Ares(2018)476416

INCEPTION IMPACT ASSESSMENT
Title of the initiative	Ecodesign and energy labelling requirements for household dishwashers
Lead DG (responsible unit)	DG ENER, UNIT C3 DG ENV, UNIT B1
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 to a lesser extent Energy Labelling are also recognised as important policy instruments in support of Circular Economy objectives.

Since the coming into force of the first ecodesign directive in 2005 and the first energy labelling directive in 1992, a variety of energy-consuming product groups such as washing machines, refrigerators, electric motors, vacuum cleaners, etc. have been covered by ecodesign and energy labelling regulations. One of these energy consuming product groups is household dishwashers.

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 dishwashers were to be reviewed by December 2014. The review is also listed in the Ecodesign Working Plan 2016-2019 among the reviews to be carried during that period. A preliminary omnibus review study was carried out in 2014 (looking at several existing product groups) followed by a dedicated review study in 2014 – 2016. A consultation forum is planned for November 2017. The impact assessment will follow end of 2017 and beginning of 2018 to assess policy options in view of proposals for revised Regulations.

Problem the initiative aims to tackle

Household dishwashers today consume around 31 TWh of electricity per year and circa 317 million m3 of water in the EU. The associated electricity consumption is expected to reach circa 40 TWh in 2030, unless specific product-related measures are taken. This increase in electricity consumption is mainly due to the higher penetration rate of this product group into the as yet unsaturated EU market, coupled with increased dishwasher filling capacities, i.e. they are able to accept more dishes, cups, cutlery and glasses, etc.

Preliminary findings indicate that a revision of the regulations would not only result in further cost-effective energy and water savings but would also support the application of improved test standards, the differentiation of products on energy performance, and better information provision to consumers.

In addition, the Ecodesign Working plan 2016-2019 indicates that, where appropriate, ecodesign and energy labelling measures should cover resource efficiency aspects, to ensure greater durability, reparability upgradeability, disassembly and recycling of products entering the market. The proposed draft Ecodesign measure contains additional requirements in this area, thereby contributing to the transition towards a more circular economy.

Additionally, household dishwashers are one of the product groups in the Energy Labelling Framework Regulation for which a revised delegated regulation introducing a rescaled label with an A to G scale need to be adopted by November 2018.

Basis for EU intervention (legal basis and subsidiarity check)

The Energy Labelling Framework Regulation ((EU) 2017/1369) 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 (2019/125/EC) 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 main 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 dishwashers will look at solutions to:

- take into account technological progress and revisions of test standards;

- induce new energy and financial savings for household dishwashers;

- remove the least energy and resource efficient dishwashers from the market;

- ensure where appropriate improved material efficiency (e.g. reparability, access to repair manuals, design for disassembly, access to spare parts);

- facilitate market surveillance;

- support the competitiveness of the dishwasher 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 will consider the following main options:

1.No action (BAU, business-as-usual), except for a rescaling of the energy label;

2.Self-regulation;

3.Energy Labelling only, including a rescaling of the energy label;

4.Increasing the ambition of the Ecodesign requirements, including possible new requirements related to resource efficiency.

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

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

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 dishwashers industry and the end consumers of household dishwashers. The increase in energy efficiency requires household dishwasher manufacturers to invest and make more production costs. Those will subsequently be recuperated through higher sales prices. This will generate extra business (all sectors) revenue compared to a BAU scenario.

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

Likely social impacts

Reducing energy consumption also decreases air pollution, which is a growing source of health problems, and facilitating further water savings reduce vulnerability to droughts among other benefits.

The consumer choices, based on improved information, such as the inclusion of noise classes, are also expected to have beneficial effects for household comfort.

Preliminary findings indicate that the revision of the regulations could bring extra jobs in the dishwasher industry, distribution sector and repair and end-product industries.

Finally, consumers will benefit from the regulation through lower energy bills.

Likely environmental impacts

Electricity consumption and water consumption in the use phase constitutes the main environmental impact of the household dishwashers. The revision is expected to deliver up to 2.1 TWh/year of net electricity savings, 0.7 Mt CO2 eq/year emission reduction and up to 5 million m3 per year of water savings in the year 2030.

In addition to the anticipated savings in terms of energy and water consumption in the use phase, other environmental aspects are being considered in this revision, addressing material efficiency concerns, reparability and resource savings, to support the transition towards a Circular Economy. Potential material savings in key components can be realised.

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 existing Ecodesign and Energy Labelling Regulations are directly applicable in all Member States, resulting in no costs for national administrations for transposition into national legislation. The updated Regulations are expected to simplify and 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. The European Committee of Domestic Equipment Manufacturers (CECED) has set up comprehensive market data collection for this sector at EU level. The CECED database includes performance data for most of the models sold on the EU market between 1997 and 2015. In addition, several manufacturers have supplied (confidential) commercial information that permitted the confirmation of certain market trends.

Consultation of citizens and stakeholders

There has already been an extensive consultation of stakeholders and experts, in particular during the review study, which was carried out in 2014-2017. It included the establishment of a dedicated website (http://susproc.jrc.ec.europa.eu/Dishwashers/index.html) where all relevant documents can be found, comprising: a stakeholder survey, two stakeholder meetings (24th June 2015 and 18th November 2015), a web-seminar held on 7th October 2016 and intermediate and final reports published in June 2017.

Around 140 stakeholders participated in the consultation, including Member States, environmental NGOs and consumer groups, market surveillance authorities, European standardisation organizations, individual manufacturers, associations of manufacturers, and recyclers and repairers.

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.