Table of contents 1.Introduction: Political and legal context 1.1.Benefits of Ecodesign and Energy Labelling 1.2.Legal framework 1.3.Legal context of the reviews 1.4.Political Context 2.Problem definition 2.1.Problem 1: Outdated energy efficiency requirements 2.2.Problem 2: Poor ‘Circular Economy’ performance 2.3.Problem 3 – Loopholes and less appropriate requirements for some technologies 2.4.General market failures 2.5.Who is affected? 2.5.1. Household refrigerating appliances’ manufacturers and retailers 2.5.2. Recycling industry 2.5.3. Consumers 2.5.4. Society as a whole 3.Why should the EU act? 3.1.Legal basis 3.2.Subsidiarity: Necessity of EU action

3.3.Subsidiarity: Added value of EU action 4.Objectives: What is to be achieved? 4.1.General objectives 4.2.Specific objectives 5.What are the available policy options? 5.1.What is the baseline from which options are assessed? 5.2.Description of the policy options 5.2.1. Option 1 – Baseline 5.2.2. Option 2 – Least Life Cycle Cost (“LLCC”) 5.2.3. Option 3 – Ambitious 5.2.4. Option 4 – Lenient 5.3.Options discarded at an early stage 5.3.1. Voluntary agreement by the industry 5.3.2. LLCC with stricter timing 6.What are the impacts of the policy options? 6.1.Environmental impact 6.1.1. Final energy savings 6.1.2. GHG-emissions 6.1.3. Circular Economy perspective 6.2.Business impacts

6.2.1. Business revenue 6.2.2. Innovation, Research and Development, Competitiveness 6.2.3. Compliance costs 6.2.4. Intellectual Property Rights 6.2.5. Stranded investments 6.3.Consumer expenditure 6.4.Administrative burden 6.5.Social Impact 6.5.1. Affordability 6.5.2. Health, Safety and Functionality Aspects 6.5.3. Employment 6.6.Linearity of the impacts in between the LLCC and ambitious options 7.How do the options compare? 7.1.Summary of the impacts 7.2.Market Surveillance 7.3.Assessment in view of Article 15(5) of the Ecodesign Framework Directive 7.4.Assessment in view of the objectives 8.Preferred option 8.1.Preferred option – Why? 8.2.REFIT (simplification and improved efficiency)

9.How will actual impacts be monitored and evaluated? Annex 1: Procedural information Annex 2: Stakeholder consultation Annex 3: Who is affected and how? Annex 4: Analytical methods Annex 5: Minutes of the consultation forum Annex 6: Employment and Market in the household refrigerating appliances sector Annex 7: The Ecodesign and Energy Labelling Framework Annex 8: Existing Policies, Legislation and Standards affecting household refrigerating appliances Annex 9: Evaluation of the Ecodesign and Energy Labelling Regulations for household refrigerating appliances Annex 10: Problem drivers Annex 11: LLCC scenario Annex 12: Analysis of the impact details Annex 13: Glossary Annex 14: List of Figures Annex 15: List of Tables This report commits only the Commission’s services involved in its preparation and does not prejudge the final form of any decision to be taken by the Commission. 1.Introduction: Political and legal context This impact assessment relates to the review of Commission Regulation (EC) No 643/2009 on the ecodesign requirements for household refrigerating appliances and Commission Delegated Regulation (EU) No 1060/2010 on the energy labelling requirements for household refrigerating appliances.

1.1.Benefits of Ecodesign and Energy Labelling Ecodesign and energy labelling are recognised globally as one of the most effective policy tools in the area of energy efficiency. They are central to making Europe more energy efficient, contributing in particular to the ‘Energy Union Framework Strategy’, and to the priority of a ‘Deeper and fairer internal market with a strengthened industrial base’. Firstly, this legislative framework pushes industry to improve the energy efficiency of products and removes the worst-performing ones from the market. Secondly, it helps consumers and companies to reduce their energy bills. In the industrial and services sectors, this results in support to competitiveness and innovation. Thirdly, it ensures that manufacturers and importers responsible for placing products on the European Union (EU) market only have to comply with a single EU-wide set of rules. It is estimated that by 2020, ecodesign and energy labelling regulations will deliver around 175 Mtoe (i.e. about 2035 TWh) of energy savings per year in primary energy in comparison to if there were no measures in place. This is roughly equivalent to Italy's energy consumption in 2010, close to half the EU 20 % energy efficiency target by 2020 and about 11 % of the expected EU primary energy consumption in 2020. The average household will invest in more expensive and efficient products, but in return saves about € 500 annually on its energy bills by 2020. Although the cost for industry, service and wholesale and retail sectors will increase, it will result in EUR 55 billion per year of extra revenue by 2020. This legislative framework benefits from broad support from European industries, consumers, environmental non-governmental organisations (NGOs) and Member States (MSs), because of its positive effects on innovation, increased information for consumers and lower costs, as well as environmental benefits. Household refrigerating appliances have been subject to EU energy labelling measures since 1995 and minimum energy efficiency requirements since 1999. Since then, the energy consumption and carbon emissions have reduced with more than 60% compared to business as usual (BAU), the administrative burden has been modest and market actors are positive on the impact of these instruments on the market. 1.2.Legal framework In the EU, the Ecodesign Framework Directive sets a framework requiring manufacturers of energy-related products to improve the environmental performance of their products by meeting minimum energy efficiency requirements, as well as other environmental criteria such as water consumption, emission levels or minimum durability of certain components before they can place their products on the market. The Energy Labelling Framework Regulation complements the Ecodesign Framework Directive by enabling end-consumers to identify the better-performing energy-related products, via an A-G/green-to-red scale. The energy label is recognised and used by 85% of Europeans. The legislative framework builds upon the combined effect of the two aforementioned pieces of legislation. See Figure 1 for a visualisation of this effect. For those consumers that do not use the energy label to select a product and for consumers in a tenant-landlord situation (where the landlord buys the refrigerating appliance and the tenant pays the bill), ecodesign requirements are important, as it safeguards consumers from the worst performing products. The Ecodesign framework Directive and the Energy Labelling framework Regulation are implemented through product-specific implementing and delegated regulations. To be covered, the energy-related products must (i) represent a significant volume of sales (more than 200000 units a year), (ii) have a significant environmental impact within the EU and (iii) represent a significant energy improvement potential without increasing the cost excessively, see also Article 15.2 of the Ecodesign Framework Directive. As an alternative to the mandatory ecodesign requirements, voluntary agreements or other self-regulation measures can be presented by the industry, see also Article 17 of the Ecodesign Framework Directive. If certain criteria are met the Commission formally recognises these voluntary agreements. The benefits are a quicker and more cost-effective implementation, which can be more flexible and easier to adapt to technological developments and market sensitivities For more details about the legal framework, including a full list ecodesign and energy labelling measures, see Annex 7. Under this framework, household refrigerating appliances are regulated by Commission Ecodesign Regulation (EC) No 643/2009 and Commission Delegated Energy Labelling Regulation (EU) No 1060/2010. The scope of these measures are: ·household refrigerating appliances with a volume smaller than or equal to 1500 l (including wine storage appliances and mini-bars). Included in the scope are also: ·household refrigerating appliances sold for non-household use, e.g. chest freezers, or for the refrigeration of items other than foodstuffs, e.g. refrigerating appliances used for storage of medicine;

·electric mains-operated household refrigerating appliances that can be battery-operated, e.g. mini fridges that can be powered by electricity from the gird or by battery. The EU Ecolabelling Regulation (Regulation (EC) 66/2010 ) complements ecodesign and energy labelling. It is a voluntary scheme that awards products with the best environmental performance throughout their lifecycle. Products that fulfil the criteria can bear the EU ecolabel, see Figure 2. Since 2011, household refrigerating appliances are no longer covered by the Ecolabelling Regulation, because the ecolabel did not bring clear benefits in comparison to the energy label. An overview of existing policies, legislations and standards affecting household refrigerating appliances in the EU and outside is given in Annex 8. 1.3.Legal context of the reviews Article 7 of the Ecodesign and Energy Labelling Regulations for household refrigerators requires both regulations to be reviewed in the light of technological progress no later than five years after their entry into force. This review should in particular assess the verification tolerances of Annex V and the possibilities for removing or reducing the values of the correction factors of Annex IV. Moreover, the Ecodesign working plan 2016-2019 also includes the review of both regulations, requiring in particular to examine how aspects relevant to the circular economy can be assessed and taken on board. This is in line with the Circular Economy Initiative , which concluded that product design is a key in achieving the goals, as it can have significant impacts across the product life cycle (e.g. in making a product more durable, easier to repair, reuse or recycle). Finally, in August 2017, the new Energy Labelling framework Regulation (EU) 2017/1369 entered into force, repealing Directive 2010/30/EU . Under the repealed Directive, energy labels were allowed to include A+ to A+++ classes to address the overpopulation of the top classes. Over time, due to technological development, also the A+ to A+++ class became overpopulated, thereby reducing the effectiveness of the labels significantly. To resolve this, the new framework regulation requires a rescaling of existing energy labels, back to the original A to G scale. Article 11 of the Energy Labelling framework Regulation lists 5 priority product groups for which new delegated acts with rescaled energy labels must be adopted at the latest on 2 November 2018. Household refrigerating appliances is one of the priority product groups. 1.4.Political Context Several new policy initiatives indicate that ecodesign and energy labelling policies are relevant in a broader political context. The main ones are the Energy Union Framework Strategy, which calls for a sustainable, low-carbon and climate-friendly economy, the Paris Agreement, which calls for a renewed effort in carbon emission abatement, the Gothenburg Protocol, which aims at controlling air pollution, the Circular Economy Initiative , which amongst others stresses the need to include reparability, recyclability and durability in ecodesign, the Emissions Trading Scheme (ETS), aiming at cost-effective greenhouse gas (GHG) emissions reductions and indirectly affected by the energy consumption of the electricity using products in the scope of ecodesign and energy labelling policies, and the Energy Security Strategy, which sets out a strategy to ensure a stable and abundant supply of energy. 2.Problem definition 2.1.Problem 1: Outdated energy efficiency requirements The problem: The current ecodesign requirements for household refrigerating appliances no longer capture cost-effective energy savings, and the current energy label no longer allows consumers to effectively differentiate sufficiently between the appliances on the market. Since the entry into force of the current Ecodesign and Energy Labelling Regulations in 2009 and 2010 respectively, the energy efficiency of household refrigerating appliances has increased significantly. In the period 2010-2015, the average energy use of a household refrigerating appliance decreased from 242 kWh/a to 201 kWh/a (see also Annex 12.2). Today, they can easily achieve the existing ecodesign limits and all models reside in the top 3 classes of the energy label. The total electricity consumption of EU household refrigeration appliances decreased significantly from 120 TWh/a in 2005 to 86 TWh/a in 2015 (40 %). This decrease happened notwithstanding the fact that the net volume of refrigerating appliances increased with 1.2 % per year and number of refrigerating appliances in the market has increased from 291.4 million units in 2005 to 303.2 million units in 2015 (4% increase). Despite the reduction in energy consumption, refrigeration appliances are still one of the largest electricity consumers in households (after electric water heaters and lighting, but before televisions, electric ovens, washing machines, dishwashers, etc.), see also Figure 3.

