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Page 1 of 89  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 13.11.2008 
SEC(2008) 2862 
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
 
Proposal for a  
 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
on the indication by labelling and standard  product information of the consumption of 
energy and other resources by energy-related products 
 
IMPACT ASSESSMENT  
{COM(2008) 778 final} 
{SEC(2008) 2863} 
2 Table of contents 
 
Executive summary.............................................................................................................. ................................. 3  
Section 1: Procedural issues and co nsultation of in terested parties ............................................................ ..... 6 
1.1. Organisation and tim ing ........................................................................................................ .............. 9  
1.2. Consultation an d exper tise..................................................................................................... ............ 10  
1.3. Opinion of the Impact  Assessment Board ......................................................................................... .1 1 
Section 2: Prob lem defi nition.................................................................................................. ........................... 12  
2.1 Market and regulatory failures related to energy label - problems to be addressed ................................. 14  
2.2 Limits of the scop e of the Di rective ....................................................................................... ..................... 17  
2.3 Limits of the functio ning of the Directive ................................................................................. .................. 18  
2.4 Identifying the affected par ties and the impa cts ther ewith................................................................. ........ 19  
2.5 Transposition and compliance ............................................................................................... .................... 20  
2.6 EU right to act: Trea ty base and s ubsidiarity .............................................................................. .............. 20  
Section 3: Objectives.......................................................................................................... ................................. 21  
Section 4: Poli cy options...................................................................................................... ............................... 22  
4.1 Policy option 1: Ba U - business as usual................................................................................... ................ 22  
4.1.1 Policy option 1a: BaU -  no further action............................................................................... ........... 23  
4.1.2 Policy option 1b: “BaU + 1”,  including optimal implementation of the current ELD....................... 23  
4.2 Policy option 2: No n-regulatory  action..................................................................................... ................. 23  
4.3 Policy option 3: Amend (recast) the ELD, including broadened scope to energy-related products .......... 23  
4.4 Policy option 4: Repeal the EL D and implement energy labelling within the Ecodesign Directive .......... 24  
Section 5: Analysis of impacts................................................................................................. ........................... 24  
5.1 Policy option 1: BaU – business as usual ................................................................................... ............... 25  
5.1.1 Policy option 1a: Ba U - no further action................................................................................ ........... 25  
5.1.2 Policy option 1b: “BaU + 1”, including op timal implementation of the current ELD........................ 26  
5.2 Policy option 2: No n-regulatory  action..................................................................................... ................. 29  
5.3 Policy option 3: Amend (recast) th e ELD, including broadened scope with energy-related products ...... 31  
5.3.1 Expected impacts from a broader scope of the ELD ......................................................................... .3 1 
5.3.2 Expected impacts from impr oved functioning of the ELD................................................................. 33  
5.4 Policy option 4: Repeal the EL D and implement energy labelling within the Ecodesign Directive .......... 36  
5.5 Administrative an d transpos ition cost ...................................................................................... .................. 37  
Section 6: Comparing options................................................................................................... ......................... 39  
Section 7: Monitoring and evaluation ........................................................................................... .................... 43  
Annex 1: Product groups covered by th e ELD and the implemen ting Directives......................................... 45  
Annex 2: EU policy instruments addressi ng energy efficiency of products................................................... 46  
Annex 3: Product labels in the EU.............................................................................................. ....................... 47  
Annex 4: Composition of energ y label: labe l and strip.......................................................................... .......... 50  
Annex 5: Content of an information fiche ....................................................................................... ................. 51  
Annex 6: Provision of product in formation in th e energy label.................................................................. .... 53  
Annex 7: Energy labels ad opted in thir d countries.............................................................................. ............ 54  
Annex 8: Energy labels ad opted in other sectors ................................................................................ ............. 55  
Annex 9: Energy consumption in the EU and savings potential of appliances.............................................. 57  
Annex 10: Achievements of energy la belling and proble ms thereof............................................................... 6 1 
Annex 11: Energy efficient public  procurement and incentives ................................................................... .. 67 
Annex 12: Administrative and transposition cost ................................................................................ ............ 79  
Annex 13: Minutes of th e stakehold er workshop .................................................................................. ........... 81  
3 EXECUTIVE SUMMARY  
 
This Impact Assessment accompanies the propo sal for the recast of the 92/75/EEC “Energy 
Labelling Directive for Household Appliances”1 (hereafter ELD). The recast of the ELD is 
one of the elements of the Action Plan on Sustainable Consumption and Production and on 
Sustainable Industrial Policy (SCP/SIP).  
 The ELD, which was adopted in 1992, requires re tailers to display a comparative label 
showing the level of energy consumption of hous ehold appliances to consumers at the point 
of sale. It is estimated that energy labelling has contributed to annual energy savings in the 
order of 3 Mtoe
2 corresponding to emission reductions of some 14 Mt  of Co2 annually over 
the period 1996-2004.  
                                                
 
1 Council  Directive 92/75/EEC of 22 September 1992 on the indication by labelling and standard product 
information of the consumption of energy and other resources by household appliances. 
2 This does not take into account energy savings from related self commi tments by Ceced (white goods) and 
Eicta (TVs)  
 The energy label is compulsory for those 
products covered by implementing measures under the framework ELD. The energy labelling scheme has been successful in contributing to pull the market of household appliances towards more energy efficien t products. It provides 
useful and comparable information to consumers, allowing them to consider investing in better performing appliances in order to realize savings in taking into account the running costs (mainly energy consumption in use). 
 
It also helps manufacturers to position their products on the market and get some payback on their investments for introducing better and more innovative 
appliances. The scheme is therefore considered as a win-win instrument for consumers, industry and the environment.   As announced in the Action Plan on Sustainable Consumption and Production and on Sustainable Industrial Policy (SCP/SIP), the ELD together with the Ecodesign Directive could deliver more savings in energy and reduction of 
environmental impacts, if extended to all energy- related product groups (p roducts that have an 
impact on energy consumption during use).  
 
4 The current ELD is a framework that mandates the Commission (assisted by a Regulatory 
Committee) to adopt labelling implementing measures for specific household appliances3. For 
these, an upgrade of the existing labels is  being prepared for adoption in 2009 and 2010. 
The impact assessment of the SCP/SIP has show n that the limited scope of the ELD restricts 
its potential to further mitigate climate change and contribute to the EU-wide target of 20% 
energy efficiency gains by 2020 and achieve the goals of sustainable production and 
consumption. This impact assessment report ther efore analyses further whether the scope and 
functioning of the ELD can be reinforced, how this can be done and what impacts it could 
have. However, as the ELD is a framework Di rective with no direct impact on products, the 
environmental, economic and social impacts can only be quantified in detail for those 
implementing measures to be adopted on sp ecific products. Accordingly, the potential 
advantages and disadvantages of  the possible revision are consid ered in the light of a number 
of selected priority produc t groups with significant enviro nmental impacts and for which 
labelling appears to be a relevant policy instrument. 
For the functioning of the ELD, th e aim is to seek increased e ffectiveness of the ELD and its 
implementing measures while reducing the admini strative burden, and ex plore the use of ELD 
as a framework for harmonised public procuremen t and incentives in the Internal Market. 
Four policy options are considered as follows: 
 
1)  No policy change, with two sub-options: 
1a)  BaU - business as usual,  1b)  BaU + 1 - full implementation of the current ELD scope. 
(2) Non-regulatory action. (3) Amend the Directive - full implementation of the current ELD scope, plus 
coverage of all energy-related produc ts, excluding means of transport. 
(4) Repeal the Directive and implement its provisions within th e Ecodesign Directive - 
full implementation of the current ELD scope, plus coverage of all energy-related products, excluding means of transport.   
 It is estimated that the policy option 1b (fully  implement the current framework) could lead 
to, based on the considered priority app liances, savings of so me 22 Mtoe by 2020, 
corresponding to emission savings of about 65 Mt of CO2. More than half of these savings 
would come from the heating and water heatin g appliances alone, which have not yet been 
addressed under the ELD. The rest of the sa vings would come from  the upgrading of the 
existing eight measures, and from a new measure on televisions.   Policy option 2 (voluntary agr eements/self commitments) woul d have advantages in adding 
little administrative burden to the business and administrations, depending on the way of 
implementing the non-regulatory action, but w ould fully rely on the feasibility and 
willingness from industry, which ha s rejected this option (CECED
4 and EICTA5). The 
capacity of this policy option to contribute to further energy savings was considered marginal 
at best.  Policy option 3 (fully e xploit current framework and extend  the scope to all energy-related 
products) involves some administrative burden for the recast but would save some €4 million 
                                                
 
3 Refrigerators, freezers and their combinations, washing machines, driers and their combinations, dishwashers, 
ovens, water heaters and hot-water storage applianc es, lighting sources and air-conditioning appliances. 
4 European Committee of Manufacturers of Domestic Equipment 
5 European Information & Communications Technology Industry Association 
 
5 in transposition costs for every upgraded or newly developed implementing measure if 
implementing Directives were replaced by impl ementing Regulations. It is estimated that 
broadening the scope of the ELD  to energy-related products coul d lead to additional savings 
of some 27 Mtoe by 20206, corresponding to emi ssion reduction of close to 80 Mt of CO2 in 
comparison to BaU. This represents additiona l savings of some 5 Mt oe against the policy 
option BaU +1 alone from the three priority product groups considered (commercial heating 
and refrigeration and windows) . More precise knowledge on th e savings potential of these 
products will be available from the Ecodesi gn preparatory studies followed by product 
specific impact assessments. Additional chan ges like introducing provisions on the legal 
protection of the use of the label, clarifying information requirements and introducing a 
framework for public procurement and incentives would further reinforce the effectiveness of 
the scheme as well as increase the savings.  
Policy option 4, repeal the ELD and implemen t energy labelling wi thin the Ecodesign 
Directive, could lead in theo ry to the same level of savi ngs as policy option 3 and would 
reduce the number of regulatory instruments, but could hardly be considered as simplification. 
This is due to the different nature of the le gal instruments: the Ecode sign Directive bans the 
less performing products regarding their globa l environmental performance focusing on all 
environmental aspects throughout the lifecycle of the product. The ELD provides an energy 
label showing to consumers the energy efficien cy performance of th e product during the use 
phase (and relevant use of other reso urces (like water) where relevant).  
The analysis and comparison of the policy options indicates that  the options 1b and 3 are the 
most cost-efficient and suitable options with strongest stakeholder support to achieve the 
policy objectives. 
Monitoring and evaluation is proposed in th e framework of Action Plan on Sustainable 
Consumption and Production and Sustainabl e Industrial Policy in  coordination with 
Ecodesign, Ecolabel and othe r related instruments. 
                                                
 
6 The figure is composed of the estimated 22 Mtoe savings by 2020 from the full implementation of the ELD and 
of some 5 Mtoe additional savings from the broadening on the scope, based on considerations on three priority 
product groups (windows, commercial refrigeration and heating appliances).  
 
6  
SECTION 1: PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
 
The Energy Labelling Directive - ELD 
This Impact Assessment accompanies the pr oposal for the amendment of the Energy 
Labelling Directive for household appliances. This framework directive provides harmonised 
EU-wide rules for energy labelling of household appliances as described in the Article 1 of 
the Directive.   The purpose of the ELD is two-fold. It informs potential purchasers of the energy (and other 
resources such as water) consumption of the various appliances on offer, so consumers can 
take account of this and of the resultant r unning costs before maki ng purchase decisions. The 
Directive also incites manuf acturers to produce more energy efficient appliances. This 
mechanism requires some basic criteria to be fulfilled in order to be effective and efficient. The main basic criteria are as follows
7:  
   
• The scheme must be uniform. If there are a variety of differing de signs of labels, for 
the same type of appliance in particular, consumers may be confused when comparing 
rival appliances and may ignor e the information altogether. 
• The scheme must be comprehensive; all appl iances of a given type must be labelled 
otherwise labelled products may be put at a disadvantage. 
• The label and the fiche8 must be as clear and as simple as possible, while conveying as 
much relevant information as possible fr om the point of view of the customer. 
• The scheme should be credible with information that can be trusted. 
• The scheme should be flexible and dynamic.  In particular it should allow for updating 
in the light of market developments a nd in particular improved efficiency of 
appliances.  
• The scheme should be as simple to run as  possible and lead to  the minimum possible 
cost for those involved (manufacturer s, retailers, Member States). 
• Finally, the scheme should be harmonized at the level of the Internal Market to avoid 
any barriers to trade between Member States in respect to  energy labelling and product 
information. 
 These criteria are very important in assu ring that information asymmetries and bounded 
rationality are avoided.  The scheme must allow end-users to easily compare which product is 
more resource efficient during its  use phase than anot her, thus avoiding buying products that 
are cheaper at the purchase but more expe nsive over their life cycle. Providing enough 
information is not enough; the label must provi de information that can easily be understood 
even with a quick look and it must focus on issues of most intere st for buyers. Complex 
information can be provided in product documentation for more demanding consumers.    As mentioned in the explanatory memorandum to  the ELD, various surveys and the existing 
Ecodesign studies
9 have shown that the energy consump tion of domestic appliances varies 
                                                 
7 Explanatory memorandum for the proposal for a Council Directive on the indication by labelling and standard 
product information of the consumption of energy and other resources of household appliances, 20 March 1991. 
8 'Product information fiche' is an information fiche containing relevant product information such as energy 
consumption, consumption of filters in average use, ve ntilation and air flow performance, etc in the case of a 
cooker hood (see Annex 6). The 'label', which is displayed on products in shops, is composed of a background 
label with basic energy information and a strip that includes the values for this information (e.g. in the case of cooker hoods, logo and model of the hood, the 'A' class,  values for filter efficiency etc). See illustrations in 
Annexes 3, 4 and 6. 
9 http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm 
 
7 widely for similar functionalities, and that a mo re efficient appliance is not necessarily more 
expensive to purchase. Thus, if potential purchas ers were better informed, they would tend to 
buy appliances which – for a given performance - we re more energy efficient, cost less to run, 
and have a better environmental footprint.  This would, through the normal competitive 
process, put considerable pressure on manufacturer s to increase their efforts to produce more 
efficient appliances, which has happened in  the case of those appliances on which 
implementing measures have been in force for some time10. However, at present customers do 
receive this information only on some produc ts covered by (eight) existing implementing 
Directives. As a result, for most products on the market, purchasers cannot easily identify the 
better performing ones and the market fails to encourage the manufacturers of producing such 
appliances.   Considering that the energy label can contribut e to making the "right" purchasing decision but 
is not the only element guiding consumer decisi on to buy a particular product, it is difficult to 
assess the impact of a labelling information sc heme on the energy efficiency of appliances. 
The background study estimates that the ELD woul d have helped to reach savings of some 3 
Mtoe per year by 2020, corresponding to annual emission reduction of some 14 Mt of CO2 
(for further details, see Annex 10).  The Article 1 of the ELD covers a selected nu mber of household app liances, as shown in 
Annex 1. The Article 1 also allows the Commi ssion, assisted by a Committee, to add further 
household appliances to this list. However, Ar t. 1 does not allow the extension of scope to 
non-household appliances. This excludes numerous  products for which a labelling scheme 
could be appropriate, such as energy-using prod ucts for commercial and industrial sectors, as 
well as energy-related products which do not consume energy but allow for energy 
conservation (e.g. window glazing and frames). 
 An important aspect of the functioning of an  energy labelling scheme is the synergy, 
complementarities and possible overlap with othe r EU labelling instruments on products. The 
Annex 2 illustrates the complementarities a nd synergies between Ecodesign, Ecolabel and 
Energy Labelling. While Ecodesign cuts the le ss efficient products fr om the market, the 
voluntary Ecolabel grants a 'best in class' label for the upper end products (corresponding 
normally to an 'A' class in the energy labelli ng classification). Energy labelling complements 
the picture in providing compulsory compara tive information on energy performance between 
these two extremes. It also pushes manufacturers to  invest on more efficient products in order 
to shorten the path from R&D to products mature for markets.    Annex 2 describes the coverage of various labell ing instruments, in particular in between the 
energy-using and non-energy usin g products. The revision of the Ecodesign Directive is 
heading towards the coverage of more produ cts. Both the Ecodesign Directive and the 
Ecolabel address the significant environmental aspects over the life cycle of a product while 
energy labelling focuses on 80-90% of the en vironmental impacts of energy-using products, 
that is, energy consumption and consumption of consumables in the use phase. Together these 
instruments contribute to policy co herence in the wider picture of sustainable energy policies.   
      
                                                
 
10 See Annex 10. 
 
8 Procedural steps for adopting Energy Labelling implementing Directives 
Before the Commission prepares an implemen ting directive it conducts a technical economic 
study which looks into the range  of performances available among products on the market 
offering similar functionalities, the potential for improvement and the related costs. This 
phase is fully coordinated with the Ecodesign process in which the sa me preparatory study 
provides the necessary techni cal analysis for both minimu m efficiency performance 
requirements under the Ecodesign Directive and for a possible labelling scheme under the 
ELD (where the display of a label showing the efficiency performance of the product in 
question can influence the purchase decision and thereby pull the market towards more 
efficient products). Extensive stakeholder cons ultation takes place during preparatory studies 
in form of bilateral meetings with directly affect ed stakeholders, complemented with public 
stakeholder consultation through the Internet  and a dedicated stakeholder workshop.  
 After impact assessment and interservice cons ultation, the Commission gathers the opinion of 
the ELD Committee operating under the re gulatory procedure with scrutiny
11 by the European 
Parliament, and the Commission adopts the Im plementing Directive following the normal 
procedures. Once adopted by the Commission and after publication in th e Official Journal, 
Member States must transpose the implementing Directive into national legislation, which the 
Commission must monitor and ta ke appropriate action in the case of late or non-compliant 
transposition by the Member States.   Like under the Ecodesign Directive, the Co mmission is involved in  formal regulatory 
dialogue with its main trading partners and with  international organisatio ns on issues such as 
the harmonization of measurement methods/standards, benchmarking and other elements directly linked to the setting of Implementing Directives. The development of measures is 
also discussed with relevant ministries from third countrie s in the frame of regulatory 
cooperation. Manufacturers from outside the EU are encouraged  to actively provide input 
from the very beginning of the process, when pr eparatory studies are carried out, and can fully 
participate in the consultation process.     
The current impact assessment 
The Action Plan on Sustainable Consumption and Production and on Sustainable Industrial 
Policy (SCP/SIP) is a joint initiative of DG ENTR, ENV a nd TREN proposing actions to 
address market and regulatory failures which a ffect the environmental performance of a large 
number of products in Europe. The main elemen t of the SCP/SIP is an  integrated product 
policy of which the ELD is one building block.   The revised Ecodesign Directive is  to be extended to cover a ll energy-related products. This 
impact assessment will consider similar extens ion to the ELD. By the Ecodesign Directive, 
minimum requirements will be set for product s with significant environmental impacts, 
focusing on key environmental aspects. To provide markets with information on best 
performing products, advanced benchmarks of environmental performance will be identified. 
Periodic reviews of minimum requi rements and advanced benchmarks will take place to adapt 
them to technological change and provide busine sses with a long-term perspective of future 
regulatory environment. Apart from considerin g the extension of the ELD to energy-related 
products, this impact assessment also consider s how the energy efficien cy criteria under the 
ELD could be used to establish a harmonise d base for public procurement and incentives  
provided by the EU and its Member States. This  would overcome the current fragmentation of 
stimuli and incentives in the Internal Market
12.  
                                                 
 
12 On the interaction between Ecodesign, Ec olabel and Energy Labelling, see Annex 2. 
 
9  
This impact assessment is one layer in the anal ytical framework of three levels of impact 
assessments related to product policy. The impact  assessment of the Action Plan focused on 
delimiting the problem definition and the remain ing problems. In the Impact Assessment of 
the Action Plan it was stated that the Ac tion Plan would only look at existing policy 
instruments and how to coordinate them better.  The main conclusion of the impact assessment 
of the Action Plan was that a mandatory approach could solve the identified market failures. Moreover, the impact assessment of the acti on plan concluded that  a specific impact 
assessment was needed to look at the extension of the scope of the ELD. 
  This impact assessment focuses on the identifica tion of the need for and the most adequate 
extension of the scope of the ELD. Further im pact assessments will identify the particular 
problems and analyse the environmental, economic and social impacts when preparing implementing measures for the setting of labellin g requirements on specific products.  
 This impact assessment does not look at nationa l or regional impacts, as energy labelling does 
not have impact on affordability (in contrary  to e.g. minimum requirements set within the 
Ecodesign Directive). Energy labe lling provides comparative information on products offered 
on the market guiding the consumer towards the most economic choices over the life time of 
the product; energy label does not cut off prod ucts with cheaper purchase prices from the 
market. The exception of setting of minimum requirements for public procurement and/or 
incentives by Member States will be looked at in  Annex 11 and in relevant chapters, such as 
5.4.2.  This document is prepared as a basis for comme nts and does not prejudge the final form of 
any decision to be taken by the Commission. Mo reover, all product categories mentioned in 
this document are included for analytical purposes only and do not prejudge any decision on 
the setting of labelling requirements on any products. Figures and numbers quoted in this 
Impact Assessment are of an indicative nature.   
1.1. Organisation and timing  
The recast (amendment) of the En ergy Labelling Directive 92/75/EEC
13 is included in the 
Commission's rolling simp lification programme Better Regulation: Simplification Strategy14. 
This is based on the Commission Legislative and Work Programme 2008 (CLWP) and on the 
Energy Efficiency Action Plan15 calling for a p ossible recast of the ELD. It was confirmed in the 
recent SCP/SIP Action Plan. 
 
Commission's minimum standards for stakeholde r consultation were respected, as described 
in chapters 1.1 and 1.2. For the purpose of the impact assessment an inter-service steering 
group (ISSG) was created with invitations to ENV, SANCO,  SG, ECFIN, ENTR, MARKT, 
LS, INFSO, COMP, and TRADE.  The start-up ISSG meeting took place on 9 November 2007 
with effective participation of ENV, SANC O, SJ, ENTR, and ECFI N. The first meeting 
discussed and agreed on the process and on wh at should be the content of the impact 
assessment study and the Commi ssion Staff Working Document (CSWD) for consultation of 
stakeholders. Three subsequent ISSG consultati ons took place before submitting the IA report 
to the IAB (Consultation on the draft stak eholder consultation document on 7 December 
                                                 
13 Council Directive 92/75/EEC of 22 September 1992 on the indication by labelling and standard product 
information of the consumption of energy and other resources by household appliances. 
14 COM (2005) 535 final of 25.10.2005. 
15 COM (2006) 545 final of 19.10.2006. 
 
10 2007, first consultation on the draf t IA report on 11 March 2008 and a second consultation on 
the draft IA report on 24 April 2008).   
 On 20 December 2007, the CSWD and the background study were published on the 
Commission's impact assessment website and on relevant EUROPA websites, such as 
http://ec.europa.eu/energy/demand/legi slation/domestic_en.htm#consultation
 for a public 
Internet consultation. The fi nal deadline for comments wa s 22 February 2008. Additionally, a 
stakeholder consultation workshop took place on 8 February 2008. Summaries of the Internet 
consultation and of the stakeholder meeti ng were published on the above web sites. 
 
1.2. Consultation and expertise  
DG TREN launched an external study (30.07.2 007 – 19.10.2007) in support to the IA with 
Europe Economics, Fraunhofer-ISI with BSR Sust ainability and FfE. The study reviewed the 
achievements of energy labelling under the pres ent ELD and looked at areas of improvement 
by carrying out technical analyses on selected energy-using (boilers an d electric motors) and 
non-energy using but energy-relate d products (windows and tyres)  in order to identify the 
potential for further energy efficiency gains, in cluding interviews of stak eholders and of seven 
Member States representatives. The study also in cluded a literature review. Finally, the study 
reviewed and summarised the options for possibl e future action. The main findings from the 
stakeholder interviews can be summarised as follows: 
 Highest importance was given to:  
• broadening the scope of the directive to additional household produc ts, such as boilers 
or TVs, and to non-household appliances, such  as motors (above 90% of stakeholders 
considered this very important or important
16): 
• upgrading the requirements of the existing implementing Di rectives (above 90%):  
• use Regulations as implementing tools in stead of Directives (close to 80%). 
 
Medium level importance was given to: 
• stricter enforcement of the requirements of the implementing measures (above 60% 
considered high or medium priority). 
• provision of additional inform ation in the label useful to consumers (about 50%)  
• including additional product information into  the label, e.g. annual cost of energy 
consumption or annual CO 2 emissions (about 50%); 
• legal protection of the label (about 50%). 
  Stakeholder consultation workshop on 8 Febr uary 2008  was attended by all relevant 
stakeholders, including members of the ELD Regulatory Committee and European associations representing the i ndustry, retailers, consumers and environmental NGOs (for the 
CSWD, minutes of the workshop and summar y results of the c onsultation, see the 
Commission ELD website: http://ec.europa.eu/energy/demand/legi slation/domestic_en.htm#consultation
). 
 Consultation in form of a workshop turned to be very valuable, as it allowed an open 
discussion on the pros and cons related to different stakeholde rs groups, in particular to 
consumers, retailers, manufactur ers and administrations. The meeting discussion helped 
stakeholders to better understand each othe rs concerns. Consequent ly, the results of the 
                                                
 
16 Options were considered in three 'classes': high, medium or low priority. 
 
11 consultation were refined and more comprehe nsive compared with the results of the 
background study, although the basic tre nd of the replies was the same.  
 The minutes of the stakeholder consultation workshop, summary results of the web-based 
consultation and stakeholder comments were published on EUROPA. In total, 66 written stakeholder comments were received on the In ternet consultation covering Member States, 
European Associations and groupings, indivi dual industry, national governments and other 
groupings. It is worth mentioni ng that the conclusions listed  hereafter are supported by all
 
stakeholders consulted.  The main results of this stakeholder consultation were that:    
• the scope of the labelling should be broa dened beyond household appliances to all 
energy-using appliances; 
• the scope of the labelling should not be  broadened to non-energy using products, 
except those which are 'energy relevant', th at is, which allow energy conservation (e.g. 
window glazing and frames); 
• the label should remain simple, relate to th e consumption of energy in use  and not be 
mixed with other environmental parameters  during the life-cycle of a product, while 
keeping the possibility to incl ude also additional informati on relevant to consumers on 
the products' performance); 
• implementation through Regulations rather than  Directives was considered to be more 
efficient; 
• tighter tolerances in test st andards and reinforced market surveillance were requested; 
• reinforce provision of energy labels in th e context of other type of sales and 
advertising, such as websites, news papers, TV ads and other media; 
• legal protection of the label against abusive voluntary use was seen beneficial, if it 
would not lead to royalty costs. 
 
