Revision of the Energy Labelling System

Revision of the Energy Labelling System

Final Report

Deutsche Energie-Agentur GmbH (dena) Energy Efficiency with Electricity Chausseestr. 128a 10115 Berlin www.dena.de

Contact: Annegret-Cl. Agricola Head of Division Tel.:

+49 (0)30 72 61 65 – 650

E-mail: [email protected]

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Rethinking Energy Labelling – Final Report

Contents 1

Project Aim and Background

4

2

Chronological Overview of the Project and its Content

4

3

Assessment of the Potential to Increase Energy Efficiency

5

4

General Issues Related to the EU Framework Directive on Energy Labelling

8

4.1

General Aspects to be Considered in the Design of the EU Energy Label

9

4.2

Layout of the EU Label for Large Household Appliances: Basic Label and Data-Strip 10

4.3

Energy Labelling for Rebuilt Appliances

10

4.4

Basic Principles for the Identification of the Class of Energy Efficiency

11

4.5

The Use of Several Operating Modes to Calculate the Energy Rating and Energy Consumption

12

4.6

Thresholds for the Classes of Energy Efficiency

13

4.7

Product Performance Details

14

4.8

Further Energy Consumption Information on Label and Fiche

14

4.9

Market Monitoring

15

5

Integration of an Updating Mechanism and Suitable Transitional Arrangements for more Dynamic Energy Labelling to Reflect Market Development

15

Washing and Drying Module – Revision of the Implementing Directive for Washing Machines

17

Principles for Calculating the Energy Rating and Energy Consumption of a Washing Machine

17

6.2

Basic Options for the Design of the Energy Label

18

6.3

Principles used to Determine the Classes of Energy Efficiency for Washing Machines

19

6.4

Information on Washing Machine Performance

20

6.5

Further Washing Machine Features Relevant to Energy Consumption

21

6 6.1

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6.6

Proposal for the Terminology used on the Energy Label for Washing Machines and the Order in which the Information is Displayed

22

6.7

Proposal for the Washing Machine Fiche

23

7

Washing and Drying Module – Revision of the Implementing Directive for Tumble Dryers

26

Principles for Calculating the Energy Rating and Energy Consumption of a Tumble Dryer

26

7.2

Basic Options for the Design of the Energy Label

27

7.3

Information on Product Performance and Other Features

27

7.4

Proposal for the Terminology used on the Energy Label for Tumble Dryers and the Order in which the Information is Displayed

28

7.5

Proposal for the Tumble Dryer Fiche

30

8

Outlook

32

7.1

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1

Project Aim and Background

In a joint project technical and design principles were drawn up for the revision of energy labelling required by the European legislative process, the main focus being on issues relevant to the amendment of EU Framework Directive 92/75/EEC on energy labelling and to the amendment of the Directives implementing the labelling of household washing machines and electric tumble dryers. The fundamental aim of the project was to ensure the effectiveness of energy labelling – and particularly the relevance of the EU Energy Label where marketing activities are concerned – and to continue to promote the energy efficiency of the corresponding appliances. The project was a joint initiative of the Federal Ministry of Economics and Labour (from 18 November 2005: Federal Ministry of Economics and Technology), the domestic appliance manufacturers AEG Hausgeräte GmbH, Bauknecht Hausgeräte GmbH, BSH Bosch und Siemens Hausgeräte GmbH and Miele & Cie. KG, the German Electrical and Electronic Manufacturers' Association ZVEI and the German Energy Agency Deutsche Energie-Agentur GmbH (dena). dena was responsible for project management. This final report presents the status of the project partners’ joint consultation process at the end of 2005 and identifies the key parameters for Germany’s position in respect of the revision of the corresponding Directives. The EU Commission is currently making decisions on energy efficiency policies which are of significance for the future. It is therefore important that sustainable suggestions be drawn up for energy labelling and that subjects under discussion throughout the EU be addressed, as this will make it possible to gain influence on the EU political process where energy labelling is concerned. Where possible, the project results should be incorporated into the revision of the EU energy labelling Framework Directive. To this end the project results should be submitted to both the EU Commission and the EU Energy Label Regulatory Committee (ELRC). Conversely, the results and trends of the European revision process were taken into account by the project, both by means of a horizontal assessment within the context of the EU Framework and by a vertical assessment of the EU implementing directives for washing machines and electric tumble dryers. This final report summarizes the project results for the period 1 January to 31 December 2005.

2

Chronological Overview of the Project and its Content

The project partners met six times during the one-year period to develop the content defined in the work programme. The project content was subdivided into the following modules: •

Assessment of the potential to improve efficiency

•

General issues

•

Washing and drying

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At the opening workshop on 8 February 2005, which was held in ZVEI’s offices in Frankfurt/Main, the project partners agreed on the general content of the project and drew up a work plan. The content of the module assessing the potential to improve efficiency was developed during the meeting on 14 March 2005 at the Economics Ministry in Berlin. The next three workshops were held on 29 April 2005 in ZVEI’s offices in Frankfurt/Main and on 13 June and 12 September 2005 at dena in Berlin to define the content of the general issues module as regards “label and fiche design”, “guidelines for the definition of energy efficiency classes” and “updating and upgrading mechanisms/ transitional arrangements”. The sixth meeting was held at dena in Berlin on 24 October 2005 to develop the washing and drying module. dena prepared, chaired, minuted and evaluated each of the meetings. Plans also exist to present the main project results in a workshop for consumer and environmental organizations and to incorporate the results of these discussions into the identification of the key parameters of the German position on the amendment to the energy labelling system.

3

Assessment of the Potential to Increase Energy Efficiency

The aim of the module assessing the potential to improve efficiency was to identify and assess the potential to increase the energy efficiency of particular washing machines and tumble dryers. The examination focussed on economic measures which optimize energy efficiency and the assessment should serve as a basis for the revision of the Directives implementing the labelling of household washing machines and electric tumble dryers. dena’s task at this stage was to calculate the energy efficiency potential specific to the technology and the consumer and to evaluate this for the workshops. dena submitted an assessment of the potential to increase energy efficiency for the appliance categories “washing machine” and “tumble dryer (condensing and air-vented dryer)” at the meeting on 14 March 2005. During this workshop the manufacturers involved suggested that the assessment of potential be based on a forecast of the future share of the market held by appliances with different features relevant to energy consumption. It was agreed that separate assessments would be carried out in three market segments (low, medium and high price) for the washing machine and the tumble dryer. dena then liaised with the project partners to develop separate templates for washing machines, condenser dryers und air vented dryers as an aid to data collection. These were filled in by the manufacturers and ZVEI and returned to dena in June 2005. The result highlights the energy efficiency potential which can be released through technical optimization. The working group is in agreement that if the consumer were to alter his habits, further potential would be unleashed. This potential was not, however, considered further.

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Although desirable in principle, there are practical difficulties associated with the consideration of expected market segment development when assessing potential, as •

There is a high level of uncertainty where certain areas of medium-term market development are concerned.

