EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 13.11.2008 
SEC(2008) 2863 
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
 
Proposal for a  
 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
on the indication by labelling and standard  product information of the consumption of 
energy and other resources by energy-related products 
 
SUMMARY OF THE IMPACT ASSESSMENT  
{COM(2008) 778 final} 
{SEC(2008) 2862} 
 
EN 2   EN EXECUTIVE SUMMARY 
This Impact Assessment accompanies the proposa l for the recast of the 92/75/EEC “Energy 
Labelling Directive for Household Appliances”1 (hereafter ELD). The recast of the ELD is 
one of the elements of the Action Plan on Sustainable Consumption and Production and on 
Sustainable Industrial Policy (SCP/SIP). 
 
The ELD, which was adopted in 1992, requires re tailers to display a comparative label 
showing the level of energy consumption of hous ehold appliances to consumers at the point 
of sale. It is estimated that energy labelling has contributed to annual energy savings in the 
order of 3 Mtoe2 corresponding to emission reductions of  some 14 Mt of Co2 annually over 
the period 1996-2004. 
The energy label is compulsory for those pr oducts covered by implementing measures under 
the framework ELD. The energy labelling scheme has been successful in contributing to pull 
the market of household appliances towards more  energy efficient products. It provides useful 
                                                 
1 Council  Directive 92/75/EEC of 22 September 1992 on the indication by labelling and standard 
product information of the consumption of energy and other resources by household appliances. 
2 This does not take into  account energy savings from related self  commitments by C eced (white goods) 
and Eicta (TVs)  
 
EN 3   EN and comparable information to consumers, allo wing them to consider investing in better 
performing appliances in order to realize sa vings in taking into account the running costs 
(mainly energy consumption in use). 
It also helps manufacturers to position their pr oducts on the market and get some payback on 
their investments for introducing better and more innovative appliances. The scheme is 
therefore considered as a win- win instrument for consumers, industry and the environment. 
As announced in the Action Plan on Sustai nable Consumption and Production and on 
Sustainable Industrial Policy (SCP/SIP), the ELD together with the Ecodesign Directive could 
deliver more savings in energy and reduction of environmental impacts, if extended to all energy-related product groups (products that ha ve an impact on energy consumption during 
use). 
The current ELD is a framework that manda tes the Commission (assi sted by a Regulatory 
Committee) to adopt labelling implementing measures for specific household appliances
3. For 
these, an upgrade of the existing labels is  being prepared for adoption in 2009 and 2010. 
The impact assessment of the SCP/SIP has show n that the limited scope of the ELD restricts 
its potential to further mitigate climate change and contribute to the EU-wide target of 20% 
energy efficiency gains by 2020 and achieve the goals of sustainable production and 
consumption. This impact assessment report ther efore analyses further whether the scope and 
functioning of the ELD can be reinforced, how this can be done and what impacts it could 
have. However, as the ELD is a framework Di rective with no direct impact on products, the 
environmental, economic and social impacts can only be quantified in detail for those implementing measures to be adopted on sp ecific products. Accordingly, the potential 
advantages and disadvantages of  the possible revision are consid ered in the light of a number 
of selected priority produc t groups with significant enviro nmental impacts and for which 
labelling appears to be a relevant policy instrument. 
For the functioning of the ELD, the aim is to seek increased effectiveness of the ELD and its 
implementing measures while reducing the admini strative burden, and ex plore the use of ELD 
as a framework for harmonised mandatory public procurement and incentives in the Internal 
Market. 
                                                
 
3 Refrigerators, freezers and their combinations, wa shing machines, driers and their combinations, 
dishwashers, ovens, water heaters and hot-water  storage appliances, lighting sources and air-
conditioning appliances. 
 
EN 4   EN Four policy options are considered as follows: 
(1) No policy change, with two sub-options: 
(1a) BaU - business as usual,  (1b) BaU + 1 - full implementation of the current ELD scope. 
(2) Non-regulatory action. (3) Amend the Directive - full implementation of the current ELD scope, plus coverage 
of all energy-related products, excluding means of transport. 
(4) Repeal the Directive and implement its pr ovisions within the Ecodesign Directive - 
full implementation of the current ELD scope , plus coverage of all energy-related 
products, excluding means of transport.  
It is estimated that the policy option 1b (fully  implement the current framework) could lead 
to, based on the considered priority a ppliances, savings of some 22 Mtoe by 2020, 
corresponding to emission savings of about 65 Mt of CO2. More than half of these savings 
would come from the heating and water heatin g appliances alone, which have not yet been 
addressed under the ELD. The rest of the sa vings would come from  the upgrading of the 
existing eight measures, and from a new measure on televisions.  
Policy option 2 (voluntary agreements/self comm itments) would have advantages in adding 
little administrative burden to the business and administrations, depending on the way of 
implementing the non-regulatory action, but w ould fully rely on the feasibility and 
willingness from industry, which ha s rejected this option (CECED
4 and EICTA5). The 
capacity of this policy option to contribute to further energy savings was considered marginal 
at best. 
Policy option 3 (fully exploit cu rrent framework and extend th e scope to all energy-related 
products) involves some administrative burden for the recast but would save some €4 million in transposition costs for every upgraded or newly developed implementing measure if 
implementing Directives were replaced by implementing Regulations. It is estimated that broadening the scope of the ELD  to energy-related products coul d lead to additional savings 
of some 27 Mtoe by 2020
6, corresponding to emission reduction of close to 80 Mt of CO2 in 
comparison to BaU. This represents additional savings of some 5 Mtoe against the policy option BaU +1 alone from the three priority product groups considered (commercial heating 
and refrigeration and windows). More precise knowledge on the savings potential of these 
products will be available from the Ecodesi gn preparatory studies followed by product 
specific impact assessments. Additional chan ges like introducing provisions on the legal 
protection of the use of the label, clarifying information requirements and introducing a 
framework for mandatory public procurement and incentives would further reinforce the 
effectiveness of the scheme as well as increase the savings. 
                                                
 
4 European Committee of Manuf acturers of Domestic Equipment 
5 European Information & Communications Technology Industry Association 
6 The figure is composed of the estimated 22 Mtoe savings by 2020 from the full implementation of the 
ELD and of some 5 Mtoe additional savings from the broadening on the scope, based on considerations 
on three priority product groups (windows, comme rcial refrigeration and heating appliances).  
 
EN 5   EN Policy option 4, repeal the ELD  and implement energy labe lling within the Ecodesign 
Directive, could lead in theo ry to the same level of savi ngs as policy option 3 and would 
reduce the number of regulatory in struments, but could hardly be considered as simplification. 
This is due to the different nature of the le gal instruments: the Ecodesign Directive bans the 
less performing products regarding their global environmental performance focusing on all 
environmental aspects throughout the lifecycle of the product. The ELD provides an energy 
label showing to consumers the energy efficien cy performance of th e product during the use 
phase (and relevant use of other reso urces (like water) where relevant).  
The analysis and comparison of the policy options  indicates that the options 1b and 3 are the 
most cost-efficient and suitable  options with strongest stak eholder support to achieve the 
policy objectives. 
Monitoring and evaluation is proposed in th e framework of Action Plan on Sustainable 
Consumption and Production and Sustainable Industrial Policy in coordination with 
Ecodesign, Ecolabel and othe r related instruments.