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the reviews 1.4.Political Context 1.5.Need to act 2.Problem definition 2.1.How the problems are defined 2.2.Problem 1: Outdated energy efficiency requirements 2.3.Problem 2: Poor “circular economy” performance 2.4.Problem 3: Low use of the Ecoprogramme by consumers 2.5.General market failures 2.6.Who is affected? 3.Why should the EU act? 3.1.Legal basis 3.2.Subsidiarity: Necessity for 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.Issues not subject to assessment 5.2.Policy options subject to assessment 5.3.What is the baseline from which options are assessed? 5.4.Description of policy options 5.5.Options discarded at an early stage 6.What are the impacts of the policy options? 6.1.Methodological considerations and key assumptions 6.2.Environmental impacts 6.3.Economic impacts 6.4.Social impacts 7.How do the options compare? 7.1.Summary of the impacts 7.2.Market Surveillance 7.3.Assessment regarding Article 15(5) of the Ecodesign Framework Directive 7.4.Assessment with regard to 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: Draft minutes: Meeting of the Consultation Forum on Ecodesign Annex 4: Evaluation of the Ecodesign and Energy Labelling Regulations for household dishwashers Annex 5: Analytical model used Annex 6: Resource efficiency Annex 7: Analysis of the Impact Assessment details Annex 8: Other Ecodesign requirements involving no change, or relatively minor updates Annex 9: Who is affected and how? Annex 10: The Ecodesign and Energy Labelling Framework 11: Existing Policies, Legislation and Standards affecting household dishwashersANNEX Annex 12: Glossary 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 1016/2010 on Ecodesign requirements for household dishwashers and Commission Delegated Regulation (EU) No 1059/2010 on Energy Labelling of household dishwashers. 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 EUR 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 dishwasher appliances represent an important component of the consumption of domestic electricity. They have been subject to EU Energy Labelling measures since 1997 and minimum Ecodesign energy efficiency requirements since 2010. 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 Regulation sets out the general rules for rescaling the existing A+ to A+++ labels: •Class A shall be empty at the moment of introduction of the label, and the estimated time within which a majority of the models falls into that class is at least 10 years; •Where technology is expected to develop more rapidly, classes A and B shall be empty when introducing the label; •Moreover, the A to G steps of the classification shall correspond to significant energy and cost savings and appropriate product differentiation from the customer’s perspective. In general, the boundaries of the label scale are defined by the performance of products on the market incorporating ‘Best Available Technology’ (BAT) and the minimum requirement under Ecodesign for those products. Subsequently, the bandwidth of the classes is determined so as to keep the same effort to move from one class to the next one. For specific product groups this may however be different to take into account appropriate product differentiation. The BAT is determined following the MEErP methodology, and is based on purely technical grounds, i.e. the product on the market with the lowest environmental impact, while ensuring that other functional requirements (e.g. performance, quality, durability) are equivalent to the base case. The EU 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. The Ecodesign framework Directive and the Energy Labelling framework Regulation are implemented through product-specific implementing and delegated regulations. As an alternative to the mandatory Ecodesign requirements, voluntary agreements or other self-regulation measures can be presented by the industry sector(s) concerned (see also Article 17 of the Ecodesign Framework Directive). If certain criteria are met, the Commission formally recognises these voluntary agreements. The benefits include 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 of Ecodesign and Energy Labelling measures, see Annex 10.

Household dishwasher appliances are currently regulated under Commission Regulation (EC) No 1016/2010 (Ecodesign) and Commission Delegated Regulation (EU) No 1059/2010 (Energy Label). An overview of existing policies, legislations and standards affecting household dishwasher appliances in the EU and outside is given in Annex 11. 1.3.Legal context of the reviews Article 7 of the Ecodesign Regulation for household dishwashers and similarly Article 7 of the Energy Labelling Regulation for household dishwashers require the regulations to be reviewed in the light of technological progress no later than four years after their entry into force. This review should in particular assess the verification tolerances of Annex III and the possibilities for setting requirements with regard to the water consumption and the potential for hot water inlet. In August 2017, the new Energy Labelling framework Regulation (EU) 2017/1369 entered into force, repealing Directive 2010/30/EU . Under the repealed 2010 Directive, energy labels were allowed to include A+ to A+++ classes to address the overpopulation of the top classes. Owing to continued technological development, the A+ to A+++ classes also became overpopulated, thereby reducing the effectiveness of the labels significantly. In order to resolve this, the new 2017 Energy Labelling 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 dishwashers are 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 - inter alia - stresses the need to include reparability, recyclability and durability in Ecodesign, the Emissions Trading Scheme (ETS) as amended , aiming at cost-effective greenhouse gas (GHG) emissions reductions and indirectly affected by the energy consumption of the energy-related 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. Moreover, the Ecodesign Working Plan 2016-2019 also includes the review of both regulations, requiring in particular the examination of 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). 1.5.Need to act The need to act is driven by the following main considerations: Cost effective increases in energy efficiency and the level of protection of the environment: Manufacturers and consumers stand to benefit from the fact that there are still cost effective energy and water savings to be achieved in washing machines and washer-dryers, even if these savings are modest in view of EU 2030 energy and climate targets. By way of illustration, electricity savings due to the existing requirements on these products were expected to be 2 TWh per year in 2020 at the time of the previous review in 2010. In reality, the consumption of dishwashers in the EU was estimated to be 3 TWh higher than ‘business-as-usual’ in 2016, meaning that the savings enabled by the Ecodesign and Energy Label revision were more than compensated by the increased number of dishwashers in use. Other policy objectives: Several other EU policy objectives require the revisions to look beyond the technical revisions mentioned in the review article of the existing regulations, e.g.: ·renewed effort in carbon emission abatement through the Paris climate agreement; ·the EU Circular Economy action plan aiming at improving the durability, reparability, recyclability of products; ·the Better Regulation policy aiming at more efficient and effective legislation; ·the need to address possible circumvention of testing standards; ·renewed energy efficiency targets.. Rescaling of energy labels

The new Energy Labelling framework Regulation requires the Commission to rescale the existing labels for five priority product groups, including dishwashers, by 2 November 2018 at the latest, to remove the A+ to A+++ classes. Effectiveness of Ecodesign and Energy Labelling measures Where regulatory measures in Ecodesign and Energy Labelling are no longer effective, or no longer as effective as expected, they need to be revised (or potentially withdrawn). This may happen as a result of technological progress, consumers' choices or market evolutions. In particular, the filling up of the top classes means that the label is no longer effective. If there is still a significant difference in energy efficiency of products remaining on the market, a label will still bring added value in terms of guiding consumers to more efficient products. 2.Problem definition 2.1.How the problems are defined The review of the Ecodesign and Energy Labelling for dishwashers started in 2015 and several studies were conducted for this purpose, as described in Annex 1. These studies evaluated the impact of the current legislation, as reported in Annex 4; they also looked at the evolution of the sector (technological and economic evolution) and at stakeholders' views. Results from the studies have been used directly as input to the analysis model of Annex 5. The results of the review are summarised in the follow-up study published in 2017 and cover the following issues: ·Energy label classes: some dishwashers already exceed the minimum level of the highest energy class A+++ in the current scale; ·Water consumption: the water consumption of household dishwashers per cycle and place setting is closely related to energy consumption, and both have been reduced significantly in the past few years. Evidence shows that pre-rinse is often applied resulting to additional water consumption ·Use of the standard programme: only 19% of consumers use the standard ("Eco") programme which is the test programme to measure energy performance; however, this use has been increasing since 2012 when the standard (Eco) programme was set as the default option. ·Programme duration: the duration of the standard (Eco) programme has recently increased to around 3.5 hours while most consumers are willing to accept a maximum of 2-3 hours. ·Technical innovation: further energy savings could be achieved by technical improvements in dishwashers, generally with a low impact on life cycle costs; ·Resource efficiency: an increased proportion of dishwashers have to be replaced in the first 5 years of use, with an impact on the average lifetime of appliances; The problems defined in this section and the policy options defined in Section 5 build on the results of the review study and on the comments from stakeholders on these results. 2.2.Problem 1: Outdated energy efficiency requirements The problem: The current Ecodesign requirements for dishwashers no longer capture cost-effective energy savings, and the current energy label no longer allows consumers to effectively differentiate between the appliances on the market. The last revision of Ecodesign requirements, in Regulation 1016/2010, introduced a new minimum requirement on energy efficiency (which came into force in the end of 2016) excluding products with an Energy Efficiency Index (EEI) lower than the A+ class limit for full-size and slim-line dishwashers, and lower than the A class limit for the smaller dishwashers (<7 place-settings. As a consequence, there are now only three Energy Label classes (A+/A++/A+++) for most models of dishwasher, and four for the smaller ones. The small number of Energy Label classes led to the classification of many models in the top classes (“Energy Label congestion”) and to poor differentiation by consumers of the performance of dishwasher models on the market. Furthermore, the "A+", "A++" and "A+++" classes introduced by the Energy Labelling Framework Directive (Directive 2010/30/EU) have been shown to be less effective in persuading consumers to buy more efficient products than the A to G scale.