The energy consumption of refrigerating appliances in comparison to the other ecodesign regulated products is shown in Figure 4. In 2009, it was projected that the electricity consumption of household refrigeration appliances in a BAU scenario in 2030 would decrease to 57 TWh/a, assuming that the regulations are at least periodically updated, to ensure their effectiveness. The 2016 Review study suggested that the electricity consumption of household refrigerating appliances could further decrease by an additional 10 TWh/a in 2030 to a level of 47 TWh/a by setting the Ecodesign requirements at the level of the Least Life Cycle Cost (LLCC). Without an update of the energy label and ecodesign measures, they will lose their effectiveness. In addition, the search cost for energy conscious consumers will increase and the incentives for the industry to develop more energy-saving products will be lower. The drivers of the problem: Problem driver 1: Technological progress - Technology for household refrigerating appliances keeps evolving, thereby improving energy efficiency. At the time of entry into force, no models qualified for the A+++ energy efficiency class and the share of models qualifying for the A++ energy efficiency class was less than 10%. Today, the top 3 energy efficiency classes are overpopulated, with the share of models in the A+++ label being more than 11 %, and more than 40 % in the A++ class. This makes it more difficult to distinguish between models. Moreover, the "A+", "A++" and "A+++" classes introduced by the Energy Labelling Framework Directive (Directive 2010/30/EU) have shown to be less effective in persuading consumers to buy more efficient products than the A to G scale. Problem driver 2: Outdated calculations - The existing energy efficiency calculations do not or no longer properly account for the real-life performance of modern refrigerating appliances. This is because some of the correction factors used in the metrics are outdated, others are used as loopholes and several cloud the real energy efficiency of the appliances. Problem driver 3: New global standard - A new International Electrotechnical Commission (IEC) standard for household refrigerating appliances, IEC 62552:2015, was published in 2015. This standard aims to be universally applicable, more efficient, more accurate and more reliable than the one currently used in the regulations, and the requirements applicable to products sold in the EU should be updated to take this new standard into account. 2.2.Problem 2: Poor ‘Circular Economy’ performance The problem: The current Ecodesign and Energy Labelling Regulations lack requirements that contribute to Circular Economy objectives, such as for reparability, recyclability and food waste prevention. The existing requirements focus mainly on energy efficiency improvements as the most significant environmental impact during the life-cycle of household refrigerating appliances. Better design can make products more durable or easier to repair, upgrade or remanufacture. It can help recyclers to disassemble products in order to recover valuable materials and components. Overall, it saves resources. The current market signals appear insufficient to make this happen, in particular because the interests of producers, users and recyclers are not aligned. In addition, reparability can be important to consumers, and products can contain valuable materials that should be made easier to recycle (e.g. rare earth elements in electronic devices). It is therefore essential to provide incentives for improved product design, while preserving the single market and competition, and enabling innovation through Ecodesign. Improved reparability will maintain or extend the useful product life, but can also contribute to the product’s energy efficiency throughout its life. It should however be noted that for refrigerating appliances the impact of the energy consumption is still the largest environmental impact with still enough potential for improvement. Table 1 shows data about the failure rates in the UK and Germany. For Germany the 13% is a significant increase from the 7% reported in the past. Thermostats/thermistors and electronics are the most frequent components to fail, while compressor failure is relatively rare (4% of repairs). (Review Study 2016)

Failure rate Period Germany 13% First 5 years UK 38% First 8 year The energy efficiency of a refrigerator or freezer diminishes by some 10% over a 15-16 year product life. This is caused by the aging of insulation foam material (diminished insulation value over time) and the wear and tear of door gaskets (leading to ice build-up) and interior elements. Insulation foam materials cannot be replaced as they are integrated in the cabinet of the appliance. Door gaskets, on the other hand, could be replaced, but they are often fully integrated into the door and spare gaskets are often not available. (Review study 2016) Recycling of household refrigerating appliances is regulated by the WEEE Directive. Article 8(2) of this Directive includes a list of materials which need to be collected separately during the recycling process. Today, the design of household refrigerating appliances does not completely facilitate this process. Another element relevant for material efficiency is food waste caused by spoilage and bad planning. Food production 'from farm to fork' constitutes almost 20% by weight of the EU's total Domestic Material Consumption (DMC). End-users, i.e. private households and food services, waste 18% of those resources. Of this end-use waste, 60% is due to food spoilage and bad planning and thus avoidable. Refrigerating appliances store two-thirds of food and drinks prior to their consumption. They play an important major role in preventing food spoilage and could contribute to better planning by being designed for optimised food preservation. Over 85% of fridges only include a standard fresh food compartment at a temperature of +4 to +5°C (possibly next to a freezer compartment). For about half of the fresh food (and drinks) this is either too warm or too cold for optimal food preservation. The presence of a chiller (−1 to 0°C) and a cellar compartment (8-14°C) could increase the shelf-life, in days, with on average a factor 3 or 4. The Complementary Study 2017 indicated that refrigerating appliances that are designed for optimised food preservation consume at least 20% more electricity than the average refrigerating appliance on the market today. To compensate for a 20% higher electricity consumption, it would be sufficient to save 2% on end-use waste,. The current lack of requirements on Circular Economy aspects means that cost-effective improvements to the ‘circularity’ of these products are not captured and that consumers do not benefit from better reparable and more durable appliances that contribute to reducing food waste. Without an update of the requirements, the problem is expected to remain as described above. The drivers of the problem: Problem driver 1/ Availability and replacements of spare parts: Currently no measures exist which regulate the availability of spare parts. The Review study 2016 suggests that a minimum availability of those spare parts that fail most frequently (i.e. thermostats and temperature sensors) or cause an efficiency loss (i.e. door gaskets) would be useful, also after the end of production of a model. If spare parts are available, it is often not clear to end-users where to order them and how to replace them. In some cases broken parts can simply not be replaced because they cannot be removed without damaging (e.g. the lamp and the lamp cover) or replacing a significant part of the appliance (e.g. the door gaskets versus replacement of the complete door). Consequently, appliances are often not repaired at all. Problem driver 2/ Design for recycling: The recycling requirements in Article 8(2) of the WEEE Directive are not directly applicable to product manufacturers, they are applicable to recyclers. Hence manufacturers are not always incentivised to design their products in view of this requirement. Problem driver 3/ Design for optimised food storage: When buying a refrigerating appliance, consumers make their decisions based on energy efficiency and price (Review Study 2016). For appliances with optimised design for food storage the energy consumption and price will be higher than for a comparable unit with only a fresh food storage compartment (at a temperature of +4 to +5°C). Hence, without taking action, the market uptake of these products will remain low. 2.3.Problem 3 – Loopholes and less appropriate requirements for some technologies The problem: The current regulations suffer from an unclear and technology-prescriptive scope, creating uncertainty as to whether some products are in or out of the scope of the current regulations, creating possible loopholes, and resulting in less appropriate requirements. This causes an unlevel playing field for industry, and Market Surveillance Authorities (MSAs) have difficulties to evaluate the scope and perform proper market surveillance. For example, professional chest freezers, i.e. chest freezers not used in a household environment, are identical in practical terms to household chest freezers. By declaring these chest freezers as “professional”, manufacturers obtain that they are excluded from the scope of the regulations. Given that professional chest freezers are specifically excluded from the Ecodesign Regulation for Professional Refrigeration, they are not in the scope of any ecodesign or energy labelling regulation, thereby creating a loophole. The total energy consumption of chest freezers sold in Europe is around 0.4 TWh/a. Mini bars are typically equipped with absorption refrigeration generators. These low noise refrigerating appliances are specifically designed to be installed in hotel rooms where guests sleep. The EU market for low noise refrigerating appliances including mini-bars amounts to 0.2-0.3 million units, consuming in total around 0.6 TWh/a. While all mini-bars were intended to be in the scope of the current Regulation, the use of mini bars in a ‘commercial’ context (i.e. a hotel room) has led to confusion about their inclusion. Moreover, a German court ruled in 2014 that they should not be considered household refrigerating appliances and hence are out of the scope of the current Regulations, creating further confusion. Furthermore, the regulations categorise products on the basis of different technologies, e.g. ‘compressor’ or ‘absorption and other’ technology. This means that certain technologies, including new ones, are covered (e.g. thermo-electric) but with less appropriate requirements (i.e. making it too easy or too difficult to comply). Without an update of the requirements, the problem is expected to remain as described above.

