examples can be found in Annex II, in which a rough extrapolation of the results of a study 
prepared by McKinsey for BDI is presented. 
38 Numbers based on DG ENV (2007) EU Water saving potential study done by ecologic 
 
EN 31   EN The Ecodesign Directive is an Internal Market Directive and will only apply to products 
placed on the market in Europe. Regardless of which options are taken, imported products would need to comply with the minimum re quirements, while exported products would not 
need to comply with the minimum requirements. Thus, minimum requirements guarantee a level playing field both within and outside Europe. It should be  noted that if these two level 
playing fields are sufficiently different it might be necessary  for manufacturers to have two 
separate production lines, one for products co mplying with minimum requirements in the EU 
and one for the rest of the wo rld. This creates addi tional costs. However, all manufacturers 
willing to be present on both markets will incu r these costs no matter where they are located. 
Therefore there should be no competitive disadvantage for EU producers on export markets unless foreign producers decide to only serve the rest of the world and thus to save costs for a 
second production line. Given the substantial size of th e EU market this is not particularly 
likely. It has to be pointed out th at if tighter standards in the EU are considered desirable and 
the rest of the world does not adopt them, this additional cost is unavoidable. 
Art 15 requires the European Commission to look into the international competitiveness issue 
when considering implementing measures. In designing the implementing measures carefully 
taking into account international competitiven ess, the European Commission can avoid a 
distortion of the international competitive balance.  To achieve this it would need to take into 
account whether manufacturers are active on the domestic market versus internationally, fixed 
versus variable adjustment cost for manuf acturers and access to technology. For the different 
options it seems that all goods in option 1 and 3 are traded internati onally. Some products in 
option 2 such as textiles are internationally traded goods whereas other products such as windows are not traded internationa lly to a large extent. Therefor e, for products of option 2, it 
will be important to assess on a case by case basis whether international competitiveness is an issue.  
To the extent that demand for environm ental products is on the rise globally
39, new export 
opportunities might arise for European and fore ign products that comply with the minimum 
requirements.  
Competitiveness of SMEs 
It is also worthwhile to look into the impact s that the Ecodesign Directive will have on SMEs. 
The Ecodesign Directive can have important benefits for SMEs. For all SMEs, office 
machinery and equipment will become cheaper because of option 1 and heating costs for 
offices will be reduced because of option 1 and option 2.  
Only 12% of all SMEs are in the manufacturi ng sector. Those SMEs ar e responsible for 26% 
of all turnover for SMEs. Also for SMEs in  the manufacturing sector there are important 
benefits. All motors purchased by SMEs will be  cheapest over the life cycle under option 1. 
This implies that manufacturing SMEs will have a lower energy bill.  
For SMEs in the services sector there will only be benefits in terms of cheaper products over 
the life cycle. SMEs in this sector make up 88%  of all SMEs and are responsible for 74% of 
all turnover of SMEs in 2005 fo r EU-27. Therefore, for most SM Es there is no downside to 
the Ecodesign Directive under either option. More over, for some there is a considerable 
upside. For example, small retailers will have  commercial refrigerators that are more energy 
efficient.  
                                                 
39 See Roland Berger (2007) Elements  of a European Ecological Industrial Policy Working Paper to the 
Informal Meeting of Environment Mini sters in Essen, Prepared for the German Presidency of the EU in 
2007. 
 
EN 32   EN However, some SMEs will need to demonstr ate that their products satisfy the minimum 
requirements. 
The above shows that one cannot make a genera l statement of the imp act of the Ecodesign 
Directive on the competitiveness of SMEs. Therefore, the Ecodesign Directive contains 
safeguards such that implementing measures will take into account the competitiveness of SMEs: 
• Art 15.4 (b) requires the Commi ssion to look into the issue of competitiveness for 
SMEs when preparing an implementing meas ure. Together with Art 15.5 (d) this 
implies that the Commission will consid er, if the competitiveness of SMEs 
requires it, a transitional period or a stage approach when setting minimum 
requirements and/or set the minimum re quirements taking into account SMEs.  
• Art 13.1 imposes an obligation on the Commis sion to take into account initiatives 
to help SMEs with ecodesign in the cont ext of programmes from which SMEs can 
benefit. This is for example done vi a the Enterprise Europe Network. The 
Enterprise Europe Network and other dissemination channels will encourage 
SMEs to adopt environmentally friend ly and energy efficient solutions. The 
Enterprise Europe support centres will consult and advise SMEs. Moreover, the 
action will aim at developing content for training and dissemination of tailor made 
information on the subject of energy sa ving and environmental compliance in 
SMEs.
40  
• Art 13.2 obliges Member States to ensure , in particular by strengthening support 
network and structures, that they encour age SMEs to adopt ecodesign principles. 
In summary, the implementing measures will ne ed to take into account the competitiveness of 
SMEs when setting the level and timing of minimum requirements. 
Conclusion 
This section has shown that limiting the produc t scope to Energy Using Products (Option 1), 
does not allow reaping the full reduction poten tial of environmental impacts that can be 
attained in a cost effective way. There are no indications that any of the three options would 
harm the competitive position of European manufacturers in the world. Also for the competitiveness of SMEs there is no indication th at one particular option would be more or 
less harmful for the competitiveness of SMEs. The impact assessments of the implementing measures will need to look into the competitiveness aspects in detail for a specific product. 
Social dimension 
This section looks into the social dimension of  the different options. First, it discusses the 
social implications of lower environmental impacts. Second, it discusses the short term and long term implications of th e Ecodesign Directive. Finally, the employment effects of the 
different options are discussed.  
An extension of the Ecodesign Directive will  allow setting minimum requirements such that 
products' environmental impacts are optimal over  the life cycle. Each implementing measure 
will need to weigh the gains from reducing th e environmental impact against the abatement 
cost. The abatement cost includes effects on jobs, competitiveness and affordability.  
Based on the simulations presented above one can gi ve an illustrative indication of the social 
gains due to the avoidance of externalitie s of option 1, 2 and 3. This can be done by 
                                                
 
40 Announced in the forthcoming SIP/SCP action plan 
 
EN 33   EN multiplying the environmental reduction potential by the cost of externalities.41 The gains of 
option 1 would minimally be €3 per year per capita. For option 2 and 3 the minimal gains would be respectively €9 and €13 per capita per year. 
Table 12 Cost avoided per capita per year 
€ option 1 option 2 Option 3 
min 3 9 13 
max 14 38 55 
For the EU-27 as a whole this corresponds to  minimal savings of between €1.6 billion for 
option 1, €4.3 billion for option 2 and €6.2 billion for option 3. 
Table 13 Cost avoided for the EU-27 
€ option 1 option 2 option 3
min 1.6 4.3 6.2 
max 7.0 18.6 27.0 
In a number of cases, the redu ction of externalities also generates savings, notably for 
products whose highest environmental impact occurs during the use phase. 
From a social point of view, any extension of the scope of the Ecodesign Directive might 
create difficulties for low income  households in the short term si nce it is expected that those 
products that will be removed from the ma rket because they do not fulfil the minimum 
requirements are the cheapest ones and thus most  easily affordable. However, these products 
also have higher life cycle co sts and thus permanently expos e low income households to 
budget pressure, particularly w ith respect to ener gy expenditures. The Ecodesign Directive 
would instead allow a long term  budgetary improvement for all households. Nonetheless, art 
15.5 (c) obliges the European Com mission to set implementing meas ures such that there shall 
be no significant negative impact on consumers in particular as regards the affordability and 
the life-cycle cost of the product. Therefore,  the European Commissi on will consider when 
setting implementing measures foreseeing trans itional periods or a staged approach for the 
introduction of minimum requirements and will set minimum requirements to balance 
affordability and the life-cycle cost of the product. Furthermore, short-term adjustment 
difficulties for low income house holds could be alleviated by financial measures by the 
Member States.  
Moreover, the impacts on competitiveness and th e social dimension of introducing minimum 
requirements are likely to be limited over the long run. This is due to the tendency for 
appliances to become cheaper the more applianc es are produced (economies of scale). A shift 
in demand towards higher energy efficient appliances will imply that over time the cost of these appliances will go down. The figure belo w indicates that from the 1960’s until now real 
                                                
 
41 Note that this is not entirely accu rate since the calculations are done on  the weighted impacts. A correct 
calculation would be based on the individual improvements of the environmental impacts. This is not 
straightforward since the cost factors for environmental impacts of Labouze et al (2003) do not 
correspond to the environm ental impacts of EIPRO. 
 
EN 34   EN prices of energy efficient energy using products have fallen on average. In Annex III more 
detailed figures are shown disa ggregating the price and resource efficiency effects over time.  
Figure 1 Relation between energy efficiency and prices for energy using products over 
time 
 
Source: Weiss, Junginger and Patel (2008) unpublished 
The Ecodesign Directive and employment 
Finally, one should also assess the employment effects of extending the scope of the 
Ecodesign Directive.  
The academic literature does not provide conclu sive evidence on the relationship between the 
environment and jobs. Studies by Morgenstern et al. (2002) and Berm an and Bui (2001), for 
the case of US, find no evidence that environm ental regulations have  adversely affected 
industrial employment. Other studies for the US  indicate that industries located in counties 
with stringent regulations have experienced job losses, or at the very least lower employment 
growth rates, relative to indus tries in less regulated counties42. Cole and Elliott (2007) 
examine the impact of environmental regulations on employment for the UK43. No significant 
                                                 
42 Henderson, V. (1996). Effects of Air Quality Regulation. American Economic Review, 86: 789-813. 
Kahn, M.E. (1997). Particulate Pollution Trends in the United States. Journal of Regional Science and 
Urban Economics, 27: 87-107. Greenstone, M. (2002). The Impact of Environmental Regulations on 
Industrial Activity: Evidence from 1970 and 1977 Clean Air Act Amendments and the Census of 
Manufacturers. Journal of Political Economy, 110 (6): 1175-1219. 
43 Matthew A. Cole and Rob J. Elliott (2007) “Do E nvironmental Regulations Cost Jobs? An Industry-
Level Analysis of the UK,” The B.E. Journal of Economic Analysis & Policy : Vol. 7: Iss. 1 (Topics), 
Article 28. 
 