Consumers do not easily understand the differences between A, A+, A++ and A+++ and purchase A or A+ class dishwashers without realising that these are the lower performing dishwashers currently on the market. Consequently, products rated in A or A+ classes currently enjoy the larger share of sales. This problem is especially relevant because the market for dishwashers in the EU is still not saturated. There are several Member States where the market penetration of dishwashers is very low, and where the number of installed dishwashers is expected to significantly increase in the coming years. It should be noted that using a dishwasher achieves important savings on energy and water when compared to manual washing-up; up to 30% on energy consumption and up to 88% on water use according to some studies. Increasing the market penetration of dishwashers therefore represents a “win-win-win” solution from an environmental, business and consumer perspective, but of course comes with an initial purchase cost - which is the probable cause of the lower market uptake in Member States with lower levels of income. The drivers of the problem: Problem driver 1: Technological progress Since the last revision, technological progress for household dishwashers has kept evolving, bringing with it increased energy efficiency. In the 2010 Ecodesign measure, best available technology (BAT) energy consumption benchmarks for the dishwashers were cited at 0.88 kWh/cycle (15 place-settings), and 0.83 kWh/cycle (13 place-settings), and indicatively 0.80 kWh/cycle for slim-line dishwashers (9 place-settings). However, compared to these 2010 benchmarks the actual BAT figures in 2017 attained were 36% lower (for heat pump-equipped machines), and 22% lower (for other BAT technologies dishwashers). For full-size dishwashers, the influence of the Energy Label on the market has led to a situation where a large proportion of high-performing products has the same highest Energy Label class A+++ (this is the “Energy Labelling congestion” observed also in other product groups, e.g. washing machines). This reduces the incentive for manufacturers to further invest in new technologies as this is not rewarded by the market. They cannot further differentiate their product within the energy class A+++, apart from using unofficial labels such as “A+++ -20%” to indicate a better level of performance than the minimum performance of the A+++ class: a solution which seems more confusing to consumers than the “A-G” label scale. Problem driver 2: Price difference between models of different energy classes As explained above, products rated A or A+, meaning the least efficient products on the market, enjoy the largest market share. This is due in particular to the high difference in purchase price between the cheaper models of A/A+ and the higher-priced A++ and A+++ models on the market. The present limited number of Energy Label classes leads consumers to differentiate products on purchase price only instead of both price and energy-efficiency. The important price difference between models of different classes prevents low-income consumers to benefit of energy-efficient appliances and it negatively impacts innovation as manufacturers do not have any incentive to produce more efficient appliances. The situation reverts instead to an incentive for manufacturers and retailers to compete on price, rather than via technology offers. Problem evolution in absence of policy measure: obstacles to innovation In the absence of a suitable policy measure, technological progress is likely to slow-down or even come to a halt. The absence of reward for more energy-efficient technologies and their small market share reduce the 'learning effect' for new technological developments introduced on the market, which increases their purchasing price, and further increases the price difference with lower-performing appliances. At the same time, in a number of Member States, the low penetration rates keep pressure on prices for the market entry of (lower-performing) products. There is therefore a risk of ‘vicious circle’ if appropriate policy measures do not re-establish a clearer differentiation and incentives to progress – not only for the higher performing but also for the lower performing appliances. 2.3.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 durability, reparability, and recyclability. The existing requirements focus mainly on energy efficiency improvements as the most significant environmental impact during the life-cycle of household dishwashers. However, dishwashers, like many other products, can be significantly improved in terms of circular economy aspects, which could be progressively achieved through Ecodesign measures. The main indicator of this poor performance is that of durability. The average lifetime of a dishwasher has reduced in recent decades from 14 to 12.5 years. For a long time, the energy efficiency gains permitted by new dishwasher models justified a quicker renewal of the stock of appliances, but this is no longer the case. Furthermore, consumer NGOs (see Annex 3 and the review study 2017) have noted the following trends, both for dishwashers and other “white goods”: ·An increase in the proportion of early product failures (<5 years); ·Increased complaints by consumers that repair is not as easy and beneficial as it should be; ·More resources are lost at product end of life, due to the difficulties encountered by professional dismantling/recycling entities to separate and recycle materials. The drivers of the problem: Problem driver 1: availability and cost of spare parts and their delivery Currently no measures exist which regulate the availability of spare parts for dishwashers and their delivery. The Review study 2017 suggests that a minimum availability of those spare parts that fail most frequently (see Annex 3.1) would be useful, also after production of the model ends. 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 it is technically unfeasible to replace certain broken parts, because they cannot be removed without damaging other parts, or because they are permanently fixed to other parts, meaning that replacing the broken part would require the replacement of a significantly larger part of the appliance. Additionally, the cost of spare parts and the cost of repair services (including travel/ labour time) are often too high in comparison with the purchase price of a new appliance. Consequently, in case of problems that occur after the expiry of the legal guarantee, defective appliances are often not repaired at all but instead are replaced by new ones.

Another important issue is the time for delivery of the spare parts - a reasonable maximum time limit is needed to ensure that consumers are not discouraged due to the waiting time. Problem driver 2: Access to repair and maintenance information There is sub-optimal information available both to individuals and to professional repair services, to easily identify the cause of problems and carry out repairs on dishwashers. The Review study 2017 uncovered that this is especially the case for independent repairers, i.e. professional repairers other than those under a contractual relationship, or “authorised”, by Original Equipment Manufacturers (OEMs). No measures currently exist regulating the availability of repair and maintenance information for dishwashers and their access to independent repairers. For example, disassembly procedures and sometimes diagnosis software are essential prerequisites for repairs and are generally not available to independent repairers. This was confirmed through the feedback received from repair and end-of-life operators during and after the December 2017 Consultation Forum. Difficult access to information affects the competitiveness of independent as compared to authorised repairers, while more competition in repair activities could potentially reduce prices and provide more options for consumers. It also increases the cost of repair, making it unattractive to consumers compared to replacement with a new appliance. Consequently, many appliances are not repaired. The current situation is likely to result in fewer dishwashers being repaired than would be economically, socially and environmentally beneficial. This also results in sub-optimal use of resources and avoidable costs for consumers. Problem driver 3: Incomplete information on the end-of-life of appliances The review study 2017 found that if recyclers are given insufficient or poor quality information related to the recycling and disposal of dishwashers, as seems to be often the case, material recovery is less efficient, which then increases the treatment cost (See Annex 6). This may be linked to several causes, such as a lack of standardised methods or insufficient and not easily understandable information (e.g. dismantling at end of life, including exploded diagrams on how to access certain parts, and what valuable material might be contained therein, e.g., Critical Raw Materials, etc.). The Waste Electrical and Electronic Equipment (WEEE) Directive establishes a list of parts that shall be easily dismantled by recyclers, using commonly available and non-proprietary tools (Annex 7 of the WEEE Directive). Integrating those parts relevant for dishwashers into the Ecodesign Regulation would facilitate the efficient implementation of this requirement already at design stage, in complement to the enforcement of the Directive by Member States in relation to waste management. Problem evolution in absence of policy measure: In the absence of policy intervention, there is no prospect for significant change in current trends: the average lifetime of appliances is likely to continue diminishing, while repair activities are unlikely to develop significantly. End-of-life activities are likely to develop, driven by other legislation, but in the absence of integration with Ecodesign requirements, the cost of recycling is likely to remain high for society. 2.4.Problem 3: Low use of the Ecoprogramme by consumers The efficiency of Ecodesign and Energy Labelling requirements is reduced by consumer habits, in particular by the low use of the Ecoprogramme, which is the programme defined by the Ecodesign Regulation for tests and therefore optimised by manufacturers for energy efficiency. The 2017 review study collected data showing that consumers on average use dishwashers as follows: 39 % of the cycles are run in normal programmes, 19 % in ecoprogrammes, 11 % in short programmes, 9 % in intensive programmes and 9% in automatic programmes. This means that the energy efficiency required under Ecodesign requirements materialise in only 19% of washing cycles, the other cycles using less energy-efficient programmes. A related issue is programme duration: consumers indicate that they are willing to use energy-saving programmes, but programmes lasting too long (> 3-4 hours) have low acceptability. The risk is that the energy savings estimated at the time of Ecodesign revisions are only partially realised. Problem evolution in absence of policy measure: slow resolution The situation seems to change progressively with the setting of the Ecoprogramme as the default programme, mandatory since the last Ecodesign revision and applicable as of December 2012. Because of the slow renewal of the stock of dishwashers, it is not possible to quantify the effect of this requirement with certainty but the one-fifth share of consumers choosing the Ecoprogramme as their regularly-used programme appears to be increasing (corroborated by data illustrating that the Ecoprogramme is used more often in newer machines). It is therefore considered that, even if the problem is still present at the time of this impact assessment, it is in way of resolution without need of additional measure. 2.5.General market failures In addition to the product specific problem drivers described in Section 2, some general market failures have been identified: Asymmetrical information - Without up to date energy efficiency requirements and energy labels, economic actors (both business and individual consumers) 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, manufacturers lack incentives to invest in new technologies and consumers lack the guarantee that the products will be cost-effective over their life-time. 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. Environmental externalities – The price of the products does not reflect the real environmental costs to society in terms of resources used from raw materials and production processes, waste management and missed opportunities for a more circular economy. Hence, without setting requirements that will improve “Circular Economy” aspects of the product, the different actors in the life cycle of the appliance will not be incentivised to improve the Circular Economy aspects of the product/ service offered.

