Commission staff working document - Accompanying document to the Proposal for a Directive of the European Parliament and of the Council on the indication by labelling and standard product information of the consumption of energy and other resources by energy-related products - Summary of the impact assessment {COM(2008) 778 final} {SEC(2008) 2862}
Date: 2008-11-13
Institutions: European Commission
Subjects: consumer information, energy consumption, household electrical appliance, labelling

EN 

EN 

   EN 

 
 
COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 13.11.2008 
SEC(2008) 2863 

COMMISSION STAFF WORKING DOCUMENT 

Accompanying document to the 

Proposal for a  

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on the indication by labelling and standard product information of the consumption of 
energy and other resources by energy-related products 

SUMMARY OF THE IMPACT ASSESSMENT 

{COM(2008) 778 final} 
{SEC(2008) 2862} 

EN 

   EN 

 
 
 
 
 
 
 
EXECUTIVE SUMMARY 

This Impact Assessment accompanies the proposal for the recast of the 92/75/EEC “Energy 
Labelling  Directive  for  Household  Appliances”1  (hereafter  ELD).  The  recast  of  the  ELD  is 
one of the elements  of  the  Action  Plan on Sustainable Consumption  and  Production and on 
Sustainable Industrial Policy (SCP/SIP). 

The  ELD,  which  was  adopted  in  1992,  requires  retailers  to  display  a  comparative  label 
showing the level of energy consumption of household appliances to consumers at the point 
of sale. It is estimated that energy labelling has contributed to annual energy savings in the 
order of 3 Mtoe2 corresponding to emission reductions of some 14 Mt of Co2 annually over 
the period 1996-2004. 

The energy label is compulsory for those products covered by implementing measures under 
the framework ELD. The energy labelling scheme has been successful in contributing to pull 
the market of household appliances towards more energy efficient products. It provides useful 

1 

2 

Council  Directive  92/75/EEC  of  22  September  1992  on  the  indication  by  labelling  and  standard 
product information of the consumption of energy and other resources by household appliances. 
This does not take into account energy savings from related self commitments by Ceced (white goods) 
and Eicta (TVs)  

EN 

2 

   EN 

 
 
                                                 
and  comparable  information  to  consumers,  allowing  them  to  consider  investing  in  better 
performing  appliances  in  order  to  realize  savings  in  taking  into  account  the  running  costs 
(mainly energy consumption in use). 

It also helps manufacturers to position their products on the market and get some payback on 
their  investments  for  introducing  better  and  more  innovative  appliances.  The  scheme  is 
therefore considered as a win-win instrument for consumers, industry and the environment. 

As  announced  in  the  Action  Plan  on  Sustainable  Consumption  and  Production  and  on 
Sustainable Industrial Policy (SCP/SIP), the ELD together with the Ecodesign Directive could 
deliver  more  savings  in  energy  and  reduction  of  environmental  impacts,  if  extended  to  all 
energy-related  product  groups  (products  that  have  an  impact  on  energy  consumption  during 
use). 

The  current  ELD  is  a  framework  that  mandates  the  Commission  (assisted  by  a  Regulatory 
Committee) to adopt labelling implementing measures for specific household appliances3. For 
these, an upgrade of the existing labels is being prepared for adoption in 2009 and 2010. 

The impact assessment of the SCP/SIP has shown that the limited scope of the ELD restricts 
its potential to further mitigate climate change and contribute to the EU-wide target of 20% 
energy  efficiency  gains  by  2020  and  achieve  the  goals  of  sustainable  production  and 
consumption. This impact assessment report therefore analyses further whether the scope and 
functioning  of  the  ELD  can  be  reinforced,  how  this  can  be  done  and  what  impacts  it  could 
have. However, as the ELD is a framework Directive with no direct impact on products, the 
environmental,  economic  and  social  impacts  can  only  be  quantified  in  detail  for  those 
implementing  measures  to  be  adopted  on  specific  products.  Accordingly,  the  potential 
advantages and disadvantages of the possible revision are considered in the light of a number 
of  selected  priority  product  groups  with  significant  environmental  impacts  and  for  which 
labelling appears to be a relevant policy instrument. 

For the functioning of the ELD, the aim is to seek increased effectiveness of the ELD and its 
implementing measures while reducing the administrative burden, and explore the use of ELD 
as a framework for harmonised mandatory public procurement and incentives in the Internal 
Market. 