The drivers of the problem: Problem driver 1: Unclear scope - the ambiguities in the scope of the current regulations result in uncertainty about the inclusion of certain products thereby creating potential loopholes. Moreover, since the entry into force of the current Ecodesign and Energy Labelling Regulations for household refrigerating appliances, other ecodesign and energy labelling regulations have been published, or are in preparation, which have refrigerating appliances in their scope. Possible overlap or gaps between these regulations exist. Figure 5 shows the different Regulations with refrigerating appliances and the products in their scope which potentially overlap. Problem driver 2: Technological progress - New technologies have been developed and are being developed in respect of refrigerating. Some of these have lower efficiencies, but have functional characteristics (e.g. they are mobile or are very silent) which justify their continued placing on the market. This technological progress results in technologies being covered but with less appropriate requirements. A more detailed description of the problems and problem drivers is given in Annex 10. An evaluation of the regulatory measures is presented in Annex 9. 2.4.General market failures In addition to the product specific problem drivers described in Sections 2.1, 2.2 and 2.3, some general market failures have been identified: Myopic behaviour - Without up to date energy efficiency requirements and energy labels, economic actors (both business and private) will not choose the product that is the most cost-effective over the product's life-time. This is because economic actors are limited by the information they have, their knowledge about products, and the finite amount of time they have to make a decision. Split incentives – Without up to date energy efficiency requirements, the guarantee that the products will be cost-effective over their life-time is lost. This is especially important for a certain group of consumers, in particular those in a landlord-tenant situations, in where the landlord buys the appliance and the tenant pays the energy bill. Price reflection – The price of the products does not fully reflect the real environmental costs to society. Hence, without setting requirements that will improve the environmental performance of the product, the different actors in the life cycle of the appliance will not be incentivised to improve these aspects of the appliance. 2.5.Who is affected? 2.5.1.Household refrigerating appliances’ manufacturers and retailers For manufacturers and retailers, the energy label is one of the main market drivers and an important quality feature. Globally, the household refrigerating appliance industry is highly competitive, with Asian manufacturers rapidly expanding their global market share. For these latter manufacturers, product price is the main selling point. The energy label allows EU industry to distinguish itself based on quality and innovation rather than solely on price. In 2015, the total employment in the household refrigerating sector in the EU was estimated at 166 000 jobs, around 19.4 million units were sold in the EU and the EU turnover was EUR 10.1 billion in consumer price. More information about employment and the size of the market of household refrigerating appliances can be found in Annex 6. Important manufacturers with EU production facilities are Electrolux, BSH, Whirlpool, Candy and Liebherr. Rapidly growing importers are Arcelik/BEKO of Turkey, and Samsung and LG of South Korea. Household refrigerating appliances manufacturers usually make the main cabinet-components in-house (i.e. the blow-formed inner-liner, insulation, the folded steel coil cabinet, the roll-bonded or Z-bonded evaporator and the condenser). Refrigerator/freezer doors require a special production line, which may be made in-house or by an external supplier. Other parts, like interior-elements (glass-shelves, containers, lamps, etc.), compressors and electronics are likely to be bought from external suppliers, also outside the EU. Almost all manufacturers are large companies. Small and Medium-sized Enterprises (SMEs) are only found in niche markets, such as wine storage appliances and related luxury refrigeration/conditioning (for cheese, chocolate, fur-coats; also humidors). Examples are Eurocave, Groupe FRIO (brands: Climadiff, Avintage, La Sommeliere), these SMEs compete with the large manufacturers such as Liebherr, Bosch and Haier. There is one large manufacturer (Dometic) for absorption appliances and a few SME-manufacturers in the minibar market with thermo-electric devices. The European industry association is APPLiA.

In the traditional retail sector the position of larger retail chains such as Metro (Media Markt) and Carrefour is increasing. For built-in appliances (29 % of the market) kitchen suppliers are important. Internet sales exist but the growth rate, especially for the more expensive no-frost appliances, is not higher than for the other distribution channels of this product group. The European association for retailers are Independent Retail Europe and EuroCommerce. 2.5.2.Recycling industry For recyclers, design requirements that facilitate the separate collection of the materials listed in Article 8(2) of the WEEE Directive would reduce the time needed and cost to disassemble and shred a household refrigerating appliance. Recycling companies are situated all over the EU . Some of the bigger recyclers are Coolrec in the Netherlands and Belgium, SIMS in the UK and Derichebourg in France. The recycling industry is represented by the European Recycling Industries’ Confederation (EURIC). 2.5.3.Consumers For consumers, the energy label offers a unique opportunity to make an informed choice as to which products offer the best environmental and energy performance allowing them to save money in the long run. Ecodesign requirements safeguard consumers from the worst performing products. Spare part availability improves the reparability of household refrigerating appliances. This ensures that consumers can have their appliances repaired, at least until the appliance reaches a lifetime equal to the simple payback period (6-7 years on average, see Annex 4.8) when the higher investment cost in a more efficient appliance is recuperated through lower electricity bills. Avoiding food waste by improving functionality not only gives consumers the opportunity to contribute to a more sustainable society but could also save them on average EUR 125/year (Complementary study 2017). Consumers are represented by the Bureau Européen des Unions de Consommateurs (BEUC) and the European Association for the Co-ordination of Consumer Representation in Standardisation (ANEC). 2.5.4.Society as a whole For society as a whole, ambitious policies in the area of energy efficiency are important tools to mitigate climate change. Effective and efficient energy labelling and ecodesign regulations contribute to achieving goals set in the Paris Agreement and they help achieve the 2030 EU climate goal. Environmental organisations are represented by the European Environmental Citizens Organisation for Standardisation (ECOS), the European Environment Bureau (EEB), TopTen, the Collaborative Labelling and Appliance Standards Program (CLASP). 3.Why should the EU act? 3.1.Legal basis The legal basis for acting at EU level through the Ecodesign framework Directive and the Energy Labelling framework Regulation is Article 114 and Article 194 of the Treaty on European Union and the Treaty on the Functioning of the European Union (TFEU) respectively. Article 114 relates to the "the establishment and functioning of the internal market", while Article 194 gives, amongst others, the EU the objective "in the context of the establishment and functioning of the internal market and with regard for the need to preserve and improve the environment" to "ensure security of energy supply in the Union" and "promote energy efficiency and energy saving and the development of new and renewable forms of energy". The Ecodesign Framework Directive and Energy Labelling Framework Regulation include a built-in proportionality and significance test. For the Ecodesign Framework Directive, Articles 15(1) and 15(2) state that a product should be covered by an ecodesign or a self-regulating measure if the following conditions are met: ·The product should represents a significant volume of sales; ·The product should have a significant environmental impact within the EU; ·The product should present a significant potential for improvement without entailing excessive costs, while taking into account:

o an absence of other relevant Community legislation or failure of market forces to address the issue properly, oa wide disparity in environmental performance of products with equivalent functionality; The procedure for preparing such measures are described in Article 15(3). In addition, the criteria of Article 15(5) should be met: ·No significant negative impacts on user functionality of the product; ·No significant negative impacts on Health, safety and environment ·No significant negative impacts on affordability and life cycle costs ·No significant negative impacts on industry’s competitiveness (including SMEs see Section 6.5.3). The Energy Labelling Framework Regulation includes similar criteria for products covered by an energy label: ·The product group should have significant potential for saving energy and where relevant, other resources; ·Models with equivalent functionality should differ significantly in the relevant performance levels within the product group; ·There should be no significant negative impact as regards the affordability and the life cycle cost of the product group; ·The introduction of energy labelling requirements for a product group should not have a significant negative impact on the functionality of the product during use. During the review process (Review study 2016), it was established that household refrigeration appliances fulfil the above eligibility criteria. 3.2.Subsidiarity: Necessity of EU action Action at EU level gives end-users the guarantee that they buy an energy efficient product and provides end-users with harmonised information no matter in which MS they purchase their product. This is becoming all the more relevant as the online trade increases. With ecodesign and energy labelling at EU level, energy efficient products are promoted in all MSs, creating a larger market and hence greater incentives for the industry to develop them. It is essential to ensure a level playing field for manufactures and dealers in terms requirements to be met before placing an appliance on the market and in terms of the information supplied to customers for sale across the EU internal market. For this reason EU-wide legally binding rules are necessary. Market surveillance is carried out by the MSAs appointed by MSs. In order to be effective, the market surveillance effort must be uniform across the EU to support the internal market and incentivise businesses to invest resources in designing, making and selling energy efficient products. Finally, Regulation (EU) 2017/1369 requires the Commission to update the current energy labelling regulation for fridges, in particular as regards rescaling the label to remove the A+ to A+++ classes. 3.3.Subsidiarity: Added value of EU action There is clear added value in requiring minimum energy efficiency levels and energy label class limits at EU-level.

Without harmonised requirements at EU level, MSs would be incentivised to lay down national product-specific minimum energy efficiency requirements in the framework of their environmental and energy policies. This would undermine the free movement of products. Before the existing ecodesign and energy label measures were implemented, this was in fact the case for many products. 4.Objectives: What is to be achieved? 4.1.General objectives Following the legal basis in the TFEU, the general objectives are to: 1.Facilitate free circulation of efficient refrigeration appliances within the internal market; 0.Promote competitiveness of the EU refrigeration appliances industry through the creation or expansion of the EU internal market for sustainable products; 1.Promote the energy efficiency of refrigeration appliances; 2. Contribution to the Commission's objective to reduce energy consumption by at least 30 % and domestic greenhouse gas (GHG) emissions by 40 % by 2030; implement the energy efficiency first principle established in the Commission Communication on Energy Union Framework Strategy; and 3.Increase energy security in the EU and reduce energy dependency through a decrease in energy consumption of household refrigeration appliances. There are several synergies between these objectives. Reducing electricity consumption (by increasing the energy efficiency) leads to lower carbon, acidifying and other emissions to air. Tackling the problem at EU level enhances efficiency and effectiveness of the measure. 4.2.Specific objectives The specific objectives of the policy options considered in this impact assessment are to correct the problems identified in the problem definition (Section 2): 1.Update the energy efficiency requirements and the energy label in line with international and technological developments, and the revised Energy Labelling framework Regulation, to achieve cost-efficient energy savings; 2.Contribute towards a circular economy in the EU by including requirements on spare part availability, recyclability and food waste reduction; 3.Redefine the scope to close potential loopholes and adopt a technology neutral approach. These objectives will drive investments and innovations in a sustainable manner, increase monetary savings for the consumer, contribute to the Energy Union Framework Strategy and the Paris Agreement, contribute to the Circular Economy Initiative and strengthen the competitiveness of EU industry. 5.What are the available policy options? The procedure for identifying policy options follows from the Better Regulation Toolbox . Specific measures in the policy options are the result of a combination of initiatives mentioned in the Review study 2016, the evaluation in Annex 9, the Inception Impact Assessment , and inspiration taken from the Ecodesign Framework Directive and the Energy Labelling framework Regulation. They are aimed at addressing the issues identified in Section 3 and achieving the policy objectives defined in Section 4. The policy options are listed in Table 2.