2.6.Who is affected? 2.6.1.Household dishwasher appliances' manufacturers and retailers For the manufacturing industry and retail sectors, the Energy Label class rating is one of the main market drivers. It is an important quality feature that allows industry and importing actors to distinguish themselves via a well-recognised and trusted label representing features associated with quality and innovation, rather than having to compete primarily on purchase price alone. Important manufacturers with EU production facilities are Bosch Siemens Home appliances (BSH), LG, Miele and Whirlpool. The European industry association is APPLiA (formerly known as CECED). These end-product manufacturers mainly assemble components supplied by other companies. Almost all manufacturers are large companies. SME manufacturing companies are solely present in niche markets, such as dishwashers equipped with heat-pumps with the SME V-Zug, or as suppliers of larger manufacturers. European manufacturers are mostly affected by the outdated energy efficiency requirements and by the resulting difficulty in introducing new energy-efficient technologies on the market. The evolution to a situation of competition on price-only, rather than on both technology performance and price, is likely to have a negative effect on their competitiveness. At the same time, the non-saturation of the market gives important margins of growth, especially in central and southern European Member States, even if competition on these markets seems to be mainly driven mainly by purchase prices. The total employment in household dishwashers is estimated at just over 44 000 jobs10, of which around 65% are in the retail sector. It is estimated the EU 2015 annual market value for household dishwashers comprises close to 5.5 billion Euros (including VAT and levies), of which almost 2.7 billion Euros is derived from industry revenues (manufacturers' sales prices), 1.75 billion Euros in retail, and just over 1 billion Euros in taxes, levies etc. It should be noted that Eurostat data related to production, as well as to exports and imports of household dishwashers in Europe in recent years seems to be only partially complete. However, other studies, such as Deloitte 2016, cited that over half of the value (54%) of the EU's annual sales of white goods relate to products that are imported from outside of the EU. 2.6.2.Repair industry This industry consists mainly of SMEs that act locally, either as ‘independent’ organisations or as "authorised" repair entities that have a contractual relationship with OEMs/ retailers. Activities in this sector are likely to benefit from better availability of spare parts and better access to maintenance and repair information. Ecodesign requirements on repair would facilitate better conditions for repair activities, and would help to ensure that consumers have affordable and fast repair options. Additionally, access to maintenance and repair information fosters greater competition in this sector, as conditions under which independent repairers operate as compared to OEM-authorised repairers, would start to level out. This is expected to lower the costs of repair, in line with reducing the technician’s time at the consumer’s home when analysing breakdowns, as the technician would have access to better product repair information. 2.6.3.Recycling industry Recycling companies are situated all over the EU. Some of the bigger recyclers can be found in Netherlands and Belgium as well as in the UK and France. The recycling industry is presented by the European Recycling Industries' Confederation (EURIC). The recycling industry is likely to benefit from Ecodesign requirements at the end of life of appliances, through e.g. easier dismantling of electric and electronic components. 2.6.4.Consumers For consumers, the EU Energy Label offers a unique opportunity to make an informed choice regarding which products offer the best environmental and energy performance, allowing them to save money over the life time of the product. Ecodesign requirements safeguard consumers from the worst-performing products. Consumers are affected by the difficulty in differentiating between the upper classes of the Energy Label. Additionally, prompt and fair-priced spare part availability would improve the reparability of household dishwashers, and would help to ensure that consumers could have their appliances repaired, even after the final production date of a particular model. This would help extend product lifetime and save consumers expense on purchasing replacement models. The discrepancy, in the case of dishwashers, between expected energy savings and realised (increasing) energy consumption raise the question of rebound effect, i.e. whether consumers habits reduced or cancelled the benefits of savings. Actually, this discrepancy is mainly due to the increased number of dishwasher in use. This is not a rebound effect stricto sensu, in the sense that this increased use lead overall to actual energy savings when taking into account the impact of handwashing. As for the impact of the under-loading of machines, this indeed reduces the expected savings and it is unlikely to change in future. Dishwashers are generally perceived to run at full load according to the consumers’ opinion, which is however a lower load than during the testing of the machines. 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). 2.6.5.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 EU’s 2030 energy and climate goals. 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). For EU and Member State policy-makers, more effective and efficient Energy Label and Ecodesign regulations mean that these policies will make additional contributions to achieving policy goals regarding the single market, energy efficiency, environmental protection, technological innovation, energy security of supply, carbon emission abatement and furthering the aims of the "Circular Economy", thus saving resources. 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 represent a significant volume of sales (indicatively, a value of more than 200 000 units a year); -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 is 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 6.3). 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 2017), it was established that household dishwasher appliances fulfil the above eligibility criteria. 3.2.Subsidiarity: Necessity for EU action Action at EU level gives end-users the guarantee that they buy an energy and resource efficient product and provides them with harmonised information no matter in which MS they purchase their product. This is becoming even more relevant as the (cross-border) online trade increases. With Ecodesign and Energy Labelling at EU level, energy and resource efficient products are promoted in all MSs, creating a larger market and hence greater incentives for the industry to develop them. It should be noted that the intra-EU trade represents around 60% of the sales of dishwashers, to be compared with 35% of extra-EU imports.

It is essential to ensure a level playing field for manufacturers and dealers in terms of requirements to be met before placing an appliance on the market (under Ecodesign) and in terms of the information supplied to customers for sale across the EU internal market (under both Ecodesign and Energy Labelling). For this reason EU-wide legally binding rules are necessary. Market surveillance is carried out by the Market Surveillance Authorities (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 should 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 dishwashers, in particular to rescale the label from A to G classes and to remove the A+ to A+++ classes. 3.3.Subsidiarity: Added value of EU action There is clear added value in requiring minimum energy and resource efficiency levels and energy label class limits at EU-level. Without harmonised requirements at EU level, MSs would have to lay down national product-specific minimum requirements in the framework of their environmental and energy policies. This would undermine the free movement of products and the level playing field for retailers across different Member States. Before the existing Ecodesign and energy label measures were implemented at EU level, this was in fact the case for many products. In the case of dishwashers, the estimated energy saving potentials are expected to be relatively small (partly due to the high development of the products during recent years), but the revision is nonetheless considered worthwhile for the following reasons: -the proposed recalibration of the Energy Labelling scheme will allow consumers and industry to take advantage of technological advances; -revised minimum energy efficiency requirements should maintain the momentum of technological progress of dishwashers placed on the EU internal market; -new Ecodesign requirements should relate to previously unregulated material efficiency aspects of the performance, repairability and durability of the machines. 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 household dishwashers in the internal market; 0.Promote competitiveness of the EU household dishwashers industry through the creation or expansion of the EU internal market for sustainable products; 1.Promote the energy efficiency of household dishwashers as a 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 2.Increase energy security in the EU and reduce energy dependency through a decrease in energy consumption of household dishwashers. There are several synergies between these objectives: reducing electricity consumption (by increasing 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; and, following the Ecodesign Working Plan 2016-2019, Ecodesign and Energy Labelling measures also contribute to the objectives of the Circular Economy Action Plan to facilitate the transition towards a more resource-efficient and circular economy in the EU. 4.2.Specific objectives In line with technological developments, the Ecodesign Directive and the recently revised Energy Labelling framework Regulation, the specific objectives to be pursued by the policy options are to correct the problems and underpinning drivers identified in Section 2, are to: 1.Update the energy efficiency requirements and the energy label to achieve cost-efficient savings of energy and other resources.

