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 - Impact assessment {COM(2008) 399 final} {SEC(2008) 2116}
Date: 2008-07-16
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) 2115/2 

CORRIGENDUM: Erreurs mineures corrigées dans le tableau du chapitre 6 et changement 
dans la disposition de l’annexe VIII pour rendre les tableaux plus lisibles. 

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 

IMPACT ASSESSMENT 

{COM(2008) 399 final} 
{SEC(2008) 2116} 

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Table of Contents 

1. 

Procedural Issues and Consultation of Interested Parties ............................................ 5 

1.1. 

Consultation and expertise ........................................................................................... 9 

1.1.1.  Studies .......................................................................................................................... 9 

1.1.2.  Stakeholder Consultations............................................................................................ 9 

1.1.3.  Academic expertise consulted.................................................................................... 10 

2. 

2.1. 

2.2. 

Problem definition:..................................................................................................... 11 

Problem ...................................................................................................................... 11 

EU's right to act.......................................................................................................... 14 

2.2.1.  Treaty establishing the European Community........................................................... 14 

2.2.2.  Policy background...................................................................................................... 14 

2.2.3.  Subsidiarity and EU added value ............................................................................... 14 

3. 

4. 

5. 

6. 

7. 

7.1. 

7.2. 

8. 

9. 

Objectives:.................................................................................................................. 15 

Policy options............................................................................................................. 15 

Analysis of impacts .................................................................................................... 16 

Comparison of the options ......................................................................................... 36 

Administrative costs................................................................................................... 37 

For Member States and the Commission ................................................................... 37 

For Manufacturers...................................................................................................... 37 

Cost-effectiveness ...................................................................................................... 39 

Monitoring and evaluation ......................................................................................... 40 

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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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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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1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

The Ecodesign Directive 

This  Impact  Assessment  accompanies  the  proposal  for  the  amendment  of  the  Ecodesign 
Directive for energy using products2. This framework directive provides harmonised EU-wide 
rules for ecodesign of products to improve their environmental performance and ensure their 
free movement in the EU. The product scope of the Directive is energy using products (EuPs) 
with  the  exclusion  of  means  of  transport.  The  Directive  does  not  in  itself  introduce  directly 
binding  requirements  for  specific  products,  but  defines  conditions  and  criteria  for  setting, 
through 
regarding 
environmentally  relevant  product  characteristics  (including  energy  consumption)  and  allows 
to  improve  quickly  and  efficiently  the  performance  of  the  products  put  on  the  market. 
Minimum requirements are set aiming at the life-cycle cost minimum to end-users, taking into 
account  the  consequences  on  other  environmental  aspects.  Implementing  measures  are  only 
considered for products with significant environmental impacts and a significant improvement 
potential  through  their  design.  The  philosophy  of  the  directive  is  to  cover  only  a  limited 
number of products with a significant contribution to environmental performance.  

implementing  measures,  minimum 

requirements 

subsequent 

In Art 15 of the Directive the conditions and criteria for selecting products for which to set 
minimum requirements through subsequent implementing measures are explained. In Art 15.2 
the  necessary  three  criteria  to  be  fulfilled  by  any  product  in  order  to  be  included  in  the 
working  plan  are  presented.  Satisfying  these  criteria  is  the  first  step  in  the  procedure  that 
could lead to an implementing measure: 

(i) The product shall represent a significant volume of sales and trade, indicatively more than 
200,000 units a year within the Community. 

(ii) The product shall have a significant environmental impact within the Community. 

(iii)  The  product  shall  present  significant  potential  for  improvement  in  terms  of  its 
environmental impact without entailing excessive costs, taking into account in particular: 

- the absence of other relevant Community legislation or failure of market forces to address 
the issue properly.  

- a wide disparity in the environmental performance of products available on the market with 
equivalent functionality. 

These criteria can be applied to energy using products and non-energy using products 

Moreover, art 15.4 of the Directive presents the criteria which the Commission needs to take 
into account in preparing a draft implementing measure: 

(a) The life cycle of the products and its significant environmental impact 

(b) The impact in terms of competitiveness, for manufacturers, including SMEs, including on 
markets outside the Community, innovation, market access and cost and benefits. 

(c) Existing national environmental legislation. 

(d) Consultation with stakeholders 

(e) The setting of implementing dates, which could include staged or transitional measure or 
periods,  taking  into  account  in  particular  possible  impacts  on  SMEs  or  on  specific  product 

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groups  manufactured  primarily  by  SMEs.  For  example,  the  Commission  is  preparing 
implementing  measures  on  set  top  boxes  and  standby/off  mode  of  electric  equipment.  For 
both  implementing  measures,  staged  minimum  requirements  will  be  introduced  to  allow 
industry to adapt to the legislation. 

These criteria can be applied to energy using products and non-energy using products 

Finally, art 15.5 contains criteria that implementing measures need to satisfy: 

(a) There shall be no significant negative impact on the functionality of the products 

(b) Health, safety and the environment shall not be adversely affected 

(c)  There  shall  be  no  significant  negative  impact  on  consumers  in  particular  as  regards  the 
affordability and the life-cycle cost of the product 

(d) There shall be no significant negative impact on industry’s competitiveness 

(e)  In  principle,  the  setting  of  an  ecodesign  requirement  shall  not  have  the  consequence  of 
imposing proprietary technology on manufacturers 

(f) No excessive administrative burden shall be imposed on manufacturers. 

These criteria can be applied to energy using products and non-energy using products 

Besides,  Annex  I  and  Annex  II  of  the  Eco-design  Directive  identify  a  wide  list  of 
environmental  parameters  must  be  considered  when  studying  the  setting  of  minimum 
requirements.  The  methodology  used  for  developing  implementing  measures  considers, 
(among  others)  the  following  environmental  impacts:  energy,  water,  waste,  global  warming 
potential,  ozone  depletion  potential,  acidification, 
the  emission  of  volatile  organic 
compounds, persistent organic pollutants, heavy metals and particulate matter into the air. The 
current  methodology  for  setting  implementing  measures  identifies  the  aspects  of  products 
having  environmental  impacts  throughout  their  lifecycle,  analyses  the  potential  for 
improvement  and  identifies  best  available  technology.  On  the  basis  of  this  information, 
minimum  requirements  are  set  to  tackle  the  most  relevant  impacts.  Typically,  only  3-5 
parameters  would  be identified because they account  for a very  high proportion  of  the total 
environmental  impact  of  the  product.  The  methodology  for  setting  implementing  measures 
does  not  weigh  the  environmental  impacts.  In  practice,  the  European  Commission  decides, 
taking into account all evidence, what the most important environmental impacts of a product 
are. The list of environmental parameters can be used to reduce the environmental impacts of 
energy using and non-energy using products. 

Procedural steps before any implementing measure is adopted 

Before the Commission proposes an implementing measure, several steps have to be carried 
out.  

First, there is a need to define a working plan with candidate products to be studied. The first 
batch  of  products  was  included  in  the  Directive.  Currently,  the  Commission  is  identifying 
product  groups  to  be  tackled  in  the  following  three  years.  The  work  plan  is  made  after 
consultation of the stakeholders and analysing whether the products satisfy the requirements 
of art 15.2.  

Second,  it  is  necessary  to  launch  preparatory  studies  for  the  products identified  in  the  work 
plan  to  identify  which  eco-design  requirements  should  be  set  for  a  particular  product  to 
improve  the  environmental  performance  of  the  product.  The  preparatory  study  provides  the 
necessary information to prepare for the next phases to be carried out by the Commission.  

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Third,  as  requested  by  Art  18  of  the  Directive,  a  group  of  interested  parties  called 
“Consultation  Forum”  is  set  up  to  allow  stakeholders  to  be  informed  and  provide  their 
positions on the possible measures. The task of the Forum is to contribute, in particular to the 
definition  and  review  of  the  implementing  measures,  to  monitoring  the  efficiency  of  the 
established  market  surveillance  mechanisms  and  to  the  assessment  of  voluntary  agreements 
and  other  self-regulatory  measures  taken  in  the  context  of  the  Directive.  The  Forum  is  also 
consulted by the Commission during the periodic modification of the working plan.  

Fourth, an impact assessment is necessary for each proposal for an implementing measure. It 
will  assess  the  environmental,  economic  and  social  impacts  and  submitted  to  the  European 
Commission’s impact assessment board. 

Fifth,  the  Commission  shall  be  assisted  by  a  Committee  operating  under  the  regulatory 
procedure with scrutiny by the European Parliament. 

Sixth, the Commission adopts a proposal for an implementing measure following the normal 
procedures, including interservice consultations. 

In  summary,  the  procedures  that  are  specified  in  the  Ecodesign  Directive  guarantee  that  all 
concerned  parties  are  heard  and  all  evidence  is  considered  when  setting  implementing 
measures. Even if at the time of being developed, these provisions were drawn up to address 
mainly energy-using products, they can equally be applied to non-energy using products. 

Regulatory Dialogue 

It  should  be  mentioned  as  well  that  the  European  Commission  is  involved  in  formal 
regulatory  dialogues  with  its  main  trading  partners  and  with  international  organisations  on 
such issues as the harmonization of measurement methods/standards, benchmarking and other 
crucial  elements  directly  linked  to  the  setting  of  implementing  measures  of  the  Eco-design 
Directive. The draft measures are notified to the World Trade Organisation/Technical Barriers 
to Trade to ensure that no barriers to trade are introduced. Additionally the draft implementing 
measures  are  discussed  with  the  relevant  ministries  from  third  countries  in  the  frame  of 
regulatory  cooperation.  Manufacturers  from  outside  the  EU  are  encouraged  to  actively 
provide  input  when  implementing  measures  are  developed  and  the  all  process  is  made 
extremely transparent from the outset. 

Transposition 

The  Ecodesign  Directive  is  being  transposed  into  Member  States  legislation  and  there  are 
currently  7  MS  that  are  late  in  their  transposition  and  confronted  with  infringement 
procedures. This is not an unusual situation for a new Directive. Furthermore the delays did 
not have yet any practical consequences, as there is no effective application of the Directive 
until  Implementing  Measures  on  specific  products  have  been  adopted  and  are  applied.  The 
development  of  such  Implementing  Measures  is  under  way  and  the  first  ones  could  be 
adopted by the end of 2008.  

Conclusion 

The different criteria, procedures and other safeguards assure that economic and social issues 
are taken into account when setting minimum requirements. Therefore, the Directive is a good 
framework  for  reducing  negative  environmental  externalities  while  taking  into  account 
potential negative economic or social impacts.  

Since  the  same  policy  goal  is  aimed  at  for  non-energy  using  products,  the  same  criteria, 
procedures  and  other  safeguards  that  already  exist  for  energy  using  products  should  be  in 
place to guarantee the policy goal. 

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The current impact assessment 

The  Action  Plan  on  Sustainable  Consumption  and  Production  and  on  Sustainable  Industrial 
Policy  (SCP/SIP),  a  joint  initiative  of  DG  ENTR,  DG  ENV  and  DG  TREN,  will  propose 
actions  to  solve  market  and  regulatory  failures  which  prevent  improving  the  environmental 
performance of a large scope of products in Europe. The main element of the SCP/SIP is an 
integrated product policy. The Ecodesign Directive is an important building block thereof.  

This  impact  assessment  is  one  layer  in  the  analytical  framework  of  three  levels  of  impact 
assessments related to product policy.  

First, the impact assessment of the Action Plan focused on delimiting the problem definition 
and the remaining problems. In the Impact Assessment of the Action Plan it was clearly stated 
that  the  Action  Plan  would  only  look  at  existing  policy  instruments  and  how  to  coordinate 
them better. The Impact Assessment of the Action Plan discussed the options of business as 
usual,  a  voluntary  approach  or  a  mandatory  approach.  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 action plan concluded that a specific impact 
assessment was needed to look at the extension of the scope of the Ecodesign Directive.  

Second,  this  impact  assessment  focuses  on  the  identification  of  the  need  for  and  the  most 
adequate  extension  of  the  scope  of  the  Ecodesign  Directive.  It  will  start  addressing  the 
environmental, economic and social trends and impacts of the different options to the extent 
possible. The extension of the scope could be dealt with through a separate legal instrument, 
such  as  a  sister  directive  that  could  contain  similar  provisions  as  the  current  eco-design 
directive but be applicable only to non-energy using products. This option has been discarded 
because  two  separate  directives  with  exactly  the  same  material  content  but  different  scope 
would  not  only  pose  an  unnecessary  burden  for  the  Community  legislator  and  the  national 
Parliaments.  It  would  also  mean  adding  to  the  volume  of  the  acquis  communautaire  and 
creating confusion for enterprises that have to understand which of the directives is actually 
relevant  for  them.  This  is  fully  in  line  with  better  regulation  principles,  in  particular 
simplification. 

Third,  where  an  implementing  measure  will  be  proposed  for  a  product,  a  specific  impact 
assessment  will  identify  the  specific  problems  and  analyse  the  specific  environmental, 
economic and social impacts of setting minimum requirements. In the impact assessment for 
the specific product group, the Commission will set out how it respected the safeguards of Art 
15. 

The  impact  assessment  principle  of  proportionality  should  be  seen  in  light  of  these  three 
layers  of  impact  assessments  and  notably  the  guarantees  and  safeguards  stipulated  in  the 
Ecodesign Directive for the implementing measure stage.  

This document is prepared as a basis for comments and does not pre-judge the final form of 
any decision to be taken by the Commission. Moreover, all products categories mentioned in 
this document are only included for analytical purposes and do not prejudge any decision on 
the inclusion of products on the working plan for the Ecodesign Directive. Finally, all figures 
and numbers quoted in this Impact Assessment are of an indicative nature only.  

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1.1. 

Consultation and expertise 

An  inter-service  steering  group  was  consulted  on  the  impact  assessment.  The  meeting  has 
taken place on 28 February 2008. ECFIN, ENV, ENTR, TREN, SG and RTD were present. 
After  the  meeting  the  DG’s  present  have  been  informally  consulted  on  a  draft  impact 
assessment. The suggestions of the different directorate generals have been taken into account 
in drafting this impact assessment. 

1.1.1. 

Studies 

The results of a number of studies have been considered. Some of the most important are: the 
EIPRO  project3,  Labouze  et  al  (2003)4,  McKinsey  (2007)5  and  the  preparatory  studies  on 
implementing  measures.  The  results  of  the  different  studies  are  not  necessarily  consistent 
because  of  the  very  different  methodologies  used  to  evaluate  the  externalities  and  potential 
impacts. Yet, in general the results of the studies point out in the same direction. 

1.1.2. 

Stakeholder Consultations 

DG ENTR and DG TREN are in regular contact with their stakeholders.  

Two consultations on the Action Plan were organised: The first one was business oriented: a 
questionnaire was sent to around 4000 companies participating in the European Business Test 
Panel.  The  consultation  took  place  from  the  15th  of  September  to  the  15th  of  October  2007. 
354  companies  responded.  69%  of  the  businesses  surveyed  where  in  favour  of  applying 
minimum standards to improve energy and resource efficiency to a broad number of products. 
The  second  consultation  was  done  jointly  with  DG  ENV  and  concerned  the  Sustainable 
Consumption and Production and the Sustainable Industrial Policy Action Plan. The Internet 
consultation  on  the  basis  of  the  questionnaire  and  a  10  pages  background  document  was 
launched on “Your voice in Europe” and took place between the 27th of July and the 23rd of 
September.  It  addressed  both  stakeholders  (national  ministries,  industries,  associations, 
NGOs)  and  the  general  public.  Participants  to  the  consultation  were  also  invited  to  provide 
position  papers.  479  answers  were  submitted.  Enhanced  use  of  eco-design  instruments  was 
generally recognised as the first best action (67.3%). 83% of the respondents strongly agreed 
with extending  the product scope of  the  Ecodesign Directive. There was  a slight preference 
for concentrating on products improving resource and energy efficiency (79.1%). A majority 
of  the  respondents  (70%)  indicated  that  actions  need  to  tackle  environmental  problems  in  a 
cost-efficient  way  and  need  to  minimise  the  social  impacts.  Eleven  Member  States,  three 
Universities  and  forty-two  associations  and  companies  also  provided  position  papers.  See 
Annex I for a more detailed account of the stakeholder consultation. 

Stakeholders  have  been  generally  very  positive  to  the  philosophy  of  the  Directive  and  the 
possibilities  it  gives  to  manufacturers,  in  terms  of  self-regulation  and  cooperating  on  the 
development  of  implementing  measures.  However,  some  stakeholders6  have  recently  raised 

3 
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6 

http://ec.europa.eu/environment/ipp/identifying.htm 
The full reference for Labouze et al (2003) is Labouze, E., V. Monier, Y. Le Guern and J.-B. Puyou. 
(2003), Study on external environmental effects related to the lifecycle of products and services – Final 
Report  Version  2,  European  Commission,  Directorate  General  Environment,  Directorate  A  – 
Sustainable  Development  and  Policy  support,  BIO  Intelligence  Service/O2  France,  Paris,  France.  See 
Annex I for some detailed statistics from Labouze et al (2003). 
http://www.mckinsey.com/clientservice/ccsi/pdf/costs_and_potentials_of_geenhouse_gas_full_ 
report.pdf 
Orgalime letter to Vice President Verheugen dated on the 11th of April. Also the position by Business 
Europe. 

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some  concerns  about  the  revision  of  the  Ecodesign  Directive.  The  main  objections  are  the 
period of legal uncertainty for the mechanical engineering industry that would be induced by 
the revision as well as the strong resistance from other industries. The European Commission 
would  take  into  account  the  comments  of  these  industry  associations  by  proposing  only  a 
limited  recast  to  the  Ecodesign  Directive  to  modify  only  its  scope  without  altering  its  other 
provisions. This should not raise legal uncertainty for the industries whose products currently 
fall under the scope of the Directive. 

1.1.3.  Academic expertise consulted 

DG ENTR has drawn on the expertise of several academic institutions for the elaboration of 
this  impact  assessment.  The  Institute  of  Environmental  Science  of  the  University  of  Leiden 
has  shared  its  expertise  and  databases  for  the  life  cycle  assessment  of  the  environmental 
impacts of products. The “Zentrum für Europäische Wirtschaftsforschung“ (ZEW) assisted by 
providing input-output analysis on the environmental databases. 

1.2. 

Opinion of the Impact Assessment Board 

This  impact  assessment  report  was  drafted  following  the  remarks  in  the  request  for 
resubmission of the Impact Assessment Board of 21 April 2008 and the Final Opinion of the 
Board on the final draft issued on 6 May 2008. The following improvements have been made: 

A comprehensive section on the current eco-design directive has been included. This section 
focuses  on  explaining  that  the  provisions  of  the  Eco-design  Directive  are  suitable  to  cover 
non-energy using products. It sets out clearly that the goal of the Eco-design Directive is to 
reduce  negative  environmental  externalities  taking  into  consideration  the  social  and 
competitiveness  impacts.  It  is  explained  that  the  goal  is  realised  by  a  list  of  criteria  and 
procedures  for  setting  implementing  measures  included  in  the  Directive.  Two  examples 
(construction products and water using products) of the value added of an extended scope of 
the Directive are included. These two examples have an illustrative purpose and do not limit 
or prejudge any decision by the Commission. 

This  final  draft  makes  clear  that  all  products  and  impacts  in  this  report  are  for  illustrative 
purpose only. Moreover, it has been clarified to which extent specific product groups listed in 
the table could be potentially covered by the extension taking into account existing legislation 
and  how  existing  voluntary  measures  and  industry  standards  would  be  taken  into  account 
when  designing  implementing  measures.  Also,  art  1.4  of  the  Directive  has  been  taken  into 
account when selecting products.  

A number of methodological issues have been clarified. It has been clarified that the energy 
and  climate  package  is  not  taken  up  in  the  baseline  since  this  would  require  a  complicated 
modelling exercise. Also, it is explained that some thresholds used in this impact assessment 
are  purely  for  illustrative  reasons  and  that  for  future  implementing  measures  no  such 
thresholds  would  be  used.  Also,  it  is  clarified  that  the  thresholds  used  could  be  higher  or 
lower  and  that  this  would  alter  the  environmental  improvement  potential  but  not  the 
comparison of the three options. The text and Annex VII clarify the weightings used in this 
impact  assessment.  Moreover,  it  is  clearly  stated  that  the  weightings  are  for  illustrative 
purposes and that the European Commission does not use weightings to determine the most 
significant environmental impacts in the implementing measures.  

This draft elaborates on the international context of the Eco-Design Directive. It clarifies the 
role  of  existing  mechanisms  on  international  standards  and  regulatory  dialogues  with  main 
trading  partners,  and  confirms  that  the  impact  on  third  countries  will  be  addressed  when 
designing implementing measures. 

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The  Impact  Assessment  Board  requested  that  net  benefits  would  be  disentangled  into  both 
costs  and  gross  benefits.  This  has  been  done  for  illustrative  purposes  for  water  heaters  and 
windows.  The  more  aggregate  analysis that was initially  in  the  main  body  of  the  report  has 
been  explained  more  thoroughly  in  Annex  II,  explaining  underlying  assumptions  more 
carefully. 

2. 

PROBLEM DEFINITION:  

2.1. 

Problem 

As explained in the impact assessment of the SCP/SIP Action Plan, the way in which products 
are  made,  used,  consumed  and  disposed  of  can  have  negative  impacts  on  the  environment. 
The aim of policy action is not to reduce pollution and CO2 emissions to zero. The aim is to 
have  a  socially  desirable  level  of  consumption  and  production  on  the  one  hand  and 
environmental  impacts  on  the  other.  The  SCP/SIP  impact  assessment  identified  several 
market  failures  and  imperfections  that  currently  prevent  society  from  reaching  the  social 
optimum7. The most important are:  

•  Environmental externalities that result from prices that do not reflect the negative 

environmental impacts of the production or consumption of products. 

•  Information asymmetries that result from high transaction costs for consumers to 
obtain  relevant  information  on  product  characteristics.  Consumers  can  often  not 
tell whether a product is more resource efficient during its use phase than another. 

•  Bounded  rationality  that  can  explain  why  even  well-informed  consumers  do  not 
act  rationally  when  making  purchasing  decisions.  Even  if  consumers  have 
sufficient information,  they can be faced with high upfront costs when buying a 
more performing product, while the benefits accrue over a longer period of time 
(i.e. during its use-phase). Consumers may not take into account the use cost of a 
product but focus on the purchase price only.  