Option Name Short name Description Option 1 Baseline BAU No further action, the household refrigeration appliances regulations currently in place remain unchanged Option 2 Least Life Cycle Cost LLCC Ecodesign limits at the LLCC level of EEI*=30 (based on the harmonised standard), circular economy requirements, A-G energy rescaled label Option 3 Ambitious Ambi The LLCC scenario, with EEI + 25% Option 4 Lenient Lenient The LLCC scenario, with EEI – 20% *Energy Efficiency Index (EEI) Figure 6 shows the link between the problems, the drivers, the objectives and the measures proposed in this Section. 5.1.What is the baseline from which options are assessed? In the baseline, the current Ecodesign and Energy Labelling Regulations and all other relevant EU-level policies and measures are assumed to continue. From 2020 onwards, lamps and electronic displays in household refrigerating appliances may be subject to ecodesign and energy labelling regulations. The impact assessment for the ecodesign and energy labelling regulations for both product groups, is ongoing. Hence, today it is too early to take the impact into account in the baseline. According to the Energy Labelling framework Regulation, products have to be registered in the product database from 1 January 2019 onwards, for all products belonging to models placed on the market after 1 January 2019; and by 30 June 2019 for products belonging to models placed on the market between 1 August 2017 and 1 January 2019. The requirement in the ETS to reduce emissions (from amongst other electricity production) will impact refrigerating appliances in a baseline scenario. Indeed, inefficient refrigerating appliances lead to more energy consumption. More electricity consumption increases the demand for ETS allowances. This either leads to higher ETS prices (which could in turn increase electricity prices) or to the need for additional emission reductions in ETS sectors (higher renewable energy targets or more reductions in industry). International policies are being developed for household refrigerating appliances, based on the new global test standard (see Annex 10). This will impact household refrigerating appliances in the EU. If the EU lags behind, the competition in the EU might change focus from innovation and quality to price. In addition, the use of the global standard in ecodesign and energy labelling regulations will enhance global competition for EU manufacturers. The use of the EU standard in ecodesign and energy labelling will result in double testing of the products (according to the EU standard and the global standard), in which case EU manufacturers will be able to compete globally at an increased costs (due to increased testing). Alternatively, it will result in testing of the products according to the EU standard only, in which case they will not be able to compete on the global market. In the baseline, the impact of the new global test standard has been taken into account. Sections 2.1, 2.2 and 2.3 describe how the situation will evolve in a baseline scenario in terms of energy savings, circular economy and scope. 5.2.Description of the policy options 5.2.1.Option 1 – Baseline Option 1 forms the baseline for the impact assessment and is described in Section 5.1. 5.2.2.Option 2 – Least Life Cycle Cost (“LLCC”) The LLCC scenario includes the following measures for the Ecodesign and Energy Label scope, test standard and metrics, energy efficiency limits and circular economy. Table 3 shows the proposed measures under Option 2. Identified problems Corrective measures Problem 1: Outdated energy efficiency requirements 1.Ecodesign energy efficiency limits 2.Updated Energy Label 3.Test standard 4.Updated metrics Problem 2: Poor ‘Circular Economy performance 5.Reparability 6.Recyclability 7.Food waste Problem 3: Loopholes and less appropriate requirements for some technologies 8.Scope

Measures related to problem 1 Measure 1: Ecodesign energy efficiency limits - The LLCC scenario requires household refrigerating appliances to achieve maximum EEI levels as shown in Table 4. The EEI level applicable from 1 April 2024 corresponds to the LLCC point as determined in the Review Study 2016. Maximum new EEI (current EEI) values 1 April 2021 (Tier 1) 1 April 2024 (Tier 2) Solid door Glass door Solid door Glass door Refrigerating appliances, except low noise refrigerating and wine storage appliances 125 (38) - 100 (30) - Low noise refrigerating appliances 300 (90) 360 (108) 250 (75) 300 (90) Wine storage appliances 155 (47) 190 (58) 140 (42) 172 (51) According the Ecodesign Framework Directive, the level of energy efficiency or consumption must be set aiming at the life cycle cost minimum to end-users for representative product models, taking into account the consequences on other environmental aspects. This is level corresponds to the maximum EEIs in Table 4. Measure 2: Updated energy Label – The Energy label will apply from 1 April 2021 onwards. The efficiency classes are set out in Table 5. The G class will be empty for standard household refrigeration appliances, but will be used for wine storage and low noise appliances that will have more lenient limit values. The A class is expected to be empty in 2021, this is in line with the new Energy Label Framework Regulation. Energy efficiency class New EEI (current EEI) A EEI ≤ 41 (13) B 41 (13) < EEI ≤ 51 (16) C 51 (16) < EEI ≤ 64 (20) D 64 (20) < EEI ≤ 80 (24) E 80 (24) < EEI ≤ 100 (30) F 100 (30) < EEI ≤ 125 (38) G EEI > 125 (38) Table 6 gives an overview of the action that needs to be undertaken. Action Who By When Ecodesign Redesign products to meet the maximum EEI limits Manufacturer or importer 1 April 2021 Energy Label Provide the updated energy labels with the product Supplier 1 December 2020 Provide the updated energy labels with the product Dealer 1 April 2021 The increase of the energy efficiency requirements will result in 5% of the products currently on the market in being removed 2021 and 18% in 2024, compared to a BAU scenario (see Annex 12). This option is feasible in the given time frame. In return these requirements are expected to result in more business revenue for industry. Stakeholder views – During the consultation forum, a stricter timing was proposed for the application of the stricter requirements, see Section 5.3.2. Some MSs and APPLiA commented that the combination of the ambition level and timing was too demanding. Most asked to postpone the application rather than to lower the ambition level. APPLiA was in favour of a lower ambition level. Environmental NGOs and Switzerland requested for more ambitious efficiency levels. All agreed that the timing for the measures should be sufficient to allow manufacturers to retest their appliances. When presenting this option to APPLiA, they agreed. Measure 3: Test Standard - The test methods are in accordance with the European version of the IEC 62552:2015 standard. Table 7 gives an overview of the action that needs to be undertaken. What Who By When Ecodesign Retest appliances’ EEI according to this new test method Manufacturer or importer 1 April 2021 Energy Label Supplier 1 December 2020

Industry calculated that the total workload based on the available test capacity amounts to 14 months. Assuming an entry into force on 1 April 2019, the proposed timing gives 24 months to retest. As such, the actions to be undertaken are feasible within the given time frame. In addition, this test standard aims to be universally applicable, faster and less costly, more accurate and more reliable. The use of the same standard in ecodesign and energy labelling will reduce the burden on the industry, improve the quality of the products and enhance global competitiveness. Stakeholder views: None of the stakeholders were opposed to using of the new test standard. Although the new standard reflects real life conditions better, consumer and environmental NGOs would like to improve this even more. Some Member States were concerned that the new test conditions do not allow optimal food preservation; this was countered by APPLiA in a comprehensive way. Measure 4: Updated metrics - The reference lines are made more flexible in design and are based on technology instead of sales and marketing. In addition, correction factors have been eliminated or reduced. The details, including the metrics, the full calculation method and a stochastic conversion table for the conversion from EEI values according to the harmonised standard (current EEI) to values according to the new global standard described in this Section (new EEI), are given in Annex 10.2.2. Table 8 gives an overview of the action that needs to be undertaken. What Who By When Ecodesign Recalculate appliances’ EEI according to the new metrics Manufacturer or importer 1 April 2021 Energy Label Supplier 1 December 2020 The introduction of the new standard requires a recalculation of the EEI even without a change to the metrics. Therefore, the introduction of the new metrics is not an additional burden on the manufacturers, importers and suppliers. The new metrics reflect technological progress and improve the transparency. Stakeholder views: The Open Public consultation (OPC) showed that stakeholders’ opinions are almost equally divided between the pros and the cons concerning the use of correction factors. In general, environmental and consumer NGOs prefer not to use them as they prefer full transparency. However, they welcomed the deletion of some and the reduction of other correction factors as did the other stakeholder. Most of the MSs that participated to the OPC are in favour of the correction factors. According to APPLiA the correction factors help consumers make sustainable choices in finite amount of time they have to make a decision. Measures related to problem 2 Measure 5: Improved reparability - A requirement is added to ensure that spare part thermostats, temperature sensors and printed circuit boards are available for a minimum period of 7 years (lifetime equal to the simple payback period) and that spare part door gaskets are available for a minimum period of 10 years. Table 9 gives an overview of the action that needs to be undertaken. Actions Who By When Ecodesign Ensure the availability of spare part thermostat, temperature sensors and printed circuit board for a period of minimum 7 years; of spare part door gaskets for a period of minimum 10 years Manufacturer or importer 1 April 2021 Manufacturers or their component suppliers will have to foresee more storage place for spare parts and/or foresee the possibility to produce them for a longer time. Industry indicated that many EU manufacturers already ensure the availability of the necessary spare parts for white goods today. The impact for EU manufacturers is mainly expected on the models that are no longer produced. For non-EU manufacturers no information is available. In general, the impact is not expected to be big. Having spare parts available ensures that the appliance’s lifetime is at least sufficiently long to ensure that the higher investment cost in a more efficient appliance is recuperated through lower electricity bills and that the appliances remain efficient throughout their life. Stakeholder views: All stakeholder are in favour of setting requirements on the availability of spare part door gaskets. With regards to the other spare parts, environmental and consumer NGOs, and some Member States, are in favour. For APPLiA, a declaration of the spare parts availability should be sufficient, as this is a driver for competition. This was also confirmed by the results of the OPC, where NGOs and individual citizens raised concern about the poor reparability of appliances, and where companies were cautious or negative about the requirements. Measure 6: Enhanced recyclability - A requirement is added to ensure that key components (as per Article 8(2) of the WEEE Directive) can be safely and readily removed, and that lamps can be removed without permanent damage to the appliance. Table 10 gives an overview of the action that needs to be undertaken. Actions Who By When Ecodesign Adapt the design of refrigerating appliances so that the material are removable Manufacturer or importer 1 April 2021 In general, the EU household refrigerating appliance manufacturers work closely together with their recycling partners to fulfil the requirements laid down in the WEEE Directive. Therefore the impact of these requirements on the manufacturers is not expected to be onerous.

