9. 7. 79 Official  Journal  of the European  Communities No C 171/41 
Opinion  on the proposal  for a Council  Directive  on the indication  by labelling  of the energy 
consumption  of domestic  appliances,  and  on the proposal  for a Council  Directive  applying 
to electric  ovens  the  Council  Directive  on  the  indication  by labelling  of the  energy 
consumption  of domestic  appliances 
The text  referred  to the Committee  has  been  published  in Official  Journal  of the European 
Communities  No  C 212  of 6 September  1979,  pages  2 to 7. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 23 August  1978,  the  Council  referred  the abovementioned  proposal  to the  Economic 
and Social  Committee  in accordance  with  Article  100  of the  Treaty  establishing  the 
European  Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  prepared  its opinion  on the above  matter  at its 167th 
plenary  session,  held  in Brussels  on 4 and  5 April  1979. 
The full  text  of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  Treaty  establishing  the European 
Economic  Community,  and  in particular  Article  100 
thereof, 
Having  regard  to the  request  made  by the  Council  of 
the European  Communities  on 23 August  1978  for  an 
opinion, 
Having  regard  to the  decision  taken  by its Bureau  on 
24 October  1978,  instructing  the Section  for Protection 
of the  Environment,  Public  Health  and  Consumer 
Affairs,  to draw  up  an opinion  and  report  on  the 
matter, 
Having  regard  to the  opinion  issued  by the Section  for 
Protection  of the  Environment,  Public  Health  and 
Consumer  Affairs  on 6 March  1979, 
Having  regard  to  the  report  submitted  by  the 
rapporteur,  Mr  Hatry, 
Having  regard  to the  discussions  at its 167th  plenary 
session,  held  on  4 and  5 April  1979  (meeting  of 
4 April  1979), energy  and  better  consumer  information  at the point  of 
sale while  indirectly  contributing  towards  the protection 
of the environment. 
1.2. In  the  light  of  experience  in  non-member 
countries,  the Committee  shares  the Commission's  view 
that the  Directives  will  help  induce  consumers  to buy 
lower-energy-consuming  appliances.  The  Commission 
reckons  that  the resultant  saving  in energy  will  amount 
to around  1 % of total  energy  consumption  by 1990, 
assuming  that  10%  of all  domestic  appliances  are 
replaced  in any  given  year. 
1.3. Similarly,  the  environment  will  benefit  from  the 
cutback  in atmospheric,  water  and  ground  pollution 
from  power  stations  which  the  Commission  considers 
will result  from  the reduced  demand  for electricity. 
1.4. On  account  of these  general  considerations,  the 
Committee  supports  the  Commission  and  welcomes  its 
intention  to gradually  apply  the  proposed  labelling 
system  to the  other  appliances  listed  in the  main 
Directive. 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
unanimously: 
1. General  comments 
1.1. The  Committee  approves  the  Commission's 
proposals.  They  will  make  for  a more  rational  use  of 1.5. The  Committee  considers  that  consumers  should 
be provided  with  appropriate  information  about  the 
provisions  in this  present  Directive;  such  action  is also 
advocated  in other  Committee  opinions  and  reports  on 
consumer  information  and  energy  saving. 
1.6. The  Committee  considers  that  the  provision  of 
energy  consumption  data  by  means  of labelling  as 
No C 171/42 Official  Journal  of the European  Communities 9. 7. 79 
proposed  in the Directive  is just  one  facet  of the general 
information  which  should  be provided  for  for  the 
consumer.  The  Committee  refers  to its previous  stands 
on the need  for full  information  for the consumer  and, 
in the present  case,  to the need  for information  relating 
to all the  relevant  characteristics  of the  appliances  in 
question. 
2. Specific  comments  on the main  directive 
2.1. Article  1 
The Committee  notes  that,  according  to  the 
Commission  representative,  agreement  has been  reached 
between  government  experts  at the  Council  that 
vacuum-cleaners  should  fall outside  the Directive  on the 
grounds  that  it is technically  difficult  to measure  their 
energy  consumption. 
2.1.2.  The  Commission  also  states  that,  after  removing 
vacuum-cleaners,  Article  1 still  covers  appliances  that 
account  for  90  to  95  % of  total  electricity 
consumption  (for  non-heating  purposes)  by household 
appliances. 
2.1.3.  The  Committee  nevertheless  feels  that 
consideration  should  be given  to the  possibility  of 
eventually  including  within  the  scope  of the  Directive 
other  high  energy  consuming  appliances  such  as electric 
fires  and  storage  heaters  provided  that  there  are proven 
methods  for measuring  their  efficiency  and they  account 
for a considerable  proportion  of energy  consumption. 
2.2. Article  2 
2.2.1.  The  Committee  also  notes  that  agreement  has 
been  reached  between  experts  at the  Council  to the 
effect  that  Article  2 should  be optional.  The  Committee 
considers  that  the  labelling  provisions  should  be 
mandatory  and  not  optional.  Only  if they  are 
mandatory  can  there  be any  hope  that  a sufficient 
number  of firms  will  comply  with  the  regulations  to 
effect  the 1 % energy  saving  envisaged. 