•  Principal-agent problems that occur where there is a misalignment of incentives of 

those purchasing the product (e.g. landlords) and those using it (e.g. tenants) 

•  The  above  market  failures  have  negative  effects  on  innovation  of  better 
performing  products  since  they  limit  the  demand  for  products  with  lower 
environmental impacts.  

The market failures identified in the impact assessment of the SCP/SIP Action Plan result in 
products  that  are  not  designed  such  that  environmental  impacts  of  products  over  their  life 
cycle are optimal from a social point of view.  

This is confirmed in reality. Based on a comprehensive list of environmental impacts for the 
EU,  Labouze  et  al  (2003)  calculated  the  total  external  cost  of  25  products  which  are 
commonly  seen  as  having  a  significant  environmental  impact  over  the  life  cycle.  For  each 
environmental impact Labouze et al report a minimum and maximum monetary value which 
corresponds  to  the  cost  of  that  environmental  impact  to  society.  The  monetary  values  are 
based on the lower and higher estimates found in the literature and are reported in Annex VII. 
In  Table1  below  the  monetary  values  for  the  environmental  impacts  are  aggregated  to  one 
monetary value which represents the cost of all environmental impacts studied by Labouze et 
al  for  that  product  group.  As  the  authors  stress  the  given  external  cost  figures  are  clearly 

7 

Impact Assessment of the SCP/SIP Action Plan, EC (2008) forthcoming 

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conservative estimates as many mechanisms and impacts that result in external costs could not 
be included. The true impact and potential is hence clearly higher. Also, and as a found more 
below,  the  numbers  for  non-energy  using  products  are  a  systematic  underestimate,  due  to 
limitations in data, assumptions of the study and a certain focus on energy-related emissions 
in the inventory data and impact assessment. The aggregated monetary value is mainly used 
implementing  measures  no  aggregation  of 
for  presentational  reasons.  For  setting 
environmental  impacts  will  be  done  and  the  European  Commission  can  decide,  taking  into 
account all evidence, which environmental impacts it deems most important. These minimum 
and  maximum  environmental  impacts  are  represented  per  capita,  for  the  EU-27  and  ranked 
per importance.  

Table1 External costs of environmental impacts per year 

Product 

Space heating 

Personal cars 

Goods transport8 

EuP domestic appliances 

Appliances and lights 

Textiles  

Building structure12 

Water heating 

Transport services 

Water supply12  

Cooking 

Furniture 

EuP IT 

per capita (€) 

EU-27 (bn €) 

Rank 

min 

max 

Min 

max 

min 

max 

41.3 

186 

20.3 

91.7 

32.2 

20.4 

15.6 

12.7 

11.6 

11 

8 

5.1 

3.5 

3.5 

3.3 

3.1 

90 

100 

101 

58 

67 

51 

38 

28 

42 

16 

14 

17 

15.8 

44.1 

10 

7.7 

6.2 

5.7 

5.4 

3.9 

2.5 

1.7 

1.7 

1.6 

1.5 

49.2 

49.5 

28.4 

32.9 

24.8 

18.9 

13.6 

20.5 

7.6 

6.9 

8.5 

1 

2 

3 

4 

5 

6 

7 

10 

14 

15 

16 

17 

18 

1 

4 

3 

2 

6 

5 

7 

10 

11 

8 

16 

17 

15 

Non eco-designable products 

47.7 

138 

22.4 

68.8 

Total 

219 

946 

106.4 

465.4 

Source: Labouze et al (2003) 

8 

Although these are not products, there are product design measures which can reduce the environmental 
impact of this category. 

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Products  to  which  eco-design  measures  can  be  applied  make  up  between  80  and  88%  of 
environmental impacts studied by Labouze et al. Total externalities are in the range of €219-
€946  per  capita  per  year.  For  the  EU-27  as  a  whole  these  externalities  amount  to  between 
€106.4-465.4 billion per year. In relative terms, th is is between 1.1% and 4.9% of EU GDP at 
the  time  of  publishing  the  study,  keeping  in  mind  the  already  mentioned  systematic 
underestimation  of  the  real  level  of  external  costs.  CO2  accounts  for  an  important  share  of 
total externalities: in the minimum scenario CO2 accounts for 77% of the externalities, in the 
maximum  scenario  CO2  accounts  for  only  44%9.  As  CO2  related  impacts  are  rather  well 
covered  in  the  external  cost  calculation  while  others  are  not,  the  true  relevance  of  CO2  is 
however lower.  

Remaining Problems, taking account of existing policies 

The  problem  definition  of  the  impact  assessment  of  the  Action  Plan  SCP/SIP  demonstrated 
that  a  number  of  policies  are  already  in  place.  It  identified  the  climate  package  (Emission 
Trading Scheme (ETS), renewables, sectors not covered by ETS), the directive on industrial 
emissions,  waste  legislation,  the  directive  on  Ambient  Air  Quality  and  Cleaner  Air  for 
Europe,  the  eco-label,  the  energy  action  plan  (energy  performance  of  buildings  directive, 
energy  efficiency  label  and  Ecodesign  Directive),  EMAS  and  ETAP.  However,  the  impact 
assessment of the Action Plan already pointed out that: 

•  Internalisation  policies  such  as  ETS  will  not  necessarily  result  in  consumers 
buying more environmentally efficient products that are optimal from a social- or 
even  consumer  perspective.  Information  asymmetries,  bounded  rationality  and 
principal-agent problems are not resolved by internalisation policies.  

•  The best way to foster environmentally efficient products is to complement price 
signals with an eco-design framework. The eco-design framework can assure that 
manufacturers produce products with environmental externalities that are optimal 
over  the  life  cycle  from  a  social  perspective.  Information  asymmetries  can  be 
resolved  by  providing  more  information  on  the  environmental  performance  of 
products.  Yet,  bounded  rationality,  principal  agent  problems  and  environmental 
externalities require a mandatory approach for product policy.  

•  Intervention on the environmental performance of products at Member State level 
might  erect  barriers  for  the  free  movement  of  products  in  the  internal  market. 
Therefore, public intervention at the EU level is justified for product policy. 

Based  on  the  definition  of  the  problem  and  the  results  of  the  Impact  Assessment  of  the 
SIP/SCP  action  plan,  the  Ecodesign  Directive  is  identified  as  a  useful  mandatory  tool  to 
address environmental externalities of products.  

However, currently the Ecodesign Directive covers only energy using products. But, energy 
using  products  are  only  responsible  for  31-36%  of  the  environmental  impacts  studied  by 
Labouze et al (see Table 2). Thus the identified market failures are currently not necessarily 
adequately addressed for other products that cause the majority of environmental impacts. 

9 

Based on Labouze et al (2003) 

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Table2 External costs of environmental impacts per year10 

per capita (€) 

EU- 27 (bn €) 

% of total 

min 

max 

min 

max 

Min 

max 

69.6 

341.6 

33.2 

167.9 

31% 

36% 

149.3 

604 

73.7 

297.9 

69% 

64% 

Energy using  

Products 

Other products 

Source: Labouze et al (2003) 

2.2. 

EU's right to act 

2.2.1.  Treaty establishing the European Community  

Article  94  &  95  of  the  EC  Treaty  state  that  the  Council  shall  adopt  the  measures  for  the 
approximation  of  the  provisions  laid  down  by  law,  regulation  or  administrative  action  in 
Member  States  which  have  as  their  object  the  establishment  and  functioning  of  the  internal 
market. This applies to all aspects of production, products and consumption in the EU.  

2.2.2.  Policy background 

The possible amendment of the Ecodesign Directive is part of the SIP/SCP Action Plan.  

2.2.3. 

Subsidiarity and EU added value  

The  subsidiarity  principle  applies  insofar  as  the  proposal  does  not  fall  under  the  exclusive 
competence of the Community.  

The objectives of the proposal cannot be sufficiently achieved by the Member States for the 
following reason: 

To leave the setting of ecodesign requirements for products to the Member States would lead 
to divergent national provisions and procedures having similar objectives that would generate 
undue  costs  for  industry  and  constitute  obstacles  to  the  free  movement  of  goods  within  the 
Community.  

Community action will better achieve the objectives of the proposal for the following reasons: 

Acting at the Community level is the only way to achieve the objective of the proposal while 
ensuring  that  the  requirements  for  products  placed  on  the  market  are  equal  in  all  Member 
States, thereby ensuring the free movement of goods in the Community. 

The  scope  of  the  proposal  is  limited  to  new  products  placed  for  the  first  time  on  the 
Community market.  

Action  at  the  Member  States  level  is  unlikely  to  address  environmental  problems  either 
efficiently or effectively. The impacts of climate change and air and water pollution are of a 
global  or  at  least  a  cross  border  nature.  Member  States  may  fail  to  take  into  account  the 

10 

EuP are the grouping of space heating, EuP domestic appliances, appliances and lights, water heating, 
cooking  and  EuP  IT.  Since  space  heating  impacts  can  be  solved  both  by  improving  the  energy 
efficiency  of  heaters  and  by  improving  the  energy  efficiency  of  the  insulation,  the  environmental 
impacts of space heating have been divided in 60% for EuP and 40% for non-EuP. The division is based 
on the estimation that up to 40% of the heating requirements can be saved by installing better insulation 
source:Ecofys (2002) 

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effects of domestically generated pollution that creates impacts outside national borders and 
therefore carry out insufficient abatement. 

3. 

OBJECTIVES:  

The  General  objective  of  this  proposal  is  the  same  as  the  overarching  one  for  the  SIP/SCP 
Action  Plan:  To  allow  industry  to  transform  environmental  challenges  into  economic 
opportunities  by  fostering  sustainable  production  and  consumption  on  the  basis  of  a  strong 
framework for product policy. 

This proposal seeks to contribute to the general objective by aiming to reduce environmental 
externalities  through  broadening  the  scope  of  products  covered  by  an  integrated  product 
policy (Specific objective). 

As  the  impact  assessment  on  the  Action  Plan  on  SCP/SIP  has  shown,  the  preferred  way  to 
implement  an  enhanced  Integrated  Product  Policy  is  to  extend  the  scope  of  the  Ecodesign 
Directive to cover additional product groups. The operational objective is therefore to extend 
the Ecodesign Directive such that products can be included which present significant potential 
for  improvement  in  terms  of  their  environmental  impact  without  entailing  excessive  costs 
(Based on the article 15 of Ecodesign Directive) 

4. 

POLICY OPTIONS 

The  policy  options  analysed  in  this  impact  assessment  only  look  into  the  most  appropriate 
product  scope  for  the  Ecodesign  Directive.  The  only  amendment  proposed  to  the  directive 
will  be  related  to  the  product  scope.  No  changes  are  necessary  for  the  procedures  of  the 
implementation of the Ecodesign Directive.  

The impact assessment does not need to consider a voluntary approach or self-regulation as an 
option: Article 17 and annex VIII of the Ecodesign Directive obliges the Commission to look 
into the option of a voluntary approach or self-regulation in the process of the adoption of an 
implementing measure for a specific product. Indeed, annex VIII of the Ecodesign Directive 
sets  out  the  criteria  for  the  admissibility  of  self-regulatory  initiatives  as  an  alternative  to 
implementing  measures.  Criteria 
added  value, 
representativeness, quantified and staged objectives, involvement of civil society, monitoring 
and  reporting,  cost-effectiveness  of  administering  a  self-regulatory  initiative,  sustainability 
and incentive compatibility. In general, the impact assessments of the implementing measures 
will  also  consider  whether  labelling  the  product  category  could  be  a  valid  alternative  to 
minimum requirements.  

are  openness  of  participation, 

Regardless of the option taken, the Directive, as do New Approach related Directives provides 
for  the  use  of  mandated  harmonised  standards  giving  presumption  of  conformity  to 
requirements of the Directive. The EU encourages that standards are developed at global level 
(Vienna and Dresden agreements) and there is scope for making use of adequate international 
standards.  However,  the  need  for  such  standards  is  determined  at  the  time  of  developing 
implementing measures for specific products. 

The three options identified for extending the scope are: 

Option 1: No Policy change (baseline) 

Under  this  option,  the  scope  of  the  Ecodesign  Directive  would  remain  as  it  is.  The  work  to 
develop  implementing  measures  for  the  priority  products  identified  in  the  directive  will  be 
continued. For street lighting products, office lighting products, stand-by and off-mode losses, 
external power supplies and simple set top boxes implementing measures would be adopted in 

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15 

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2008. For the other priority products identified in the directive the technical studies preparing 
the implementing measures would be completed as planned.11 The working plan that brings 
together and complements available information and arguments as to which products should 
be included among the indicative priorities would be adopted swiftly. 

Option 2: Extend the Ecodesign Directive beyond energy using products but the exclusion for 
means of transport would be maintained (art. 1.3) 

Under  the  second  option,  the  scope  of  the  Ecodesign  Directive  would  be  extended  beyond 
energy  using  products  but  the  current  exclusion  for  means  of  transport,  specified  in  art  1.3, 
would  be  maintained.  This  impact  assessment  presents  the  available  evidence  to  inform 
policymakers  on  which  product  groups  could  be  envisaged  under  such  extension.  As  this  is 
based  on  preliminary  screening  exercises,  this  must  not  exclude  other  product  groups  that 
need to be evaluated as well. As this is based on preliminary screening exercises, this does not 
exclude further product groups to be evaluated and to be considered under this, or a following, 
extension. 

The  implementing  measures  and  the  working  plan  of  the  baseline  scenario  would  be 
implemented without delay. 

After the adoption of the amended Ecodesign Directive by the EU the working plan would be 
updated  or  extended  to  cover  products  beyond  energy  using  products  while  maintaining  the 
exclusion  of  means  of  transport.  Based  on  this  working  plan,  technical  studies  for 
implementing  measures  per  product  group  would  be  launched.  Based  on  these  technical 
studies the Commission would prepare implementing measures for specific products. 

(4)  Option  3:  Extend  the  scope  beyond  energy  using  products  including  means  of 

transport 

The justification to include means of transport would be that means of transports have very 
significant environmental impacts.  

Under  this  Option  the  scope  of  the  Ecodesign  Directive  would  be  extended  beyond  energy 
using products and the exclusion of means of transport, currently specified in art 1.3, would 
be deleted.  

The  implementing  measures  and  the  working  plan  of  the  baseline  scenario  would  be 
implemented without delay. 

After the adoption of the amended Ecodesign Directive by the EU the working plan would be 
updated  or  extended  to  cover  products  beyond  energy  using  products.  Means  of  transport 
could also be taken up in the working plan. Based on this working plan, technical studies for 
implementing  measures  per  product  group  would  be  launched.  Based  on  these  technical 
studies the Commission would prepare implementing measures for specific products. 

5. 

ANALYSIS OF IMPACTS 

To  analyse  the  expected  impacts  of  extending  the  scope  of  the  EuP,  first  the  environmental 
impacts of  the  options are identified based on available information.  The analysis  is carried 
out at the level of broad product categories for which ecodesign can be applicable. The aim is 
to identify whether an extension of the scope of the framework directive could be beneficial 
or not. Second, it is investigated whether the Ecodesign Directive could apply to the product 
category.  This  is  done  by  looking  at  the  complementarity  of  the  Ecodesign  Directive  with 

11 

http://ec.europa.eu/energy/demand/legislation/doc/planning.pdf 

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existing  legislation  and  by  looking  at  the  applicability  of  the  concepts  of  the  Ecodesign 
Directive  to  the  product  group.  Finally,  indicative  potentials  in  terms  of  environmental 
improvement and economic and social impacts are assessed for the 3 options. 

Changing  the  scope  of  the  Ecodesign  Directive  does  not  have  direct  impacts  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  in  a  comitology  procedure.  As  the 
current  Ecodesign  Directive  already  mentions,  before  implementing  measures  are  adopted 
stakeholders will be consulted and a specific impact assessment will be made by Commission 
services.  All  results  presented  in  this  document  are  illustrative  of  the  impacts  that  could  be 
reaped by having implementing measures for products of the different options. 

Moreover, it is worth stressing that the impacts of the implementing measures would only be 
realised  in  the  long  run.  It  takes  time  to  develop  implementing  measures  because  it  is  done 
product by product and are only adopted after a thorough policy making process.  

Finally, it should be emphasised that for any implementing measures that could be adopted in 
the future, a much more detailed analysis will be carried out, as is already now the case for 
implementing measures under the Ecodesign Directive.  

Option 1: No Policy change (baseline) 

In this section evidence is presented on the environmental impacts of energy using products, 
then the potential of energy using products to reduce CO2 emissions is discussed, finally an 
assessment  is  given  of  the  environmental  impact  of  energy  using  products  beyond  CO2 
emissions. The assessment of the environmental improvement potential and the economic and 
social impacts of the three options is undertaken in a later section and summarised in Table 8. 

The baseline does not include the expected impact of the Energy and Climate change package 
on the improvement of the energy efficiency. 

The  Emission  Trading  Scheme  (ETS)  forces  producers  to  buy  emission  rights  for  their 
production related CO2 emissions. It is likely that producers would at least pass through some 
of these costs to consumers. These increased costs will to some extent change the behaviour 
of consumers. To model these pass through effects and their impact on consumer behaviour 
requires very complicated modelling and is beyond the scope of this impact assessment. One 
of the most likely direct effects is a higher electricity price. This electricity price will make 
energy  savings  products  even  more  beneficial.  Consumers  would  rationally  react  to  higher 
electricity prices  by saving energy by for example buying more energy efficient  appliances. 
However,  as  demonstrated  in  the  problem  section  (and  in  the  impact  assessment 
accompanying  the  SCP/SIP  action  plan)  and  also  recognised  in,  for  example,  the  Stern 
Report,  product  policy  can  complement  the  ETS  since  it  solves  some  market  failures  not 
directly  addressed  by  ETS,  in  particular  relating  to  information  asymmetries,  bounded 
rationality and principal agent problems. For the comparison of the different options it seems 
that not including ETS in the baseline does not change the comparison between Option 1 and 
Option  2.  For  both  a  higher  electricity  price  seems  the  most  significant  impact  of  ETS. 
However, some means of transport under option 3 are not directly affected by the electricity 
price. Therefore, Option 3 seems less affected by ETS than option 1 and 2.  

The  renewable  energy  targets  of  the  Energy  and  Climate  Package  will  decrease  the  CO2 
content  of  electricity  production.  This  will  make  the  CO2  savings  of  energy  efficiency 
measures smaller. However, there seems again no difference for the comparison of option 1 
and 2 concerning the impact of the renewable energy targets.  

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Based on Labouze et al (2003), the environmental impact of energy using products is between 
31%  and  36%  of  all  impacts  studied.  See  table  3.  It  is  to  be  stressed  that  due  to  the  pre-
selection, as done by the Labouze study, of product groups that are commonly understood to 
have  a  high  environmental  impact,  many  of  which  are  energy  using  products,  these  are 
overrepresented. Important meta groups of products including food are under-addressed. That 
means  that  the  true  contribution  of  EuPs  to  the  overall  environmental  impact  is  lower  than 
approximated,  i.e.  the  importance  for  extending  the  EuP  Directive  to  non  EuP  products  is 
higher  than  found  by  that  study.  Furthermore,  the  study  of  Labouze  does  not  differentiate 
between different production processes. This is obviously especially relevant for non-energy 
related  products,  which  are  dominated  by  the  production  phase.  Considering  this  additional 
argument it can be concluded that the relative share of non energy using products among the 
overall impact is much higher than the stated ca. 66%. 

Table 3 Environmental impacts of energy using products, yearly values 

per capita (€) 

EU-27 ( bn €) 

% of total impact 

Product 

Min 

max 

min 

max 

min 

max 

Space heating12 

24.6 

111.6 

12.18 

55.02 

11% 

12% 

EuP domestic appliances 

Appliances and lights 

Water heating 

Cooking 

EuP IT 

16 

13 

8 

4 

3 

101 

58 

38 

16 

17 

7.7 

6.2 

3.9 

1.7 

1.5 

49.5 

28.4 

18.9 

7.6 

8.5 

7% 

6% 

4% 

2% 

1% 

11% 

6% 

4% 

2% 

2% 

Total EuP 

68.6 

341.6 

33.18 

167.92 

31% 

36% 

Source: Labouze et al (2003) 

Energy using products are responsible for a substantial share of greenhouse gas emissions and 
have  a  demonstrated  improvement  potential.  The  preparatory  studies  for  the  implementing 
measures of specific products have largely confirmed the environmental savings potential and 
have demonstrated that the minimum requirements could lead to significant monetary savings. 
Indeed,  the  studies  for  the  implementing  measures  of  the  Ecodesign  Directive  have  shown 
that for boilers and water heaters a mix of ecodesign, installation and labelling requirements 
would result in yearly net savings of €45 billion as of 2020 13. In addition, extrapolations based 

12 

13 

Since space heating impacts can be reduced both by the improving the energy efficiency of heaters and 
by improving the energy efficiency of the insulation, the environmental impacts of space heating have 
been divided in 60% for EuP and 40% for non-EuP. The division is based on the estimation that up to 
40% of the heating requirements can be saved by installing better insulation source:Ecofys (2002). 
See p 32. of R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of 
Boilers (2007), Task 7, p. 39 and R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study 
on the Ecodesign of Water Heaters (2007), Task 7. And see p 39 of R. Kemna, M. van Elburg, W. Li, 
R. van Holseijn. Preparatory study on the Ecodesign of Boilers (2007), Task 7, p. 39 and R. Kemna, M. 
van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of Boilers (2007), Task 7 

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on  a  recent  study  by  McKinsey  discussed  in  Annex  II  seem  to  confirm  that  significant 
amounts of CO2-equivalents can be saved while saving money to the consumer.  

For  other  significant  environmental  parameters  the  reduction  potential  for  energy  using 
products is less significant. Table 4 below shows the share of CO2-equivalent related costs in 
the  cost  of  total  externalities  for  energy  using  products.  The  share  of  cost  related  to  CO2-
equivalents  in  total  environmental  cost  is  between  44%  and  86%.  It  could  reach  90%  for 
specific energy using products such as space heating and water heating.  

