Page 11 - European Energy Innovation - Spring 2016 publication

Spring 2016 European Energy Innovation
the most easily understood and it
seems that there will be an agreement
to (eventually) revert back to it - this The emphasis on Lowest Life Cycle
improved clarity will almost certainly
improve consumer understanding and
purchasing behaviour.
However, perhaps the most important
aspect of the rescaling should be
ensuring that the top energy classes
are not reached too early. They must
remain empty as an incentive for
manufacturers to develop new and
innovative products. This is why it is
important to develop a system where
we consider the future evolution of
a product category over the longer-
term development cycle. In simple
terms this would mean introducing a
label today where, say, no products
are in the top one or two categories
(A or A and B) and are unlikely to be
populated by more than 25% - 35% of
the products available on the market
within the next 10 years. Achieving an
A therefore offers a clear incentive to
develop a product and invest in the
innovation process.
Beyond the label we also need to
look at what more can be done within
the legislation to improve the market
for energy using products as well as
boost the innovation potential of the
product categories. Therefore we need
to identify and optimise the regulation
- which will include focussing on
ambition; the participation of industry
in the process; and improving market
surveillance. Finally we will also need
to provide the long term stability
and predictability of the regulatory
process, which given the number of
revisions to this legislation to-date,
www.europeanenergyinnovation.eu
11
ENERGY LABELLING
needs to be achieved this time.
Cost (LLCC) also needs to be
reconsidered, though we may perceive
this direction to be the best course
of action today, it may preclude
channels that offer better life cycle
costs in the long run. Instead, allowing as ensure that a business only has
more focus on equivalent costs and
potential learning curves would not
only offer more flexibility but it can
also extend possibilities for greater
technological advancement over time.
The legislation must remain cognisant
of the extent to which innovation is
possible within a product category.
If the technologically reasonable
limits of energy efficiency innovation
has been reached, then categories
shouldn't necessarily be marked
down - at the very least other factors
such as resource efficiency should be
considered.
An issue that has been raised is a
number of products that do not
comply with eco design requirements
are still in circulation. The lack of
market surveillance has stymied
the motivation of manufacturers to
innovate. The effect of this is that
manufacturers lose confidence in
the system and therefore the energy
efficiency gains (and costs savings for
consumers) do not materialise in the
volume that they should. This requires
not only greater efforts by the market
surveillance authorities in the EU's
28 Member States but also requires
improvements to the legal terms for
following up on non-compliance as
well as specific clauses related to
defeat devices.
To improve surveillance the draft
legislation on labelling proposes the
creation of a pan-European database
for products that are sold with an EU
energy label. The premise behind
this idea is that it will assist market
surveillance authorities to access
the information they need, as well
to provide the information once to
the database rather than responding
to numerous requests. However,
this proposal has triggered intense
political debate. Selected parties on
the left want to turn it into a do-it-all
database of sales data; resource use;
and anything else they can think of.
This has benefits; the creation of this
dataset could enable data mining so
that consumers searching for products
can do so not only on purchase price,
but also on energy consumption or
even costs over time. However, the
other side of the argument is that the
idea of having such a vast amount of
sensitive commercial material held on
servers at the European Commission
or with market surveillance authorities
is a step too far. Further, it would be
remiss of the group not to explore
the cost implications of creating such
a database, both in monetary terms
and time. It is without question that
market surveillance has to improve,
or else there will not be an incentive
for manufacturers to provide the
innovation required to achieve the
high energy efficiency ratings. Though
a product database provides a solution
to this and certainly makes the job of
surveillance authorities easier; we must
carefully consider all possible options
and guarantee that commercially
sensitive data is never put at risk. l