The above stakeholder input from the bac kground study, stakeholder consultation meeting 
and the stakeholder comments received through th e web were integrated into this report as 
described in the sections below.    The joint internet stakeholde r consultation on Sustainable C onsumption and Production (SCP) 
and on Sustainable Industrial Policy (Sustainable Industrial Policy launched in 2007 by ENV 
and ENTR is also relevant for this IA. In particular stakehol ders highlighted  the role of 
relevant Community legislation to reinforce the potential of public incentives and public procurement for the deployment of energy efficient and green products: 
 
• 34% of stakeholders found public pr ocurement and incentives important; 
• 29% found fiscal incentives, subsid ies and trading schemes important; 
• 82% found it was important that public pr ocurement concentrate on green products, 
even if they were more expensive; 
• 60% felt green procurement should be mandatory. 
 
1.3. Opinion of the Impact Assessment Board  
This impact assessment report takes into ac count the opinions of the Impact Assessment 
Board dated 4 June and 25 July 2008 as follows:  
• Problem analysis has been further elaborat ed and presented in the context of the 
introduction of the SCP/SIP and the revi sion of the Ecodesign Directive. More 
 
12 explanation has been provided on why the pot ential of the current ELD has not been 
fully exploited in the past. Market failure  in the field of public procurement and 
incentives has been identified and the potenti al of the Energy Labelling Directive to 
tackle this failure have been addressed. 
• Objectives have been revised in relation to the reworked problem analysis and specific 
objectives are related directly to the problems identified. 
• The range of policy options have been wi dened in broadening the BaU to two sub-
options in order to more widely consider different options, includi ng the use of latest 
EC Baseline scenario figures.  
• The analysis of the impacts focuses on how the options can solve the identified market 
and regulatory failures and the options are compared based on effectiveness, 
efficiency and consistency. 
• Structure and content of the report have been aligned with the impact assessments on 
the Communication of SCP/SIP and the Ecodesign Directive. 
 Upon the second opinion,  
• The problem definition was further clarifie d and policy objectives were complemented 
with operational objectives, including an expl anation on the role of the Framework 
Directive and its implementing measures in relation to the specific objectives. 
• Explanation on the coherence of the objectiv es with the SIP/SCP was fine-tuned and 
reasoning on the option of rep ealing the Directive was reinfo rced in the context of the 
past achievements. 
• Ecodesign Directive as an alternative implementing mechanism and the assessment of 
the impacts were further dealt with in releva nt chapters and the be nefits of considering 
the two BaU sub-options were spelt out. 
• Monitoring and evaluation was refined with not ions on timelines and further details on 
particular stakeholder positions were added, including crosschecking the presentation 
of the document.     
 
S
ECTION 2: PROBLEM DEFINITION  
As discussed in the impact assessment of the SCP/SIP Action Plan and restated in the IA on 
the amendment of Directive 2005/32/EC, pr oducts can have negative impacts on the 
environment depending on how they are made, used and disposed. The SCP/SIP impact 
assessment identified several market failures and imperfections, which prevent society from 
reaching the social optimum17. The most important market failures were summarised in the IA 
on 2005/32/EC as: 
• Environmental externalities that result from prices not reflecting the negative 
environmental impacts of the production or c onsumption of products leads consumers to 
choices that do not necessarily act in the interest of the society. 
• Information asymmetries that result from hi gh transaction costs for consumers to obtain 
relevant information on product characteristic s. Consumers can ofte n not tell whether a 
product is more resource effici ent during its use phase than another one, thus consumers 
are buying products that are cheape r at the purchase but more expensive over the life cycle. 
• Bounded rationality explaining why even well -informed consumers do not act rationally 
when making purchasing decisions. Even if co nsumers have sufficient information, they 
can be faced with high upfront costs when  buying a more performing product, while the 
                                                 
17 Impact Assessment of the SCP/SIP Action Plan, EC (2008) forthcoming. 
 
13 benefits accrue over a longer period of time (i.e. during it s use-phase). Consumers may not 
take into account the use cost of a product but focus short-sightedly  on the purchase price 
only.  
• Principal-agent problems that occur where ther e is a misalignment of incentives of those 
purchasing the product (e.g. landlord or industria l plant) and those using it (e.g. tenant or 
provider to an industrial plant). 
The above market failures have negative e ffects on development of better performing 
products since they limit the demand for produ cts with lower environmental impacts. The 
market failures result in  products that are not designed such that environmental impacts of 
products over their life cycle are optimal. Th e Ecodesign preparatory studies show that 
typically more than 90% of the life cycle en vironmental impacts take place during the use 
phase18.  
 
Globally, combating information asymmetries through energy efficiency measures seems 
possible at a negative cost. The 2006 status report on energy consumption and efficiency 
trends prepared for the Commission commented that:  “Most of the energy efficiency measures are cost-e ffective. This means that they will result in 
net money savings for end-users, as the reduc ed electricity cost over the life time of the 
appliances will outweigh the additional purchasing cost for a more efficient model. In many cases there is an increase in manufacturing cost  to manufacturers, whic h can be passed on to 
the users or can be compensate d by productivity gains (and in many cases will decrease over 
time when the most efficient components will be mass produced). Over the last ten years, the 
EU white goods appliances co st less and the efficiency ha s improved, while keeping the 
industry sector healthy (though with limited marg in) and despite fears by manufacturers that 
the policy action introduced in the 90ies could have had a negative imp act. Instead the "white 
goods" industry sector acknowledges the added value of the label as a means to differentiate 
products on the market. Overall it can be conc luded that energy efficiency measures and in 
particular minimum requirements and labels are cost effective for society and reduce CO2 
emissions at a negative cost.”
19  
 The uptake of energy efficient pr oducts requires consumer and us er awareness as well as the 
provision of clear and easily understandable info rmation from manufacturers and retailers.  
Such information is unlikely to be provided in the form and on the scale required without 
some degree of government inte rvention, although this  information is normally provided by 
manufacturers in their product documentation and catalogues in any case. An important 
question is on how to best packag e and provide this information to  be useful, reliable, credible 
and easy-to-understand for consumers.  Energy consumption in use is not the only en vironmental impact of products. However an 
EIPRO study
20 on environmental impact of products identified that energy consumption in 
use is the single most important factor for energy-using products. Broadening the focus from 
energy and resource efficiency in use phase to all significant environmental impacts over the 
life cycle of the product would risk increasing information asymmetries in providing more 
                                                 
18 http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm   
19 Electricity Consumption and Efficiency Trends in the Enlarged European Union - Status report 2006, Bertoldi 
and Atanasiu, 2007. 
20 Environmental impact of products (EIPRO); analysis of the life-cycle environmental impacts related to the 
final consumption of the EU-25. Summary of the final report by DG Environment and DG Joint Research 
Centre, May 2006. 
 
14 information on complex environmental impacts ove r the life cycle of th e product. Given that 
the present focus of the ELD on energy and reso urce already tackles typically more than 90% 
of the environmental impacts of energy-using products, broade ning of the focus at the 
expense of the clarity of information is consider ed inappropriate. When consulted specifically 
on this issue, all st akeholders, including consumer asso ciations and environmental NGOs, 
were in favour of, at least for the coming year s, a focus on the consumption of resources in 
use, thereby guiding consumers on the cost of running an appliance. 
Experience shows that customer purchase decisi on can be influenced with clear and easy-to-
understand information, if it focuses on consumer s' primary interest, the cost of the product. 
While the purchase price of a product is a trivial way to compare costs between products, 
adding life cycle considerations or externalities into the picture tends to confuse consumers. 
The way to convey information under the ELD has been to provide it in a comparative way 
showing not only the best but also the worst a ppliances in terms of operating cost. It is 
important to keep this simplicity of the messa ge in order to avoid providing too complex 
information for consumers. For example, in a recent survey21, 71% of the retail consumers 
interviewed confirmed that they would be willi ng to use energy-efficient appliances in order 
to stop climate change against only 12%, who would be willing to purchase carbon offsets/credits. The results are similar in third countries such as India, China or Brazil. This may illustrate a main reason why the EU energy label has been copied more or less identically by so many third countries rather than been broadened to include all environmental impacts 
over the whole life cycle of the product. Si milarly, out of global retail consumers only 21% 
expressed willingness to pay for products with  environmental and social benefits.   
 
2.1 Market and regulatory failures related to energy label - problems to be addressed  
The market failures discussed under chapter on 'Problem definition' apply also on energy 
labelling. A range of policies is in place to improve the energy and environmental 
performance of products
22. These are for example the Ecodesign (EuP) Directive23 which 
establishes a framework for setting Ecodesign requirements for energy-using products while 
ensuring free movements of products within the Internal Market, taking a life-cycle perspective. A number of other legislations address specific aspects of the life-cycle of 
products, such as in particular  waste or hazardous substances  while the Energy Performance 
of Buildings Directive
24 addresses the system efficiency  in buildings through installation 
requirements.   The labelling schemes set by the ELD
25, the Energy Star Regulation26, the Ecolabel 
Regulation27 and other schemes developed by Member  States, retailers and other economic 
operators provide consumers with information on the energy and environmental performance 
                                                 
21 Addressing consumer concerns about climate change, Sheila M. J. Bonini, Greg Hintz and Lenny T. 
Mendonca, McKinsey Quartely, March 2008. 
22 As identified e.g. in the impact assessments of the Action Plan SCP/SIP and Ecodesign Directive, and the 
subsequent Action Plan on SCP/SIP.  
23 Directive 2005/32/EC of the European Parliament and of the Council establishing a framework for the setting 
of Ecodesign requirements for energy-using products, OJ L 101, 22.7.2005, p.29-58. 
24 Directive 2002/91/ECof the European Parliament and of the Counc il of 16 December 20 02 on the energy 
performance of buildings.  
25 Council Directive 92/75/EEC of 22 September 1992 on the indication by labelling and standard product 
information of the consumption of energy and other resources by household appliances, OJ L 297, 13.10.1992, 
p.16-19. 
26 Regulation (EC) 106/2008 of the European Parliament and of the Council of  15 January 2008 on a 
Community energy efficiency labelling programme for office equipment, OJ L 39, of 13.02.2008, p. 1–7. 
27 Regulation (EC) No 1980/2000 of the European Parliament and of the Council of 17 July 2000 on a revised 
Community eco-label award scheme, OJ L 237, 20.9.2000, p. 1-8.  
 
15 of products. Incentives and public procurement are being implemented by Member States to 
stimulate the better performance of products. The Energy Star Regula tion also obliges EU 
institutions and Member State authorities to purchase office equipment which meet minimum 
levels of energy efficiency. 
 
Most product legislation addresse s specific aspects of a product’s life-cycle and not all the life 
cycle aspects. While the Ecodesign Directive and the Eco-label take a life-cycle perspective, 
in the case of energy-using produ cts, studies show that typica lly more than 90% of the life 
cycle environmental impacts ta ke place during the use phase28.  
 Information to consumers under EU policy focuse s on energy and consumables efficiency of 
household appliances in the use phase under th e ELD and of energy efficiency of office 
equipment under the Energy Star Programme. The Ec o-label covers all life  cycle phases but in 
practice only a limited number of products are re gistered under the scheme. Finally, actions at 
national level (Nordic Swann, Blue  Angel…) are not coordinated.  
 
Regulatory instruments are not sufficiently connected and potential synergies between 
different instruments are not sufficiently expl oited. Implementation could be more dynamic 
and forward-looking to drive th e performance of products upwards. Divergent national and 
regional approaches send conflicting signals to producers, and as a result the full potential of 
the Internal Market is not realised.   The potential of the ELD has not been fully expl oited mainly due to shortage of staff in the 
Commission and allocation of reso urces to other priorities, whic h has led, among others, to no 
implementing measures on boilers and water heaters.  On water heaters, there were no 
consistent measurement standards between differe nt types of water heat ers in the past. This 
meant that it would have been impossible to  produce clear simple information to guide 
customers. In order to remedy the situation, the Commission issued a Mandate for standardisation (M204) in 1996. However, the ma ndate was rejected by CEN as regards gas 
water heaters, and progress by Cenelec in deve loping the necessary standards for electric 
water heaters was very slow.  Finally, in 2000, a self commitment was made by manufacturers 
of electric storage water heaters to reduce standing losses. In 2003, a renewed mandate 
(M324) was issued. Based on the mandate, CEN ha s produced an EN standard, while Cenelec 
is still at the stage of a prEN. These standard s will now be used in order to develop Ecodesign 
and energy labelling implementing measur e on water heaters unde r the current ELD. 
 On boilers, a harmonized minimum efficiency st andard was adopted for (household size) gas 
and oil boilers in 1992 (Directive 92/42/EC). As the standard contained a star rating system 
(based on energy efficiency), boilers were not in cluded in the initial list of products to be 
energy labelled.  Experience showed that the star  rating system was not effective. In view of 
this, the relevant parts of Directive 92/42/ EC were repealed by Directive 2005/32/EC 
(Ecodesign) and an energy label for boilers is  now being developed in parallel with the 
Ecodesign requirements. The Commission consu lted the Ecodesign Consultation Forum with 
its Working Document on boilers  and water heaters on 29 Febr uary 2008 in order to propose 
Ecodesign and energy labelling implementing measures/Directives on water heaters and 
boilers later this year.   Also, the possibility of labelling further ligh ting sources or adding ne w household appliances 
(e.g. televisions) into the scope of  the Directive (Article 1.2 of  the Directive) has not been 
exploited. Concerning televisions , a self-commitment by industry  (EICTA) was initiated in 
                                                
 
28 http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm   
 
16 2004. It delivered good results on reducing stand-by losses of TVs but failed in trying to 
introduce a voluntary label (mainly because retailers generally were  pealing of the label from 
TV frames displayed in shops and show room s). EICTA decided to stop the self-commitment 
in 2007.  As to the in/efficiency of the existing implementing Directives, the Annex 10 shows, on the one hand, how efficiently the market has been tr ansformed (almost all labelled appliances are 
A or A+), and on the other hand, how inefficien t the implementing Directives have become, 
as efficiency of the appliances is not anymor e clearly distinguished wh en distributed to two 
levels of A classes only.   The new policy approach of the Action Plan aims at integrating the potential of the different 
policy instruments, implementing them in a dynamic way. It comprises suggestions for 
actions as follows:  
• The scope of the Ecodesign Directive will be extended. Minimum requirements will be set 
for products with significant environmen tal impacts, focusing on key environmental 
aspects from a life-cycle perspective. A revised impact assessment is available since 6/5/2008. 
• Product labelling under the ELD and Ecolabel Regulation will be further developed to 
provide consumers with information about th e energy and/or envir onmental performance 
of products. A proposal for a revised Ecolabe lling scheme was presented as part of the 
SCP/SIP package. The present IA analyses further ho w to reinforce effectiveness of 
product labelling and in particular the ELD to achieve the objectives of the SCP/SIP . 
• The energy efficiency and environmental crite ria under the above schemes will be used to 
establish a harmonised base for public procur ement and incentives pr ovided by the EU and 
its Member States. This would help to ove rcome the current situ ation of inadequate 
information with fragmentation of stimulus and incentives in the Internal Market, as 
described in Annex 11. 
• A range of other actions to arrive at smarter consumption will also be undertaken. In 
particular, action will be implemented with retailers and producers of products to green 
their own activities and supply chains, as well as raising the awaren ess of consumers at 
large and increasing their proactive role. 
 
The impact assessment on the Ecodesign Directive identifies an external cost due to current 
market failures ranging from €74 – €298 billion in  the EU-27. Out of this total cost, energy-
using products account for some 1/3 (€25-100) of which typically more than 90% of the life 
cycle environmental impacts take place during the use phase. ELD and Ecodesing will help reducing this cost.   Market failures to public procurement decisi ons are mainly information asymmetries and 
bounded rationality
29. Lack of information about the long term financial benefits is a main 
barrier to the uptake of resource efficient products. However, even when the relevant 
information and necessary credit is easily availa ble, procurers may still not decide rationally 
but act in a myopic (i.e. short- sighted) way buying the low pri ce – high lifetime cost product. 
The cause for this lies in the difficulty to pro cess complex information in a purchase situation 
and to draw from it the correct (rational) c onclusions. This puts emphasis on the level of 
                                                 
29 Impact Assessment on SCP/SIP.  
 
17 simplicity to understand the information and to  realise its value in relation to purchaser 
preferences in comparison w ith other similar product. 
 Although the assessment of the usefulness and impact  of various types of incentives is a task 
for Member States and not for this impact assess ment, energy labelling can be considered as a 
European-wide framework within which the nati onal authorities can develop such schemes. 
Experience and research
30 shows that some general issues are common for such schemes to 
work:  
• schemes which give customers rebates or ot her incentives should a pply to all products 
providing the same function and be available in all relevant stor es and distribution 
chains (no restrictions as to t ype of outlets se lling the product); 
• incentives should be valid for a log time period enough across the whole country to 
help retailers plan their purchas es and marketing strategies;  
• incentive schemes should be general without need for forecast of sales or budgets (no 
reward for incremental sales). 
 The European energy labelling scheme has helpe d, for example, the Netherlands and the Italy 
to develop incentive schemes. The Dutch EPR sc heme has been successful in transforming 
the market for household appliances in the Netherlands
31 and several Member States32 are 
planning incentive schemes for th e future. In the absence of minimum efficiency requirements 
in form of specifically id entified labelling classes33 for public procurement and incentive 
schemes, the industry and consumers will risk working under 27 different schemes with varying efficiency levels. The ro le of the product specific impact  assessments is to judge the 
right level for such levels, if a ny, on each product group being labelled.  
 
  
2.2 Limits of the scope of the Directive 
Stakeholders found, in line with the Action Plan on SCP/SIC, that energy labelling scheme 
could be successful also when applied to a nu mber of products not covered by its current 
scope, which is restricted to household appliances. Stakeholde rs have requested that all 
energy-using products but also some non-energy using products co uld be energy labelled to 
inform potential buyers of their performance.  The additional energy-related appliances 
represent a technical energy savi ngs potential of above 158 Mtoe
34, which cannot be 
addressed within the scope of the present Direct ive. It should be considered whether some of 
this potential would be worth- while addressing with labelling and whether it would be cost-
efficient to do so. For a number  of non-energy using products which however have an impact 
                                                 
30 Cool labels - The first three years of the Eu ropean Energy Label, University of Oxford. 
 
31 Energy Premium Scheme EPR for domestic appliances in the Netherlands, Hans-Paul Siderius, Novem.  
 
32 For example, the most recent French intention to ge neralise the 'bonus-malus' system from cars to electrical 
appliances, Le Monde, 19.8.2008.  
33 It is important to express the harmonised minimum energy  efficiency classes in form  of classes (A-G) instead 
of in form of a numerical value (e.g. energy efficiency index) in order to avoid disturbing the markets when the values for classes change as a result of a revised implementing measure.  
34 COM (2006) 545 final of 19.10.2006 estimates that the technical savings potential from commercial and 
industrial sectors is 152 Mtoe by 2020, which represents 27 % and 30 % respectively of the total consumption of 549 Mtoe 2020 under BaU. The figure excludes energy-related non-energy using products from the residential 
sector, such as windows. The figures must be taken as indicative given that boundaries between 'household', 
'commercial' and 'industrial' products are not always clear cut. 
 
18 on energy conservation, such as windows (glazing and frames), the savings potential can also 
be considered in energy terms.   Also in the case of energy-using products outsi de the scope of the current ELD, information 
asymmetries are a main market failure. Howe ver, market structure of the energy-using 
products can lead to different pr actical situations than  in the case of hous ehold appliances. For 
example, industrial appliances ar e traded largely on an OEM market
35, which represents 80-
90% of total sales of these products. While not being responsible for paying the running costs, 
OEM manufacturers tend to put less emphasis on designing efficient appliances/parts, as 
inefficiency in use does not add to  manufacturers' costs. Also, there is often a situation of split 
budgets where one budget is used to spend mone y so that another budget can show savings.36 
For example, investing in the efficiency of an  industrial pumping or co mmercial refrigeration 
system is the responsibility of the maintenance department or service provider, and earmarked 
in its budget (meaning that mainly purchase/invest ment cost matters), while the savings due to 
increased efficiency accrue to the budget of the production/sales department and the general 
budget of the enterprise. The impact assessm ent of SCP/SIP show similar information 
asymmetries related to other energy-related products.     Currently, the ELD does not allow the provision of product informati on in the label such as an 
estimate of the annual running cost in moneta ry terms (though it gives estimates of yearly 
consumption) or carbon footprin t. The relevance of opening th e possibility to show such 
information under the ELD should be assessed as part of the revision in order to aim at further reducing the information asymmetries in th e market. Similarly, the ELD does not allow 
provisions to cover advertising by manufacturers, retailers or th eir representatives in media, 
such as websites (e.g. Internet  sales), newspapers or TV. This media has an important 
growing impact on consumer knowledge and purc hase decisions. Provisions on these issues 
could help changing the consumer behaviour based on purchase price towards purchases based on life cycle cost. 
 
2.3 Limits of the functioning of the Directive 
The dynamism of the ELD - within a given scope – depends, first of all, on the resources 
allocated within the Commission to develop ne w implementing measures (periodic reviews) 
and on the support by the Member States in the Regulatory Committee.  Another obstacle to 
the adoption of reviews is the industry stakehol ders’ resistance in upgrading the A–G ratings, 
as it implies downgrading of appliances in st ock (an 'A' appliance becomes a 'B' or a 'C' 
appliance, which leads to decreased value of  these appliances in stock due to reduced 
consumer interest). 
Currently the ELD framework only allows implementing Directives, which require 
transposition by Member States and the fo llow up of the transposition by the Commission. 
Implementing measures in the form of regulatio ns or decisions would reduce administrative 
burden and respond to a strong reque st made by industry in order to  ensure level playing field 
for competition in the Internal Market and th e harmonised introduction of measures across the 
Member States. 
                                                
 
35 Original equipment manufacturer, or OEM, is an ambiguous and abstruse phrase that refers to containment-
based re-branding, where a company uses a component of another company in its product, or sells the product of 
another company under its own brand. OEM refers to th e company that originally manufactured the product.  
36EuP Lot 11 study on industrial motors, pumps, fans and circulators: 
http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm .  
 
19 Tolerances in test standards are considered to be too wide in the case of many appliances37, 
which can allow an appliance to have a falsel y higher ranking. As technical development has 
increased the accuracy of testing devices a nd methods, it should be assessed whether some 
provisions could be added to the ELD th at would contribute minimising variation. 
Market surveillance is not addressed in the provi sions of the ELD contrary to other relevant 
Community legislation . Several stakeholders38 have reported insufficient surveillance and 
enforcement by Member State authorities, both  in respect to manufacturers meeting the set 
requirements and retailers displaying correct information. 
The energy label has no legal protection, which en tails risks of abuse by third parties. The 
lack of provisions ruling the voluntary use of the Community energy label by third parties can 
put the credibility of the scheme in danger.  
The ELD makes no provision regarding the use of implementing measures as a basis for 
public procurement or incentives by Member St ates. Today, Member State practices are not 
harmonised as to the efficiency levels for a ppliances purchased/promoted. Consumers, public 
administrations and industry would benefit if the Member States made harmonised use of the 
energy class levels and measurement standards set out in the implementing measures as reference for their public procurement or incentives.   
 
2.4 Identifying the affected part ies and the impacts therewith 
• The (framework) ELD puts requirements only on Member State authorities and 
Commission, while the Implemen ting Directives address: 
o Retailers/dealers being responsible for the a ffixing of the label at the point of sales on 
the regulated appliances and for the provision of correct information to consumers; 
o Manufacturers/suppliers be ing responsible for measuring and declaring the 
performance of their models, for holding th e technical documentation and for providing 
the labels to retailers/dealers; 
o Member State authorities for the implement ation of the direc tives, including both 
transposition into national legislation and market surveillance. 
In addition, implementing measures affect al l citizens and public aut horities as potential 
customers. Labelled products require manufacturer s to provide energy e fficiency information 
in a standard format to be made publicly available. This allows consumers and public 
purchases to more easily calcula te running cost of products and to compare the efficiency of 
products. Furthermore, particularly for a typi cal consumer, it is ve ry difficult, if not 
impossible, to calculate the running cost for a TV or a lamp
39 but very easy and convenient to 
compare the efficiency levels between different  TVs or lamps shown in an A-G efficiency 
scale.  
The labelling scheme provides a level playin g field for manufacturers to position their 
products in term of energy efficiency in their marketing and design activities in a predictable 
way. It also results in a larger and more co mpetitive market in providing an incentive to 
                                                 
37 See e.g. Ecodesign pr eparatory studies on 
http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm#studies   
38 E.g. ANEC, CECED, Swedish Energy Agency. 
39 Calculating the annual running costs fo r example for a fridge or a freezer that  is running constantly tends to be 
much easier with help of the annual consumption figures provided in the energy label. 
 
20 produce high-efficiency appliances. More effici ent appliances also provide manufacturers a 
competitive advantage in third country markets.  
For retailers, a well functioning energy labelling scheme can be a powerful marketing tool for 
products that often provide hi gher profit for the retailer and lower life-cycle cost for 
consumer.  
The visibility and credibility  of a label endorsed by public authority allow households to 
compare appliances and buy those that cost  less over the life-cycle of the product and 
contribute to a better environment.  
Public authorities can lean on a harmonised EU  level scheme when setting incentives or 
rebate schemes for the most efficient applianc es while respecting fair competition. Clear and 
credible ranking of appliances  can help public aut horities to purchase (f or relevant product 
groups) or to set up incentive schemes with doubl e benefit in form of savings for the public 
sector and in contribution to an increased demand for energy efficient and environmentally 
sound appliances. This is an im portant aspect of the SCP/SIP40.  
The way in which these aspects would develop ov er time is further described under the policy 
option 'business as usual'. 
2.5 Transposition and compliance 
In the early days of the energy labelling, failure  to display labels and incorrect labelling was 
an important issue. The situation has improved but compliance remains a concern41. Currently 
the (Framework) Directive provides for implementi ng Directives (under article 9). This is in 
contrast with the Ecodesign Directive 2005/32/EC  which allows for implementing measures 
to be either decisions or regulations. The adva ntage of regulations is that they reduce the 
legislative burden on Member States and allo w for a level playing fi eld for manufacturers 
who will no longer be affected by divergent pr ogress on transposition across the EU27; there 
can be significant time delays in transpositi on which may cause uncertainty in the market.42   
 The Ecodesign Directive requires Member States  to designate authorities responsible for 
market surveillance to ensure compliance with  the provisions of the Directive. Possible 
actions include an adequate scale of ch ecks on compliance, provision of necessary 
information and spot checks on pr oducts.  Member States are required to report their market 
surveillance findings to the Commission. Thes e authorities are responsible for market 
surveillance on compliance with both mini mum performance requirements and energy 
labelling schemes. 
 
