Contents

1.Introduction: Political and legal context

1.1.EU energy and climate objectives

1.2.The contribution of Ecodesign and Energy labelling

1.3.Legal context of the impact assessment

2.Problem definition

2.1.What are the problems?

2.1.1.    The first key problem: missed in-use energy savings from tumble dryers    

2.1.2.    The second key problem: market failures due to lack of regulatory provisions on circular economy    

2.1.3.    A third additional problem: reduced effectiveness/unnecessary complexity of some legal requirements    

2.2.What are the problem drivers?

2.2.1.    Lenient energy efficiency index (EEI)    

2.2.2.    Overpopulation of the highest classes of the energy label    

2.2.3.    Current calculation methods do not sufficiently represent real energy consumption from tumble dryers    

2.2.4.    Circular economy: insufficient availability of spare parts    

2.2.5.    Circular economy: insufficient repair and maintenance information    

2.2.6.    Circular economy: insufficient information for end-of-life processing    

2.2.7.    Circular economy: insufficient user maintenance information    

2.3.How likely is the problem to persist?

3.Why should the EU act?

3.1.Legal basis

3.2.Subsidiarity: Necessity of EU action

3.3.Subsidiarity: Added value of EU action

4.Objectives: What is to be achieved?

4.1.General objectives

4.2.Specific objectives

5.What are the available policy options?

5.1.What is the baseline from which options are assessed?

5.1.1.    Stock    

5.1.2.    Environmental parameters    

5.1.3.    Economic parameters    

5.2.Description of the policy options

5.2.1.    Policy option 1 (BAU): business as usual    

5.2.2.    Policy option 2 (PO2) – lenient option: energy labelling measures    

5.2.3.    Policy Option 3 (PO3) – ambitious option: new energy efficiency limits    

5.2.4.    Policy Option 4 (PO4): circular economy    

5.2.5.    Complementary measures    

5.2.6.    Transitional period for the implementation of the policy options    

5.3.Options discarded at an early stage

5.3.1.    Voluntary agreement    

5.3.2.    Modification of the verification tolerances    

6.What are the impacts of the policy options?

6.1.PO2 – lenient option: energy labelling measures

6.1.1.    Environmental impacts    

6.1.2.    Economic impacts    

6.1.3.    Social impacts. Employment    

6.2.PO2 + PO3 – ambitious option: rescaling of the energy label and new energy efficiency limits

6.2.1.    Environmental impacts    

6.2.2.    Economic impacts    

6.2.3.    Social impacts. Employment    

6.3.PO2 + PO4 – rescaling of the energy label and circular economy measures

6.3.1.    Environmental impacts    

6.3.2.    Economic impacts    

6.3.3.    Social impacts. Employment    

6.4.PO2 + PO3 + PO4 –rescaling of the energy label, new energy efficiency limits and circular economy measures

6.4.1.    Environmental impacts    

6.4.2.    Economic impacts    

6.4.3.    Social impacts. Employment    

6.5.Additional impacts jointly assessed for all policy options

6.5.1.    Payback period (affordability)    

6.5.2.    Costs    

6.5.3.    Indirect employment    

6.5.4.    Competitiveness    

6.5.5.    Fundamental rights    

6.5.6.    Geographical distribution    

7.How do the options compare?

7.1.Effectiveness

7.2.Efficiency

7.3.Coherence with other EU policies and legislative framework

7.3.1.    Coherence with the overarching objectives of EU policies    

7.3.2.    Coherence with Article 15(5) of the Ecodesign Framework Directive    

7.4.Coherence with the proportionality and subsidiarity principles

8.Preferred option

8.1.Preferred policy option

8.2.REFIT (simplification and improved efficiency)

8.3.Application of the ‘one in, one out’ approach

8.4.Overview in the context of current energy prices

9.How will actual impacts be monitored and evaluated?

Annex 1: Procedural information

1.Lead DG, Decide Planning/CWP references

2.Organisation and timing

3.Consultation of the RSB

4.Evidence, sources and quality

Annex 2: Stakeholder consultation (Synopsis report)

1.Review study and stakeholder consultations

2.First Consultation Forum on 18 September 2019

3.Stakeholders comments during and after the consultation forum

4.Publication of the Call for Evidence and stakeholders feedback

5.Second Consultation Forum on 10 March 2022

Annex 3: Who is affected and how?