The benefits from improving the efficiency of recycling, on the other hand, reduces its costs and makes it more attractive. This is of benefit to all stakeholders, including industry who finances the collection, treatment, recovery and environmentally sound disposal of WEEE from private households. The requirements for lighting are included in this regulation instead of in the regulation lighting to reduce the burden on manufacturers and make sure that different requirements on the refrigerating appliances apply at the same time. Stakeholder views: Environmental and consumer NGOs, recycling industry and some Member States, strongly recommend including requirements in the regulation on recyclability. This was confirmed by the OPC. For APPLiA the proposed requirement is an acceptable. Measure 7: Prevention of food waste - To prevent food waste, beneficial metrics for appliances that optimise their design for food preservation have been proposed. See Annex 11.2 for the full calculation method and Annex 11.3 for the changes to the metrics with regards to food waste, i.e. the use of a correction factor and the change in the target temperature of chill compartments. Table 11 gives an overview of the action that needs to be undertaken. To ensure that consumers are properly informed about correct food storage, requirements that inform consumers about the impacts of food waste, optimal food storage and the presence of compartments that optimise food preservation have been added. Those are: (a)compartments should be marked with a symbol marking the type of food that should be stored in that compartment; (b)instruction manuals for end-users and installers and free access website should include: –clear guidance about where and how fresh food should be stored for the best preservation over the longest period; –the recommended setting of temperatures in each compartment for optimum food preservation; –an estimation of the impact of temperature settings on food waste; (c)the energy label makes a differentiation between different compartments of the appliance, including those compartments that improve the food storage. Action Who By When Ecodesign Recalculate appliances’ EEI according to these new metrics Manufacturer or importer 1 April 2021 Energy Label Supplier 1 December 2020 The introduction of the new standard requires a recalculation of the EEI even without a change to the metrics. Therefore, the introduction of the new metrics is not an additional burden on the manufacturers, importers and suppliers. These metrics, on the other hand, will promote an optimised design for food preservation which could help prevent food waste. The additional information requirements and the markings on the energy label will not create an additional burden, because measure 1 and 2 already require an update of the information requirements and energy labels. The marking of the compartments will create an additional burden, but the impact is not expected to be big, as most manufacturers already mark their compartments. Stakeholder views: Most environmental NGOs, except for CLASP, and the consumer NGOs are not in favour of favourable metrics for appliances that potentially reduce food waste, because believe that there is not enough proof that an improved design guarantees food waste reduction. Several Member States and APPLiA are in favour and see it as a first step to tackle this problem. This was also confirmed by the OPC. Measures related to problem 3 Measure 8: Refined scope - The present ambiguity in the scope is removed, firstly by defining the main functional (i.e. refrigerating appliances) and technology-neutral categories (i.e. low noise appliances and mobile refrigerating appliances), and secondly by expanding on what is in the scope and what is not. See Annex 11 for a more detailed description. This proposal clarifies was the intended scope, but does not change it. However, some manufacturers of professional chest freezers and mini-bars, including some SMEs, will have to make their products compliant. Table 12 gives an overview of the action that needs to be undertaken. What Who By When Ecodesign Make products comp Manufacturer or importer 1 April 2021 Energy Label Supplier 1 December 2020 Most of the products produced by EU manufacturers, including SMEs active in the manufacturing of mini-bars, already comply with the regulations. Therefore, the impact is assumed to be moderate. Including these products in the scope will ensure that EU SMEs who invested in making their products compliant are protected, which reduces the unlevelled playing fields for all manufacturers. Stakeholder views: All stakeholders agreed that the scope should be clarified. Environmental NGOs and some MSs requested to include professional chest freezers in the scope. The main manufacturers of mini-bars requested to clarify the scope for mini-bars. The OPC showed that most stakeholders are in favour of having mini-bars (low noise appliances) and appliances with glass doors in the scope.

5.2.3.Option 3 – Ambitious The Ambitious scenario sets minimum energy efficiency limits at 25 % higher than LLCC-level for all refrigerating appliances except for low noise and wine storage appliances, see Table 13. Otherwise, the Ambitious scenario is the same as the LLCC scenario. The actions that need to be undertaken are as described in Section 5.2.2. 1 April 2021 (Tier 1) 1 April 2024 (Tier 2) Refrigerating appliances, except low noise refrigerating and wine storage appliances 100 75 The increase of the energy efficiency requirements will remove 48 % of the products from the market in 2021 and 20 % in 2024, compared to a BAU scenario behaviour (see Annex 12). This is feasible technologically, given that products with these EEI levels already exist in the market. However, the affordability for some European consumers may be affected. Business revenue for industry is expected to increase. Stakeholder views: TopTen and other environmental NGOs have expressed interest in this ambitious scenario during the Review Study 2016. For example, Switzerland already applies the A++ level (current EEI=33) as a minimum requirement since 2014. Consumer NGOs requested a careful assessment of ambitious energy efficiency requirements to ensure that low income households can still afford household refrigerating appliances. In general, APPLiA is concerned about the number of products that would be removed from the market by setting ambitious EEI requirements. They presented the possible effects of the LLCC scenario with stricter timing (See Section 5.3.2) on MS with lower incomes to raise awareness about the effect of ambitious requirements. 5.2.4.Option 4 – Lenient The lenient scenario sets minimum energy efficiency requirements 20 % lower than the LLCC scenario for all refrigerating appliances except for low noise and wine storage appliances, see Table 14. Otherwise, the lenient scenario is the same as the LLCC scenario. The actions that need to be undertaken are as described in Section 5.2.2. 1 April 2021 (Tier 1) 1 April 2024 (Tier 2) Refrigerating appliances, except low noise refrigerating and wine storage appliances 135 110 The increase of the energy efficiency requirements will not remove additional units from the market as compared to the baseline (see Annex 12.1). As such, this will not result in additional business revenue. Stakeholder views: Based on the proposal that was presented during the Consultation Forum (see Section 5.3.2), APPLiA argued for a more lenient level on the basis that costs were higher than originally estimated. 5.3.Options discarded at an early stage 5.3.1.Voluntary agreement by the industry A voluntary agreement has to be given priority according to the Ecodesign Framework Directive, provided it meets the objectives in a quicker and more cost-effective manner. Today minimum mandatory requirements are already in force. Since no proposal has been put forward by industry, there is no voluntary agreement that meet the conditions of the Ecodesign Framework Directive. As a consequence, this option is discarded from further analysis. When substituting mandatory requirements by a voluntary agreement there would be a risk of free riders, in case not all actors present on the market would sign such an agreement and comply with it. Stakeholder views: None of the stakeholders are in favour of voluntary agreements for the reasons set out above. 5.3.2.LLCC with stricter timing This option is the same as the LLCC scenario, but the application of the requirements are brought forward by one year as indicated in Table 15. This option was presented to stakeholders during the consultation forum.

Tier 1 Tier 2 LLCC 1 April 2021 1 April 2024 LLCC with stricter timing 1 April 2020 1 April 2023 Stakeholder views: Almost all stakeholders, including some environmental NGOs, agreed that the timing in combination with the minimum requirements was too demanding. The main reasons that were mentioned were the need to retest all appliances. With an estimated entry into force on 1 April 2019, the time to retest would only be 12 months, while APPLiA calculated the time needed to retest to 14 months (see Section 5.2.2). 6.What are the impacts of the policy options? The analytical methods used to determine the impacts are described in detail in Annex 4. Details about the share of products that would be removed from the market as a result of the different scenarios can be found in Annex 12.1. The reparability, recyclability and food waste requirements introduced in the LLCC, ambitious and lenient options will not be quantitatively discussed. Indeed, due to the relatively small monetary and energy impacts involved (Impact Assessment Study 2018), their possible influence on the outcomes of a quantitative analysis would be smaller than the error margin of such an analysis (estimated at ±5%). A qualitative assessment is made in Section 6.1.3. 6.1.Environmental impact 6.1.1.Final energy savings The final energy (i.e. electricity) savings per product placed on the market are described in Annex 12.2. Figure 7 shows the EU final energy consumption of the total population of household refrigeration appliances for the different scenarios. This excludes wine storage and low noise refrigerating appliances (0.3 TWh/a energy savings, see Annex 4). EU Final energy use, in TWh/a The average lifetime of refrigerating appliances is 16 years, which means that it will take some time before the whole stock of products has changed. As such, there is only a small difference between the scenarios in 2020. The savings expected by 2030 for the different scenarios are given in Table 16. The savings of the baseline relative to 2015 are 14.3 TWh/a (16 %) in 2020 and 26.8 TWh/a (31 %) in 2030. Energy consumption (TWh/a) Savings in 2030 (TWh/a) Savings in 2030 (%) Savings compared to the remaining savings for the period 2016-2030 (%) Baseline 59.2 LLCC 46.9 9.6 15 0.68 Ambitious 47.0 11.9 20 0.84 Lenient 54.7 4.5 7 0.32 Active energy policies will reduce the ETS price. However, this is justified because the ETS only tackles the price reflection based market failures (for electricity using products); market failures such as myopic behaviour and split incentives can only be tackled by these active energy policies. Stakeholder views – See stakeholder comments on the energy efficiency requirements in Sections 5.2.2, 5.2.3 and 5.2.4. 6.1.2.GHG-emissions