2.6 EU right to act: Treaty base and subsidiarity 
The ELD is based on Article 95 of the Treaty. 
In order to achieve a well-f unctioning Internal Market for household (and possibly other) 
appliances and a level playing fi eld without technical ba rriers to trade, a compulsory labelling 
scheme was be set out at Community level. Now the scheme needs to be reviewed. The 
principle of subsidiarity is re spected by the fact that Member States are assigned appropriate 
responsibilities with regard to  the implementation of Community  legislation related to energy 
efficiency of appliances and market surveill ance. This includes the Comitology process in 
which the Member States are able  to exercise their legal power . A proposal is currently on the 
                                                
 
40 Sustainable Consumption and Production and Sustainable Industrial Policy. 
41 Survey of Compliance Directive 92/75EEC, Draft Interim Report to the Commission, 25 August 2008.  
42 Background study: http://ec.europa.eu/energy/demand/legislation/domestic_en.htm   
 
21 table to provide the European Parliament with  a reinforced right of  scrutiny. The Directive 
keeps proportionate as it does not go beyond what  is required for achieving its policy goals. 
 
SECTION 3: OBJECTIVES  
The general objective of this policy revision is  to contribute to the EU energy policy goals 
sated in the Energy Efficiency Action Plan and in the Climate Change Package; to save at 
least 20% of its present energy consumption in a cost-effective manner and reduce overall emissions to at least 20% below 1990 levels by  2020, with contribution to the Lisbon Agenda 
and to the EU Sustainable Development Strategies. This will be done in identifying the most cost-efficient way(s) to reinforce the market  transformation towards more efficient and 
environmental-friendly products, which contribu te to energy savings, better environment and 
sustainable production and cons umption, while providing useful and easy-to-understand 
information on product performance to consumers   The specific objectives are to contribute to energy saving,  and related emissions reduction, 
within two sub-categories of products:  
(1) household appliances; (2) all energy-related products
43.  
 
Depending on the policy option chosen, the specific objectives will be achieved by means of operational objectives that were consulted with  stakeholders (Annex 13) as summarised in 
table 3.1. The outcomes sought by the ELD are r ealised through the implementing measures 
and are to be evaluated on the basis of the results of these measures.  
 
Table 3.1: Operational objectives 
No Operational objectives 
1 Increase the number of household appliances for which an energy label is introduced  
2 Introduce energy label to priority energy-using and energy-related appliances  
3 Regularly review existing implementing measures according to timeframe indicated in each 
implementing measure 
4 Provide additional useful product information in la bels based on product specific impact assessment 
5 Cover distant mail, media advertising and other distant selling activities with energy label as defined in 
implementing measures based on sp ecificities of each product group 
6 Save administrative cost in implementing ELD with implementing measures 
7 Prevent unauthorised use of label 
8 Ensure adequate framework require ments on measurement tolerances and market surveillance activities 
9 Ensure framework requirements for Member State public procurement and in centive schemes and that 
these schemes are linked with energy labelling s cales of individual implementing measures  
 
No further objectives for the savings of other esse ntial resources (Article 1 of the Directive) in 
the use phase are developed in order to keep the focus clearly on the main environmental 
impacts. A well designed product labelling ought to take such trade-offs into account and 
ensure that the focus on one environmental pa rameter (energy consumption in use) is not 
promoted at the detriment of the global en vironmental performance of the product over its 
lifecycle. Potential trade-offs must be addres sed in product specific impact assessments. 
                                                 
43 Energy-related products are products that have an impact on energy consumption during use. This includes 
products such as window frames, whose insulation properties influence the energy required for the heating and 
cooling of the buildings etc.  
 
22 However, the issue of consumption of 'other esse ntial resources' in use phase and the trade-off 
with energy mainly applies to a very limited number of well known products, the so called 
'wet goods' (washing and dish washing machines and dryers to some degree). Currently there 
is no accepted methodology that could prioritise between environmental impacts. However in 
the case of energy-using products it is clear that typically mo re than 90% of environmental 
impacts take place in the use phase corresponding to energy consumption. 
 The indicators for the specific objectives are in  particular the electricity (TWh) and primary 
energy (Mtoe) saved and related CO2 emissi ons reduced, depending on the product group in 
question (e.g. an electric, gas, oil or solid fu el appliance). Changes in market share towards 
higher efficiency appliances/classes over time a nd the amount of energy saved indicates the 
speed of market change i nduced by the labelling scheme. 
 
S
ECTION 4: POLICY OPTIONS  
In the light of the past achievements (see A nnex 10), termination of the labelling scheme 
cannot be considered as a valid policy option. On  the contrary, in the light of the speed in 
market developments and the environmental pressure, it is necessary to consider how to reinforce the scheme with minimum, or possibly reduced, additional burden. As requirements for a well-functioning Internal Market have not changed since the adoption of the ELD, Member State or non-regulatory ac tion alone is not a re alistic altern ative. Instead, alternative 
EU-level solutions need to be considered in combination with other available regulatory and 
non-regulatory actions in order to consider to what extent each policy option is capable in 
reaching the maximum of the energy savings an d emission reduction objectives set out in the 
Action Plans for Energy Efficiency and SCP/ SIP and the Climate Change Package. Four 
policy options are identified that could possibl y achieve the specific objectives. These are:  
 
(1) No policy change, with two sub-options: 
1a)  BaU - business as usual,  1b)  BaU + 1 - full implementation of the current ELD scope. 
(2) Non-regulatory action. (3) Amend the Directive - full implementation of the current ELD scope, plus 
coverage of all energy-related produc ts, excluding means of transport. 
(4) Repeal the Directive and implement its provisions within th e Ecodesign Directive - 
full implementation of the current ELD scope, plus coverage of all energy-related products, excluding means of transport.  
 The product specific impact assessments will have  to look at further 'sub-options' within the 
scope of the ELD, such as the appropriate info rmation on labels or possible provisions to 
upgrade the label grid depending on the type of product in question. Further actions such as 
requirements for suppliers and dealers to organise  consumer advisory serv ices or the like can 
not be dealt with under actions stemming from Article 95 of the Treaty.    
 
4.1 Policy option 1: BaU - business as usual  
This policy option is divided in two sub-options , one with no further action and one with full 
implementation of the cu rrent scope of the ELD. 
  
 
23 4.1.1 Policy option 1a: BaU -  no further action 
This BaU scenario includes the current scope of the ELD with no development of new or 
updated implementing measures. The option serves as an analytical baseline for comparison 
of costs and benefits with the other policy options. The impact of options 3 and 4 will be compared against both BaU options. 
The effect of the labelling implementing measures  will continue to have some effect in time 
even without strengthening the sc heme, in particular for those products on which there are no 
minimum (Ecodesign) requirements in place. Ho wever, given that the life time of an 
appliance varies around 10-12 ye ars, the impact of the incr eased energy efficiency of 
appliances covered by implementing measures  will vanish around 2013-2015, as the latest 
implementing measures have been introduced in 2002-2003
44. Although energy efficiency of 
these appliances is not expected to go down by 2020 ('nega-joules' gained), it is not expected 
to increase without additional measures on  the product groups currently covered by 
implementing Directives. In addition, a labellin g scheme looses its impact once all or most 
models correspond to the A rating.     
4.1.2 Policy option 1b: “BaU + 1”,  including op timal implementation of the current ELD 
The “BaU + 1” scenario includes the scope  as it is currently but with an optimal 
implementation of the current ELD based on the Ar ticle 1 of the Directive. The option implies 
to cover all relevant household appliances by impl ementing measures as foreseen in Article 1. 
This means the introduction of implementi ng measures for new household energy-using 
appliances such as boilers, water heater and TVs, and the upgrading of the existing 
implementing Directives.  
Apart from the full implementation of the pres ent ELD scope, account must be taken on other 
relevant regulatory and non-regulatory acti on, such as Ecodesign, Ecolabel, Energy-Star, 
IPPC
45 and voluntary industry and Member State in itiatives. Member States are expected to 
continue developing national and regional la belling schemes (e.g. Blaue Engel or Nordic 
Swan). Member States would continue public procurement procedures on an uncoordinated 
national basis and provide incentives for the acceleration of the uptake of more performing 
products without a harmonised framework.  
 
4.2 Policy option 2: Non-regulatory action 
The second policy option relies on voluntary ac tion by industry to reinforce energy labelling 
in combination with other rele vant Community tools, such as the Ecodesign Directive, 
Ecolabel, Energy-Star. This option would co exist with voluntary national and regional 
labelling schemes. Member State participatio n would be based on a voluntary approach to 
harmonise incentives and public procurement fo r energy efficient goods in line with option 1. 
 
4.3 Policy option 3: Amend (recast) the ELD , including broadened scope to energy-
related products 
The third option includes amending the ELD , taking into account the amended Ecodesign 
Directive, in order to accommodate actions that  help to reach the specific objectives. This 
policy option considers covering all energy-using products (excl uding means of transport) and 
                                                 
44 Implementing measures on ovens, air-conditioni ng appliances and refrigerators and freezers. 
45 The Integrated Pollution Prevention and Control Dir ective (IPPC) on energy and re source efficiency focuses 
on the production processes and not on product efficiency. 
 
24 energy-related products (that have an impact on  energy consumption when in use/installed) 
within the scope of the revised ELD, as defi ned in the draft Comm unication on SCP/SIP.  
The implementing Directives/measures would se rve as a framework for Member State public 
procurement and incentives across the Internal  Market, subject to compliance with existing 
Internal Market and competiti on rules. The levels for public procurement or incentives would 
be based on class levels among t hose set out in the implementi ng measures while leaving the 
possibility for public authorities to take into account the affordability of consumers in each 
Member State. This would ensure sufficient ch oice of products on the market and guarantee 
budgetary neutrality of purchases over the life cycle of the product for procurers.   
For the sake of clarity and simplification and to  limit the discussions in co-decision procedure 
to the main elements of the ELD to be consid ered, the amendment of the Directive would be 
implemented through the recasting technique.46  
The actual energy-related products  to be labelled can not be listed out in this impact 
assessment as it would requir e separate product specific impact assessments backed by 
preparatory studies. For indicative purpose, so me products based on past studies and reports 
with most promising savings potential and su itability for energy labe lling under the ELD are 
considered in Annex 9. 
 
4.4 Policy option 4: Repeal the ELD an d implement energy labelling within the 
Ecodesign Directive 
This option would include repealing the ELD and implementing its provisions through the 
Ecodesign Directive, as also considered in th e Action Plan for SCP/SIP. It would cover the 
same scope and include the same actions and general implementation framework as analysed 
under the option 3, including public  procurement and incentives. 
 
SECTION 5: ANALYSIS OF IMPACTS  
In the following chapters, a qualitative and qua ntitative assessment is performed for impacts 
on which sufficiently reliable data are availabl e. The analysis focuses on the achievement of 
the specific objectives by policy options considered against the BaU scenario (additional savings achieved against option 1a). Change in the scope of the ELD framework has no direct 
impacts, as the ELD is a framework directiv e. The environmental, economic and social 
impacts stem from implementing measures on specific products, whic h are adopted by the 
Commission in a comitology procedure (the ELD Committee) following a technical/economic 
preparatory study, stakeholder consultation, WTO/TBT notifica tion and dedicated impact 
assessment. As a result of the studies, tec hnical recommendations are made for minimum 
requirements under Ecodesign, energy labelling schemes under the ELD and other possible measures, as appropriate. Thus, figures and resu lts presented in this impact assessment are 
examples of what could be achieved, if the scope of the framework directive would be 
extended with a parallel action by an amende d Ecodesign Directive (e xtension to energy-
related products).   The policy options are considered keeping in mind that fluctuation in  energy prices and 
energy dependency will continue having an imp act on the EU economy. In the likely future 
economic context with rising energy prices, th e urgency and pressure to achieve energy 
savings will continue and the usefulness of the labelling tool as a pol icy instrument will be 
reinforced. 
                                                
 
46 http://eur-lex.europa.eu/LexUriServ/LexU riServ.do?uri=CELEX :32002Q0328:EN:HTML   
 
25 5.1 Policy option 1: BaU – business as usual 
The policy option 1 is divided in two sub-options (1a and. 1b) in order to consider the BaU in 
an analytically useful 'no-change' (baseline) option and in a 'full implementation' (BaU +1) 
option. This allows considerations  on issues such as resources needed for full implementation 
of the current ELD against the baseline as we ll as the comparison of other policy options 
against both BaU sub-options. 
5.1.1 Policy option 1a: BaU - no further action  
A number of policies and inst ruments is already in place: the climate package (Emission 
Trading Scheme (ETS), sectors beyond ETS a nd renewables), Directives on industrial 
emissions, waste, air quality, Energy Services , Energy Performance of Buildings, Energy 
Labelling and Ecodesign, Energy Star, Eco-la bel, Combined Heat and Power, Energy 
Efficiency Action Plan, EMAS and ETAP . 
EU energy labelling affects all products covere d by an implementing Directive and put on the 
Internal Market, irrespective if  they are manufactured in th e EU or in a third country. 
Therefore the impacts are the same for EU a nd non-EU companies.  In principle, energy 
labelling stimulates innovation within the aff ected industry. Companies putting most efficient 
appliances on the European market increase th eir chances to be competitive also on other 
markets, as the demand for energy efficient products will grow steadil y together with the 
global fight to mitigate climate change. The possi bility to differentiate products and promote 
the better ones helps manufacturers to recove r R&D-investments for more efficient products. 
 The BaU is based on the European Commission Baseline scenario for energy trends
47 
assuming a steady growth of the EU economy w ith a sustained industrial component. It also 
assumes relatively high world energy prices comp ared with previous projections and similar 
to reference projections from other sources, which increase at a moderate pace. It takes 
account of policies and measures al ready in place at  the end of 2006. 
 The carbon intensity of GDP, e xpressed as CO2 emissions per unit of GDP, is projected to 
decrease by 1.8% per year during 2005-2030, slightly down fr om 2.2% per year in 1990-
2005. For the period 2005-2030, this result is almo st exclusively due to  energy efficiency 
gains, while in the past the reduction of carbon intensity of GDP was al so due to the reduction 
in the carbon intensity of energy (by 33%).   The final energy demand sectors continue to us e more natural gas instead of more carbon 
intensive fuels. Consequently, direct CO2 emissions by these s ectors, namely in industry, 
residential, services and agriculture, are shown to  be stable or to incr ease only at a moderate 
pace between 2005 and 2020.   Synergies and complementary with other energy efficiency activities would continue mainly 
with Ecodesign, Energy-Star and Ecolabel as depicted in Annex 2. Possible synergies may 
well appear also when the EPBD and ESD are imp lemented, particularly if they are revised, 
as currently planned for the EPBD. Member Stat es and industry would continue the existing 
schemes (e.g. Blaue Engel, Nordic Swan and industry voluntary action) on product groups not 
regulated at EU level. CECED, the Eu ropean Committee for Domestic Equipment 
Manufacturers, and EICTA are not proposing new vol untary agreements, as they consider that 
the Ecodesign together with the ELD are a better framework for implementing European 
product policy, as it leaves no space for free riders. 
                                                
 
47 Trends to 2030 – Updaate 2007, European energy and Transport, European Commission: 
http://ec.europa.eu/dgs/energy_transport/figures/trends_2030_update_2007/index_en.htm   
 
26  
It is estimated that with present policies in place, 65 TWh to 75 TWh per year including the 
related CO 2 emissions could be saved by 201048. The climate change and energy policy 
package has an impact due to its increased emphasis on reducing emissions and the likely increase in electricity prices  by 10-15 % by 2020 in comparison  to today’s level. For final 
consumers, increases in unit electricity prices  are partially compensa ted by overall increased 
energy efficiency, which is resulting in a reduc tion of electricity consumption of around 10 %. 
This, to a large extent, will count er the above mentioned increases  in electricity prices. These 
combined effects lead to a rather moderate energy cost increase pred iction for households 
which is estimated to be about € 150 per year (in 2020)
49. Therefore, electric ity price increases 
alone cannot be expected to stimulate a strong er push for more efficient appliances than 
current policies.  
The Ecodesign Directive is under revision in order to include all energy-related products. This 
will allow setting requirements on all these pr oducts but will not have any impact on the 
functioning of the ELD. The impact is relevant only in the case that a product group covered 
by an ELD implementing directive is subject to Ecodesign requirements. However, in 
practice, new minimum requirements would just empty some of the lowe r labelling classes in 
the existing labels without the need to review  the existing ELD implementing Directives, as 
long as some models have be tter performances than the minimum energy performance 
requirement set under the Ecodesign measures.   Under this option, Member St ates would continue implem enting public procurement and 
incentive schemes on national basis with  distortions of the Internal Market
50. It shows that 
policies in place are not sufficiently aligned an d linked with each other to realize synergies 
but send conflicting signals and leave gaps that result in a fragmented regulatory framework 
rather than a consistent one . As an exception, the Ener gy-Star Programme on office 
equipment provides coordinated levels for ma ndatory public purcha ses of the products 
covered, contributing to  solving information asymmetries for public procurer s by showing the 
'hidden' costs of use over the expected life span. 
No stakeholder supported this policy option. 
5.1.2 Policy option 1b: “BaU + 1”, including opti mal implementation of the current ELD  
The current scope of the ELD allows addressing  the technical energy sa ving potential of 91 
Mtoe by 2020 in the residential sector51. While a big part of this technical potential could be 
addressed with minimum energy performance requirements under the Ecodesign Directive, 
some of it - one third as an or der of magnitude - s hould be addressed with  the ELD, subject to 
product specific preparatory studies. Howeve r, it is not appropriate to set minimum 
requirements at the level of best availa ble technology. Affordability, competition and 
differentiation in functionalities usually justify some diversity on the market; in turn, such 
diversity justifies prov iding reliable information to consumers on the products’ performance 
through labelling.   
                                                 
48 Electricity Consumption and Efficien cy Trends in the Enlarged European Union – Status Report 2006. P 
Bertoldi, B Atanasiu. 2007.  
49 SEC(2008) 85/323 of 23 January 2008.  
50 Impact Assessment on SCP/SIP. 
51 Defining the border line between residential and comm ercial products may be easy in the case of vacuum 
cleaners or coffee machines of certain type but is more difficult in the case of vacu um cleaners of bigger size, 
which could also be used by SMEs in the commercial sector. This is why this impact assessment refrains from 
defining products specific to these sectors but refers to the general technical savings potential estimated by 
Commission official documents.  
 
27 The BaU+1 option is considered as an option to fully implement the existing provisions and 
tools, that is, continuing to develop impl ementing measures on product groups covered by 
Article 1 of the Directive, such as household boilers and water heaters. Also, it includes fully 
exploiting the possibilities offe red by the Article 1.2 of the Directive in setting energy 
labelling requirements on any household applian ce not yet explicitly men tioned in Article 1, 
such as TVs. This option would also incl ude the updating of the existing implementing 
Directives.  
In the past, the introduction of more efficient appliances has been extremely cost-effective. 
However, due to exhaustion of the "easy" sa ving potential for some appliances and higher 
R&D-costs the cost-effectiveness will decrease, but remain quite positive, especially when 
considering raise of the price of energy. 52 Precise quantifications ar e impossible to give but 
Annexes 9, 10 and 11 provide indicative figures in the case of exemplary product groups.   
 
To date, there has been no upgrade of values for efficiency classes (A-G scale values), except 
for refrigerators and freezers. As  a consequence, most of the appliances today have reached 
the A or B level, which risks undermining the e ffectiveness of the sche me on the longer run. 
However, it also confirms the success of the scheme; appliances have become more energy 
efficient. Although energy labell ing and technological developmen t have made further energy 
savings more challenging in the case of th e product groups already labelled, considerable 
savings can still be reached in upgrading the existing implementing Directives with a corresponding estimated savings of some 2 Mtoe
53 by 2020 (without minimum efficiency 
requirements under Ecodesign), corresponding to emission savi ngs of some 8,4 Mt of CO2  
and of some €3 billion by 2020. The potential is particularly important in the Implementing 
Directives on air-conditioning applian ces, dishwashers and washing machines54.  
Full implementation of the ELD would include addressing the savings potential of heating 
and water heating appliances, which has not  yet been done under the ELD. These heating 
appliances are estimated to repr esent about half of the total co st-efficient savings potential of 
the considered appliances within the scope of the present ELD. The Ecodesign preparatory 
study aims at about 58 Mtoe total savings55 in primary energy (90 Mt of Co2)56 by 2020 in 
residential heating and water heating with th e combination of the Energy Performance of 
Buildings Directive (EPBD), Ecodesign Dir ective and ELD. The mixture of Ecodesign, 
installation and labelling require ments would result in yearly net savings of €45 billion as of 
2020, out of which about €15 billion57 could be reached by energy labelling. 
While most savings on heating and water he ating appliances will be achieved through 
Ecodesign and EPBD requirements on installati on, the estimated impact of the ELD could 
                                                 
52 Impact Assessment Report for the Actio n Plan for Energy Efficiency 2006: 
http://ec.europa.eu/energy/action_pl an_energy_efficiency/index_en.htm   
 
53 This is slightly more than the above 1 Mtoe saving estimated in the Impact Assessment Report for the Action 
Plan for Energy Efficiency 2006: http://ec.europa.eu/energy/action_plan_energy_efficiency/index_en.htm , which 
estimated the savings potential to be equal to some 30% of already realised energy savings. However, the latest technological  developments show that the potential is higher (Ecodesign preparatory studies: 
http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm
).  
54 Ecodesign studies: http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm   
55 The Ecodesign preparatory studies http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm estimate 
that the total energy saving potential of boilers and water heaters in the residential and commercial sectors is 77 
Mtoe. Some 75% (58 Mtoe) of these savings come from the boilers and water heaters of the size typically used 
in residential sector. 
56 Conversion factor from primary en ergy (Mtoe) to emissions (Mt of  Co2) is 2,597. MEEuP Ecodesign 
methodology: http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm  
57 On electricity pr ice of €0,136/kWh. 
 
28 account to savings of some 18 Mtoe58 by 2020, corresponding to emissions saved of some 46 
Mt of CO2 and yearly net savings of some  €15 billion. The estimate made by the background 
study on the impact of labelling on boilers alone is slightly lower but in the same order of 
magnitude (savings of 20 Mt of CO2 vs. €5.5 b illion from labelling on boilers alone). For 
clarity, the above saving figures  through energy labelling, lik e the other figures in this 
chapter, are estimates based on the most probabl e future scenario with impact assumed from a 
joint action of EPBD, Ecodesign and ELD.   
It is important to notice that heating and wa ter heating appliances are often sold through 
installers rather than directly to customers (p rincipal-agent problem), which can lead to low-
efficient and over-sized appliances. However, it is currently considered to include mandatory 
requirements in the EBPD (under review) oblig ing installers to match efficient heating 
systems (rated under the labelli ng scheme) with the heat demand of the particular building. 
This requirement would further increase the eff ect of the labelling scheme and the synergy 
between the two Directives.  
An energy label is planned on televisions with  a total savings potential of 46 TWh by 2020.59 
Out of this total potential, it is estimated that energy labell ing could catch around 12 (about 1 
Mtoe) by 2020, corresponding to  emission reduction of 4,860 Mt of CO2 and €1,6 billion61 pa 
by 2020. As to lighting, the Ecodesign preparat ory studies indicate th at general lighting 
appliances would provide some 74 TWh of savi ngs potential of which energy labelling could 
catch some 16 TWh (about 1,5 Mtoe) by 2020, corre sponding to reduced emissions of 6,4 Mt 
of CO2 vs. €2.2 billion.  
Based on the above considerations, it is estimated  that vigorous implementation of the current 
ELD, including the upgrading of the existing implementing Dir ectives and the development 
of new ones would help to reach savings of some 22 Mtoe62  by 2020 in the case of the 
considered priority appliances  alone, corresponding to emissi on reduction of some 65 Mt of 
CO2 , or €22 billion by 2020.  
Office equipment is covered by the Energy Star Programme under the International 
Agreement signed between the EU and the USA to  coordinate their en ergy labelling schemes 
for office equipment. Although the Agreement w ould legally allow covering also the office 
equipment under the ELD, such an overlap is considered inappropria te and inefficient. 
Under the BaU+1 option, the ELD can only be im plemented with Directives leading to a 
transposition cost of €4 million per updated or  new implementing directive (see Annex 12).  
Apart from its scope, the focus and the legal requirements of the ELD have an impact on its 
potential to reach the policy objectives. Some  of the main issues are discussed below. 
The way to integrate fast decision making pro cedure under the current legal framework of the 
ELD would be to introduce staged energy la belling with gradually increasing 'A-levels'. 
                                                 
58 The estimated savings potential of 31 Mtoe from commercial heating and water heating appliances would 
remain outside the ELD. However, the division between residential and commercial sector savings potential 
must be seen indicative, as there is no clear cut betw een residential and commercial sector heating and water 
heating appliances; the main difference being the size of the appliances. Thus, the savings figure include the impact of the labelling of some 25% heating and water hea ting appliances foreseen for residential use but sold to 
commercial customers.
 
59 Ecodesign preparatory study lot 5: http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm   
60 Average specific EU emissions in 2003 for EU-2 5: 400g CO2 per kWh, EURELECTRIC, Environmental 
Statistics of the European Electricity Industry, Trends in Environmental Performance 2003-2004.  
61 On assumed electricity price of €0,136/kWh, as in the Ecodesign MEEuP methodology: 
http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm   
62 Savings in electricity (TWh) are converted to savings in primary energy (Mtoes). A c onversion factor 0,086 is 
used based on the EU Energy and Transport in Figures, Statistical pocketbook, 2007/2008 .   
 
