INCEPTION IMPACT ASSESSMENT

Title of the initiative

Ecodesign and energy labelling requirements for household refrigerators 

Lead DG (responsible unit)

ENER, C.3

Likely Type of initiative

Commission implementing regulation (ecodesign)

Commission delegated regulation (energy labelling)

Indicative Planning

Completion of the Impact Assessment in the second quarter of 2018

Additional Information

http://ec.europa.eu/energy/en/topics/energy-efficiency/energy-efficient-products

The Inception Impact Assessment is provided for information purposes only. It does not prejudge the final decision of the Commission on whether this initiative will be pursued or on its final content. All elements of the initiative described by the Inception impact assessment, including its timing, are subject to change.

A. Context, Problem definition and Subsidiarity Check

Context

Increasing energy efficiency is an important objective of EU policy (for more information, see https://ec.europa.eu/energy/en/topics/energy-efficiency). A crucial policy instrument for achieving the 2020 and 2030 EU climate and energy targets is the setting of minimum efficiency requirements for products – through ecodesign, in combination with informing customers about their energy performance – through energy labelling. See http://ec.europa.eu/energy/en/topics/energy-efficiency/energy-efficient-products.

Ecodesign and Energy Labelling legislations are recognised as key contributors in product policy supporting the Energy Union objectives and the transition to a Circular Economy.

Since the coming into force of the first ecodesign directive in 2005 and the first energy labelling directive in 1992, a variety of energy-related product groups such as washing machines, dishwashers, electric motors, vacuum cleaners, etc. have been covered by ecodesign and energy labelling regulations. One of these product groups is household refrigerating appliances, i.e. electric mains-operated household refrigerating appliances with a storage volume up to 1 500 litres.

Each ecodesign regulation and energy labelling regulation contains provisions for its future evaluation and possible revision, taking into account the experience gained with their implementation and technological progress. The ecodesign and energy labelling regulations on household refrigerating appliances were to be reviewed by August 2014 and December 2015 respectively. The reviews are also listed in the Ecodesign Working Plan 2016-2019 among the reviews to be carried during that period.

Therefore, a preliminary omnibus review study was carried out in 2014 looking at several existing product groups followed by a dedicated review study in 2015 – 2016. This dedicated study evaluated a possible revision of the Ecodesign measure for household refrigerating appliances, including the possibility to set requirements for material resources reduction and life-time extension. The review study also identified opportunities where refrigeration appliances can make a valuable contribution to fighting food waste. A spin-off study was carried out in 2016-2017 to investigate more in detail scope for reducing food waste through refrigerator design or instructions to the user. 

The impact assessment started in June 2017 and a consultation forum is scheduled for 6 December 2017.

Problem the initiative aims to tackle

The total energy consumption of the installed stock of household refrigerating appliances decreased from 122 TWh/year in 2005 to 86 TWh/year in 2015; this consumption is estimated to drop further in a BAU scenario to 57 TWh/year in 2030. The measures proposed in the impact assessment can deliver up to 10 additional TWh/year net savings in 2030.

Over the last years the global refrigeration industry has been working to create a global standard for household refrigerating appliances. It aims not only to be universally applicable, but also to improve the efficiency (faster, lower costs), accuracy (more sophisticated defrost testing) and reliability (fighting loopholes, precise indications of relevant testing) of refrigerating appliance testing. Using this standard, adapted to the EU situation, in Ecodesign and Energy Labelling is thus crucial for global competitiveness but also for better market surveillance and lowering the administrative burden for industry.

The metrics used in the existing Ecodesign and Energy Labelling regulations for household refrigerating appliances were developed 25 years ago. Since then there has been considerable technological progress, which is no longer reflected in today’s metrics for efficiency levels that are >60% lower than 25 years ago. Furthermore, the appliance-based approach is complex in the legislation and unnecessarily rigid.

The current regulation includes correction factors for climate-class (1.1 for sub-tropical ST and 1.2 for tropical T), no frost (1.2), built-in appliances (1.2) and the bonus for the chill compartment (50 kWh at EEI=100). Some of these factors are used as (legal) loopholes and are obscuring the real electricity consumption and efficiency for the end-consumer.

Preliminary findings show that there are considerable benefits in proposing a revision of the current regulation, both in terms of optimising regulatory aspects as in realising additional energy-, CO2 emission- and monetary savings. As such, a revised regulation would be more effective by supporting global test standards, addressing the outdated metrics and updating the correction factors. The proposed review would also improve the efficiency of the legislation: verifiable exemptions and allowances are needed, and clear and more ambitious efficiency targets are possible.

Household refrigerating appliances are one of the priority product groups identified in the new Energy Labelling Framework Regulation that entered into force on 1 August 2017 and which requires the adoption of a revised delegated regulation introducing rescaled labels with an A to G scale by November 2018.

In addition, the Commission has flagged in the Ecodesign Working plan 2016-2019 that the Ecodesign implementing measures should cover resource efficiency aspects where appropriate, to ensure greater durability, accessibility, design for disassembly and reparability of products entering the market and therefore contribute to the transition towards a more circular economy.

With regards to resource efficiency, only a limited number of useful ecodesign criteria were identified in the study. The first one is to ensure the availability of a spare part that would prevent energy efficiency losses of household refrigerating appliances and the second one is to allow the use of more energy consuming refrigerators when they are optimised for food storage to prevent food waste.