EN 35   EN trade-off between employment and the enviro nment is found. The preferred option of the 
climate package is projected to have a +0.05% effect on employment in the EU-2744. 
Since, the Ecodesign Directive is an Internal Market Direct ive it will appl y to any product 
placed on the EU market regardle ss of the place where the goods are produced. Therefore, it 
is unlikely that delocalisation and the resulting job losses would occur as a consequence of the 
enlargement of the scope of  the Ecodesign Directive.  
However, although the effect on the total econo my might be non-negative, some industries 
can be negatively affected by en vironmental legislation. Yet, there is evidence that those 
effects are sometimes overstated initially. The effects of the US Acid Rain Programme on 
coal mining employment had originally been estimated at 13000-16000 by the year 2010. 
Current estimates are in the range of 4100 net jobs lost.45 
Finally, there is some evidence that energy effici ency measures lead to job creation in Europe. 
One study determined the employment effects of energy conservation schemes for France, 
Germany, The Netherlands, Spain and the United Kingdom46. In all countri es, the energy 
conservation schemes, both for EuP and energy saving appliances such as insulation or 
windows have been found to create employment . France has since 1974 a programme of tax 
incentives in place to favour energy saving invest ments for residential space heating. Over the 
lifetime of the Income Tax Incentive scheme  71,000 labour years have been created. For 
Germany, the employment impact of the Th ermal Insulation programme, which imposes 
insulation requirements for new buildings, is  40,100 labour years for the period up to 2010. 
The condensing boiler programme in the Netherlands, which promotes the uptake of energy 
efficient boilers, induces a total cumulative employment effect of 3,800 labour years over the 
period 1995-2010. 
The main driving force behind the positive empl oyment effect of investment in energy 
efficiency in the residential sector is the fa ct that the energy sector has rather low labor 
intensity. The resulting shift of expenditures fr om the energy sector to other sectors with 
higher labor intensity leads to  increased employment. Labor intensity is higher in the 
construction sector which needs to install energy efficient appliances than in the EuP producing goods or the transport manufacturing sect or. This would imply th at the products of 
option 2 would be the most positive for employment. 
Conclusion 
In summary, this section discussed the social  impacts of the different options. The main 
conclusions are that option 2 and 3 result in lower enviro nmental impacts which have a 
sizeable social value compared to option 1. Regardless of the option, minimum requirements for products can result in short term negative  income effects for poor income households but 
these are offset by positive income effects ove r the longer term. This is because minimum 
requirements are set such that products have the lowest life cycle cost. These long term 
benefits are general since highe r volumes for products with lo wer environmental impacts will 
result in price declines for these products. Fi nally, there is no eviden ce that either of the 
options will result in job losses. However, it wi ll be necessary that social impacts are carefully 
scrutinised in the impact assessments of the implementing measures. 
                                                
 
44 See Table III of Annex I of SEC(2008) 85/3. 
45 http://www.epa.gov/airmarkt/res ource/docs/coalemployment.pdf 
46 H. Jeeninga, C. Weber, I. Mäenpää, F. Rivero  García, V. Wiltshire, J. Wade (1999). Employment 
Impacts of Energy Conservation Schemes in the Residential Sector, project for DG TREN. 
 
EN 36   EN 6. C OMPARISON OF THE OPTIONS  
As already indicated above, th e possible extension of the sc ope of the Ecodesign Directive 
does not trigger any direct cost or benefits. Th e cost and benefits of  the Ecodesign Directive 
will only arise when an implementing measure will be set for a specific product category.  
The analysis in the previous section can be summarised in a decision table:  
Option Disadvantages for covering/limiting under 
eco-design Advantages for covering/limiting under 
eco-design 
Not extending 
beyond EuPs 1) short run negative income effect on low-
income households for some products 
2) Adjustment cost for those manufacturers 
which products initially do not meet minimum requirements. 
3) Limited environmental improve-ment 
potential even if relevant  cost benefits exist. 
 1) Significant abatement potential in terms of 
CO2 
2) The Potential for other environmental 
savings is somewhat limited: Improving the environmental impact of EuP by 10% will lead to improvements of 1.5% of the total environmental impacts. Most of these benefits are however reaped by reducing CO2 and acidification. 
2) long run positive income effect on low 
income households 
Extend scope 
beyond EuP except means of transport 1) Potential short run negative income effect 
on low-income households for some products 
2) Adjustment cost for those manufacturers 
which products initially do not meet minimum requirements 1) Significant additi onal abatement potential 
at low cost per tonne of CO2.  
2) complementary to construction products 
directive and energy performance of buildings directive 
3) Potential for other environmental savings 
is important: Improving the environmental impact of products covered by option 2 by 10% results in additional improvements of at least 2.5% of the total environmental impacts compared to option 1.  
4) Compared to option 1, the same 
environmental impact could be realised more efficiently if the products with the highest savings potential can be covered, regardless of the product category. 
5) long run positive income effect on low 
income households 
6) Employment effects could be more 
positive than for option 1 or option 3 
(6) Extend 
the 
scope 
beyond 
energy 
using 
product
s 
includin
g 
means 
of 
transpo
rt 
 1) Potential short run negative income effect 
on low-income households for some products 
2) Adjustment cost for those manufacturers 
which products initially do not meet minimum requirements 
3) Type-approval legislation for motor vehicles 
already provides for stringent requirements on environ-mental performance and an application of the Ecodesign Directive would not provide additional benefits.  
4) Current and foreseen legislation already 
covers the CO2 abatement potential for motor vehicles. The CO2 and cars proposal will save 600 Mt CO2 equivalents between 2010 and 2020. The recently adopted Euro-standards for 1) long run positive income effect on low 
income households 
1) Potential for other environmental savings 
is important: Improving the environmental impact of products covered by option 3 by 10% results in improvements of an additional 4.3% compared to option 1 and an additional 1.8% of the total environmental impacts compared to option 2. But, see point 2 of disadvantages. 
 
EN 37   EN light and heavy vehicles will also significantly 
reduce other environmental impacts. Light commercial vehicles, trucks and busses, and motorbikes remain outside the framework.  
3)Non-road means of transport are produced 
in very low volumes making the application of the eco-design framework difficult. 
 
At this stage, it can be recommended based on the available evidence to widen the scope of 
the Directive to energy-related pr oducts. While there are also st rong indications that widening 
the Directive beyond thos e products could deliver  significant benefits, it is recommended to 
carry out further investigations and further a ssess the option of including non-energy related 
products in the scope of the Dire ctive following a future review.  
7. A DMINISTRATIVE COSTS  
7.1. For Member States and the Commission 
It appears that there are two areas in which th e actions might generate administrative costs for 
Members States and the Commission. These are: 
(a) Work for defining implementing measures of  the Ecodesign Directive. The extension of 
the product scope of the Ecodesign Directive wi ll broaden the choice of product groups for 
which implementing measures can be adopt ed. Among those the products that have a 
significant environmental impact and potential for improvement will be identified and listed in the Working Plan referred to in Article 16 of the Ecodesign Directive. The eventual additional budgetary needs, resulting from the extension of the product scope will be determined by the Working Plan.  The 
potential  allocation of addition al resources must be 
compatible with existing financial programming and will be subject to the current financial 
and budgetary rules and procedures . The expected integration of the decision structures of the 
Ecodesign Directive and the Energy  Labelling Directive and the informative role of the eco-
label suggested in the SCP/SIP Action Plan will provide synergies which guarantee that 
resources are used such that implementing measures have the biggest environmental impacts at the lowest cost for the economy. 
(b) The time and costs involved cannot be quantif ied precisely but as a guideline it has been 
assumed that the implementation of the amende d Ecodesign Directive would require six full 
time equivalent work from Comm ission staff and equivalent amount s of time from officials in 
at least 10 Member States (it is unlikely that  all Member States would be involved in the 
detailed discussions). 
 Given the average annual cost of a Co mmission official (€ 117.000/year)  this 
would cost the Commission € 702 ,000. This does not include any add on for overhead costs. The 
assignment of staff for these particular tasks from existing or additional resources remains subject to resources av ailability and will be decided in th e framework of the annual resources 
allocation procedure.   
 
7.2. For Manufacturers  
Extending the scope of the Ecodesign Directive m eans that a greater number of products can 
potentially fall under ecodesign requirements. The total administrative burden impact depends 
on the number and nature of any self-regulatory standards or minimum requirements imposed by the Commission and the number of products aff ected by each standard. Therefore it is here 
only possible to provide a general indication of  the possible impacts on administrative burden. 
 
EN 38   EN For any new minimum requirement, an assessme nt of the implications on administrative 
burdens will be carried out. It should also be recalled that Article 15 para 4f of the Ecodesign 
Directive requires that an implementing measur e does not lead to excessive administrative 
burden on manufacturers. 
The Ecodesign Directive foresees procedures that  generate administrative costs for producers. 
They comprise the following elements: 
1. A CE conformity marking needs to be affi xed to the product (or the packaging and the 
documentation) and a declaration of conformity  needs to be provided by the manufacturer. 
Where information on how to install or use the product is provided to the end user, Member States can require this to be in their official language(s). (Art. 5) 
2. A conformity assessment needs to be carr ied out by the manufacturer  (or an authorized 
representative) that establishes that a product fulfills the criteria laid down in a minimum 
requirement. How this assessment needs to be carried out is specified by the implementing 
measure. The documentation relating to the conf ormity assessment needs to be kept for 10 
years for inspection and need to be in an offici al language of the EU. (Art. 8) Details on what 
documentation needs to be kept are laid dow n in annex IV to the Ecodesign Directive. 
3. Where a product is an input for the manuf acturing of a product covered by a minimum 
requirement, the producer of the input can be  required by the implementing measure to 
provide relevant information regarding the char acteristics of his product to the manufacturer 
of the final product (Article 11). The need  to use Article 11 will be assessed by the 
implementing measures. In principle Article 11 will only be used if the inputs provided are 
essential to meet the minimum re quirements for the end product.  
4. The implementing measure can require the producer to provide the consumer with 
information regarding the ecological profile of  the product and the benefits of ecodesign. 
(Article 14). Article 14 would normally not be  used since the Energy Efficiency Labeling 
Directive will normally be used to provide su ch information. See forthcoming SCP/SIP action 
plan. 
However, those producers that already have  obtained an Eco-label and/or an EMAS 
certification benefit from the presumption of conformity stated in the current Ecodesign 
Directive if the criteria of the product are assessed and the relevant standard also complies 
with the criteria set out in the relevant minimu m requirement. Thus, if an assessment of the 
product design has been carried out alr eady, duplication of costs is avoided.
  