The transition towards low-global warming potential (GWP), non-ozone depleting (ODP) refrigerants and foaming agents is practically complete for this product group (> 98 % isobutane for refrigerant, cyclopentane as foaming agent). As such, the trends for GHG-emissions are similar to the energy consumption trends. The main difference is that for the energy scenarios, by convention, a primary energy factor of 2.5 (according the Annex V of the Energy Efficiency Directive (Directive 2012/27/EU), whereas for the projections of the GHG-emissions changes in carbon-intensity of electric power generation are taken into account. Figure 8 shows the EU GHG-emissions of the total population of household refrigeration appliances for the different scenarios, this excludes wine storage and low noise refrigerating appliances (0.1 Mt CO2 eq./a GHG-abatement, see Annex 4). The GHG emission savings expected by 2030 for the different scenarios are given in Table 17. The savings of the baseline relative to 2015 are 7.2 Mt CO2 eq./a (21 %) in 2020 and 14 Mt CO2 eq./a (41 %) in 2030. GHG emissions (Mt CO2 eq./a) Savings in 2030 (Mt CO2 eq./a) Savings in 2030 (%) Savings compared to the remaining savings for the period 2016-2030 (%) baseline 20.1 LLCC 16.9 3.2 16 0.30 Ambitious 16.0 4.1 21 0.38 Lenient 18.6 1.5 10 0.14 Stakeholder views – Comments on the GHG-emissions from energy use are included in the comments on the energy efficiency requirements Sections 5.2.2, 5.2.3 and 5.2.4. On the emissions from refrigerants, environmental NGOs requested to include a requirement to avoid that hydrofluoro-olefins (HFOs) would be used in household refrigerating appliances. 6.1.3.Circular Economy perspective The environmental life-cycle assessments in the Review Study 2016 show that the energy consumption and the related emissions are the dominant environmental impacts for this product category. For this reason, the circular economy requirements are limited only to those requirements that make sense from a life cycle perspective. Note that the options do not differentiate between these material resources measures, i.e. they are all part of all options, except the baseline option. Design for optimised food storage - For material resources efficiency, reduction of food waste through better, more specific preservation is the most important element. The beneficial metrics for appliances that optimise their design for food preservation lead to lower EEI values (higher efficiencies). However in reality, the energy consumption of the appliances will be higher (at least 20 % higher, see also Section 2.2) and the real savings are expected through the reduction of food waste. The Complementary Study on food waste concluded that with optimal storage conditions the current food waste due to ‘not-used-in time’, estimated at 23 Mt/year (EU 2011-2012), can be reduced by almost 60% (13 Mt). An additional 20-25% (7-8 Mt) can be saved on food waste from leftovers and too much food prepared or served (leftovers) etc. by better preservation. However, it is clear that measure alone will not solve the food waste problem. Several other barriers need to be overcome: ·consumer behaviour ·current product specific legislation on food preservation ·food labelling (e.g. expiry dates)

To steer the consumer behaviour some requirements have been added to inform them about the correct preservation of food, the impacts of food waste and the presence of compartments that optimise food preservation. Without a thorough study on consumer behaviour it is impossible to estimate whether these requirements are sufficient to trigger changes in consumer behaviour. Unfortunately, Ecodesign and Energy Labelling cannot regulate the influencing factors more than that. Therefore, it should be seen as a first step in that direction. For these reasons, the beneficial metrics only conservatively decrease the EEI values (between 2 % and 5 %, depending on the number of doors, see Annex 11.3), they do not completely compensate for the 20 % increase in energy consumption. In addition, the Complementary Study 2016 concluded that: ·it would be enough to only reduce the food waste with only 2% to compensated for the 20 % higher energy use (see also Section 2.2); ·the existence of different compartments ranging from -1 °C to 17 °C creates new energy savings opportunities, e.g. by capturing the ‘waste-cold’ from low-temperature compartments and defrosting; ·optimal food storage also keeps food healthier and tastier. Hence, the measure makes sense from a broader environmental perspective. Availability and replacement of spare parts - As a safeguard against the possible reduction of the product lifetime and also to maintain energy efficiency over time, the availability of spare part thermostats, temperature sensors, printed circuit boards and door gaskets is important. Life time extension, including from re-use, is not useful seeing the large energy saving potential that still remains for this product group. Such requirements would stagnate the entry of new, more efficient models on the market. A period of 7 years for safeguarding the reduction in product lifetime and 10 years for maintain energy efficiency over time, is expected not to extend the life time which is on average 16 years. Design for recycling - Finally, to facilitate recycling, the removability of key components as per Article 8(2) of the WEEE Directive is important. Stakeholder views – See stakeholder views on circular economy in Section 5.2.2. 6.2.Business impacts 6.2.1.Business revenue To achieve energy and carbon savings, industry has to invest. As such, the cost will be higher. In retail, with average wholesale- and retail margins (and Value Added Tax (VAT) assumed fixed, the cost will also be higher. This will be translated into a higher price (in absolute euros) of the appliance, which will affect consumer expenditure. Consequently, the acquisition cost for the consumer will increase as a consequence of the policy scenarios (despite the assumption of a learning effect of 1% for prices above the current base case level; see also Section 6.3 and Section 6.5.1). This investment leads to a higher revenue for the industry and retail sector, as indicated in Table 18. sector INDUSTRY WHOLESALE RETAIL* TOTAL Increase scenario 2015 2020 2030 2015 2020 2030 2015 2020 2030 2015 2020 2030 2030 Baseline 4.1 4.2 4.3 0.3 0.3 0.3 4.1 4.2 4.3 8.6 8.7 8.9 ref LLCC 4.1 4.2 4.6 0.3 0.3 0.3 4.1 4.2 4.6 8.6 8.7 9.5 0.6 Ambitious 4.1 4.2 5.2 0.3 0.3 0.4 4.1 4.6 5.3 8.6 9.1 10.9 1.9 Lenient 4.1 4.2 4.3 0.3 0.3 0.3 4.1 4.2 4.3 8.6 8.7 8.9 0 *= includes repair (estimated 0.5 bn Euro/a) . ** inflation-corrected/recalculated in Euros 2010 at 2% inflation Option 1 - baseline - gives an increase of 0.3 billion Euros (Net Present Value(NPV) 2010) in 2030 with respect to 2015. Option 2 - LLCC - gives an extra 7% in turnover (EUR 0.6 billion) in 2030. Option 3 - ambitious - gives an extra 21% (EUR 1.9 billion) in total business turnover. Option 4 - lenient - no increase with respect to baseline scenario. Figure 9 shows the projected industry revenue for the different scenarios.

It is expected that the business revenue will not be impacted significantly by the rescaling, even with products in the A+ and the A++ class that will end up in the F and G class respectively. This is because it is not the intention that manufacturers will keep on making the same products that will end up in the F and G class with competitive lower mark-ups. Today, due to the overpopulation of the top energy classes, energy efficiency improvement cannot be shown to the consumers and will therefore not be rewarded in the price of the model. It is expected that the measures will give sufficient incentive for manufacturers to improve the energy efficiency of their products (see also Section 6.2.2) as to reach the new A and B levels that can then be sold at a higher price. The move toward more efficient appliances is also shown in Annex 12, Table 44, where in the period 2021 – 2025, the percentage of appliances in the F and G class are rapidly decreasing. In addition, rescaling itself will have the same impact on all refrigerating appliances, their manufacturers and suppliers. All refrigerating appliances will bear the new energy label at the point of sales after the date of application without overlap. The impact assessment of the energy labelling framework regulation states that a period of overlap is likely to confuse consumers and lead to sales of less efficient appliances, although it is impossible to quantify by how much. The introduction of the new energy labels will go together with information campaigns for consumers. Stakeholder views – APPLiA commented that the disregarded scenario (see Section 5.3.2) would remove a large amount of products from the market. Such scenarios will require significant redesign which requires significant investment. Stakeholders did not comment on Business revenue. 6.2.2.Innovation, Research and Development, Competitiveness The household refrigeration appliances industry spends approximately EUR 0.35 billion (3.8 % of its total turnover) on research and development (R&D) (APPLiA). The revision of the household refrigeration appliance labelling regulation is expected to support innovation and drive market transformation, as was observed in the past. It is in line with ongoing market trends towards higher energy efficiency, where a high-energy label rating is a strong commercial driver (Review Study 2016). However, it is not expected that the regulation will lead to any significant structural increase of R&D budgets, unless if the requirements do not take the normal pace of R&D into account. There is however a shift in priorities for the R&D budget, which is directed more towards e.g. energy efficiency improvements instead of e.g. new production techniques. The same goes for investments in new production lines for more efficient products. In addition, products meeting the requirements are already commercially available on the market. Almost all manufacturers of refrigerating appliances are large companies. Hence, it assumed that they have the technological capabilities that allow them to reach the top label levels. Impact will be most limited in option 4 - lenient scenario and most challenging in the option 3 - ambitious scenario. The option 2 - LLCC scenario is in line with the pace of innovation over the past period. To further keep the R&D expenditure at its normal pace, the proposed period between the application of the first and second tier of requirements is 3 years, whereas in the current Regulation this is 2 years. The development of innovative energy-efficient technologies at competitive prices will enhance the competitiveness of European manufacturers. This is important because Asian manufacturers are rapidly expanding their global market share. For these manufacturers, product price, rather than quality, is one of the main selling points. The SMEs are protected by lower requirements for wine storage appliances and low noise appliances, these are the products they typically produce. Stakeholder views – Stakeholders did not comment on Innovation, Research and Development, Competitiveness. 6.2.3.Compliance costs Ecodesign and energy label requirements for refrigerating appliances in the scope have a strong influence on the market and have been in existence for the last 20 years.

Research and development as well as production investments are common practice in the industry. Redesign would happen with or without new measures. As a consequence, the compliance costs and amongst others, the cost for redesign, are not expected to increase. Any potential extra cost is expected to be absorbed by the industry. With or without the measures, manufacturers will be obliged to test their products according to the new test method, otherwise they will not be able to compete on the global market. Therefore, costs from testing according to the new standard will be the same for all options, including the baseline. As regards the SMEs operating in some niche markets, the Commission proposals have done their utmost to minimise the burden (see Section 6.5.3). The administrative burden of current and proposed measures is further developed in Section 6.4. Stakeholder views - The ecodesign requirements have not led to complaints on extra costs that were not repaid, in the short or long run, by extra revenue. 6.2.4.Intellectual Property Rights The technologies considered in all scenarios are commonly available to all major manufacturers. Stakeholder views - No concerns were raised that the options would impose proprietary technology on manufacturers. 6.2.5.Stranded investments The risk of stranded investments could exist for the least energy efficient appliances such as combi appliances with a single thermostat design (Type I). However, these products and their components have been introduced in the market in the 1960s and production lines and other capital costs have long been depreciated (written off). Therefore, there are no risks on stranded investments. Stakeholder view - APPLiA did not raise the issue of stranded investments. 6.3.Consumer expenditure Consumer expenditure consists of acquisition costs, maintenance/repairs and running costs. For refrigerating appliances, the repair costs are modest (estimated in the order of EUR 0.5 billion/year) and are assumed to be included in the acquisition costs. The running costs are equal to the energy costs. For a detailed analysis of the acquisition cost and the energy cost, see Annex 12.3. The overall consumer expenditure (= sum of the acquisition and running costs) for the different scenarios are shown in Figure 10. Figure 10: Projected consumer expenditure over the period 2005-2030, in billion Euros [2010] (Impact Assessment Study 2018). Option 1 - baseline - consumer expenditure rises by EUR 4.7 billion (17%) per year between 2015 and 2030. Option 2 - LLCC - saves the most in consumer expenditure, almost 3 billion Euros per year (9%) with respect to the baseline in 2030. Option 3 - Ambitious - The expenditure is considerably more than any other scenario over the period 2021-2030. Only in 2028 it drops below the baseline. In 2030 it drops to a level similar to the lenient scenarios in 2030. Option 4 – Lenient - The expenditure is lower than the baseline, but higher than the LLCC. A sensitivity analysis of the consumer expenditure is included in Annex 12.3.2. Stakeholder views – APPLiA questioned the feasibility of the discarded scenario (see Section 5.3.2) in certain countries in terms consumer expenditure and affordability. Several eastern European MS also commented on the feasibility of this scenario with respect to consumer expenses and affordability. Consumer organisations stated that the ambitious option would eliminate a specific, very low-cost type of combi-appliance (Type I) which is believed necessary to serve low-income households. 6.4.Administrative burden The administrative burden of new measures under the Energy Labelling Framework Regulation were calculated in the Impact Assessment for the Energy Labelling Framework Regulation. The costs for household refrigeration appliances are summarised in Table 19. For ecodesign measures for products with an energy label, the above-mentioned impact assessment study considered that there was no additional administrative burden for industry, because there were vested commercial interests. More details are found in Annex 12.4