2.Maintaining and supporting the past market trend towards progressively more energy efficient and more environmentally friendly appliances. 3.Contribute towards a circular economy in the EU by supporting longer-lasting products, inter alia, by facilitating their repair, and by increasing their recyclability at the end of life. 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 the Better Regulation Toolbox . Specific measures in the policy options are the result of a combination of initiatives mentioned in the Review study 2017, the evaluation of the efficiency and effectiveness of the Ecodesign and Energy Labelling (Annex 4), the Inception Impact Assessment , comments received on working documents at and after the Ecodesign Consultation Forum meeting, and – importantly - alignment with the 2009 Ecodesign Framework Directive and the recast 2017 Energy Labelling framework Regulation. In view of the issues identified in Section 2, the policy options should address two challenges at the same time, which normally would call for opposite solutions: the revised energy classes should lead to better differentiate between products and the differences in purchase price between appliances of different classes should be more than compensated by the savings in energy and water; at the same time, the strengthening of minimum energy efficiency should not halt the increase in penetration rate of dishwashers in those Member States where this rate is low – as the increased use of dishwasher is overall beneficial to energy and water savings overall when compared to handwashing. The increase in purchase prices generally associated with technological progress risks therefore to put in question the overall savings generated by the increased use of dishwashers. 5.1.Issues not subject to assessment During the review study and subsequent stakeholders' consultations, several issues were the object of a large consensus between stakeholders. They are not re-discussed in detail in this report. These issues are the following: ·Acceptance of the changes in the IEC and CENELEC standards on the measurement of dishwasher performance (e.g., inclusion of plastic elements, pots and changes in the shape of the dishes, etc), as well as the measurement of the combined cleaning and drying efficiency. These changes have been widely accepted by stakeholders, they are in line with the prior changes in directly relevant international standards, and they bring the testing parameters closer to consumers' real use of the machines. ·Exclusion of the low power modes from the average energy consumption per cycle, and their separate regulation (i.e., dishwasher-specific, rather than via the "horizontal" Standby Regulation currently under revision). Regulating the low power modes separately for dishwashers has been welcomed by industry stakeholders since it streamlines the calculation of the current annual energy consumption. However, environmental NGOs and consumer associations would prefer dishwashers to be covered by the horizontal regulation or by both. ·Maintenance of the minimum cleaning efficiency (Ic > 1.12) and drying efficiency (Id > 1.08). These minimum performance parameters guarantee the satisfactory functioning of dishwashers, and consumers expressed their satisfaction with the current limits. ·the non-inclusion of requirements on hot water inlet, because related energy savings are too dependent on the household heating system efficiency. Additionally, the water consumption has been considered as a non-independent design parameter, owing to its strong interlinkage with electricity consumption. It has been observed that a reduction in the energy consumption of dishwashers triggers a reduction in their water consumption, up to a certain level. In this phase, energy savings are realised by reducing the amount of water to be heated up, and therefore by reducing in parallel both overall water and energy consumption. However, going beyond this level of energy efficiency, to the levels of ultra-high energy efficiency dishwashers, a slight increase in water consumption per cycle is observed, owing to the different technology that they use. Regulating water consumption in addition to energy efficiency risks to trigger unwanted effect such as a reduction in the rinsing of dishes. Finally, the duration of the dishwashing programmes was not considered as a crucial parameter to be regulated. The average duration of the Eco-programme (around 3.5h) exceeds only by a small extent the time range preferred by consumers (2 to 3h) and this does not seem to push consumers to choose alternative programmes when the Eco-programme is set as default programme. In addition to the measures described in the options above, some measures were considered as de minimis changes to the current Ecodesign and Energy Labelling regulations on dishwashers. This corresponds to highly technical changes or changes with negligible impacts, for which it does not seem possible or proportional to propose several options for assessment. They are however implicitly included in the different options, except for the baseline, and will be integrated into the preferred option. These measures concern: ·Low-power modes ·Noise ·Cleaning and drying efficiency

Further information on these measures and assessment of their impacts can be found in Annex 8. 5.2.Policy options subject to assessment The policy options in Table 1 aim to address the problem drivers (Section 2) and to achieve the policy objectives (Section 4). Some policy options considered and discarded at an early stage are presented in Section 5.3. Option Name Short name Description Option O Baseline BAU No further action - the household dishwashers regulations currently in place remain unchanged Option A Combinations of more ambitious Ecodesign requirements and Energy Labelling ED+EL BAT=33 Implementation of revised requirements under Ecodesign and revised Energy Labelling, with BAT considered at EEI = 33.5 Several scenarios can be considered here, as described under 0. Option B Combinations of less ambitious Ecodesign requirements and Energy Labelling ED+EL BAT=39 Implementation of revised requirements under Ecodesign and revised Energy Labelling, with BAT considered at EEI = 38.9 Several scenarios can be considered here, as described under 0. Option C Combinations of additional Ecodesign requirements on material efficiency ME Horizontal measures applicable in addition to the requirements of Options O, A or B. New requirements under Ecodesign on material efficiency aspects. Several sub-options can be considered here, as described under 5.2. Table 1: Policy options In all options the calculation formula of the Energy Efficiency Index (EEI) of a household dishwasher model is the same as described in Annex 5. 5.3.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. According to the Energy Labelling framework Regulation, products have to be registered in a new product database (EPREL) from 1 January 2019 onwards, for all models placed on the market after 1 January 2019; and by 30 June 2019 for models placed on the market between 1 August 2017 and 1 January 2019. Also in the application of the Energy Labelling framework Regulation, the energy efficiency classes have to be updated for a number of product groups including dishwashers. In a 'Business as Usual' approach, this would be done while keeping the same limits of existing classes. Annex 5, Section 5.1 describes how the situation would evolve in a baseline scenario in terms of energy savings, circular economy and scope. The patterns of technological progress were assessed based on historical data, e.g., it was observed that the penetration of higher energy efficiency classes tends to follow a normal distribution, being shaped by the regulations in place. This approach was thus maintained when modelling the technological progress in all scenarios. 5.4.Description of policy options 5.4.1.Policy option 0 -- BAU 2015 This option implies that the current regulations stay in place and are not revised, even though the associated problems, and the need for action, have already been explained in Sections 2 and 3. This option is retained as a baseline BAU (2015) scenario, In the BAU scenario, the efficiency of all dishwashers is assumed to continue the trend observed in recent years; i.e. improvement is expected to be slow and to remain close to the existing minimum requirements because of the suboptimal market development (absence of, or limited competition on technology, and no push and pull effect by regulation). 5.4.2.Policy option A -- Combinations of more ambitious Ecodesign requirements and Energy Labelling This option considers the revision of Ecodesign requirements on energy efficiency in combination with Energy Labelling, as a combined market "push and pull" effect. The simultaneous revision of both regulations would ensure that the pushing effect of the Ecodesign requirements, with possible removal of the least efficient models from the market, and the pulling effect of the Energy Labelling, with new energy efficiency scales, would be coordinated. Regarding the energy efficiency classes of the Energy Label, the new framework Regulation requires leaving Class A empty when the revised Regulation enters into force. In consequence, the limit of Class A would be fixed at the first integer below the index of the technology considered as BAT. Other classes are then defined up to the limit fixed by the minimum requirement for slim-line dishwashers (the last Class G being accessible only to counter-top dishwashers). Note that the distribution of Energy classes could be done using classes of either regular or irregular width, depending on the level(s) of market incentives being created for appliances to improve and move from one class to another. Under policy option A, the share of products classified in Class A is expected to remain very limited in the next ten years: depending on the specific scenarios, the projected share of Class A in 2030 should vary between 0% and 2%. This is because great efforts are needed to reach this level of performance, leading to higher purchase prices and limited uptake.