Table 4 Share of Greenhouse gases in environmental impacts for energy using products, 
yearly values 

Per capita (€) 

% of total external costs for 
considered products14 

Min 

22.2 

13 

11 

8 

3 

2 

59.2 

169 

Max 

56.6 

32.4 

28.9 

19.5 

7.9 

6.1 

151.4 

416 

min 

90% 

83% 

87% 

99% 

86% 

65% 

86% 

77% 

max 

51% 

32% 

50% 

51% 

51% 

35% 

44% 

44% 

Product 

Space heating 

EuP domestic appliances 

Appliances and lights 

Water heating 

Cooking 

EuP IT 

Total EuP 

Total Products 

Source: Labouze et al (2003) 

Conclusion 

The  main  conclusion  of  this  section  is  that  the  current  possible  coverage  of  the  Ecodesign 
Directive has a significant potential to reduce CO2 and other greenhouse gas emissions, by far 
the  most  significant  environmental  impacts  of  energy  using  products.  In  the  section  on 
environmental  impacts  below,  summarized  in  Table  8,  it  will  be  demonstrated  that  the 
potential  of  ecodesign  for  energy  using  products  to  reduce  other  environmental  impacts 
beyond CO2 is more limited. 

14 

It is to be stressed that the calculation of external costs necessarily overestimates the relevance of CO2 
as  many  other  environmental  impacts  are  not  included,  e.g.  land  use  (e.g.  for  agriculture,  mining, 
transport,  housing)  opposed  to  nature,  which  is  in  between  understood  to  be  of  similar  relevance  as 
climate change. 

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Option  2:  Extend  the  Ecodesign  Directive  beyond  energy  using  but  the  exclusion  of 
means of transport would be maintained (art. 1.3) 

In this section evidence is presented on the applicability of the eco-design directive for non-
EuP and the environmental impact of all products, except means of transport. The assessment 
of the environmental improvement potential and the economic and social impacts of the three 
options is undertaken in a later section and summarised in Table 8.  

Table  5  shows  the  products  that,  based  on  a  preliminary  screening  in  Annex  III,  satisfy  the 
requirements of art 15.2 of the Ecodesign Directive. These product groups are presented for 
illustrative purpose only and do not imply that the European Commission would take them up 
in  the  Working  Plan.  Indeed,  the  analysis  done  here  is  proportionate  for  this  impact 
assessment.  To  select  the  products  for  the  Working  Plan  the  European  Commission  would 
consult stakeholders and check the requirements of art 15.2 in much more detail before taking 
a policy decision on which products to include in the Working Plan. For example, the product 
groups  referred  to  in  the  below  table  are  quite  broad.  For  the  working  plan  the  product 
definition would be narrower such that a much more precise judgment could be made whether 
to include a product in the Working Plan or not. Moreover, the inclusion of a product in the 
Working Plan does not necessarily imply that an implementing measure would eventually be 
adopted for that product by the European Commission. 

Based  on  a  preliminary  screening,  the  products  that  satisfy  art  15.2  of  the  Ecodesign 
Directive would be construction products, textiles, water using products and furniture. These 
products account for 22-25% of the environmental impacts studied by Labouze et al (2003). 
As already discussed this is however underestimated (see in above section on Option 1).  

Table  5  Environmental  impacts  of  non-energy  using  products  excluding  means  of 
transport, yearly values 

Product15 

Space heating16 

Textiles  

Building structure 

Water supply17  

Furniture 

Total 

Source: Labouze et al (2003) 

per capita (€) 

EU-27 ( bn €)  % of total impact 

Min 

max 

Min  

max 

min  

Max 

16.5 

74.4 

8.12 

36.68 

11.6 

11 

3.5 

3.3 

67 

51 

42 

14 

5.7 

5.4 

1.7 

1.6 

32.9 

24.8 

20.5 

6.9 

8% 

5% 

5% 

2% 

2% 

8% 

7% 

5% 

4% 

1% 

45.9 

248.4. 

22.5 

121.8 

22% 

25% 

15 

16 
17 

To avoid double counting water heating has been omitted from this list although more resource efficient 
water using apparatus also impact on the water heating requirements. 
See footnote above on how space heating has been divided in an EuP part and a construction part. 
Although water supply is not a product, eco-design measures on water using products could reduce the 
demand for water and thus alleviate the environmental impact of water supply. 

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Important  impacts  can  be  expected  from  the  inclusion  of  construction  products  such  as 
windows  and  insulation  for  refurbishings  not  covered  by  the  Energy  Performance  of 
Buildings  Directive.  For  construction  products,  implementing  measures  could  improve  the 
insulation  capacity  for  example  by  setting  a  maximum  U-value  according  to  the  intended 
purposes. U-values summarise the capacity of a material to retain heat, the lower a U-value 
the better the insulation capacity. 

Also other categories can have significant impacts. For water using products examples of eco-
design measures are:  

•  Sensors such that the water stops flowing in the absence of movement.  

•  Infusion of air into water to decrease the water content per volume unit. Infusing air into 

water allows saving water without changing the functionality of water using products. 

•  Toilettes with a dual flush such that the consumer can choose to flush 4 or 6 liters of water. 

•  The  main  benefits  of  ecodesign  for  water  using  products  would  be  a  reduction  in  total 
water  use  of  5.2%.  Moreover,  less  hot  water  spent  by  shower  implies  also  less  energy 
needed to heat it, which would save 0.20-0.23% of total final energy consumption in the 
EU-25  which  corresponds  to  18.2  -  21.7  Mt  CO2  emissions  saved  per  year.  Reducing 
water use would also lead to the reduction of environmental impacts of water supply. This 
reduction potential would be reaped at a rate of 3% a year18, at low or no extra costs.19 See 
Annex IV for more details. 

Unfortunately is the Labouze study is limited in scope; while more advanced studies such as 
EIPRO  find  other  relevant  non-energy  related  products  with  very  high  impacts  .  Some 
environmental impacts are not appropriately covered as the data used by Labouze et al (2003) 
was  limited  e.g.  regarding  a  number  of  relevant  emissions  (e.g.  human  and  ecotoxicity;  as 
stated by the authors). As a result; products with a higher relevance in these areas are poorely 
represented in the overall results (e.g. paper products). Due to lack of data or incomplete data 
(especially for the production stages as can be seen in the annex of the study), the impact of 
non-energy using products is additionally underestimated.  
Possible large improvement potentials in this area will require further investigation of these 
products.  
The  Ecodesign  Directive  encourages  self  regulation  as  an  alternative  to  implementing 
measures (art 17). The indicative criteria for the admissibility of self-regulatory initiatives as 
an alternative to an implementing measure in the context of  this  Directive are:  Openness of 
participation;  Added  Value;  Representativeness;  Quantified  and  staged  objectives; 
Involvement of Civil Society; Monitoring and reporting; Cost-effectiveness of administering a 
self-regulatory initiative; sustainability and incentive compatibility. Several sectors could be 
interested in self-regulation.  

Conclusion 

In summary, this section shows that there are non-energy using products that would meet the 
requirements of art 15.2 of the Ecodesign Directive. Moreover, for many t of these products 
there is a clear potential for ecodesign measures that appear to be cost effective. Below, see 
Table 8, evidence will be presented that overall environmental improvements are substantial 
as well. 

18 

19 

A replacement rate of 3% is the rate commonly used for construction products. This replacement rate 
assumes that all construction products have an average life time of 33 years. 
See annex IV and footnote 75. 

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(5)  Option  3:  Extend  the  scope  beyond  energy  using  products  including  means  of 

transport 

This section presents evidence on the environmental impact of means of transport. Then the 
potential  of  these  products  for  reducing  CO2  emissions  is  discussed.  In  addition,  it  is 
discussed  whether  the  Ecodesign  Directive  is  the  appropriate  framework  to  regulate  the 
environmental  impacts  of  means  of  transport.  This  exercise  is  done  separately  for  road 
transport  and  other  means  of  transport.  The  assessment  of  the  environmental  improvement 
potential  and  the  economic  and  social  impacts  of  the  three  options  is  undertaken  in  a  later 
section and summarised in Table 8.  

Table 6 shows that the environmental impact of means of transport is between 23% and 26% 
of all impacts studied.  

Table 6 Environmental impacts of means of transport, yearly values 

per capita (€) 

EU-27 (bn €) 

% 
of 
impact 

total 

min 

max 

Min 

max 

min 

max 

32 

20 

5 

58 

90 

15.8 

44.1 

15% 

9% 

100 

10.0 

49.2 

9% 

11% 

28 

217 

2.5 

13.6 

2% 

3% 

28 

107 

26% 

23% 

Product 

Personal cars 

Goods transport 

Transport services 

Total means of transport 

Source: Labouze et al (2003) 

These  figures  show  that  the  environmental  impacts  of  means  of  transport  are  sizeable. 
Passenger  cars  account  for  most  of  the  environmental  impacts.  Ecodesign  measures  can  be 
taken for the overall vehicle or for the engine and transmissions. For the overall vehicle one 
can improve the aerodynamics, optimise the weight of the car or reduce the rolling resistance 
of the tyres. For the engine and transmissions improvements the most promising technologies 
that  exist  today  reduce  the  internal  friction  in  engines  and  improve  thermal  management. 
Goods transport also has an important share of environmental impacts. Ecodesign measures in 
light commercial trucks, reduction of internal engine friction and improved aerodynamics are 
the  two  most  cost  effective  ones.  For  medium  to  heavy  commercial  vehicles  (trucks  and 
busses)  the  main  design  lever  is  improvements  of  the  power  train.For  trains,  measures  to 
improve the energy recovery when breaking, lightweight modular construction and two-level 
carriages are available design improvements that would abate CO2. In air transportation one 
needs  to  further  optimise  the  construction  of  planes  as  regards  materials  application  and 
engine  efficiency.  To  improve  the  environmental  performance  of  existing  planes  one  can 
retrofit them with winglets or reduce the weight of the seats used. Finally, transport services 
have a small contribution to environmental impacts.  

In  the  next  stage  it  is  investigated  whether  the  cost  effective  level  of  abatement  will  be 
reached  by  forthcoming  legislation  and  whether  the  Ecodesign  Directive  is  the  appropriate 
legislative  tool  for  means  of  transport.  This  is  done  for  vehicles  first  and  then  for  the  other 
means of transport. 

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Vehicles 
Road transport accounts for 73% of total energy demand for means of transport20. 

The proper functioning of the Internal Market for vehicles is based on the EC Type-Approval 
System.  This  system  provides  for  market  access  throughout  the  EU  for  new  vehicles 
complying with technical requirements relating to health, safety and environmental protection 
provided by a wide range of  Directives  and  Regulations. Compliance with the legislation is 
assessed before the vehicles are placed on the market.  

With regard to the environmental performance of motor vehicles existing Community policies 
largely address two main issues:  

•  Pollutant emissions from vehicles (including Nitrogen Oxides, Particulate Matter, 
Carbon  Monoxide,  etc)  are  regulated  through  the  so-called  Euro  standards, 
providing limit values for the emission of these pollutants from new vehicles. The 
Euro  standards  are  becoming  more  stringent  over  time  to  reflect  the  increasing 
need  for  environmental  protection  and  to  adapt  to  technical  progress.  The  latest 
adopted standards are the Euro 5 and 6 standards21 for light duty vehicles and the 
Euro V standards22 for heavy duty vehicles. The present Euro standard for mopeds 
and  motor  bikes23  is  currently  reviewed  and  the  Commission  is  preparing more 
stringent limit values for these vehicles. 

•  CO2 emissions from cars are addressed in an integrated approach. A proposal for 
the  main  regulation  of  that  approach  was  adopted  in  December  2007  and  is 
currently  being  discussed  in  Council  and  Parliament.  The  regulation  would 
introduce  CO2  emission  limits  for  manufacturers  of  120  g  CO2  per  km  for  the 
average  new  passenger  car  fleet  in  2012.  Several  other  proposals  further 
contributing  to  reduced  CO2  emissions  are  in  preparation.  One  example  is  the 
upcoming  proposal  on  rolling  resistance  of  tyres  and  tyre  pressure  monitoring 
systems, expected to be adopted by the Commission during the second quarter of 
2008.24  Other  types  of  vehicles  (such  as  light  commercial  vehicles,  trucks  and 
busses and motorbikes) do not have binding CO2 targets yet. The Commission is 
in the process of evaluating suitable measures and test methods but no decisions 
on  the  principles  have  been  taken  so  far.  In  principle,  the  Ecodesign  Directive 
could regulate this. 

In  addition  to  these  two  major  groupings,  there  are  several  other  community  policies 
addressing the environmental impact of motor vehicles. These include the Directives on end-
of-life-vehicles (recycling)25 and the use of certain refrigerants in air-conditioning systems26.  

With  regards  to  pollutant  emissions,  existing  type  approval  legislation  is  already  forcing 
manufacturers to take environmental impacts into consideration when designing the vehicles. 
With regard to CO2 emissions, manufacturers already take this aspect into consideration when 
designing  the  vehicles,  and  will  give  it  even  more  attention  in  the  future  following  the 

20 
21 
22 

23 
24 

25 
26 

IEA (2006) Energy Technology Perspectives. 
Regulation (EC) No 715/2007 
Directive  2005/55/EC.  The  Commission  adopted  a  proposal  for  the  Euro  VI  standards  in  December 
2007, currently discussed in Council and Parliament. 
Provided for by Directive 97/24/EC 
These  two  tyre  related  aspects  of  CO2  emissions  from  cars  will  be  included  in  a wider  proposal  also 
covering safety aspects of motor vehicles. 
Directive 2000/53/EC 
Directive 2006/40/EC 

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adoption  of  the  legislative  proposals  under  discussion  in  Council  and  Parliament.  For 
example, the impact assessment for a regulation to reduce CO2 emissions from passenger cars 
specified  that  600  M/tonne  CO2  emissions  would  be  saved  by  the  regulation  between  2010 
and  202027.  The  regulation  would  also  reduce  fine  particulate  matter  (PM)  by  at  least  3%, 
SO2 by at least 14% and NOX by at least 4%. Moreover, the Euro 5 and Euro 6 standards will 
substantially reduce the quantity of PM in the EU.  

In summary, given i) the existing regulatory requirements, ii) the measures proposed by the 
Commission  but  not  yet  adopted  and  iii)  the  balance  between  environmental  and  safety 
criteria that are inherent to the Type-Approval System it seems that including motor vehicles 
under  the  Ecodesign  Directive  would  have  a  somewhat  limited  complementary  abatement 
potential. Due to the complexity of existing legislation related to environmental performance 
mentioned  above  it  was  not  possible  to  determine  further  improvement  potential  resulting 
from applying ecodesign principles to road transport vehicles. 

Other means of transport 

The  potential  benefits  of  covering  other  means  of  transport  are  smaller  compared  to  road 
transport  but  still  significant.  Air  transport  accounts  for  11%  of  total  energy  demand  for 
means of transport, water transport for 9% and rail for 3%.28 

There  is  however  a  number  of  reasons  why  it  will  be  difficult  to  apply  the  Ecodesign 
Directive  to  means  of  air-,  water-  and  rail  transport.  The  volumes  sold  in  EU-27  for  these 
products  are  below  the  threshold  of  200,000  specified  in  art  15.2  (a)  of  the  Ecodesign 
Directive29. Moreover, airplanes and ships are continuously entering and exiting the EU. The 
international nature of these products makes it difficult to regulate the design in a European 
legislation. . In addition, in Air Transport the main operational cost is and will increasingly be 
fuel consumption. Thus, less fuel - and hence less CO2 emissions - is already the main market 
driver  for  aircraft  design.  Finally,  for  all  other  means  of  transport  design  is  often  customer 
specific which also renders the applicability of the eco-design approach difficult. 

Conclusion 

In  summary,  this  section  shows  that  means  of  transport  have  a  sizeable  impact  on  the 
environment  and  that  there  is  a  potential  to  reduce  CO2  emissions.  However,  the  potential 
abatement  in  the  transport  sector  seems  to  be  largely  addressed  and  the  limited  potential 
benefits  of  applying  the  ecodesign  approach  to  regulate  means  of  transport  seems  not  to  be 
proportionate in view of the difficulties that that would engender. 

Analysis of environmental, economic and social trends and impacts of the three options 

In this section the environmental, economic and social impacts of the three options are further 
assessed.  

27 
28 
29 

Table 5 on p 85 of SEC(2007) 1723 
IEA (2006) Energy Technology Perspectives. 
See annex IV for the statistics. However, this threshold is only indicative. 

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Environmental impacts 

To assess the potential of the options to improve on the significant environmental parameters, 
a simulation has been undertaken based on the EIPRO database for the EU-2530. The EIPRO 
database contains information on the environmental impact of 480 sectors that span the total 
economy in the EU-25. The EIPRO database considers the environmental impact parameters 
of  abiotic  depletion,  global  warming,  ozone  layer  depletion,  human  toxicity,  freshwater 
aquatic  ecotoxicity,  marine  aquatic  ecotoxicity,  terrestrial  ecotoxicity,  photochemical 
oxidation, acidification and eutrophication. Finally, these impacts are weighed and condensed 
by EIPRO into one environmental impact parameter. The weighted cumulative environmental 
impact  is  primarily  for  presentational  purpose  and  for  easy  comparison  of  the  options.  As 
already mentioned, the methodology for setting implementing measures allows the European 
Commission to decide which environmental impacts it deems important and it is by no means 
bound to the analytical approach taken here. 

The  simulation  imposes  an  exogenous  improvement  in  the  environmental  performance  of 
10%  or  15%.  The  10%  or  15%  appear  conservative  based  on  the  efficiency  improvement 
potential between average product performance and suggested minimum requirements in the 
preparatory  studies  currently  undertaken  for  the  Ecodesign  Directive.  For  the  worst 
performing  products  in  a  product  range  the  improvement  potential  will  off  course  be  much 
higher.  Nonetheless,  this  simulation  should  be  seen  as  illustrative.  For  some  products,  the 
10% or 15% can be assumed to be too low or too high.  

In  the  Directive,  implementing  measures  are  only  considered  for  products  with  significant 
environmental impacts. Therefore, for the purpose of the example, the simulation considered 
improvement only in the cases of products whose environmental impact are higher than 0.5% 
of the total environmental impacts in Europe. This is an arbitrary cut-off used for illustrative 
purposes for this impact assessment.31 Another illustrative threshold, e.g. 1% or 2.5%, could 
have been used. Other thresholds would alter the environmental improvement potential but it 
would not have significantly altered the comparison of the three options. For the purpose of 
selecting  the  products  for  which  implementing  measures  are  considered  the  European 
Commission does not intend to use this kind of quantitative threshold. 

Since the environmental impact of the agricultural phase of the life cycle of food is already 
covered  by  the  principle  of  cross  compliance  under  the  Common  Agricultural  Policy,  this 
stage has been excluded from the analysis.  

Based  on  these  selection  criteria,  there  are  7  product  categories  that  qualify  under  option  1 
(Table  7).  These  product  categories  represent  12.6%  of  weighted  cumulative  environmental 
impacts. There are 11 additional product categories under option 2 that represent an additional 
15.0%  of  weighted  cumulative  environmental  impacts.  As  argued  above  this  is  an 
underestimation.  ,.  Finally,  one  product  category  under  option  3  represents  an  additional 
18.8% of weighted cumulative environmental impacts. The weights used for the aggregation 
are the ones utilised in the EIPRO study, which were reviewed by the JRC. 

30 

31 

The EIPRO database is probably the most comprehensive IO-table of environmental impacts of sectors 
in Europe. It contains 480 sectors and 283 consumption sectors. It was built up by adapting US data to 
EU’s  context  and  production  structure  and  was  calibrated  to  ensure  that  the  sum  of  the  individual 
impacts  sum  up  to  EU-25  estimated  total  environmental  impacts,  in  particular  in  terms  of  CO2 
emissions. For each broad product category, the whole life-cycle costs are included. The EIPRO data is 
an  approximation  to  the  quantification  of  the  environmental  impacts,  which  can  be  useful  to  identify 
major trends due to policy changes. The reference year is 2000 
Since this simulation is for illustrative purposes, no information is given on which product groups are 
included and which are not.  

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Table 7 Summary statistics for the products used in the simulation 

Option 1

Option 2 

Option 3 

% of total current environmental impacts covered

12.6%  27.6% (+15%)  46.4% (+33.8%)

Number of product categories 

7 

18(11) 

19(12) 

In brackets the differences to the baseline option are represented. 

The results of the simulation are shown in Table 8 below. These results are illustrative.  

Table 8 Annual environmental effect of improving the environmental impact of selected 
products by 10% in 202032 33 relative to current products 

Category 

Option 1 

Option 2 

Option 3 

Abiotic depletion 

global warming  

ozone layer depletion  

Human toxicity  

0.0% 

-9.5% 

-2.5% 

-5.5% 

-0.1% 

-2.4% 

-0.3% 

-2.5% 

Freshwater aquatic ecotoxicity  

-0.1% 

-0.6% 

Marine aquatic ecotoxicity  

Terrestrial ecotoxicity  

photochemical oxidation  

acidification  

eutrophication  

Weighted sum 

-0.1% 

-3.8% 

-0.2% 

-0.8% 

-0.4% 

-3.0% 

-4.2% 

-5.2% 

-1.2% 

-2.1% 

-1.5% 

-4.0% 

-9.9% 

-7.4% 

-2.5% 

-5.4% 

-0.8% 

-4.0% 

-1.1% 

-5.5% 

-6.3% 

-3.7% 

-5.8% 

As  can  be  deducted  from  Table  8  above,  and  under  the  mentioned  restrictions  of  an 
underestimation  for  non  energy-using  products,  Option  1  reduces  the  weighted  cumulative 
environmental impact of the economy by 1.5% compared to the status quo today. The main 
impacts  are  on  global  warming  (-2.5%  of  total)  and  acidification  (-4.2%).  For  other 
environmental parameters, the impacts of option 1 are smaller. Option 2 reduces the weighted 
cumulative environmental impact by at least 4.0% compared to the status quo. Compared to 

32 

33 

Since  the  use  phase  of  products  is  also  assumed  to  be  improved  by  10  or  15%,  the  results  implicitly 
assume  that  all  products  are  new  products.  Therefore,  the  results  need  to  be  interpreted  as  annual 
environmental  improvements  in  2020.  The  forecast  do  not  take  into  account  changes  in  economic 
structure or the climate change package.  
See Annex V for a definition of technical terms used in this table. 