Administrative burden one-off annual BAU For the first 6 months provide a second label and supply extra labels on request to dealers 3300 - Dealers re-labelling around 2.5% of products on stock/display or on the internet 600 - Database, supplier costs 90 - Database, EU budget 90 9 - Joint support actions, EU budget (e.g. EEPLIANT) 33 x Support joint surveillance actions (Horizon2020) 60 x External laboratory costs (SMEs) 66 x Market surveillance, Member State costs 330 x Total business-as-usual (BAU) - 489 Total new costs of measures 3990 99 Stakeholder views – No comments were made on the administrative burden. 6.5.Social Impact 6.5.1.Affordability In this Impact Assessment, affordability is based on the simple payback time of the appliance. The life cycle costs and payback time are based on EU28 average price values for, amongst others, electricity. For Member States with lower than average electricity prices, the payback time will be higher than this EU28 average payback time. To be affordable in all Member States, the EU28 average payback time is kept lower or equal than half of the lifetime of the product. A sensitivity analysis of the life cycle costs (LCC) based on the data in the Review Study 2016 and the electricity prices in Germany and Romania, which are at the higher and lower end respectively of electricity prices in the EU can be found in Annex 12. For option 2 – LLCC, on average the prices are projected to go up by 10-12 %, whereas the annual energy costs go down by 23-25 %. At the projected energy prices this means a simple payback period of 6 -7 years for an appliance that lasts on average 16 years. In other words, also for consumers with below-average income this is economically a worthwhile investment. The risk that consumers would postpone the purchase of a new appliance exits. However, this behaviour has not been observed with the introduction of the current Regulations, therefore it is not considered here. Moreover, with the introduction of the previous regulations for refrigerating appliances, the purchase price of refrigerating appliances did not change much. The industry managed to maintain the same average prices over the last 15 years. Only in the first two years, when not all manufacturers were capable of producing the highest energy label levels, there was a slight price increase, which subsequently disappeared. Only in the case where the purchaser (e.g. a landlord) is not the one paying the energy bill (e.g. a tenant) the economic considerations for the purchaser may be different. Ecodesign measures are intended for just those situations, i.e. to ensure that a landlord or a short-time-user buys an appliance that meets at least a minimum efficiency level. Stakeholder views – See stakeholder comments consumer expenditure, Section 6.3. 6.5.2.Health, Safety and Functionality Aspects There are no specific health and safety aspects related to the measures analysed. There are no known negative impacts from using more efficient appliances as prescribed by the policy options. Stakeholder views – Stakeholders did not report any negative impacts in this respect. 6.5.3.Employment Total employment - The EU impact on employment is estimated from the increase in revenue and turnover per employee, this is the convention as per the MEErP methodology. Table 20 gives an overview of the employment impact according to the boundaries described in Annex 12.5. While there is some correlation between revenue and employment for a manufacturing industry, there are however other influencing factors (e.g. macro-economics, EU trade policy, strategy of EU companies to move workforce to low-cost countries outside the EU, etc.) which have not been taken into account in the impact modelling. Hence, the real job impacts are expected to be lower than indicated in the report. sector INDUSTRY* WHOLESALE** RETAIL*** TOTAL Increase scenario 2015 2020 2030 2015 2020 2030 2015 2020 2030 2015 2020 2030 2030 BAU 83 84 87 1.2 1.3 1.3 82 83 86 166 169 174 ref LLCC 83 84 92 1.2 1.3 1.4 82 83 91 166 169 185 11 Ambitious 83 84 104 1.2 1.3 1.5 82 91 106 166 177 212 38 Lenient 83 84 87 1.2 1.3 1.3 82 83 86 166 169 174 0 *=33% manufacturer, 33% Original Equipment manufacturer (OEM) (of which 50% EU), 33% business services; EUR50k/job; **=EUR250k/job ***=EUR60k/job

In Option 2 - LLCC and Option 3 – ambitious, approximately 11000 and 38000 jobs would be created, respectively, as compared to a baseline, equally divided between industry and trade. Option 4 - lenient - hardly any jobs would be created/retained as compared to the baseline. SMEs - SME manufacturers of refrigeration appliances in the scope can only be found in niche markets such as minibars (low noise appliances) or customised wine storage appliances produced in one-off or small series for restaurants, bars or connoisseurs usually with glass doors, see also Section 2.5.1. Their market share in these niche markets may be 30-40%. Table 21 shows an overview of the estimated employment in SMEs involved in the production of refrigeration appliances in the scope. SME Employment (number of jobs) Wine storage appliances 500-800 Mini-bars 200 In order to retain these SME jobs, it is proposed to apply more lenient requirements for wine storage and low noise appliances. For wine storage and low noise appliances with glass doors even less stringent appliances are proposed, see also Section 5.2.2. Stakeholder views – Stakeholders did not comment on the total employment. APPLiA and the MSs are in favour of more lenient requirements for wine storage and low noise appliances. For glass door appliances, this could be done either through a glass door correction factor (supported by several MS) or through separate requirements (supported by some MS and APPLiA). NGOs are not in favour of correction factors. 6.6.Linearity of the impacts in between the LLCC and ambitious options In case that another option would be selected with an ambition level in between the LLCC and ambitious scenario, it should be noted that the impacts are not fully linear. The expected cut off rate and the affordability for low income households are impacts that are only linear up to a certain point. According to industry and consumer associations, beyond a certain point (somewhere between the LLCC and the ambitious scenario), the impact is no longer linear. The non-linearity originates from the need to increase R&D efforts and investments in new production lines higher than the normal development pace, see also Section 6.2.2 In this case, industry is confronted with considerably higher costs which they may or may not be able to carry. In addition, as regards to affordability, the price of refrigerating appliances will increase when the extra production costs can no longer be absorbed by a normal development pace. This risks that low-income families will no longer be able to afford a new refrigerating appliance. Instead, they will continue to use and repair their old energy inefficient refrigerating appliance longer than is environmentally responsible.



7.How do the options compare? 7.1.Summary of the impacts Tables 22 and 23 summarise the impacts described in Section 0. Impact (unit) 2020 2030 2040 absolute absolute increment absolute increment baseline baseline LLCC Ambitious Lenient baseline LLCC Ambitious Lenient Unit electricity (kWh/a) 181 161 -47 -59 -23 122 -35 -45 -17 Electricity consumption (TWh/a) 73 59 -9.6 -12 -4 51 -15.6 -19 -7 GHG emissions (Mt CO2 eq./a) 27.9 20.1 -3.3 -4.0 -1.4 15.3 -4.6 -5.7 -2.2 Acquisition costs (EUR billion) 10.4 10.7 0.7 2.6 0 11.1 2.6 3.9 0.7 Energy costs (EUR billion) 18.3 21.8 -3.4 -5.0 -1.6 27.9 -8.26 -10.86 -4.01 Consumer expenditure (EUR billion) 28.7 32.6 -2.7 -2.2 -1.6 38.9 -5.6 -6.7 -3.3 Industry revenue (EUR billion) 4.20 4.33 0.28 0.86 0 4.46 1.06 1.47 0.27 Wholesale revenue (EUR billion)) 0.31 0.32 0.02 0.06 0 0.33 0.08 0.11 0.02 Retail revenue (EUR billion) 4.17 4.30 0.27 1.02 0 4.42 1.05 1.58 0.26 Employment ('000jobs) 169 174 11 38 0 179 42 61 0 Impact (unit) 2021-2030 2021-2040 absolute increment absolute increment baseline LLCC Ambitious Lenient baseline LLCC Ambitious Lenient EU electricity consumption (TWh/a) 660 -47 -62 -21 1250 -185 -235 -85 EU GHG emissions (Mt CO2 eq./a) 239 -17 -22 -7 424 -60 -77 -28 Consumer expenditure (billion Euros 2010) 305 -7.7 -1.3 -6.7 665 -53 -52 -35 Energy costs (billion Euros 2010) 199 -16 -24 -7 450 -80 -112 -37 Acquisition costs (billion Euros 2010, incl. VAT) 106 8 23 0 215 27 57 2 Industry revenue (EUR billion) 43 3.2 7.7 0.1 87 11 20 1 Wholesale revenue (EUR billion) 3 0 1 0 6 -3 -3 -3 Retail revenue (EUR billion) 42 3 9 0 86 11 23 1 Total revenue (EUR billion) 88 7 18 0 179 18 40 -2