•

Generally speaking, the market players (ELRC, manufacturers, other stakeholders) hold different views on development.

In addition, and in view of the fact that the EU Commission aspires to update and to upgrade the energy labelling system, it can be assumed that labelling will be adapted to reflect the market more frequently in future than is currently the case. There is therefore little need for market forecasts with only limited reliability. In the course of their discussions the project partners came to the conclusion that assessing potential on the basis of the expected market share of a product is unlikely to be practicable. It was therefore decided to abandon this idea and to base assessments instead on the following procedure: •

The definition of reference technologies for appliance components relevant to energy consumption as a basis for the assessment of energy consumption when using alternative technologies.

•

Identification of an optimized model and assessment of the energy consumption expected when the technologies available for the period under review and the cost of their implementation are taken into account.

The example of the high price segment for washing machines und tumble dryers as currently seen by the manufacturers involved is used to illustrate the results of the assessment of the potential of the examined appliance categories and price segments in Table 1 below. Existing energy efficiency potential was calculated for washing machines on the basis of the threshold value for class A and for tumble dryers on the basis of the mid class C value (i.e. the mean value between the lower thresholds for class B and class C).

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Technical Measures

Energy Efficiency Potential

Achievable Market Share

Additional Cost for the Consumer

100 %

€ 70 – 140

Washing machine / High price market segment 1. Installation of brushless motor for drum 2. Improvement of partload operation through optimized water level measurement

30 – 50 Wh/kg

Condenser dryers without heat pump technology / High price market segment 1. Installation of permanently excited DC motor 2. Optimization of thermal insulation

64 Wh/kg

20 – 70 %

approx. € 90

Condenser dryers with heat pump technology/ High price market segment 1. Installation of heat pump 2. Installation of permanently excited DC motor

314 Wh/kg

70 – 90 %

approx. € 320

70 – 100 %

approx. € 95

Air vented dryers / High price market segment 1. Installation of permanently excited DC motor

70 Wh/kg

2. Optimized process and technical design Table 1: Assessment of energy efficiency potential available in washing machines and tumble dryers in the high price market segment as seen by the manufacturers involved in the project.

A significant change in the marketing strategies of the large electronic retail chains and also in consumer demand for large household appliances has been observed in Germany, particularly since 2002/03. Consumer demand has shifted to a great extent towards the low price segment. At the same time, current market research in Germany shows that the consumer bases his decision on which large household appliance to buy mainly on environmental and consumption aspects (e.g. low energy and water consumption) and the price of the appliance (cf. Innofact’s market research on washing machine buying, “Kaufentscheidung bei Waschmaschinen”, of December 2005). The developments discussed above make forecasting the future market potential of domestic appliances according to low, medium and high price very difficult. The standardized EU energy labelling system for

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domestic appliances has been successfully established as a mechanism which both creates market transparency in respect of the environmental aspects of the appliances and the energy they use and which can also be used effectively by the manufacturers to promote particularly energy-saving appliances. It is suggested that the main emphasis in the revision of the Directives implementing the labelling of household washing machines and electric tumble dryers be placed on the identification of the optimized model for the high price segment together with the aforementioned technologies to ensure the advertising relevance of energy labelling in the future. On this basis suitable data can then be used to assess the theoretic extent to which energy efficiency can be improved in the European domestic appliance market, taking into account the technology-driven and consumer-dependent potential to optimize energy consumption.

4

General Issues Related to the EU Framework Directive on Energy Labelling

The aim of the revision of the EU Framework Directive is to identify the principles to be applied when defining the various implementing directives for the products to be labelled, taking into account features specific to the appliance. In the joint working group suggestions were drawn up as to the future design of the label showing energy consumption and of the information sheet (fiche) for the appliance. Important aspects considered included the information to be included on the label and in the fiche and the layout and design of these documents. The working group’s deliberations were based on the Working Document on the revision of the Energy Labelling Framework Directive 92/75/EEC provided by the EU Commission in early 2004. Comments submitted to the EU Commission by the Economics Ministry and CECED1 were also taken into account. Particular attention was given to the information contained in Table 1 of the Working Document on the type and extent of the details to be included. The aims of energy labelling and the revision thereof are as follows:

1

•

To establish the energy efficiency of a particular appliance as a significant product feature

•

To help the end user to classify an appliance according to energy efficiency

•

To help the end user to decide which appliance to buy

•

To provide details on other important features such as performance

•

To make the EU Energy Label suitable for the manufacturer’s product marketing activities

CECED: European Committee of Domestic Equipment Manufacturers

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If these aims are to be fulfilled, the information included and the layout and design thereof must •

Provide details of energy consumption

•

Provide details of the performance of the particular product

•

Be concise and easy to understand

Where reasonable and possible, the product system should be taken into account in the information on energy consumption. In principle, energy labelling must be accompanied by measures which aim to educate the consumer and influence user habits, as this cannot be achieved by the label alone. Minimum requirements cannot be demanded of product performance under the scope of energy labelling, as these would not result in corresponding barriers to market entry. The standardized EU energy labelling of large household appliances has been introduced successfully both to the end consumer and the retail market. In a survey carried out by dena’s EnergieEffizienz Initiative in the autumn of 2004, for example, 62% of those responsible for buying large household appliances confirmed that they were familiar with the classes of energy efficiency. 96% of the people familiar with the energy rating scheme consider class A to be either “very important” or “more likely to be important”.

4.1

General Aspects to be Considered in the Design of the EU Energy Label

The aim of energy labelling is to create market transparency in respect of the energy used by a particular product by means of an EU Energy Label for the relevant appliances or technical applications2 and to influence the market towards particularly energy-saving products and appliances as a result of that label. Certain aspects should be given particular importance in the design of the label if this objective is to be pursued. These are as follows: •

Consumer interest in the comprehensibility, simplicity and transparency of the label.

•

A depiction of the energy-saving features of the product taking real conditions of use into account.

•

The suitability of the label for the manufacturer’s product marketing activities.

The working group came to the conclusion that the future layout of the energy label should be based on current practice. The label identifies the energy-saving features of the product and takes into account any additional significant features in respect of performance or other environmental aspects (e.g. the consumption of further resources). At the heart of the label is the information on the energy efficiency of the appliance in question.

2

A variety of technical applications relevant to energy consumption (e.g. domestic appliances, lamps, etc.) are currently labelled according to the EU Framework Directive and the corresponding Directives implementing energy labelling. In this report the term “appliance” has been used to denote all of the applications affected by the Framework Directive to simplify linguistic construction.