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Option  1  the  additional  improvement  potential  of  Option  2  is  at  least  2.5%.  The  main 
additional  impacts  are  on  abiotic depletion,  global  warming  and  marine  depletion.  Option  3 
reduces the weighted cumulative environmental impact of the economy by 5.8% compared to 
the status quo. The additional improvement potential of Option 3 over option 1 is -4.3% and 
the main additional impacts compared to Option 1 are on abiotic depletion, global warming, 
human toxicity, marine aquatic ecotoxicity and photochemical oxidation.  

The  environmental  improvement  potential  of  the  products,  regardless  of  the  option,  will  be 
realised  over  the  life  cycle  of  the  product.  This  implies  that  this  improvement  potential  is 
gradual and for durable products will only be reaped over the somewhat longer term. 

The  conclusion  of  this  section  is  that  Option  3  could  have  the  biggest  environmental 
improvement  potential.  However,  since  most  of  the  additional  improvement  potential  of 
Option 3 compared to option 2 is already addressed by forthcoming legislation, Option 2 and 
Option 3 would have similar environmental improvement potential. 

Competitiveness  

This  section  looks  into  the  competitiveness  aspect  of  extending  the  Ecodesign  Directive.  A 
general discussion is followed by a discussion of the internal competitiveness aspects and the 
competitiveness impacts for SMEs. 

Art 15.5 (d) imposes on the European Commission that implementing measures for products 
cannot have a significant negative impact on industry’s competitiveness. This implies that the 
European Commission needs to assure that implementing measures are only set such that this 
condition 
the  following  dimensions  of 
“competitiveness”  need  to  be  looked  at:  SMEs,  innovation,  market  access  and  other 
international competitiveness aspects, and cost and benefits.  

is  respected.  Art  15.4  (b)  clarifies 

that 

Cost and benefits 

It  is  not  straightforward  to  conduct  an  analysis  of  the  cost  and  benefits  of  potential 
implementing measures without knowing in detail which products would be covered and how 
minimum  requirements  would  be  set.  Besides,  the  portion  of  the  impacts  of  ecodesign  in 
option  3  (transportation  means)  not  covered  by  existing  or  planned  legislation  are  not 
differentiable in the current datasets34.  

However,  to  provide  some  indication  of  the  nature  of  the  costs  and  benefits  over  time  of 
options 1 and 2, the same case studies (water heaters, windows) used in the SCP/SIP Impact 
Assessment,  using  the  same  sources  of  information,  were  analysed  in  greater  detail.  The 
results  are  presented  in  Tables  9,  10  and  1135  below.  This  analysis  is  illustrative  only,  but 
deemed appropriate for the purpose of the current impact assessment. Full blown analysis of 
the  costs  and  benefits  of  all  potential  implementing  measures  is  neither  proportionate  nor 
feasible  at  this  stage.  A  more  detailed  analysis  will  be  done  when  identifying  the  minimum 
requirements for the product groups . 

To analyse potential impacts in the two case studies, the period between 2010 and 2019 was 
selected.  For  this  period  of  time,  discounted  upfront  costs  of  least  life-cycle  costs  products 
were compared with the discounted upfront cost of products considered to be the “baseline”. 
In  the  simulation,  it  was  estimated  that  water  heaters  are  replaced  every  ten  years  and  that 

34 

35 

For  example,  the  case  of  more  performing  tyres,  a  product  that  could  be  covered  by  Ecodesign,  is 
already  considered  in  the  Proposal  for  a  Council  and  Parliament  Regulation  on  Advanced  Vehicle 
Safety and Tyres. 
For a detailed presentation of the analysis, see Annex VIII 

EN 

27 

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windows36 are replaced every 25 years. This implies that 4% of all windows are replaced in a 
given year. These payment flows and the benefits (differences in  energy consumption) over 
time were discounted at a rate of 4%. The results are presented in terms of net flows (cost-
benefits)  (Table  9).  The  detailed  flow  of  potential  cost  and  benefits  is  presented  in  Annex 
VIII.  

Table  9  Present  value  of  net  benefits  from  the  inclusion  of  minimum  performance  for 
one example of products in options 1 and 2 (in 2007 Euros) 

Year  2010  2011  2012 2013 2014 2015 2016 2017  2018  2019 Total

Option 
1 
Products 

Option 
2 
Products 

Water 
heaters 
"extra 
small" 

Water 
heaters 
"extra 
large" 

Windows 
(50% 
double 
glazing) 

Windows 
(only 
double 
glazing) 

-195 

-99 

-18 

49 

104 

148 

184 

211 

233 

248 

865 

684  1563  2277 2848 3297 3640 3894 4072  4185  4244 30704

- 

1,020   - 708   - 418 

- 150 

98  

327 

539 

734  

913   1,077  1392 

-
2040 

-

1416  -837

-300

196 

655  1078 1468  1826  2154 2784 

Source: own estimations from the same sources used in the SCP/SIP Impact Assessment 

In the case of water heaters, it appears that there are already appliances in the market that are 
not  only  more  attractive  from  a  life-cycle  perspective  but  also  from  the  up-front  costs  (the 
“extra-large”  case).  This  implies  that  benefits  would  be  derived  from  the  beginning  of  the 
application  of  the  implementing  measure.  In  the  other  case  (extra  small  water  heaters  and 
windows with different proportions of double glazing in the refurbishment) the up-front costs 
are  higher  than  the  ones  of  less  efficient  products,  implying  that  the  aggregate  investment 
would pay-off only in the longer term.  

In  terms  of  energy  savings,  the  penetration  of  more  performing  products  would  induce 
important savings in all the cases (Table 10). 

36 

It is estimated that half of the existing windows have already been replaced by more performing ones. 
Therefore the analysis concentrates only on the proportion still to be refurbished. This analysis is done 
only  for  illustrative  purposes.  In  order  to  simplify  the  analysis,  only  double  glazed  windows  are 
associated with more efficient insulation performance. However, the Commission is aware that double 
glazed  windows  are  not  needed  for  every  intended  purpose  in  the  EU  for  the  purpose  of  improving 
insulation.  Single  glazed windows have  also  improvement  potential  in  terms  of  insulation, which  can 
contribute  to  energy  savings.  The  estimates  presented  consider  two  replacement  shares  with  double 
glazed windows: 50% and 100% of yearly refurbishment.  

EN 

28 

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Table 10 Energy savings per year in GWh 

Year 

2010  2011  2012  2013  2014  2015  2016  2017  2018  2019  Total 

Option 
1 
products 

Option 
2 
products 

Water 
heaters 
"extra 
small" 

Water 
heaters 
"extra 
large" 

891  1782  2673  3564  4455  5346  6236  7127  8018  8909  49001 

4007  8014  12022 16029 20036 24043 28050 32058  36065  40072 220396

Windows 
(50% 
double 
glazing)  1669  3337  5006  6674  8343  10011 11680 13348  15017  16685 91769 

Windows 
(only 
double 
glazing)  3337  6674  10011 13348 16685 20022 23359 26696  30034  33371 183538

Source: own estimations from the same sources used in the SCP/SIP Impact Assessment 

In terms of CO2 emissions, each of these products would increasingly reduce the emissions 
associated with their use (Table 11). 

Table 11 emissions savings per year (M t of CO2) 

Year 

2010  2011  2012 2013 2014 2015 2016 2017  2018  2019  Total

Option 
1 
Products 

Option 
2 
Products 

Water 
heaters 
"extra 
small" 

Water 
heaters 
"extra 
large" 

Windows 
(50% 
double 
glazing) 

Windows 
(only 
double 
glazing) 

1 

1 

2 

2 

3 

4 

4 

5 

5 

6 

33 

3 

5 

8 

11 

14 

16 

19 

22 

25 

27 

150 

1 

2 

3 

5 

6 

7 

8 

9 

10 

11 

63 

2 

5 

7 

9 

11 

14 

16 

18 

21 

23 

126 

Source: own estimations from the same sources used in the SCP/SIP Impact Assessment 

It  is  clear  that  addressing  both  energy-using  and  non-energy  using  products  could  improve 
their  performance  and  would  complement  the  Climate  and  Energy  package  adopted  by  the 

EN 

29 

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Commission in January 2008. As mentioned above, these are only examples37 of the potential 
direction  of  the  impacts  and  do  not  imply  any  commitment  to  introduce  implementing 
measures  for  these  products.  A  more  thorough  analysis  would  be  undertaken  in  the  impact 
assessment of each implementing measure. 

In addition, it needs to be reminded that the provisions of Art 15.5 (d) require such analysis by 
the European Commission in the Impact Assessment of the implementing measures. The kind 
of analysis that would be undertaken at the product level:  

•  The  Commission  will  look  at  how  costly  it  is  to  redesign  the  manufacturing  process  for 
those producers whose products would not meet the minimum requirements. Based on this 
information  it  will  take  a  decision  on  the  timing  of  the  phasing  in  of  the  minimum 
requirements. 

•  The Commission will look at the variable cost of adjusting the product in question when 

determining the level of the minimum requirements. 

•  The  Commission  will  look  at  the  amount  of  existing  stock  of  products.  This  information 
will  be  taken  into  account  when  deciding  the  timing  of  the  phasing  in  of  the  minimum 
requirements.  

Some general competitiveness aspects of the options 

The  extension  of  the  Ecodesign  Directive  should  allow  the  introduction  of  implementing 
measures for products with significant environmental impact and significant potential for the 
improvement  of  that  environmental  impact  at  the  lowest  economic  cost  to  society.  By 
maintaining the product scope of Option 1, the full reduction potential which can be reaped at 
no extra cost or even at a gain to private individuals, is not reached. If one would try to reduce 
certain  environmental  impacts  with  the  current  product  scope  nothing  guarantees  that  this 
happens  in  a  cost  effective  way.  For  example,  water  efficient  appliances  such  as  showers, 
taps, washing machines and dish washers all offer households possibilities for water saving38, 
equally  diminishing  the  energy  required  to  heat  the  water.  Installing  water  efficient 
appliances,  e.g.  by  eco-design,  for  all  of  them  can  reduce  the  use  of  a  household  from  280 
l/day today to 167 l/day, representing total savings of 41% of household water use. Yet, under 
the  current  scope  of  the  eco-design  directive,  only  the  water  use  of  washing  machines  and 
dish washers can be regulated. Installing water efficient appliances for energy using products 
only  has  a  potential  to  reduce  the  water  use  of  a  household  by  12  l/day,  representing  total 
savings  of  4%  of  household  water  use.  If  one  would  need  to  go  beyond  4%  savings  for 
households  and  the  scope  of  the  Ecodesign  Directive  would  be  only  energy  using  products, 
the  current  technology  would  not  suffice  and  it  would  be  very  costly  to  reach  this  higher 
target.  On  the  other  hand,  with  an  extended  scope  one  can  go  beyond  4%  reduction  with 
existing technologies at lower additional cost.  

International Competitiveness 

As already stated before, a regulatory dialogue with the main trading partners is ongoing on 
the  implementing  measures  of  the  Eco-design  Directive.  Moreover,  manufacturers  and 
countries  from  outside  the  EU  can  participate  in  the  consultation  forum  for  implementing 
measures of specific product groups.  

37 

38 

Another examples can be found in Annex II, in which a rough extrapolation of the results of a study 
prepared by McKinsey for BDI is presented. 
Numbers based on DG ENV (2007) EU Water saving potential study done by ecologic 

EN 

30 

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The  Ecodesign  Directive  is  an  Internal  Market  Directive  and  will  only  apply  to  products 
placed  on  the  market  in  Europe.  Regardless  of  which  options  are  taken,  imported  products 
would  need  to  comply  with  the  minimum  requirements,  while  exported  products  would  not 
need  to  comply  with  the  minimum  requirements.  Thus,  minimum  requirements  guarantee  a 
level playing field both within and outside Europe. It should be noted that if these two level 
playing  fields  are  sufficiently  different  it  might  be  necessary  for  manufacturers  to  have  two 
separate production lines, one for products complying with minimum requirements in the EU 
and  one  for  the  rest  of  the  world.  This  creates  additional  costs.  However,  all  manufacturers 
willing to be present on both markets will incur these costs no matter where they are located. 
Therefore there should be no competitive disadvantage for EU producers on export markets 
unless foreign producers decide to only serve the rest of the world and thus to save costs for a 
second  production  line.  Given  the  substantial  size  of  the  EU  market  this  is  not  particularly 
likely. It has to be pointed out that if tighter standards in the EU are considered desirable and 
the rest of the world does not adopt them, this additional cost is unavoidable. 

Art 15 requires the European Commission to look into the international competitiveness issue 
when considering implementing measures. In designing the implementing measures carefully 
taking  into  account  international  competitiveness,  the  European  Commission  can  avoid  a 
distortion of the international competitive balance. To achieve this it would need to take into 
account whether manufacturers are active on the domestic market versus internationally, fixed 
versus variable adjustment cost for manufacturers and access to technology. For the different 
options it seems that all goods in option 1 and 3 are traded internationally. Some products in 
option  2  such  as  textiles  are  internationally  traded  goods  whereas  other  products  such  as 
windows are not traded internationally to a large extent. Therefore, for products of option 2, it 
will be important to assess on a case by case basis whether international competitiveness is an 
issue.  
To  the  extent  that  demand  for  environmental  products  is  on  the  rise  globally39,  new  export 
opportunities might arise for European and foreign products that comply with the minimum 
requirements.  

Competitiveness of SMEs 

It is also worthwhile to look into the impacts that the Ecodesign Directive will have on SMEs. 
The  Ecodesign  Directive  can  have  important  benefits  for  SMEs.  For  all  SMEs,  office 
machinery  and  equipment  will  become  cheaper  because  of  option  1  and  heating  costs  for 
offices will be reduced because of option 1 and option 2.  

Only 12% of all SMEs are in the manufacturing sector. Those SMEs are responsible for 26% 
of  all  turnover  for  SMEs.  Also  for  SMEs  in  the  manufacturing  sector  there  are  important 
benefits. All motors purchased by SMEs will be cheapest over the life cycle under option 1. 
This implies that manufacturing SMEs will have a lower energy bill.  

For SMEs in the services sector there will only be benefits in terms of cheaper products over 
the life cycle. SMEs in this sector make up 88% of all SMEs and are responsible for 74% of 
all turnover of SMEs in 2005 for EU-27. Therefore, for most SMEs there is no downside to 
the  Ecodesign  Directive  under  either  option.  Moreover,  for  some  there  is  a  considerable 
upside. For example, small retailers will have commercial refrigerators that are more energy 
efficient.  

39 

See Roland Berger (2007) Elements of a European Ecological Industrial Policy Working Paper to the 
Informal Meeting of Environment Ministers in Essen, Prepared for the German Presidency of the EU in 
2007. 

EN 

31 

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However,  some  SMEs  will  need  to  demonstrate  that  their  products  satisfy  the  minimum 
requirements. 

The  above  shows  that  one  cannot  make  a  general  statement  of  the  impact  of  the  Ecodesign 
Directive  on  the  competitiveness  of  SMEs.  Therefore,  the  Ecodesign  Directive  contains 
safeguards  such  that  implementing  measures  will  take  into  account  the  competitiveness  of 
SMEs: 

•  Art 15.4 (b) requires the Commission to look into the issue of competitiveness for 
SMEs when preparing an implementing measure. Together with Art 15.5 (d) this 
implies  that  the  Commission  will  consider,  if  the  competitiveness  of  SMEs 
requires  it,  a  transitional  period  or  a  stage  approach  when  setting  minimum 
requirements and/or set the minimum requirements taking into account SMEs.  

•  Art 13.1 imposes an obligation on the Commission to take into account initiatives 
to help SMEs with ecodesign in the context of programmes from which SMEs can 
benefit.  This  is  for  example  done  via  the  Enterprise  Europe  Network.  The 
Enterprise  Europe  Network  and  other  dissemination  channels  will  encourage 
SMEs  to  adopt  environmentally  friendly  and  energy  efficient  solutions.  The 
Enterprise  Europe  support  centres  will  consult  and  advise  SMEs.  Moreover,  the 
action will aim at developing content for training and dissemination of tailor made 
information  on  the  subject  of  energy  saving  and  environmental  compliance  in 
SMEs.40  

•  Art 13.2 obliges Member States to ensure, in particular by strengthening support 
network and structures, that they encourage SMEs to adopt ecodesign principles. 

In summary, the implementing measures will need to take into account the competitiveness of 
SMEs when setting the level and timing of minimum requirements. 

Conclusion 

This section has shown that limiting the product scope to Energy Using Products (Option 1), 
does  not  allow  reaping  the  full  reduction  potential  of  environmental  impacts  that  can  be 
attained in a cost effective way. There are no indications that any of the three options would 
harm  the  competitive  position  of  European  manufacturers  in  the  world.  Also  for  the 
competitiveness of SMEs there is no indication that one particular option would be more or 
less harmful for the competitiveness of SMEs. The impact assessments of the implementing 
measures will need to look into the competitiveness aspects in detail for a specific product. 

Social dimension 

This  section  looks  into  the  social  dimension  of  the  different  options.  First,  it  discusses  the 
social  implications  of  lower  environmental  impacts.  Second,  it  discusses  the  short  term  and 
long  term  implications  of  the  Ecodesign  Directive.  Finally,  the  employment  effects  of  the 
different options are discussed.  

An extension of the Ecodesign Directive will allow setting minimum requirements such that 
products' environmental impacts are optimal over the life cycle. Each implementing measure 
will need to weigh the gains from reducing the environmental impact against the abatement 
cost. The abatement cost includes effects on jobs, competitiveness and affordability.  

Based on the simulations presented above one can give an illustrative indication of the social 
gains  due  to  the  avoidance  of  externalities  of  option  1,  2  and  3.  This  can  be  done  by 

40 

Announced in the forthcoming SIP/SCP action plan 

EN 

32 

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multiplying the environmental reduction potential by the cost of externalities.41 The gains of 
option  1  would  minimally  be  €3  per  year  per  capita.  For  option  2  and  3  the  minimal  gains 
would be respectively €9  and €13 per capita per year. 

Table 12 Cost avoided per capita per year 

€ 

option 1  option 2 

Option 3 

min 

max 

3 

14 

9 

38 

13 

55 

For  the  EU-27  as  a  whole  this  corresponds  to  minimal  savings  of  between  €1.6  billion  for 
option 1, €4.3 billion for option  2 and €6.2 billion for option 3. 

Table 13 Cost avoided for the EU-27 

€ 

option 1  option 2  option 3

min 

max 

1.6 

7.0 

4.3 

6.2 

18.6 

27.0 

In  a  number  of  cases,  the  reduction  of  externalities  also  generates  savings,  notably  for 
products whose highest environmental impact occurs during the use phase. 

From  a  social  point  of  view,  any  extension  of  the  scope  of  the  Ecodesign  Directive  might 
create difficulties for low income households in the short term since it is expected that those 
products  that  will  be  removed  from  the  market  because  they  do  not  fulfil  the  minimum 
requirements are the cheapest ones and thus most easily affordable. However, these products 
also  have  higher  life  cycle  costs  and  thus  permanently  expose  low  income  households  to 
budget  pressure,  particularly  with  respect  to  energy  expenditures.  The  Ecodesign  Directive 
would instead allow a long term budgetary improvement for all households. Nonetheless, art 
15.5 (c) obliges the European Commission to set implementing measures such that there shall 
be no significant negative impact on consumers in particular as regards the affordability and 
the  life-cycle  cost  of  the  product.  Therefore,  the  European  Commission  will  consider  when 
setting  implementing  measures  foreseeing  transitional  periods  or  a  staged  approach  for  the 
introduction  of  minimum  requirements  and  will  set  minimum  requirements  to  balance 
affordability  and  the  life-cycle  cost  of  the  product.  Furthermore,  short-term  adjustment 
difficulties  for  low  income  households  could  be  alleviated  by  financial  measures  by  the 
Member States.  

Moreover, the impacts on competitiveness and the social dimension of introducing minimum 
requirements  are  likely  to  be  limited  over  the  long  run.  This  is  due  to  the  tendency  for 
appliances to become cheaper the more appliances are produced (economies of scale). A shift 
in  demand  towards  higher  energy  efficient  appliances  will  imply  that  over  time  the  cost  of 
these appliances will go down. The figure below indicates that from the 1960’s until now real 

41 

Note that this is not entirely accurate since the calculations are done on the weighted impacts. A correct 
calculation would be based on the individual improvements of the environmental impacts. This is not 
straightforward  since  the  cost  factors  for  environmental  impacts  of  Labouze  et  al  (2003)  do  not 
correspond to the environmental impacts of EIPRO. 

EN 

33 

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prices  of  energy  efficient  energy  using  products  have  fallen  on  average.  In  Annex  III  more 
detailed figures are shown disaggregating the price and resource efficiency effects over time.  

Figure 1 Relation between energy efficiency and prices for energy using products over 
time 

Source: Weiss, Junginger and Patel (2008) unpublished 

The Ecodesign Directive and employment 

Finally,  one  should  also  assess  the  employment  effects  of  extending  the  scope  of  the 
Ecodesign Directive.  

The academic literature does not provide conclusive evidence on the relationship between the 
environment and jobs. Studies by Morgenstern et al. (2002) and Berman and Bui (2001), for 
the  case  of  US,  find  no  evidence  that  environmental  regulations  have  adversely  affected 
industrial  employment.  Other  studies  for  the  US  indicate  that  industries  located  in  counties 
with stringent regulations have experienced job losses, or at the very least lower employment 
growth  rates,  relative  to  industries  in  less  regulated  counties42.  Cole  and  Elliott  (2007) 
examine the impact of environmental regulations on employment for the UK43. No significant 

42 

43 

Henderson,  V.  (1996).  Effects  of  Air  Quality  Regulation.  American  Economic  Review,  86:  789-813. 
Kahn, M.E. (1997). Particulate Pollution Trends in the United States. Journal of Regional Science and 
Urban  Economics,  27:  87-107.  Greenstone,  M.  (2002).  The  Impact  of  Environmental  Regulations  on 
Industrial  Activity:  Evidence  from  1970  and  1977  Clean  Air  Act  Amendments  and  the  Census  of 
Manufacturers. Journal of Political Economy, 110 (6): 1175-1219. 
Matthew  A.  Cole  and  Rob  J.  Elliott  (2007)  “Do  Environmental  Regulations  Cost  Jobs?  An  Industry-
Level Analysis of the UK,” The B.E. Journal of Economic Analysis & Policy: Vol. 7: Iss. 1 (Topics), 
Article 28. 