3 

Refrigerators,  freezers  and  their  combinations,  washing  machines,  driers  and  their  combinations, 
dishwashers,  ovens,  water  heaters  and  hot-water  storage  appliances,  lighting  sources  and  air-
conditioning appliances. 

EN 

3 

   EN 

 
                                                 
Four policy options are considered as follows: 

(1) 

No policy change, with two sub-options: 

(1a)  BaU - business as usual,  

(2) 

(3) 

(4) 

(1b)  BaU + 1 - full implementation of the current ELD scope. 

Non-regulatory action. 

Amend the Directive - full implementation of the current ELD scope, plus coverage 
of all energy-related products, excluding means of transport. 

Repeal the Directive and implement its provisions within the Ecodesign Directive - 
full  implementation  of  the  current  ELD  scope,  plus  coverage  of  all  energy-related 
products, excluding means of transport.  

It is estimated that the policy option 1b (fully implement the current framework) could lead 
to,  based  on  the  considered  priority  appliances,  savings  of  some  22  Mtoe  by  2020, 
corresponding  to emission savings of about 65 Mt of CO2. More than half of these savings 
would  come  from  the  heating  and  water  heating  appliances  alone,  which  have  not  yet  been 
addressed  under  the  ELD.  The  rest  of  the  savings  would  come  from  the  upgrading  of  the 
existing eight measures, and from a new measure on televisions.  

Policy  option  2  (voluntary  agreements/self  commitments)  would  have  advantages  in  adding 
little  administrative  burden  to  the  business  and  administrations,  depending  on  the  way  of 
implementing  the  non-regulatory  action,  but  would  fully  rely  on  the  feasibility  and 
willingness  from  industry,  which  has  rejected  this  option  (CECED4  and  EICTA5).  The 
capacity of this policy option to contribute to further energy savings was considered marginal 
at best. 

Policy  option  3  (fully  exploit  current  framework  and  extend  the  scope  to  all  energy-related 
products) involves some administrative burden for the recast but would save some €4 million 
in  transposition  costs  for  every  upgraded  or  newly  developed  implementing  measure  if 
implementing  Directives  were  replaced  by  implementing  Regulations.  It  is  estimated  that 
broadening the scope of the ELD to energy-related products could lead to additional savings 
of some 27 Mtoe by 20206, corresponding to emission reduction of close to 80 Mt of CO2 in 
comparison  to  BaU.  This  represents  additional  savings  of  some  5  Mtoe  against  the  policy 
option BaU +1 alone from the three priority product groups considered (commercial heating 
and  refrigeration  and  windows).  More  precise  knowledge  on  the  savings  potential  of  these 
products  will  be  available  from  the  Ecodesign  preparatory  studies  followed  by  product 
specific  impact  assessments.  Additional  changes  like  introducing  provisions  on  the  legal 
protection  of  the  use  of  the  label,  clarifying  information  requirements  and  introducing  a 
framework  for  mandatory  public  procurement  and  incentives  would  further  reinforce  the 
effectiveness of the scheme as well as increase the savings. 

4 
5 
6 

European Committee of Manufacturers of Domestic Equipment 
European Information & Communications Technology Industry Association 
The figure is composed of the estimated 22 Mtoe savings by 2020 from the full implementation of the 
ELD and of some 5 Mtoe additional savings from the broadening on the scope, based on considerations 
on three priority product groups (windows, commercial refrigeration and heating appliances).  

EN 

4 

   EN 

 
                                                 
Policy  option  4,  repeal  the  ELD  and  implement  energy  labelling  within  the  Ecodesign 
Directive,  could  lead  in  theory  to  the  same  level  of  savings  as  policy  option  3  and  would 
reduce the number of regulatory instruments, but could hardly be considered as simplification. 
This is due to the different nature of the legal instruments: the Ecodesign Directive bans the 
less  performing  products  regarding  their  global  environmental  performance  focusing  on  all 
environmental aspects throughout the lifecycle of the product. The ELD provides an energy 
label showing to consumers the energy efficiency performance of the product during the use 
phase (and relevant use of other resources (like water) where relevant).  

The analysis and comparison of the policy options indicates that the options 1b and 3 are the 
most  cost-efficient  and  suitable  options  with  strongest  stakeholder  support  to  achieve  the 
policy objectives. 

Monitoring  and  evaluation  is  proposed  in  the  framework  of  Action  Plan  on  Sustainable 
Consumption  and  Production  and  Sustainable  Industrial  Policy  in  coordination  with 
Ecodesign, Ecolabel and other related instruments. 

EN 

5 

   EN