29 However, although the ELD does not prohibit this, it would be difficult to predict the 
technological development and assess the corr esponding impacts over a long period of time.  
Article 5 of the ELD makes provision on the c ontent of the implementing Directives in 
order to cover mail order and other sales situ ations, where th e potential customer cannot be 
expected to see the appliance displayed. Th e three most recent implementing Directives63 
make requirements on the provision of labels and information in mail orders and in other 
distance selling, including the Internet.  
Manufacturers and retailers some times provide energy labels or other type of energy 
efficiency related information when advertisin g in media, depending on the type of product, 
size of advertising and media used, but in practice only when the appliances are “A”-
graded. Manufactures and retail ers selling appliances below A-grade do not publish such 
information, if it is not specifically required in the implementing Directives, as it would 
harm sales.  
The current wide measurement tolerances for the regulated appliances often allow 
manufacturers to claim that a ppliances are of higher class th an they would be under tighter 
tolerances. This can partially affect the credibility of the label. The situation can not be corrected under business as usual. The enfor cement authorities have not reported any badly 
displayed or missing labels since the beginni ng of the energy labelling scheme although a 
recent study shows the contrary
64. Also, several actors have recently reported compliance 
problems or requested streng thened market surveillance65. The necessary Community 
legislation on market surveillance is in plac e but it does not seem to be adequately 
implemented. 
Under this policy option, the energy label would be used by third parties for voluntary 
labelling under no legal rules or agreed approva l procedure. The voluntar y use within the EU 
has not yet led to major identified problems but could potentially do so without legal 
protection and clear framework rules with the ma jor risk of jeopardizing the value of the EU 
energy label and the investments made since y ears by all parties involved. This cannot be 
adjusted under the current ELD. 
As to the stakeholder preference, intervie ws conducted for the background study showed 
highest interest in reinforcing the implementatio n of the articles of the present ELD while the 
stakeholder consultation for the impact assessment showed strongest preference for broadening the scope (option 3) . The background study was based on a sample of interviews, 
while the stakeholder consultation included all relevant stakeholders; the stakeholder consultation meeting allowed stakeholders to co nsider the pros and cons in an open manner 
(see Annex 13).  
5.2 Policy option 2: Non-regulatory action 
This policy option looks at the potential for non-regulatory action to further reinforce energy 
labelling in combination with other relevant  tools, such as ELD, Ecodesign Directive, 
Ecolabel, Energy-Star, national/regional sche mes (such Blaue Engel or Nordic Swan). 
Synergies and complementary with other energy efficiency activities would continue mainly 
with Ecodesign, Energy-Star and Ecolabel as depicted in Annex 2. Possible synergies or 
overlaps could appear with the EPBD and ESD. Voluntary initiatives could not be monitored 
                                                
 
63 2003/66/EC, 2002/40/EC and 2002/31/EC. 
64 Survey of Compliance Directive 92/75/EEC, Draft Final Report to the Commission, 25 August 2008. 
65 E.g. ANEC-R&T-2006-ENV-008 (final), January 2007; CECED paper on the Commission  Proposals on the 
Marketing of Products: COM (2007) 37 and COM (2007) 53, PP 07-01, named ''Fair play for all economic 
operators'', 24 April 2007. STEM test on fridges, May 2007; Intelligent Energy for Europe project, CEECAP, no. 
EIE / 05 / 195 / SI2.419686 of June 2008, CECED: http://www.ceced.org/  
 
30 under the current legal framework and their imp acts on the other instruments could not be 
controlled. 
Voluntary initiatives by industry (self-regulation) may be an alte rnative to legislation or may 
be a complementary measure, which contribu tes to the achievement of the legislative 
objective. While the voluntary initiatives taken by CECED66 to set energy reduction targets 
for refrigerators, freezers, and washing mach ines and dishwashers have complemented the 
compulsory energy labelling schemes for thes e products (BaU), CECED is not proposing any 
more voluntary schemes but prefers action under  the combination of mandatory Ecodesign 
and ELD. Similarly EICTA has abandoned the use of  self-commitments as an alternative to 
EU legislation under Article 95 for consumer electronics. For several years members of 
EICTA run a self-regulatory initiative for re ducing the stand-by energy consumption of TVs 
and DVD players. Though it had pos itive effects, it was considered  not to be a viable option 
for this sector where the market is very frag mented and in which the self-regulatory initiative 
could not ensure level playi ng field for the industry.   
Self-regulatory action by the indu stry would help to avoid admi nistrative cost for European 
and national administrations. However, as compar ative labelling schemes must be set for each 
product group, voluntary labelli ng of different product groups would risk using different 
principles in labelling schemes,  which is one of the main reas ons that has triggered mandatory 
labelling across the world (see Annex 7). This  was also one of the main reasons for the 
development of the ELD on 1992. However, alt hough there is no question in replacing the 
ELD by self-regulatory measures, these measur es could maybe complement the ELD. The 
problem is that voluntary action seldom includes the whole industrial sector but leaves free 
riders outside the scheme67, which can affect competitiveness of those who commit obeying 
the rules.  
As to other energy-using products, no proposal  for voluntary labelling has been made. 
Voluntary labelling could be set at Member Stat e (MS) level. However, the ELD superseded a 
number of largely voluntary energy labelling ini tiatives at Member States in order to achieve 
a harmonised provision of product information a nd to ensure the use of harmonised standards 
avoiding market fragmentation68. Since 1992, the need for harmonised approaches in the 
Internal Market have further in creased, not reduced, so national/ regional action in this domain 
is opposed by the industry. Als o, self-regulatory initiatives would require endorsement and 
monitoring by Commission and Member States to  avoid affecting the credibility of the 
official EU scheme. This would reduce the bene fits in terms of admi nistrative burden and 
leave various loopholes for possibl e legal action where necessary. 
Self-regulation would not provid e a harmonised framework appl icable across the Internal 
Market, therefore it could not be used for th e setting of levels for public procurement and 
fiscal incentives. Several parallel labelling schemes could risk increasing the cost for the 
consumer to obtain relevant information on product characteristics (manufacturers would 
have to transfer the cost of market fragme ntation to consumers) and lead even greater 
information asymmetries and bounded rationality, as  has been the case in the past. This could 
lead to social costs as low income households  would be the first to suffer from irrational 
purchase choices. Also, during th e stakeholder consultation, i ndustry expressed their clear 
preference for mandatory labelling in order to create level playing field69. Under voluntary 
schemes, companies whose products perform ba dly in terms of environmental impact are 
                                                 
66 http://www.ceced.org/   
67 Such as the Europump voluntary circulator labelling scheme: 
http://work.sitedirect.se/sites/europump/europump/index.php   
68 Background study: http://ec.europa.eu/energy/demand/legislation/domestic_en.htm#consultation   
69 See e.g. http://www.ceced.org/   
 
31 unwilling to display a label on th eir products, catalogues, media, Internet, etc., as it would 
negatively affect sales.  
Thus, it is estimated that while non-regulator y action could in theory help to broaden 
somewhat the scope and focus and to decreasin g administrative burden, in practice there are 
no signs of self regulatory initiati ves that could be considered as a valid alternative to a legal 
scheme. Accordingly, the estimated savings of this policy option are equal to the baseline 
(policy option 1a) and clearly less than in sub-policy option BaU + 1 (1b), that is, no 
additional significant savings are ex pected from this policy option. 
Stakeholders did not support policy option 2.   
 
5.3 Policy option 3: Amend (recast) the ELD , including broadened scope with energy-
related products 
The Ecodesign Directive curren tly only applies to energy-us ing products and the ELD to 
household appliances. The Communication on th e Sustainable Consumption and Industrial 
Policy (SCP/SIP) considers enlarging the scope of the two Directives also to all energy-
related products, maintaining the exception of mean s of transport, which already is subject to 
separate policies and legislation fo r reducing environmental impacts.  
The broadening of the scope of the ELD would be coordinated with other product policy tools 
such as Ecodesign, Ecolabels and Energy-Star ensuring comp lementarity and coordination. 
The amendment of the ELD includes the extens ion of its scope to energy-related products. 
The recast of the ELD would in clude requirements for implem enting measures to identify 
labelling classes at a level belo w which public authorities would not be allowed to procure or 
provide incentives such as rebate schemes.  The level in genera l should not be more 
burdensome to public finance than under the present procur ement practices  taking into 
account the full life time of the product. Thus there will be significant impetus for choosing 
the more energy and resource performing products whilst encouraging and inducing 
innovation for the industry (see Annex 11).  Below these aspects are analysed in two sub-sections focusing on impacts from the broadening of the scope on th e one hand and on the expected impacts from measures to 
improve the functioning of the scheme, incl uding the provision of a harmonized basis for 
public procurement and incentives.   
5.3.1 Expected impacts from a broader scope of the ELD 
The background study provides ample information on the expected impacts of the amendment 
and broadening of the scope of the ELD. It id entifies no negative soci al or environmental 
impacts. Potential economic and environmental benefits are identified depending on the exact 
scope of the amendments. The main savings potential from a broa dened scope would be 
expected to come from products such as heatin g or cooling in the commercial or industrial 
sectors. Technical savings poten tial in commercial and industria l sectors is estimated to 157 
Mtoe by 2020. How much of this potential coul d be reached by product labelling would have 
to be considered in separate product specific studies
70.  
Commercial refrigeration, industr ial motors, windows, tyres, and construction materials have 
been proposed by stakeholders as possible ener gy-related products to be labelled. However, 
tyres are excluded as belonging to 'means of transport'. Also, a separate proposal on the 
labelling of tyres is under pr eparation by the Commission.   
                                                 
70 A revised ELD would not save any energy. This will be achieved only after the development of product 
specific implementing measures. 
 
32 As shown in Annex 9, commercial refrigerato rs, freezers, chillers, display cabinets and 
vending machines are expected to provide savings of some 5 TWh (about 0.5 Mtoe) by 2020, 
corresponding to a reduction of emissions around 2 Mt of CO2. Th e border line between 
'household' and 'commercial' refrigeration is not  clearly defined; the bigger power range of 
'household' refrigeration and freezer appliances are also used e.g. in the SMEs, which lowers 
the above savings figure (it is estimated that some 25% of the smaller power range 
'commercial refrigeration' is already include d into the implementing Directives on household 
refrigeration and freezer appliances)71.  
Commercial heating is estimated to save some 3-4 Mtoe by 2020, corresponding to reduced 
emissions of some 9 Mt of CO2. The savings potential of industri al products would have to be 
considered in separate technical studies and impact assessments but information from the 
Ecodesign preparatory study on indu strial motors, pumps and fans  shows that energy labelling 
under ELD might not be the best choice due to the spec ificities of the ma rket for industrial 
products and to the latest developm ents in standards (see Annex 9). 
As shown in the Annex 9, based on the back ground study, windows would offer an estimated 
€ 4 billion/a savings corresponding to 25 million tonnes of CO 2, if conventional double 
glazing was replaced by low-e windows. Produc t specific technical studies and impact 
assessment analysis would have to be develope d in order to asses the feasibility of setting 
labelling requirements on windows, taking into account climatic zones. This might require 
developing the necessary multi-criteria scheme  based on different weather requirements in 
different climatic zones and altitudes as is done in the US and in some Member States, such as 
in Finland. However, it would be important to consider the related impact of the Energy 
Performance of Buildings Directive, which se ts minimum energy efficiency requirements on 
buildings and several of its co mponents; windows may be subject to specific requirements 
under this Directive in  the line of heating and coo ling systems, chimneys etc. 
The impact assessment of the Ecodesign Directiv e shows that the reduction potential in the 
construction sector is 78 Mt of CO2 due to th e use of construction pr oducts. These reductions 
would be partly due to the co mbination of the product specific approach of the Ecodesign and 
Energy Labelling Directives but first of all to installation requirements under the Energy 
Performance of Buildings Directive. How much of  this technical potential could be realised 
with help of a labelling scheme would have to be backed up by a technical study, which should also look at the suitability of the construction produc t market for product labelling (see 
further discussion on the impact of diffe rent types of markets in Annex 9).  
 Energy-related products could also  alternatively be covered by a Directive of the legislator 
(co-decision) as is the case of  cars (Directive on the labelling of  cars is under revision) ortyres 
(proposal under consideration).  In summary, compared with the baseline, a conser vative estimate is that broadening the scope 
of the ELD to energy-related products
72 could result in additional energy savings, in 
conjunction with simultaneous additional Ecodesign measures, based on the above priority 
product groups considered alone, in the magnitude of 27  Mtoe73 by 2020, corresponding to 
                                                 
71 Ecodesign studies: http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm   
72 The estimate exclude the impact of product groups with possibly very important savings potential (e.g. 
commercial and industrial lighting) but does not yet consid er any industrial products in proper sense. Sufficient 
information for further considerations of these products  will be available from the current and future Ecodesign 
preparatory studies.  
73 Savings in electricity (TWh) are converted to savings in primary energy (Mtoes). A conversion factor of 
0,086 is used based on the EU Energy and Transport in Figures, Statistical pocketbook, 2007/2008.  
 
33 emission reductions of some 78 Mt of CO274 (excluding the technical sa vings potential from 
construction products of which the majority w ould be stemming from the EPBD). Compared 
with BaU + 1 option, this would correspond to  additional savings of some 5 Mtoe when 
extending the ELD only to windows and to select ed cooling and heating appliances in the 
commercial sector. 
These figures seem a realistic estimate given that, although there is an important technical 
savings potential in the other energy-using products, many of them beyond the household 
sector are often not sold to consumers but to  specialised people or to OEM manufacturers, 
who do not sell/purchase these products fro m outlets/shops but directly from other 
manufacturers. Due to these market differe nces, the product specific impact assessments 
would have to carefully consider what kind of energy labelling info rmation and procedure 
would best address the specifi cities of the markets of each individual product group. The 
revised ELD could provide the scope for this leaving the final cons iderations for product 
specific technical studies and impact assessments  at the level of the implementing measures.  
As to employment effects, the impact a ssessment on the amendment of the Ecodesign 
2005/32/EC Directive identifies some evidence for job creation in Europe due to energy 
efficiency measures. While no evidence is ava ilable on the relations be tween energy labelling 
and employment, there are no reasons to assume  negative employment impacts induced by 
energy labelling. The labelling of products does not affect the overall demand for products; it 
just shifts demand towards more efficient pr oducts, which basically include more technology 
and added value, hence stimulates innovation.  
 
5.3.2 Expected impacts from improved functioning of the ELD 
Apart from its scope, the focus and the precise legal requirements of the ELD have an impact 
on its potential to reach and further contribute to the policy objectives. Some of the main 
issues with impact on achieving th e objectives are discussed below. 
In order to achieve more dynamic labelli ng the Commission could adopt implementing 
measures defining staged introduction of labelling thresholds defined in advance for ensuring 
that the "A" class would be populated only by a lim ited number of appliances (as far as it is 
technically possible to pred ict products' technological development and assessing 
corresponding impacts). As for option 1b, dynamism largely depends on the resources made available within the Commission to devel op new measures and on the support of the 
Regulatory Committee. The outcome  sought by the increased dynamism is the frequency of 
updated labelling scales, which should happen wh en the A class is populated by more than 
50% of appliances.   The extended ELD could provide a framework fo r public procurement and incentive schemes 
by Member States as shown in the SCP/SIP. Many Member States already provide incentives 
(e.g. rebate schemes) for energy performing produc ts and make significant efforts to green 
their public procurement practic e; however, the extent and level of this may differ from 
country to country.   The impact of harmonised energy efficient public procurement and incentives has been 
analysed in Annex 11. On public procurement, the main conclusion is that even very 
ambitious public procurement requirements can be  less expensive than current procurement 
                                                
 
74 Total savings potential from heating and water heating appliances is estimated to 77 Mtoe by 2020 of which 
energy labelling would catch close to 20 Mtoe (household 18 Mtoe + commercial 0,5 Mtoe). The rest of the 
savings (57 Mtoe) would come from minimum energy performance standards and EBPD requirments.  
 
34 practices and save substan tial amounts of energy and CO 2 emissions; public procurement can 
be used to accompany market transformation towards more energy efficient goods. The product groups considered show considerable sa vings potential. Public procurement rules on 
water heaters would save 18 Mt of CO2 and €1 .5 billion over the life cycle of the product. 
Similarly, energy efficient public procurement of  street lighting would save 8 Mt of CO2, 
corresponding to € 320 million over the life time of the product.  
Combining labelling with incentive schemes delivers equally positiv e and dynamic effects. 
An example on washing machines in the Netherlands, backed by a broad literature survey for energy-using and energy-related products indica tes that for every doubling of the cumulative 
volume sold, costs for these produc ts would decrease between 15-20 %.
75 The main 
conclusion is that the inclusion of provision s for incentives encourag es sales of innovative 
products. This is also importa nt for learning effects.  
In order to further minimize fragmentation in th e Internal Market, it would be beneficial to 
introduce harmonized measures wi thin the context of the ELD along the lines of what the 
Legislator recently introduced under the Energy Star Regulation76. In this way, the ELD 
would contribute solving information asymmetr ies for public procurers in line with Energy 
Star by showing the 'hidden' costs of use over the expected life span. Thus, the revised ELD 
should aim at linking Member  State public procurement a nd incentive schemes to the 
minimum efficiency thresholds indicated for these purposes in product specific implementing 
measures, backed by an impact assessment.  
 
Article 5 of the ELD makes provision on the c ontent of the implementing Directives in 
order to cover mail order and other sales situ ations, where th e potential customer cannot be 
expected to see the appliance displayed. As mentioned earlier manufacturers and retailers 
selling appliances publish regularly information on the efficiency level, even if not required 
in the implementing Directive, when the appliance is rated in the “A” class but fail to do so 
for obvious reasons when the appliance scores lo wer. This reduces the potential impact of 
the label. It is not expected that the situation would change  without mandatory requirements 
on the provision of information in mail orders  and in other distance selling, including the 
Internet.  
Legal provisions on adequate information woul d be particularly important in the case of 
advertising in the context of distant selling through various media, such as the Internet, 
newspapers, leaflets etc. Such information provision would help to convey the message on 
comparative negative environmental impacts (externalities) of all products covered by 
implementing measures/Directives and reduce information asymmetries. Administrative 
                                                 
75 Junginger et al (2008) Technological learning in the energy sector. This study has been performed within the 
framework of the Netherlands Resear ch Programme on Scientific Assessment and Policy Analysis for Climate 
Change (WAB). 
76 The current list of products covered include: Appliances (Battery Chargers, Clothes Washers, Dehumidifiers, 
Dishwashers, Refrigerators & Freezers, Room AC, Room  Air Cleaners, Water Cool ers ) Heating & Cooling 
(Air-source Heat Pumps, Boilers, Central AC, Ceiling Fa ns, Dehumidifiers, Furnaces, Geothermal Heat Pumps, 
Home Sealing (Insulation), Light Commercial, Programmable Thermostats, Room AC, Ventilating Fans) Home 
Envelope (Home Sealing (Insulation and Air Sealing), Roof Products, Windows, Doors, & Skylights), Home Electronics (Battery Charging Syst ems, Cordless Phones, Combination Units, Digital-to-Analog Converter 
Boxes (DTAs), DVD Products, External Power Adapters, Home Audio, Televisions, VCRs), Office Equipment 
(Computers, Copiers and Fax Machines, Digital Duplicators, Notebook Computers/Tablet PCs, Mailing Machines, External Power Adapters , Monitors, Printers, Scanners, a nd All-in-Ones), Lighting (Compact 
Fluorescent Light Bulbs (CFLs), Residential Light Fixtures, Ceiling Fans, Exit Signs), Commercial Food Service 
(Commercial Dishwashers, Commercial Fryers, Commerc ial Hot Food Holding Cabinets, Commercial Ice 
Machines, Commercial Solid Door Refrigerators & Freezers, Commercial Steam Cookers), Other Commercial 
Products (Battery Charging Systems, Exit Signs, External Power Adapters, Roof Products, Vending Machines, 
Water Coolers). 
 
35 burden for manufacturers and re tailers would be limited to advertising in the case of low-
efficient appliances given that the provision of labelling informa tion on 'A' level appliances is 
already commonplace. Accordingly, the ELD should allow setting requirements to display the 
energy class of a product in mail order, media advertising and other di stant sales situations 
leaving the details of these requirements fo r each product specific implementing measure.  
Input from stakeholders showed that there is a need for legal protection of the energy label 
against possible fraudulent use. The label coul d primarily be protected by public law which 
means that under the basis of the ELD (Article 95 of the EC Treaty), Member States protect 
the label through market surveillance and enforce it with the means of ad ministrative law (e.g. 
fines, decision or banning of the product). Some stakeholders re quested private law 
protection, which would mean that the energy la bel be protected by intellectual property law 
in the territory of the European Economic Ar ea (this in practice would mean a sort of 
trademark protection). However, the label as  it looks currently, du e to its commonplace 
elements, cannot be protected with the means of  intellectual property law unless a specific 
trademark is added to the label. The impact of such an exercise should be subject to a 
thorough analysis (for example, even the "Community flag" is not the property of the EU, but 
of the Council of Europe).  A discussion paper on veri fication and enforcement
77 showed that one of the shortcomings of 
the ELD was the enforcement of the labelling in the field. Although the market surveillance 
authorities have discretion to decide what to  do with a retailer/manufacturer that has a non-
compliant label (normally a warn ing, fine or banning of the product), enforcement of proper 
labelling is often weak and lack of resources is cited as the reason. Therefore, a framework on 
better and less burdensome enforcement in th e amendment of the ELD could be useful. 
However, this would not include any add itional market surveillance but just the 
implementation of the existing requirements stat ed in Community legislation. In particular, 
aligning requirements with the Ecodesign Directive seems appropriate.  The background study estimates that  the administrative and trans position cost together is 5 €
78 
million for the development of new implementing Directives. The cost for upgrading the existing ones is estimated to  € 4.7 million per Directive
79 (see more detail in  Chapter 5.5 and 
in Annex 12). 
Stakeholders welcomed the broadening of the scope to energy-relate d products, which would 
offer additional savings opportunities. Italy a nd UK reminded about the importance of impact 
assessment in defining the products to be covered. Euroace did not  support labelling of 
insulation products. Vehicle parts were c onsidered out of scope. Also, additional 
improvements to the ELD functioning, such as re quirements on display of  label in distance 
selling and on media, legal prot ection of the scheme and the us e of implementing regulations 
or decisions instead of Dir ectives, was supported by stakehol ders. Consumer groups, green 
NGOs and Eurocommerce requested clear labels focusing on energy consumption in use as 
the main information. Consumer groups and NGOs  also requested labelling information to be 
indicated in second-hand shops. Industry, in particularly CECE D and Marcogaz requested that 
each actor be held responsible for its tolerances (manufacturer s vs. test laboratories) and 
requested explicit figures on these tolerances . Support to implementation through Regulations 
rather than Directives was unanimous due to it s cost-effectiveness (For details see results of  
                                                 
77 Frank Klinckenberg: Discussion Paper. Experiences with Verification and Enforcement of the EU Energy 
Label. 
78 €1 million of administrative cost for the revision and €4 million for the transposition by Member States. 
79 €720.000 for the development/revision of the implementing Directive and €4 for transposition by Member 
States. See chapter 5.5. 
 
36 the stakeholder consultation in Annex 13 and on 
http://ec.europa.eu/energy/demand/legi slation/domestic_en.htm#consultation ). 
  
5.4 Policy option 4: Repeal the ELD an d implement energy labelling within the 
Ecodesign Directive 
As discussed above and in the Annex 10, re pealing the ELD without implementing its 
provisions in other Community legislation is considered as an unacceptable option both from the point of view of stakeholde rs and of its expected impacts. The ELD is the well known EU-
wide instrument to address poten tial purchasers with comparativ e information on consumption and 
cost of an appliance in the us e phase. Ecodesign sets minimum re quirements for putting products on 
the market and addresses all environmental para meters throughout the whole life cycle of the 
product.  
Under the EPBD, the performance of the whole building (overall performance of the building 
integrating the physical characteri stics; building shell and its desi gn, shape, construction material 
etc.) is labelled, including lighting, heating and air- conditioning installations in the relevant climate 
zone. Some Member States may even include in th e label the impact of ot her electric appliances 
although this is not a mandatory requirement. Th at is, apart from selected appliances, EPBD 
includes the whole system and its co ntrols. This is important as even the most efficient appliance 
(e.g. a motor) can not compensate losses due to ba d controls or system characteristics. The same 
applies in the other way around; even the most effi cient system does not help  avoiding the losses of 
an inefficient appliance. Moreove r, the EPBD falls unde r the national bui lding codes and the Article 
175 of the Treaty while the ELD is based on Article 95. 
Accordingly, this policy option includes rep ealing the ELD and implementing its provisions 
instead through the Ecodesign Directive as en visaged in the Action Plan on SCP/SIP. The 
Ecolabel and Energy Star would continue coexisting with syne rgies and complementarity, as 
described in Annex 2,  with the difference that Ecodesign w ould cover the application areas of 
both the ELD (comparative labelling of products  on the market) and th e Eco-desing Directive 
(setting minimum requirements for putting products on the market).  
One Directive instead of two would reduce the number of legislative instruments but would 
create other problems.  
First, there would be a need to integrate the eight existing labelling implementing Directives 
into the Ecodesign framework where they do not fit, in particular with the model 
implementing measure defined in Ecodesign Anne x VII. Also, as identified in the draft 
SCP/SIP Communication, the amendment of the Ecodesign Directive be yond its Article 1 (on 
scope) would not be appropriate  considering that the Direc tive was adopted recently (July 
2005), is not transposed yet by al l Member States and is in th e process of being implemented 
with the first draft measures being submitted to a Regulatory Committee.  
Second, the Ecodesign Directive sets requiremen ts (technical specifications to be met by 
products) on manufacturer s only, while the ELD se ts requirements also on  retailers (dispay of 
the label).The Ecodesign Directive addresses al l significant environmen tal parameters during 
the life cycle of the product while the ELD focuses on energy and other consumables during 
the use phase; the message is comparative and ta rgets product performance that is directly of 
interest to the consumer. Drastic changes would be needed to incorpor ate the ELD provisions 
and its implementing Directives into th e Ecodesign Directive, which would be 
disproportionate compared with  the benefits, and would risk  complicating rather than 
simplifying the legal framework.  
Putting requirements of to these two different  legislative instruments within one single 
Directive could seriously endanger the clarity of both Directives. As described above, the 
 
37 ELD has led to success because it provides a powe rful marketing tool for manufacturers and 
retailers, and a clea r message for customers (buy “A” to save money). It focuses on product 
performance in use phase directly  of interest to consumers. 
The criteria for successful (energy) labelling, as  presented above, are deci sive in assuring that 
information asymmetries and bounded rationality are avoided.  The energy labelling scheme 
must allow end-users to easily compare which product is more resource efficient during its 
use phase than another, thus help to avoid buyi ng products that are cheape r at the purchase but 
more expensive over the lif e cycle of the product.  
In addition, the lack of a pplicable methodology that woul d allow rating, comparing and 
ranking products on their globa l environmental performance (mixing energy consumption 
with emissions to air or soil, noise or recycl ability etc) throughout li fecycle makes that the 
introduction of a comparative “Ecodesign” label is not a feasible option at this stage. This is 
part of the reason why the Communication on SC P/SIP considers review ing the situation in 
2012. 
Third, the repeal of the ELD would not be understood by many stakeholders and by third 
countries that copied the scheme (see Annex 7) or intend to introduce it.  
What is said about public procurement under th e policy option 3 and about  administrative cost 
in chapter 5.5 would also apply under the policy option 4.   Stakeholders rejected this opt ion, including the indication of ot her environmental information 
over the life cycle of the product on the labe l. Consumer groups, supported by Italy and 
France, saw a particular danger in mixing th e energy label with other environmental 
information. They requested care in indicatin g any further such information on the label; 
''consumers need a simple message and carbon di scussion should be kept out of the label''. 
Eurocommerce reminded that sales personnel can  not take the responsibility to convey 
complex environmental information to consumers; the label must remind simple. 
Environmental NGOs stressed the urgency to a ddress energy consumption without affecting 
other environmental parameters. Within the in dustry, CECED did not see the indication of 
e.g. CO2 neither feasible nor enforceable while Or galime considered that it could be useful to 
open the label for the indication of  other environmental parameters . (For details see results of 
the stakeholder consultation in Annex 13 and on  
http://ec.europa.eu/energy/demand/legi slation/domestic_en.htm#consultation
. 
 