1.Practical implications of the initiative

2.Summary of costs and benefits

Relevant sustainable development goals

Annex 4: Analytical methods

1.Model description

2.Data sources, scaling and projections

2.1.Sales data

2.2.Stock

2.3.Price versus performance

2.4.Rated capacity

2.5.Electricity costs and emission factors

2.6.Employment

2.7.Mark-up factors

2.8.Material input

2.9.Performance data

Annex 5: EEI calculation and rescaling of the energy label

1.calculation of the new EEI

1.1.New calculation method for Etc and Tt

1.2.New calculation method for SEc

2.Energy label distribution

3.Projection of the energy labelling distribution

Annex 6: Key assumptions for policy options

1.For BAU

2.For PO2

3.For PO3

4.For PO4

Annex 7: Additional impacts related to resource efficiency

1.Water consumption

2.Waste

Annex 8: Sensitivity analysis

1.Sensitivity analysis regarding the variation in repair costs and product lifetime

1.1.Baseline values

1.2.Influence of an increase in repair costs

1.3.Increase of the lifetime

2.Sensitivity analysis on the use of the MIX scenario instead of REF2020

Annex 9: List of spare parts

Annex 10: SME test

1.Identification of the affected businesses

2.Threshold question: to what extent is the initiative relevant for SMEs?

Annex 11: Refrigerants in tumble dryers

1.F-gas regulation

2.Price development of refrigerants for heat pumps

3.Transition to heat pumps with low GWP refrigerants

Annex 12: Analysis of current ecodesign and energy labelling regulations for household tumble dryers

1.Effectiveness

1.1.Energy savings

1.2.Specific energy consumption and rated capacity

1.3.Market share and price of heat pump tumble dryers

2.Efficiency

3.Relevance

Annex 13: Additional charts and tables for the different policy options

1.Greenhouse gas emissions

1.1.PO2

1.2.PO2+PO3

1.3.PO2+PO4

1.4.PO2+PO3+PO4

2.Retail turnover

2.1.PO2

2.2.PO2+PO3

2.3.PO2+PO4

2.4.PO2+PO3+PO4

3.Retail employment

3.1.PO2

3.2.PO2+PO3

3.3.PO2+PO4

3.4.PO2+PO3+PO4

Annex 14: The Ecodesign and Energy Labelling Framework

Glossary

1.Introduction: Political and legal context

1.1.EU energy and climate objectives

The EU has longstanding objectives to increase energy efficiency and to reduce its greenhouse gas emissions. These go along with other objectives to reduce its environmental impacts. In December 2019, the Commission presented the European Green Deal 1  to strengthen these objectives and as the cornerstone of its strategy to fulfil the United Nation’s 2030 Agenda for Sustainable Development 2 . In September 2020, it presented a Climate Target Plan (CTP) for 2030 3 , showing the need for a higher contribution of energy efficiency and renewable energy to achieve a net 55% GHG emission reduction most cost-effectively, in line with the Paris Agreement. The European Parliament and Council subsequently agreed to achieve this level of reduction in GHG emissions. The Commission followed this by adopting the EU “Fit for 55” package 4  aiming to achieve the necessary cut in GHG emissions.

One pillar of the CTP and subsequently the ‘Fit for 55’ package is energy efficiency. A revision of the Energy Efficiency Directive (EED) 5 to increase the overall ambition was proposed. This would require Member States to enhance their National Energy and Climate Plans (NECPs) to achieve at least an overall 9% reduction in EU energy consumption in 2030 compared to the reference 6 . The EED itself contains limited energy saving measures and in addition to Member State actions, measures at EU level are needed 7 . In this context, the ecodesign and energy labelling rules for products arise as important instruments to realise EU’s energy and decarbonisation objectives.

Another pillar of the European Green Deal is a more circular economy. The new Circular Economy Action Plan 8  sets out steps to work towards this. It aims to reduce product environmental impacts for example through promoting longer product lives, greater resource efficiency and enhancing recycling and recycled content. Certain of these aspects can be addressed through measures under the Ecodesign Directive since decisions made at design can influence the product’s life span and ease of maintenance, repair, reuse, upgrade, recyclability and waste handling. The Ecodesign Working Plan 2016-2019 identified ecodesign measures’ potential to contribute to circular economy objectives and subsequent supporting studies have systematically considered resource efficiency aspects.

Reducing energy use and promoting the circular economy are also important for many other reasons 9 . Lower energy use reduces the EU’s energy import dependence and improves energy security, aspects that are particularly relevant in the current context of continuous increase of energy prices. On 8 March 2022, the Commission published its Communication “RepowerEU: Joint European action for more affordable, secure and sustainable energy” 10 , being one of its pillars the fast reduction of EU dependence on fossil fuels at the level of homes, buildings and the industry by boosting energy efficiency gains.

Ecodesign and energy labelling contribute to improved air quality and support energy system integration and the alleviation of energy poverty. It is also expected to lead to the creation of jobs, encourage innovation and support and facilitate economic growth 11 . Both energy savings and promoting the circular economy lead to reduced environmental damage from materials extraction and resource efficiency. Most of these co-benefits are difficult to quantify, but are well known and perceived by society.

