Opinion on the proposal for a European Parliament and Council Directive on energy efficiency requirements for household electric refrigerators, freezers and their combinations ()

(95/C 155/07)

On 8 February 1995 the Council decided to consult the Economic and Social Committee, under Article 100A of the Treaty establishing the European Economic Community, on the abovementioned proposal.

The Section for Energy, Nuclear Questions and Research, which was responsible for preparing the Committee's work on the subject, adopted its Opinion on 11 April 1995. The Rapporteur was Mr Kielman.

At its 325th Plenary Session (meeting of 27 April 1995), the Economic and Social Committee adopted the following Opinion unanimously.

1. Introduction

1.1. The proposal in question is for a Directive implementing the SAVE framework programme ().

1.2. The framework programme represents the continuation of the Community action programme for improving the efficiency of electricity use (PACE) ().

1.3. The SAVE programme has been implemented via specific directives on a series of questions such as:

- energy certification of buildings, billing actual energy use in multi-occupancy buildings, regular inspection of boilers and promoting energy audits in businesses;

- efficiency requirements for domestic hot-water boilers ();

- a framework Directive on the indication by labelling and standard product information of energy consumption by household appliances ();

- a Directive on the energy labelling of household refrigerators ().

1.4. In its earlier Opinions on the SAVE programme and the implementing Directives, the Committee:

- approved the inclusion of measures to enhance energy efficiency within the framework of the SAVE programme;

- also argued for maximum compliance with the principle of subsidiarity;

- urged the Commission to adopt measures in the event of shortcomings in the Member States' implementation of the Directives and to apply the highest current technical standards.

2. Gist of the Commission document

2.1. The purpose of the Commission proposal is to set 'floor level' energy efficiency requirements for domestic refrigeration appliances for foodstuffs.

2.1.1. The draft Directive covers most refrigerators and should help to prevent barriers from arising on the internal market. The proposal is therefore based on Treaty Article 100, according to which legislation must be harmonized in order to achieve the common market. Moreover, Article 100a(3) stresses the need for a high level of environmental protection.

2.1.2. A further aim is to reduce energy consumption and, in full compliance with the principle of subsidiarity, to cut CO2 emissions (Treaty Article 130r).

2.2. The proposal concerns newly produced mains electrical domestic refrigeration appliances, except for those cooled by absorption.

2.3. The 'Whereas' clauses refer to:

- the Council Resolution of 15 January 1985 ();

- the Council Resolution of 16 September 1986 ();

- the readiness of several Member States to adopt individual provisions in this area;

- the conformity of the proposal with Treaty Article 3b;

- the Council Decision of 5 June 1989 ();

- the Council conclusions of 29 October 1990;

- the Council Decision of 29 October 1991 () (SAVE programme: Specific Actions for Vigorous Energy Efficiency);

- the Council Resolution of 7 May 1985 ();

- the Council Decision of 22 July 1993 ().

2.4. The proposal is motivated by the fact that the directives already adopted concerning information on domestic refrigerators and energy labelling are not sufficient to ensure improved energy efficiency of appliances. To this end two measures on 'floor level' standards are suggested which are complementary, essential and compatible with the earlier directives. The present proposal introduces the first measure, based on the 'statistical approach', to take effect within five years. Four years later, and depending on the results of the first measure, a further proposal will if necessary be drawn up using a technical/economic approach (Article 8 of the draft Directive).

2.5. The proposed standards are determined on the basis of a comparison of appliances with comparable performance characteristics. In this way categories are defined within which specific standards are established on the basis of the adjusted volume, which is calculated according to the appliance's volume and performance characteristics.

2.6. Annex II of the draft Directive proposes self-assessment of refrigeration typeconformity, via a choice of modules. In addition, the task of surveillance falls to the Member States.

2.7. The Commission has pointed out that attempts were made to reach agreement with manufacturers in this sector, but as they were unsuccessful the Directive was proposed. It is acknowledged that voluntary agreements are still preferable. It is also recognized that the ideal would be a combination of information, standards and incentives for consumers and manufacturers. The Explanatory Memorandum maps out future lines of action concerning these incentives.