5.5 Administrative and transposition cost 
For the EU administration, the background study es timates the administrative cost to amend 
the ELD framework to about €1 million to whic h a transposition costs of some 4 € million 
should be added for the Member States. The co st for the development of new implementing 
measures or upgrading the existing one s is estimated to €720.000 per Directive80. The figures 
do not include overhead costs. 
The cost for transposition of (implementing) Di rectives by the Member States is estimated to 
about €4 million81 per new or upgraded implementing directive (see Annex 12). Assuming 
                                                 
80 The background study estimates that the administrative cost of developing a new Implementing directive is 
about € 720 000 per new Directive and that the revision of an existing Implementing directive would be half of 
this cost € 360 000)80. However, halving the cost for the revision of an existing Implementing directive is based 
on an assumption that the revision process would involve less work. However, revision of a Directive follows the 
same legislative process and in both cases a solid bac kground study is needed, as th e technological and market 
development makes the results of the initial study useless for revision. Accordingly, the cost of € 720 000 is used 
in this impact assessment for developing a new or revising an existing Impl ementing Directive/measure.   
81 27 Member States x €150.000 = €4.040.000. 
 
38 that the eight existing implementing Direct ives would be revised and two new ones82 be 
developed before the adoption of a possibl y revised ELD the total administrative and 
transposition cost for this action would be about € 47 million83 under the option 1b. 
Would any further implementing Directives  be developed or upgraded, the total 
administrative and transposition cost would be € 4.7 million84 per Directive. 
Transposition costs would be saved if the ELD was implemented with Regulations or 
Decisions instead of Directiv es. It can be assumed that, on the period of 2009-2011, about 10 
new implementing measures would be develo ped on the basis of the on-going preparatory 
studies85, which alone would correspond to the savi ngs of total transposition cost of €40 
million. To these savings should also be added th e savings from the fact that there would be 
no resources needed for the follow-up of the na tional transposition, infringement procedures 
or similar. Furthermore, it would bring important  advantages to the Internal Market and the 
industry as the absence of national transpositio n would ensure that implementing legislation 
came into force at the same time across the Internal Market in an identical form.  
The administrative cost caused due to labelling activity are closely related to the overall 
activities of the product policy, in particularly that of the Ecodesi gn Directive, as described in 
the impact assessment of the Ecodesign Directive. The main activities causing the administrative costs for Member States and the Commission are: 
 
• Definition of ELD implementing Directives/m easures; Ecodesign preparatory studies 
and product specific impact assessments.   
• The extension of the product scope of the ELD would broaden the choice of product 
groups for which implementing Directives/m easures could be adopted. If this would 
happen, the administrative expenditure w ould be covered by the usual annual 
budgetary allocation.  
• Costs for the Comitology procedure. (See Annex 12.)  
 The expected integrated decision structures of the Ecodesign Directive and the ELD and the informative role of the eco-label suggested in the SCP/SIP Action Plan will provide synergies 
which guarantee that resources are used  as cost-efficiently as possible.  
 As to the administrative cost for manufacturers and retailers, extending  the scope of the ELD 
implies that more products can potentially fa ll under the ELD implementing measures. The 
total administrative burden impact  depends on the nature of these measures and the number of 
products affected by each implementing measure. Th erefore it is here onl y possible to provide 
a general indication of the possi ble impacts on administrative burden. 
 The administrative burden due to a possible extension of the scope of the ELD, and 
subsequent increased number of implementing measures, is composed of actions as follows:    
 - printing labels and including them in product packaging (paid by manufacturers) 
- putting labels on products displaye d in shops (paid by  retailers) 
- testing products (paid by manufacturers bu t usually already part  of the cost for 
assessing compliance with other legisl ation like the Ecodesign Directive) 
                                                
 
82 Planned on TVs, boilers and water heaters. 
83 Administrative cost for developing/upgrading 10 implementing Directives x €720.000 and transposition cost 
of 10 implementing Directives x €4. 
84 Administrative cost of €720.000 + transposition cost of 27 Member States x €150.000. 
85 The most immediate candidates being vacuum cleaners, household fans, comfort fans, commercial 
refrigerators, commercial freezers, ce rtain types of solid fuel boilers and household lighting appliances  
http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm  
 
39 - industry 'self-policing' of voluntary agre ements, 'challenges' etc. (paid by 
manufacturers). 
 
To this can be added the activities paid by the governments for the 'enforcement' in shops and 
the 'enforcement' of the accuracy of effi ciency information. As can be seen, for 
manufacturers, administrative burden is limited to printing of the label and the strip. The rest 
of the activities will take  place as part of the normal business. The information provided in the 
label is already readily available for th e manufacturer and provi ded also in product 
documentation. The printing costs of several hundred  euros in relation to an appliance and the 
related information documentation and manuals a nd packaging seems neglig ible. It is to be 
noted that only the black-and-white strip needs to be put into each product packaging. The coloured background of th e label is to be prov ided in limited numbers by manufacturers to 
retailers for affixing on products to be displayed in shops, not for every product shipped (see 
Annex 4). Additionally, an info rmation fiche is provided with more complex technical 
information for customers willing to get more  detailed technical in formation on the product 
(see Annex 5).     It has to be noted that the administrative bu rden for manufacturers seems very small given 
that the existing provisions would not require 'a dditional' information but rather the provision 
of already existing information in a given agr eed format. It must be noted also that no 
additional market surveillance is requested  but only the application of the existing 
Community legislation on market surveillance in  line with the Ecodesign Directive. For 
retailers, administrative cost is the cost in displaying the label on the product. The burden for 
retailers of putting the label on the right appliance in shops l ooks minimal compared with the 
benefit of making available info rmation that allows comparat ive differentiation of products 
for consumers. 
  
S
ECTION 6: COMPARING OPTIONS  
As mentioned above, the possible extension of  the scope of the ELD does not change any 
direct costs or benefits for economic operato rs (except administrative cost for the EU 
Institutions and Member States ). They will only occur when implementing measures are set 
on specific products. Accordingly, table 6.1 shows some expected impacts of the considered 
policy options based on the exempl ary product groups analysed above.  
 
Table 6.186: Comparison of expected annual indi cative impacts (savings) of policy 
options against objectives and potential costs/burden – based on  consideration on 
selected product groups only  
Administrative and transposition cost/burden  
increased/reduced cost  Policy 
option Energy  
Mtoe by 
2020  Environment  
Mt of CO 2 by 
2020 Monetary 
 € billion by 
2020  Administrations  
(MS, EU)  Manufacturers and 
retailers 
1a Baseline Baseline Baseline Baseline Baseline 
 
1b  
22 Mtoes  
65   
€22 billion87 New or revised Directive = 
€4.7 million per Directive in Manufacturers: cost 
for printing and 
                                                 
86 Note that the table only summarises impacts from the broadening of the scope. Impacts and additional 
potential savings from improved functioning of the ELD, including harmonised public procurement and 
incentives, are summarised below.  
 
40 Mt of CO 2 total, including €4 of 
transposition cost.   including labels in 
product packaging 
and testing products 
(ca €3000/product88). 
Retailers: putting 
labels on products in 
shops. 
2 
 About as 
baseline About as 
baseline About as 
baseline +/- 
(Insufficient basis for 
estimates) Potentially reduced 
burden 
 
3 
  
27 Mtoes 
  
≈ 78  
Mt of CO 2 
  
€26 billion89 
+ improved 
competitivenes
s and innovation. Amend Directive = €5 
million in total, including €4 
million for transposition. 
If new or reviewed 
Directive = €4.7 million per Directive, including €4 
million for transposition. 
If Regulations or Decisions 
the cost is €720.000 (no 
transposition cost, that is, 
savings of €4 million from non-transposition cost Manufacturers: cost 
for printing and 
including labels in 
product packaging 
and testing products. Increased cost for 
testing and labelling 
of newly introduced products. 
Retailers: putting 
labels on products in shops. 
 
4 
  
27 Motes 
  
≈ 78  
Mt of CO 2  
€26 billion 
+ improved 
competitivenes
s and 
innovation. Amend Directive = €5 
million in total, including €4 
million for transposition. 
If new or reviewed 
Directives = €4.7 million 
per Directive, including €4 million for transposition. 
If Regulations or Decisions 
the cost is €720.000 (no 
transposition cost, that is, 
savings of €4 million from non-transposition cost Manufacturers: cost 
for printing and 
including labels in product packaging 
and testing products. 
Retailers: putting labels on products in 
shops. 
 
Figures in table 6.1 and elsewhere in this re port, including conversion between units, are 
based on the Ecodesign MEEuP methodol ogy and preparatory technical studies90 and on the 
EU Statistical pocketbook on Energy and Transport in Figures 2007/200891, as detailed in the 
above chapters and in relevant Annexes. For the average specific EU emissions, Eurelectric 
environmental statistics have been used. Despite  of the seemingly clear figures they hide a 
complex reality of interlinked impacts. These indicative figures will be further considered in product specific impact assessments. For the need s of this impact assessment, the relevance 
and underlying assumptions of the figures used have been approved th rough the Eurostat and 
Ecodesign processes.     
                                                                                                                                                        
 
87 Includes savings of about €15 billion from boilers and water heaters as defined in the Ecodesing Lot 1 and 2 
technical studies. Savings in electricity in upgrading th e old implementing Directives and developing new ones 
on televisions and lighting are calculate with electricity price of €0,136/kWh. 
88 Shared cost with Ecodesign. 
89 To be noted, for monetary savings of primary energy in commercial heating, the same relation has been used 
as in Lot ½ technical study on household heating and water heating appliances. 
90 The Ecodesign technical preparatory studies are based on a common (MEEuP) methodology:   
http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm 
91 http://ec.europa.eu/dgs/energy_transport/figures/pocketbook/ 
 
41 A particular issue is the defi nition of the border line betw een residential and commercial 
sector products. It may be easy in the case of e.g. smaller vacuum cleaners or coffee machines 
but be more difficult in the case  of vacuum cleaners of bigger size, which could also be used 
e.g. by SMEs in the commercial sector. This is w hy this impact assessment refrains in general 
from defining products specific to  these sectors but rather fo cuses on the type and power 
range of appliances most typica l to these sectors. However, in  the option 3 and 4, commercial 
heating and water heating applia nces and their savings potential have been considered on the 
basis of the Ecodesign preparator y studies on heating and water he ating appliances in general 
while this report focuses on 'commercial' heati ng and water heating only  (options 3 and 4). 
Considering the typical power ranges of these appliances used in each of these sectors92, an 
assumption of a possible 25% overlap of app liances between these sectors have been 
assumed. Moreover, the different conversion factors from energy to  CO2 take into account the 
difference between oil and gas as defined in  the Lot 1 and 2 Ecodesign preparatory studies93. 
The concrete impact of this on the aggregate figures on options 3 and 4 is that the conversion 
factors between units (Mtoes, CO 2 and €) do not match one-to-one. 
 Table 6.2 below compares the effectiveness, e fficiency and consistency of each policy option. 
 In summary, policy option 1b  can reach important energy savings involving minor 
administrative burden for manufacturers and retailers and no admini strative burden for 
Member States from the amendment in co-decis ion of the Framework Directive. However, an 
estimated transposition cost of €4 million for Me mber States from the transposition of each 
new or updated implementing directive is imposed.  
Stakeholder position varied fr om neutral to positive. 
Policy option 2  would not reach the objectives and wa s rejected by stakeholders, including 
industry.  
Policy option 3  can deliver the same energy savings as  the option 1b but would also open the 
way to further savings, subject to product specific preparatory studies and impact assessment. 
Using the recasting technique would keep the le gislative amendment proportionate and simple 
but would include an administrative burden of €1.2 million from the revision in co-decision of the ELD. However, if implemented with Regula tions or Decisions inst ead of Directives, €4 
million of transposition costs would be saved per every new or revised implementing measure 
(compared to option 1b).  
Apart from impacts due to a broadened scope of  the ELD, the revision would allow clarifying 
the framework provisions on information provision in distant selling on various media, legal 
protection of the label, prin ciples for measurement tolera nces and market surveillance 
activities. Also, the revisi on would allow setting a ha rmonised framework for public 
procurement and incentive across the Internal  Market with importa nt additional savings 
potential, e.g. emission savings of 18 Mt of CO 2 from water heaters an d 8 Mt of CO2 from 
street lighting, corresponding to savings of 1,5 billion vs. €320 million over the life time of 
the product respectively.  
These changes in the labelling scheme woul d allow upgrading the ELD according to the 
recent and expected market development, incl uding an adequate response to the continuous 
pressure on security of supply a nd climate change. In this cont ext, energy labelling must be 
seen as one crucial element in the broader context of market transformation within the 
SCP/SIP.  
                                                
 
92 Oil and gas boilers above 70 kW and water heaters of XXXL and XXXXL -sizes are used mainly in non-
residential sectors . 
93 http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm 
 
42 Policy option 3 had strong stakeholders support.  
 
Table 6.2: Effectiveness, efficiency and consistency 
 
Policy 
option Effectiveness 
 Efficiency 
 Consistency 
 
1a Policy objectives are not 
achieved  Some of the resources available for 
energy efficiency could be released; 
little resources are needed Negative balance of indirect 
impacts on environmental terms 
(no savings achieved beyond 
'negajoules') 
1b Most policy objectives 
can be achieved with 
savings of some 65 tons of CO2 based on 
considered product 
groups Resources available at present will 
allow achieving the expected 
impacts, except a major administrative burden from the 
transposition of the implementing 
Directives and unfavourable impact on Internal Market  Positive balance of environmental 
impacts, potential positive social 
impacts (employment impact) and positive balance on economy 
(savings for consumers and 
society, expected increased competitiveness and innovation). 
2 Unlikely to achieve the 
policy objectives Necessary resources needed are 
difficult to estimate due to expected 
scattered implementation of energy labelling with no guarantee of 
impacts Environmental balance unlikely to 
be positive. Positive balance for 
industry in short-term and negative in long-term, negative expected 
economic balance for consumers 
and for Internal Market operators. 
3 Specific objectives can 
be achieved with savings 
of some 78 tons of CO2 
based on considered product groups only. 
Potential to further 
benefits with legal 
protection introduced 
(reliability of scheme and use of regulations or 
decisions). Resources available at present will 
allow achieving the expected 
impacts, no significant resources 
needed by manufacturers or retailers. Potential to reduced administrative 
burden for Member States and 
Commission linked with increased 
positive environmental and economic 
impact. Positive balance of environmental 
impacts, potential positive social 
impacts (employment impact) and 
positive balance on economy (savings for consumers and 
society, expected increased 
competitiveness and innovation). 
4 Specific objectives can 
be achieved only (equalling to some 78 
tons of CO2), if 
requirements on retailers are included into the 
amended Directive.  Resources available at present will 
allow achieving the expected impacts, no significant resources 
needed by manufacturers or retailers. 
Potential to reduced administrative burden linked with increased positive 
environmental and economic impact, 
if implemented with implementing measures. Negative balance of unintended 
social impacts in form of unclear legislation, potential negative 
environmental impact from loss of 
clarity in labelling information. 
 
Policy option 4 , though technically capable of deliveri ng similar savings as policy options 3 
once the new legislation would be in place, woul d risk leading to confusion with two policy 
measures different in nature w ithin one single piece of legisl ation; one focusing on minimum 
requirements on energy-related products thro ughout the life cycle of the product with 
requirements on manufacturers only and anothe r one on the labelli ng of energy-related 
products with focus on use ph ase with requirements on manuf acturers and retailers. The 
legislative effort to import the energy effici ency labelling provisions into the Ecodesign 
Directive would not be proporti onate and would add complexity  instead of clarity for the 
stakeholders affected with risk to generating a label with unclear or confusing information to 
consumer.   
 
 
43 Cost-effectiveness  
 As already explained before, the extension of the scope of the ELD has little impact beyond 
making it possible to launch new implementi ng measures. The cost-effectiveness of 
implementing measures will be addressed in de tail in specific product impact assessments for 
which the Ecodesign preparatory t echnical studies provide input. 
 Based on the analysis provided in this impact assessment option 3 is the most cost-effective 
option.    
S
ECTION 7: MONITORING AND EVALUATION  
Monitoring and evaluation should be looked in the broader fr amework of the Sustainable 
Consumption and Production Policy and Sustaina ble Industrial Policy (SCP/SIP) together 
with the Action Plan on Energy Efficiency and relevant product policy instruments. As the 
Action Plan on Energy Efficiency94 states, monitoring and evalua tion capabilities of public 
authorities will depend to a la rge extent on the human and financial resources that can be 
attributed to these tasks at EU, na tional, regional and local level.  
 The Action Plan foresees regular reporting to the European Parliament. Monitoring on the 
ELD (Framework Directive) could provide information on the various stages of the 
implementation process of the ELD in line with the information provided on the advancement of the Ecodesign Directive, such as the number of preparatory studies launched and finished 
and implementing measures adopted. As foreseen  also for Ecodesign, collaboration with the 
working group of Eurostat on Sustainable Deve lopment indicators is envisaged to assess the 
possibility to include statistics on products fo r which implementing measures are developed 
(e.g. reporting market share of pr oducts per labelling category).  
 
The main indicator to monitor progress towards the specific objectives and to verify whether 
the implementation of the policy provides the expected results and contributes to the 
objectives of the Climate Pack age, the renewed Li sbon agenda and more  generally to the 
renewed Sustainable Developmen t Strategy, is the energy sa vings achieved with product 
groups labelled and the evolution of the leve l of efficiency of appliances for which 
implementing measures are in force by 2020.  
In the short term, evaluation s hould be implemented at the le vel of the existing Framework 
Directive and its implementing Directives. On th e medium term, the revised Directive and its 
implementing measures should be evaluated in order to more clearly measure and compare 
the impact of the amendment with the past achievements and the set objectives.  
Due to the general nature of Framework Direct ives, the specific objectives (energy saved as 
defined in Section 3) will be achieved by means of the operational objectives that are defined 
in each implementing measure, including the levels  for efficiency classes to be applied. These 
indicators are the changes in market share to wards higher efficiency appliances/classes over 
time and the amount of energy saved. 
The above indicators should be co nsidered as subject to fine-t uning, including possible shift 
in timelines according to the development of the implementation proce ss, in collaboration 
with the Member States through the Energy Labe lling Committee and affected stakeholders.  
                                                
 
94 COM(2006)545 final: http://ec.europa.eu/energy/action_plan_energy_efficiency/index_en.htm  
 
 
44 It is important to evaluate the impact of the implementing measures also  on the long term in 
coordination with the Eco-desing and other pr oduct policy instruments. Particular attention 
must be paid on the impact of each individual instrument. 
Many past evaluations of labe lling programs have focused on consumer awareness of the 
label but have not explicitly linked the label to actual behaviour (i.e., to the efficiency of the 
appliances purchased and to the most likely purchase if there had been no label). Future 
evaluations should be more comprehensive than  has been the case so far and include the 
analysis and assessment of all instruments foreseen for market-transformation under the 
SCP/SIP. 
 
 
45 ANNEX 1: PRODUCT GROUPS COVERED BY THE ELD  AND THE IMPLEMENTING DIRECTIVES  
The table below shows the coverage of hous ehold products by the ELD (Article 1) and 
products covered by the existing implementing Di rectives. Other household products, such as 
televisions or comfort fans, c ould be covered under Article 1.2 of 92/75/EC. Products beyond 
the household sector, such as commercial air-conditioning a nd refrigeration, industrial 
cooking appliances, indust rial motors, machine tools, and energy-related products that do not 
consume energy in use (e.g. windows) could be covered only if the ELD was amended or implemented within an amended Ecodesign Directive. 
Table on actual vs. possible coverage of products by energy labelling 
Household 
appliances 
covered by Article 1 of 92/75/EC Covered by 
implementing 
Directives Information provided on the label Information that 
could be provided 
on the label 
Refrigerators, 
freezers and their 
combinations  2003/66/EC 
(94/2/EC ) Energy efficiency class, energy 
consumption, fresh food volume, frozen 
food volume, noise Annual 
consumption or 
any other significant 
environmental 
impact or product performance 
characteristics  
relevant to use phase for 
consumers 
Washing 
machines, driers and their 
combinations 96/89/EC 
(95/12/EC ) 
 
95/13/EC  
 96/60/EC Washing machine
: Energy efficiency class, 
energy consumption, washing performance class, spin drying efficiency class, maximum 
spin speed, capacity, water consumption, 
estimated annual consumption, noise. Tumble drier
: energy efficiency class, 
energy consumption, capacity, water 
consumption, estimated annual 
consumption, noise. Washer-dryer : as 
above.   Idem. 
Dishwashers 1999/9/EC 
(97/75/EC ) Energy efficiency class, energy 
consumption, cleaning performance, drying 
performance, water consumption, noise Idem. 
Ovens 2002/40/EC  Energy e fficiency class, energy 
consumption (conventional and forced air convection), usable volume, size (S,M,L), 
noise Idem.
 
Water heaters and 
hot-water storage appliances  
No implementing measure was developed. 
Lighting sources 98/11/EC Energy effi ciency class, luminous flux, input 
power, average rated life of the lamp (hours). Idem.
 
Air-conditioning 
appliances 2002/31/EC Energy efficiency class, annual energy 
consumption, cooling output, energy 
efficiency ration, type, heat output, heating performance, noise. Idem.
 
 
 
46 ANNEX 2: EU POLICY INSTRUMENTS ADDRESSING ENERGY EFFICIENCY OF PRODUCTS  
This Annex illustrates the dynamic process created by various policy instruments with 
synergy, complementarity and overlaps of the va rious policy instruments addressing energy 
labelling. 
 
Graph 1: Interaction between Ecodesign, ELD and Ecolabel 
Policy instruments addressing
product energy efficiency
Product range Ecodesign Ecolabel
(voluntary)Energy labelling
(mandatory)
Best
WorstTier 1Phase 1 Phase 2
Tier 2
FORBIDDENFORBIDDENGRANTED ON
REQUESTExample of a coordinated and dynamic implementation of the instruments
Phase 2 is followed by a complete revision of limit values for all instruments.Benchmark Benchmark
 
 
Graph 2: Interaction between EU policy inst ruments addressing energy efficiency of 
products  
Policy instruments addressing
product energy efficiency
Ecodesign of
Energy-Using Products
Energy-Using Products Non-energy using
productsMinimum requirementsfor placing on the marketBenchmarks
for best productsMandatory
performancelabellingby producersby retailersVoluntary producer
labelling of best products
office householdother
(eg industrial)EU EcolabelEnergy Star
Energy
LabellingWith the exception of Energy Star, all instruments presented here allow addressing other
environmental aspects than energy use
Former directives on minimum
energy performance *
* of boilers, ballasts for 
fluorescent lighting and 
refrigerators, now implementing
measures of the EuP Directive
 
 
47 ANNEX 3: PRODUCT LABELS IN THE EU  
This Annex aims at giving an overview of the product labelling and, in  particular, of the 
energy labelling in the EU. There are three Comm unity product labels app lied in the Internal 
Market. The 'Energy Star' label is an endorse ment label used to show the most energy 
efficient office equipment (PCs, printers, faxes, copying machines, monitors etc.).  
 
 The Energy Star label is vo luntary and may be affixed by 
manufacturers only on those produ cts that meet the qualifying 
criteria (usually around 25% best range).   The Energy Star is a labelling programme owned by the US Government but the Community sign ed an international agreement 
with the USA in 2000 to coordina te energy labelling for office 
equipment using the Energy Star  scheme and logo. The Energy 
Star Programme was considered to  be more appropriate to follow 
fast evolving technologies used for office equipment and to cover 
equipment traded worldwide.   The Agreement was renewed in December 2006 for five years and currently provides for volunt ary labelling of 24 office 
products.   
 
 
The “Ecolabel” is a voluntary label. It acts as a label of excellence pr oviding the benchmarks 
for top performance for all environmental aspe cts during the complete product’s lifecycle. 
The Commission recently reviewed the Ecolabel  Regulation, which currently provides for 
voluntary labelling of 24 product groups.  
           