In March 2022 the Commission adopted the ESPR (Ecodesign for Sustainable Products Regulation) a proposal to replace the Ecodesign Framework Directive 12 , which will expand the scope of ecodesign from energy-related products to any kind of physical good that is placed on the market, with some exceptions that are set out in the ESPR itself. Ecodesign product regulations adopted under the existing Directive would nevertheless continue in force until repealed. When the proposed legislation is eventually adopted future amendments to existing product regulations would be carried out under its framework. The adoption of the ESPR is expected to have little influence on the results of this IA, as it is further developed in section 5.1.

1.2.The contribution of Ecodesign and Energy labelling

There are market barriers that hamper the introduction and uptake of more energy efficient and more long lasting products. It is desirable for policies to address these barriers since they lead, from the point of view of the consumer and society, to unrealised economically viable energy savings. Behavioural failures refer to the cognitive limitations and biases that prevent consumers and investors to appreciate rationally the benefits of energy efficiency 13 . Market failures arise from the fact that many impacts and aspects of energy supply or resource use are not brought into market prices 14 . Market barriers such as lack of information and awareness or financing challenges result in economically rational energy savings not being realised or more sustainable choices not being made.

The EU Ecodesign Directive aims to address these barriers by setting performance requirements to remove the worst performing products from the market. The assessment aims to ensure that the minimum requirements are set at the level of Least Life Cycle Cost (LLCC). These harmonised requirements have specifically addressed energy efficiency and have led to significant reductions in energy use of household and industrial products. Being set at EU level, they have avoided subjecting industry to multiple national rules.

Energy labelling rules in turn complement ecodesign requirements, by providing information to consumers with the aim of encouraging them to purchase products that have a better energy performance than the minimum. This has helped consumers to reduce their energy bills by easily identifying and comparing more energy efficient appliances. Nearly 80 % of the EU public recognise the label and say it has influenced their purchase decision 15 . 

The impact of ecodesign and energy labelling measures is gathered in the Ecodesign Impact Accounting 16 , which estimates that in 2020 a quarter of the energy savings and a third of the greenhouse gas emissions reductions to achieve the EU’s 20-20-20 climate and energy policy goals was due to the application of those measures.

The benefits of ecodesign and energy labelling are not limited to the EU energy and environmental goals but they also contribute to some of the 17 Sustainable Development Goals (SDGs) adopted by the UN. By reducing in-use energy consumption and the subsequent environmental impacts such as GHG emissions or acidification, ecodesign and energy labelling measures contribute to the SDGs 7 (affordable and clean energy), 10 (reduced inequalities), 11 (sustainable cities and communities) and 13 (climate action). In particular the following targets included in the abovementioned SDGs are addressed: target 7.3 (double the improvement of energy efficiency), 8.4 (improve resource efficiency in consumption and production), 10.1 (reduce income inequalities) by reducing the consumer’s energy bill and notably for those in situation of energy poverty, 11.6 (reduce the environmental impact of cities) and 13.1 (strengthen resilience and adaptative capacity to climate-related hazards). In addition, circular economy measures under ecodesign also contribute to the following SDGs and targets: the abovementioned targets 8.4 and 11.6 by lengthening the lifetime of the product, reducing waste and increasing recyclability and SDG 12 (responsible consumption and production) and in particular its targets 12.2 (sustainable management and use of natural resources) and 12.5 (substantially reduce waste generation).

Annex 3 quantifies the impact of the preferred policy option on the abovementioned SDGs.

1.3.Legal context of the impact assessment

Article 7 of the Ecodesign and of the Energy Labelling Regulations for household tumble dryers 17 18 (henceforth “the TD Ecodesign Regulation” and “the TD Energy Labelling Regulation”, respectively) mandate a review of the legislation on tumble dryers. In particular, the review should have regard to the verification tolerances and the efficiency of the appliances. In addition, Article 11 of the Energy Labelling Framework Regulation (EU) 2017/1369 19  mandates a rescaling of the existing energy labels to an A to G scale, in a way that no products are expected to fall into energy class A at the moment of the introduction of the label.

Consequently a review 20 of the TD Ecodesign and Energy Labelling Regulations was included in the Ecodesign Working Plan 2016-2019 21 . This noted that the review would also assess aspects relevant to the circular economy. The impact assessment builds therefore upon the current ecodesign rules on tumble dryers and is intended to keep the relevance of the existing legislation by adapting it to technical progress.

2.Problem definition

2.1.What are the problems?

2.1.1.The first key problem: missed in-use energy savings from tumble dryers 

The EU Reference Scenario 2020 projects energy consumption to be reduced to 1.124 Mtoe of primary energy and 864 Mtoe of final energy in 2030, which is insufficient to attain the energy efficiency target under the fit-for-55 package. As indicated in section 1.1, the draft revision of the EED sets out an additional binding reduction of 9% of energy consumption in the EU from energy efficiency measures, which would bring the energy consumption down to 1.023 Mtoe of primary energy and 787 Mtoe of final energy by 2030.