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This energy efficiency information should be based clearly on previous practice and must include: •

A list of the different classes of energy efficiency using the A - G rating scheme and

•

The classification of the appliance into one of these seven classes of energy efficiency

The number of classes of energy efficiency should be the same for all of the labelled appliance categories to ensure that the consumer is provided with a consistent and comprehensible flow of information. If information on product performance is also provided by category, this should be displayed, like energy efficiency, using the A - G rating scheme. Further information such as •

Energy and if appropriate water consumption (or the consumption of other resources)

•

Capacity (e.g. maximum load for washing machines)

•

Noise levels

should be included as a numerical value on the label. For a wide range of products “time” is also an important factor where energy labelling is concerned. If the cycle or programme on which the information on the energy label is based takes too long, the consumer may decide to choose an alternative, shorter cycle, which uses more energy. Allowance should be made for this in the context of energy labelling by providing information on the class of efficiency and energy consumption which is based on operating modes which reflect realistic user behaviour as closely as possible.

4.2

Layout of the EU Label for Large Household Appliances: Basic Label and Data-Strip

The large household appliances which must be labelled according to the implementing Directives (refrigerators and freezers, washing machines, combined washer-dryers and tumble dryers, dishwashers, electric ovens, air conditioners) are labelled using the basic label and a data-strip. The basic label and the data-strip or the corresponding information is provided to the retailer by the manufacturer. A division of the label into data strip and basic label is economically advantageous and also makes the “linguistic” implementation of energy labelling easier for the manufacturer of appliances destined for sale in several countries, as the data-strip contains no information requiring translation. This system should therefore be retained.

4.3

Energy Labelling for Rebuilt Appliances

It should be noted that several professional suppliers of large household appliances buy up used machines and rebuild them. These appliances are described as “second-hand appliances” in the CECED statement (2004) on the Working Document of the EU Commission. They should, however, be considered new, as

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they have been rebuilt according to the product specifications for that appliance. Such appliances are generally technically outdated and have a relatively high energy consumption, but they do not fall under the current labelling requirements of the EU directive. With “rebuilt appliances” we do not, however, mean those appliances which are offered for sale on the second-hand market without any optical or external refurbishment. The working group agrees that where appliances have been altered technically or in their functionality the information provided under the energy labelling Directives should be re-evaluated. These rebuilt appliances should not, however, be termed “second hand”. “Refurbished appliances” would seem more fitting for this range of products. The manufacturers and CECED are requested to find an exact definition for this type of appliance which clearly separates it from the classical second-hand product which is no longer new, and is provided by the private individual for sale on the second-hand retail market without any technical alteration. The working group further recommends a survey of the share held in the market by classical second-hand appliances within the EU-25 (identification of the number of second hand appliances in relation to the total number of large household appliances in EU households). Depending on the result of this survey, the introduction of a general requirement to identify appliances with the EU Energy Label should be considered.

4.4

Basic Principles for the Identification of the Class of Energy Efficiency

The following parameters can in principle be used to determine the energy rating of an appliance: •

The energy used in a particular operating mode (or the energy used by a portfolio of different operating modes)

•

The relation of the energy used in a particular operating mode (or several operating modes) to the energy consumption benchmark

•

The relation of energy consumption to a product performance benchmark

•

The “typical” energy consumption per unit of time (year)

•

Any combination of the above

It is quite conceivable that unsatisfactory performance would have a negative impact on the class of energy efficiency, as a poor washing performance, for example, could result in a garment being washed several times over. The possibility of considering energy consumption in relation to product-specific features when determining the class of energy efficiency in future was discussed exhaustively by the working group. Where applicable and possible, the definition of energy efficiency – as the basis for determining the

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energy rating – could be provided in the implementing directive for the particular appliance in the form of a formula which expresses this relation. A further conclusion drawn by the working group was that if a category of appliance has a “continuous spectrum” of (several) parameters relevant to energy consumption (such as the volume of the compartments in cold appliances), an energy efficiency index should be used to determine the energy rating. Otherwise the energy consumption of an appliance calculated on the basis of the measurement specifications could be used as a direct means of determining the class of energy efficiency.

4.5

The Use of Several Operating Modes to Calculate the Energy Rating and Energy Consumption

It would be a good idea to allow the possibility of taking several operating modes (a “portfolio”) into account when defining the class of energy efficiency, as this would make it possible to calculate energy consumption under conditions which are as realistic as possible. The optimization of the energy consumption of an appliance on the basis of one single operating mode, generally the mode used to determine the energy rating, is not desirable. The energy rating should in fact provide an incentive to optimize the energy efficiency of a particular appliance under real conditions. If several operating modes are used to determine the class of energy efficiency the following aspects should be taken into account: •

The selection of the operating modes used to determine the class of energy efficiency should be based on user behavior and limited to a few conditions relevant to energy consumption to ensure that the effort involved is acceptable.

•

Only measurable features should be used to determine the class of energy efficiency

•

At the suggestion of the ELRC the features relevant to energy consumption should be determined by the competent standardization bodies.

•

If several operating modes are used to define the class of energy efficiency, it should be remembered that combining the corresponding results can lead to an increase in the number of measurement errors. The application of suitable statistical methods can reduce the effort involved in measuring the appliance.

•

The same portfolio of operating modes should be used to calculate both the energy rating and energy consumption to ensure that the data shown on the Energy Label is consistent.

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4.6

Thresholds for the Classes of Energy Efficiency

The basic parameters for the classes of energy efficiency are as follows: •

The lowest energy consumption conceivable for the future which is feasible under market conditions and is likely to be accepted by the market

•

The highest energy consumption existing on the market

The field between these values is subdivided in such a fashion that •

A class of energy efficiency is (significantly) larger than allowed for by the accuracy of measurement which could be achieved under acceptable conditions

•

The energy rating of two adjacent classes is fundamentally different, i.e. no artificial difference is made between appliances which have practically the same level of energy efficiency.

The market share expected for each of the classes of energy efficiency of a product is not taken into account when defining the energy efficiency thresholds, as practical problems are associated with the corresponding forecasts: •

There is a high level of uncertainty where certain areas of medium-term market development are concerned.

•

Generally speaking, the market players involved (ELRC, manufacturers, other stakeholders) usually hold differing views

•

Energy labelling will be adjusted to reflect market development more quickly in future than was the case in the past thanks to the planned updating process.

There is therefore little need for market forecasts with only limited reliability. If despite this a method of defining the class of energy efficiency is chosen which takes market share predictions into account, a standardized method of preparing these forecasts must be devised. The energy efficiency thresholds should be defined on the basis of •

Market distribution at the time of designation

•

The technologies relevant to energy consumption available at the time of designation which are expected to be cost-effective

The working group was unable to come to a final decision regarding the method of defining classes of energy efficiency during its consultations. The following models were suggested by the project partners: •

The best class of energy efficiency is defined in line with those energy efficiency technologies expected to be cost-effective at the time of designation.

•

Class A efficiency is set at a level which no appliance available on the market is able to achieve when the criteria are defined; this would provide the incentive to optimize appliances.

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It is of fundamental importance that a definition of “cost-effective technologies” be included in the Framework Directive. Considerations of economic efficiency should include the product life (life cycle analysis) and take into account both acquisition and operating costs over a defined period of useful life.