Administrative costs on a producer level: 
Since most products under the Ecodesign Directive fall also  under other Single Market 
Directives, e.g. Machinery Direc tive, affixing the CE marking to  the product or the packaging 
and documentation should not en tail any additional cost.  
Most manufacturers also already have a mandatory  declaration of conformity and need to add 
some information specific to this Directive.  
The costs of information storage are also deemed minimal. What is costly is the generation  of 
the documentation of the conformity assessmen t. The required information comprises: 
(a) a general description of the pr oduct and of its intended use; 
(b) the results of relevant environmental assessment studies carried out by the 
manufacturer, and/or references to environmental assessment literature or case studies, which are used by the manufact urer in evaluating, documenting and 
determining product design solutions; 
 
EN 39   EN (c) the ecological profile, if required by the implementing measure; 
(d) elements of the product design specifi cation relating to environmental design 
aspects of the product; 
(e) a list of the appropriate standards referred to in Article 10, applied in full or in 
part, and a description of the solutions adopted to meet the requirements of the 
applicable implementing measure where the standards referred to in Article 10 have not been applied or where thes e standards do not cover entirely the 
requirements of the applicable implementing measure; 
(f) a copy of the information concerning th e environmental design aspects of the 
product provided in accordance with the requirements specified in Annex I, 
Part 2; 
(g) the results of measurements on the ecodesign requirements carried out, 
including details of the c onformity of these measurements as compared with 
the ecodesign requirements set out in the applicable implementing measure. 
The most costly elements of this assessment are likely to be related to the environmental 
assessment studies and the results of meas urements on the ecodesign requirements. No 
empirical data regarding the costs of an assessment is available; however the cost for 
compliance with Eco-label can serve as a benc hmark. According to the impact assessment for 
the Eco-label Regulation, they  vary between 1 000 and 10 000 Euros per product. The costs 
are believed to be clos er to the lower end, or even lower,  of the above range for the Ecodesign 
Directive: Eco-label looks at all environmenta l parameters and can regulate as much as 25 
different environmental parameters. As explai ned above, the Ecodesign  Directive would only 
impose minimum requirements for the most si gnificant environmental parameters of a 
product. This would normally imply covering on average 3 and up to 5 parameters. Moreover, 
the Eco-label Regulation requires third part y verification whereas  under the Ecodesign 
Directive self assessment is the default option. Self assessment would be typically cheaper.  
Total administrative costs: 
The total administrative costs of a minimum re quirement consist of th e individual producer 
cost multiplied by the number of products falling under the minimum requirements. This in turn depends largely on the product definition and on the market struct ure. A narrow market 
with a limited number of products and few criteria th at need to be met will  lead to a relatively 
low total administrative burden. Conversely, a br oad product definition, complex criteria and 
a high number of different products in th e market will lead to a significantly higher 
administrative burden. 
Extending the scope of products that can be co vered by the Ecodesign Di rective in itself does 
not necessarily entail that the administrative burden will be increased. From an efficiency 
perspective, reaching certain environmental bene fits will be cheaper if the products causing 
the most significant impact can be addressed rather than to c over a larger number of products 
that each of them have a minor impact. Ov erall, the impact on administrative burden is 
therefore dependent on a number of factors and it cannot be said that extending the scope of 
the Directive will lead to an increase or a decrease in administrative burden. 
8. C
OST-EFFECTIVENESS  
As already explained before, the extension of sc ope of the Ecodesign Directive has very little 
impact beyond making it possible to launch new implementing measures. The cost-
effectiveness of implementing measures will be addressed in detail pe r specific product group. 
 
EN 40   EN This will be done by preparatory technical studies , the stakeholder consultation forum (art 18) 
and the impact assessments for the implementing measures.  
Based on the analysis provided in this impact assessment option 2 is the most cost effective 
option. Within the products screened in Optio n 2 a high environmental impact that can be 
reaped cost effectively would come from energy related products such as construction 
products and water using products . Furthermore, also a number of other product groups may 
offer significant potential for cost efficient im provements, as there is evidence that their 
impact is even more significant than bot h the Labouze 2003 and the EIPRO study have 
demonstrated when looking at products such as : detergent/cleaning prod ucts, footwear/leather 
products, other food products, print-media ( books, journals, newspaper), hygiene paper, 
mattresses, batteries, and toys. Ongoing Co mmission studies will look further into the 
environmental impact and improvement potentia l of these products. Further research could 
also investigate on the environmental and economic sustainability of the use of 
concrete/cement, steel, aluminium, plastics and other important materials. These product 
groups and materials are presente d for illustrative purpose only 
There seems to be little potential for additi onal environmental improvement in the transport 
sector beyond current and planned EU legisl ation. Therefore, opti on 3 is not withheld. 
9. M ONITORING AND EVALUATION  
The Action Plan foresees regular reporting to the European Parliament. Monitoring on the 
Ecodesign Directive could provide information on the various stages of the implementation 
process of the Ecodesi gn Directive such as: 
- number of preparator y studies launched  
- number of preparatory studies finished - number of implementing measures adopted Moreover, collaboration with the working gr oup of Eurostat on Sustainable Development 
indicators is envisaged to assess  the possibility to include sta tistics on the resource efficiency 
of products for which implementing measures are developed. Eurostat could for example 
report the market share of resource effi cient products per labelling category.  
The Commission plans to collect further inform ation and evidence as regards the potential 
benefits of including non-energy related pr oducts in the scope of this Directive. 
Based on this further assessment; and other releva nt information, the effects of the presently 
recommended widening of the scope and options  for a further widening to non-energy related 
products should be reviewed. To this end; it is recommended to foresee a review of the Directive in 2012.  
 
EN 41   EN ANNEX I   
Analysis of the Consultation on the Sus tainable Consumption and Production and 
Sustainable Industrial Policy Action Plans. 
The European Commission undertook two pub lic consultations on the Sustainable 
Consumption and Production and Sustaina ble Industrial Policy Action Plans.  
The first one was targeted to companies. The European Business Test Panel scheme was built 
up to consult businesses in the different Member States on specific topics of their interest. The 
companies that have signed up to participate at the Panel are duly in formed of the launching 
of the consultations, which are carried out in a ll the official languages of the European Union.  
In the case of the consultation on SCP/SIP, 354  responded to the survey, of which 66% are 
SMEs. Companies of all Member States of the European Union, except Bulgaria, 
Luxembourg and Cyprus, responded to the survey. 
In the following table, it can be seen that a majority of the respondents supported the 
extension of minimum standards to a broad number of products. 
Table 1 Business Response to extending enviro nmental minimum standard  to a broad number 
of products 
Minimum standards to improve energy and re source efficiency applied to a broad 
number of products 
Yes 214  (69.3%) 
No 65  (21%) 
Don't know 30  (9.7%) 
Source: SCP/SIP consultation in EBTP 
The second public consultation on the Su stainable Consumption and Production and 
Sustainable Industrial Policy Action Plans took place between July 27th and September 23rd, 
2007. This consultation was a joint undertaki ng by DG Environment and DG Enterprise and 
Industries. 
The purpose of the consultation was to gather public and st akeholder’s opinions on the 
different areas of action, on the barriers to improve the situation in these areas and on the 
options for action. A Background document explai ning the issues at stake and the options 
being under consideration was al so available for the respondent s. Participants were also 
invited to provide position papers on  the different topic at stake.  
The survey was accessed by 658 participants. 479 of  them provided their affiliation: 277 were 
individuals and 202 stakeholders . The industrial sector and the environmental constituency 
presented both around 30% of total answers. In both groups stakehol ders constituted around 
half of the participants. First, participants we re asked what the best options are to promote 
better products. The results for st akeholders are shown in Figure  1. Broadening the scope of 
products to which environmental minimum requi rements apply was seen as the first best 
option. The combination of dynamically settin g minimum requirements for products and 
setting advanced performance benchmarks for be st performing products al so received strong 
report.  
Figure 1 opinion of the stakeholders on th e options to promote better products 
 
EN 42   EN Opinion on the options - Stakeholders
0102030405060708090
Broader scope
of products w ith
minimum
requirementsDynamic Minimun
Requirements
and benchmarks
for best
performing
productsEnhanced use of
Energy
Efficiency labelLabe lling
indicating
various
performancePublic
procurement
focusing on
energy
efficiencyTaxation
reflecting energy
and resource
efficiency
Most important Second most important Third most important
 
Figure 2 shows the general public’s opinion on th e best options to promote better products. A 
taxation reflecting energy and resource efficiency is the most advocated one. The combination of dynamically setting minimum requirements fo r products and setting advanced performance 
benchmarks for best performing products  also received strong support..  
Figure 2 opinion of the general public on th e options to promote better products 
Opinion on the options - General Public
020406080100120140160180
Broader scope
of products w ith
minimum
requirementsDynamic Minimun
Requirements
and benchmarks
for best
performing
productsEnhanced use of
Energy
Efficiency labelLabe lling
indicating
various
performancePublic
procurement
focusing on
energy
efficiencyTaxation
reflecting energy
and resource
efficiency
Most important Second most important Third most important
 
Finally a strong majority, in particular among stakeholders , agrees that environmental 
problems need to be tackled in a cost-efficient way while minimizing the social impact (Table 
2).  
 
EN 43   EN Table 2: Focus of the actions 
Focus General Public / 
Consumer Stakeholder/OrganisationGrand 
Total 
Actions need to be cost-efficient even if the positive environmental impacts are not maximised 
5.3% 8.8% 6.7% 
Actions need to prioritize social viability over environmental impacts 5.3% 2.7% 4.3% 
Actions need to tackle environmental problems in a cost-efficient way while minimizing the social impacts 
62.9% 80.2% 70.0% 
Actions should mainly concentrate on solving environmental problems, regardless of their costs or social impacts 
26.5% 8.2% 19.1% 
 
EN 44   EN ANNEX II   
Study by Mckinsey for the BDI 
This annex discusses the results of a study by McKinsey undertaken for the initiative 
“Business for climate protection” of the BD I Bundesverband der Deutschen Industrie. The 
study builds on a methodology for a global cost  curve developed by McKinsey. McKinsey 
cooperated with Professors R Socolow; S P acala, R Williams (Princeton University) and D 
Anderson (Imperial College London). The met hodology for Germany was further discussed 
with Professors Hellwig (MPI Bonn), Strobele (University of Munster) and Von Weizsacker 
(University of Cologne). 
In this annex the assumptions made by McKinsey ; the assumptions made for extrapolation of 
results from Germany to the EU and the results of the extrapolation are discussed. The information in this annex has not been used in  the revised version of the impact assessment 
report but it is consistent with the argument s brought forward and provides additional insights 
concerning the economic and environmental benef its that could result  from extending the 
scope of the Ecodesign Directive. 
Assumptions made by McKinsey 
To calculate the abatement cost per tonne of CO2 for a product it seems that the life cycle cost 
for the users of the product and the energy cons umption over the life cycle are compared for 
energy efficient and current products. The time period over which the abatement cost is calculated is therefore the life cycle of the product which is  different from product to product. 
For example for vehicles a 4.5 years first ow nership for private owned cars was assumed. 
The following discount rates to calculate the NPV of the life cycle cost of products have been 
used: 
Table 1: discount rates used in the McKinsey study 
Decision maker Discount factor 
Individuals 4.5% Industry 9.5% 
Commercial 9% Energy sector 7% 
The choice of a discount rate influences how fu ture benefits and costs are translated into 
current benefits and costs. For energy efficien cy, cost are immediate whereas benefits accrue 
over time. The higher the discount f actor the lower the future benefits are in net present value. 
The lower the discount factor the higher the fu ture benefits are in net present value.  
Discount factors in the range of 4.5-9.5% are re asonable. Therefore, the discount factors have 
not been used to overstate the benefits of the energy efficient investments. 
However, using different discount factors for decision makers influences the most cost 
effective measures. The discount factors ch osen by McKinsey make energy efficient 
investments by individuals more cost  effective than those by industry.  
The annual oil price is assumed to be $57 in 2010 and $52 in 2020. The reference for the oil 
price is the Annual Energy Outlook 2007. The exch ange rate assumed was 1 euro would cost 
1.2 dollar. A higher oil price would inflate for exam ple the benefits of a lternative energies and 
more fuel efficient cars.  
 