The main tool for energy labelling at EU leve l is the “energy label” under the ELD, which 
focuses on the energy efficiency of household appliances (on coverage  of product groups, see 
Annex 1).   
  
  
                    
 
 
48 This is achieved with the help of a transparent and easy-to-understand energy label, which is 
fixed at the point of sales on household ap pliances covered by specific implementing 
Directives. The label provides consumers compar ative information about the estimated energy 
consumption between similar appliances enabling  them to make a more informed purchasing 
choice in by alerting them on the cost of running the appliance.  
 In 1979, the Council passed a Directive
95 intended to introduce a Community-wide voluntary 
scheme for energy labelling of domestic a ppliances. The Directiv e allowed, but did not 
oblige, the Member States to introduce energy labels. However, due to a disagreement over 
technical measurement standards and their to lerances, none of the Commissions proposals 
was accepted by the Council. In a climate of general disinterest to make the voluntary 
European scheme work, several Member Stat es and industry groupings started developing 
their own voluntary schemes. As the voluntar y schemes proved to be failures, Denmark96 
notified a national obligatory scheme in 1983 . With a view to avoid several voluntary 
schemes based on different technical basis on a variety of products, and considering the 
Danish notification the Commission made a pr oposal for a harmonised scheme at European 
level in order to avoid hindering the functioning of the Internal Market. The ELD was adopted 
in 1992 introducing a framework that allows the Commission, assist ed by a regulatory 
committee, to adopt implementing Directiv es for specific household appliances.  
 The energy label is compulsory and obliges ma nufacturers to declare the energy consumption 
(and possible additional relevant information on the performance in use, such as noise or water consumption) irrespective if  the product is doing best (“A” class) or poorly (“G” class). 
The setting of criteria/classes under the ELD is based on the Ar ticle 95 legal basis ensuring a 
level playing field for industry and consumer s, including for a harmonised measurement 
method (standard) to be applied for the determination of the product performance. Under the 
ELD, there are eight Implementing Directives
97, three98 of which have been updated due to 
technological developments.  Beyond the primary objective of the energy labelli ng to save energy, the label also provides 
consumers with comparative information on the use of other resources such as water (e.g. 
dishwashers and washing machines) or emitted  levels of noise in use. The Ecodesign 
preparatory studies
99 have shown that typica lly more than 90% of the life-cycle environmental 
impacts of energy-using products take place during the use phase. As such, although the 
energy label focuses on consumption of resour ces in the use phase, it usually addresses in 
practice the most significant environmental im pacts over the life cycle of the energy-using 
product.   Currently, given that oldest existing implemen ting Directives have al ready had their impact 
(most sold appliances correspond now to the le vels A or B) there is no incentive for the 
industry to further develop more efficient appliances. Furthermore, even if such appliances 
would exist, there is no mech anism for the industry to mark et the more efficient products 
based on a reliable (harmonized ) European-wide scheme such as the energy labelling. For 
                                                
 
95 OJC, 145/1 of 13.06.179. 
96 Danish notification to the Commission OJL 109/8 of 26.04.1983. 
97 http://ec.europa.eu/energy/demand/legislation/domestic_en.htm#consultation   
98 94/2/EC on household electric refrigerators, freezers an d their combinations, 95/12/ EC on washing machines 
and 97/17/EC on dishwashers.  
99 http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm   
 
 
 
49 these appliances, there is a need to upgrade the criteria for the energy label. This is being 
prepared under the current ELD.   The success of the ELD labelling scheme is partly  due to it being used by the Member States 
for setting levels for incentives (rebate scheme s for the best classes)  but no quantitative 
information is available to estimate the actual effect of this. Minimum efficiency levels for 
national public purchases also push manufacturers to design appliances above the minimum 
level. The downside is that there are many different procurement/incentive levels across the 
27 Member States, and sometimes none at all.    
 
50 ANNEX 4: COMPOSITION OF ENERGY LABEL : LABEL AND STRIP  
The energy label is composed of a coloured  background label fixed on products displayed in 
shops and of a black-and-white strip provided with each product.  The information to be given 
on the label and strip is regulated in implem enting Directives. For printed packaging the 
energy label is black-and-white. 
Label:        S t r i p :  
                         
             
 
 Energy label for printed pa ckaging (e.g. on lamps): 
 

 
51 ANNEX 5: CONTENT OF AN INFORMATION FICHE  
This Annex shows an example of requirements se t on the content of the information fiche on 
dishwashers under the impleme nting Directive 97/17/EC. 
 "The fiche shall contain the following information.   The information may be given in the form of a table covering a number of models supplied by 
the same supplier. The information shall be gi ven in the order specified below unless it is 
contained in a more general de scription of the appliance: 
 1. Supplier's trade mark.  2. Supplier's model identifier.  3. The energy efficiency class of the model determined in accordance with Annex IV. Expressed as ‘Energy efficiency class … on a scale of A (more efficient) to G (less efficient)’. 
Where this information is provided in a table this may be expressed by other means provides 
it is clear that the scale is from A (m ore efficient) to G (less efficient). 
 4. Where the information is provides in a table, and where some of the appliances listed in the 
table have been granted a ‘Community Eco- label’ pursuant to Re gulation (EEC) No 880/92, 
this information may be included here. In this  case the row heading shall state ‘Community 
Eco-label’, and the entry shall consist of a copy  of the Eco-label mark. This provisions is 
without prejudice to any requirement s under the EU Eco-label scheme. 
 
5. Manufacturer's name, code or indication for the ‘standard’ cycle to which the information 
in the label and the fiche relate.  6. Energy consumption in kWh per cycle using st andard, cycle determined in accordance with 
the test procedures of the ha rmonized standards referred to 
in Article 1 (2), and described as ‘Energy c onsumption XYZ kWh per st andard test cycle, 
using cold water fill. Actual energy consump tion will depend on how the appliance is used’. 
 7. Cleaning performance class, determined in accordance with Annex IV. Expressed as 
‘Cleaning performance class … on a scale of A (h igher) to G (lower)’. This may be expressed 
by other means provided it is clear that the scale is from A (higher) to G (lower). 
 8. Drying performance class, determined in ac cordance with Annex IV. Expressed as: ‘Drying 
performance … on a scale of A (higher) to G (lower)’. This may be expressed by other means provided it is clear that the scale is from A (higher) to G (lower). 
 9. Capacity of appliance in standard place se ttings, as defined in Annex I, note VIII. 
 10. Water consumption per cycle in litres using st andard cycle, as defined in Annex I, note 
IX.  11. Programme time for standard cycle, determin ed in accordance with the test procedures of 
the harmonized standards referred to in Article 1 (2).  12. Suppliers may include the information in points 5 to 11 in respect of other cycles. 
 
 
52 13. The estimated annual consumption of energy and water equal to 220 times the 
consumptions expressed in points 6 (e nergy) and 10 (water). This shall 
be expressed as ‘estimated a nnual consumption (220 cycles)’. 
 14. Where applicable, noise durin g standard cycle, in acco rdance with Council Directive 
(EEC) No 86/594.  The information on the label may be given in th e form of a representation of the label in 
colour or in black and white." 
 
 
 
 
 
 
53  ANNEX 6: PROVISION OF PRODUCT INFORMATION IN THE ENERGY LABEL  
 
The Annex 6 illustrates how product informati on is displayed on the energy label with an 
example of a possible label on cooker hoods. In formation provided on the label focuses on 
product performances directly of interest to consumers allowi ng comparison between 
products displayed in shops or  in adverts. Product inform ation in the existing eight 
implementing Directives (see Annex1) follows this structure. 
 
 Example of a possible energy label on cooker hoods with use phase related information. 
 
 
        

 
54 ANNEX 7: ENERGY LABELS ADOPTED IN THIRD COUNTRIES  
This Annex provides a sample of energy labels  adopted in third count ries based on the EU 
energy label as a model. 
 
 
 
    
 
55 ANNEX 8: ENERGY LABELS ADOPTED IN OTHER SECTORS  
The Annex 8 illustrates how the EU energy label on household products has been applied in 
the building sector. There are similar applications  of the energy label in other sectors at the 
EU and Member State/third country level too (EU car label, window label in UK and 
Finland…).  
 
 
 

 
56  
   
 
 

 
57 ANNEX 9: ENERGY CONSUMPTION IN THE EU AND SAVINGS POTENTIAL OF APPLIANCES   
 
This Annex provides an overview of the energy consumption in  the EU in general and of 
energy consumption of appliances in part icular, including their savings potential. 
 Energy consumption in the EU is estimated to increase by 9% from 2005 to 2020 with current policies in place
100. The household, commercial and industr ial sectors (excluding transport) 
represent some 70% of the total energy consump tion in the EU, with energy savings potential 
of close to 30%. The current Energy Labelling Directive only allows addressing the energy 
efficiency potential of the household sector , which represents 25% of the total energy 
consumption in the EU. A revised/extended en ergy labelling could capture part of the 
potential from the commercial and industrial se ctors and contribute to the EU energy savings 
objective as set in the Action Plans on  Energy Efficiency and SCP/SIP.  
 The Action Plan for Energy Efficiency identif ied a high potential for energy savings by 2020 
in the household, commercial and industry se ctors (27%, 30% vs. 25%). In 2006, annual 
consumption of electricity by th e household sector in the EU- 25 was estimated to be in the 
region of 800 TWh and growing at just under 2.3 % a year
101.   
 In addition to the electricity consumed in operating household appliances such as white goods (fridge, washing machine, oven etc), lighting or  consumer electronics (TV, Hifi, gaming 
consoles etc), account also needs to be taken of  boilers and water heat ers.  Some 270 million 
tonnes of oil-equivalent are used for space heating in the EU-27 of which over 75 % was 
consumed in the household sector. Overall th e household sector in the EU-27 consumes 338 
Mtoe. 
 
Apart from boilers and water heaters, the consum ption attributable to the main categories of 
household appliances covered by the current sc ope of the ELD is shown in table 2.1.   
 
Table 1: Stock and energy consumption of household appliances – EU-25, 2004 
• Type of 
appliance • Stock 
(No of units, 
million) • Average 
unit energy 
consumption 
(kWh/year) • Total 
energy 
consumption 
(TWh/year) • Annual 
Sales 
(No of units, 
millions) 
• Refrigerators • 199 • 305 • 61 • 14 * 
• Freezers • 93 • 383 • 35 • 4.2 * 
• Washing machines • 169 • 217 • 36 • 13.8 * 
• Dishwashers • 71 • 286 • 20 • 5.8 * 
• Electric ovens • - • - • 15 • - 
• Lighting • - • 509 • 92 • - 
• TVs • - • 177 • 48 • 30. 6** 
• Other household 
*** • - • - • 457 • - 
                                                 
100 COM (2008) final annex. 
101 Europe's environment - The fourth assessment,  European Environment Agency, State of the  environment 
report No 1/2007.  
 
58 • Total • - • - • 767 • - 
  *The figures are the sum of sales in 2004 fo r West European countries and CZ, HU, PL and SK. 
  **Figures are for EU25+, 2003 
– Source: Odysee, NMC, Ecodesign studies 
***consumer electronics (except TVs), air conditi oning, electric heating and water heating, ICT… 
 
Detailed data is available only for a subset of  appliances that account for roughly 300 TWh of 
electricity consumption102. Lighting, for which labelling has had a relatively low impact till 
now, is a major area of consumption, almost doubl e the level for televisions which are not yet 
subject to mandatory labelli ng. Electric heating, air conditi oning equipment and consumer 
electronics/ICT account for the bulk of electricity consumpti on not listed in this table. 
 The breakdown of electricity consumption by all categories of end use equipment is shown in 
figure 2.1 for EU-15 and in  Figure 2 on the new Member States in 2004. H eating equipment and consumer electronics 
represent the main equipment not  currently subject to mandatory labelling for the household 
sector. 
 
 
Figure : Breakdown of 704 TWh of electric ity consumption among residential end-use 
equipment – EU-15, 2004 
– Refrigerator/Freezer
s, 15%
Washing Machine, 
4%
Dishwasher, 2%
Drier, 2%
Room air-
conditioning, 1%
Electric Storage 
Water Heater, 9%
Electric Ovens, 2%
Electric Hobs, 5%
Consumer 
electronics and 
other equipment 
stand-by, 6%Lighting, 12%Tv on Mode, 3%Office Equipment, 
1%Residential Electric 
Heating, 22%Central Heating 
Circulation Pumps, 
4%Misc., 12%
 
– Source: European Commission Status Report 2006, "Electricity  Consumption and Efficiency Trends in the Enlarged European 
Union" 
                                                 
102 No detailed data is available on electric heating, of fice equipment, driers, air conditioning, water heaters, 
electric hobs, etc.  However, figures 2.1 and 2.2 report a breakdown of consumption for more categories.   
 
59  
Figure 2: Breakdown of 63 TWh of electric ity consumption among residential end-use 
equipment – New Member States, 2004 
Refrigerators/Freezer
s, 22%Consumer Electronics 
and stand-by, 13%Misc., 7% Heating/Cooling, 10%
Lighting, 20%
Washing Machines, 
11%Cooking/Dishw asher, 
10%Electric Storage Water 
Heater, 7%
 
Source: European Commission Status Report 2006, "Electricity Consumption and E fficiency Trends in the Enlarged 
European Union" 
 
The ELD only covers household appliances. However, the savi ngs potential of other energy-
using and energy-related appliances is significa nt, which to some extent could be addressed 
with energy labelling. Depending on the type of product and market, the provisions of the 
ELD can be used either for the setting of th e label together with product information on 
products displayed in shops/outlets or for the setting of levels for efficiency classes only 
without the label for products sold in the OEM market. For ex ample, the figure 3 shows the 
efficiency levels corresponding to the efficiency classes on the energy label of refrigerators. 
Energy efficiency levels are calculated for each  appliance according to its consumption and its 
compartments' volume taking into account the app liance type. The level is thus not calculated 
in kWh but provides efficiency levels on a comparative basis. The value of the efficiency level speaks more for experts and informed purchases while the comparative energy efficiency class is more easily unders tood by non-professional customers. 
 
Figure 3: Energy efficiency index and e fficiency levels on refrigerators  
A++ A+ A B C D E F G 
<30 <42 <55 <75 <90 <100 <110 <125 >125
 
At best, the provision of energy efficiency information is combined with information 
provision requirements under the Ecodesign Dir ective, which allows addressing both non-
professional and professional OEM purchasers, who might be more  conscious of the cost of 
running and maintaining equipment.   
 
60 The background study and the Ecodesign prepar atory studies have identified savings 
potentials of selected products as follow103: 
 
• Industrial motors: 9.85 TWh/a would be saved, if today's motors were replaced by IE2 
level motors and an additional 5.55 TWh/a w ould be saved with IE3 level motors. In 
the service sector, th e respective amount would be 7.85 and 3.65 TWh/a;  
• Commercial refrigerators and freezers, includ ing chillers, display cabinets and vending 
machines: total estimated 21 TWh savings potential by 2020. As most  of this will be 
achieved by Ecodesign some quarter of th e savings could be achieved by energy 
labelling;  
• Windows: € 4 billion/a savings (25 million tonnes CO 2) would be reached if the 
conventional double glazing was replaced by low-e windows. Although a significant 
proportion of those savings would also be in  the household sector, windows cannot be 
covered under the current ELD  as they do not consume energy in the use phase. 
 
As a main commercial product, refrigerators an d freezers, including chillers, display cabinets 
and vending machines, would offer an estimated 21 TWh savings potential by 2020104. These 
appliances are among the best candidates for ener gy labelling in the commercial sector. It can 
be estimated that energy labell ing could reach some quarter of this potential analogously to 
the household cold appliances, corresponding to 4-6 TWh of savings by 2020. The lower relative energy savings reached by energy labelling from these appliances compared to household appliances in general is due to the type of markets in which the 'user' is not always 
responsible for the purchase decision. Also, ther e is an 'overlap' of household and commercial 
appliances meaning that the present implemen ting Directives already include some 25% of 
the refrigerator and freezer sizes used in commercial sector, e.g. in SMEs. 
As a main industrial product, motors have be en proposed by stakeholders to be addressed 
with energy labelling, which at the first gl ance could make sense. However, the Lot 10 
Ecodesign preparatory study
105 advises to label motors under the new ISO 60034-30 motor 
efficiency standard rather than under the ELD. The ISO standard includes an efficiency 
classification and thus provides a globally accept ed basis for motor efficiency labelling. A 
simple indication of the efficiency level on th e motor name plate and in the documentation is 
a more cost-efficient way of handling the labe lling of a product mainly  traded in the OEM 
market (industry to industry business). This could be achieved under th e Ecodesign Directive 
(where retailers are not to be  addressed). The same applies to fans and pumps which do not 
necessarily require labelling under ELD. Howe ver, labelling under the ELD would most 
probably make sense in the smaller power ra nges of these products, as they are more 
frequently put on the market  through outlets/shops.   
However, it can be difficult to define th e boundaries between 'r esidential/household', 
'commercial' or 'industrial' product. The same  lighting, refrigeration or air-conditioning 
household appliance could be used  also in the smallest SMEs in the commercial sector. The 
approach to partially solve this problem in most  reports is to consider appliances that are 
intended for households as household appliances, regardless in which sector they are used. 
The same applies to the border line between co mmercial and industrial products (e.g. motors, 
pumps, ventilation and air-conditioning products).  
 
                                                 
103 Background study on industrial motors and windows and Ecodesign preparatory study lot 12 on commercial 
refrigeration:  http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm#studies 
104 Ecodesign studies: http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm#studies   
105 http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm   
 
61  ANNEX 10: ACHIEVEMENTS OF ENERGY LABELLING AND PROBLEMS THEREOF  
 
This Annex provides a more detailed descriptio n of the achievements of the energy labelling 
than the body text, including complementary information on problems related to energy 
labelling.   In the absence of systematic monitoring and ev aluation of the ELD over the past years, a 
specific background study
106 was launched by the Comm ission. The background study, 
together with a number of other reports on the performance of the energy labelling, provide a 
clear broad picture on main issu es at stake, although many of the details are beyond the reach 
of this report.   There have been a number of studies on the impact of the ELD
107, including the external 
background study to this  report.  The studies demonstrate an increased take up of higher 
efficient appliances over the past decade. The impact has been greatest for white goods, 
particularly refrigerators, freezers and wash ing machines. The take up of higher energy 
efficient appliances has been greater in the EU -15, where the directives have been in place for 
a longer time, than in the new Member Stat es. However, the New Member States are 
currently making a leap directly to A-class appliances thanks to the label that has made manufacturers less interested in producing lo wer-efficiency appliances. The success of the 
labelling scheme is also demonstrated in the hi gh number of third count ries that have adopted 
a similar label or sometimes an ex act copy of the EU energy label
108 as show in Annex 7. 
Also, the energy label has been recently copied  by other sectors within the EU and third 
countries (see Annex 8).  
It is estimated that with all current policies already in place, a total of 65 TWh to 75 TWh per 
year would be saved by 2010
109. While it is difficult to separate out the impact of labelling 
from other factors such as minimum efficiency  standards or "busines s as usual" technical 
development, it has been estimated that energy labelling schemes could account for about half 
of the increased take up of highe r energy efficient appliances, cont ributing in total to some 35 
TWh of savings per year (2010) 110 and corresponding to some 3 Mtoe111 of primary energy.  
The rest of the savings is composed mainly of technological development and minimum energy performance requirements set under Dir ective 2005/32/EC (Ecodesign Directive) for 
                                                
 
106 Study on a possible extension, tightening or simplification of framework directive 92/75/EEC on energy 
labelling of household appliances, Report by Europe Econo mics and Fraunhofer-ISI with BSR Sustainability and 
FfE, 19 October 2007.   
107 E.g. OECD/IEA, Energy labels and standards, 2000; GSK and Fraunhofer ISI, 2001, Evaluating the 
Implementation of the Energy Consumption Labelling Ordinance; IEA, 2003, Cool appliances: policy strategies 
for energy efficient homes;  Atkins ad ATN, 2006, Impact Assessmen t of the Future Action Plan for Energy 
Efficiency; European Commission Joint Research Center, 2006, Electricity Consumption and Efficiency Trends 
in the Enlarged European Union; Benoit Lebot (UNDP- GEF) and Paul Waide (IAE), The European Energy 
Label: An energy efficiency success story with an imp act beyond EU borders; ANEC-R&T, 2007, A review of 
the range of activity throughout Member States related to compliance with the EU Energy Label regulations in 
those countries  
108 Benoit Lebot and Paul Waid e, The European label: an energy effici ency success story with  an impact beyond 
EU borders. 
109 Electricity Consumption and Efficien cy Trends in the Enlarged European Union – Status Report 2006. P 
Bertoldi, B Atanasiu. 2007  
110 Background study: http://ec.europa.eu/energy/demand/legislation/domestic_en.htm#consultation 
111 Estimated electricity savings by the ELD are about 35 TWh by 2010. For convenience, savings in electricity 
(TWh) are converted to savings in primary energy (Mtoes). A conversion factor of 0,086 is used based on the EU 
Energy and Transport in Figures, Statistical pocketbook, 2007/2008.  
 
62 fridges, freezers, ballasts for fluorescent lightin g and hot-water boilers. For example, as to 
cold appliances, it has been estimated that  between 1996 and 2004, the average efficiency of 
newly purchased cold appliances improved by 30 per cent, dishwashers by 35 per cent and washing machines by 23 per cent. The above estimate on the savings due to energy labelling is supported by a report from CECED estimati ng that annual electricity consumption by 
appliances installed in European house holds fell by 34 TWh per year on 1995 to 2005
112.  
 The scale of the current take up of higher effici ency appliances can be seen in Table 1 and 
Figure 1 for the EU15.  
Table 1: Energy rating of household appliance - percentage of sales – EU 15, 2004-05 
•  • % A or 
above • % B • % C or 
below 
• Refrigerators • 61 • 30 • 9 
• Freezers • 47 • 26 • 27 
• Washing machines • 79 • 11 • 10 
• Dishwashers • 81 • 11 • 8 
• Electric ovens • 47 • 37 • 16 
• Lighting (households) • 54% households with some CFLs    
–  Source: EC Status Report 2006 
As one sees for all household appliances (exc luding lighting), the majority of products are 
either rate B or above.  (We discuss the new Member States below).    
 
Figure 1: Energy rating of household appliance - percentage of sales – EU 15, 2004-05 
0102030405060708090100
Refrigerators Freezers Washing
machinesDishwashers Electric ovens%
% A or above % B   % C or below  
– Source: EC Status Report 2006 
                                                 
112 Energy Efficiency, A shortcut to Kyoto Targets.  The Vision of European Home Appliance Manufacturers.  
Ceced 2006.  
 
63 As has been emphasised in an IEA report113, the introduction of the labelling programme has 
shown a marked progression toward s the more efficient categorie s (A appliances). The figure 
below illustrates this, with fewer and fewer products  being sold in the less efficient classes of 
D or below.   
Figure 2: Share of EU cold appliance market by labelling class from 1990-92 to 1999 
• 
  
–   Source: Waide 2001 
 
As an example we can look at refrigerators.  Recent market data on the share of energy 
efficient appliances suggests that the EU mark et for refrigerators is moving towards a higher 
share of most efficient classes of appliances (i.e . the impact of labels on refrigerators seems to 
have been quite important).  
Figure 3: Labels impact on EU refrigerator market 
01020304050
ABCDEFG%
EU Market 2003 EU Market 1999 EU Market 1996 EU Market 1992
 
– Source: Waide 2004 
                                                 
113 IEA, 2003, Cool appliances: policy st rategies for energy efficient homes. 
 
64 Encouragingly, within the new Member States the number of A rated appliances sold is also 
high, as can be seen in the case of washing machines.  
 
Figure 4: Breakdown of 13.8 millions of sales per washing machines classes in EU, 2004 
0102030405060708090100
West Center-East
A+ A B C Others 
Note: 8 Countries East: PL, CZ, SK, BG, SI, RO, HU, and HR; 
10 Country West: AT, BE, DE, ES, FR, GB, IT, NL, PT, SE Source: Overview of sales and trends for main appliances, GfK 2004 
 
The benefit of more efficient pr oducts being sold also  has an impact on the stock of products.  
As older products are replaced, th e flow of new, more efficient,  products adds to the existing 
stock of products.  This means over time the en tire stock of products becomes more efficient 
and so energy savings accumulate.   It has been estimated that between 1996 an d 2004/05, the average efficiency of newly 
purchased cold appliances improved by 30 per ce nt, dishwashers by 35 per cent and washing 
machines by 23 per cent. It is estimated that with the current policies already in place, 65 
TWh to 75TWh per year could be saved by 2010
114. It is assumed that more than half, some 
35 TWh (3 Mtoe), is due to la belling, the remaining part is due to structur al technical 
improvements.115 Industry comes to conclusions of th e same order of magnitude estimating 
that annual electricity consum ption by appliances installed in European households fell by 34 
TWh between 1995 and 2005, a fall of 12 per cent.116 
 These results are similar to those in third count ries, e.g. in Australia and Switzerland when the 
provision of information on appliance running cost s has been increased. From the Australian 
NAEEP programme there is evidence to demonstr ate decreases in energy consumption of 1 to 
6% and increases in energy efficiency of 1.4  - 3.6% across the use of  5 main appliances 
during the period 1993-2001. It has been estimated if labelling had not been introduced, the 
annual electricity consumption of  all new appliances (of the types labelled) in 1992 would 
have been about 11% higher than it was, and the total household electri city consumption in 
Australia would have been about 1.6% higher. Projections from the Swiss E2000 energy label 
(which were granted only to appliances which met targets of power consumption in different 
                                                
 
114  Electricity Consumption and Efficiency Trends in the Enlarged European Union – Status Report 2006. 
P Bertoldi, B Atanasiu, 2007.  
115 Impact Assessment Report for the Actio n Plan for Energy Efficiency 2006:  
http://ec.europa.eu/energy/action_pl an_energy_efficiency/index_en.htm   
116  Energy Efficiency, A shortcut to Kyoto Targets.  The Vision of European Home Appliance 
Manufacturers,  Ceced 2006.  
 