Regarding Ecodesign minimum requirements on energy efficiency, and distinguishing three size ranges as in the current legislation (full-size, slim-line and counter-top), 2 sub-options are considered: the requirements could remain at the same level of stringency as in the current Regulation or they could be made more stringent for full-size appliances. The last sub-option concerns the date of entry into force: revised minimum requirements can enter into force immediately or via two Tiers, the first Tier maintaining the current level of ambition and stricter measures applying 4 years later in a second Tier. A higher level of stringency is proposed only for the full-size appliances because they are the only dishwashers that at present can accommodate new and more energy efficient technologies, in terms of the physical space available within the dishwasher dimensions. For example, technologies such as adsorption drying technologies or heat pumps are only present in the full-size dishwashers. In order to analyse the impact of the different combinations of the Energy Labelling measures defined for this option and the different sub-options for Ecodesign, several scenarios were considered: -Scenario A1 with no increased stringency of the current Ecodesign requirement on energy consumption. -Scenario A2 with more stringent Ecodesign requirement on energy consumption for full-size appliances via a second Tier that enters into force in 2024. -Scenario A3 with more stringent Ecodesign requirement on energy consumption for full-size appliances but entering into force earlier, in a single Tier in 2021. For all scenarios the Energy Label is to be introduced in April 2021, with a proportional sequence of Energy bandwidths, where – with a value of EEI=71 as the lower limit for the "G" class - every higher class limit represents an EEI improvement value of approximately 14%, as shown below in Table 2. Class "G" will be left empty for full-size and slim-line household dishwashers, but will still be populated by top-counter household dishwashers. Additionally, a fourth scenario is considered to assess the possibility of using non-proportional bandwidths in the Energy Label, as smaller bandwidths in the lower classes may incentivise the improvement of the least efficient models. -Scenario A4: same Ecodesign minimum requirements as in the A2 scenario; Energy Label with non-proportional classes. Finally, the impact of a lower demand of products due to an estimated increase in the cost of the appliances has been analysed for the Scenario A4 through a sensitivity analysis, in comparison with a similar analysis realised for the Scenario B3. The results of this analysis are presented in Section 6 as Scenario A4a. Stakeholders views: Option A corresponds to the ambition level recommended by some Member States, consumer associations and environmental NGOs during and after the December 2017 Consultation Forum. These stakeholders consider that the current BAT level is defined by the heat pump-equipped dishwashers (HP), with a declared EEI=33.5. Furthermore, these stakeholders believe that the costs of reaching a higher ambition level are not as high as were described in the Review study 2017 . 5.4.3.Policy option B -- Combinations of less ambitious Ecodesign requirements and Energy Labelling This option also considers the revision of Ecodesign requirements on energy efficiency in combination with Energy Labelling. Regarding Energy Labelling, Option B corresponds to the proposal expressed by some Member States and manufacturer representatives, whereby in their opinion the current BAT level should NOT be defined by the HP equipped dishwashers, but instead by other technologies (the best non-heat pump technology having a declared energy efficiency index set at EEI=38.9). The rationale for this alternative proposal is based on several current functional limitations of HP equipped dishwashers, compared to conventional dishwashers: I.HP technology is not capable of performing two consecutive Ecoprogrammes; II.HP technology cannot supply the high temperatures needed for example in intensive programmes; III.HP technology requires a long duration for the Ecoprogramme cycle, and this could discourage consumers from using the Ecoprogramme for which the HP is optimally designed. In Option B, the Energy Label is also introduced in April 2021, but a value of EEI=38 is used as the lower limit for the "A" class. Proportional improvements are used for the Energy Label class bandwidths – each class limit represents a 10% proportional improvement on the previous class, as shown in Table 2. Under Policy Option B, the share of products that are projected to be classified with Energy Label Class A after ten years (in 2030) is relatively high: approx. 20% of the market. This higher estimated market share, in comparison with Option A, is based on two factors: firstly, current BAT machines already reach EEI values close to EEI=38, and secondly manufacturers' efforts involved in increasing the energy efficiency of products with higher EEI values is lower – and cheaper – in relative terms than increasing the energy efficiency of products with lower EEIs.

As in Option A, Class "G" will be left empty for full-size and slim-line household dishwashers, but will be populated by top-counter household dishwashers. In order to analyse the impact of the different combinations of the Energy Labelling measures defined for this option and the different sub-options for Ecodesign, several scenarios within Option B were considered: -Scenario B1 (similar to A1) with no increased stringency of the current Ecodesign requirement on energy consumption. -Scenario B2 (similar to A2) with more stringent Ecodesign requirements on energy consumption for full-size appliances via a second Tier in 2024. -Scenario B3 (similar to A3) with more stringent Ecodesign requirements on energy consumption for full-size appliances already from 2021. Additionally, the impact of a lower demand of products due to an estimated increase in the cost of the appliances has been analysed for the Scenario B3, throughout a sensitivity analysis. The results of this analysis are presented in Section 6 as Scenario B3a. This correspond to comments made by industry stakeholders and it is assessed on the most stringent scenario (in terms of requirements and timing) to simulate a 'worst-case' scenario. Stakeholders’ views: option B corresponds to the ambition level, for the energy label, recommended by industry stakeholders and some Member States. Regarding the ecodesign requirement on energy efficiency, industry recommends to keep the current level, as in scenarios A1 and B1, while environmental NGOs and most Member States consider that the level should be increased, at least at the level of scenarios A3 and B3 or even beyond. Scenarios A2, A4 and B2 represent a tentative compromise between these positions. 5.4.4.Policy option C -- Combinations of additional Ecodesign requirements on material efficiency The possible Ecodesign requirements described in this option aim to solve the market failures highlighted in Section 2 that are associated with the reduction of the average lifetime of the appliances, premature disposal of repairable appliances and the lack of or difficult access to maintenance and repair information. The measures considered here were identified during the review study, based on the different studies and initiatives on this field summarised in Annex 6. They relate to the following aspects: a.End-of-life of appliances b.Spare parts availability and delivery c.Repair and maintenance information The possible requirements on material efficiency are presented separately of other policy options for the sake of presentation and assessment. They should nevertheless be considered as additional (not alternatives) to the requirements on energy efficiency presented in the previous options and, after assessment, they should ultimately be combined with requirements on energy efficiency. Three possible scenarios have been envisaged in this Impact Assessment: Under Scenario C0, two measures are considered: the marking of refrigerating gases in case of the use of a heat-pump (as per the F-gas Regulation) and the safe removal of key electrical and electronic components (as per Article 8(2) of the "WEEE" Directive ). Building on the Directive Annex VII, the key components for washing machines and washer-dryers include: ·Printed circuit boards (larger than 10 cm2); ·Electrolyte capacitors containing substances of concern (height > 25 mm, diameter > 25 mm or proportionately similar volume);

·Liquid crystal displays (larger than 100 cm2); ·Batteries; ·Heat pumps. These measures implement the WEEE legislation already in force – except for heat pump, which is not mentioned as such in the Directive Annex VII. However, since Annex VII to the WEEE Directive includes a minimum list of substances and components to be removed from WEEE, components such as heat pumps which have similar technical characteristics with components listed in Annex VII should be removed for the WEEE as well for the achievement of the objectives of these measures. The measures should also be seen in relation with the platform of exchange of information between producers and recyclers, established in implementation of the WEEE Directive. The inclusion of these measures in the Ecodesign Regulation would facilitate their implementation by clarifying the role of producers and of Market Surveillance Authorities, without changing the nature of existing obligations. Their cost is therefore considered as negligible for economic actors. Scenario C1 includes Ecodesign measures on repair and end-of-life in addition to the measures stemming from existing legislation as described under C0. This scenario builds on the measures included in the working documents discussed at the Consultation Forum in December 2017, with only few changes for clarification. This Scenario considers specific requirements for disassembly for the purpose of repair in addition to the requirements for dismantling for the purpose of depollution and material recycling. Manufacturers shall ensure that household dishwashers are designed so that there is easy access to and removal of same components listed under C0 plus the following: ·motor; ·piping and related equipment including all hoses, valves and filters. With regard to spare parts, their availability for a minimum period of time of 7 years after the last model was produced and a maximum delivery time of 3 weeks are included. This concerns spart parts necessary for the use of the dishwashers, which include: ·Motor ·Circulation and drain pump ·Heaters and heating elements ·Door hinge and seal ·Piping and related equipment including all hoses, valves and filters ·Structural and interior parts related to door assemblies, spray arms, seals and interior racks. ·Printed circuit boards ·Liquid crystal displays The measures on spare parts reflect the current practice, as least for the major brands represented on the market, which offer the same or better conditions for the provision of spare parts. The measures aim therefore at creating a level-playing field by setting the same minimum conditions for all producers and importers and establishing the basis for the controls of Market Surveillance Authorities and for possible complaints of consumers and repairers in case of failure to meet the requirements. Their additional cost is also considered as negligible in comparison with the current obligations and practice. In addition, wider access to Repair and Maintenance Information by professional repairers is foreseen, with the possibility of proportional fees. Professional repairers include authorised repairers, i.e. repairers under contract with one or several brands, and independent repairers. The access of independent repairers would be new for part of the information concerned, for example the access to digital codes for diagnosis and reprogramming. In order to avoid possible risks regarding intellectual property and liability issues expressed by stakeholders, conditions are imposed on independent repairers to declare that they have the appropriate skills (as covered by national legislation and possible registration) and liability insurance. Checking these conditions represent an extra cost, of administrative nature, for those manufacturers willing to check the access of independent repairers.