4.7

Product Performance Details

The quality of the service provided by an appliance (product performance, e.g. the wash performance of a a washing machine) is of particular interest to the end consumer. Information on product performance is therefore of primary importance when deciding which appliance to buy. It is relevant at the point of sale and could increase the benefits of energy labelling. The performance indicators included on the EU Energy Label should be chosen on the basis of the following criteria: •

Relevance for the “average” end consumer

•

Relevance for the service provided by the appliance

•

The possibility of measuring, reproducing and classifying performance within reasonable error margins

•

Acceptable amount of effort involved in measurement

•

Significant differences in performance to the other appliances available on the market.

It is possible to show product performance as a numerical value or using the A – G rating scheme. Showing product performance using a rating scheme makes it possible to take the efficiency aspect into account. This can be based on a calculation which puts the benefits and efforts related to the performance of a specific product in relation to one another.

4.8

Further Energy Consumption Information on Label and Fiche

The label should show the energy used by the specific model in kWh. The energy consumption level shown should be the same as that used to determine the energy rating. The value shown can be a measured value or a value which was calculated arithmetically. A value calculated arithmetically is applied where different operating modes (a test cycle portfolio) are used to determine energy consumption and the energy efficiency index so as to reflect user behaviour as closely as possible. The provision on the EU Label of additional energy consumption data such as a set of values for the energy used in a variety of operating modes would not be of advantage, as this would affect the comprehensibility, simplicity and concision of the label. The fiche should show the energy used in the test cycle portfolio which was used to determine the energy rating. A requirement to show qualitative information, such as the implications of special features – would

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not be appropriate. Explanations for the consumer should be included in the product information provided by the manufacturers.

Comprehensive information for the end consumer plays a decisive role in the optimization of energy consumption. Internet-based information, for example, such as other offers from the manufacturers or national campaigns, can help the consumer to reduce the amount of electricity used. Reference to such information could be provided within the scope of the manufacturer’s marketing activities.

4.9

Market Monitoring

The working group considers effective and efficient market monitoring in respect of energy labelling to be a good idea. Market monitoring should include both an inspection of the accuracy of the information provided by the manufactures for the EU Energy Label and the extent to which energy labelling is applied to the appliances sold on the retail market. The requirements of effective and efficient market monitoring should also be taken into account in the revision of the EU Framework Directive. The EU Framework Directive and all corresponding implementing Directives should ensure that the EU Label is designed in such a way as to enable reliable (i.e. measurable, reproducible and statistically relevant) market monitoring which can be carried out at reasonable cost and on the basis of a statistically guaranteed method.

5

Integration of an Updating Mechanism and Suitable Transitional Arrangements for more Dynamic Energy Labelling to Reflect Market Development

The working group discussed the declared objective of establishing in the EU Framework Directive a standardized procedure for the regular assessment of the necessity of updating the product-specific implementing Directives and the three corresponding alternatives set out in Annex 3 / Guidelines on revision of implementing Directives of the EU Commission’s Working Document.

Updating mechanism After an exhaustive discussion the working group agreed on the following position in respect of the introduction of an updating mechanism: •

The updating mechanism should support a standardized assessment of the market relevance of the information on the EU Label for each category of appliance

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•

A period of eight years after the relevant implementing Directive comes into force or after the definition of the thresholds for the classes of energy efficiency (A-G) should be set for the introduction of a regular updating mechanism

•

The procedure to assess market relevance should include an assessment of the market share of the appliance category in each of the energy efficiency classes and the energy savings which can be achieved with technical measures taking into account their cost effectiveness.

•

The energy labelling information (EU Label) should be updated or revised in accordance with the relevant implementing Directive if the market share of those appliances which fulfil the requirements of class A efficiency at the time of the assessment has reached 25% and it can be assumed that any energy savings potential can be released in a cost-effective fashion.

Transitional arrangement Should a revision of the implementing Directive as regards the energy labelling information be necessary, an EU-wide transitional arrangement should be established which provides the manufacturers with a transition period in which to adjust their products to the market. This transitional arrangement should also be clear and easy to understand for all of the market players (manufacturers, retailers, consumers and other affected parties), thus helping to avoid market distortion. A transitional arrangement should be formulated which makes it possible for both the manufacturer and the retailer to use the EU Energy Label for each category of appliance according to the provisions of both the “old implementing Directive” and at the same time the “new implementing Directive” for a period of one year (12 months). The year the underlying directive came into force could be stated clearly on the basic label to make it possible for the consumer (and the retail trade) to differentiate between information on the EU Label according to the old and the new implementing Directive. The suppliers of appliance databases should also allow for an entry which displays the year of the underlying implementing Directive. If a revised implementing Directive is already available for individual categories of appliances the differences between the labels according to old and new directive should be noted in the corresponding databases. The working group also discussed a suggestion that energy labelling should not only incorporate the year of the corresponding implementing Directive but that a differentiation should also be made in the colour of the “old” and the “new” Energy Label, in which case a different background colour would be allocated to the old and the new directive. Several members of the working group were in favour of this additional distinguishing feature, but no final position was established for the working group at this time.

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6

Washing and Drying Module – Revision of the Implementing Directive for Washing Machines

Over the course of several work meetings proposals were drawn up for the revision of the implementing Directive for washing machines (95/12/EC) in the context of both the general issues module and the washing and drying module. The aim of the meetings of the working group was to achieve a differentiated depiction of market supply and an optimized depiction of consumer behaviour resulting from a revision of the EU Directive implementing the energy labelling of washing machines. The working group identified a pressing need for the revision of implementing Directive 95/12/EC taking particular account of the following elements: •

A significant portion of the washing machines available on the European market achieve class A efficiency. The original marketing and incentive effect of class A efficiency is therefore considerably weakened

•

The class of energy efficiency and energy consumption are determined on the basis of the standard 60°C cotton / 100% load test cycle. Energy consumption in a large number of the appliances sold on the market is optimized on the basis of this test cycle by the manufacturer

•

At the same time, the underlying standard 60°C cotton / 100% load cycle does not adequately reflect normal user behaviour

Up-to-date information on average user behaviour in the EU where washing and drying is concerned is currently not available. Existing information would appear to indicate, however, that an extended test cycle portfolio in respect of both the temperature selected and the washing load should be chosen to depict realistic user behaviour. The results of a recent survey3 on washing behaviour commissioned by dena as part of the EnergieEffizienz Initiative in 2005, for example, indicate that most consumers wash at temperatures of 30°C and 60°C. 30°C is used for 4.4 washes per month and 40°C for 4.5 washes. On average, clothes are washed only 4.2 times per month at 60°C. 67% of the German consumers surveyed revealed that they fully load the washing machine, while 21% claimed to fill the washing machine at least three quarters full.