65 modes of operation, linked to running costs) also  estimated savings of approximately 1% of 
Switzerland’s overall electricity consumption.117   
 Using only energy savings as a benefit (tha t is allocating no monetary value to the 
environmental benefits), the NAEEEP is projec ted to deliver almost 4.2 billion Australian 
dollars to the community (after the projected $2.6 billion costs are deducted from the $6.8 
billion energy savings at 10 % discount rate by  2018). This experience suggests that such 
schemes to increase awareness of running costs/en ergy efficiency are cost  effective. Savings 
can be achieved at a negative cost to society. Th e extra costs of more efficient appliances are 
offset by savings in running costs over the life of the appliance. No effect expected on 
availability or cost of inputs, access to finan ce or investment cycle. Action will promote the 
most efficient technologies ava ilable over inefficient technologies. 
  
Table 2: Overall effectiveness of labelling 
•  • Compliance• Importance 
of energy 
efficiency • Influence 
of label on 
purchase 
• Denmark • *** • *** • 56 
• Netherlands • *** • *** • 45 
• Austria • ** • *** • 39 
• Sweden • ** • *** • 39 
• Finland • ** • ** • 41 
• Portugal • * • ** • 35 
• UK • *** • * • 24 
• France • ** • * • 32 
• Ireland • ** • * • 15 
• Spain • * • * • 19 
• Greece • * • * • 4 
Note: ***>70%; **50-70%; *<50% 
– Source: Shiellerup, Winward, Boardman, Cool Labels 1998 
The background study also note that the Europ ean energy label design has been successfully 
copied in a number of other ju risdictions for a number of produc ts (for illustration, see Annex 
7). Nonetheless, one must be careful not to a ttribute the increase in sa les of energy efficient 
products wholly to energy labelling. Given th e range of policy instruments directed at 
encouraging the take up of energy efficient prod ucts and the financial benefit to consumers 
from reduced energy costs, it is difficult to a ttribute a specific degree of influence to the 
introduction of the mandatory labelling schemes. One study118 suggested that the impact of 
labelling was closely linked both to the level of compliance and to general awareness of the 
importance of energy efficiency.  It was told th at in favourable circumst ances the existence of 
the label could account for over half of the take  up of the higher efficiency appliances. 
   
These studies also identified probl ems with labelling.  In the ear ly years, compliance in terms 
of failure to display labels or incorrect label ling, was an issue.  The situation has improved but 
                                                 
117 Impact Assessment Report for the Ac tion Plan for Energy Efficiency 2006: 
http://ec.europa.eu/energy/action_pl an_energy_efficiency/index_en.htm   
118 Shiellerup, Winward, Boardman, Cool Labels 1998 
 
 
66 compliance remains a concern.  The design of th e label has generally been commended for its 
effectiveness in signalling relative efficiency  of products but there has been concern that 
consumers can be confused by a mix of formal and informal advice.  More recently criticism has focused on the fixe d nature of the A-G scale and the need to 
recalibrate the scale to allow for improvement s in technology which ha ve taken place since 
the scale was first set which mean that “A” rate d products are no longer at the leading edge of 
energy efficiency. A more detaile d description of the directives  and of the main evaluation 
studies is given in Appendi x 1 of the background study. 
 The background study identifies some positive social impacts  due to the broadening of the 
scope of the ELD but the impact s are rather speculative. A nyhow, energy labelling does not 
have the same possible short term social im pacts on low income households than minimum 
performance requirements might have, as it does not cut off products from the market. On the 
contrary, energy labellin g guides consumers towards appliances that are cheaper over the life 
cycle of the product and as such better also for the environment and society. Doing so, it 
promotes increased demand of higher energy e fficient appliances implying that over time the 
cost of these appliances will go down due to increased demand, which is positive particularly 
for low income households. Energy labelling doe s not put a constraint  on household budget or 
restrict the choice of products but guides consumers towards the most economic and 
environment-friendly products over the life cycle of the product. To help low income households to benefit from these savings, ap art from labelling information, incentives for 
consumers are useful to further facilitate the uptake of higher cla ss models, taking into 
account the specific economic and market situa tion in each Member State. Also, public 
procurement can support this objective in crea ting demand for high-efficient appliances and 
help reducing the price through hi gher production series.      
 
 
 
67  ANNEX 11: ENERGY EFFICIENT PUBLIC PROCUREMENT AND INCENTIVES  
 
This Annex describes the problems that can be  tackled and the potential impacts (positive and 
negative) of changes to public procurement and incentives included in Options 3 and 4. 
Option 3 includes amending the ELD with covera ge of all energy-using products (excluding 
means of transport) and energy-related produ cts. The ELD would be implemented through 
implementing measures rather than through Dire ctives, and they would serve as a framework 
for Member State public procurement and incentives across the Internal Market.  
 Option 4 includes repealing the ELD and impl ementing its provisions through the Ecodesign 
Directive. It would cover the same scope and include the same actions and general 
implementation framework as analysed under the option 3. 
 
1. Problems
 
 
• Significant energy use and the related enviro nmental impact from public authorities' 
energy-using products: 
 
Energy consumption from public authority use of products forms a notable part of the 
problem tackled by the ELD in particular  once expanded beyond household appliances. 
Public authorities spend around 16%  of the EU's Gross Domestic Product. Part of this is 
spent on energy using products covered by th e ELD with often even greater shares of 
expenditures on the energy used by the product during its lifetime.  
• Purchasing practices by public authorities cost them more over the lifetime of the 
product when purchasing cheaper but energy inefficient products 
 
Public authorities will lose significant amounts of money each year if they do not take into 
account the costs of the energy use of produc ts when deciding on which products to buy. 
Although limited budget availability would incite  public authorities to opt for products 
with lower purchasing price, they risk paying more at term for its use (even where energy 
labels are in place). 
 
• Slow market uptake of more energy effici ent products holds back price decreases 
and innovation in energy efficient products 
 
The failure of consumers, including public pur chasers to take into account energy prices 
reduces sales of energy efficient products. Sl ow increases of market share for more energy 
efficient products in turn reduces the return on investments in energy efficient design: – as 
manufacturers get longer pay back periods for any investments to improve their products, 
so are less willing to invest. Over time, the slower rate of improvements in energy efficiency will have a great effect on future energy use. This slow rate of improvement holds back energy saving goals. 
 
2. Objectives
 
 
Better Public procurement and the introduction of incentives in Options 3 and 4 have the 
following objectives:  
• To reduce costs for public authorities (over the lifetime of products) by reducing the 
annual energy bills; 
 
68  
• To reduce consumption of energy and of ot her essential resource by products bought by 
public authorities; 
 
• To promote innovation in energy efficiency of  products, by increasi ng the sales of the 
more energy-efficient products on the market; 
 
• To avoid confused market si gnals to producers from a sca ttergun of incentive schemes. 
 
 
3. The 'Do Nothing Scenario' – problems with current practices  
 
A) Inefficient and costly Public pr ocurement of energy using products 
Currently, public procurers often buy products which are more expensive for the authority 
than other products on the market, particularly  once the running costs ar e taken into account. 
Taking an example from the market for water boilers (from an Ecodesign preparatory study): 
the table 11.1 shows that the product usually purchased is significantl y more expensive over 
the lifecycle than many others on the mark et. It is also more energy consuming and 
environmentally harmful. 
 
Table 11.1: Energy performance and co sts of large size water heater 
Large water heaters Primary energy 
consumption 
KWh/a  CO 2 emissions 
over life cycle 
tonne  Purchase price 
€ Life cycle cost 
€ 
Current model purchased 7375 75 1189 9001 
Least life cycle cost 5023 51 937 6341 
5 5004 51 4000 11605 
6 4850 49 1750 7423 
7 4549 46 2517 8328 
8 4214 43 1800 7268 
Best available technology 4014 41 2180 8053 
Source: Task 6 of the Ecodesign preparatory study on water heaters 
 
• The EU currently lags behind its global tr ade partners in implementation of public 
procurement measures aiming at improvi ng energy efficiency and environmental 
improvement. In the US the public procurem ent provisions of Energy Star have been 
applied already for a long time and have for example contributed to driving upwards the 
entire energy efficiency market of office e quipment. Similar provisions where introduced 
in the Community at the end of 2006 under th e Energy star programme covering office 
equipment. 
 
• No framework at the level of the Internal Market exists on energy efficient public 
procurement or incentives. Divergent practices weaken the market signals for business. 
 
• The Commission services do not have informa tion on the levels of public procurement 
that looks particularly at energy efficiency considerations. For ''green'' public procurement 
 
69 a recent study “Take 5”119 shows that about 35% of procur ement practices have significant 
'green' criteria  while in other cases Member States in clusion of green cr iteria is weak.  
 
Drivers for Change 
• The European Commission, the Council and the European Parliament have recognized the 
importance of using public procurement as  a means of stimulating sustainable 
consumption and production and pulling envir onmental technologies into the market 
place120.  
• In June 2006, the Council has adopted th e renewed EU Sustainable Development 
Strategy121 including the goal to bring the averag e level of EU green public procurement 
procedures that include ener gy and environmental considerat ions up to the standard 
currently achieved by the be st performing member stat es by 2010. However, voluntary 
actions at national level are not sufficien tly connected and implementation is not 
sufficiently dynamic and forward-looking to dr ive the performance of products upwards. 
Divergent national and regional approaches send conflicting signals to producers, and as a 
result the full potential of the Internal Market is not realized. 
• Directive 2006/32/EC on energy end-us e efficiency and energy services122 provides that 
the public sector should fulfil an exemplary ro le by adopting at least two measures from a 
list in Annex aimed at procurement of energy efficient equipment and buildings. 
• The new Energy Star Regulation123 already obliges central gov ernment to apply, in their 
procurement procedures for office equipment,  the energy efficiency requirements as 
included in Energy Star Standards. 
 Experience points out that these commitments will not solve the problems by themselves
124. 
Option 3 and 4 are in line with these commit ments and expand the policy approach in the 
Energy Star Regulation.  
 
B) Lack of stimulation of innovation and the longer term impact on prices and energy 
efficiency  
Different market signals from public purchasing limits sales of more efficient products. This 
has two effects:  
• It limits innovation in more energy effici ent products, by reducing the attractiveness of 
investment by manufacturers; and 
• It limits the economies of scale that the producer  could benefit from – and so the price of 
the more energy-efficient products remains higher.  
 
                                                
 
119 http://www.ec.europa.eu/envi ronment/gpp/pdf /take_5.pdf 
120  EP resolution of 5 July 2005 on the Communication on the implementation of ETAP (COM(2005) 16 final). 
121  http://ec.europa.eu/sustainable/sds2006/index_en.htm   
122 OJ L 114, 27/04/2006. 
123 http://ec.europa.eu/energy/demand/legislation/energy_star_programme_en.htm   
124 Also, see Commission Working Paper SEC(2008) 2126/2. 
 
70 Figure 11.1: Dynamic effects of increasing market share (proxied by time) on price  
Evolution of prices by type of energy efficiency (kg laundry/kWh )
050100150200250300
1977
1980
1983
1986
1989
1991
1994
1998
2000
2002
2004
2006
YearPrices (€ 2006)3.5
5.0
5.3
5.6
 
Own calculations based on data provided by Cope rnicus Institute of the Universiteit Utrecht. 
 
Figure 11.1 above points to this missed potenti al. This describes the market for washing 
machines in the Netherlands. The horizontal axis represents time. The vertical axis represents the price of the washing machines. The lines re present different models of washing machines 
based on the energy efficiency. (The energy efficiency is measured as the load (in kg) for a kWh of electricity. The higher the load per kWh the more efficient is the appliance
125).  
The figure illustrates that the price for a given energy efficiency level declines over time 
which is due to learning and economies of s cale in production as volumes of production of 
more efficient models increase. This price d ecline accelerates once a new, more efficient 
model is established on the market.  
A broad literature survey for energy using produ cts and energy related products indicates that 
for every doubling of the cumulative volume sol d, costs for these products would decrease 
between 15-20 %.126  
In the Netherlands, acco rding to a report by IVM127, the introduction of incentives for more 
energy efficient white goods in the Netherlands from 2001 led to significantly faster market 
penetration of more efficient products. This is  estimated to have br ought forward the energy 
efficiency of the market by 3 years – so sp eeding up the decline of prices by 3 years.  
                                                 
125 For example, to wash 5 kg of laundry, with an app liance whose efficiency is 3. 5kg/kWh, the appliance will 
need to use 1.43 kWh (5kg/3.5 kg/kWh) and operate during almost 86 minutes (1.43*60 minutes). An appliance whose efficiency is of 5.6 kg/kWh would, for the same 5 kg of laundry, use only 0.88 kWh and run less than 53 
minutes. 
126 Junginger et al (2008) Technological learning in the energy sector. This study has been performed within the 
framework of the Netherlands Resear ch Programme on Scientific Assessment and Policy Analysis for Climate 
Change (WAB). 
127 IVM and consortium for the European Commission (DG ENV) "The use of differential VAT rates to promote 
changes in consumption and innovation" (2008).  
 
71 Public procurement and incentives (as for energy labelling) have the sa me kind of effect, if 
designed correctly.  
On the reasonable assumption that earlier re turns on investment will lead to greater 
investment by manufacturers in efficiency, greater rates of innovation would result if 
incentives and public procurement across Member St ates pulled in the same direction. Public 
procurement can provide market rewards for mo re efficient products, providing manufacturers 
with incentives to invest in design of more e fficient products (whilst still saving authorities 
costs). 
A recent OECD Report on the Environmental Pe rformance of Public Procurement (2003) 
refers to several examples of product invent ion in response to procurement initiatives, 
including the development of highly energy e fficient clothes dryers, electric motors, and 
office copiers128.  
 
C) Reduced impacts on the market from  a scatter-gun approach to incentives 
Many Member States provide financial incentives, such as grants for substitution of electricity 
for heating (Sweden), ecological tax reform (G ermany), refunds for Category A++ appliances 
(Belgium) that intend to encourage consumers to buy more energy effi cient products. Many of 
these incentives are linked to the implementing Directives of the ELD. Where this is not the 
case, the criteria can differ s ubstantially from one country to another. The result is a 
fragmentation of the Internal Ma rket for the products concerned. 
The following tables show the example of fis cal incentives on roof insulation and energy 
saving windows in some countries w ith similar climatic conditions.  
Table 11.2:  minimum requirements and incentives for insulation in some Member States 
2005; the case of roof insulation.  
Member State Minimum R 
value129 Amount 
€ Maximum 
amount/share granted 
€ 
Belgium (Fed) 2.5 tax reduction: 40% of the price 2 600 
Brussels 4 20/ m² 20% of the price 
Wallonia 3 4-8/m² 10 000 
France 3 Tax credit: 25 or 40 % of the price - 
Luxembourg 4.3 13-15 /m² - 
Germany 4.5 100 % interest rate paid by the Bund - 
 
Despite of similar climate conditions, the incentives are based on quite different performance criteria. For example, a producer th at supplies windows with a U-value
130 of 2.0 will benefit 
from increased demand due to fiscal incen tives only in Belgium but not for example in 
Luxembourg or Germany. This limits the economies  of scale that the producer and ultimately 
the consumer could benefit from, if the basi s for incentives was the same across Member 
States for similar climate conditions.  
Table 11.3: minimum requirements and incentive s for insulation in some Member States 
2005; the case of windows. 
                                                 
128 Westling 2000.   
129 R-value is used to describe insulation properties of certain building insulation materials. The SI unit for R-
value is Kelvin square meters per watt (K·m²/W).  
130 The U-value describes how well a building material cond ucts heat. It measures the rate of heat transfer 
through a material of known thickness over a given area under standard conditions (Unit: W/m2 ºC of 
temperature difference between both sides of the heat transfer). 
 
72 Member State Maximum U 
value Amount 
€ Maximum amount 
granted € 
Belgium (Fed) 2 tax reduction: 40 % of the price 2 600 
Brussels 2 25/m² 20 % of the price 
Wallonia 2 40/m² 10 000 
France 1.5 - 2 Tax credit: 25 or 40 % of the price - 
Luxembourg 1-1.3 12-30/m² - 
Germany 1.3 100 % interest rate paid by the Bund - 
Austria (Vienna) 1.9 2-3 % of the annual loan cost - 
 
 
4. Options on public procurement and incentives in Options 3 and 4  
 
Under either of these two opti ons, the ELD woul d provide that: 
• implementing measures for products wo uld use the labelling classes to set 
performance thresholds for public pr ocurement or incentive schemes. 
This would not necessarily cover all products for which there are implementing measures but 
only products that are directly relevant for th e use of public procurement or incentives. The 
relevance would have to be demonstrated  by product specific impact assessments. 
For some of the most relevant products - o ffice equipment – the Council and the Parliament 
have already accepted131 introducing compulsory public procurement based on energy 
efficiency criteria.132. These existing measures would not  be duplicated, but the approach 
extended to other relevant products.  
The thresholds set for public procurement in implementing measures would be set (in line 
with a requirement in the Directiv e) at a level that they would: 
• be at an appropriate level which would ensu re sufficient competition in the market;  
• take into account the potential of the procurement to stimulate the market for energy 
efficient products. Considerati ons include setting the level at  a sufficient high level to 
stimulate the market but also on whether th e share of public purchases is sufficient to 
influence the market; 
• assure that the threshold is such that the products' life cycl e costs are lower than current 
practices. 
Member States have already committed to make  use of public procurem ent as an instrument 
to generate cost-effect ive energy savings. Article 5 and Anne x VI of Directive 2006/32/EC on 
energy end-use efficiency and energy services sets  out that they shall ensure that the public 
sector purchase energy efficient equipment with  minimized life-cycle costs to ensure cost-
effectiveness.  
 
5. Benefits and Costs  
 
The key benefits from introduction of the measures in Options 3 and 4 would be: 
                                                 
131 Regulation EC N°106/2008 on Energy Star. 
132 Without prejudice to cost-effectiveness and taking into account the minimum thresholds laid down in Article 
7 of Directive 2004/18/EC on the coordination of procedures for the award of public works contracts, public 
supply contracts and pub lic service contracts. 
 
73 • Net financial benefits to public authorities; 
• Reductions in the cost for the public budget of  achieving existing en ergy goals and related 
environmental goals; 
• Reductions in environmental harm from public actions; 
• Greater effectiveness of the Ener gy Label and Ecodesign Directives;  
• Public procurement levels would be an incen tive for manufacturers to invest in more 
energy- and resource-efficient products thus dr awing the market upwar ds, the levels could 
also be set such that they facilitate the gradual adjustment of the minimum requirements 
over time.  
• Stimulation of innovation in energy-efficiency and decreases in price of energy efficient 
products over time.  
The key costs from the introduction of the m easures could be for so me product groups, but 
not all, thresholds that  raise the upfront costs for author ities. Even where there are cost 
savings over the lifetime, this  may cause problems with exis ting accounting practices and 
funding in some authorities.  Note that the choice on where to put the perfor mance level with associated upfront costs and 
energy savings would be made in the implem enting measures and decided through committee 
procedure. The Commission believe s that this procedure offers sufficient guarantees to avoid 
the imposition of unjustified increases in upfro nt purchase costs when setting thresholds. 
Moreover, guarantees are taken up in the legi slation on what should be considered when 
drafting the implementing measures allow for a ppropriate outcomes. It also ensures that 
sensitivity analysis is carried out to take in to account various welfare and living standards in 
the EU.   These benefits and costs are desc ribed in more detail below. 
 
A) Direct financial benefits to public authorities 
There would be net financial gain for public au thorities from the purchasing of more energy-
efficient products that would result from th e options including public procurement. The 
financial benefit of purchasi ng of products can not be ju dged only from looking at the 
purchase price – but must take into account the costs of energy over the lifecycle.  
It is important to note that the most cost-effi cient product over the life time might also have a 
lower purchase price than the products currently purchased.  
• Example 1: Water heaters  
7 % of water heaters sold on the EU market ar e bought by public authoriti es. The prices paid 
in the market and the life-cycle costs are shown above in Table 11.1. The Table shows the 
energy performance and prices for different ty pes of large size water heaters. The current 
standard model costs € 1 200 in purchase cost and € 9 000 in life-cycle cost. As the table 
shows, the product with lowest life-cycle cost (€  6 350) is also the least expensive to purchase 
(€ 950) but is not the most commonly purchased.  
Therefore, public procurers could buy even mo re energy efficient products than least life-
cycle cost without being worse o ff than with their current proc urement practice s. Indeed, in 
this particular case, on the assumptions use d, public procurers would save € 950 by shifting 
from current models purchased to the best technology available on the market.  
 
74 However, thresholds for public procurement w ould be likely to be se t well below the best 
technology on the market, to take into account th e difficultly some authorities have in funding 
purchases (partly due to budgeting rules that do not take into account future savings) and to 
leave sufficient competition on the market. This would have to be carefully considered in product specific impact assessments. 
In cases like this, the structure of the market may not change significantly in future: the prices 
and costs of energy will change (energy costs probably being higher than those used in the 
data, which dates from before 2008). The Ecode sign of Energy Using Products Directive may 
bring forward implementing measures e.g. for water heaters with the aim of removing 
inefficient products from the market. However, in practice, future mi nimum requirements set 
by the Ecodesign Directive could well be set below the energy efficiency level that brings minimum life-cycle cost (to account for other considerations such as 'competitiveness' or affordability, in particular regarding low inco me households.) This would leave the market 
structure similar to the existing structure. 
 
• Example 2: Heating, Ventilation  and Air Conditioning Systems  (HVAC Systems)  
A life cycle cost evaluation of alternative HVAC  systems carried out in the US in 2005, has 
led a public authority to buy a HVAC system, based on an alternative energy-efficient 
technology, whose energy consumption was markedly lower so that cost savings outweighed 
higher capital and maintenance costs  as well as yielding environm ental benefits in terms of 
reduced greenhouse gases and other air pollutants
133. 
 
• Example 3: Public street lighting 
Public procurement makes up 39 % of the market  for lights that can be used for illuminating 
large spaces. Other uses are in industry or for example purchases for football stadiums. If the 
2.1 million street lights currently procured per year would be upgraded to best available 
technology, there would be savings of € 323 million  over the life cycle (while at the same 
time saving an additional 7.7 million tonne of CO 2 over the life cycle of the product).134 
The above are examples where, after an exte nsive study, performance levels could be set 
below which public procurement and incentives  are not allowed. Other examples can be 
found where it will not make sense to set such performance levels and the product by product assessment methodology would then not justify action.   
Estimating the direct financial benefit 
The full financial benefit to pub lic authorities from introduction of Option 3 or 4 can not be 
calculated. It would depend on the thresholds set in implementing measures, the relative 
purchase price of products, energy costs and th e number of products bought by authorities. 
Product specific impact assessment s will be used to estimate be nefits (and costs) of possible 
thresholds in implementing measures. However, indications of the poten tial financial benefits 
can be estimated for some examples and indicate  that the potential financial benefits are very 
large. 
In the water heater example, setting thresholds at  the level of least life cycle cost is estimated 
to save €2bn.   
                                                
 
133 Fuller, Sieglinede and St ephen R. Petersen, 1996 Life-Cycle Costing Manual for the Federal Energy 
Management Program, referred to in 2003 OECD Report on the environmental performance of public 
procurement. 
134 Calculations based  on PWC (2008) Study on public procurement for energy efficient products in the 
European Union. The same CO 2 per MWh conversion factor as for water heaters has been used.  
 
75  
Table 11.4: Aggregate results of pub lic procurement (PP) requirements 
 
Compared with current procurement 
practice Absolute differences  Current 
procurement 
practice 100% PP with least 
life cycle cost 100% PP with more 
ambitious products 
Purchase cost  million €  594 -45 441 
Total Life cycle cost  M €  7,611 -2,063 -1,546 
Energy consumption  GWh 70,195 -22,734 -26,573 
CO 2 total emissions  Mt 48 -15.5 -18.1 
 
 
B) Reducing the cost for the public  budget and environmental harm 
By using energy efficiency to meet enviro nmental goals, society is able to achieve 
environmental goals at a lower cost  than through many other methods.   
This is particularly the case under the threshold for public proc urement likely to be set under 
the implementing measures; the purchase of a more  efficient appliance would save authorities 
money over the life of the product.  
Authorities could voluntarily go further, to gain additiona l environmental savings from 
purchasing best available technology. This would come at additional cost, though it would 
still be likely to be more efficient than other means – but this extra effort is not what Options 
3 and 4 would require.  
Environmental problems impose costs on society,  for example through sickness from poor air 
quality arising from power ge neration emissions. Member St ates set environmental policy 
goals to reduce these harms and spend public m oney to achieve them. Yet, the expenditure 
decisions of public authorities te nd to contribute to environmental harm. This is not efficient: 
a contradiction in public policy. Usually, the way to  best cut those costs is to reduce the harm 
caused by public authorities. 
In the example above, in purchasing the most  efficient technology pub lic authorities would 
save 34 tonne of CO 2 over the life cycle of each water he ater, which at € 30 per tonne of CO 2 
is valued at an additional € 920 savings/product.  That €920 is a social benefit, but the public 
authority also benefits from reduced energy expe nditure If the public au thority had to achieve 
that €920 benefit in ways which cost the sa me upfront, but which did not save energy, 
achieving that benefit would be more expensive. 
In the water heater example, in terms of CO 2 savings, ambitious public procurement targets 
on energy efficiency would save 15.5 million tonnes of CO 2 compared to the current public 
procurement practices. This represents savings of 38 % and is valued at € 540 million at € 30 per tonne of CO
2.  
 
C) Greater effectiveness of th e ELD and Ecodesign Directives 
The ELD labels provide information to consumers that allows them to choose products which 
fit their needs and save their money over the lifetime of the product – in particular to avoid 
selection of products with a cheap upfront cost  but which has greater energy costs during use. 
By doing so, the Directive promotes energy e fficiency across the EU for economic, geo-
political and environmental goals. 
 