This access should also be seen in relation with competition rules: in EU competition law, some vertical arrangements that impose restrictions on the supply of spare parts by their manufacturers to third parties have such a potential for being anticompetitive that they do not benefit from the so-called ‘block exemption regulation' (Regulation EC/330/2010). The objectives pursued with the Ecodesign requirements on making available spare parts and repair information equally to independent repairers and repairers under contract of manufacturers are therefore consistent with those of EU competition law. Scenario C2 includes Ecodesign measures on product durability, repair and end-of-life. This Scenario would require, in addition to the measures introduced in Scenario C1, a requirement for the product to have a minimum in-service lifetime of 10 years or an equivalent commercial guarantee by manufacturers, with the objective of extending the average lifetime of the appliances from the current 12.5 to 16 years, and preserving the corresponding resources. Stakeholders’ views: the measures on circular economy were supported by environmental NGOs and consumer associations, and by associations or representatives of recyclers and of repairers in the Consultation Forum. Representatives of manufacturers are not favourable to the measures on spare parts under C1 and C2, for which they would prefer simple declarations without minimum requirements, and they are opposed to the access of independent repairers to repair and maintenance information because of the risks on intellectual property and on liability and quality issues, which in their view risk impacting their reputation. Member States have diverging views or have not expressed an opinion. The responses to the Open Public Consultation (see Annex 2) have confirmed the importance of material efficiency requirements for stakeholders: Some 63% of the participants were in favour of including Ecodesign requirements on reparability and durability, and 65% of respondents considered that this information should be on Energy Labels. Regarding the reparability of products, participants valued mostly as "very important" to "important" (in the range 62%-68%) each of the following: a warranty, the availability of spare parts, and a complete manual for repair and maintenance. The delivery time of spare parts was rated as 56% "very important" to "important". 5.4.5.Summary of Policy Options The different options and scenarios are summarised in the following Table 2. Option Scenario Minimum Energy Rating 2021 Minimum Energy Rating 2024 Energy Labelling classes – EEI bands Option O – BAU EEI full-size DWs < 63 EEI slim-line DWs < 63 EEI counter-top DWs < 71 Option A ED-EL BAT=33 (set with respect to heat pump-equipped dishwashers) A1 EEI full-size DWs < 63 EEI slim-line DWs < 63 EEI counter-top DWs < 71 A ≤ 32 32 < B ≤ 36 36 < C ≤ 42 42 < D ≤ 47 47 < E ≤ 54 54 < F ≤ 62 62 < G A2 EEI full-size DWs < 63 EEI slim-line DWs < 63 EEI counter-top DWs < 71 EEI full-size DWs < 58 EEI slim-line DWs < 63 EEI counter-top DWs < 71 A3 EEI full-size DWs < 58 EEI slim-line DWs < 63 EEI counter-top DWs < 71 A4 EEI full-size DWs < 63 EEI slim-line DWs < 63 EEI counter-top DWs < 71 EEI full-size DWs < 58 EEI slim-line DWs < 63 EEI counter-top DWs < 71 A ≤ 32 32 < B ≤ 38 38 < C ≤ 44 44 < D ≤ 50 50 < E ≤ 56 56 < F ≤ 62 62 < G Option B ED-EL BAT=39 (set with respect to other non-heat pump BAT options) B1 EEI full-size DWs < 63 EEI slim-line DWs < 63 EEI counter-top DWs < 71 A ≤ 38 38 < B ≤ 42 42 < C ≤ 46 46 < D ≤ 52 52 < E ≤ 56 56 < F ≤ 62 62 < G B2 EEI full-size DWs < 63 EEI slim-line DWs < 63 EEI counter-top DWs < 71 EEI full-size DWs < 58 EEI slim-line DWs < 63 EEI counter-top DWs < 71 B3 EEI full-size DWs < 58 EEI slim-line DWs < 63 EEI counter-top DWs < 71 Option C (material efficiency considerations) To be combined with Options O, A or B C0: existing legislation C1: requirements on repair and end-of-life C2: requirements on durability, repair and end-of-life Table 2. Overview of options and scenarios 5.5.Options discarded at an early stage 5.5.1.Voluntary Agreement Voluntary Agreements (VA) are given priority, subject to certain regulatory efficiency provisions, according to the framework provisions of the 2009 Ecodesign Directive. However, no VA proposal has been made by any industry sector active on this market. Minimum mandatory requirements are already in force for this product; therefore, if they were to be substituted by a VA, there could arguably be a risk of free-riders, if the VA were not signed up to – and complied with - by all actors present on the market. Hence, this option is discarded from any further analysis. No stakeholders have expressed support for this option. For all the reasons given above, this option is discarded. 5.5.2.Mandatory Energy Labelling scheme only This option would consider the use of energy labels according to the Energy Labelling Regulation No 2017/1369 and the withdrawal of the requirements under the Ecodesign Directive. A labelling scheme (as ''pull-effect'') alone will be much less effective that the setting of this policy together with minimum Ecodesign energy efficiency requirements. The mandatory Energy Label makes the relative efficiency of products transparent to consumers, and thus gives incentives to manufacturers to compete on energy efficiency of products. However, Energy Labelling alone cannot achieve the withdrawal of inefficient products from the market, which is the strong point of Ecodesign measures. Energy Labelling alone might allow products with a lower energy efficiency than permitted today to re-enter the market; they could then compete on cheap purchase price alone (rather than the complete Life Cycle Cost [LCC]).

Also, the effectiveness of Energy Labelling alone would have to rely heavily on consumers' understanding of the Energy Label, in order to make informed decisions. However, consumers may not always choose the most efficient dishwasher model for several reasons, such as split incentives or asymmetrical information. Consumers may often base their purchase decisions on purchase price only, and on other factors such as availability in the shop or warehouse, rather than on the long-term optimal life cycle costs and relative environmental impact of the product to be chosen. No stakeholders expressed support for this option, however. For all the reasons given above, this option is discarded. 6.What are the impacts of the policy options? 6.1.Methodological considerations and key assumptions This section describes for each scenario the associated environmental, economic and social impacts on manufacturers, retailers, consumers and general environment, comparatively to the baseline (scenario BAU 2015). The measures introduced in Options A and B have been assessed following the analytical methods described in detail in Annex 5. The material efficiency requirements introduced in Option C are assessed qualitatively based on the information summarised in Annex 6. With the adoption of the Ecodesign Working Plan 2016-2019 in November 2016, the Commission committed for the first time explicitly to systematically explore resource efficiency requirements in Ecodesign. As a result, the methodological basis for the inclusion of such requirements is not yet fully developed; there are no well-established and uniformly accepted methodologies in place to identify these requirements in the context of mandatory legislation. Therefore, the ‘circular economy’ requirements that are proposed here are based mainly on stakeholder input, existing studies and evidence of product failure (e.g. on spare parts), and focus on measures that can be relatively easily implemented. As such, they can be considered a starting point that can subsequently be complemented or refined when the methodological tools are available. In several Member States, initiatives or legislation exists that stimulate circular elements. Some Member States already establish requirements on the availability of spare parts for repair (such as Spain) or have taken legal action to reduce premature obsolescence (France). Several Member States set themselves targets for circular initiatives such as increasing reuse or reducing the production of waste, on top of EU requirements. However, most experiences with circular economy considerations at Member State level are relatively young. Regulation of professions, including repairers, is at the discretion of Member States and related requirements seem to differ between them, including as concerns requirements for registration and insurance. While it is evidently not feasible to address all these issues in the legal context of Ecodesign, the measures proposed do take these circumstances into account. There is also a lack of methodologies to quantify the costs and benefits of such criteria in the context of the ‘least life cycle cost’ (LLCC) calculations applied for energy efficiency in Ecodesign, in particular as regards the assessment of trade-offs. Although a fully quantified impact assessment of such requirements has not been possible at this stage, a qualitative impact assessment was made, based on inputs taken from technical, scientific and policy-making literature, and nascent evidence from other similar product groups. This forms the basis of an assessment, which can be refined over time and be supplemented with actual quantitative data collected via the monitoring and the evaluations. These data will also serve at the time of the next revisions of the product regulations. To support improvements in the methodological framework, the Commission mandated CEN/CENELEC to develop standards for material efficiency under Ecodesign and a first set of horizontal standards is expected next year. These will be integrated in the MEErP methodology as appropriate. A broader update of the MEErP is foreseen in 2019, in particular to see how circular economy aspects could be better integrated in preparatory and review studies, including the LLCC calculations. The key assumptions used in this impact assessment are explained in Annex 5. In general, uncertainty on the results is due to the assumptions made on the simulation of future consumption of dishwashers. In order to estimate the energy consumption values, the declared energy consumption values were transposed (adapted) to "real" consumption values that are closer to real use by incorporating correction factors for user behaviour and future sales distributions for the projected lifetime of product types. 6.2.Environmental impacts 6.2.1 Electricity consumption All scenarios save energy compared to the BAU at unit level, even if the total energy consumption of dishwashers at the overall EU level is expected to increase, due to the related increase in the EU stock. Figure 2 and 3 show electricity consumption in the policy options BAU, A and B. BAU results in an energy consumption of circa 489 TWh/year in 2030. When compared to BAU, Scenarios A1 to A4 save between 1.92 and 3.83 TW/h in 2030, while Scenarios B1 to B3 save between 0.41 and 2.15 TW/h in 2030. A conclusion from the above graphs is that, the stricter the Ecodesign measure on minimum energy efficiency, the higher the energy savings. The projected savings should however be viewed cautiously, as they can be uncertain if the volume of sales of household dishwashers is not in line with the assumptions. Scenario B3a analyses the possible effects of the stricter requirement on the volume sales of the household dishwashers. Scenario B3a has the same conditions as scenario B3, but it considers that the demand of household dishwashers in the future would be different considering reported price elasticities of demand for this appliance as well as the cross price elasticity with low energy efficiency appliances.