Basis for EU intervention (legal basis and subsidiarity check)  

The Energy Labelling Regulation is based on Article 194(2) of the Treaty on the Functioning of the European Union, which provides a legal base for measures to promote energy efficiency. The Ecodesign Directive is based on Article 114 of the Treaty on the Functioning of the European Union, the legal base for measures for the functioning of the internal market. Through these Directive and Regulation, the European Parliament and the Council have given a legislative mandate to the Commission to regulate the environmental performance of energy-related products and in particular their energy efficiency. To ensure the free circulation of goods, it is appropriate to set EU-level rules on the energy labelling and ecodesign of energy-related products. If the EU did not intervene, Member States would set their own rules, which would be necessarily different, due to the complexity of the technical aspects, thereby disrupting the functioning of the internal market. This was the case prior to the establishment of the first ecodesign and energy labelling regulations at EU level.

B. Objectives and Policy options

The objective of the measure is, in the context of ensuring free circulation of goods in the internal market, to contribute to energy efficiency, CO2 emission abatement and security of energy supply as well as realising a high level of environmental and consumer protection. More specifically, the impact assessment on household refrigerating looks at solutions to:

Take into account technological progress and the globalised test standard

Induce new energy and financial savings in household refrigerating appliances

Remove the least energy-efficient household refrigerating appliances from the market

Make sure that household refrigerating appliances designed for specific applications requiring particular physical characteristics are subject to requirements that are justified and effective

Facilitate market surveillance

Support the competitiveness of the household refrigeration industry through the expansion of the EU internal market for sustainable products.

Introduce the rescaled energy label with an A to G scale

The impact assessment considers the following main options:

1.No EU action (‘BAU’, Business-as-Usual); except for a rescaling of the energy label

2.Self-regulation;

3.Energy Labelling only;

4.Update of the current Ecodesign regulation and Energy Labelling

Option 1 assumes that current policy measures will not change, except for the rescaling of the energy label from an A to G scale. This implies that technological enhancements will not be reflected, some loopholes will persist and that financial and energy savings opportunities for end users will be missed. Option 2 was not proposed by industry for fear of ‘free riders’. Option 3 does not exploit the full saving potential.

Option 4 is the preferred option. It provides for more stringent minimum efficiency requirements, includes products not previously covered and improves the efficiency and effectiveness of the regulation.

C. Preliminary Assessment of Expected Impacts

The impacts listed below are those deriving from the preferred option as described above.

Likely economic impacts

Most affected stakeholders are the household refrigeration industry and the end consumers of household refrigerating appliances. The increase in energy efficiency requires manufacturers to invest in product design and make more production costs. Those costs will subsequently be recuperated through higher sales prices. This will generate around €1.8 billion per year extra business (all sectors) revenue compared to a BAU scenario.

It is expected that the regulation will lead to a better international competitiveness and that the savings on energy bills will outweigh the price increase of the household refrigerating appliances, leading to overall reduced costs for end-users in comparison to a BAU scenario.

Likely social impacts

It is expected that the regulation will create or retain 36.000 direct jobs equally divided between trade and manufacturing industry in 2030.

Consumers will benefit from the regulation through lower energy bills; in 2030, consumers will save around 3.5 billion per year in comparison to the BAU scenario.

In addition, consumers who purchase optimised food storage appliances (with multiple compartments), will benefit from the regulation through reduced food waste and hence cost. Although these appliances consume around 20% more energy, in terms of mass and energy equivalent, it would be enough to save 2% (i.e. 9% instead of 11% avoidable waste) on end-use food waste to compensate for this.

Likely environmental impacts

Electricity consumption in the use-phase is the main environmental impact of household refrigerating appliances. The regulation is expected to deliver up to an additional 10 TWh of net electricity savings by 2030, representing the electricity consumption of 3.75 million homes (appliances and lighting), or 12% of the total energy consumption of household refrigerating appliances in stock in 2015. This translates into 3.5 million tons of CO2eq savings.

Likely impacts on fundamental rights

No impact expected.

Likely impacts on simplification and/or administrative burden

Overall, the administrative burden is considered negligible with respect to the expected benefits. The regulation is directly applicable in all Member States, resulting in no costs for national administrations for transposition into national legislation. The updated regulation is expected to simplify/clarify the work of national market surveillance authorities. Disproportionate burdens for manufacturers are avoided, amongst others due to transitional periods which duly take into account redesign cycles.

D. Evidence Base, Data collection and Better Regulation Instruments

Impact assessment

An impact assessment is being prepared to support the preparation of this initiative and to inform the Commission's decision.

Evidence base and data collection

Different data sources exist. Several market research entities or industry associations have set up a comprehensive market data collection for this sector. At EU level, Eurostat data are available. In addition, some associations have also set up dedicated databases for this product group.

Consultation of citizens and stakeholders

There has already been extensive consultation of stakeholders and experts, in particular during the preparatory review study, which was carried out between January 2015 and March 2016. It included the establishment of a dedicated website (www.ecodesign-fridges.eu) where all relevant documents can be found, a stakeholder survey, two stakeholder meetings, and a final report published in March 2016. It resulted in nearly 35 stakeholder position papers and expert comments. Over 30 stakeholders participated to the consultation, including Member States, environmental NGOs, market surveillance authorities, European standardisation organisations, individual manufacturers and one industry association.

The Commission gained further stakeholder inputs through the Consultation Forum held in December 2017. This will be followed by the impact assessment study during which additional technical information and expertise will be collected and analysed. In addition, an open public consultation on this topic will be conducted. For this purpose, a questionnaire will be drafted and published early 2018 on the Commission's central consultation page (https://ec.europa.eu/info/consultations_en). Stakeholders' positions and comments on the present inception impact assessment and through to the open public consultation will be analysed and be part of the impact assessment. Later in 2018, the draft measures will be subject to the 4-week Feedback Mechanism.

A summary of the consultation activities' results will be published on the consultation page once all consultation activities are closed and in an Annex to the impact assessment report..

Will an Implementation plan be established?

No. The regulation is directly applicable in all Member States. Implementation of ecodesign and energy labelling measures is facilitated through several initiatives, for example the European cooperation on market surveillance.