EN 45   EN Finally, McKinsey assumes that the demand of consumers does not change as a result of 
climate change measures and also that the industrial structure would not change. These 
assumptions are unrealistic but adding more realism would require significantly more 
complex models. 
Assumptions made for extrapolat ion of results from Germany 
The assumptions for the extrapolation of results from Germany to the EU-27 are presented 
and evaluated in this section. In general the extrapolation of the results gives illustrative 
indications of the likely e ffect at the EU level.  
For the own calculations based on McKinsey (2007) the resu lts for Germany have been 
multiplied by the inverse of German’s share in  EU-GDP to obtain the EU results. In the 
aggregate this assumption seems to be justifie d for the purpose of providing an indication of 
potential impacts: Germany is slightly more CO 2 intensive per toe than the EU-27 as a whole. 
Germany’s production of electricity emits more CO 2 since it is relatively reliant on coal and 
less reliant on nuclear and renewables.  
Table 2: Source of electricity  generation as % of total 
2004 EU27 Germany
 Coal  29.9% 48.6% 
 Oil  4.4% 1.6% 
 Gas  19.7% 11.4% 
 Nuclear  30.7% 27.1% 
 Renewables (*) 13.9% 9.5% 
 Other (***) 1.4% 1.8% 
Source: Energy & Transport in fi gures Statistical pocketbook 2007  
Table 3 provides some comparative figures for Germany and EU27. In terms of emissions 
intensity, the distortion is factor 2.4 tCO2/toe / 2.2 tCO2/t oe =1.09. So, extrapolating the 
results to EU 27 would be overe stimated by 9%. Yet Germany is less energy intense –due to 
structure of industry; existing le vels of insulation; efficiency of car park- than EU27. Factor 
164 toe/MEUR / 185 toe/MEUR=0.88. So, in terms of energy intensity, the results of the 
extrapolation would be underestimated by 12%. Combining the two, Germany emits slightly 
less CO2 per Euro (per Million Euro of GDP (393.6 tCO2/MEUR / 407 
tCO2/MEUR=0.967076). Therefore; using GDP to extrapolate abatement costs potential 
appears to be a reasonable approximation.  
Table 3: Key indicators for Germany and EU-27 used to estimate the potential errors of the 
extrapolation of Germany’s results  in McKinsey (2007) to EU-27 
 
EN 46   EN 
 
Source: factsheet DG TREN 2007 
The study of McKinsey uses a conversion factor of 0.72 Tonne CO2 equivalent per Mwh in 
2004 which declines to 0.64 Tonne CO2 equivale nt per MwH in 2020 as a result of the 
changes in the energy production sector47. 
Also, distortions at sectoral le vel could invalidate extrapolation of Germany’s results to the 
EU-27. 
Buildings:  Ecofys estimates that the abatement potenti al of state of the art insulation is 67% 
reduction in heat loss in Germany compared  to an average reduction of 56% in EU-1248. 
Therefore, extrapolation of Germany’s result could be a 67/56 (19%) overstatement for the 
EU-27. However, Germany is fairly advanced  in replacing single glass for double glassed 
windows. In Germany only 27% of the window surface is single glassed compared to 45.4% 
being single glassed in the rest of Europe.49 Based on the windows surface being single glass 
the result could be an understatement of the savings potential for the EU-27. Although, 
climatologic conditions do play a role, the savings potential is there. In the Netherlands, single 
glassed windows are 40% of the total window surface, in France 44% and in Belgium 46%. 
Transport:  Germany’s new cars emit more CO2 than the average in EU-27. The factor is 
approximately 172/158=1.09.50 So, extrapolating Germany’s result on cars seems to be a 
slight over-estimation. On the other hand; th e car stock in Germany is probably somewhat 
more often replaced than in EU-27 whic h could counterbalan ce the over-estimation. 
Energy production: as shown above,  Germany’s production of electricity emits more CO2 
since it is relatively reliant on coal and less reliant on nuclear and renewables.  
Energy Using appliances: Since all other sectors are more energy intensive than the EU-27 
while Germany’s total economy is less energy intens ive than the EU-27, it must be that other 
household use of energy and industry’s use of en ergy in Germany is less energy intensive than 
the EU-27. This implies that the savings for energy using appliances (corresponding to 
household use of energy and industry) are star ting from a relatively high level of energy 
efficiency. Since the EU-27 starts from a lower level of energy efficiency the extrapolations 
for energy using products could well be an unde restimation of the EU -27 savings potential. 
                                                 
47 See footnote 58 of McKinsey (2007). 
48 Austria, Belgium, Denmark, Finland, France, Germ any, Ireland, UK, Spain, Sweden, Netherlands, Italy. 
49 Based on GEPVP the association of glass manufacturers. 
50 Impact Assessment CO2 in cars. 
 
EN 47   EN Based on economic theory, one could claim that  Germany’s energy efficiency should already 
be higher than the EU-27. Indeed, electricity prices for industry are on average 15% higher 
and for households more than 20%  higher than in EU-27. These higher prices should induce 
more energy efficient purchases.  
Table 4: Average electricity prices  
Industry 2005 2006 2007 
EU-27 0.0672 0.0752 0.082 
Germany 0.078 0.0871 0.0946 
Difference 16% 16% 15% 
households 2005 2006 2007 
EU-27 0.1013 0.1068 0.1173 
Germany 0.1334 0.1374 0.1433 
Difference 31.7% 28.7% 22.2% 
In sum, to a first approximation the extrapolation from Germany to the EU seems not totally 
unreasonable and can give a ballpark estimate of the likely impacts at the EU level.  
Discussion of the results  of the extrapolation 
The important environmental impacts of energy using products include direct and indirect 
greenhouse gas emissions. Significa nt evidence exists that th e energy use and the related 
greenhouse gas emissions of energy using produc ts can be significantly  reduced. Only those 
product design policies that are abating CO2 emissions and that would pay back over the amortisation period of the users are included in  the analysis. So, all abatement potential that 
costs more than €0 per tonne CO2 are not ta ken up. The table below shows the yearly CO2 
emission reduction potential by ecodesign measures  in 2020 for energy using products. The 
second column presents the CO 2 reductions which can be achi eved with existing technology 
if the market failures identified above are resolved
51. The yearly CO2 re duction potential of 
energy using products is considerable with 287 million tonnes of CO252. This is equivalent to 
a reduction of 7.2% of  current emissions53. The third column presents the costs per tonne CO2 
of undertaking these measures k eeping into account in itial investment a nd savings during the 
use phase. On average €124 will be  saved per tonne of CO2. The fourth column presents the 
total net savings. Total net savings equal the abatement cost per tonne CO2 multiplied by the CO2 reduction potential. In total, € 35.7 billion can be saved.  
Table 5: Cost-benefit of yearly CO2 emissi ons reduction potential by eco-design measures for 
energy using products in 2020
54 
                                                 
51 See p 5 of McKinsey (2007) 
52 The original communication on the EuP directive estimated the potential bene fits at 200 million tonne of CO2 per 
year by the year 2020  
53 Source for current em issions is CAIT 2007. 
54 For a discussion of the assumptions made see Annex II. 
 
EN 48   EN Sector CO2 reductions which 
have negative abatement 
costs (Mt CO2 equivalent) Abatement 
cost per t CO2 
equivalent Net savings (billion €) 
Household sector 157.3 -130 20,5 
Industrial sector 129.9 -117 15,2 TOTAL 287 -124 35,7 
Source: own calculations based on McKinsey (2007) 
Table 5 shows that investing in more energy e fficient products will not  only lead to lower 
emissions but lead to consider able savings for households and industry. These estimates are 
conservative. Indeed, the studies for the impl ementing measures of the Ecodesign Directive 
have shown that for boilers and water heater s a mix of ecodesign, inst allation and labelling 
requirements would result in yearly net savings of €45 billion as of 202055 On the basis of the 
EuP preparatory studies it is estimated that a comprehensive set of ecodesign requirements for 
the remaining major energy-using products woul d bring another € 30 billion of saving per 
annum as of 2020.56 
Table 6 shows the CO2 abatem ent potential for innovative de tergents and construction 
products. Only those investme nts that pay off are analys ed. For example, 2L-renovation, 
which is more energy efficient that the othe r options, comes at cost of over €100 per tonne 
CO2 and is not analysed. 
                                                 
55 See p 32. of R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of 
Boilers (2007), Task 7, p. 39 and R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study 
on the Ecodesign of Water Heaters (2007), Task 7. And see p 39 of R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of Boilers (2007), Task 7, p. 39 and R. Kemna, M. 
van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of Boilers (2007), Task 7 
56 http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm#consultation_forum 
 
EN 49   EN Table 6: Cost-benefit of yearly CO2 emi ssion reduction potential by ecodesign measures for 
option 2 in 2020 
 Cumulative 
abatement 
potential 
(Mt CO2 
equivalent) Abatement 
cost per t CO2 
equivalent Net savings 
(million €) 
Innovative detergents 4.7 -336 1600 
7L-renovation57 (multi-family house) 19 -135 2559 
7L-renovation (3-6-family house) 18 -60 1052 
7L-renovation (1-2 family house) 60 -49 2949 
Office building insulation 12 -26 320 
School building insulation 2 -15 36 
TOTAL 115.7 -65 8516 
Source: own calculations based on Mckinsey (2007) 
The huge and very cost effici ent potential of innovative (a mbient temperature washing) 
detergents is due to the caused cost savings, as another recent and independently reviewed 
study from Procter and Gamble confirms (P rocter&Gamble 2006). The total CO2 emission 
savings potential sum up to about 5 M t / y ear in the EU, assumi ng a replacement of 2001 
market leading detergents by cold-wash detergen ts, of which the first products now enter the 
market. Of the reduction potential in the constr uction sector, 78 Mt of CO2 would be due to 
the use of construction products. The other reductions in the c onstruction sector would be due 
to the combination of the product specific appr oach of the Ecodesign di rective and the whole 
building approach of the Energy Perf ormance of Buildings Directive. 
The table below shows the yearly CO2 emission reduction potential for m eans of transport in 
2020. Only those policies that are abating CO 2 emissions and represent cost savings are 
shown58. For example, hybrid cars have an a dditional cost of ove r €1000 per tonne CO2 
abated. Moreover, only those policies that  are related to ecodesign improvements are 
withheld. Changes in consumption behaviour a nd other measures unrelated to ecodesign are 
not taken up. The cost effectiv e saving potential of product de sign for means of transport is 
largely due to cars (37.4 Mt CO2 e), other vehicl es (8.5 Mt CO2 e) and trains (8.5 Mt CO2 e). 
The potential of ecodesign for airplanes ( 2.3 Mt CO2) seems to be less important.  
                                                 
57 7L renovation is a renovation whic h reduces the heating needs of a house to 7 liters of heating oil per 
square meter every year 
58 Own calculations based on McKinsey (2007). Note that ships are not discussed by this study. 
 