2.8. According to the Commission, it is estimated that implementation of the first level of minimum efficiency standards (assuming annual sales of 14 million refrigerators) will have roughly the following impact:

- a 13% reduction in annual electricity consumption for refrigeration appliances in year 2002

- a 10% reduction in annual CO2 emissions in the same year

- an average increase of about 1% in the price of these appliances, with a 10% reduction in lifetime electricity cost

- a total purchase cost increase of around ECU 140 million per year. Energy savings are estimated at ECU 1,400 million per year.

2.9. In terms of application, Article 9 of the draft Directive provides that before 1 January 1996 the Member States shall adopt the necessary legal provisions and inform the Commission thereof; these provisions to apply from 1 January 2000.

3. General comments

3.1. The standards laid down by the proposal (CEN EN 153 of May 1990) are being adjusted by CEN to bring them more into line with the actual use of refrigerators and freezers by consumers.

3.1.1. The proposal on the energy efficiency of household refrigeration appliances has been put forward because improvements in the energy consumption of these appliances produce relatively substantial savings, although the situation varies from one country to another.

3.1.2. The Committee considers that the best way to achieve positive results is to aim for complete cooperation with manufacturers and consumers.

3.1.3. Commission policy must focus on surveillance of the CE marking as a key task.

3.1.4. Consideration can also be given to extending the scope of Article 6 in such a way that not only the Member States but also manufacturers can provide information on the failure of products on the market to conform to the CE marking.

3.2. Alerting the consumer to the benefits of buying energy-efficient appliances should be encouraged in addition to laying down minimum standards.

3.3. Minimum standards are already applied in the US, Australia and Switzerland, while Japan, Austria and Canada intend to introduce them. Labelling regulations are in force in the US, Canada, Australia and Scandinavia.

3.4. More stringent standards could harm SMEs in particular. Employment could suffer as a result. Reducing the adjustment period could harm industry, but might be considered after consultation.

3.5. Measures should be taken for other household appliances. An implementing Directive has already been adopted for the labelling of washing machines and refrigerators. The Commission is studying the possibilities for other appliances, such as portable air conditioners, dishwashers and water boilers. In this connection it should be pointed out that manufacturers play an active role in reducing the energy consumption of household appliances and of refrigeration appliances in particular. Such an involvement can also help to suppress possible negative side-effects on consumers, such as the temporary disappearance of 'low-cost models' in some product groups; industry could, for instance, try to hold down prices. Moreover, most of the Commission departments are of the view that voluntary agreements with manufacturers are to be preferred.

3.6. The proposal should not affect the competitiveness of European manufacturers. Exports outside the EU, where there is a growing demand for energy-efficient appliances, will increase. The temporary disappearance of low-cost models in some product groups will also lead to the introduction of new low-cost models.

3.7. The proposal takes full account of the subsidiarity and transparency principles. Community policy dictates that technical requirements are to be harmonized throughout the internal market and CO2 emissions reduced effectively.

3.8. The Committee would point out that the price increases for refrigerators and freezers and the reduction in electricity costs could have a different financial impact on different groups of consumers in some Member States.

4. Conclusions

4.1. Industry and consumers must be involved in the implementation of the first level of efficiency standards for household electric refrigerators, freezers and their combinations, as described in the proposal. Industry can be actively involved by carrying out interim surveys of progress on efficiency in the period between the adoption of the proposal and the first official assessment. The Committee notes that industry is prepared to make the findings of its data bank available if necessary.

4.2. The Committee urges the Commission to involve industry and consumers actively in the process of assessing the results and if necessary establishing a second set of efficiency standards as referred to in Article 8 of the proposal.

4.3. The Annexes stipulate when and in what way refrigerators must have a CE marking affixed. It is important that the significance of this mark be communicated clearly to the consumer. Industry and consumers must play a role in this.

4.4. The Committee approves the proposal subject to the foregoing comments.

Done at Brussels, 27 April 1995.

The President

of the Economic and Social Committee

Carlos FERRER

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