EN 

34 

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trade-off  between  employment  and  the  environment  is  found.  The  preferred  option  of  the 
climate package is projected to have a +0.05% effect on employment in the EU-2744. 

Since,  the  Ecodesign  Directive  is  an  Internal  Market  Directive  it  will  apply  to  any  product 
placed on the EU market regardless of the place where the goods are produced. Therefore, it 
is unlikely that delocalisation and the resulting job losses would occur as a consequence of the 
enlargement of the scope of the Ecodesign Directive.  

However,  although  the  effect  on  the  total  economy  might  be  non-negative,  some  industries 
can  be  negatively  affected  by  environmental  legislation.  Yet,  there  is  evidence  that  those 
effects  are  sometimes  overstated  initially.  The  effects  of  the  US  Acid  Rain  Programme  on 
coal  mining  employment  had  originally  been  estimated  at  13000-16000  by  the  year  2010. 
Current estimates are in the range of 4100 net jobs lost.45 

Finally, there is some evidence that energy efficiency measures lead to job creation in Europe. 
One  study  determined  the  employment  effects  of  energy  conservation  schemes  for  France, 
Germany,  The  Netherlands,  Spain  and  the  United  Kingdom46.  In  all  countries,  the  energy 
conservation  schemes,  both  for  EuP  and  energy  saving  appliances  such  as  insulation  or 
windows have been found to create employment. France has since 1974 a programme of tax 
incentives in place to favour energy saving investments for residential space heating. Over the 
lifetime  of  the  Income  Tax  Incentive  scheme  71,000  labour  years  have  been  created.  For 
Germany,  the  employment  impact  of  the  Thermal  Insulation  programme,  which  imposes 
insulation requirements for new buildings, is 40,100 labour years for the period up to 2010. 
The condensing boiler programme in the Netherlands, which promotes the uptake of energy 
efficient boilers, induces a total cumulative employment effect of 3,800 labour years over the 
period 1995-2010. 

The  main  driving  force  behind  the  positive  employment  effect  of  investment  in  energy 
efficiency  in  the  residential  sector  is  the  fact  that  the  energy  sector  has  rather  low  labor 
intensity.  The  resulting  shift  of  expenditures  from  the  energy  sector  to  other  sectors  with 
higher  labor  intensity  leads  to  increased  employment.  Labor  intensity  is  higher  in  the 
construction  sector  which  needs  to  install  energy  efficient  appliances  than  in  the  EuP 
producing goods or the transport manufacturing sector. This would imply that the products of 
option 2 would be the most positive for employment. 

Conclusion 

In  summary,  this  section  discussed  the  social  impacts  of  the  different  options.  The  main 
conclusions  are  that  option  2  and  3  result  in  lower  environmental  impacts  which  have  a 
sizeable social value compared to option 1. Regardless of the option, minimum requirements 
for products can result in short term negative income effects for poor income households but 
these  are  offset  by  positive  income  effects  over  the  longer  term.  This  is  because  minimum 
requirements  are  set  such  that  products  have  the  lowest  life  cycle  cost.  These  long  term 
benefits are general since higher volumes for products with lower environmental impacts will 
result  in  price  declines  for  these  products.  Finally,  there  is  no  evidence  that  either  of  the 
options will result in job losses. However, it will be necessary that social impacts are carefully 
scrutinised in the impact assessments of the implementing measures. 

44 
45 
46 

See Table III of Annex I of SEC(2008) 85/3. 
http://www.epa.gov/airmarkt/resource/docs/coalemployment.pdf 
H.  Jeeninga,  C.  Weber,  I.  Mäenpää,  F.  Rivero  García,  V.  Wiltshire,  J.  Wade  (1999).  Employment 
Impacts of Energy Conservation Schemes in the Residential Sector, project for DG TREN. 

EN 

35 

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6. 

COMPARISON OF THE OPTIONS 

As  already  indicated  above,  the  possible  extension  of  the  scope  of  the  Ecodesign  Directive 
does not trigger any direct cost or benefits. The cost and benefits of the Ecodesign Directive 
will only arise when an implementing measure will be set for a specific product category.  

The analysis in the previous section can be summarised in a decision table:  

Option 

Disadvantages  for  covering/limiting  under 
eco-design 

Advantages  for  covering/limiting  under 
eco-design 

extending 

Not 
beyond EuPs 

1)  short  run  negative  income  effect  on  low-
income households for some products 

1) Significant abatement potential in terms of 
CO2 

2)  Adjustment  cost  for  those  manufacturers 
which  products  initially  do  not  meet  minimum 
requirements. 

Limited 

3) 
environmental 
potential even if relevant cost benefits exist. 

improve-ment 

2)  The  Potential  for  other  environmental 
savings  is  somewhat  limited:  Improving  the 
environmental  impact  of  EuP  by  10%  will 
lead  to  improvements  of  1.5%  of  the  total 
environmental 
these 
benefits  are  however  reaped  by  reducing 
CO2 and acidification. 

impacts.  Most  of 

3)  long  run  positive  income  effect  on  low 
income households 

scope 
Extend 
beyond 
EuP 
except means of 
transport 

1)  Potential  short  run  negative  income  effect 
on low-income households for some products 

1)  Significant  additional  abatement  potential 
at low cost per tonne of CO2.  

2)  Adjustment  cost  for  those  manufacturers 
which  products  initially  do  not  meet  minimum 
requirements 

2)  complementary  to  construction  products 
directive  and  energy  performance  of 
buildings directive 

3)  Potential  for  other  environmental  savings 
is  important:  Improving  the  environmental 
impact  of  products  covered  by  option  2  by 
10% results in additional improvements of at 
total  environmental 
least  2.5%  of 
impacts compared to option 1.  

the 

to  option  1, 
the  same 
4)  Compared 
environmental 
impact  could  be  realised 
more  efficiently  if  the  products  with  the 
highest  savings  potential  can  be  covered, 
regardless of the product category. 

5)  long  run  positive  income  effect  on  low 
income households 

6)  Employment  effects  could  be  more 
positive than for option 1 or option 3 

1)  Potential  short  run  negative  income  effect 
on low-income households for some products 

1)  long  run  positive  income  effect  on  low 
income households 

2)  Adjustment  cost  for  those  manufacturers 
which  products  initially  do  not  meet  minimum 
requirements 

3) Type-approval legislation for motor vehicles 
already provides for stringent requirements on 
environ-mental 
an 
application  of  the  Ecodesign  Directive  would 
not provide additional benefits.  

performance 

and 

results 

2)  Potential  for  other  environmental  savings 
is  important:  Improving  the  environmental 
impact  of  products  covered  by  option  3  by 
10% 
improvements  of  an 
additional  4.3%  compared  to  option  1  and 
an additional 1.8% of the total environmental 
impacts compared to option 2. But, see point 
2 of disadvantages. 

in 

the 
beyond 
using 

Extend 
scope 
energy 
products 
including  means 
of transport 

4)  Current  and  foreseen  legislation  already 
covers the CO2 abatement potential for motor 
vehicles. The CO2 and cars proposal will save 
600  Mt  CO2  equivalents  between  2010  and 
2020. The recently adopted Euro-standards for 
light  and  heavy  vehicles  will  also  significantly 

EN 

36 

   EN 

 
reduce  other  environmental  impacts.  Light 
commercial  vehicles,  trucks  and  busses,  and 
motorbikes remain outside the framework.  

3)  Non-road  means  of  transport  are  produced 
in  very  low  volumes  making  the  application  of 
the eco-design framework difficult. 

At this stage, it can be recommended based on the available evidence to widen the scope of 
the Directive to energy-related products. 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.  

7. 

ADMINISTRATIVE COSTS 

7.1. 

For Member States and the Commission 

It appears that there are two areas in which the actions might generate administrative costs for 
Members States and the Commission. These are: 

(a)  Work  for  defining  implementing  measures  of  the  Ecodesign  Directive.  The  extension  of 
the product scope of the Ecodesign Directive will broaden the choice of  product  groups for 
which  implementing  measures  can  be  adopted.  Among  those  the  products  that  have  a 
significant environmental impact and potential for improvement will be identified and listed 
in  the  Working  Plan  referred  to  in  Article  16  of  the  Ecodesign  Directive.  The  eventual 
additional  budgetary  needs,  resulting  from  the  extension  of  the  product  scope  will  be 
determined  by  the  Working  Plan.  The  potential  allocation  of  additional  resources  must  be 
compatible  with  existing  financial  programming  and  will  be  subject  to  the  current  financial 
and budgetary rules and procedures. The expected integration of the decision structures of the 
Ecodesign Directive and the Energy Labelling Directive and the informative role of the eco-
label  suggested  in  the  SCP/SIP  Action  Plan  will  provide  synergies  which  guarantee  that 
resources are used such that implementing measures have the biggest environmental impacts 
at the lowest cost for the economy. 

(b) The time and costs involved cannot be quantified precisely but as a guideline it has been 
assumed that the implementation of the amended Ecodesign Directive would require six full 
time equivalent work from Commission staff and equivalent amounts of time from officials in 
at  least  10  Member  States  (it  is  unlikely  that  all  Member  States  would  be  involved  in  the 
detailed  discussions).  Given  the  average  annual  cost  of  a  Commission  official  (€ 
117.000/year) this would cost the Commission € 702 ,000. This does not include any add on 
for  overhead  costs.  The  assignment  of  staff  for  these  particular  tasks  from  existing  or 
additional  resources  remains  subject  to  resources  availability  and  will  be  decided  in  the 
framework of the annual resources allocation procedure.  

7.2. 

For Manufacturers  

Extending the scope of the Ecodesign Directive means that a greater number of products can 
potentially fall under ecodesign requirements. The total administrative burden impact depends 
on the number and nature of any self-regulatory standards or minimum requirements imposed 
by the Commission and the number of products affected by each standard. Therefore it is here 
only possible to provide a general indication of the possible impacts on administrative burden. 
For  any  new  minimum  requirement,  an  assessment  of  the  implications  on  administrative 
burdens will be carried out. It should also be recalled that Article 15 para 4f of the Ecodesign 

EN 

37 

   EN 

 
Directive  requires  that  an  implementing  measure  does  not  lead  to  excessive  administrative 
burden on manufacturers. 

The Ecodesign Directive foresees procedures that generate administrative costs for producers. 
They comprise the following elements: 

1.  A  CE  conformity  marking  needs  to  be  affixed  to  the  product  (or  the  packaging  and  the 
documentation)  and  a  declaration  of  conformity  needs  to  be  provided  by  the  manufacturer. 
Where information on how to install or use the product is provided to the end user, Member 
States can require this to be in their official language(s). (Art. 5) 

2.  A  conformity  assessment  needs  to  be  carried  out  by  the  manufacturer  (or  an  authorized 
representative)  that  establishes  that  a  product  fulfills  the  criteria  laid  down  in  a  minimum 
requirement.  How  this  assessment  needs  to  be  carried  out  is  specified  by  the  implementing 
measure.  The  documentation  relating  to  the  conformity  assessment  needs  to  be  kept  for  10 
years for inspection and need to be in an official language of the EU. (Art. 8) Details on what 
documentation needs to be kept are laid down in annex IV to the Ecodesign Directive. 

3.  Where  a  product  is  an  input  for  the  manufacturing  of  a  product  covered  by  a  minimum 
requirement,  the  producer  of  the  input  can  be  required  by  the  implementing  measure  to 
provide relevant information regarding the characteristics of his product to the manufacturer 
of  the  final  product  (Article  11).  The  need  to  use  Article  11  will  be  assessed  by  the 
implementing  measures.  In  principle  Article  11  will  only  be  used  if  the  inputs  provided  are 
essential to meet the minimum requirements for the end product.  

4.  The  implementing  measure  can  require  the  producer  to  provide  the  consumer  with 
information  regarding  the  ecological  profile  of  the  product  and  the  benefits  of  ecodesign. 
(Article  14).  Article  14  would  normally  not  be  used  since  the  Energy  Efficiency  Labeling 
Directive will normally be used to provide such information. See forthcoming SCP/SIP action 
plan. 

However,  those  producers  that  already  have  obtained  an  Eco-label  and/or  an  EMAS 
certification  benefit  from  the  presumption  of  conformity  stated  in  the  current  Ecodesign 
Directive  if  the  criteria  of  the  product  are  assessed  and  the  relevant  standard  also  complies 
with the criteria set out in the relevant minimum requirement. Thus, if an assessment of the 
product design has been carried out already, duplication of costs is avoided.  

Administrative costs on a producer level: 

Since  most  products  under  the  Ecodesign  Directive  fall  also  under  other  Single  Market 
Directives, e.g. Machinery Directive, affixing the CE marking to the product or the packaging 
and documentation should not entail any additional cost.  

Most manufacturers also already have a mandatory declaration of conformity and need to add 
some information specific to this Directive.  

The costs of information storage are also deemed minimal. What is costly is the generation of 
the documentation of the conformity assessment. The required information comprises: 

(a) 

(b) 

a general description of the product and of its intended use; 

the  results  of  relevant  environmental  assessment  studies  carried  out  by  the 
manufacturer, and/or references to environmental assessment literature or case 
studies,  which  are  used  by  the  manufacturer  in  evaluating,  documenting  and 
determining product design solutions; 

(c) 

the ecological profile, if required by the implementing measure; 

EN 

38 

   EN 

(d) 

(e) 

(f) 

(g) 

elements  of  the  product  design  specification  relating  to  environmental  design 
aspects of the product; 

a list of the appropriate standards referred to in Article 10, applied in full or in 
part, and a description of the solutions adopted to meet the requirements of the 
applicable implementing measure where the standards referred to in Article 10 
have  not  been  applied  or  where  these  standards  do  not  cover  entirely  the 
requirements of the applicable implementing measure; 

a copy of the information concerning the environmental design aspects of the 
product  provided  in  accordance  with  the  requirements  specified  in  Annex  I, 
Part 2; 

the  results  of  measurements  on  the  ecodesign  requirements  carried  out, 
including  details  of  the  conformity  of  these  measurements  as  compared  with 
the ecodesign requirements set out in the applicable implementing measure. 

The  most  costly  elements  of  this  assessment  are  likely  to  be  related  to  the  environmental 
assessment  studies  and  the  results  of  measurements  on  the  ecodesign  requirements.  No 
empirical  data  regarding  the  costs  of  an  assessment  is  available;  however  the  cost  for 
compliance with Eco-label can serve as a benchmark. According to the impact assessment for 
the Eco-label Regulation, they vary between 1 000 and 10 000 Euros per product. The costs 
are believed to be closer to the lower end, or even lower, of the above range for the Ecodesign 
Directive:  Eco-label  looks  at  all  environmental  parameters  and  can  regulate  as  much  as  25 
different environmental parameters. As explained above, the Ecodesign Directive would only 
impose  minimum  requirements  for  the  most  significant  environmental  parameters  of  a 
product. This would normally imply covering on average 3 and up to 5 parameters. Moreover, 
the  Eco-label  Regulation  requires  third  party  verification  whereas  under  the  Ecodesign 
Directive self assessment is the default option. Self assessment would be typically cheaper.  

Total administrative costs: 

The  total  administrative  costs  of  a  minimum  requirement  consist  of  the  individual  producer 
cost multiplied by the number of products falling under the minimum requirements. This in 
turn depends largely on the product definition and on the market structure. A narrow market 
with a limited number of products and few criteria that need to be met will lead to a relatively 
low total administrative burden. Conversely, a broad product definition, complex criteria and 
a  high  number  of  different  products  in  the  market  will  lead  to  a  significantly  higher 
administrative burden. 

Extending the scope of products that can be covered by the Ecodesign Directive in itself does 
not  necessarily  entail  that  the  administrative  burden  will  be  increased.  From  an  efficiency 
perspective,  reaching  certain  environmental  benefits  will  be  cheaper  if  the  products  causing 
the most significant impact can be addressed rather than to cover a larger number of products 
that  each  of  them  have  a  minor  impact.  Overall,  the  impact  on  administrative  burden  is 
therefore dependent on a number of factors and it cannot be said that extending the scope of 
the Directive will lead to an increase or a decrease in administrative burden. 

8. 

COST-EFFECTIVENESS 

As already explained before, the extension of scope of the Ecodesign Directive has very little 
impact  beyond  making  it  possible  to  launch  new  implementing  measures.  The  cost-
effectiveness of implementing measures will be addressed in detail per specific product group. 
This will be done by preparatory technical studies, the stakeholder consultation forum (art 18) 
and the impact assessments for the implementing measures.  

EN 

39 

   EN 

Based on the analysis provided in this impact assessment option 2 is the most cost effective 
option.  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 
the  use  of 
concrete/cement,  steel,  aluminium,  plastics  and  other  important  materials.  These  product 
groups and materials are presented for illustrative purpose only 
There seems to be little potential for additional environmental improvement in the transport 
sector beyond current and planned EU legislation. Therefore, option 3 is not withheld. 

the  environmental  and  economic  sustainability  of 

investigate  on 

9. 

MONITORING AND EVALUATION 

The  Action  Plan  foresees  regular  reporting  to  the  European  Parliament.  Monitoring  on  the 
Ecodesign  Directive  could  provide  information  on  the  various  stages  of  the  implementation 
process of the Ecodesign Directive such as: 

- number of preparatory studies launched  

- number of preparatory studies finished 

- number of implementing measures adopted 

Moreover,  collaboration  with  the  working  group  of  Eurostat  on  Sustainable  Development 
indicators is envisaged to assess the possibility to include statistics on the resource efficiency 
of  products  for  which  implementing  measures  are  developed.  Eurostat  could  for  example 
report the market share of resource efficient products per labelling category.  

The  Commission  plans  to  collect  further  information  and  evidence  as  regards  the  potential 
benefits of including non-energy related products in the scope of this Directive. 

Based on this further assessment; and other relevant information, the effects of the presently 
recommended widening of the scope and options for a further widening to non-energy related 
products  should  be  reviewed.  To  this  end;  it  is  recommended  to  foresee  a  review  of  the 
Directive in 2012.  

EN 

40 

   EN 

ANNEX I  

Analysis of the Consultation on the Sustainable Consumption and Production and 
Sustainable Industrial Policy Action Plans. 

The  European  Commission  undertook  two  public  consultations  on  the  Sustainable 
Consumption and Production and Sustainable Industrial Policy Action Plans.  

The first one was targeted to companies. The European Business Test Panel scheme was built 
up to consult businesses in the different Member States on specific topics of their interest. The 
companies that have signed up to participate at the Panel are duly informed of the launching 
of the consultations, which are carried out in all the official languages of the European Union.  

In the case of the consultation on SCP/SIP, 354 responded to the survey, of which 66% are 
SMEs.  Companies  of  all  Member  States  of  the  European  Union,  except  Bulgaria, 
Luxembourg and Cyprus, responded to the survey. 

In  the  following  table,  it  can  be  seen  that  a  majority  of  the  respondents  supported  the 
extension of minimum standards to a broad number of products. 

Table 1 Business Response to extending environmental minimum standard to a broad number 
of products 

Minimum  standards  to  improve  energy  and  resource  efficiency  applied  to  a  broad 
number of products 

Yes 

No 

Don't know 

214 

 (69.3%) 

65 

30 

 (21%) 

 (9.7%) 

Source: SCP/SIP consultation in EBTP 

The  second  public  consultation  on  the  Sustainable  Consumption  and  Production  and 
Sustainable Industrial Policy Action Plans took place between July 27th and September 23rd, 
2007. This consultation was a joint undertaking by DG Environment and DG Enterprise and 
Industries. 

The  purpose  of  the  consultation  was  to  gather  public  and  stakeholder’s  opinions  on  the 
different  areas  of  action,  on  the  barriers  to  improve  the  situation  in  these  areas  and  on  the 
options  for  action.  A  Background  document  explaining  the  issues  at  stake  and  the  options 
being  under  consideration  was  also  available  for  the  respondents.  Participants  were  also 
invited to provide position papers on the different topic at stake.  

The survey was accessed by 658 participants. 479 of them provided their affiliation: 277 were 
individuals  and  202  stakeholders.  The  industrial  sector  and  the  environmental  constituency 
presented both around 30% of total answers. In both groups stakeholders constituted around 
half  of  the  participants.  First,  participants  were  asked  what  the  best  options  are  to  promote 
in 
for 
better 

stakeholders 

products. 

results 

shown 

The 

are 

EN 

41 

   EN 

Figure  1.  Broadening  the  scope  of  products  to  which  environmental  minimum  requirements 
apply  was  seen  as  the  first  best  option.  The  combination  of  dynamically  setting  minimum 
requirements for products and setting advanced performance benchmarks for best performing 
products also received strong report.  

EN 

42 

   EN 

Figure 1 opinion of the stakeholders on the options to promote better products 

Opinion on the options - Stakeholders

90
80
70
60
50
40
30
20
10
0

Broader scope
of products w ith
minimum
requirements

Dynamic Minimun
Requirements
and benchmarks
for best
performing
products

Enhanced use of
Energy
Efficiency label

Labelling
indicating
various
performance

Public
procurement
focusing on
energy
efficiency

Taxation
reflecting energy
and resource
efficiency

Most important

Second most important

Third most important

Figure 2 shows the general public’s opinion on the best options to promote better products. A 
taxation reflecting energy and resource efficiency is the most advocated one. The combination 
of dynamically setting minimum requirements for products and setting advanced performance 
benchmarks for best performing products also received strong support..  

Figure 2 opinion of the general public on the options to promote better products 

Opinion on the options - General Public

180
160
140
120
100
80
60
40
20
0

Broader scope
of products w ith
minimum
requirements

Dynamic Minimun
Requirements
and benchmarks
for best
performing
products

Enhanced use of
Energy
Efficiency label

Labelling
indicating
various
performance

Public
procurement
focusing on
energy
efficiency

Taxation
reflecting energy
and resource
efficiency

Most important

Second most important

Third most important

EN 

43 

   EN 

 
 
Finally  a  strong  majority,  in  particular  among  stakeholders,  agrees  that  environmental 
problems need to be tackled in a cost-efficient way while minimizing the social impact (Table 
2).  