6.1

Principles for Calculating the Energy Rating and Energy Consumption of a Washing Machine

The working group has drawn up a proposal which bases both energy rating and energy consumption on a portfolio of several operating modes. The class of energy efficiency and energy consumption of a

3

Telephone survey of 2,127 persons by the market research institute TNS Emnid in October/November 2005.

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washing machine should be determined on the basis of the 60°C cotton and 40°C cotton wash cycles. There is no need to take measurements for the 30°C cycle, as the amount of energy consumed at this temperature is low and the relative rate of measurement error high. The following proposal was made for a test cycle portfolio – with three temperature and load combinations and seven test runs – which determines the energy rating and the energy consumption shown on the EU Label for washing machines: •

Three test runs at 60°C cotton and 100% load (maximum load) plus

•

Two test runs at 60°C cotton and 40% load plus

•

Two test runs at 40°C cotton and 60% load.

The energy used in this test cycle portfolio should be calculated using a suitable measuring system. The manufacturer is currently testing the type and number of test cycles for practicality, particularly where measurement effort and accuracy is concerned. These tests should provide a technically feasible, costoptimized test cycle portfolio which reflects real conditions as closely as possible. They had not, however, been completed when this final report was drawn up. Energy consumption should be shown as the weighted arithmetic average of the test cycle portfolio values. At present the label shows energy consumption per wash cycle as a numerical value. This can give the impression that machines with a high maximum load are less energy efficient than those with a low maximum load. Energy consumption (numerical value) should therefore be shown on the EU Label for washing machines in large, bold print. The maximum load should also be emphasized using bold print.

6.2

Basic Options for the Design of the Energy Label

The working group sees three basic possibilities for the future design of the EU Label after revision of the implementing Directive for washing machines. • Model 1: The revised EU Energy Label for washing machines has the same structural layout as the former EU Label. The main alteration is the introduction of a test cycle portfolio of a variety of temperature and load combinations (instead of the 60°C cotton cycle currently used) to determine the energy rating and energy consumption. The thresholds for the classes of energy efficiency are redefined. • Model 2: The amount of information on the future EU Energy Label for washing machines is reduced and only shows the consumption of energy (and water if applicable). No information is provided on product performance. A test cycle portfolio is introduced which uses several temperature and load combinations to determine the energy rating. In addition, the thresholds for the classes of energy efficiency are redefined.

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• Model 3: The revised EU Energy Label for washing machines has the same basic structural layout as the former EU Label. A test cycle portfolio is introduced which takes several temperature and load combinations into account. An energy efficiency index which describes the relationship between washing performance and the energy used in the test cycle portfolio is introduced to determine the energy rating. This energy efficiency index is used to redefine the thresholds for the classes of energy efficiency. Energy consumption is shown as the weighted arithmetic average of the newly introduced test cycle portfolio values. Finally, the previous Energy Label for washing machines is revised to include water efficiency and dryer suitability as new indicators of product performance using the familiar A-G classification. The working group’s proposal for the implementation of Model 3 developed during a series of intensive meetings is described in the sections below.

6.3

Principles used to Determine the Classes of Energy Efficiency for Washing Machines

The working group held a thorough discussion on how the classes of energy efficiency should be calculated in future. The central idea was to define the energy efficiency of a washing machine in future as the model-specific “efficiency of the energy used in relation to the washing performance achieved”. A proposal was therefore drawn up to introduce an energy efficiency index describing the relationship between washing performance and the energy used in the test cycle portfolio to determine the energy rating. More detailed tests are required, however, to assess the proposal to define the class of energy efficiency as the model-specific degree of efficiency. Thorough examination is particularly required of the verifiability of the measurements, clarity for the consumer, the optimization of the washing performance to energy consumption ratio and the avoidance of the effects of improper use. The class of energy efficiency (A-G) is determined using the arithmetic weighted average energy consumption calculated using the test cycle portfolio described above. This definition can be shown in strongly simplified form using the following ratio:

Basic principle: Energy efficiency index = washing performance / energy consumption

The manufacturers involved consider the following equation to be a possible approach towards determining the class of energy efficiency as the ratio of washing performance to energy consumption based on the underlying test cycle portfolio:

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E _ eff

wash _ perf − Basis WP _ factor − Basis = e [ kWh kg ] E _ factor [ kWh kg ]

wash _perf

washing performance (calculated on the basis of the current calculation rule)

E_factor:

0.15

WP_factor: Basis:

1 0.5

The factors above (E factor, WP factor, basis) serve to define the various variables.

6.4

Information on Washing Machine Performance

The EU Energy Label valid today shows not only the energy rating, but also washing performance and spin performance based on a seven-part rating scheme ranging from A - G. The working group has drawn up a proposal whereby the main product-specific parameters for the washing machine would also be based on a rating scheme in future. At the same time, a proposal was drawn up for a re-specification of the rated product performance information to be given on the label. Again, the efficiency of the service provided by the washing machine would be the decisive factor when specifying such information. It is suggested that in addition to the energy rating the following information be shown using the A-G scale on the Energy Label for washing machines: •

Water efficiency

•

Dryer suitability

The term “dryer suitability” should initially be used as a working term to describe the dryness of the clothes after spinning. The working group agrees that the comprehensibility of this term should be verified and if necessary another, more suitable term be chosen for the label. Water efficiency should be determined using a calculation rule for the water efficiency index which shows the ratio of water consumption to rinse performance for the same test cycle portfolio as that used to determine energy consumption. Further research is currently required, particularly into the level of accuracy and the reproducibility of the measurement of rinse performance. CENELEC4 is currently working on the enhancement of the measurement specifications. The complete working group is of the opinion, however, that the degree of water efficiency should be shown as a rating on the Energy Label with the option of taking the enhancement of the measurement specifications into account at a later date.

4

CENELEC: European Committee for Electrotechnical Standardization

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Basic principle: water efficiency = water consumption / rinse performance As with the proposal regarding the re-definition of the class of energy efficiency, further analysis of the verifiability of the measurements, clarity for the consumer, and the avoidance of the effects of improper use are required in respect of the introduction of the “water efficiency index” variable. The manufacturers involved consider the following equation to be a possible approach towards determining the water efficiency index as the ratio of water consumption to rinse performance:

WEI

waterfactor − Basis spec _ water − Basis = rins _ index rinsfactor

rinse factor: water factor:

1 1.5

Basis water: rinse index:

0.5 average of alkalinity and zeolite (based on: the measured alkalinity index and zeolite index)

The factors above (rinse factor, water factor, basis water, rinse index) serve to define the various variables. “Dryer suitability” is equivalent to what has been termed spin performance to date. The reason for the altered terminology is to stress the fact that better spin efficiency results in low residual moisture, thereby reducing the time and effort needed to dry the clothes. Dryer suitability should also be calculated on the basis of the test cycle portfolio used to determine the energy rating and water efficiency.

6.5

Further Washing Machine Features Relevant to Energy Consumption

The working group discussed which other features possibly relevant to energy consumption should be taken into account either in the context of the definition of the energy rating (or of energy consumption) or as an independent numerical value on the Energy Label.

