Commission staff working document accompanying the Proposal for a Directive of the European Parliament and of the Council establishing a framework for the setting of ecodesign requirements for energy related products - Summary of the impact assessment {COM(2008) 399 final} {SEC(2008) 2115}
Date: 2008-06-25
Institutions: European Commission
Subjects: EC conformity marking, eco-label, energy consumption, energy saving, energy-generating product, marketing standard

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 16.7.2008 
SEC(2008) 2116 

COMMISSION STAFF WORKING DOCUMENT 

accompanying the 

Proposal for a 

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

establishing a framework for the setting of ecodesign requirements for energy related 
products 

SUMMARY OF THE IMPACT ASSESSMENT 

{COM(2008) 399 final} 
{SEC(2008) 2115} 

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SUMMARY 

This  Impact  Assessment  accompanies  the  proposal  for  the  amendment  of  the  Ecodesign 
Directive for Energy Using Products1. The amendment of the Ecodesign Directive is one of 
the  elements  of  the  Action  Plan  on  Sustainable  Consumption  and  Production  and  on 
Sustainable Industrial Policy (SCP/SIP) which is a joint initiative of DG ENTR, DG ENV and 
DG TREN. The main element of the SCP/SIP is an integrated product policy. The Ecodesign 
Directive is an important building block of the Action Plan.  

The  current  Ecodesign  Directive  covers  only  energy  using  products  (excluding  means  of 
transport). For these and under the condition that no self-regulatory mechanism is offering a 
valid  alternative,  the  Directive  allows  the  setting  of  mandatory  minimum  requirements 
corresponding  to  the  performance  of  the  product  that  has  least  life  cycle  cost.  Also,  the 
Directive specifies a number of criteria and safeguards such that minimum requirements take 
into  account  competitiveness  and  social  issues.  This  guarantees  that  improvements  in 
environmental  performance  are  cost-effective.  While  the  purchase  prices  of  these  products 
might  rise  in  the  short  term,  their  superior  performance  more  than  offsets  this  over  the  life 
span of the product by lower usage costs. 

However,  the  impact  assessment  of  the  Action  Plan  mentioned  above  has  shown  that  the 
limited scope of the Ecodesign Directive represents an important restriction on the potential 
impact  that  the  EU's  Integrated  Product  Policy  can  have.  This  impact  assessment  report 
therefore analyses whether the scope of the Ecodesign Directive could be extended and what 
impacts  the  extension  could  have.  The  objective  of  the  report  is  therefore  to  provide 
information to policy makers on the possible scope of such an extension. 

Three options are considered:  

(1) 

(2) 

No extension of the scope, thus only energy using products can be covered, 

Extend the scope beyond energy using products maintaining the exclusion for means 
of transport, and 

(3) 

Extend the scope beyond energy using products including means of transport 

Changing  the  scope  of  the  Ecodesign  Directive  would  not  have  direct  impacts  on  products, 
since  the  Ecodesign  Directive  is  a  framework  Directive.  The  environmental,  economic  and 
social impacts are linked with the implementing measures for specific product groups. These 
implementing  measures  are  adopted  by  the  Commission  under  the  regulatory  comitology 
procedure.  Before  the  implementing  measures  are  adopted,  stakeholders  will  be  formally 
consulted  and  a  specific  impact  assessment  will  be  made  by  Commission  services.  All 
impacts mentioned in the report are illustrative examples of the impacts that could be reaped 
by  having  implementing  measures  for  products  of  the  different  options.  Moreover,  the 
impacts would only be realised in the long run since the adoption of implementing measures 
is done product by product and after a thorough assessment process.  

The  analysis  of  the  options  takes  into  account  a  number  of  issues.  First,  the  environmental 
impacts  are  discussed  for  broad  product  categories.  Second,  it  is  reviewed  whether  the 
Ecodesign Directive would overlap with existing legislation already addressing environmental 
impacts. Third the environmental improvement potential and the economic and social impacts 
of the options are assessed.  

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Dir 2005/32/EC  

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The  analysis  of  the  available  data  indicates  that  significant  reductions  of  environmental 
impacts  are  possible  while  at  the  same  time  also  allowing  economic  savings  for  businesses 
and  final  consumers.  Generally  speaking,  the  potential  benefits  are  larger  the  broader  the 
scope of products that can be addressed through implementing measures. 

Although the potential benefits would be highest in the case of covering all products (option 
3) the report shows that the Ecodesign Directive does not appear to be complementary to the 
Type-Approval System since much of the potential benefits in the transport sector will already 
be  reaped  by  forthcoming  legislation  such  as  the  CO2  in  cars  legislation  and  the  new  Euro 
standards. Within the products screened in Option 2 a high environmental impact that can be 
reaped  cost  effectively  would  come  from  energy  related  products  such  as  construction 
products and water using products. Furthermore, also a number of other product groups may 
offer  significant  potential  for  cost  efficient  improvements,  as  there  is  evidence  that  their 
impact  is  even  more  significant  than  both  the  Labouze  2003  and  the  EIPRO  study  have 
demonstrated when looking at products such as: detergent/cleaning products, footwear/leather 
products,  other  food  products,  print-media  (books,  journals,  newspaper),  hygiene  paper, 
mattresses,  batteries,  and  toys.  Ongoing  Commission  studies  will  look  further  into  the 
environmental  impact  and  improvement  potential  of  these  products.  Further  research  could 
also investigate the environmental and economic sustainability of the use of concrete/cement, 
steel, aluminium, plastics and other important materials. These product groups and materials 
are presented for illustrative purpose only.  

The screening analysis of the cost and benefits of option 1 and 2 shows that the importance of 
the  upfront  costs  is  highly  dependant  on  the  nature  of  the  products  and  even  between  sub-
categories  of  the  same  product  type.  In  the  illustrative  cases  analysed,  net  benefits  increase 
over time with an increased uptake of products responding to minimum requirements. 

An extended scope will allow introducing implementing measures for those non energy using 
product  categories  that  have  the  highest  potential  for  improvement  of  environmental 
performance while also leading to the highest savings during the use phase. This would not 
necessarily  be  possible  under  the  current  Directive  which  is  restricted  to  energy  using 
products. More detailed analyses will be conducted for the impact assessments that need to be 
prepared for each implementing measure. 

At this stage, it can be recommended based on the available evidence to widen the scope of 
the  Directive  to  energy-related  products.  Extending  the  scope  to  means  of  transport  would 
have  limited  benefits.  While  there  are  also  strong  indications  that  widening  the  Directive 
beyond  those  products  could  deliver  significant  benefits,  it  is  recommended  to  carry  out 
further investigations and further assess the option of including non-energy related products in 
the scope of the Directive following a future review.  

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