Table 2: Focus of the actions 

Focus 

Actions need to be cost-efficient even if 
the  positive  environmental  impacts  are 
not maximised 

Actions  need 
viability over environmental impacts 

to  prioritize 

social 

Actions  need  to  tackle  environmental 
problems  in  a  cost-efficient  way  while 
minimizing the social impacts 

Actions  should  mainly  concentrate  on 
solving 
problems, 
regardless  of 
their  costs  or  social 
impacts 

environmental 

General Public / 
Consumer 

Stakeholder/Organisation

Grand 
Total 

5.3% 

5.3% 

8.8% 

6.7% 

2.7% 

4.3% 

62.9% 

80.2% 

70.0% 

26.5% 

8.2% 

19.1% 

EN 

44 

   EN 

ANNEX II  

Study by Mckinsey for the BDI 

This  annex  discusses  the  results  of  a  study  by  McKinsey  undertaken  for  the  initiative 
“Business  for  climate  protection”  of  the  BDI  Bundesverband  der  Deutschen  Industrie.  The 
study  builds  on  a  methodology  for  a  global  cost  curve  developed  by  McKinsey.  McKinsey 
cooperated  with  Professors  R  Socolow;  S  Pacala,  R  Williams  (Princeton  University)  and  D 
Anderson  (Imperial  College  London).  The  methodology  for  Germany  was  further  discussed 
with Professors Hellwig (MPI Bonn), Strobele (University of Munster) and Von Weizsacker 
(University of Cologne). 

In this annex the assumptions made by McKinsey; the assumptions made for extrapolation of 
results  from  Germany  to  the  EU  and  the  results  of  the  extrapolation  are  discussed.  The 
information in this annex has not been used in the revised version of the impact assessment 
report but it is consistent with the arguments brought forward and provides additional insights 
concerning  the  economic  and  environmental  benefits  that  could  result  from  extending  the 
scope of the Ecodesign Directive. 

Assumptions made by McKinsey 

To calculate the abatement cost per tonne of CO2 for a product it seems that the life cycle cost 
for the users of the product and the energy consumption over the life cycle are compared for 
energy  efficient  and  current  products.  The  time  period  over  which  the  abatement  cost  is 
calculated is therefore the life cycle of the product which is different from product to product. 
For example for vehicles a 4.5 years first ownership for private owned cars was assumed. 

The following discount rates to calculate the NPV of the life cycle cost of products have been 
used: 

Table 1: discount rates used in the McKinsey study 

Decision maker 

Individuals 

Industry 

Commercial 

Energy sector 

Discount factor 

4.5% 

9.5% 

9% 

7% 

The  choice  of  a  discount  rate  influences  how  future  benefits  and  costs  are  translated  into 
current benefits and costs. For energy efficiency, cost are immediate whereas benefits accrue 
over time. The higher the discount factor the lower the future benefits are in net present value. 
The lower the discount factor the higher the future benefits are in net present value.  

Discount factors in the range of 4.5-9.5% are reasonable. Therefore, the discount factors have 
not been used to overstate the benefits of the energy efficient investments. 

However,  using  different  discount  factors  for  decision  makers  influences  the  most  cost 
effective  measures.  The  discount  factors  chosen  by  McKinsey  make  energy  efficient 
investments by individuals more cost effective than those by industry.  

The annual oil price is assumed to be $57 in 2010 and $52 in 2020. The reference for the oil 
price is the Annual Energy Outlook 2007. The exchange rate assumed was 1 euro would cost 
1.2 dollar. A higher oil price would inflate for example the benefits of alternative energies and 
more fuel efficient cars.  

EN 

45 

   EN 

Finally,  McKinsey  assumes  that  the  demand  of  consumers  does  not  change  as  a  result  of 
climate  change  measures  and  also  that  the  industrial  structure  would  not  change.  These 
assumptions  are  unrealistic  but  adding  more  realism  would  require  significantly  more 
complex models. 

Assumptions made for extrapolation of results from Germany 

The  assumptions  for  the  extrapolation  of  results  from  Germany  to  the  EU-27  are  presented 
and  evaluated  in  this  section.  In  general  the  extrapolation  of  the  results  gives  illustrative 
indications of the likely effect at the EU level.  

For  the  own  calculations  based  on  McKinsey  (2007)  the  results  for  Germany  have  been 
multiplied  by  the  inverse  of  German’s  share  in  EU-GDP  to  obtain  the  EU  results.  In  the 
aggregate this assumption seems to be justified for the purpose of providing an indication of 
potential impacts: Germany is slightly more CO2 intensive per toe than the EU-27 as a whole. 
Germany’s production of electricity emits more CO2 since it is relatively reliant on coal and 
less reliant on nuclear and renewables.  

Table 2: Source of electricity generation as % of total 

2004 

 Coal  

 Oil  

 Gas  

EU27  Germany

29.9% 

48.6% 

4.4% 

1.6% 

19.7% 

11.4% 

 Nuclear  

30.7% 

27.1% 

 Renewables (*) 

13.9% 

9.5% 

 Other (***) 

1.4% 

1.8% 

Source: Energy & Transport in figures Statistical pocketbook 2007  

Table  3  provides  some  comparative  figures  for  Germany  and  EU27.  In  terms  of  emissions 
intensity,  the  distortion  is  factor  2.4  tCO2/toe  /  2.2  tCO2/toe  =1.09.  So,  extrapolating  the 
results to EU 27 would be overestimated by 9%. Yet Germany is less energy intense –due to 
structure of industry; existing levels of insulation; efficiency of car park- than EU27. Factor 
164  toe/MEUR  /  185  toe/MEUR=0.88.  So,  in  terms  of  energy  intensity,  the  results  of  the 
extrapolation would be underestimated by 12%. Combining the two, Germany emits slightly 
less  CO2  per  Euro 
/  407 
tCO2/MEUR=0.967076).  Therefore;  using  GDP  to  extrapolate  abatement  costs  potential 
appears to be a reasonable approximation.  

(per  Million  Euro  of  GDP 

tCO2/MEUR 

(393.6 

Table 3: Key indicators for Germany and EU-27 used to estimate the potential errors of the 
extrapolation of Germany’s results in McKinsey (2007) to EU-27 

EN 

46 

   EN 

Source: factsheet DG TREN 2007 

The study of McKinsey uses a conversion factor of 0.72 Tonne CO2 equivalent per Mwh in 
2004  which  declines  to  0.64  Tonne  CO2  equivalent  per  MwH  in  2020  as  a  result  of  the 
changes in the energy production sector47. 

Also,  distortions  at  sectoral  level  could  invalidate  extrapolation  of  Germany’s  results  to  the 
EU-27. 

Buildings: Ecofys estimates that the abatement potential of state of the art insulation is 67% 
reduction  in  heat  loss  in  Germany  compared  to  an  average  reduction  of  56%  in  EU-1248. 
Therefore,  extrapolation  of  Germany’s  result  could  be  a  67/56  (19%)  overstatement  for  the 
EU-27.  However,  Germany  is  fairly  advanced  in  replacing  single  glass  for  double  glassed 
windows. In Germany only 27% of the window surface is single glassed compared to 45.4% 
being single glassed in the rest of Europe.49 Based on the windows surface being single glass 
the  result  could  be  an  understatement  of  the  savings  potential  for  the  EU-27.  Although, 
climatologic conditions do play a role, the savings potential is there. In the Netherlands, single 
glassed windows are 40% of the total window surface, in France 44% and in Belgium 46%. 

Transport:  Germany’s  new  cars  emit  more  CO2  than  the  average  in  EU-27.  The  factor  is 
approximately  172/158=1.09.50  So,  extrapolating  Germany’s  result  on  cars  seems  to  be  a 
slight  over-estimation.  On  the  other  hand;  the  car  stock  in  Germany  is  probably  somewhat 
more often replaced than in EU-27 which could counterbalance the over-estimation. 

Energy production: as shown above, Germany’s production  of electricity  emits more CO2 
since it is relatively reliant on coal and less reliant on nuclear and renewables.  

Energy Using appliances: Since all other sectors are more energy intensive than the EU-27 
while Germany’s total economy is less energy intensive than the EU-27, it must be that other 
household use of energy and industry’s use of energy in Germany is less energy intensive than 
the  EU-27.  This  implies  that  the  savings  for  energy  using  appliances  (corresponding  to 
household  use  of  energy  and  industry)  are  starting  from  a  relatively  high  level  of  energy 
efficiency. Since the EU-27 starts from a lower level of energy efficiency the extrapolations 
for energy using products could well be an underestimation of the EU-27 savings potential. 

47 
48 
49 
50 

See footnote 58 of McKinsey (2007). 
Austria, Belgium, Denmark, Finland, France, Germany, Ireland, UK, Spain, Sweden, Netherlands, Italy. 
Based on GEPVP the association of glass manufacturers. 
Impact Assessment CO2 in cars. 

EN 

47 

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Based on economic theory, one could claim that Germany’s energy efficiency should already 
be higher than  the EU-27.  Indeed,  electricity prices for industry are on average 15% higher 
and for households more than 20% higher than in EU-27. These higher prices should induce 
more energy efficient purchases.  

Table 4: Average electricity prices  

Industry 

2005 

2006 

2007 

EU-27 

0.0672  0.0752  0.082 

Germany 

0.078 

0.0871  0.0946 

Difference 

16% 

16% 

15% 

households  2005 

2006 

2007 

EU-27 

0.1013  0.1068  0.1173 

Germany 

0.1334  0.1374  0.1433 

Difference 

31.7%  28.7%  22.2% 

In sum, to a first approximation the extrapolation from Germany to the EU seems not totally 
unreasonable and can give a ballpark estimate of the likely impacts at the EU level.  

Discussion of the results of the extrapolation 

The  important  environmental  impacts  of  energy  using  products  include  direct  and  indirect 
greenhouse  gas  emissions.  Significant  evidence  exists  that  the  energy  use  and  the  related 
greenhouse gas emissions of energy using products can be significantly reduced. Only those 
product  design  policies  that  are  abating  CO2  emissions  and  that  would  pay  back  over  the 
amortisation period of the users are included in the analysis. So, all abatement potential that 
costs more than €0 per tonne CO2 are not ta ken up. The table below shows the yearly CO2 
emission reduction potential by ecodesign measures in 2020 for energy using products. The 
second column presents the CO2 reductions which can be achieved with existing technology 
if the market failures identified above are resolved51. The yearly CO2 reduction potential of 
energy using products is considerable with 287 million tonnes of CO252. This is equivalent to 
a reduction of 7.2% of current emissions53. The third column presents the costs per tonne CO2 
of undertaking these measures keeping into account initial investment and savings during the 
use phase. On average €124 will be  saved per tonne of CO2. The fourth column presents the 
total net savings. Total net savings equal the abatement cost per tonne CO2 multiplied by the 
CO2 reduction potential. In total, € 35.7 billion can be saved.  

51 
52 

53 

See p 5 of McKinsey (2007) 
The original communication on the EuP directive estimated the potential benefits at 200 million tonne of CO2 per 
year by the year 2020 
Source for current emissions is CAIT 2007. 

EN 

48 

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Table 5: Cost-benefit of yearly CO2 emissions reduction potential by eco-design measures for 
energy using products in 202054 

Sector 

Household sector 

Industrial sector 

TOTAL 

CO2 reductions which 
have negative abatement 
costs (Mt CO2 equivalent) 

157.3 

129.9 

287 

Abatement 

Net savings (billion €) 

cost per t CO2 
equivalent 

-130 

-117 

-124 

20,5 

15,2 

35,7 

Source: own calculations based on McKinsey (2007) 

Table  5  shows  that  investing  in  more  energy  efficient  products  will  not  only  lead  to  lower 
emissions but lead to considerable savings for households and industry. These estimates are 
conservative.  Indeed,  the  studies  for  the  implementing  measures  of  the  Ecodesign  Directive 
have  shown  that  for  boilers  and  water  heaters  a  mix  of  ecodesign,  installation  and  labelling 
requirements would result in yearly net savings of €45 billion as of 2020 55 On the basis of the 
EuP preparatory studies it is estimated that a comprehensive set of ecodesign requirements for 
the  remaining  major  energy-using  products  would  bring  another  €  30  billion  of  saving  per 
annum as of 2020.56 

Table  6  shows  the  CO2  abatement  potential  for  innovative  detergents  and  construction 
products.  Only  those  investments  that  pay  off  are  analysed.  For  example,  2L-renovation, 
which is more  energy efficient  that  the other options, comes at cost  of over  €100  per tonne 
CO2 and is not analysed. 

54 
55 

56 

For a discussion of the assumptions made see Annex II. 
See p 32. of R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of 
Boilers (2007), Task 7, p. 39 and R. Kemna, M. van Elburg, W. Li, R. van Holseijn. Preparatory study 
on the Ecodesign of Water Heaters (2007), Task 7. And see p 39 of R. Kemna, M. van Elburg, W. Li, 
R. van Holseijn. Preparatory study on the Ecodesign of Boilers (2007), Task 7, p. 39 and R. Kemna, M. 
van Elburg, W. Li, R. van Holseijn. Preparatory study on the Ecodesign of Boilers (2007), Task 7 
http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm#consultation_forum 

EN 

49 

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Table 6: Cost-benefit of yearly CO2 emission reduction potential by ecodesign measures for 
option 2 in 2020 

Abatement 

cost per t CO2 
equivalent 

Net savings 
(million €) 

Cumulative 
abatement 
potential 

(Mt CO2 
equivalent) 

Innovative detergents 

7L-renovation57 (multi-family house) 

7L-renovation (3-6-family house) 

7L-renovation (1-2 family house) 

Office building insulation 

School building insulation 

TOTAL 

4.7 

19 

18 

60 

12 

2 

115.7 

-336 

-135 

-60 

-49 

-26 

-15 

-65 

1600 

2559 

1052 

2949 

320 

36 

8516 

Source: own calculations based on Mckinsey (2007) 

The  huge  and  very  cost  efficient  potential  of  innovative  (ambient  temperature  washing) 
detergents  is  due  to  the  caused  cost  savings,  as  another  recent  and  independently  reviewed 
study  from  Procter  and  Gamble  confirms  (Procter&Gamble  2006).  The  total  CO2  emission 
savings  potential  sum  up  to  about  5  M  t  /  year  in  the  EU,  assuming  a  replacement  of  2001 
market leading detergents by cold-wash detergents, of which the first products now enter the 
market. Of the reduction potential in the construction sector, 78 Mt of CO2 would be due to 
the use of construction products. The other reductions in the construction sector would be due 
to the combination of the product specific approach of the Ecodesign directive and the whole 
building approach of the Energy Performance of Buildings Directive. 

The table below shows the yearly CO2 emission reduction potential for means of transport in 
2020.  Only  those  policies  that  are  abating  CO2  emissions  and  represent  cost  savings  are 
shown58.  For  example,  hybrid  cars  have  an  additional  cost  of  over  €1000  per  tonne  CO2 
abated.  Moreover,  only  those  policies  that  are  related  to  ecodesign  improvements  are 
withheld. Changes in consumption behaviour and other measures unrelated to ecodesign are 
not taken up. The cost effective saving potential of product design for means of transport is 
largely due to cars (37.4 Mt CO2 e), other vehicles (8.5 Mt CO2 e) and trains (8.5 Mt CO2 e). 
The potential of ecodesign for airplanes (2.3 Mt CO2) seems to be less important.  

57 

58 

7L renovation is a renovation which reduces the heating needs of a house to 7 liters of heating oil per 
square meter every year 
Own calculations based on McKinsey (2007). Note that ships are not discussed by this study. 

EN 

50 

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Table 7: Cost-benefit of yearly CO2 emission reduction potential by ecodesign measures for 
means of transport in 2020 

Sector 

Cars 

Light,  medium  and  heavy 
vehicles (trucks and buses) 

Train 

Air 

TOTAL 

CO2 reductions which 
have negative 
abatement costs (Mt 
CO2 equivalent) 

Abatement cost per 
t CO2 equivalent 
(averages) 

Net savings (€ 
million) 

37.4 

8.5 

8.5 

2.3 

56.8 

-139 

-167 

0 

0 

5213 

1422 

0 

0 

-117 

6635 

Source: own calculations based on McKinsey (2007) 

As shown in Table 8 below, products of Option 1 have a savings potential of 287 Mt CO2 and 
could  save  €35.5  billion  for  consumers  and  companies.   Products  of  option  2  have  an 
additional  savings  potential  of  122  Mt  CO2 and  could  save  €8.5  billion  for  households  and 
consumers. Products of option 3 have a savings potential of 57 Mt CO2, and could save €6.6 
billion for households and consumers. However, the saving potential for means of transport is 
already addressed by forthcoming legislation. 

Table 8: Cost-benefit of yearly CO2 emission reduction potential by ecodesign measures for 
selected products of the three options in 2020 

Sector 

CO2 reductions 
which have 
negative abatement 
costs (Mt CO2 
equivalent) 

Abatement cost 
per t CO2 
equivalent 
(averages) 

Net savings (€ 
billion) 

Option 1 Energy using products 

Option  2  All  products  except 
means of transport 

Option 3 Means of transport 

287 

122 

56.8 

Source: own calculations based on McKinsey 

-124 

-65 

-117 

35,7 

8,5 

6,6 

EN 

51 

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ANNEX III  

Illustration of learning curves and the fall in prices and rise in energy and resource 
efficiency for energy using products59 

This  annex  illustrates  learning  curves  and  the  fall  in  prices  and  rise  in  energy  and  resource 
efficiency for energy using products. 

For  washing  machines,  laundry  dryers  and  refrigerators  the  stylised  facts  seem  to  be: 
declining prices and declining energy (and water) consumption.  

Figure 1 Price and resource developments of washing machines 

500

1965

200

150

100

50

()
x

=

±

4699

(
y
7119
R2 = 0.51
LR = (31.7 ± 7.2)%

−

.
550

±

.
100

)

2007

2

1.5

1

0.5

0.2

n
o
i
t
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0.15

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1965

1965

(

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451

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259
R2 = 0.54, LR = (27.3 ± 6.1)%

−

.
460

±

.
090

()
x

)

=

±

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364

.
y
910
R2= 0.86, LR = (24.7 ± 2.2)%

−

.
410
±

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030

)

()
x

Electricity consumption
Water consumption

2007

2007

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103
4x102
Cumulative global washing machines production in million

8x102

6x102

2x103

4x102

6x102

8x102

103

2x103

Cumulative global production of washing machines in million

Figure 2 Price and energy efficiency of laundry dryers 

200

150

100

y
t
i
c
a
p
a
c

y
r
d
n
u
a

l

g
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50

s
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1969

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2003

−

.
460

±

.
070

)

()
x

=

±

384

(
y
1164
R2 = 0.80
LR = (27.2 ± 4.9)%

f

o
n
o

i
t

p
m
u
s
n
o
c

y
g
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n
E

1.5

1

0.9

0.8

0.7

0.6

0.5

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t
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i

1969

−

.
320

=

().
x

.(
9024
±

y
R2 = 0.84
LR = (19.9 ± 3.1)%

±

.
040

)

2003

60

80

100

200

Cumulative global production of laundry dryers in million

60

80

100

200

Cumulative global production of laundry dryers in million

Figure 3 Price and energy efficiency of refrigerators 

e
m
u
o
v

l

l
/

6
0
0
2
R
U
E
n

i

s
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1964

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0.4

0.3

0.2

−

.
140

±

.
030

)

2007

1964

=

().
x

.(
1126
±

y
R2 = 0.39
LR = (9.1 ± 2.0)%

−

.
320

=

().
x

.(
y
9054
±
R2 = 0.68
LR = (19.9 ± 2.4)%

±

.
030

)

2007

40

60 80

102

200

400

600 800

103

2000

40

60

80

102

200

400

600 800

103

2000

Cumulative global production of refrigerators in million

Cumulative global production of refrigerators in million

For freezers both prices and energy efficiency have remained relatively constant over time for 
the studied sample. Given the limited number of observations, one should be cautious about 
inferring general statements on price and energy efficiency of freezers. 

59 

This section is based on Weiss, Junginger and Patel (2008) unpublished. 

EN 

52 

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Figure 4 Price and energy efficiency of freezers 

±

.
060

)

.().
040
x

.(
y
8042
=
±
R2 = 0.04
LR = (-3.1 ± 4.5)%

6

5

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0.5

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0.2

1970

0.1

20

2003

−

.
040

±

.
080

)

().
x

.(
y
4090
=
±
R2 = 0.02
LR = (2.8 ± 5.9)%

40

60

80

100

200

400

600

800

Cumulative global production of freezers in million

Cumulative global production of freezers in million

EN 

53 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX IV  

Detailed discussion of applicability of eco-design to option 2 products 

This  annex  contains  a  more  detailed  discussion  on  the  applicability  of  the  eco-design 
Directive to option 2 products.  

Construction products 

a) The extension of the Ecodesign Directive to construction products can be complementary 
to current policies relating to the energy performance of buildings:  

The  construction  products  directive  (Directive  89/106/EEC)  sets  measurement  standards  for 
the  technical  performance  of  construction  products.  It  assures  that  requirements  set  by 
Member  States  on  buildings  (or building elements), notably as regards the environment  and 
the energy economy and heat retention, are consistent with these measurement standards.  

The  Energy  Performance  of  Buildings  Directive  (Directive  2002/91/EC)  only  covers  new 
buildings  and  major  renovations  –  representing  25%  of  the  building  value-  for  existing 
buildings above 1000 square meters. However, existing buildings below 1000 square meters 
account  for  around  70%  of  the  overall  building  stock  and  more  than  70%  of  the  energy 
consumption  related  to  buildings.  Besides,  “minor”  renovations,  such  as  replacing  single 
glassed  windows  by  single  glassed  with  better  insulation  capacity  and/or  double  glassed 
windows,  also  have  a  significant  environmental  potential.  For  this  type  of  small,  product 
specific improvements, principal-agent problems are precisely the biggest. In addition, there 
is a need to deal with significant environmental impacts of construction other than the energy 
performance. For civil work and the building structure, the energy related externalities – CO2 
emissions  -  are  only  25-35%  of  all  environmental  externalities60.  Setting  minimum 
requirements  for  the  most  significant  environmental  impacts  of  construction  products  could 
contribute considerably to enhance the overall environmental performance of buildings. 