EN 50   EN Table 7: Cost-benefit of yearly CO2 emi ssion reduction potential by ecodesign measures for 
means of transport in 2020 
Sector CO2 reductions which 
have negative 
abatement costs (Mt 
CO2 equivalent) Abatement cost per 
t CO2 equivalent 
(averages) Net savings (€ 
million) 
Cars 37.4 -139 5213 
Light, medium and heavy vehicles (trucks and buses) 8.5 -167 1422 
Train 8.5 0 0 
Air 2.3 0 0 
TOTAL 56.8 -117 6635 
Source: own calculations based on McKinsey (2007) 
As shown in Table 8 below, products of Opti on 1 have a savings potential of 287 Mt CO2 and 
could save €35.5 billion for consumers and companies.  Products of option 2 have an 
additional savings potential of 122 Mt CO2 and could save €8.5 billion for households and 
consumers. Products of option 3 have a savings  potential of 57 Mt CO2, and could save €6.6 
billion for households and consumers. However, the saving potential for means of transport is 
already addressed by forthcoming legislation.  
Table 8: Cost-benefit of yearly CO2 emi ssion reduction potential by ecodesign measures for 
selected products of the three options in 2020 
Sector CO2 reductions 
which have 
negative abatement 
costs (Mt CO2 
equivalent) Abatement cost 
per t CO2 
equivalent (averages) Net savings (€ 
billion) 
Option 1 Energy using products 287 -124 35,7 
Option 2 All products except means of transport 122 -65 8,5 
Option 3 Means of transport 56.8 -117 6,6 
Source: own calculations based on McKinsey 
 
EN 51   EN ANNEX III   
Illustration of learning curves and the fall  in prices and rise in energy and resource 
efficiency for energy using products59 
This annex illustrates learning curves and the fall in prices and rise in energy and resource 
efficiency for energy using products. 
For washing machines, laundry dryers and refr igerators the stylised facts seem to be: 
declining prices and declining energy (and water) consumption.  
Figure 1 Price and resource developments of washing machines 
Cumulative global washing machines production in million4x1026x1028x1022x103103Real price of washing machines 
in EUR2006/kg laundry capacity
50150200500
100R2 = 0.51
LR = (31.7 ± 7.2)%1965
2007). .() (1005504699 7119±−±= x y
Cumulative global production of washing machines in million4x1026x1028x1022x103103Electricity consumption 
in kWh/kg laundry capacity
0.150.20.51.52
0.11
Water consumption 
in l/kg laundry capacity
24682040
10Electricity consumption
Water consumption
R2= 0.86, LR = (24.7 ± 2.2)%1965
2007
). .(). .(030410910 364±−±= x y1965
2007R2 = 0.54, LR = (27.3 ± 6.1)%). .() (090460259 451±−±= x y
 
Figure 2 Price and energy e fficiency of laundry dryers 
 
Cumulative global production of laundry dryers in million60 80 200 100Price of laundry dryers 
in EUR2006/kg laundry capacity
50150200
100
R2 = 0.80
LR = (27.2 ± 4.9)%1969
2003
). .() (070460384 1164±−±= x y
Cumulative global production of laundry dryers in million60 80 200 100Energy consumption of laundry dryers 
in kWh/kg laundry capacity
0.50.60.70.80.91.5
1
R2 = 0.84
LR = (19.9 ± 3.1)%1969
2003 ). .(). .(0403209024±−±= x y
 
Figure 3 Price and energy e fficiency of refrigerators 
Cumulative global production of refrigerators in million20 40 60 80 200 400 600 800 2000 102103Price of refrigerators in EUR2006/l volume
23456
1R2 = 0.39
LR = (9.1 ± 2.0)%1964
2007). .(). .(0301401126±−±= x y
Cumulative global production of refrigerators in million40 60 80 200 400 600 800 2000 102103Electricity consumption of refrigerators 
in EUR2006 per day and 100 liter volume
0.20.30.40.50.62.0
1R2 = 0.68
LR = (19.9 ± 2.4)%
1964
2007). .(). .(0303209054±−±= x y
 
                                                 
59 This section is based on Weiss, Ju nginger and Patel (2008) unpublished. 
 
EN 52   EN For freezers both prices and energy  efficiency have remained rela tively constant over time for 
the studied sample. Given the limited number of observations, one should be cautious about inferring general statements on price and energy efficiency of freezers. 
Figure 4 Price and energy  efficiency of freezers 
Cumulative global production of freezers in million20 40 60 80 200 400 600 800 100Price of freezers in EUR2006/l volume
23456
R2 = 0.04
LR = (-3.1 ± 4.5)%
19702003). .(). .(0600408042±±= x y
Cumulative global production of freezers in million20 40 60 80 200 400 600 800 100Electricity consumption 
in kWh per day and 100l volume0.20.30.40.50.62.0
0.11
R2 = 0.02
LR = (2.8 ± 5.9)%19702003
). .(). .(0800404090±−±= x y
 
 
EN 53   EN ANNEX IV   
Detailed discussion of applicability of eco-design to option 2 products 
This annex contains a more detailed discus sion on the applicability of the eco-design 
Directive to option 2 products.  
Construction products 
a) The extension of the Ecodesign Directive to  construction products can be complementary 
to current policies relating to the energy performance of buildings:  
The construction products directive (Directiv e 89/106/EEC) sets measurement standards for 
the technical performance of construction pro ducts. It assures that requirements set by 
Member States on buildings (o r building elements), notably as  regards the environment and 
the energy economy and heat retention, are consis tent with these measurement standards.  
The Energy Performance of Buildings Dir ective (Directive 2002/91/EC) only covers new 
buildings and major renovations – representing 25% of the building value- for existing 
buildings above 1000 square meters. However, existing buildings below 1000 square meters 
account for around 70% of the overall building stock and more than 70% of the energy 
consumption related to buildings. Besides, “m inor” renovations, such  as replacing single 
glassed windows by single glassed with better  insulation cap acity and/or double glassed 
windows, also have a significant environmental potential. For this ty pe of small, product 
specific improvements, principal-agent problems are precisely the biggest. In addition, there 
is a need to deal with signifi cant environmental impacts of cons truction other than the energy 
performance. For civil work and the building st ructure, the energy related externalities – CO2 
emissions - are only 25-35% of a ll environmental externalities60. Setting minimum 
requirements for the most significant environm ental impacts of construction products could 
contribute considerably to enhance the overa ll environmental performance of buildings. 
Eco-design requirements for ener gy saving products could be complementary to the EPBD. 
The eco-design requirements would, for instan ce, set minimum requirements for important 
energy saving products. By doing so: 
• Internal market problems in relation to Member State specific performance 
requirements on products are solved. 
• The potential of small product specific improvements can be reaped. 
b) Based on Labouze et al (2003) , the total environmental impact  of construction is between 
15% and 16% of all environmental impacts studied.  
                                                 
60 Labouze et al (2003). 
 
EN 54   EN Table 1: environmental impact of construction  
 per capita (€) EU-27 ( bn €) % of total impact 
Product min max min max min max 
Space heating61 16.5 74 8.1 36.6 8% 8% 
Building structure 11 51 5.4 24.8 5% 5% 
Civil construction work 6 20 3.0 9.7 3% 2% 
Total construction 33.5 145 16.5 71.1 16% 15% 
In the table below the yearly CO2 emission reduction potential in  2020 that are also beneficial 
for the economy are demonstrated for the construction sector62: 
Table 2: Cost-benefit of yearly CO 2 emission reduction potential in 2020 
 Cumulative 
abatement 
potential 
(Mt CO2 
equivalent) Abatement 
cost per t 
CO2 
equivalent Net 
savings 
(million 
€) 
7L-renovation63 (multi-family house) 19 -135 2559 
7L-renovation (3-6-family house) 18 -60 1052 
7L-renovation (1-2 family house) 60 -49 2949 
Office building insulation 12 -26 320 
School building insulation 2 -15 36 
TOTAL 111 -62 6916 
For the renovation of family houses, 1-2 and 3-6 households whose surface is lower than 1000 m2, the EPBD is currently not applicable a nd some of the abatement potential mentioned 
above could be realized thr ough renovations with better performing products that could 
eventually be considered in the Ecodesign Dire ctive. For the insulation in office and school 
                                                
 
61 Note that space heating is both under energy using products and construction products. On the one 
hand, one can improve the efficien cy of boilers. The current minimum requirements considered would 
improve boilers with 17% (source: preparatory stud y for implementing measures). On the other hand, 
one can improve the insulation of buildings such that heating requirements go down. Heating insulation 
can reduce the heating requirements of buildings su bstantially. EURIMA, a sector association claims 
that insulation can reduce energy requirements by more than 40% Ecofys I (2002). 
62 Own calculations based on McKinsey ( 2007). McKinsey made the assumption that 3% of buildings would be 
renovated annually.  
63 7L renovation is a renovation whic h reduces the heating needs of a house to 7 liters of heating oil per 
square meter every year. 
 
EN 55   EN buildings and the 7L-renovation in multi-family houses, it is likely that the 1000 square meter 
threshold is attained.  
The approach followed does make the trade-off between affordability for households and 
environmental savings. More stringent requirements on insu lation material, windows and 
other construction products could result in even bigger CO2 savings . Yet, the costs of such an 
approach would not justify such requirements. Table 5 presents cost-benefit of the additional yearly emission reduction potential of sh ifting from 7L-renovation to 2L-renovation
64. 
Compared to 7L-renovation an additional 15 M Tonnes of CO2, 13.5% extra, can be saved. 
Yet, this will cost €12 billion extra. Abatemen t costs per extra tonne would be on average 828 
€/T CO2 compared to an ETS price per ton CO2 of 20-30 Euro. Based on this evidence 2L-
renovation standards seem not cost  effective for the time being.  
Table 3: Cost-benefit of additional yearly  CO2 emission reduction potential in 2020 of going 
from 7L-renovation to 2L-renovation 
  CO2 reductions 
(Mt CO2 
equivalent) cost per tonne 
CO2 
equivalent Costs 
(million €) 
2L-renovation (multi-family house 4 660 2502 
2L-renovation (3-6 family house) 3 714 2030 
2L-renovation (1-2 family house) 8 947 7629 
TOTAL 15 828 12162 
Product specific improvements are important. Fo r example, replacing the current stock of 
single glazed windows by low-energy glazing at a ra te of 3% per annum and the current stock 
of double glazed windows by low-energy glazing at  a rate of 1% per annum saves 22.9 Mt 
CO2 equivalents in 2019.65 This will result in discounted  energy savings of €5.6 billion in 
2019 using 2007 electricity prices.  
In Switzerland, general building codes and specif ic building codes have been complementary 
over the last thirty year. Moreover, the polic y succeeded in increasing  the uptake of more 
energy efficient construction pr oducts at decreasing costs for these products. For insulation 
and glazing, Jakob (2007) and Jakob and Madlen er (2004) show a continuing trend of cost 
reduction and a successful market penetration of more advanced windo ws (with lower heat 
transmissivity, see figure 5. In pa rticular the shift towards more stringent energy standards in 
1988 can be clearly disti nguished in figure 5.  
Figure 1: Penetration rate and price developments of energy efficient glass66 
                                                 
64 2L renovation is a renovation whic h reduces the heating needs of a house to 2 liters of heating oil per 
square meter every year. 
65 Own calculations based on GEPVP. 
66 Development of the relative production output (quantity-based) for double and triple glazing in 
Switzerland, 1970–2001 (%) and the price difference for glass manufacturing between 1970 and 2006 
(CHF (2006)/m2). 
 