Load control One of the features which could be taken into account when determining the energy rating of a washing machine is load control. This feature was considered in more depth and resulted in the opinion that it is not a good idea to take load control systems into account which provide the user with an optical or acoustic indication of the load, as the influence of this on energy consumption cannot be measured. If load control is available the consumer should be informed of this in the product information provided by the manufacturer.

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Influence of the spin speed on energy consumption Low residual moisture in the clothes can be achieved with high spin speeds (generally above 1,100 rpm). This increases the energy used during the spin cycle, but at the same time reduces the energy required to dry the clothes, resulting in a lower overall energy requirement for washing and drying. High-speed spinning requires between 5% (at 60°C) and 10% (at 40°C) more energy than lower spin speeds, but this can be factored into the total energy consumption using a correction factor. The manufacturers taking part in the project have suggested the following formula to determine a correction factor for the “spin energy”:

Ecorrected = Emeasured – (0.6 – (residual moisture [%] / 100%)) × m [kg] × 0.03 [kWh/kg] The residual moisture (or “dryer suitability”) should be calculated on the basis of the test cycle portfolio. The working group was also in agreement that the amount of energy required to dry the clothes (“energy for drying”) should not be stated on the Energy Label.

Wash time The working group held an in-depth discussion of whether information should be provided as to the arithmetic weighted average wash time if the energy rating and energy consumption are provided on the basis of a portfolio of several operating modes (test programme portfolio), but was unable to come to a mutual understanding.

6.6

Proposal for the Terminology used on the Energy Label for Washing Machines and the Order in which the Information is Displayed

In addition to information on energy efficiency, water efficiency and dryer suitability using the seven-part rating scheme, the following information should be displayed on the EU Label for washing machines: •

Energy consumption [kWh]

•

Water consumption [ l ]

•

Maximum load [kg]

At the same time, the EU Energy Label should also provide information in line with current practice on noise emissions [dB(A)] according to the national regulations. The working group was unable to reach a consensus regarding suitable physical variables (numerical values) to identify the spin performance of a washing machine. Several members of the working group are in favour of continuing to include the spin speed. In contrast, other members are in favour of showing changes to torque (centripetal acceleration) as a numerical value on the Energy Label so that washing

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machines with a high capacity whose spin speed is lower, but whose spin performance is constant because the drum has a larger diameter do not suffer a marketing disadvantage. Energy consumption should therefore be emphasized on the label by means of large, bold print. Information on the maximum load should also be shown in bold print as this load (e.g. 5 kg or 7 kg) has an influence on the level of energy and water consumption. Emphasizing this information on the EU Label would serve to make this relationship clear to the consumer. As a result of its discussions, the working group suggests the following terminology in the sequence shown for the layout of the EU label for washing machines:

Energy

Washing Machine

Manufacturer Model More efficient A ….. G Less efficient Water efficiency Dryer suitability (or alternative term) Maximum load

bold

Energy consumption

bold, large type

Water consumption Noise Illustration 1: Proposal for the terminology used on the Energy Label for washing machines and the order in which it is displayed.

The design of the label common today, and particularly the illustration of the energy rating using arrows of different colour and size, should remain unchanged.

6.7

Proposal for the Washing Machine Fiche

Implementing Directive 95/12/EC states that the following information must be shown in the washing machine fiche:

The fiche shall contain the following information. The information may be given in the form of a table covering a number of models supplied by the same supplier, in which case it shall be given in the order specified, or given close to the description of the appliance:

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1.

Supplier's trade mark.

2.

Supplier’s model identifier

3.

The energy efficiency class of the model as defined in Annex IV. Expressed as ‘Energy efficiency class . . . on a scale of A (most efficient) to G (least efficient).’ Where this information is provided in a table, this may be expressed by other means provided it is clear that the scale is from A (most efficient) to G (least efficient).

4.

Where the information is provided in a table, and where some of the appliances listed in the table have been granted an 'EU eco-label' pursuant to Regulation (EEC) No 880/92, this information may be included here. In this case the row heading shall state ‘EU eco-label’, and the entry shall consist of a copy of the eco-label mark. This provision is without prejudice to any requirements under the Community eco-label mark scheme.

5.

Energy consumption in kWh per cycle using standard 60 °C cotton cycle in accordance with the test procedures referred to in Article 1 (2), described as ‘energy consumption XYZ kWh per cycle, based on standard test results for 60 °C cotton cycle’. Actual energy consumption will depend on how the appliance is used.’

6.

Washing performance class as determined by Annex IV. Expressed as ‘Washing performance class . . . on a scale of A (higher) to G (lower)’. This may be expressed by other means provided it is clear that the scale is from A (higher) to G (lower).

7.

Spin drying efficiency class (Annex IV). Expressed as: 'Spin drying performance . . . on a scale of A (higher) to G (lower)'. Followed by the statement: ‘NB if you use a tumble drier. Choosing a washing machine with A-rated spin, instead of one with a G-rated spin will halve your tumble drying costs. Tumble drying clothes usually uses more energy than washing them.’ This statement may also be included as a footnote. Where this information is provided in a table, this may be expressed by other means provided it is clear that the scale is from A (most efficient) to G (least efficient), and that the statement concerning running costs is included in the table, or in a footnote.

8.

Water extraction efficiency in accordance with the test procedures of the harmonized standards referred to in Article 1 (2) for a standard 60 °C cotton cycle. Expressed as ‘Water remaining after spin . . . % (as a proportion of dry weight of wash)’.

9.

Maximum spin speed attained for standard 60 °C cotton cycle in accordance with the test procedures of the harmonized standards referred to in Article 1 (2).

10. Capacity of appliance for standard 60 °C cotton cycle in accordance with the test procedures of the harmonized standards referred to in Article 1 (2). 11. Water consumption per cycle using standard 60 °C cotton cycle in accordance with the test procedures of the harmonized standards referred to in Article 1 (2). 12. Programme time for standard 60 °C cotton cycle in accordance with the test procedures referred to in Article 1 (2). 13. Suppliers may include the information in points 6 to 12, in respect of other wash cycles. 14. The average annual consumption of energy and water based on 200 standard 60 °C cotton cycles. This shall be expressed as ‘estimated annual consumption (200 standard 60 °C cotton washes) for a four-person household’. 15. Noise during washing and spinning cycles using standard 60 °C cycle, in accordance with Directive (EEC) No 86/594. If a copy of the label, either in colour or black and white, is included in the fiche, then only the further information included in the fiche need be included.