Eco-design  requirements  for  energy  saving  products  could  be  complementary  to  the  EPBD. 
The  eco-design  requirements  would,  for  instance,  set  minimum  requirements  for  important 
energy saving products. By doing so: 

•  Internal  market  problems  in  relation  to  Member  State  specific  performance 

requirements on products are solved. 

•  The potential of small product specific improvements can be reaped. 

b) Based on Labouze et al (2003), the total environmental impact of construction is between 
15% and 16% of all environmental impacts studied.  

60 

Labouze et al (2003). 

EN 

54 

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Table 1: 

environmental impact of construction  

Product 

Space heating61 

Building structure 

Civil construction work 

per capita (€) 

EU-27 ( bn €)  % of total impact 

min 

16.5 

11 

6 

max 

min 

max 

min 

max 

74 

51 

20 

8.1 

5.4 

3.0 

36.6 

24.8 

9.7 

8% 

5% 

3% 

8% 

5% 

2% 

Total construction 

33.5 

145 

16.5 

71.1 

16% 

15% 

In the table below the yearly CO2 emission reduction potential in 2020 that are also beneficial 
for the economy are demonstrated for the construction sector62: 

Table 2: 

Cost-benefit of yearly CO2 emission reduction potential in 2020 

7L-renovation63 (multi-family house) 

7L-renovation (3-6-family house) 

7L-renovation (1-2 family house) 

Office building insulation 

School building insulation 

TOTAL 

Cumulative 
abatement 
potential 

(Mt CO2 
equivalent) 

Abatement 

cost per t 
CO2 
equivalent 

Net 
savings 
(million 
€) 

19 

18 

60 

12 

2 

111 

-135 

-60 

-49 

-26 

-15 

-62 

2559 

1052 

2949 

320 

36 

6916 

For the renovation of family houses, 1-2 and 3-6 households whose surface is lower than 1000 
m2,  the  EPBD  is  currently  not  applicable  and  some  of  the  abatement  potential  mentioned 
above  could  be  realized  through  renovations  with  better  performing  products  that  could 
eventually be considered in the Ecodesign Directive. For the insulation in office and school 

61 

62 

63 

Note  that  space  heating  is  both  under  energy  using  products  and  construction  products.  On  the  one 
hand, one can improve the efficiency of boilers. The current minimum requirements considered would 
improve boilers with 17% (source: preparatory study for implementing measures). On the other hand, 
one can improve the insulation of buildings such that heating requirements go down. Heating insulation 
can  reduce  the  heating  requirements  of  buildings  substantially.  EURIMA,  a  sector  association  claims 
that insulation can reduce energy requirements by more than 40% Ecofys I (2002). 
Own  calculations  based  on  McKinsey  (2007).  McKinsey  made  the  assumption  that  3%  of  buildings  would  be 
renovated annually. 
7L renovation is a renovation which reduces the heating needs of a house to 7 liters of heating oil per 
square meter every year. 

EN 

55 

   EN 

 
 
                                                 
buildings and the 7L-renovation in multi-family houses, it is likely that the 1000 square meter 
threshold is attained.  

The  approach  followed  does  make  the  trade-off  between  affordability  for  households  and 
environmental  savings.  More  stringent  requirements  on  insulation  material,  windows  and 
other construction products could result in even bigger CO2 savings. Yet, the costs of such an 
approach would not justify such requirements. Table 5 presents cost-benefit of the additional 
yearly  emission  reduction  potential  of  shifting  from  7L-renovation  to  2L-renovation64. 
Compared to 7L-renovation an additional 15 M Tonnes of CO2, 13.5% extra, can be saved. 
Yet, this will cost €12 billion extra. Abatemen t costs per extra tonne would be on average 828 
€/T CO2 compared to an ETS price per ton  CO2 of 20-30 Euro. Based on this evidence 2L-
renovation standards seem not cost effective for the time being.  

Table 3: Cost-benefit of additional yearly CO2 emission reduction potential in 2020 of going 
from 7L-renovation to 2L-renovation 

CO2 reductions 
(Mt CO2 
equivalent) 

cost per tonne 
CO2 
equivalent 

Costs 
(million €) 

2L-renovation (multi-family house 

2L-renovation (3-6 family house) 

2L-renovation (1-2 family house) 

TOTAL 

4 

3 

8 

15 

660 

714 

947 

828 

2502 

2030 

7629 

12162 

Product  specific  improvements  are  important.  For  example,  replacing  the  current  stock  of 
single glazed windows by low-energy glazing at a rate of 3% per annum and the current stock 
of double glazed windows  by  low-energy glazing at a rate of  1% per  annum saves  22.9 Mt 
CO2  equivalents  in  2019.65  This  will  result  in  discounted  energy  savings  of  €5.6  billion  in 
2019 using 2007 electricity prices.  

In Switzerland, general building codes and specific building codes have been complementary 
over  the  last  thirty  year.  Moreover,  the  policy  succeeded  in  increasing  the  uptake  of  more 
energy  efficient  construction  products  at  decreasing  costs  for  these  products.  For  insulation 
and  glazing,  Jakob  (2007)  and  Jakob  and  Madlener  (2004)  show  a  continuing  trend  of  cost 
reduction  and  a  successful  market  penetration  of  more  advanced  windows  (with  lower  heat 
transmissivity, see figure 5. In particular the shift towards more stringent energy standards in 
1988 can be clearly distinguished in figure 5.  

64 

65 

2L renovation is a renovation which reduces the heating needs of a house to 2 liters of heating oil per 
square meter every year. 
Own calculations based on GEPVP. 

EN 

56 

   EN 

  
                                                 
Figure 1: 

Penetration rate and price developments of energy efficient glass66 

601

202

]

%

[

e
r
a
h
S

t
e
k
r
a
M

100

90

80

70

60

50

40

30

20

10

0

 Double glazing insulation  

 Double glazing insulation with
heat protection coating  

 Triple glazing insulation with
heat protection coating  

Cost of glass [CHF/m2]

Total cost of glass
manufacturing [CHF/m2]

700

600

500

400

300

200

100

0

]
2
m

/
)
6
0
0
2
(
F
H
C

[

t
s
o
C

450

100

 1970   1980   1985   1990   1993   1996   1999  2000  2001  

Source: DG ENTR, based on data from: Jakob and Madlener 2004, p.16 and 17 

Also  for  insulation  material  there  is  an  important  potential  for  improvement.  Insulating  the 
total  stock  of  houses  built  before  1974,  which  have  not  been  insulated  yet,  to  the  currently 
recommended  standards  is  said  to  reduce  energy  consumption  by  42%67.  Moreover,  this 
would result in savings of 353 Mt CO2 per year which is above 5% of total CO2 emissions in 
the EU. It is estimated that the refurbishment takes place at a rate of 4% so this potential can 
be reaped over the next 25 years.  

The  below  table  discusses  the  different  materials  of  insulation  and  their  respective  cost-
benefits.  In  the  last  column  information  is  given  on  the  amortisation  rate.  It  appears  that 
insulation pays off rather quickly.68  

66 

67 

68 

Development  of  the  relative  production  output  (quantity-based)  for  double  and  triple  glazing  in 
Switzerland, 1970–2001 (%) and the price difference for glass manufacturing between 1970 and 2006 
(CHF (2006)/m2). 
Based  on  studies  done  by  ecofys  covering  Austria,  Belgium,  Denmark,  Finland,  France,  Germany, 
Ireland, UK, Spain, Sweden, Netherlands, Italy, Norway, Switzerland and Turkey. 
The numbers do not include the fixed costs of refurbishment. This is a valid assumption since there are 
two decisions. One is the decision to refurbish or not. This decision affects the refurbishment rate which 
is  assumed  fixed  at  3%  in  the  calculations.  The  other  decision  is,  once  one  has  chosen  for 
refurbishment, whether or not to install insulation.  

EN 

57 

   EN 

 
 
 
 
 
 
                                                 
Also for insulation, the Ecodesign Directive could result in an acceleration of learning curves.  

Figure 2 

Textiles 

Textile  products  such  as  clothing  and  footwear  do  have  relevant  environmental  impacts 
(EIPRO  2006),  even  though  not  all  studies  investigated  in  the  EIPRO  project  agree  on  the 
relevance  of  the  product  category.  There  is  an  agreement  that  clothing  and  footwear 
contributes significantly to water use and acidification, whereas a relevant contribution to land 
use,  eutrophication,  greenhouse  gases,  photochemical  ozone  and  waste  is  agreed  by  Nijdam 
and Wilting (2003) and partly by Labouze et al. (2003) and Dall et al. (2002). 

Criteria  for  textile  products  have  been  developed  by  main  eco-labels,  which  prove  the 
environmental relevance and eco-design improvement potential of this product group. Some 
non-exhaustive examples are given in the following table: 

EN 

58 

   EN 

 
 
Table 6: different requirements for textiles 

Eco-Label 

Type of Textiles  Requirements regarding 

Textile  fibre:  type  of  fibre,  limitation  of  toxic 
residues  in  fibres,  reduction  of  air  and  water 
pollution  during  fibre  process;  processes  and 
chemicals: 
limitation  of  harmful  substances, 
fitness for use: performance and durability 

Residues in the final product, emissions from the 
production  of  material 
(tannery),  harmful 
substances,  VOC,  PVC,  energy  consumption, 
electrical components, packaging, durability 

Natural  vegetable  fibres,  skins  and  leather  – 
tanning,  skins  and  leather  -  treatment  with 
chemical 
and  water 
energy 
consumption, recycling systems 

products, 

Type  of  fibres,  chemical  substances,  resins, 
packaging, replacement 

For  example  for  Leather  Bags:  formaldehyde 
content,  PCP,  heavy  metals,  dyestuff  fastness, 
plastics, metals, durability, information consumer 

Fitness  for  purpose,  materials  (fibres,  plastics), 
hazardous materials, packaging 

EU 
Eco-label 
(www.ec.europa.eu/en
vironment/ecolabel) 

Textiles 

EU 
Eco-label 
(www.ec.europa.eu/en
vironment/ecolabel) 

Shoes 

Nordic 
(www.svanen.nu) 

Swan 

Textiles, 
and leather 

skins 

Japanese  Eco-Label 
(www.ecomark.jp) 

Japanese  Eco-Label 
(www.ecomark.jp) 

Australian  Eco-label 
(www.aela.org.au) 

Clothes, 
Household Textile 
Products,  Textile 
for 
Products 
Industrial Use 

Bags 
and 
Suitcases (Leather 
Bags, 
Fabric 
Bags, 
Synthetic/Artificia
l  Leather  Bags, 
Other 
Bags, 
Suitcases) 

Textiles  (Clothing 
and 
Bedding 
Products,  Interior 
Textile 
Applications, 
Yarns 
and 
Fabrics,  Textile 
Outdoor 
Bags, 
Textile 
Applications) 

Moreover, Labouze et al. (2003) rank the external costs of environmental impacts of textiles 
on the 6th position, behind EuP products (space heating, EuP domestic appliances, appliances 
and lights) and transport (personal cars and good transports). 

EN 

59 

   EN 

Detergents 

Innovative  detergents  are  projected  to  save  4.7  Mt  CO2  equivalents  yearly  in  2020  at  a 
negative cost of -336 Euro/t CO2 avoided. In other words, the CO2 reduction can be achieved 
without additional  expenses but  instead  leads  to large  economic savings. Overall  savings of 
households would amount to €1.6 billion. 69 Based on the environmental parameters described 
in  the  eco-labels  for  detergents  a  simulation  was  conducted  that  25%  of  the  worst 
environmental performing products would be banned from the market70:  

Table 8 

Product 

Environmental 
impact 

savings as % of total 
impact of product 
category 

Cleaners  for 
sanitary 
facilities 

CDV 

Total 
Phosphorus 

Biodegradability 
of chemicals 

VOCs 

CDV 

All-purpose 
Cleaners 

Total 
Phosphorus 

Biodegradability 
of chemicals 

VOCs 

CDV 

Total 
Phosphorus 

Total Chemicals 

Hazardous 
Ingredients 

Detergents 
for 
Dishwashers 

22% 

17% 

33% 

17% 

20% 

17% 

5% 

17% 

17% 

12% 

14% 

26% 

absolute savings   unit/yr 

29,812,757 

Mlitres 

149 

tonne 

15 

1,490 

tonne 

tonne 

22,361,482 

Mlitres 

15 

tonne 

597 

746 

tonne 

tonne 

991,159 

Mlitres 

29,736 

86,727 

tonne 

tonne 

3,963 

tonne 

69 
70 

Own calculations based on McKinsey (2007). 
Own  calculations  based  on  AEAT  in  Confidence  (2004)  The  Direct  and  Indirect  Benefits  of  the 
European Ecolabel – Final Report. The main assumptions made are 1) the eco-label corresponds to the 
10% best environmental performing products on the market 2) environmental performance of products 
follows a standard normal distribution 3) the 25% worst performing products are replaced according to 
a normal distribution of the 75% best performing products. 

EN 

60 

   EN 

                                                 
Biodegradability 
of chemicals 

Hand 
Dishwashing 
Detergents 

CDV 

Total Chemicals 

Hazardous 
ingredients 

Laundry 
Detergents 

CDV 

Total 
Phosphorus 

Total Chemicals 

Hazardous 
ingredients 

Biodegradability 
of chemicals 

17% 

11% 

12% 

11% 

8% 

11% 

11% 

17% 

32% 

5,949 

tonne 

8,246,593 

Mlitres 

72,110 

tonne 

20,693 

tonne 

19,890,591 

Mlitres 

165,233 

660,858 

tonne 

tonne 

6,609 

tonne 

114,733,010 

tonne 

An older analysis done by P&G demonstrates how the environmental performance for laundry 
detergents  can  be  improved.  The  analysis  –summarised  in  the  below  table-  represents  a 
‘cradle-to-grave’  LCA  for  1  wash  under  UK  conditions  for  wash  habits  and  infrastructure. 
Under the study’s conditions, it is concluded that compact detergents (both powder & liquid) 
are  environmentally  preferable  detergent  formulations,  mainly  due  to  the  lower  use  of 
chemicals,  resulting  in  benefits  on  aquatic  toxicity,  eutrophication,  ozone  depletion  and 
photochemical smog71. This study does not include the newer cold-wash detergents that have 
the much larger potential and via a different mechanism of saving energy for water heating, as 
detailed more above and as found by both McKinsey 2007 and P&G 2006.  

Table 9 

Lice cycle energy consumption and emissions for 1 wash under UK conditions with year 2001 P&G laundry formulations 

While  there  is  already  legislation  that  covers  the  environmental  performance  of  chemicals, 
this  does  not  cover  the  cold-wash  effect  with  the  huge  and  very  cost-efficient  savings 
potential of 5 M t / CO2 per year. REACH regulates chemicals in general and there is also the 
Detergents Directive which regulates detergents specifically, but again both have no effect on 

71 

G.  Van  Hoof,  D.  Schowanek,  TCJ  Feijtel  (2003).  Comparative  Life  Cycle  Assessment  of  laundry 
detergent  formulations  in  the  UK.  Part  I:  Environmental  fingerprint  of  five  detergent  formulations  in 
2001. Tenside (in press). 

EN 

61 

   EN 

 
                                                 
cold-wash  detergents,  hence  the  extended  Eco-design  legislation  is  fully  complementary. 
Therefore, detergents are fully meeting the art 15.2 of the Eco-design Directive . 

Water using products 

24.4%  of  all  water  is  consumed  by  the  domestic  sector.  More  resource  efficient  use  and 
improving the technical performance of showers, baths, taps, washing machines, dish washers 
and toilet flushes could lead to water savings for households of between 29-41%. Improving 
the technical performance could lead to water savings for households of 25%.72  

Table 10 

Source: study on water by DG ENV 

The  below  table  provides  examples  of  such  improvements  in  the  technical  performance  of 
household devices.  

72 

Eco-logic (2007) EU Water saving potential (Part 1 –Report) prepared for DG ENV. 

EN 

62 

   EN 

 
                                                 
Table 11: Typical water saving devices 

Source: study on water by DG ENV 

This  corresponds  to  savings  of  6.1%  of  total  water  use.  Disregarding  washing  and  laundry 
machines, which are already regulated under the Ecodesign Directive, the savings potential is 
15% smaller corresponding to savings of 5.2% of total water use. 

More water efficiency also means higher energy efficiency. For example for baths, showers 
and taps less water use means less hot water use, which implies less water heating by boilers 
which in turn results in electricity savings. The water saving potential for these products is 28-
34%, which is also the assumed water heating need saving for a household73.  
Water heaters currently use 92 Twh/year of primary energy74. Reducing heating needs by 28-
34% should lead to a reduction in energy use of 26-31 Twh/year. This represents savings of 
0.20-0.23%  of  total  final  energy  consumption  in  the  EU-25.  Reducing  energy  use  would  in 
turn  result  in  18.2  -  21.7  Mt  CO2  emissions  saved  per  year.  By  2020,  roughly  40%  of  that 
potential  could  be  saved  assuming  a  replacement  rate  of  3%  per  annum.  This  would 
correspond to CO2 savings in the magnitude of 7.5 Mt CO2 per year. 

Water efficiency of appliances seems not to be reflected in prices as available evidence for the 
UK indicates75. Another study finds payback times for water efficient showers to be 3.5 years 
and for water efficient toilet flush to be 6-11 years.76  

73 

74 
75 

This  assumption  is  underbuild  by  technical  arguments.  The  main  technical  improvement  to  get  more 
water efficient taps, showers and baths for the same level of quality is to infuse more air into the water. 
This technique will apply to water regardless of it being hot or cold. 
Task 7 on water heaters of the preparatory studies for eco-design. 
Pricing  in  the  longer  term  should  not  be  a  barrier  to  uptake  for  more  efficient  showers  as  currently 
available water efficient showers tend not to be priced higher then the market average. The long-term 
decline in the price of baseline (inefficient) water using equipment is expected to be 2.45%. Reductions 

EN 

63 

   EN 

 
                                                 
There  seems  to  be  scope  for  improving  the  water  efficiency  of  apparatus  in  agriculture  and 
industry as well e.g. irrigation equipment.  

Furniture 

The  EIPRO  project  investigated  furniture  only  in  the  broader  category  "Housing,  furniture, 
equipment  and  utility  use",  with  some  underlying  studies  confirming  the  relevance  of 
furniture for eutrophication (Labouze et al. (2003)), resource depletion and waste (Dall et al. 
2002 and Moll et al. 2004). 

Criteria  for  furniture  have  been  developed  by  several  main  eco-labels,  which  prove  the 
environmental relevance and eco-design improvement potential of this product group. Some 
non-exhaustive examples are given in the following table: 

Table 12 

Eco-Label 

Type of Furniture 

Requirements regarding 

Eco-label 

EU 
(www.ec.europa.eu/en
vironment/ecolabel/ind
ex_en.htm) 

Furniture 

No agreed requirements so far 

Nordic 
(www.svanen.nu) 

Swan 

Furniture and fitments 

Nordic 
(www.svanen.nu) 

Swan 

Furniture 
Outdoor 
Playground Equipment 

and 

Wood,  wood  based  panels,  surface  treatment  of 
wood,  metals,  plastics,  padding  materials,  fabrics, 
glass, adhesives, waste, packaging 

Solid  wood,  wood-based  panels  and  high  pressure 
laminate,  wood  preservation,  surface  treatment  of 
wood,  maintenance  products  for  wood,  metals, 
plastics, adhesive 

German  Blue  Angel 
(www.blauer-engel.de) 

Furniture 

Manufacturing: origin of the wood, formaldehyde in 
wood-based  materials,  coating  systems;  use:  indoor 
air  quality,  packaging,  wearing  parts;  recycling  and 
disposal; 
advertising 
statements 

information, 

consumer 

Japanese 
(www.ecomark.jp) 

Eco-Label 

Furniture 

Wood  origin,  CFC,  BTX,  polymers,  coatings,  paint, 
adhesives, repair system, packaging, information,  

Australian  Eco-label 
(www.aela.org.au) 

Furniture and Fittings (Office/ 
Domestic  Chairs,  Office/ 
Domestic  Desks  &  Tables, 
Bedroom  Furniture,  White 
Furniture, Fittings) 

Fitness  for  purpose,  materials  (timber  and  other 
natural  materials,  plastics,  fabrics,  glass,  rubber, 
adhesives,  metals,  coatings),  hazardous  materials, 
post consumption recycling and labelling 

in the price of water efficient equipment of between 5% and 15% are expected. Current example prices 
for showers are about £142 for 7.5 kW electric shower (3.46 l/min), £184 for a 10.8 kW electric shower 
(4.99 l min) and £184 for a standard mixer shower (8 l min). Current example prices for WCs are about 
£163  for  a  6/4-litre,  dual-flush WC, £275  for  a  4.5-litre  WC  but,  surprisingly,  only  £120  for  a  4.5/3-
litre, dual flush WC. Current examples of the prices of baths are £455 for a 140-litre bath, £198 for a 
160-litre  bath,  £118  for  a  200-litre  bath  and  £171  for  a  290-litre  bath.  As  these  figures  show,  bath 
volume is not an indicator of price UK’s Market Transformation Programme and Assessing the cost of 
compliance  with  the  Code  for  Sustainable  homes,  Environment  Agency,  2007  (available  from 
www.environment-agency.gov.uk). 
Eco-logic (2007) EU Water saving potential (Part 1 –Report) prepared for DG ENV. 

64 

   EN 

76 

EN 

                                                                                                                                                         
Australian  Eco-label 
(www.aela.org.au) 

Outdoor 
Furniture 
(Commercial  and  Public  Use 
Outdoor  furniture,  Domestic 
Outdoor 
Recreational 
Furniture,  Roadside  Furniture, 
Outdoor 
and 
Ornaments) 

Fittings 

Fitness  for  purpose,  materials  (timber  and  other 
natural  materials,  plastics,  fabrics,  glass,  rubber, 
adhesives,  metals,  coatings),  hazardous  materials, 
post consumption recycling and labelling 

For furniture there are a lot of company specific success stories of improvements over the life 
cycle. Successful examples include the eco-design of office furniture77 or wooden furniture78. 