EN 56   EN 100450
202601
0102030405060708090100
 1970   1980   1985   1990   1993   1996   1999  2000  2001  Market Share [%]
0100200300400500600700
Cost [CHF(2006)/m2] Double glazing insulation  
 Double glazing insulation with
heat protection coating  
 Triple glazing insulation withheat protection coating  
Cost of glass [CHF/m2]
Total cost of glassmanufacturing [CHF/m2]
 
Source: DG ENTR, based on  data from: Jakob and Madlener 2004, p.16 and 17 
Also for insulation material there is an important potential for improvement. Insulating the 
total stock of houses built before 1974, which have  not been insulated ye t, to the currently 
recommended standards is said to  reduce energy consumption by 42%67. Moreover, this 
would result in savings of 353 Mt CO2 per year which is above 5% of total CO2 emissions in 
the EU. It is estimated that the refurbishment ta kes place at a rate of 4% so this potential can 
be reaped over the next 25 years.  
 
 
The below table discusses the different materi als of insulation and their respective cost-
benefits. In the last column information is given on the amortisation rate. It appears that 
insulation pays off rather quickly.68  
                                                 
67 Based on studies done by ecofys covering Austria, Belgium, Denmark, Finland, France, Germany, 
Ireland, UK, Spain, Sweden, Netherlands, Italy, Norway, Switzerland and Turkey. 
68 The numbers do not include the fixed costs of refurb ishment. This is a valid assumption since there are 
two decisions. One is the decision to refurbish or not.  This decision affects th e refurbishment rate which 
is assumed fixed at 3% in the calculations. Th e other decision is, once one has chosen for 
refurbishment, whether or not to install insulation.  
 
EN 57   EN 
 
Also for insulation, the Ecodesign Directive could result in an acceleration of learning curves.  
Figure 2 
 
Textiles 
Textile products such as clot hing and footwear do have re levant environmental impacts 
(EIPRO 2006), even though not all studies inve stigated in the EIPRO project agree on the 
relevance of the product category. There is  an agreement that clothing and footwear 
contributes significantly to wate r use and acidification, whereas a relevant contribution to land 
use, eutrophication, greenhouse ga ses, photochemical ozone and wa ste is agreed by Nijdam 
and Wilting (2003) and partly by Labouze et al. (2003) and Dall et al. (2002). 
Criteria for textile products have been de veloped by main eco-labels, which prove the 
environmental relevance and eco-design improve ment potential of this product group. Some 
non-exhaustive examples are given in the following table: 
Table 6: different requirements for textiles 
Eco-Label Type of Textiles Requirements regarding 
EU Eco-label 
(www.ec.europa.eu/e
nvironment/ecolabel
) Textiles Textile fibre: type of fibre, limitation of toxic 
residues in fibres, redu ction of air and water 
pollution during fibre process; processes and 
chemicals: limitation of harmful substances, fitness for use: performance and durability 
 
EN 58   EN EU Eco-label 
(www.ec.europa.eu/environment/ecolabel) Shoes Residues in the final product, emissions from the 
production of material  (tannery), harmful 
substances, VOC, PVC, energy consumption, 
electrical components,  packaging, durability 
Nordic Swan 
(www.svanen.nu) Textiles, skins 
and leather Natural vegetable fibres , skins and leather – 
tanning, skins and leather - treatment with chemical products, energy and water consumption, recycling systems 
Japanese Eco-Label 
(www.ecomark.jp) Clothes, 
Household Textile Products, Textile Products for Industrial Use Type of fibres, chemical substances, resins, 
packaging, replacement 
Japanese Eco-Label 
(www.ecomark.jp) Bags and 
Suitcases (Leather Bags, Fabric Bags, 
Synthetic/Artificia
l Leather Bags, Other Bags, Suitcases) For example for Leather Bags: formaldehyde 
content, PCP, heavy me tals, dyestuff fastness, 
plastics, metals, durability, information consumer 
Australian Eco-label 
(www.aela.org.au) Textiles (Clothing 
and Bedding Products, Interior Textile Applications, Yarns and Fabrics, Textile Bags, Outdoor Textile Applications) Fitness for purpose, materials (fibres, plastics), 
hazardous materials, packaging 
Moreover, Labouze et al. (2003) rank the external costs of environmental impacts of textiles 
on the 6
th position, behind EuP products (space heati ng, EuP domestic appliances, appliances 
and lights) and transport (pers onal cars and good transports). 
 
EN 59   EN Detergents 
Innovative detergents are projec ted to save 4.7 Mt CO2 equi valents yearly in 2020 at a 
negative cost of -336 Euro/t CO2 avoided. In ot her words, the CO2 reduction can be achieved 
without additional expenses but instead leads to large economic savings. Overall savings of households would amount to €1.6 billion.
69 Based on the environmental parameters described 
in the eco-labels for detergents a simula tion was conducted that 25% of the worst 
environmental performing products would be banned from the market70:  
Table 8 
Product 
Environmental impact savings as % of total 
impact of product 
category absolute savings  unit/yr 
CDV 22% 29,812,757 Mlitres 
Total Phosphorus 17% 149 tonne 
Biodegradability 
of chemicals 33% 15 tonne Cleaners for 
sanitary facilities 
VOCs 17% 1,490 tonne 
CDV 20% 22,361,482 Mlitres 
Total 
Phosphorus 17% 15 tonne 
Biodegradability 
of chemicals 5% 597 tonne All-purpose 
Cleaners 
VOCs 17% 746 tonne 
CDV 17% 991,159 Mlitres 
Total 
Phosphorus 12% 29,736 tonne 
Total Chemicals 14% 86,727 tonne Detergents 
for 
Dishwashers 
Hazardous 
Ingredients 26% 3,963 tonne 
                                                 
69 Own calculations based on McKinsey (2007). 
70 Own calculations based on AEAT in Confidence (2004) The Direct and Indirect Benefits of the 
European Ecolabel – Final Report. The main assumpti ons made are 1) the eco-label corresponds to the 
10% best environmental performing products on the market 2) environmental performance of products 
follows a standard normal distribution 3) the 25% worst performing products are replaced according to 
a normal distribution of the 75% best performing products. 
 
EN 60   EN Biodegradability 
of chemicals 17% 5,949 tonne 
CDV 11% 8,246,593 Mlitres 
Total Chemicals 12% 72,110 tonne Hand 
Dishwashing Detergents 
Hazardous 
ingredients 11% 20,693 tonne 
CDV 8% 19,890,591 Mlitres 
Total 
Phosphorus 11% 165,233 tonne 
Total Chemicals 11% 660,858 tonne 
Hazardous 
ingredients 17% 6,609 tonne Laundry 
Detergents 
Biodegradability 
of chemicals 32% 114,733,010 tonne 
An older analysis done by P&G demonstrates how the environm ental performance for laundry 
detergents can be improved. The analysis –su mmarised in the below table- represents a 
‘cradle-to-grave’ LCA for 1 wash under UK cond itions for wash habits and infrastructure. 
Under the study’s conditions, it is concluded th at compact detergents (both powder & liquid) 
are environmentally preferable detergent form ulations, mainly due to the lower use of 
chemicals, resulting in benefits on aquati c toxicity, eutrophicati on, ozone depletion and 
photochemical smog71. This study does not include the newe r cold-wash detergents that have 
the much larger potential and via a different mechanism of saving energy for water heating, as 
detailed more above and as f ound by both McKinsey 2007 and P&G 2006.  
Table 9 
 
Lice cycle energy consumption and emissions for 1 wash under UK conditions with year 2001 P&G laundry formulations 
While there is already legislation that covers  the environmental performance of chemicals, 
this does not cover the cold-wash effect w ith the huge and very cost-efficient savings 
potential of 5 M t / CO2 per year. REACH regulates  chemicals in general and there is also the 
Detergents Directive which regulates detergents specifically, but again bot h have no effect on 
                                                 
71 G. Van Hoof, D. Schowanek, TCJ Feijtel (2003). Comparative Life Cycle Assessment of laundry 
detergent formulations in the UK. Part I: Environmental fingerprint of five detergent formulations in 
2001. Tenside (in press). 
 
EN 61   EN cold-wash detergents, hence the extended Eco- design legislation is fully complementary. 
Therefore, detergents are fully meeting the art 15.2 of the Eco-design Directive . 
Water using products 
24.4% of all water is consumed by the domes tic sector. More resource efficient use and 
improving the technical performance of showers, baths, taps, washing machines, dish washers 
and toilet flushes could lead to water savings  for households of between 29-41%. Improving 
the technical performance could lead to  water savings for households of 25%.72  
Table 10 
 
Source: study on water by DG ENV 
The below table provides examples of such im provements in the technical performance of 
household devices.  
Table 11: Typical water saving devices 
                                                 
72 Eco-logic (2007) EU Water saving potential (Part 1 –Report) prepared for DG ENV. 
 
EN 62   EN 
 
Source: study on water by DG ENV 
This corresponds to savings of 6.1% of tota l water use. Disregarding washing and laundry 
machines, which are already regulated under the Ecodesign Directive, the savings potential is 
15% smaller corresponding to savi ngs of 5.2% of total water use.  
More water efficiency also means higher energy  efficiency. For example for baths, showers 
and taps less water use means less hot water us e, which implies less water heating by boilers 
which in turn results in electricity savings. Th e water saving potential for these products is 28-
34%, which is also the assumed wate r heating need saving for a household73.  
Water heaters currently use 92 Twh/year of primary energy74. Reducing heating needs by 28-
34% should lead to a reduction in energy use of 26-31 Twh/year . This represents savings of 
0.20-0.23% of total final energy consumption in  the EU-25. Reducing energy use would in 
turn result in 18.2 - 21.7 Mt CO2 emissions sa ved per year. By 2020, roughly 40% of that 
potential could be saved assuming a replace ment rate of 3% per annum. This would 
correspond to CO2 savings in the magnitude of 7.5 Mt CO2 per year. 
Water efficiency of appliances s eems not to be reflected in prices  as available evidence for the 
UK indicates75. Another study finds payback times for water efficient showers to be 3.5 years 
and for water efficient toile t flush to be 6-11 years.76  
                                                 
73 This assumption is underbuild by technical arguments. The main technical improvement to get more 
water efficient taps, showers and baths for the same level of quality is to infuse more air into the water. 
This technique will apply to water regardless of it being hot or cold. 
74 Task 7 on water heaters of the preparatory studies  for eco-design. 
75 Pricing in the longer term should not be a barrier to uptake for more efficient showers as currently 
available water efficient showers tend not to be pr iced higher then the market  average. The long-term 
decline in the price of baseline (inefficient) water using equipment is expected to be 2.45%. Reductions 
in the price of water efficient equipment of between  5% and 15% are expected . Current example prices 
 