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It transpired from the discussions of the working group regarding the washing and drying module that the information currently required for the fiche needs to be adapted under the revision of the implementing Directive for washing machines to reflect the new information on the Energy Label and the revised test cycles and test procedures. The following alterations would be required: • A test cycle portfolio for three temperature and load combinations should be used to replicate the wash cycles used in a normal household for the information required by the energy labelling directive. The proposed test cycle portfolio is as follows: 60°C + 100%; 60°C + 40%; 40°C + 60%, with the number of test cycles still to be determined (proposal: seven test cycles weighted as follows: 3×(60°C + 100%); 2×(60°C + 40%); 2×(40°C + 60%). This would require that o

Energy consumption (point 5)

o

Water consumption (point 11)

o

Wash time (point 12) and

o

Noise in accordance with the regulations of the EU Member State (point 15)

are shown in the fiche as the arithmetic weighted average of the new test cycle portfolio. • Water extraction efficiency (point 8) should be replaced by dryer suitability (A-G) and also be shown as the arithmetic weighted average of the new test cycle portfolio. • Maximum spin speed should be shown as a numerical value (point 9). • Capacity (point 10) should be replaced by the term “maximum load”. Note: Consumer understanding of the term “maximum load” also requires analysis. • The annual consumption of energy and water (point 14) should not be based on the number of wash cycles, but on an annual weight of 1,000 kg (for the underlying temperature and load combinations, which should be determined in line with the test cycles). • Electrical power consumption in standby mode should be calculated on the basis of the new standard EN 62301. Future regulations in respect of the EU Eco-Design Directive should be taken into account. The manufacturers involved are of the opinion that only standby power of over 1 Watt should be stated. No differentiation would thus be required of standby power under this level. dena does not share this opinion, but would like to see as exact details as possible (within specific measuring tolerances) of electrical power consumption in standby mode included in the fiche. dena is also of the opinion that the annual power consumed by standby mode (in kWh/a) in a representative operating cycle5 for a four-person household should also be included in the fiche.

5

The same assumptions should be applied to this representative annual operating cycle as are used to determine annual energy and water consumption.

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In addition to the above, the washing machine fiche should also include the following information, which is based on the details listed in Annex I of the Working Document of the EU Commission for inclusion by the supplier in the fiche: • Point 16, new: Reference to the underlying standards and the implementing Directive, including the year in which the EU Directive came into force.

7

Washing and Drying Module – Revision of the Implementing Directive for Tumble Dryers

Over the course of several work meetings proposals were drawn up for the revision of the implementing Directive for household electric tumble dryers (95/13/EC) in the context of both the general issues module and the washing and drying module. The working group also considers there to be a need for a basic revision of energy labelling where the tumble dryer is concerned. The aim of the meetings of the working group was to achieve a differentiated depiction of market supply and an optimized depiction of consumer behaviour resulting from a revision of the EU Directive implementing the energy labelling of tumble dryers.

7.1

Principles for Calculating the Energy Rating and Energy Consumption of a Tumble Dryer

The revision of the implementing Directive should make the class of energy efficiency and energy consumption of a tumble dryer dependent upon several operating modes which reflect user behaviour as closely as possible. It is suggested that three cycle and load combinations be used to determine both energy rating and energy consumption. At the end of 2005 CENELEC formed working groups to draw up a suitable test cycle portfolio for these three cycle / load combinations. These will be available at the end of 2006 at the earliest. For this reason, only the scenarios • cupboard dry cotton / full load • cupboard dry cotton / partial load • iron dry cotton / partial load can currently be named as a basis for energy consumption information. No statement can yet be made on the loads to be chosen or the number of test runs to be considered. After selection and further definition of the operating modes listed above, specific energy consumption should be shown as the arithmetic weighted average of the corresponding test cycle portfolio values to determine the energy rating. Similarly, energy consumption should be shown on the Energy Label as an

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arithmetic weighted average of the energy used by the test cycle portfolio. As with the washing machine, more detailed tests are also required to assess the proposal to define the class of energy efficiency in a tumble dryer as the product-specific degree of efficiency. Thorough examination is particularly required of the verifiability of the measurements, clarity for the consumer and the avoidance of the effects of improper use. In view of the current work of the working groups within the standardization body, no statement can be made regarding the thresholds used to determine the class of energy efficiency. A reclassification of the classes of energy efficiency or a redefinition of the thresholds can be expected, however.

7.2

Basic Options for the Design of the Energy Label

The working group sees three basic possibilities for the future design of the EU Label after revision of the implementing Directive for tumble dryers. • Model 1: The revised EU Energy Label for tumble dryers has the same structural layout as the former EU Label. The main modification is the introduction of a test cycle portfolio composed of a variety of cycle and load combinations to determine the energy rating and the level of energy consumption. The thresholds for the classes of energy efficiency are redefined on the basis of this test cycle portfolio. • Model 2: The amount of information on the future EU Energy Label for tumble dryers is reduced and only shows energy and water consumption. No information is provided on product performance. A test cycle portfolio comprising several cycle and load combinations is introduced to determine the class of energy efficiency. • Model 3: The revised EU Energy Label for tumble dryers has the same structural layout as the former EU Label. A test cycle portfolio is introduced which uses a variety of temperature and load combinations to determine the energy rating and energy consumption. The thresholds for the classes of energy efficiency are redefined on the basis of the underlying test cycle portfolio. Energy consumption is shown as the weighted arithmetic average of the newly introduced test cycle portfolio values. Finally, the previous Energy Label for tumble dryers is revised to include condensing efficiency and ventilation efficiency as new indicators of product performance using the familiar A-G classification. The working group’s proposal for the implementation of Model 3 developed during a series of intensive meetings is described in the sections below.

7.3

Information on Product Performance and Other Features

The EU Label for tumble dryers should include not only the energy rating and energy consumption, but also further information on product performance and other features.

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The A-G rating scheme should be used to show the condensing efficiency of a condenser dryer or the ventilation efficiency of an air vented dryer. In addition, both the maximum load and noise emissions according to the applicable regulations of the EU Member State should be shown on the EU Label as a numerical value. A discussion of the features which could be applied to determine the energy rating of a tumble dryer established that measuring the load in a similar fashion to that used for washing machines is not a satisfactory solution. As with the washing machine, if load measurement is available the consumer should be informed of this in the product information provided by the manufacturer.

Information on drying time The working group was unable to reach a consensus as to whether information regarding the arithmetic weighted average drying time based on the programmes used in the test cycle portfolio should be included in the Energy Label.

Influence of the tumble dryer on other energy requirements The implications of an air vented dryer for the heat required in the immediate vicinity of the appliance should also be included in the information package which comes with the dryer, and where appropriate also in the fiche. As far as heat exchange is concerned, the heat given out by a condenser dryer to its immediate vicinity should not be considered an additional benefit, as the overall energy treatment is complex.