Figure 4 shows the results of the sensitivity analysis (scenario B3a) and the results including the energy needed for handwashing of dishes that are not washed by the dishwashers. Scenario B3a has the highest savings of ca. 6.3 TWh p.a. in 2030. However, the estimated energy consumption of "scenario B3a + handwashing" is higher even than the energy consumption of the BAU scenario, if the resources consumed in handwashing are taken into account (5.39 TWh or +30% more in 2030). The above sensitivity analysis exercise was repeated for Scenario A4 (irregular Energy Labelling bandwidths, plus two Tiers of Ecodesign minimum requirements). Scenario A4a (as in Scenario B3a) analyses the possible effects of the stricter requirements on annual dishwasher sales figures at EU level. Figure 4a gives the results, which shows similar relative trends for Scenarios A4/ A4a to those which were observed when comparing Scenarios B3/ B3a. That is, lower sales of dishwashers result in lower energy consumption of dishwashers in the EU, but in higher energy consumption overall when taking into account handwashing. However, this negative impact – on sales and on energy consumption when taking into account handwashing – is limited in comparison with Scenario B3a. Note that the energy consumed by handwashing is not taken into account for scenarios other than the sensitivity analyses B3a and A4a. That is, in all the other scenarios examined, the dishwasher sales patterns are assumed to follow constant historical trends, and the energy and water use per machine are the only aspects which are changed, depending on the hypotheses of each scenario. 6.2.2 Greenhouse gas emissions One of the main environmental impacts is the greenhouse gas (GHG) emissions from electricity consumption during the use phase. The trends in scenarios for GHG emissions are similar to the energy consumption trends. However, the main difference is that the absolute savings over time are higher due to the continuous decrease of specific GHG emissions per kWh electricity. The decrease of specific GHG is because of the increased use of renewable energy sources in EU electricity production, and the shift toward cleaner fossil fuels such as natural gas. Note that the Scenario B3a and A4a sales perturbation effects on energy use (Section 6.2.1) would also be reflected proportionally with regard to GHG emissions, but it was not considered necessary to repeat this exercise here. 6.2.3. Water savings Figure 7 and Figure 8 show the total water consumption for the scenarios considered in this impact assessment. The BAU values are given in the graphs for comparison. There are water savings over time for all the scenarios examined, compared to the BAU. Scenarios A2 and A3 show the same amount of water savings (14 million m3/year in 2030), and provide around twice the water saving volumes yielded by Scenarios B2/ B3. Scenario B3 provides a much larger 59 million m3 of water saving in 2030, when the market penetration of dishwashers is maintained. However, the sensitivity analysis with a reduced market penetration modelled in Scenario B3a results in high increases in water consumption of ca. 95 million of m3 in excess of the BAU scenario, when the water consumed in additional hand dishwashing activities is considered. 6.2.4. Environmental impacts of material efficiency requirements 6.2.1. 6.2.2. 6.2.3. 6.2.4. 6.2.4.1. Energy consumption, greenhouse gas emissions and water savings The impact of longer product lifetimes through increased reparability on energy consumption, greenhouse gas emissions and water savings would likely be negative, as replacement machines would be expected to be more energy efficient in these fields than older machines that are replaced. However, the increase of energy efficiency of dishwashers is no longer improving as rapidly as in the past (it is now estimated in the order of 1% annually), to the extent that the gains due to the higher energy efficiency of new appliances cannot compensate for the environmental burdens of the disposed appliance. Similarly, the extra cost involved cannot be recuperated during the product lifetime (see 2.1). A recent study found that even when taking increased efficiency of newer models into account, extending the lifetime of a dishwasher by 4 years can potentially achieve savings of up to 27% of environmental impact due to resource use and reduce other relevant environmental impacts such as ecotoxicity and freshwater eutrophication by up to 20%. 6.2.4.2. Resources used in production Longer product lifetime means less of a requirement for new replacement machines per year, reducing the environmental impacts associated with the production (energy, water and material use). A recent study shows that while the manufacturing process itself has comparatively low impact, the materials used in a dishwasher cause environmental impacts, most notably abiotic depletion, Ecotoxicity and freshwater eutrophication. The level of impact of course depends on the amount of certain materials used in the dishwasher and the potential reduction of this impact due to repair depends on the amount of product life saved, but the impact will always be positive.

6.2.4.3. Recycling and depollution at end-of-life The improvement in disassembly at the end-of-life phase as a consequence of the proposed measures is expected to make recycling and depolluting easier, providing a large positive environmental effect by making available recycled materials (particularly steel and copper) that can replace virgin materials. 6.3.Economic impacts 6.3.1 Business impacts of Options A and B The increased acquisition costs by consumers, discussed afterwards in Section 6.3.2, can be translated into a revenue increase for all or some of the economic actors. According to the review study, it is estimated that ca. 49% of the increase of the purchase price will become additional revenue for the manufacturing industry and 39% for the retail sector. However, for manufacturers, additional investment costs should be taken into account, in order to adapt the models to the requirements of the proposed regulations. Table 3 shows that the total business revenue increases between 5% and 9% in 2030 for the Option A scenarios and between 0% and 2% for the Option B scenarios (not considering the sensitivity analyses performed in A4a and B3a). Note that the modelling of revenues takes into account not only extra production costs based on today's pricing, but also a learning effect that reduces production costs. Sector Industry Retailer Total % increase by 2030 Scenario 2020 2025 2030 2020 2025 2030 2020 2025 2030 BAU 1502 1630 1865 1525 1703 1920 3027 6653 3785 Scenario A1 1514 1717 1907 1564 1794 2059 3078 7008 3966 5% Scenario A2 1533 1786 1955 1590 1866 2136 3123 7290 4091 8% Scenario A3 1552 1800 1970 1603 1881 2148 3155 7348 4118 9% Scenario A4 1498 1699 1960 1565 1774 2048 3063 6933 4008 6% Scenario A4a 1490 1690 1920 1560 1760 2010 3050 3450 3930 4% Scenario B1 1143 1635 1849 1508 1709 1932 2651 3260 3781 0% Scenario B2 1457 1675 1872 1522 1750 1956 2979 2129 3828 1% Scenario B3 1460 1677 1886 1526 1752 1971 2986 1264 3857 2% Scenario B3a 942 1233 1356 984 1298 1418 1926 2531 2774 -26% Table 3 Overview business revenues for BAU scenario and each of the scenarios under study, in million Euro2015 The industrial net present value (INPV) and estimates of the free cash flows (FCFs) of a representative manufacturer have been considered in this IA for the BAU scenario and the different scenarios. These parameters provide an estimate of the economic impact that implementing the scenarios will have on the industry. The INPV is useful for evaluating the long-term effects and the cash flow is an important indicator of the industry's financial situation in the short-term. This analysis was done in this impact assessment in particular because of the specific market situation in the dishwasher sector, with a need to assess whether stricter minimum energy requirements could damage the sector via price increases, with associated decreases in sales. Further information can be found in Annex 5.3.5. Figure 9 shows the simulated evolution of the Free Cash Flows (FCFs) for the scenario BAU and the scenarios A1 to A4. The comparison of evolution of FCFs with BAU after implementation year show lower FCF for scenario A1 by -3% on average and higher FCF for A2 and A4 (between 14% and 16.5%) and for scenario A3 (by 27.5%). However, the necessary investments mean that FCFs for Scenarios A3 (in 2021) and A2 (in 2024) will become sharply negative by comparison to the BAU for the relevant years of implementation because of the initial investment needed from manufacturers. Figure 10 shows as an example the expected evolution of the Free Cash Flows (FCFs) for the scenario BAU and the scenarios B1 to B3. The scenarios B2 and B3 show FCFs grow by 15% and 27.5% respectively after the implementation year, considering BAU as a baseline. However, as for scenarios A2, A3 and A4, the necessary investments mean that FCFs for Scenarios B3 (in 2021) and B2 (in 2024) will become sharply negative by comparison to the BAU for the relevant years of the implementation because of the initial investment needed from manufacturers. Figures 11a and 11b describe the effect of decreasing the demand. The FCFs are lower for Scenario B3a than for Scenario B3, and for Scenario A4a in comparison with Scenario A4, since the increase in the prices of appliances lowers the sales volumes. However, it should be noted that the FCFs of Scenario A4a and B3a are approximately equal to those resulting from BAU by the year 2030. This study addresses uncertainties and examines the robustness of the FCF and INPV results by applying sensitivity analyses, which consider variations in the following parameters: capital conversion cost (CCC), product conversion costs (PCC), stranded assets and weighted average cost of capital (WACC). These analyses show that the results are sensitive to all of the above-mentioned parameters. However, it is important to note that the INPV remains positive in all conditions, even in the worst-case modelled situations. Furthermore, the results from the calculation of the ratio of EBIT (earnings before interests and tax): Revenues indicates that it is feasible for industry to apply the regulatory requirements. Annex 5, Section 5.3.5 contains the related information on assumptions, uncertainties, and the robustness of the results obtained, together with additional information on FCFs and the industrial net present value (INPV). Other impacts on business such as on innovation, research and development, competitiveness and trade, stranded assets and intellectual property have also been further analysed in Annex 5.3.