EN 63   EN There seems to be scope for improving the water efficiency of apparatus in agriculture and 
industry as well e.g. ir rigation equipment.  
Furniture 
The EIPRO project investigated furniture onl y in the broader category "Housing, furniture, 
equipment and utility use", with some unde rlying studies confirming the relevance of 
furniture for eutrophication (Labouze et al. (2003)), resource depletion and waste (Dall et al. 
2002 and Moll et al. 2004). 
Criteria for furniture have been developed by  several main eco-labels, which prove the 
environmental relevance and eco-design improve ment potential of this product group. Some 
non-exhaustive examples are given in the following table: 
Table 12 
Eco-Label Type of Furnit ure Requirements regarding 
EU Eco-label 
(www.ec.europa.eu/environment/ecolabel/ind
ex_en.htm) Furniture No agreed requirements so far 
Nordic Swan 
(www.svanen.nu) Furniture and fitments Wood, wood ba sed panels, surface treatment of wood, 
metals, plastics, padding materials, fabrics, glass, adhesives, 
waste, packaging 
Nordic Swan 
(www.svanen.nu) Outdoor Furniture and 
Playground Equipment Solid wood, wood-based panels and high pressure laminate, 
wood preservation, surface treatment of wood, maintenance 
products for wood, metals, plastics, adhesive 
German Blue Angel 
(www.blauer-engel.de) Furniture Manufacturing: origin of the wood, formaldehyde in wood-
based materials, coating systems; use: indoor air quality, 
packaging, wearing parts; recycling and disposal; consumer 
information, advertising statements 
Japanese Eco-Label 
(www.ecomark.jp) Furniture Wood origin, CFC, BTX, polymers, coatings, paint, 
adhesives, repair system, packaging, information,  
Australian Eco-label 
(www.aela.org.au) Furniture and Fittings 
(Office/ Domestic 
Chairs, Office/ Domestic Desks & 
Tables, Bedroom 
Furniture, White Furniture, Fittings) Fitness for purpose, materials (timber and other natural 
materials, plastics, fabrics, glass, rubber, adhesives, metals, 
coatings), hazardous materials,  post consumption recycling 
and labelling 
Australian Eco-label Outdoor Furniture Fitness fo r purpose, materials (timber and other natural 
                                                                                                                                                         
for showers are about £142 for 7.5 kW electric shower (3.46 l/min), £ 184 for a 10.8 kW electric shower 
(4.99 l min) and £184 for a standard mixer shower (8 l min). Current example prices for WCs are about 
£163 for a 6/4-litre, dual-flush WC, £275 for a 4.5- litre WC but, surprisingly, only £120 for a 4.5/3-
litre, dual flush WC. Current examples of the prices of baths are £455 for a 140-litre bath, £198 for a 
160-litre bath, £118 for a 200-litre bath and £171 fo r a 290-litre bath. As these figures show, bath 
volume is not an indicator of price UK’s Market Transformation Programme and Assessing the cost of compliance with the Code for Sustainable home s, Environment Agency, 2007 (available from 
www.environment-agency.gov.uk). 
76 Eco-logic (2007) EU Water saving potential (Part 1 –Report) prepared for DG ENV. 
 
EN 64   EN (www.aela.org.au) (Commercial and 
Public Use Outdoor 
forniture, Domestic Recreational Outdoor 
Furniture, Roadside 
Furniture, Outdoor Fittings and 
Ornaments) materials, plastics, fabrics, glass, rubber, adhesives, metals, 
coatings), hazardous materials,  post consumption recycling 
and labelling 
For furniture there are a lot of company specif ic success stories of improvements over the life 
cycle. Successful examples include the eco-design of office furniture77 or wooden furniture78. 
                                                 
77 http://www.steelcase.com/uk/offi ce_furniture_steelcase_index.aspx 
78 Klostermann and Tukker (Eds.) (1998) Product innovation and eco-efficiency, Kluwer Acedemic 
Publishers. 
 
EN 65   EN ANNEX V  
Volumes sold for other means of transportation 
This annex assesses whether the whether the th reshold of article 15 2 (a) is met for other 
means of transport. In this artic le it is stated that products sh all represent a significant volume 
of sales and trade, indicitavely more th an 200000 units a year within the Community.  
The data is based on the available informati on in PRODCOM for the year 2006. For transport 
by water only floating structures are so ld over 200,000 units. Yet, no significant 
environmental impacts can be expected from them.  
Table 1 
transportation by water Sold 
Volume 
EU27 
Non-sea going ferry boats, cruise ships, excursion boats and similar vessels 455 
Tugs 114 
Sea-going dredgers 51 
Floating cranes, floating docks, and other ve ssels, the navigability of which is 
subsidiary to their main function (exc l. dredgers, floating or submersible 
drilling or production platforms; fishi ng vessels and warships), sea-going 57 
Dredgers, and other vessels, the navigabili ty of which is subsidiary to their 
main function (excl. floating or submer sible drilling or production platforms; 
fishing vessels and wa rships), not sea-going 31 
Other vessels (including lifeboats) other than rowing boats, sea-going 1731 
Other vessels (including lif eboats other than rowing boats) not sea-going 2478 
Floating structures (including rafts, tanks, coffer-dams, landing-stages, buoys 
and beacons) 622050 
Non sea-going sailboats, for pleasure or sports, of a length < 7.5 m 20189 
Non sea-going sailboats for pleasure or s ports, > 100 kg in weight and 7.5 m in 
length 5112 
Inflatable vessels for pleasure or  sports, of a weight < 100 kg 50332 
Inflatable vessels for pleasure or  sports, of a weight > 100 kg 20741 
Non sea-going motorboats for pleasure or  sports, < 7.5 m in length (excluding 
outboard motorboats) 12777 
Rigid boats- 100 kg in weight (includi ng outboard motorboats, rowing boats 
and canoes) 94069 
 
EN 66   EN Rigid boats > 100 kg in weight and < 7.5 m in le ngth (including outboard 
motorboats, rowing boats and canoes) 42931 
Rigid boats > 100 kg in weight and 7.5 m in length (including outboard 
motorboats, rowing boats and canoes) 6321 
For rail transport no product category has sa les above 10,000 units a year. Combined the 
volumes are below 15,000 units.  
Table 2 
rail transport Sold 
volume 
EU27 
Rail locomotives powered from an ex ternal source of electricity 566 
Diesel-electric locomotives 323 
Self-propelled railway or tramway coaches, vans and trucks powered from an 
external source of electricity (excludi ng railway or tramway maintenance or 
service vehicles) 1629 
Self-propelled railway or tramway coaches , vans and trucks (excluding those 
powered by electricity, railway and tram way maintenance or service vehicles) 511 
Railway or tramway maintenance or se rvice vehicles (including workshops, 
cranes, ballast tampers, track-liners, testing coaches and track inspection vehicles) 1193 
Rail/tramway passenger coaches; luggage vans, post office coaches and other 
special purpose rail/tramway co aches excluding rail/tramway 
maintenance/service ve hicles, self-propelled 991 
Tank wagons and the like, insulated, refrig erated or covered and closed vans 
and wagons for railway or tramway use (excluding self-propelled) 3743 
Rail/tramway goods vans/wagons including self-discharging vans/ wagons, 
open with non-removable sides 60cm, tank wagons etc., insulated, refrigerated/covered, closed vans/wagons 5848 
For air transport no product category has sale s above 2,000 a year. Combined the volumes are 
lower than 10,000 a year.  
 
EN 67   EN Table 3 
air transport Sold 
volume 
EU27 
Turbojets or turbofans of a dry thrust > 25 kN, for civil use 1574 
Turboprops of a power < 1100 kW, for civil use 982 
Gliders and hang gliders, for civil use 509 
Helicopters of an unladen wei ght < 2000 kg, for civil use 182 
Helicopters of an unladen wei ght > 2000 kg, for civil use 383 
Aeroplanes and other aircra ft of an unladen weight < 2000 kg, for civil use 1333 
Aeroplanes and other aircraft of an  unladen weight > 2000 kg, but < 15000 kg 
for civil use 230 
Aeroplanes and other aircra ft of an unladen weight > 15 000 kg, for civil use 434 
In the category other, bicycles and parts, i nvalid carriages and vehi cles not mechanically 
propelled. The 200,000 sold criteria excludes “Inva lid carriages motorized  or mechanically 
propelled”. Other categories such as bicycles a nd parts or vehicles not mechanically propelled 
seem not to have a very big environmental impact.  
Table 4 
Other Sold 
volume 
EU27 
Non-motorized bicycles and other cycl es, without ball bear ings (including 
delivery tricycles) 1876540 
Non-motorized bicycles and other cycles  with ball bearings (including delivery 
tricycles) 10413953 
Frames for bicycles, other non-motorized cycles and side-cars (excluding parts 
of frames) 2244108 
Front forks for bicycles, ot her non-motorized cycles and side-cars (excluding 
parts of front forks) 1103244 
Wheel rims for bicycles other non- motorized cycles and side-cars 19314277 
Wheel spokes for bicycles, other non- motorized cycles and side-cars 6335948 
Hubs without free-wheel or braking de vice for bicycles, other non-motorized 
cycles and side-cars 3877819 
 
EN 68   EN Coaster braking hubs and hub brakes for bicycles and other non-motorized 
cycles 2723865 
Brakes for bicycles and other non-motor ized cycles (excluding coaster braking 
hubs and hub brakes) 7895581 
Pedals for bicycles and other non-motorized cycles 662357 
Crank-gear for bicycles and other non-motorized cycles 1215878 
Luggage-carriers for bicycles a nd other non-motorized cycles 2696298 
Invalid carriages not mechanically propelled 861633 
Invalid carriages motorized or mechanically propelled 134871 
Vehicles not mechanically propelled including industry tr olleys, barrows, 
luggage trucks, hopper-trucks, hand pu lled golf trolleys excluding shopping 
trolleys 9306570 
 
EN 69   EN ANNEX VI  
Definition of technical terms 
This annex defines the definition of technical terms79 
• Abiotic depletion refers to the exhaustion of natural resources such as iron ore or copper, 
which are regarded as non-living. Impacts cons idered are those deri ved from the extraction 
of minerals and fossil fuels. 
• Global warming is the impact of greenhouse gase s emissions on the radiative forcing of the 
atmosphere. These emissions have negative impacts on human and ecosystem health, and 
material welfare. 
• Human toxicity includes the impacts on human health of toxic substances emitted to the 
environment. 
• Fresh water aquatic ecotoxicity refers to the impact of toxic substances emitted to 
freshwater aquatic ecosystems. 
• Marine aquatic ecotoxicology refers to the im pact of toxic substances emitted to marine 
aquatic ecosystems. 
• Terrestrial ecotoxicity refers to the impact  of toxic substances emitted to terrestrial 
ecosystems.  
• Photochemical oxidation is the formation of reactive chemical compounds, such as ozone, 
by the action of sunlight on certain primary air pollutant s. These compounds may be 
injurious to human health, ecosy stems, materials and crops.  
• Acidification is the result of acidifying pollu tants emissions, such as SO2 or NOx, to the 
air. These emissions have negative impacts on soil, groundwater, surface waters, biological 
organisms, ecosystems and materials. 
• Eutrophication is the consequence of high levels  of macronutrients, such as nitrogen and 
phosphorus, in the environment. 
• Land use refers to the transformation and occ upation of land by human activities, such as 
agriculture, housing, road infrastructure etc. Th is has direct impacts on biodiversity, soil 
erosion, groundwater protection an d other environmental aspects. 
• Stratospheric ozone depletion refers to the re duction of ozone in the stratosphere (“Ozone 
hole”) caused by chemical and photochemical  reactions e.g. with chlorofluorocarbons 
(CFCs) and other substances. 
                                                 
79 These defintions have been taken from H. Ca bal Y.Lechón R. Sáez (2005) European Sustainable 
Electricity; Comprehensive Analysis of Future European Demand and Generation of European 
Electricity and its Security of Supply research partly funded by DG RTD. 
 