7.4

Proposal for the Terminology used on the Energy Label for Tumble Dryers and the Order in which the Information is Displayed

In addition to the information on energy rating and condensing efficiency, the following information should be displayed as a numerical value on the EU Label: • Energy consumption [kWh] • Maximum load [kg] At the same time, the EU Energy Label should also provide information in line with current practice on noise emissions [dB(A)] according to the national regulations. Energy consumption should be highlighted on the label by means of large, bold print. The maximum load should also be shown in bold print. As a result of its discussions, the working group suggests the following terminology in the sequence shown for the layout of the EU label for tumble dryers:

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Energy

Tumble Dryer

Manufacturer Model More efficient A … G Less efficient Condensing efficiency Ventilation efficiency Maximum load

bold

Energy consumption

bold, large type

Noise Illustration 2: Proposal for the terminology used on the Energy Label for tumble dryers and the order in which it is displayed

The design of the label common today, and particularly the illustration of the energy rating using arrows of different colour and size, should remain unchanged.

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7.5

Proposal for the Tumble Dryer Fiche

Implementing Directive 95/13/EC states that the following information must be shown in the tumble dryer fiche:

The fiche shall contain the following information. The information may be given in the form of a table covering a number of appliances supplied by the same supplier, in which case it shall be given in the order specified, or given close to the description of the appliance. 1.

Supplier's trade mark.

2.

Supplier’s model identifier

3.

The energy efficiency class of the model as defined in Annex IV. Expressed as ‘Energy efficiency class . . . on a scale of A (more efficient) to G (less efficient).’ Where the information is provided in a table, this may be expressed by other means provided it is clear that the scale is from A (more efficient) to G (less efficient).

4.

Where the information is provided in a table, and where some of the appliances listed in the table have been granted an ‘EU eco-label’ pursuant to Regulation (EEC) No 880/92, this information may be included here. In this case the row heading shall state ‘EU ecolabel’, and the entry shall consist of a copy of the eco-label mark. This provision is without prejudice to any requirements under the Community eco-label mark scheme.

5.

Energy consumption (Annex 1 note V).

6.

Rated capacity of cotton (Annex I note VI).

7.

Water consumption in accordance with test procedures of the harmonized standards referred to in Article 1 (2), for ‘dry cotton’ programme cycle, if applicable.

8.

Drying time in accordance with test procedures of the harmonized standards referred to in Article 1 (2) for ‘dry cotton’ cycle.

9.

The same information as given above, under notes 5, 6, 7 and 8, but in respect of the ‘iron dry cotton’ and ‘easy care textiles’ programmes. These lines may be omitted if there is no such cycle on the machines in question.

10. Suppliers may include the information in points 5 to 8 in respect of other drying cycles. 11. The average annual consumption of energy (and water if applicable) based on the drying of 150 kg using ‘dry cotton’, plus 280 kg using ‘iron-dry’ cotton, plus 150 kg using ‘easy care’ textile programmes. This shall be expressed as ‘estimated annual consumption for a four person household normally using a drier’. 12. The type of appliance, air vented or condensing, in accordance with test procedures of the harmonized standards referred to in Article 1 (2), (Annex I note VII). 13. Where applicable, ‘noise’ in accordance with Directive 86/594/EEC. If a copy of the label, either in colour or black and white, is included in the fiche, only the further information included in the fiche needs to be included.

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It transpired from the discussions of the working group regarding the washing and drying module that the information currently required for the fiche needs to be adapted under the revision of the implementing Directive for tumble dryers to reflect the new information on the Energy Label and the revised test cycles and test procedures. The following alterations would be required: • A test cycle portfolio of a combination of cycles and loads should be used to replicate the drying programmes used in a normal household for the information required by the energy labelling directive. This would require that o

Energy consumption (point 5)

o

Water consumption (point 7) if applicable

o

The still open question of the drying time (point 8) and

o

Noise in accordance with the regulations of the EU Member State (point 13)

are shown as the arithmetic weighted average of the new test cycle portfolio. • Capacity (point 6) should be replaced by the term “maximum load”. Note: Consumer understanding of the term “maximum load” also requires analysis. • The annual consumption of energy and (if applicable) water (point 11) should be based on the test cycle portfolio selected and an annual total drying weight of 750 kg. • Following standard EN 61121, airflow should be included for the air vented dryer to make apparent the amount of air extracted from the room. • Electrical power consumption in standby mode should be calculated on the basis of the new standard EN 62301. Future regulations in respect of the EU eco-design directive should be taken into account. The manufacturers involved are of the opinion that only standby power of over 1 Watt should be stated. No differentiation would thus be required of standby power under this level. dena does not share this opinion, but would like to see as exact details as possible (within specific measuring tolerances) of electrical power consumption in standby mode included in the fiche. dena is also of the opinion that the annual power consumed by standby mode (kWh/a) in a representative operating cycle6 for a four-person household should also be included in the fiche. In addition to the above, the tumble dryer fiche should also include the following information, which is based on the details listed in Annex I of the Working Document of the EU Commission for inclusion by the supplier in the fiche: • Point 14, new: Reference to the underlying standards and the implementing Directive, including the year in which the EU Directive came into force.

6

The same assumptions should be applied to this representative annual operating cycle as are used to determine annual energy and water consumption.

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8

Outlook

Over the course of the twelve months of consultations the working group produced some fundamental proposals both in respect of the planned revision of the EU Framework Directive 92/75/EEC and of the applicable implementing Directives 95/12/EC (washing machines) and 95/13/EC (tumble dryers). In the next phase, the main results of these consultations will be presented to representatives of consumer and environmental organizations and discussed with these. The following conclusions of the working group will be focussed on in these discussions: • The revision of the Framework Directive and the two implementing Directives in such a way that there is “little change to the existing label” and the conditions are “optimized to reflect consumer (user) behaviour.” • The revision of the implementing Directives for washing machines and tumble dryers from the angle of “improved integration of product-specific (energy) efficiency in relation to product performance” and a redefinition of the thresholds for the classes of energy efficiency taking existing technical and economic energy savings potential into account. • The transparency, simplicity and comprehensibility of the information on the EU Label. • The calculation of the energy rating and energy consumption for the EU Label on the basis of operating modes which reflect real user behaviour as closely as possible. • The possibility of basing the energy rating and energy consumption on several operating modes where possible and reasonable. • A presentation of the proposals developed for the terminology used on the standardized EU Energy Labels for washing machines and tumble dryers and the order in which the information is displayed. • A discussion of how to ensure an effective and efficient market monitoring of energy labelling which includes an inspection of both the accuracy of the information provided by the manufactures for the EU Energy Label and the extent to which energy labelling is applied to the appliances sold in the retail market and via other distribution channels. The Economics Ministry intends taking the results of these dialogues with consumer and environmental organizations into account when identifying the key parameters on which the German delegation in the ELRC will base its position as regards the revision of the Directive. The parties involved in the project are in favour of continuing work on the revision of the Framework Directive without delay and would also like to see a revision of the Directives implementing the labelling of household washing machines and electric tumble dryers. The result could be the creation of a successful win-win strategy which, thanks to a revision of EU energy labelling in line with market developments and consumer interests, both supports the manufacturers’ marketing strategies in respect of particularly energy-efficient domestic appliances and at the same time helps to release further energy efficiency potential in private households.

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