76 The energy label promotes i nnovation by increasing market rewards for more efficient 
products. Shaping public procurement – which is  a significant part of many markets – to 
reward the more efficient products simultaneous ly provides security of returns and higher 
returns for investments in innovation in energy efficiency. The higher th e thresholds are, the 
greater this effect would be. The product specific  impact assessments will have to consider the 
appropriate market share of appliances for appropriate co mpetition based on the product 
group and the specificities of the market in question.   
Although in principle minimum requirements for th e Ecodesign Directive w ill be set at least 
life-cycle cost, for some products this might harm the competitiveness of the industry unduly 
or affect affordability for consumers. In such cases, minimum requirements will be only 
gradually set at the least life-cycle cost level.  For those products, publ ic procurement can be 
used to reward products that already satisfy hi gher energy efficiency st andards and act as an 
incentive to accelerate and smoothen the tr ansition towards more stringent minimum 
requirements. 
For example, the technical study for water pum ps suggests setting minimum requirements so 
that 10 % of the current less efficient wate r pumps on the market would be excluded in 2010. 
The requirements could be graduall y strengthened so that 60 % of  the current best performing 
products can remain on the market in 2020. In  2020, this would generate energy savings of 
5.8 TWh per annum. In contrast, setting minimum requirements at the least life-cycle cost 
would imply that only 30 % of the best perf orming products currently  on the market would 
remain viable. In 2020, this would generate energy savings of 8.8 TWh per annum but would 
come at an adjustment cost  of € 1 billion to industry.135 Here, the role of labelling and public 
procurement could be to allow for a smooth and accelerated transition towards more energy efficient products. Setting public procurement requirements at least life-cycle cost, would 
have direct environmental impacts, would dr ive the market upwards, would save money for 
public authorities and would leave from the st art 30 % of the market open for competition.  
 
D) Long-term economic benefits from increased innovation 
There is also a long-term financial benefit for authorities from speedi ng penetration of energy-
efficient technologies and innova tion. Increasing volumes of ener gy-efficient products brings 
down purchase price of future purchases of ef ficient products (through economies of scale) so 
allowing authorities to save en ergy in future, whilst greater innovation means that more 
highly efficient products will become av ailable to them in the future.  
This would benefit both consumers and public  authorities – but to  bring about these 
innovation effects, public procurement would need  to promote purchase of  the products in the 
top of the market. Whilst this is possible, the thresholds in implementing measures are likely 
to be set below this level, to take into account  financing considerations  in public authorities. 
• The benefits of thresholds for incentives  
The benefits of incentives for promoting mo re energy-efficient products depend on a number 
of factors, but are similar to the benefits fr om public procurement measures – promoting the 
uptake of more efficient products, with both direct and long-term economic and 
environmental impacts. 
The benefits of setting minimum levels for incentives in Member States come from the 
concentration of the market signal sent to ma nufacturers – if Member St ate incentives pull the 
market in the same direction, th e greater the stimulus to mark et penetration and innovation.  
                                                
 
135 Note that the adjustment cost is provided by industry and not yet fully justified. See technical study on water 
pumps http://www.ecomotors.org/files/Lot11_Pumps_FinalReport.pdf 
 
77 Typically, though depending on market  structure, the minimum le vels for incentives would 
need to be set at levels which concentrated market rewards on those products in the market 
which were innovative, and which assisted market  penetration of products  whose high upfront 
cost held back their penetrati on. The benefits achieved by th e implementing measures in this 
regard would depend on the appropriateness of th e level set. Clearly a sensitivity analysis 
should take into account disparities of  welfare among consumers in the EU.  
 
 
Costs  
As shown above, for many products, thresholds fo r public procurement w ill create savings for 
public authorities, particularly over the life-cycl e. In some cases, thresholds could be set at 
levels which require greater upfront purchase costs but which are paid back from saved 
energy costs. The product specific impact assess ments will have to consider the pay back time 
for the proposed threshold included in th e implementing measures. As the implementing 
measures have to be endorsed by the Regulatory Committee of Member States 
representatives, possible difficu ltly of some public authoritie s to fund upfront purchases will 
be flagged out  during the discussions. 
The level of benefits (or costs) from a life-cycle perspective for most office equipment is 
rather easy to determine, as the use pattern is  rather homogeneous and predictable. However, 
as the use pattern for most other products is rather user specific, it should be properly 
considered in the product specific impact a ssessments. Also, the Regulatory Committee will 
have a say when setting levels for incentives ; Anyway it would stay with the individual 
Member State to decide whethe r or not to have an  incentive scheme – not hing in the Options 
3 or 4 relating to incentives would place costs on the Member States, authorities or the private 
sector. 
 
6. Conclusions  
 
• Member States have already committed to make use of public procurement as an 
instrument to generate cost-effective energy savings. Article 5 and A nnex VI of Directive 
2006/32/EC on energy end-use effi ciency and energy services sets out that they shall 
ensure that the public sector  purchase energy efficient eq uipment with minimized life-
cycle costs to ensure cost-effectiveness;  
• Public procurement at the threshold levels ar e likely to be significantly less expensive over 
the life cycle than existing procurement practic es: this will depend on the threshold levels 
set in implementing measures (even very am bitious public procurement requirements can 
be less expensive than current practices); 
• Inclusion of provisions for incentives encour ages sales of innovative products. This is 
important for reducing the prices of more-e fficient products and increasing the rates of 
innovation in energy efficiency. A broad litera ture survey for ener gy using products and 
energy related products indicate s that for every doubling of the cumulative volume sold, 
costs for these products woul d decrease between 15-20 %136;  
                                                 
136 Junginger et al (2008) Technological learning in the energy sector. This study has been performed within the 
framework of the Netherlands Resear ch Programme on Scientific Assessment and Policy Analysis for Climate 
Change (WAB). 
 
78 • Inclusion of the option would support and enhance the opera tion of the energy label and 
Ecodesign Directive and save substantial amount s of energy and related emissions, such as 
CO 2 or NOx;  
• Use of public procurement in this way is usually a cheaper way to achieve existing 
environmental goals than other public policy measures; 
• The setting of harmonized leve ls for public incentives shou ld take into account market 
realities in the EU and in particular the di fferences in welfare and purchasing power of 
consumers which are still di vergent across the 27 Member States. Decisions in 
implementing measures will be based on analysis of the financial benefits and costs to public authorities.  
 
79  
ANNEX 12: ADMINISTRATIVE AND TRANSPOSITION COST  
This Annex addresses administrative cost as  discussed in Chapter 5.5 and based on the 
background study. The presented figures are indicative.  
Main administrative costs for Me mbers States and the Commission: 
Amendment of the Framework Directive: €5 million in total (€1 million for administrative 
work on the amendment and €4 million for transposition by Member States).  
Transposition cost for the 27 Member States from amended Framework Directive or amended 
or new implementing Directives of €4 million
137.  
Amend an existing implementing Directive or  develop a new implementing Directive under 
the existing ELD:  €4.7 million (720.000138 million for administrative work on the 
amendment/development of the new Directive and €4 million for transposition by Member 
States).  
It is to be noted that if the amendment to the Framework ELD would lead to implementation 
of the ELD with implementing Regulation or D ecisions instead of Directives, the one-off €5 
million revision cost would lead to savings of €40 million in transposition costs alone for the 
ten first upgraded or newly developed implementing measure adopted under the new 
framework. 
 
Administrative cost for manufacturers and retailers 
 
Changes in administrative cost to  manufacturers and retailers wi ll occur only if the scope is 
extended and/or implementing measures are set on new products. These costs will be assessed 
in product specific impact assessments. The b ackground study shows that  the costs are likely 
to vary considerably depending on the product involved, the number of models subject to 
testing and the degree of test ing already carried out for othe r purposes, such as under the 
Ecodesign Directive. One of such shared costs is  the testing for conformity assessment, which 
is estimated to €1000-3000 per prod uct type. Another cost for ma nufacturers is to provide the 
background label for retailers on products that ar e displayed in shops and the black-and-white 
strip for every product sh ipped (see Annex 4). 
 The information required for the label and information fiche is derived from measurements 
manufacturers already carry out in the course of product deve lopment and qual ity control. 
Most manufacturers already publish the basic in formation in their brochure or technical 
literature but not in easily accessible form for consumers.
139 Thus the matter seems to be more 
                                                 
137 Precisely €4.050.000 (27 MS x 150 000€). 
138 The background study estimated that  the revision of an existing impl ementing Directive would cost less 
(€360.000) than the development of a new one. However, there is no such difference in cost given that new 
technical studies are needed due to market and technical development, including product development, and the 
same administrative/legal procedure will be used for both. This does not include any add on for overhead costs. 
139 Compliance cost assessment, The energy labelling (ref rigerators and freezers) regulations 1994, Department 
of the Environment. 
 
 
80 about the accessibility and easin ess to understand the informati on rather than the additional 
cost of providing it.   The cost for retailers is limited to the display of the right label on the pr oduct associated with 
the strip provided in the produc t packaging. Accordingly, given that only simple information 
requirements are set on manufacturer s and retailers there is no risk  that these actors would not 
be able to meet the set criteria, unlike in so me cases when setting minimum requirements.  
 In summary, the background study shows that most  of the energy efficiency measures are 
cost-effective, including energy labelling. In many cases there is some increase in operating 
cost to manufacturers and retailers due to ener gy labelling requirements. However, these costs 
can be passed on the consumer. The backgrou nd study shows that ener gy labelling leads to 
net money savings for the use, as electricity cost over the life time of the appliance will be bigger than any additional purchas ing cost for the more efficient model. For example, in the 
case of EU white goods manu facturers, their ope ration has become more profitable, 
appliances cost less and the efficiency has im proved with help of t echnological development 
and guidance towards more efficient and profita ble appliances by the energy label – despite 
fears by manufacturers when the policy action was initially introduced in the 90ies.  
  
 
81 ANNEX 13: MINUTES OF THE STAKEHOLDER WORKSHOP  
 
 EUROPEAN COMMISSION 
DIRECTORATE-GENERAL FOR ENERGY AND TRANSPORT 
 
 
DIRECTORATE D - New and Renewable Energy Sources, Energy Efficiency & Innovation Energy efficiency of products & Intelligent Energy – Europe  
 
 
Brussels, 10.03.2008 
 
  
MINUTES 
    Consultation meeting on the revision of the Energy Labelling Directive 92/75/EEC on 8 February 2008.  
Centre Albert Borschette (CCAB), room  0D, rue Froissart 36, 1040 Brussels,  
 
Participants: see Annex 1 to these minutes.   The Chairman opened the meeti ng and outlined the context for the stakeholder consultation. 
The renewed Sustainable Development Strategy calls upon the Commission to propose an EU 
Consumption and Production Action Plan (DG E NV) to "help identify and overcome barriers 
for SCP and to ensure better coherence between  different related po licy areas. The possible 
revision of the Energy Labelling Directive makes pa rt of this context as well as of the parallel 
initiative on Sustainable I ndustrial Policy led by DG ENTR. Th e purpose of this consultation 
is to collect comments and views from all stakeholders on the main policy options for a 
possible revision of the Energy Labelling Fr amework Directive 92/75/EC. Part of the 
SCP/SIP would be to extend th e scopes of the Ecodesign Dir ective 2005/32/EC and of the 
Labelling Directive 92/75/EEC, vehicles and th eir parts (such as tyres or air-conditioning) 
being excluded.  The Chairman then gave an overview on the next steps in preparing Ecodesign and energy 
labelling implementing measures. For SCP/SIP it is important to maximize synergies and 
consistency between these two legislative tools, as well as with Energy-Star, Ecolabel, RoHs, 
WEEE and other relevant legislation. In that context, it could make sense to extend the 
mandate of the Energy Labelling regulatory Committees to also cover the Ecodesign Directive.  Stakeholders were invited to continue pr oviding comments by 22  February 2008; the 
Commission would aim making a proposal on revising 92/75/EC before the summer break 
2008. The meeting was structured based on the ques tions and policy options discussed in the 
Commission working document that  was published on 20 December 2007 on 
http://ec.europa.eu/energy/dema nd/legislation/eco_design_en.htm
. 
The comments made during the meeting and note d in these minutes are subject to possible 
fine-tuning or change by stakeholde rs by 22 February, at latest.   
 
82 Due to the urgency to update the existing Ener gy Labelling Implementing Directives it was 
agreed to conduct a discussion on the design of the label outsid e the context of the revision 
process towards the end of the meeting.  
The summary of the discussion is as follows: 
 
The meeting participants fully agreed on the gene ral principle of reinforcing the use of energy 
labelling (Q2).  
Question/Policy Option  Yes No 
Q2. Do you agree to the general principle of  reinforcing the use of (energy labelling)  in 
order to more vigorously contribute to the Union ’s objectives on climate mitigation, 
competitiveness and sustainable product policy?   
X   
 
 Upon this agreement, a discussion was conducte d on a possible wider scope of the revised 
directive, as summarise d in below table.   
 
Question/Policy Option  Yes No 
Q6. Would you like to add other products  to the scope of the labelling Directive than 
those covered at present (household appliances only)?  X  
P1. Extending labelling to additional household  appliances displayed in shops/outlets, 
such as televisions, water heaters, boilers … X  
P2. Extending labelling to non-household energy-using appliances, such as electric 
motors  X  
P3. Extending labelling to non-energy using  products, such as windows, tyres or services  X X 
 
 The majority of the meeting participants responded positively to the above questions, 
particularly as to adding ot her energy-using or (non en ergy –using but) energy-related 
products to the scope of the directive. On the question to add all non-energy using products 
into the scope of the directive  the majority of participants expressed doubts.  
 ITALY supported by the UK expressed a negativ e position on adding systematically non-
energy using products into the scope. Instead, it was supported that 'energy-related' non-
energy using products could be covered (except ve hicle parts, such as tyres) if an impact 
assessment so would advice; therefore the re vised Framework Directive should keep that 
possibility opened in select ed well justified cases. The N ETHERLANDS felt that we should 
only label carefully selected non EUP. EURO ACE supported labelling of windows, but felt 
that any label on insulation products would not be useful. FRANCE and GERMANY had 
doubts on going beyond non energy-related non EUP.      The discussion on the possible revised scope led to the question on content and type of the label to be used, as summarised in the below table.  
 
83 Question/Policy Option  Yes No 
Q3. For energy using products, would you favour the use of an energy label focusing on 
the energy consumption in use  
or of an ‘Ecodesign label ’, (near to the Eco-label showing the ‘best’) giving the global 
environment performance of the product throughout its life-cycle?        X  
 
X 
P5b. Replace the energy label  by an ‘Ecodesign ’ label combining several significant 
environmental parameters   X 
Q4. Are you in favour of adding CO 2 on the energy label? How could reliable 
information be assured in the light of different energy mixes in the 27 Member States       X 
 
P5a. Provision of additional product information  on the energy label, such as CO2 
emissions or annual running costs  (X) 
Q5. Are you in favour of adding annual running costs  on the energy label?   X 
 
For energy-using products there was unanimity on the need to maintain the energy label with 
focus on energy consumption in use phase, incl uding the indication of the consumption of 
other relevant consumables during the use phase, in line with the presen t successful scheme.  
 Environmental NGOs stressed that the urgency wa s to address energy consumption (while not 
affecting other environmental parameters) and the need to urgently review the existing 
implementing Directives.   Stakeholders requested to keep the message cl ear and simple and not to indicate additional 
environmental information such as CO2, except possibly if the scope was broadened towards 
non-energy using products. CECED reminded that  indicating CO2 would be neither feasible 
nor enforceable and therefore should not be a legal requirement. OR GALIME supports this 
view as far as the use phase is  concerned and clarifies that fo r the rest of the life cycle 
information CO2 emissions may be relevant for some products. Including this option into the 
legal framework may be appropriate, as the ques tion is about possible practical difficulties to 
collect the necessary data. UK was not against in dicating some CO2 footpr int as such but not 
necessarily on the label.    ANEC and BEUC, supported by Italy and Fran ce, saw a danger in mi xing the energy label 
with other environmental information, as consumers need a simple message; carbon 
discussion should be kept out of the label. The energy label should focus on energy and other 
consumables at use phase and should not aim at  including other environmental parameters 
during the life-cycle. The key for consumers is th at the label provides re liable information on 
the energy consumption of running an applian ce in real life situation and on the most 
consumer relevant functional performance (as r unning cycle of washing machines). This is in 
fact anyway a way to indirectly cont ribute to preserve the environment.  
 On the indication of the running cost, FRANCE , supported by ANEC and BEUC, stated that 
standard running cost in the context of the 27+7 countries im plementing the European energy 
label would never match with the real running cost to the consumer. Instead of helping, it 
would contribute to disinformati on of consumers. UK stated that  running cost is important 
information to consumers but recognised that pr acticalities hinder their inclusion in the label. 
 
 
84 EUROCOMMERCE reminded that sales personnel can not take the resp onsibility and are not 
able to convey complex environmental information to consumers. The label must remain simple and convincing for both consumers and sales personnel in order to be efficient. 
 ORGALIME considered that it could be useful in some cases to open the possibility for the 
indication of other environmental parameters in the revised Framework Directive. It would be 
a pity not to have this possibility, if the need was there in the future (change of priority in 
environmental concerns) and/or for particular product groups. 
 A request was made, supported by BELGIUM, fo r further synergies between various tools 
(Ecodesign, energy labelling, Energy -Star, Ecolabel, RoHs, WEEE). 
 It was summarised that the Framework Directive should: 
 
- focus on consumption of energy and other re sources in use for energy-using products 
and some non energy-using but energy related products 
- keep the possibility to include additional information useful to consumers such as 
functional performance; 
- open the possibility to include other envi ronmental aspects throughout the life cycle 
for non-energy using products. 
  On policy options 10, 7 and 8, there was a full ag reement, as shown in the table below.   
 
Question/Policy Option  Yes No 
P10. Implementation through Regulation  rather than Directive  X   
P7. Tighter tolerances  in the measurement standards X   
P8. Better enforcement  of the labelling requirements in respect of both manufacturers 
meeting the set standards and retailers displaying correct information X   
 
CECED supported by ORGALIME demanded that ea ch actor be held responsible for its 
tolerances, that is, manufacturers to be re sponsible only for product variances and the 
variances in test labora tories to be decreased. MARCOGAZ supported CECED and 
considered that a general statement on tighter tolerances is not enough  but should include 
explicit figures. ANEC and BEUC supported and re quested that the presen t test standards be 
revised in order to better reflect the actual us e of the appliance (such as test standard on 
washing machines).  To improve the situation, DENMARK propo sed, supported by EUROACE, to increase 
information sharing and provision of technical data between test labor atories, although it is 
difficult as product models often differ in diffe rent Member States. A European database 
could be developed, e.g. within the Intelligent Energy Europe programme. ANEC requested that all market surveillance activ ities in Member States should  be centrally registered and 
reported to the Commission. ITALY reminded th at the Australian scheme also includes 
sanctions and covers some 20-30 products tested  annually. CECED doubted  how much of this 
can be brought into the lega l text but was ready to c ontribute.  The UNITED KINGDOM 
suggested that technical files should be ope n to all (at least MS),  and the verification 
procedure should be made easier.  
 
85 Question/Policy Option  Yes No 
P6a. Reinforce provision  of labels on internet sales  X  
P6b.  Reinforce provision  of labels in the context of other type of sales and advertising : 
www-pages, newspaper and TV adds … X  
P6c. Provision of information  on energy consumption (apart from labelling) in media and 
advertising : www-pages, newspaper, magazines and TV adds … X  
P9. Legal protection  of the label  X  
 
As the table shows, stakeholders  require stronger provisions across all of th e above issues. 
Environmental NGOs requested better display of  labels outside shops and in departments 
where the products are sold, including second hand shops.  The Netherlands foresaw difficulties in how to  enforce a provision of information in media 
and advertising.   CECED was positive about legal protection of th e label but wanted to avoid any possible 
royalty issues.   The issue of possible alternative routes beyond the considerations in the Commission working 
document was addressed with no reactions by the st akeholders, as shown in the below table.  
 
Question/Policy Option  Yes No 
Q8. Do you want to propose an alternative route  beyond the considerations in this 
document?   X 
 
 Finally, the issue of how to en sure dynamic labelling was addressed with considerations on 
the type of specific distortions relevant to  manufacturers, retailers and consumers. The 
summary results of the discussion are shown in the below table. 
   
Question/Policy Option  Yes No 
Q7. In view of dynamic labelling , which approach would you suggest for the transition 
from an existing labelling scheme to a new labelling classification in order to cause 
minimum distortions?    
P4. Reinforce dynamic labelling  with periodic reviews and rescaling of the ratings, 
including a possible redesign of the label and upgrading of the existing Directive  X  
 
CECED reminded of the importance of an adequa te return to the investment made by the 
industry, which is particularly im portant, if the scope of the di rective is broadened and more 
products are to be labelled. Cons equently, in order to respond to the request for a dynamic 
labelling scheme, CECED proposed a new numeri cal labelling scale, which had also been 
presented to Member States the day befo re. The scale would reduce the burden of 
manufacturers in the event of updating existin g labelling schemes and would not require 
 
86 manufacturers and retailers to 'downgrade' thei r products in the event of an upgraded label. 
The 'buy A'  -slogan would have to be replaced by a 'buy green'  -slogan. 
 CECED continued that the indication of the labe l is legally binding for manufacturers but they 
should not be held res ponsible for re-labelling of alr eady sold products. EICTA supported 
CECED position reminding that products in the ICT sector develop very fast and could 
require frequent updates. CECED suggested that rescaling of energy labels that had taken 
place in Australia and Korea involved changes to  the label design. For consumers, changing 
only the scale of the label is less disturbing th an changing the whole label. All necessary 
efforts should be made to reduce the burden of th e label for those involved in the process, e.g., 
the label must be translated to the languages of the 27+7 European countries in which it is implemented.   ANEC/BEUC reiterated that the shortcoming of the energy scheme comes from its lack of flexibility and not on its layout. ANEC/BEUC opposed the suggested numerical scale and 
wanted to keep the A-G scale,  without A+ or A++. Consumer s are used to A-G and they 
should not be confused with a numerical labellin g scale. Any significant change to the label’s 
layout should be evaluated thro ugh extensive consumer researc h. Also, the existing label has 
been copied by a number of other economies a nd Europe should not in troduce a change to 
something that has proven to work. 'Buy A' has become a known slogan for efficient 
appliances among consumers and it works also with colour blind people.  
EUROCOMMERCE confirmed that some of th eir members had reacted positively to the 
proposed numerical scale but that  they did not make a final d ecision on the preferred option. 
EUROCOMMERCE was concerned a bout the number of revisions of existing labels, as it is 
the retailers that need to inform customers. Th ey would prefer that ap pliances in the stock 
should not be re-labelled, only new appliances. 
 To facilitate the transfer from the old to the ne w label BEUC the label should include the date 
on which it has been introduced. DENMARK suggested a transitional label but BEUC and ANEC objected, as the indication of the year of introduction was considered less confusing 
than a third intermediary label.  Environmental NGOs preferred the existing A- G label and requested regular updates of 
implementing Directives every five years. CECED opposed this propos al and suggested to 
update labelling scales depending on the type  of product and its specific technological 
development with 12 months of coexistence of the old and new label, at maximum. 
NETHERLANDS opposed the proposed 12-month coexistence but recognised the difficulty 
of manufacturers to update th e underlying label. Also ANE C and BEUC opposed the 12-
month coexistence suggesting 6 months as a maximum. Requests were also made to update old labels on a given fo reseen specific date. 
 FRANCE found the numeri cal scale interesting but supports the A-G scale because it is well 
known for consumers. GERMANY recognised that  there is no interest among retailers to 
downgrade their products in the event of an upgraded label. The N ETHERLANDS requested 
that the revised framework dir ective identify responsibilities in  the event of rescaling and 
specify the time for coexistence of different labels, which should be as s hort as possible. In 
the case of Energy-Star, manufacturers are re sponsible for implementing the requested 
changes and it works. UK welcomed the wo rk undertaken by CECED in developing a 
constructive proposal but strongly favoured the existing A-G scale until more information was 
available on the pros and cons  of the numerical scale.  
 
 
87 The NETHERLANDS asked the Comm ission to investigate whethe r there would be a legally 
acceptable procedure which would allow dyna mic and speedy decision on the date for 
updating the coloured background of the labe l in the “CECED” numerical scale.  
 At the end of the meeting, it was agreed that  a working group be established in order to 
identify the advantages and disa dvantages from the point of view  of manufacturers, retailers, 
consumers and public administrations in relati on to different labellin g scales and design. 
Proposals for participation in the working grou p could be made to th e Commission until 22 
February, at latest.   End of meeting.     
Annex 1: List of participants 
 
EU Member States 
 
Austria, Ministry of Economics and Labour 
Belgium Bulgaria, Ministry of Economy and Energy Denmark, Danish Energy Authority Estonia, Ministry of Economi c Affairs and Communications 
Finland, Ministry of Environment, Mi nistry of Employment and Economy 
France, Ministère charge de l'énergie and Ademe 
Germany, Ministry for the Environment, Fe deral Ministry of Economics and Technology, 
Dena, Fraunhofer ISI Italy, ENEA Lithuania, Energy Agency Luxembourg, Service de l'Energie de l'Etat Netherlands, Ministry of Econom ic Affairs and Senter-Novem 
Poland, Ministry of Economy Slovak Republic,  Slovenia, Ministry of Environment  Sweden, Swedish Energy Agency United Kingdom, Defra and Mark et Transformation Programme 
 EFTA Member Countries: Norway, Ministry of Energy 
 
Environmental NGOs and Consumer Associations 
ANEC, The European Consumer Voice in Standardisation 
BEUC, The European Consumer's Organsiation ECEEE, European Council for an Energy Efficient Economy ECOS, representing WWF, EEB, Friends of  Earth, Birdlife International, …  
Inforse-Europe, International Ne twork for Sustainable Energy 
 
Industry and Retailers 
CECED, European Committee of Do mestic Equipment Manufacturers 
CELMA, Federation of National Manufactur ers Associations for Luminaires and 
Electrotechnical Components for Luminaires in the European Union EHI, European Heating Industry EICTA, European Digital Technology Industry 
 
88 ELC, European Lighting Industry 
EPEE, European Partnership for Energy and Environment EuroAce, The European Alliance of Companies for Energy Efficiency in Buildings Eurocommerce, Association of retail, wholesal e and international trad e sectors in Europe 
Marcogaz, Technical Associati on of the Natural Gas Industry 
ORGALIME,  The European Engineering Industries A ssociation representing the interests of 
the Mechanical, Electrical, Electronic, Metalworking & Metal Articles Industries  
ETRMA, European Tyre & Rubbe r Manufacturers’ Association 
 European Commission: TREN,  ENV, ENTR