The Ecodesign of Energy Related Products Directive (ErP) has resulted in the banning of inefficient light sources. Hywel Davies looks at other products that might be under threat.
The Ecodesign of Energy Related Products (ErP) Directive (full title - Directive 2009/125/EC, establishing a framework for the setting of ecodesign requirements for energy-related products) sets minimum environmental performance requirements for dozens of product groups. Its main focus is on energy performance in use, whether that is the energy the product uses or the impact the product has on energy use where it is installed.
All energy using products sold in the domestic, commercial and industrial sectors are covered by the Directive, apart from means of transport, which are covered by other legislation. The revised Directive, which came into force on 20th November 2009, covers all energy-related products including windows, insulation materials, and water using products such as shower heads or taps. However, it is still not clear whether these products will be addressed through measures under the Ecodesign Directive or under other measures such as the Energy Performance of Buildings Directive or Energy Services Directive.
It is generally acknowledged that a product's lifetime energy use is strongly influenced at the design phase. So the Directive aims to improve the environmental performance of products throughout their life by considering the raw materials used, manufacturing, packaging and distribution processes, installation and maintenance, as well as use and final disposal at the early stages of product design. It seeks to remove disparate national rules on environmental performance which create obstacles to trade within the European market. It is intended to benefit both businesses and consumers, by facilitating free movement of products and by enhancing product quality and environmental protection.
The "framework" Directive sets out overall performance criteria, but does not prescribe specific measures, standards or overall energy saving targets for specific product groups. Implementing measures setting specific requirements will be introduced for each product group, usually in the form of EU Regulations. These take direct effect in all Member States, without transposition into national laws. Where there are conflicting laws in place, they are superseded by the EU Regulation, so that the new rules come into effect across the EU at the same time. Manufacturers must meet the requirements of the Regulation in order to legally place their product on the market. Requirements for product energy labels to give consumers energy and environmental information are adopted alongside the Ecodesign measures.
The Commission has identified a long list of product groups to be covered by the Directive, including many domestic appliances (standby usage amounted to some 10% of domestic energy demand in 2005). Implementing measures are introduced after a process of initial study and discussion of the proposed measure with key stakeholders and national regulators.
Manufacturers who market a product covered by an implementing measure in the EU must ensure that it conforms to the energy and environmental standards set out by the measure.
The Ecodesign Working Plan for 2009-2011 published in October 2008 gives an indicative list of product groups considered to be priorities for adoption of implementing measures. The Commission are due to produce a new Working Plan for the period 2012-2014. A study has been initiated to provide background material for the revised Working Plan. Information on the Commission website suggests that the new plan is due to be published in October 2012.
In practice, implementing measures focus on products with high potential to cut greenhouse gas emissions at low cost by reducing energy demand, many of them domestic appliances. But a Regulation covers electric mains-operated air conditioners with a rated capacity of ≤12 kW for cooling, or heating if there is no cooling function, and comfort fans with a power input ≤125W. It is worth noting that air conditioning systems over 12 kW are subject to regular inspections under the EPBD, but these are proving difficult to implement due to a systemic failure of enforcement. Perhaps the Commission could propose a regulation for the ecodesign of the larger units to deliver energy savings instead? There is also a Regulation covering fans over 3kW, and another for water pumps for pumping clean water.
What is to come?
Development of measures for boilers, hot water heaters, office lighting, room air conditioners, solid fuel burning devices, room heating and warm air central heating, waste water pumps, motors and air conditioning systems are all in the current workplan, with the Regulation for boilers and water heaters due to be published soon. Manufacturers should be on the lookout for the revised workplan due to be published shortly.
Further Resources
EU guidelines accompany the various Commission Regulations implementing the Ecodesign Directive. They provide links to a very wide range of further information: hec.europa.eu/energy/efficiency/ecodesign/doc/overview_legislation_eco-design.pdf
For the latest European Commission information on the Directive go to ec.europa.eu/enterprise/policies/sustainable-business/ecodesign/index_en.htm
For the DEFRA website on the Directive and associated regulations and measures, go to efficient-products.defra.gov.uk/cms/product-area-updates
Development of the Ecodesign Directive
The Directive is the joint responsibility of DG Enterprise and Industry and DG Energy, as it combines original plans for an Energy Efficiency Requirements Directive with those for an Ecodesign for Electrical & Electronic Equipment Directive. So while the Directive's primary aim is to cut energy use, it also covers environmental considerations including materials and water use, polluting emissions, waste and recyclability. It is estimated that over 80% of these product-related environmental impacts are determined during the design phase of a product.
The original Ecodesign Directive 2005/32/EC, adopted in 2005, set a framework for manufacturers of energy-using products to reduce the energy consumption and other environmental impacts of their products. It was amended in 2008 as Directive 2008/28/EC. The Directive was recast to extend the scope to cover all energy-related products in 2009.