EN 70   EN ANNEX VII  
External cost factors to monetarise environmental impacts80 
This annex summarises the external cost factors to monetise environmental impacts which can 
be found in the literature.  
• 
  
                                                 
80 This annex is based on page 71 of Labouze et al. 
 
EN 71   EN ANNEX VIII  
Estimation of costs and benefits for some products in option 1 and 2 
For option 1, the case of water heaters was analysed  in detail. On the basis of the results of the 
Preparatory Study, Task 6 (http:/ /www.ecohotwater.org/), the fo llowing information was used 
for the extra small water heaters: 
Category XS  
Market share 12.5%  
Life-time (years) 10  
Type  BC XS EIWH E 8 
Energy consumption kWh/y 1,762 1,348 
Electricity consumption 1,527 1,348 
Gas consumption 235 0 
Purchase price (EUR) 187 318 
Life-cycle cost (EUR) 1,961 1,667 
CO2 emissions (Tn) 1.198 0.917 
And 
Number of appliances sold per year 2,152,000 
Estimated number of installed appliances 21,520,000
The results are presented in the following table: 
    Baseline 2010 2011 2012 2013 2014 2015 2016 
total number of 
appliances-Least 
LC purchased 
(million)   0.0 2.2 2.2 2.2 2.2 2.2 2.2 2.2 
Number of Least 
LCC installed 
(million)   0.0 0.0 2.2 4.3 6.5 8.6 10.8 12.9 
Remaining number 
of appliances-BC 
(million)    21.5 19.4 17.2 15.1 12.9 10.8 8.6 6.5 
Additional 
N 0.0 281.9 281.9 281.9 281.9 281.9 281.9 281.9 
 
EN 72   EN Purchase Cost 
(million EUR) 
Discounted 
additional purchase 
cost (million EUR)     281.9 256.3 233.0 211.8 192.5 175.0 159.1 
N 0 493 493 493 493 493 493 493 
I 0 0 493 986 1,479 1,973 2,466 2,959 
O 5,799 5,219 4,639 4,059 3,479 2,900 2,320 1,740 Runing cost (M€/y) 
T 5,799 5,712 5,626 5,539 5,452 5,365 5,279 5,192 
Upfront + running 
cost (M€)   5,799 5,994 5,907 5,821 5,734 5,647 5,560 5,474 
Difference between 
Upfront and runnig 
costs to baseline 
(M€)     -195 -108 -22 65 152 239 325 
NPV of the 
difference of 
upfront and 
running cost to 
baseline (M€)     -195 -99 -18 49 104 148 184 
N 0 2,901 2,901 2,901 2,901 2,901 2,901 2,901 
I 0 0 2,901 5,802 8,703 11,604 14,504 17,405 
O 37,918 34,126 30,335 26,543 22,751 18,959 15,167 11,375 Energy 
consumption 
(Gwh) 
T 37,918 37,027 36,136 35,245 34,355 33,464 32,573 31,682 
Energy savings 
compared with 
baseline     891 1,782 2,673 3,564 4,455 5,346 6,236 
N 0 2 2 2 2 2 2 2 
I 0 0 2 4 6 8 10 12 
O 26 23 21 18 15 13 10 8 CO2 emission (M 
Tn) 
T 26 25 25 24 23 23 22 22 
Emission saving 
compared with     1 1 2 2 3 4 4 
 
EN 73   EN baseline (M Tn) 
N= New appliance (least life-cycle); I= Installed New appliances (least life-cycle); O= 
currently installed capacity, assimilated to Baseline appliance in the markets; T= Total 
For the case of extra large water heaters, the following information was used: 
Category XL  
Market share 5,5%  
Life-time (years) 10  
Type  BC XL COMBISTOR condensing
Energy consumption kWh/y 11,566 7,334
electricity  7,293 134
gas 4,273 7,200
Purchase price (EUR) 665 1,037
Life-cycle cost (EUR) 11,786 8,636
CO2 emissions (Tn) 8 5
And  
Number of appliances sold per year 946,880
Estimated number of installed appliances 9,468,800
The results are 
    BAU 2010 2011 2012 2013 2014 2015 2016 
total number of 
appliances-Least 
LC purchased 
(million)   0 1 1 1 1 1 1 1 
Number of Least 
LCC installed 
(million)   0 0 1 2 3 4 5 6 
Remaining number 
of appliances-BC 
(million)   9 9 8 7 6 5 4 3 
Additional 
Purchase Cost N 0 352 352 352 352 352 352 352 
 
EN 74   EN (million EUR) 
Discounted 
additional purchase 
cost (million EUR)     352 320 291 265 241 219 199 
N 0 308 308 308 308 308 308 308 
I 0 0 308 616 925 1,233 1,541 1,849 
O 13,441 12,097 10,753 9,409 8,064 6,720 5,376 4,032 Runing cost (M€/y) 
T 13,441 12,405 11,369 10,333 9,297 8,262 7,226 6,190 
Upfront + running 
cost (M€)   13,441 12,757 11,721 10,685 9,650 8,614 7,578 6,542 
Difference between 
Upfront and runnig 
costs to baseline 
(M€)     684 1,719 2,755 3,791 4,827 5,863 6,899 
NPV of the of 
difference between 
upfront and running 
cost to baseline 
(M€)     684 1,563 2,277 2,848 3,297 3,640 3,894 
N 0 6,944 6,944 6,944 6,944 6,944 6,944 6,944 
I 0 0 6,944 13,889 20,833 27,778 34,722 41,667 
O 109,516 98,565 87,613 76,661 65,710 54,758 43,806 32,855 Energy 
consumption (Gwh) 
T 109,516 105,509 101,502 97,495 93,487 89,480 85,473 81,466 
Energy savings 
compared with 
baseline     4,007 8,014 12,022 16,029 20,036 24,043 28,050 
N 0 5 5 5 5 5 5 5 
I 0 0 5 9 14 19 24 28 
O 74 67 60 52 45 37 30 22 CO2 emission (M 
Tn) 
T 74 72 69 66 64 61 58 55 
Emission saving 
compared with 
baseline (M Tn)     3 5 8 11 14 16 19 
 
EN 75   EN  N= New appliance (least life-cycle); I= In stalled New appliances (least life-cycle); O= 
currently installed capacity, assimilated to Baseline appliance in the markets; T= Total 
For option 2, the case of windows was analysed. The data for the analysis is fr om PricewaterHouse Cooper (2007).  
standard single glazed Double glazed 
Purchase price (euro/m2) 100 150 
Energy use during lifespan (kwh/m2) 8400 6480 
CO2 emitted during lifespan (kg 
CO2e/m2) 6297 4980 
 Replacement surface (m2/y)  52,141,600 52,141,600  
The replacement rate represents 4% of th e still unrefurbished windows throughout the EU. 
The results are shown in the table below. 
  Baseline 2010 2011 2012 2013 2014 2015 2016 2017
Purchase costs ( M 
EUR) 5,214  7,821  7,821  7,821  7,821  7,821  7,821  7,821  7,821
Additional purchase 
costs (M EUR)   2,607  2,607  2,607  2,607  2,607  2,607  2,607  2,60 7
NPV of Additional 
purchase costs (M 
EUR)   2,607  2,507  2,410  2,318  2,229  2,143  2,060  1,981
Energy consumption 
of new installations 
(GWh/y) 14,600  11,263 11,263 11,263 11,263 11,263  11,263 11,263 11,26 3
Cumulative energy 
savings compared 
with baseline 
(GWh/y)   3,337  6,674  10,011 13,348 16,685  20,022 23,359 26,69 6
Energy consumption 
(M €) 2,482  1,915  3,829  5,744  7,659  9,573  11,488 13,402 15,31 7
Cumualtive energy 
savings (M €)   567  1,135  1,702  2,269  2,837  3,404  3,971  4,538
NPV of cummulative 
energy savings (M€)   567  1,091  1,574  2,017  2,425  2,798  3,138  3,44 9
Total purchase cost - 
energy savings (M   - 2,040 - 1,416 - 837  - 300  196  655  1,078  1,468
 
EN 76   EN EUR) 
CO2 impacts (M t 
CO2e) 11  9  17  26  35  43  52  61  69 
Emissions avoided 
relative to baseline 
(M T CO2)   2.3  4.6  6.9  9.2  11.4  13.7  16.0  18.3 
 
In the case of only considering 50% of the windows replaced with double glazing and the 
other 50% with single glazing, th e results are presented below. 
  Baseline 2010 2011 2012 2013 2014 2015 2016 2017
Purchase costs (euro) 5,214  6,518  6,518  6,518  6,518  6,518  6,518  6,518  6,518 
Additional purchase 
costs   1,304  1,304  1,304  1,304  1,304  1,304  1,304  1,304 
NPV of Additional 
purchase costs   1,304  1,253  1,205  1,159  1,114  1,071  1,030  991 
Energy consumption 
of new installations 
(GWh/y) 14,600  12,931 5,631  5,631  5,631  5,631  5,631  5,631  5,631
Cummulative energy 
savings compared 
with baseline 
(GWh/y)   1,669  17,937 26,905 35,873 44,842  53,810 62,778 71,74 7
Energy consumption 
(M €) 2,482  2,198  4,397  6,595  8,793  10,991  13,190 15,388 17,58 6
Cummualtive energy 
savings (M €)   284  567  851  1,135  1,418  1,702  1,986  2,26 9
NPV of cummulative 
energy savings (M€)   284  545  787  1,009  1,212  1,399  1,569  1,72 4
Total purchase cost - 
enegy savings   - 1,020 - 708  - 418  - 150  98  327  539  734 
CO2 impacts (M t 
CO2e) 11  10  20  29  39  49  59  69  78 
Emissions avoided 
(M T CO2)   1.1  2.3  3.4  4.6  5.7  6.9  8.0  9.1