1.1.1. 6.3.2 Business impacts of Option C The material efficiency requirements will impact different business sectors differently. Effects are foreseen for the following sectors: 6.3.1. 6.3.2. 6.3.2.1. Effects on manufacturers An unavoidable impact of achieving the policy goal of longer product lifetimes is a corresponding decrease in the number of new products sold, which negatively impacts manufacturers. The expected increase of repairs (after expiry of the legal guarantee) would offset this to a certain extent, which will vary, depending on the profit margins of manufacturers on spare parts and provided repair services. Some studies indicate a very large variation in the rates charged for spare parts and repair services between different manufacturers and even the same manufacturers in different Member States . The overall impact on manufacturers in scenario C1 is expected to be neutral to negative, and negative for Scenario C2. 6.3.2.2. Effects on retailers Retailers who act only as an intermediate between manufacturers and consumers would be expected to be negatively impacted by lower annual sales volumes due to longer product lifetimes. This would be compensated in part by the expected corresponding increase in the market for spare parts, which retailers can also profit from. Also, given the fact that the market for dishwashers is not saturated in a number of Member States, in those Member States the effects on sales would be expected to be lower. The overall impact on retailers is expected to be neutral to slightly negative. 6.3.2.3. Effects on independent repair businesses A stated aim of the material efficiency measures in scenario C1 is to improve the competitiveness of independent repairers vis-à-vis manufacturers repair services. The impacts on these businesses, mostly SMEs , would be expected to be positive. Increases of 15%-20% of repairs were observed after the consumption law came into force in France . The measures requiring availability of spare parts and access to repair information should help independent repairers to overcome barriers currently limiting their capability to compete in a fair way, widening the range of products which they could repair. This is expected to greatly outweigh the potential negative effect of lower profit margins due to more competition between repair services. Also the lower costs for repair are expected to drive up the overall demand for repairs, as studies show that consumers currently cite (perceived) high costs as the main reason to not repair but replace a dishwasher. The overall impact on repair businesses is expected to be positive in scenarios C1 and C2. 6.3.2.4. Effect on reuse operators/second-hand retailers Longer product lifetimes would have an evident positive impact on second-hand retailers. Better and cheaper repair options would in particular benefit businesses that combine repair and second-hand sale of appliances. A minimal product lifetime of 10 years resulting from more durable products (in scenario C2) would greatly improve the market value of second-hand devices younger than 10 years. The overall impact on second-hand retailers of both scenarios C1 and C2 is expected to be positive. 6.3.2.5. Effect on recycling businesses Longer product lifetime could mean less availability of discarded machines to recyclers, which would be a negative impact. However, the requirements for disassembly in all scenarios C0, C1 and C2 will facilitate extraction of valuable materials from discarded devices and make it easier to depollute materials. This will cause a strong positive effect in the long term (from the moment devices marketed under this regulation reach recycling facilities). Improved extractability of the key components due to better disassembly will increase the recovery rate of copper and precious metals such as gold, palladium and silver, with an estimated yearly potential economic benefit of 6.3-6.6 million euros .

The overall impact on recycling businesses is expected to be positive for all scenarios. 6.3.3 User expenditure User expenditure consists of acquisition costs, maintenance/repair and running costs (including detergent, salt, rinsing agent, electricity and water costs). The running costs due to the consumption of detergents, salt and rinsing agents by one single user were estimated at EUR 50.1 per year and the repair costs at EUR 57.36 per year10. The acquisition costs with various scenarios are summarised in Figure 12. In all scenarios an increase in the purchase price is observed. According to these estimates, the stricter the energy label, the higher the average acquisition costs of the machines (considering that the sales are not affected by the increase in the purchase price). This increase in the purchase price is largely due to the introduction of more complex technology in the machines. Once low-cost improvement options have been exhausted, manufacturers have to resort to more advanced and more costly design options. Scenarios A1, A2 and especially A3 indicate that manufacturers would have to use these more advanced and costly options if they wanted products to be awarded with the higher/ highest energy efficiency classes (i.e. to adopt the heat pump technology or compete with it via other technologies). Thus, Option A will be more challenging for the average consumer in terms of affordability (purchase cost), as these additional costs will be (at least partly) passed on to consumers. However, the projected increase in the purchase price is not fully reflected in the predicted user expenditure at EU level, as shown in Figure 13. Considering together the impacts of both acquisition and running costs, the trends in overall consumer expenditure (see Figure 13) are as follows: in the BAU scenario, consumer expenditure is predicted to reach ca. 38 billion euro2015 in 2030, representing an increase of 47% between 2015 and 2030. The total user expenditure for all scenarios is of the same order of magnitude, even if there are differences in the average purchase price for each scenario. Scenarios B2 and B3 relatively save the most at EU level in consumer expenditure, but the saving is estimated to be only 1% with respect to BAU in 2030, which is well within the uncertainties of the estimations. The LLCC for dishwasher products can only be examined by simulating the situation for the "single user", which is discussed below and shown in Table 4. Single user expenditure Table 4 shows the user expenditure for an average dishwasher for each scenario. The single user expenditure considers an average product under each of the conditions of the policy scenario or the scenario under consideration in year 2030. The LCC includes the average purchase price divided by the lifetime of the product, the average water and energy consumption in 2030 as well as the consumption of auxiliaries and maintenance and repair costs for that year. As can be seen, the differences between the options are not sufficiently conclusive to determine which minimum energy requirement is more beneficial. Euro2015/year BAU A1 A2 A3 A4 B1 B2 B3 Purchase price 47.02 50.21 52.32 52.62 50.49 47.32 47.91 48.28 Electricity 55.66 52.11 49.45 49.38 42.26 54.42 52.39 51.59 Water 16.97 16.26 16.02 16.12 14.55 16.62 16.59 16.52 Detergents 107.52 107.52 107.52 107.52 107.52 107.52 107.52 107.52 Total 227.16 226.10 225.31 225.65 214.81 225.88 224.40 223.91 Table 4. Single user expenditure for the scenarios. Costs calculated for the average product in year 2030 and reported in Euro 2015 (cost of electricity=0.212 euro2015/kWh, cost of water = 5.9 euro 2015/m3) based on PRIMES 2016 model. Stakeholders’ views – Industry disagrees that the current LLCC could be set at an overall lower EEI level (e.g. at an EEI=58 instead of the current limit set at EEI=63). The industry association APPLiA presented to the Consultation Forum another approach, and compared the LCC of each of the energy efficiency class currently available on the market. The calculation presented does not consider how the market can evolve in the future. The analysis (summarised in Table 5) was performed according to the data provided by Eurostat, Eurocommerce and GfK and shows that the LLCC is reached for the current A+ class and therefore, industry proposed that the minimum Ecodesign requirements for energy consumption should not become stricter. However, the difference in LCC between the energy efficiency class A+ and the next energy efficiency class A++ is approximately 3.5%. As in the previous calculations, this difference is too small to be considered conclusive to fix the minimum energy requirement. EEI< 33 40<EEI<49 49<EEI<55 55<EEI<63 Electricity consumption per cycle (kWh/cycle) 0.55 0.83 0.92 1.05 Observed purchase price (EUR, 2016) 1886 588 423 325 Life cycle cost (EUR) 2294.29 1224.86 1120.01 1082.16 Assumptions Average electricity cost: 0.2052 EUR/kWh kept constant during the lifetime Lifetime: 12.5 years and 280 cycles/year Capacity: 13 ps The first column corresponding to EEI<33 is referred to heat pump dishwashers Table 5. LLCC analysis from the market perspective, presented by APPLiA in the consultation forum. APPLiA questioned the feasibility of the more ambitious Ecodesign Tiers incorporating enhanced minimum performance requirements, with respect to the situation in several Eastern European MS in terms of consumer expenditure and affordability (see Annex 5, Section 5.2.6). Regarding material efficiency requirements of Option C, longer product lifetimes would have a positive effect on consumer expenditure (i.e. lower expenditure). This would certainly apply to scenario C2 and also to scenario C1 if - as a consequence of the measures proposed - repair costs were lowered to below the threshold that consumers are willing to spend on repair (estimated to be around 30% of the price of a new product). 6.3.4 Administrative burden The administrative burden of new measures under the Energy Labelling Framework Regulation was calculated in the Impact Assessment for the Energy Labelling Framework Regulation. The costs for household dishwasher appliances