77 
78 

http://www.steelcase.com/uk/office_furniture_steelcase_index.aspx 
Klostermann  and  Tukker  (Eds.)  (1998)  Product  innovation  and  eco-efficiency,  Kluwer  Acedemic 
Publishers. 

EN 

65 

   EN 

 
                                                 
ANNEX V 

Volumes sold for other means of transportation 

This  annex  assesses  whether  the  whether  the  threshold  of  article  15  2  (a)  is  met  for  other 
means of transport. In this article it is stated that products shall represent a significant volume 
of sales and trade, indicitavely more than 200000 units a year within the Community.  

The data is based on the available information in PRODCOM for the year 2006. For transport 
by  water  only  floating  structures  are  sold  over  200,000  units.  Yet,  no  significant 
environmental impacts can be expected from them.  

Table 1 

transportation by water 

Non-sea going ferry boats, cruise ships, excursion boats and similar vessels 

Tugs 

Sea-going dredgers 

Floating cranes, floating docks, and other vessels, the navigability of which is 
subsidiary  to  their  main  function  (excl.  dredgers,  floating  or  submersible 
drilling or production platforms; fishing vessels and warships), sea-going 

Dredgers,  and  other  vessels,  the  navigability  of  which  is  subsidiary  to  their 
main function (excl.  floating or submersible drilling  or production platforms; 
fishing vessels and warships), not sea-going 

Other vessels (including lifeboats) other than rowing boats, sea-going 

Other vessels (including lifeboats other than rowing boats) not sea-going 

Floating  structures  (including  rafts,  tanks,  coffer-dams,  landing-stages,  buoys 
and beacons) 

Non sea-going sailboats, for pleasure or sports, of a length < 7.5 m 

Non sea-going sailboats for pleasure or sports, > 100 kg in weight and 7.5 m in 
length 

Inflatable vessels for pleasure or sports, of a weight < 100 kg 

Inflatable vessels for pleasure or sports, of a weight > 100 kg 

Sold 
Volume 
EU27 

455 

114 

51 

57 

31 

1731 

2478 

622050 

20189 

5112 

50332 

20741 

Non sea-going motorboats for pleasure or sports, < 7.5 m in length (excluding 
outboard motorboats) 

12777 

Rigid  boats-  100  kg  in  weight  (including  outboard  motorboats,  rowing  boats 
and canoes) 

94069 

EN 

66 

   EN 

Rigid  boats  >  100  kg  in  weight  and  <  7.5  m  in  length  (including  outboard 
motorboats, rowing boats and canoes) 

42931 

Rigid  boats  >  100  kg  in  weight  and  7.5  m  in  length  (including  outboard 
motorboats, rowing boats and canoes) 

6321 

For  rail  transport  no  product  category  has  sales  above  10,000  units  a  year.  Combined  the 
volumes are below 15,000 units.  

Table 2 

rail transport 

Rail locomotives powered from an external source of electricity 

Diesel-electric locomotives 

Self-propelled railway or tramway coaches, vans and trucks powered from an 
external  source  of  electricity  (excluding  railway  or  tramway  maintenance  or 
service vehicles) 

Self-propelled  railway  or  tramway  coaches,  vans  and  trucks (excluding those 
powered by electricity, railway and tramway maintenance or service vehicles) 

Railway  or  tramway  maintenance  or  service  vehicles  (including  workshops, 
cranes,  ballast  tampers,  track-liners,  testing  coaches  and  track  inspection 
vehicles) 

Rail/tramway passenger coaches; luggage vans, post office coaches and other 
rail/tramway 
special 
maintenance/service vehicles, self-propelled 

rail/tramway 

excluding 

purpose 

coaches 

Tank wagons and  the like, insulated, refrigerated or covered and closed vans 
and wagons for railway or tramway use (excluding self-propelled) 

Rail/tramway  goods  vans/wagons  including  self-discharging  vans/  wagons, 
insulated, 
open  with  non-removable  sides  60cm, 
refrigerated/covered, closed vans/wagons 

tank  wagons  etc., 

Sold 
volume 
EU27 

566 

323 

1629 

511 

1193 

991 

3743 

5848 

For air transport no product category has sales above 2,000 a year. Combined the volumes are 
lower than 10,000 a year.  

EN 

67 

   EN 

Table 3 

air transport 

Turbojets or turbofans of a dry thrust > 25 kN, for civil use 

Turboprops of a power < 1100 kW, for civil use 

Gliders and hang gliders, for civil use 

Helicopters of an unladen weight < 2000 kg, for civil use 

Helicopters of an unladen weight > 2000 kg, for civil use 

Sold 
volume 
EU27 

1574 

982 

509 

182 

383 

Aeroplanes and other aircraft of an unladen weight < 2000 kg, for civil use 

1333 

Aeroplanes and other aircraft of an unladen weight > 2000 kg, but < 15000 kg 
for civil use 

Aeroplanes and other aircraft of an unladen weight > 15 000 kg, for civil use 

230 

434 

In  the  category  other,  bicycles  and  parts,  invalid  carriages  and  vehicles  not  mechanically 
propelled.  The  200,000  sold  criteria  excludes  “Invalid  carriages  motorized  or  mechanically 
propelled”. Other categories such as bicycles and parts or vehicles not mechanically propelled 
seem not to have a very big environmental impact.  

Table 4 

Other 

Sold 
volume 
EU27 

Non-motorized  bicycles  and  other  cycles,  without  ball  bearings  (including 
delivery tricycles) 

1876540 

Non-motorized bicycles and other cycles with ball bearings (including delivery 
tricycles) 

10413953 

Frames for bicycles, other non-motorized cycles and side-cars (excluding parts 
of frames) 

2244108 

Front forks for bicycles, other non-motorized cycles and side-cars (excluding 
parts of front forks) 

Wheel rims for bicycles other non-motorized cycles and side-cars 

1103244 

19314277 

Wheel spokes for bicycles, other non-motorized cycles and side-cars 

6335948 

Hubs without  free-wheel or braking device  for bicycles, other  non-motorized 
cycles and side-cars 

3877819 

EN 

68 

   EN 

Coaster  braking  hubs  and  hub  brakes  for  bicycles  and  other  non-motorized 
cycles 

2723865 

Brakes for bicycles and other non-motorized cycles (excluding coaster braking 
hubs and hub brakes) 

Pedals for bicycles and other non-motorized cycles 

Crank-gear for bicycles and other non-motorized cycles 

Luggage-carriers for bicycles and other non-motorized cycles 

Invalid carriages not mechanically propelled 

Invalid carriages motorized or mechanically propelled 

7895581 

662357 

1215878 

2696298 

861633 

134871 

Vehicles  not  mechanically  propelled  including  industry  trolleys,  barrows, 
luggage  trucks,  hopper-trucks,  hand  pulled  golf  trolleys  excluding  shopping 
trolleys 

9306570 

EN 

69 

   EN 

ANNEX VI 

Definition of technical terms 

This annex defines the definition of technical terms79 

•  Abiotic depletion refers to the exhaustion of natural resources such as iron ore or copper, 
which are regarded as non-living. Impacts considered are those derived from the extraction 
of minerals and fossil fuels. 

•  Global warming is the impact of greenhouse gases emissions on the radiative forcing of the 
atmosphere. These emissions have negative impacts on human and ecosystem health, and 
material welfare. 

•  Human  toxicity  includes  the  impacts  on  human  health  of  toxic  substances  emitted  to  the 

environment. 

•  Fresh  water  aquatic  ecotoxicity  refers  to  the  impact  of  toxic  substances  emitted  to 

freshwater aquatic ecosystems. 

•  Marine  aquatic  ecotoxicology  refers  to  the  impact  of  toxic  substances  emitted  to  marine 

aquatic ecosystems. 

•  Terrestrial  ecotoxicity  refers  to  the  impact  of  toxic  substances  emitted  to  terrestrial 

ecosystems.  

•  Photochemical oxidation is the formation of reactive chemical compounds, such as ozone, 
by  the  action  of  sunlight  on  certain  primary  air  pollutants.  These  compounds  may  be 
injurious to human health, ecosystems, materials and crops.  

•  Acidification is the result of acidifying pollutants emissions, such as SO2 or NOx, to the 
air. These emissions have negative impacts on soil, groundwater, surface waters, biological 
organisms, ecosystems and materials. 

•  Eutrophication is  the consequence  of  high levels  of  macronutrients,  such  as  nitrogen  and 

phosphorus, in the environment. 

•  Land use refers to the transformation and occupation of land by human activities, such as 
agriculture,  housing,  road  infrastructure  etc.  This  has  direct  impacts  on  biodiversity,  soil 
erosion, groundwater protection and other environmental aspects. 

•  Stratospheric ozone depletion refers to the reduction of ozone in the stratosphere (“Ozone 
hole”)  caused  by  chemical  and  photochemical  reactions  e.g.  with  chlorofluorocarbons 
(CFCs) and other substances. 

79 

These  defintions  have  been  taken  from  H.  Cabal  Y.Lechón  R.  Sáez  (2005)  European  Sustainable 
Electricity;  Comprehensive  Analysis  of  Future  European  Demand  and  Generation  of  European 
Electricity and its Security of Supply research partly funded by DG RTD. 

EN 

70 

   EN 

                                                 
ANNEX VII 
External cost factors to monetarise environmental impacts80 

This annex summarises the external cost factors to monetise environmental impacts which can 
be found in the literature.  

• 

80 

EN 

This annex is based on page 71 of Labouze et al. 

71 

   EN 

 
                                                 
Estimation of costs and benefits for some products in option 1 and 2 

ANNEX VIII 

For  option  1,  the  case  of  water  heaters  was  analysed  in  detail.  On  the  basis  of  the  results  of  the  Preparatory  Study,  Task  6 
(http://www.ecohotwater.org/), the following information was used for the extra small water heaters: 

Category 

Market share 

Life-time (years) 

Type  

Energy consumption kWh/y 

Electricity consumption 

Gas consumption 

Purchase price (EUR) 

Life-cycle cost (EUR) 

CO2 emissions (Tn) 

And 

XS 

12.5% 

10 

BC XS 

EIWH E 8 

1,762 

1,527 

235 

187 

1,961 

1.198 

1,348 

1,348 

0 

318 

1,667 

0.917 

Number of appliances sold per year 

2,152,000 

Estimated number of installed appliances 

21,520,000

EN 

72 

   EN 

 
 
 
 
The results are presented in the following table: 

  Baseline 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

total number of 
appliances-Least 
LC purchased 
(million) 

Number of Least 
LCC installed 
(million) 

Remaining number 
of appliances-BC 
(million)  

Additional 
Purchase Cost 
(million EUR)  N

Discounted 
additional purchase 
cost (million EUR)

0.0 

2.2 

2.2 

2.2 

2.2 

2.2 

2.2 

2.2 

2.2 

2.2 

2.2 

0.0 

0.0 

2.2 

4.3 

6.5 

8.6 

10.8 

12.9 

15.1 

17.2 

19.4 

21.5 

19.4 

17.2 

15.1 

12.9 

10.8 

8.6 

6.5 

4.3 

2.2 

0.0 

0.0 

281.9 

281.9 

281.9 

281.9 

281.9 

281.9 

281.9 

281.9 

281.9 

281.9 

281.9 

256.3 

233.0 

211.8 

192.5 

175.0 

159.1 

144.7 

131.5 

119.6 

Runing cost (M€/y)

N

I

0 

0 

493 

0 

493 

493 

493 

493 

493 

493 

493 

493 

493 

493 

986 

1,479 

1,973 

2,466 

2,959 

3,452 

3,945 

4,438 

O 5,799 

5,219 

4,639 

4,059 

3,479 

2,900 

2,320 

1,740 

1,160 

580 

0 

T

5,799 

5,712 

5,626 

5,539 

5,452 

5,365 

5,279 

5,192 

5,105 

5,018 

4,932 

EN 

73 

   EN 

  
 
 
 
 
  
Upfront + running 
cost (M€) 

Difference between 
Upfront and runnig 
costs to baseline 
(M€) 

NPV of the 
difference of 
upfront and 
running cost to 
baseline (M€) 

Energy 
consumption 
(Gwh) 

Energy savings 
compared with 
baseline 

CO2 emission (M 
Tn) 

5,799 

5,994 

5,907 

5,821 

5,734 

5,647 

5,560 

5,474 

5,387 

5,300 

5,213 

-195 

-108 

-22 

65 

152 

239 

325 

412 

499 

586 

-195 

-99 

-18 

49 

104 

148 

184 

211 

233 

248 

N

I

0 

0 

2,901 

2,901 

2,901 

2,901 

2,901 

2,901 

2,901 

2,901 

2,901 

2,901 

0 

2,901 

5,802 

8,703 

11,604 

14,504 

17,405 

20,306 

23,207 

26,108 

O 37,918 

34,126 

30,335 

26,543 

22,751 

18,959 

15,167 

11,375 

7,584 

3,792 

0 

T 37,918 

37,027 

36,136 

35,245 

34,355 

33,464 

32,573 

31,682 

30,791 

29,900 

29,009 

891 

1,782 

2,673 

3,564 

4,455 

5,346 

6,236 

7,127 

8,018 

8,909 

N

I

O

0 

0 

2 

0 

2 

2 

2 

4 

2 

6 

2 

8 

26 

23 

21 

18 

15 

13 

2 

10 

10 

2 

12 

8 

2 

14 

5 

2 

16 

3 

2 

18 

0 

EN 

74 

   EN 

 
 
  
 
  
 
  
T

26 

25 

25 

24 

23 

23 

22 

22 

21 

20 

20 

Emission saving 
compared with 
baseline (M Tn) 

1 

1 

2 

2 

3 

4 

4 

5 

5 

6 

N= New appliance (least life-cycle); I= Installed New appliances (least life-cycle); O= currently installed capacity, assimilated to Baseline appliance in 
the markets; T= Total 

For the case of extra large water heaters, the following information was used: 

Category 

Market share 

Life-time (years) 

Type  

Energy consumption kWh/y 

electricity  

gas 

Purchase price (EUR) 

Life-cycle cost (EUR) 

CO2 emissions (Tn) 

XL 

10 

5,5%  

BC XL 

COMBISTOR condensing

11,566

7,293

4,273

665

11,786

8

7,334

134

7,200

1,037

8,636

5

EN 

75 

   EN 

 
  
 
 
 
And  

Number of appliances sold per year 

Estimated number of installed appliances 

946,880

9,468,800

The results are 

total number of 
appliances-Least 
LC purchased 
(million) 

Number of Least 
LCC installed 
(million) 

Remaining number 
of appliances-BC 
(million) 

Additional 
Purchase Cost 
(million EUR) 

Discounted 
additional purchase 
cost (million EUR)

BAU 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

0 

0 

9 

1 

0 

9 

1 

1 

8 

1 

2 

7 

1 

3 

6 

1 

4 

5 

1 

5 

4 

1 

6 

3 

1 

7 

2 

1 

8 

1 

1 

9 

0 

N

0 

352 

352 

352 

352 

352 

352 

352 

352 

352 

352 

352 

320 

291 

265 

241 

219 

199 

181 

164 

149 

EN 

76 

   EN 

  
  
  
  
  
  
  
Runing cost (M€/y)

Upfront + running 
cost (M€) 

Difference between 
Upfront and runnig 
costs to baseline 
(M€) 

NPV of the of 
difference between 
upfront and running 
cost to baseline 
(M€) 

Energy 
consumption (Gwh)

N

I 

0 

0 

308 

0 

308 

308 

308 

616 

308 

308 

308 

308 

308 

308 

308 

925 

1,233 

1,541 

1,849 

2,158 

2,466 

2,774 

O 13,441 

12,097 

10,753 

9,409 

8,064 

6,720 

5,376 

4,032 

2,688 

1,344 

0 

T 13,441 

12,405 

11,369 

10,333 

9,297 

8,262 

7,226 

6,190 

5,154 

4,118 

3,082 

13,441 

12,757 

11,721 

10,685 

9,650 

8,614 

7,578 

6,542 

5,506 

4,470 

3,435 

684 

1,719 

2,755 

3,791 

4,827 

5,863 

6,899 

7,935 

8,970 

10,006 

684 

1,563 

2,277 

2,848 

3,297 

3,640 

3,894 

4,072 

4,185 

4,244 

6,944 

6,944 

6,944 

6,944 

6,944 

6,944 

6,944 

6,944 

6,944 

6,944 

0 

6,944 

13,889 

20,833 

27,778 

34,722 

41,667 

48,611 

55,555 

62,500 

N

I 

0 

0 

O 109,516  98,565 

87,613 

76,661 

65,710 

54,758 

43,806 

32,855 

21,903 

10,952 

0 

T 109,516  105,509 101,502

97,495 

93,487 

89,480 

85,473 

81,466 

77,459 

73,451 

69,444 

EN 

77 

   EN 

 
  
  
  
  
  
Energy savings 
compared with 
baseline 

CO2 emission (M 
Tn) 

Emission saving 
compared with 
baseline (M Tn) 

4,007 

8,014 

12,022 

16,029 

20,036 

24,043 

28,050 

32,058 

36,065 

40,072 

N

I 

O

T

0 

0 

74 

74 

5 

0 

67 

72 

5 

5 

60 

69 

5 

9 

52 

66 

5 

14 

45 

64 

5 

19 

37 

61 

5 

24 

30 

58 

5 

28 

22 

55 

5 

33 

15 

53 

5 

38 

7 

50 

5 

42 

0 

47 

3 

5 

8 

11 

14 

16 

19 

22 

25 

27 

 N= New appliance (least life-cycle); I= Installed New appliances (least life-cycle); O= currently installed capacity, assimilated to Baseline appliance 
in the markets; T= Total 

For option 2, the case of windows was analysed. 

The data for the analysis is from PricewaterHouse Cooper (2007).  

standard 

single glazed 

Double glazed 

Purchase price (euro/m2) 

Energy use during lifespan (kwh/m2) 

CO2 
CO2e/m2) 

emitted 

during 

lifespan 

(kg 

100

8400

6297

150

6480

4980

 Replacement surface (m2/y)  

52,141,600 

52,141,600 

EN 

78 

   EN 

  
  
  
  
The replacement rate represents 4% of the still unrefurbished windows throughout the EU. 

The results are shown in the table below. 

Purchase costs ( M 
EUR) 

Additional purchase 
costs (M EUR) 

NPV of Additional 
purchase costs (M 
EUR) 

Energy consumption 
of new installations 
(GWh/y) 

Cumulative energy 
savings compared 
with baseline 
(GWh/y) 

Energy consumption 
(M €) 

Cumualtive energy 
savings (M €) 

NPV of cummulative 
energy savings (M€)

Baseline 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

5,214  

7,821  

7,821  

7,821  

7,821  

7,821  

7,821  

7,821  

7,821  

7,821  

7,821  

2,607  

2,607  

2,607  

2,607  

2,607  

2,607  

2,607  

2,607  

2,607  

2,607  

2,607  

2,507  

2,410  

2,318  

2,229  

2,143  

2,060  

1,981  

1,905  

1,832  

14,600   11,263  11,263  11,263  11,263  11,263  11,263  11,263  11,263  11,263  11,263 

3,337  

6,674   10,011  13,348  16,685  20,022  23,359  26,696  30,034  33,371 

2,482  

1,915  

3,829  

5,744  

7,659  

9,573   11,488  13,402  15,317  17,232  19,146 

567  

1,135  

1,702  

2,269  

2,837  

3,404  

3,971  

4,538  

5,106  

5,673  

567  

1,091  

1,574  

2,017  

2,425  

2,798  

3,138  

3,449  

3,731  

3,986  

EN 

79 

   EN 

  
  
  
  
  
  
Total purchase cost - 
energy savings (M 
EUR) 

CO2 impacts (M t 
CO2e) 

Emissions avoided 
relative to baseline 
(M T CO2) 

- 2,040 

- 1,416 

- 837  

- 300  

196  

655  

1,078  

1,468  

1,826  

2,154  

11  

9  

17  

26  

35  

43  

52  

61  

69  

78  

87  

2.3  

4.6  

6.9  

9.2  

11.4  

13.7  

16.0  

18.3  

20.6  

22.9  

In  the  case  of  only  considering  50%  of  the  windows  replaced  with  double  glazing  and  the  other  50%  with  single  glazing,  the  results  are  presented 
below. 

Purchase costs (euro)

Additional purchase 
costs 

NPV of Additional 
purchase costs 

Energy consumption 
of new installations 
(GWh/y) 
Cummulative energy 
savings compared 
with baseline 
(GWh/y) 

Energy consumption 
(M €) 

Baseline 
5,214  

2010 
6,518  

2011 
6,518  

2012 
6,518  

2013 
6,518  

2014 
6,518  

2015 
6,518  

2016 
6,518  

2017 
6,518  

2018 
6,518  

2019 
6,518  

1,304  

1,304  

1,304  

1,304  

1,304  

1,304  

1,304  

1,304  

1,304  

1,304  

1,304  

1,253  

1,205  

1,159  

1,114  

1,071  

1,030  

991  

952  

916  

14,600   12,931 

5,631  

5,631  

5,631  

5,631  

5,631  

5,631  

5,631  

5,631  

5,631  

1,669   17,937  26,905  35,873  44,842  53,810  62,778  71,747  80,715  89,684 

2,482  

2,198  

4,397  

6,595  

8,793   10,991  13,190  15,388  17,586  19,785  21,983 

EN 

80 

   EN 

  
  
 
  
  
  
  
Cummualtive energy 
savings (M €) 

NPV of cummulative 
energy savings (M€)

Total purchase cost - 
enegy savings 

CO2 impacts (M t 
CO2e) 

Emissions avoided 
(M T CO2) 

284  

567  

851  

1,135  

1,418  

1,702  

1,986  

2,269  

2,553  

2,837  

284  

545  

787  

1,009  

1,212  

1,399  

1,569  

1,724  

1,865  

1,993  

- 1,020 

- 708  

- 418  

- 150  

98  

327  

539  

734  

913  

1,077  

11  

10  

20  

29  

39  

49  

59  

69  

78  

88  

98  

1.1  

2.3  

3.4  

4.6  

5.7  

6.9  

8.0  

9.1  

10.3  

11.4  

EN 

81 

   EN