2.3. Article  3 
2.3.1.  The  Committee  observes  that  Article  3 does  not 
cover  appliances  imported  into  the  EEC  from 
non-member  countries. 
2.3.2.  It therefore  suggests  that  Article  3 should 
include  a reference  to the responsibility  of importers  for making  sure  that  the appliances  which  they  import  are 
labelled  before  they  are put on sale. 
2.4. Article  10 
2.4.1.  The  Committee  considers  that  the  Member 
States  could  be given  21 months,  rather  than  two  years 
to comply  with  the Directive.  This  should  be adequate, 
bearing  in mind  that  the  draft  Directive  has  already 
been  the  subject  of discussions  with  interested  parties 
and that  all the Governments  agree  that  there  is a need 
to economize  on energy  consumption. 
2.5. Annex  1 
2.5.1.  The  Committee  considers  that  the  label  should 
be headed  'energy  consumption'  rather  than  'product 
information'  if the  data  given  only  refers  to energy 
consumption. 
2.5.2.  In the  view  of the  Committee  it would  be 
preferable  to replace  the proposed  Community  symbol 
(an outline  map  of the EEC)  by a symbol  that  makes  no 
reference  to the  composition  of the  Community,  and 
consequently  the  period  in which  the  product  was 
manufactured  (something  which  can  easily  be deduced 
from  the map). 
2.5.3.  The  Committee  considers  that  energy 
consumption  should  be measured  under  standardized 
conditions  of use,  as is stated  in the  sixth  recital.  It 
therefore  stresses  the importance  of having  uniform  and 
satisfactory  methods  of measurement  and  trusts  that  the 
relevant  standardization  work  at the CENELEC  will  be 
completed  as quickly  as possible.  The  Committee  hopes 
that consumers  will  be involved  with  the  work  of the 
standardization  bodies. 
3. Specific  comments  on the directive  on electric  ovens 
3.1. In view  of the comments  on the proposed  outline 
Directive,  the  Committee  approves  the  proposal  to 
apply  it in the first  instance  to electric  ovens. 
3.2. It considers,  however,  that  micro-wave  and  fan 
ovens  should  also  be covered  where  this  is technically 
possible. 
3.3. Although  it is unable  to take  a definitive  stand  on 
the matter,  the  Committee  doubts  whether  the 
indication  on  the  label  of consumption  per  hour 
provides  the  consumer  with  sufficiently  clear  and 
complete  information  to be  able  to make  a full 
assessment  of the product. 
9. 7. 79 Official  Journal  of the European  Communities No C 171/43 
Done  at Brussels,  5 April  1979. 
The Chairman 
of the Economic  and  Social  Committee 
Fabrizia  BADUEL  GLORIOSO 
Opinion  on the proposal  for a Council  Directive  relating  to the approximation  of the laws, 
regulations  and  administrative  provisions  of the  Member  States  concerning  misleading  and 
unfair  advertising 
The text  referred  to the Committee  has  been  published  in Official  Journal  of the European 
Communities  No  C 70 of 21 March  1978,  page  4. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 10 March  1978,  the Council  referred  the abovementioned  proposal  to the Economic  and 
Social  Committee  in accordance  with  Article  100  of the  Treaty  establishing  the European 
Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  prepared  its opinion  on the above  matter  at its 167th 
plenary  session,  held  in Brussels  on 4 and  5 April  1979. 
The full  text  of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE,  HAS  ADOPTED  THE  FOLLOWING  OPINION 
Having  regard  to the  Treaty  establishing  the European 
Economic  Community  and,  in particular,  Article  100 
thereof, 
Having  regard  to the  request  made  by the  Council  of 
the European  Communities  on 10 March  1978  for  an 
opinion, 
Having  regard  to the  Decision  taken  by its Bureau  on 
29 March  1978,  instructing  the  Section  for  Protection 
of the  Environment,  Public  Health  and  Consumer 
Affairs  to draw  up an opinion  and  a report  on the 
matter, 
Having  regard  to the  opinion  issued  by the  Section  for 
Protection  of the  Environment,  Public  Health  and 
Consumer  Affairs  on 6 March  1979, 
Having  regard  to  the  report  submitted  by  the 
rapporteur,  Mr Ramaekers, 
Having  regard  to the  discussions  at its 167th  plenary 
session,  held  on  4 and  5 April  1979  (meeting  of 
5 April  1979), following  a vote  by name,  (Article  45 of the  Rules  of 
Procedure)  resulting  in 77 votes  for,  2 against  and 
39 abstentions: 
1. General  comments 
1.1. The  Committee  observes  that,  in  proposing 
approximation  of  the  Member  States'  legislation 
concerning  misleading  and  unfair  advertising,  the 
Commission  has  taken  the  initiative  towards  the 
realization  of an  important  aim  laid  down  in the 
Community's  preliminary  programme  for  a consumer 
protection  and  information  policy. 
1.2. Advertising  is a socio-economic  phenomenon  that 
is part  of our  contemporary  society  and  one  of the 
elements  that  go  to  make  up  current  marketing 
techniques.  It plays  an  important  role  in relations 
between  competitors  and  in relations  between  industry