7.2.Market Surveillance All proposed policy options would be subject to Article 15(8) of the Ecodesign Framework Directive, as well as Article 8(1) and (3) of Energy Labelling Framework Regulation, which requires that MSAs can verify the conformity of a product with all regulatory requirements. The cost for market surveillance organised by MSs is the same for all options, i.e. EUR 330.000 annually, see Section 6.4. Stakeholder views – APPLiA and other industry associations, have emphasised the importance of securing a sufficient level of market surveillance to ensure that only compliant products are placed on the market. In this respect, they call for increased enforcement by MSAs. 7.3.Assessment in view of Article 15(5) of the Ecodesign Framework Directive Pursuant to Article 15(5) of the Ecodesign Framework Directive, future implementing measures should fulfil a number of criteria, see Section 3.1. An assessment of the options in view of these criteria and on the basis of Tables 22 and 23 is shown in Table 24. Significant impacts as stipulated in Article 15 of the Ecodesign Directive baseline LLCC Ambitiouos Lenient No negative impacts on the functionality (Section 6.2) ✓ ✓ ✓ ✓ No negative impacts on health, safety and environment (Section 0) ✓ ✓ ✓ ✓ No negative impact on consumers (Section 6.3 and 0) ✓ ✓ X ✓ No negative impacts on industry's competitiveness (Sections 6.2) ✓ ✓ ✓ ✓ Not imposing proprietary technology (Section 6.2) ✓ ✓ ✓ ✓ No excessive administrative burden on manufacturers (Section 6.2 and 6.4) ✓ ✓ ✓ ✓ Although option 3 - ambitious has the best values in most of the categories in Tables 22 and 23, it cannot be retained as the option for a future implementing measure because it does not fulfil the criterion ‘no negative impact on consumers’ of Article 15(5). The consumer expenditure in the short term is too high for the average consumer in terms of affordability and life cycle cost, i.e. the simple payback time is higher than half the lifetime of the product (see also Section 6.5.1.). In addition, the ‘x’ also refers to the fact that the option would eliminate a specific, very low-cost type of combi-appliance (Type I) that according to the consumer organisation is believed necessary to serve low-income households. Option 2 – LLCC and option 4 – lenient fulfil all criteria. 7.4.Assessment in view of the objectives An assessment of the options in view the objectives in Section 4, on the basis of Tables 22 and 23, is shown in Table 25. Option 4 - lenient does not contribute to the general objectives and only contributes to two out of three specific objectives. It is therefore not seen as an appropriate policy option. Option 1 – baseline does not contribute to any of the objectives. Option 3 – ambitious contributes to all objectives in the same way as option 2 – LLCC, except for the specific objective ‘Update the energy efficiency requirements and the energy label in line with international and technical developments’. Here the option goes beyond the international and technical developments. In any case, this option has been excluded based on the evaluation in Section 7.3. As a consequence option 2 – LCCC is the preferred option. More information on the benefits of option 2 are included in the next paragraph. General Objectives baseline LLCC Ambitious Lenient 1. Ensure free circulation of efficient products within the internal market; 0 + + 0 2. Promote competitiveness of the refrigeration industry through the creation or expansion of the EU internal market for sustainable products;* 0 + + 0 3. Promote the energy efficiency of refrigeration appliances;** 0 + ++ 0 4. Contribution to the Commission's objective to reduce energy consumption by 30 % and domestic GHG emissions by 40 % by 2030;*** 0 + + 0 5. Increase the security of energy supply in the Union through a reduction in energy consumption of household refrigeration appliances 0 + + 0 Specific Objectives 1. Update the energy efficiency requirements and the energy label in line with international and technical developments; 0 ++ + 0 2. Contribute towards a circular economy in the EU by including requirements on spare part availability and food waste reduction 0 + + + 3. Redefine the scope to close potential loopholes and adopt a technical neutral approach 0 + + + *Innovation will enhance competitiveness of the EU manufacturers; the effect on innovation is therefore included in this objective. **The promotion of energy efficient appliances for the ambitious scenario will be significantly higher than for the LLCC scenario. However, we should take into account that the risk exists that the market uptake of these more efficient appliances might be slower because they are unaffordable for low-income families. ***The contribution to the 2030 target increases with 0.16% for energy efficiency and 0.08% for GHG emissions for the ambitious scenario in comparison to the LLCC scenario. This does not make the difference between limited improvement and significant improvements. 8.Preferred option

8.1.Preferred option – Why? Option 2 - LLCC fulfils the criteria in Article 15(5) of the Ecodesign Regulation and Article 16(2) of the Energy Labelling Regulation, see Section 3.1, and will achieve the objectives as set out in Section 5 in the best way, see Section 7.4. By 2030, option 2 – LLCC will results in the following: ·Energy savings of 9.6 TWh/yr and GHG emission savings of 3.1 MtCO2eq./a, i.e. 0.66% of the Union’s 2030 target for final energy consumption savings and 0.25 % of the Union’s 2030 target for GHG-emissions savings; ·Savings on annual end-user expenditure of EUR 2.8 billion and extra business revenue of EUR 0.44 billion per year, which translates into around 11 000 jobs; ·An alignment with technological progress and global minimum energy efficiency requirements in other economies; ·Ensuring EU industry’s competitiveness and leading role as high-quality manufacturers; ·Safeguarding of SMEs working in niche markets. This option promotes innovation and medium-term cost reduction for more efficient household refrigeration appliances. 8.2.REFIT (simplification and improved efficiency) This section will describe how the preferred option is expected to improve the efficiency of the existing measures. The LLCC option will reduce the total consumer expenditure as compared to the baseline. This consumer expenditure includes the acquisition cost and the energy cost. The acquisition cost will be higher, but the energy cost will decrease significantly as compared to the baseline. In addition, this option will improve industry’s revenues significantly. Table 26 gives an overview of the increment in cost and as compared to the baseline. 2030 2040 Comment Acquisition costs (EUR billion) 0.7 2.6 The acquisition cost increases, but the total consumer expenditure decreases. Energy costs (EUR billion) -3.4 -8.26 Consumer expenditure (EUR billion) -2.7 -5.6 Industry revenue (EUR billion) 0.28 1.06 There is an increase in revenue industry, wholesale and retail Wholesale revenue (EUR billion)) 0.02 0.08 Retail revenue (EUR billion) 0.27 1.05 Administrative burden dealers (EUR ‘000) 600 The increase in administrative cost is due to the introduction of the rescaled energy label and the database requirements Administrative burden suppliers (EUR ‘000) 3900 90 90 Administrative burden EU (EUR ‘000) 90 9 9 9.How will actual impacts be monitored and evaluated? The main monitoring element will be the tests carried out to verify compliance with the ecodesign and energy labelling requirements. This monitoring should be done by MS market surveillance authorities to ensure that requirements are met. The main indicator for evaluating the impact of potential ecodesign and energy labelling regulations is the achievement of a market improvement towards household refrigerating appliances with a smaller environmental impact. An analysis of the products on the market (sales figures, performance, etc.) will determine if the shift towards more resource efficient products has happened as estimated, in particular based on the following sub-indicators, which reflect the general and specific objectives: ·Reduction of the electricity consumption and related GHG emissions of household refrigeration appliances; ·Increasing the economic savings for European consumers;

·Safeguarding the competitiveness of the European household refrigeration appliances industry and the full value chain; ·Improving the regulatory effectiveness and efficiency of the regulation; ·Compliance with energy efficiency requirements, i.e. maximum EEI for the different product categories; ·Compliance with material efficiency requirements ospare part availability, odisassembly of key-components, ofood preservation; ·Compliance of those products that were potentially excluded due to loopholes. The evaluation should therefore assess these sub-indicators.

Annex 1: Procedural information 1.Lead Directorates General (DG), Decide Planning/CWP references DG ENER is the lead DG for the Ecodesign and Energy labelling regulation for household. Decide number of the underlying initiative for the review of ecodesign requirements for household cold appliances is PLAN/2016/441 (inception impact assessment published on 23/01/2018 at https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-476272_en ) Decide number of the underlying initiative for the review of energy labelling for household cold appliances is PLAN/2016/445 (inception impact assessment published on 23/01/2018 at https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-476308_en ) The following DGs (Directorates General) have been invited to contribute to this impact assessment: ENER (Energy), SG (Secretariat-General), GROW (Internal Market, Industry, Entrepreneurship and SMEs), ENV (Environment), CNECT (Communications Networks, Content and Technology), JUST (Justice and Consumers), ECFIN (Economic and Financial Affairs), REGIO (Regional policy), RTD (Research and Innovation), CLIMA (Climate Action), COMP (Competition), TAXUD (Taxation and Customs Union) EMPL (Employment), MOVE (Mobility and Transport), TRADE (Trade) and the JRC (Joint Research Centre) were consulted on the draft IA in March 2018. 2.Organisation and timing The last Ecodesign Working Plan 2016-2019, adopted in November 2016, confirms that household refrigeration appliances continue to be a priority product group. Furthermore, the recent Energy Label Regulation (EU) 2017/1369 stipulated that household refrigeration appliances are one of the five priority subjects for which the Commission should adopt a new energy label regulation in accordance with the said overall regulation by 2 November 2018. Article 19 of the Ecodesign Directive foresees a regulatory procedure with scrutiny for the adoption of implementing measures. Subject to qualified majority support in the Regulatory Committee and after scrutiny of the European Parliament and of the Council, the adoption of the measure by the Commission is planned for the end of 2018. 3.Consultation of the RSB The Regulatory Scrutiny Board (RSB) delivered its opinion on a draft of the Impact Assessment on 7 May 2018 after the meeting on 3 May.





RSB Opinion 07.05.2018 Where and how the comments have been taken into account (B) Main considerations (1)The report does not clearly explain how the general assessment criteria from the framework Ecodesign Directive on affordability and significant impacts apply to household refrigerating appliances. The affordability criterion is not discussed in the context of large income disparities across the EU. An explanation was added in Section 6.5.1, 7.3 and 7.4 on how affordability and significance was assessed. In addition, a sensitivity analysis of the life cycle costs (LCC) based on the data in the Review Study 2016 and the electricity prices in Germany and Romania, which are at the higher and lower end respectively of electricity prices in the EU was included in Annex 12. (2)The report does not discuss how the primary purpose of eco-labelling, to increase energy efficiency of household refrigerating appliances, could be weakened by including the objectives of the circular economy. Some text was added to Section 5.2.2 and Annex 11.3 to give a better explanation on the correction factors for better food preservation. Section 6.1.3 now includes an explanation on the effect of the circular economy requirements on the energy consumption. In addition, it explains better requirements make sense in this respect. (3)The methodology behind assessing the impacts of the proposed measures and the modelling results suggest the need to qualify the reported results. Section 6.1.3 explains more on the ava