The revised EED will mandate Member States to lay down measures at national level to collectively contribute to the EU binding target. Co-responsibility between Member States is necessary because only collectively it will be possible to meet the global EU energy and climate goals, but entails the risk that some Member States may not fully realise their national objectives, jeopardising the achievement of the 9% target. Ecodesign and energy labelling measures (which unlike measures in the scope of the EED have the advantage of being directly applicable across the EU) must contribute to that 9% by reducing energy consumption on top of the reductions achieved under the EED.

Energy consumption in the household sector accounted in 2019 for about 28% of the EU 27 final energy consumption 22 , namely 248 Mtoe. The in-use energy consumption from tumble dryers reached 1,3 Mtoe in 2020 23 , equivalent to 0,5% of the EU final energy consumption from households and to 12% of the final energy consumption from household appliances. Further energy savings from tumble dryers could help to reduce energy consumption and increase the contribution of the household sector to the overall energy efficiency target. Nevertheless, the regulations for tumble dryers will not lead to further energy savings from this product group. This is indicated in section 7.2.2 of the review study 24 , which explains that the two regulations currently in force have worked on pushing the EU market towards more efficient tumble dryers, but that further improvements are still possible by intensifying the presence in the market of tumble dryers that are based on the BAT (Best Available Technology).

2.1.2.The second key problem: market failures due to lack of regulatory provisions on circular economy

The lack of regulatory provisions on circular economy lead to market failures because embedded energy consumption during production, distribution and EoL lead to negative environmental effects that are not internalised in the price of tumble dryers. This makes industry not to receive sufficiently strong signals as to incorporate resource efficiency criteria in the design and manufacturing of their products. In addition, circular economy and climate and energy policies like energy efficiency, have not always been well integrated before the adoption of the Green Deal. For instance, the IPCC’s Summaries for Policy Makers hardly mentioned circularity or resource efficiency as a decarbonisation option, and the own first Circular Economy Action Plan of 2015 vaguely mentioned climate change while acknowledging that “to date ecodesign requirements have mainly targeted energy efficiency”. Nowadays, scientific literature has demonstrated the connection between circular economy, energy savings and climate change, thanks to seminal studies like Material Economics’ and Sitra’s, entitled The circular economy – A powerful force for climate mitigation (2018) 25 , from the UN’s International Resources Panel 26 27  or even by the Commission’s in-depth analysis for the Long-Term Strategic Vision to reduce GHG emissions. Now these interlinkages are acknowledged at both scientific and policy levels, notably under the European Green Deal and its initiatives (e.g. Renovation Wave, EPBD revision).

2.1.3.A third additional problem: reduced effectiveness/unnecessary complexity of some legal requirements

Some aspects of the legislation should be revisited because they are either unnecessary or inadequately addressed, creating confusion and reducing the effectiveness of the current legal framework. Although these aspects do not entail a quantifiable environmental impact, the revision of the legislation is an opportunity to improve them. The related drivers are already enumerated in this section in order to avoid over-complication of the next section 2.2, which will focus on the drivers to the two key problems.

Unnecessary scale of condensation efficiency

The condensation efficiency is a measure for the emission of moisture from the appliance to the ambient and has a small influence on energy efficiency. According to GfK market data from 2019, confirmed by EPREL (European Product Database for Energy Labelling) data from 2021, almost all models on the EU market have condensation efficiencies above 80% and half of the models have a condensation efficiency of 84% and above. As a result, the minimum value for the condensation efficiency (set in the TD Ecodesign Regulation at 70%) and the condensation efficiency classes displayed on the energy efficiency label are meaningless, since almost all new tumble dryers are concentrated in classes A and B. The condensation efficiency information included in the energy label has therefore no added value.

Complex approach to low power modes

Minimum values for energy consumption in low power modes applicable to tumble dryers are set in the Horizontal Standby Regulation 28  but they are not included in the TD Ecodesign Regulation. However, the TD Ecodesign Regulation includes factors linked to low power modes, which are used in the formula for the overall calculation of the energy efficiency. The existence of requirements on low power modes in both the TD Ecodesign and Standby Regulations results in an unnecessary complexity of the legislative framework. This approach is not in line with the legislation for other products such as washing machines and dishwashers, for which the factors have been deleted and replaced by minimum low power mode values. At the same time, those values have been removed from the Horizontal Standby Regulation in order to avoid duplicities.

Increased length of drying cycles

Manufacturers interest to reach higher efficiency classes has resulted in compensating the decrease of temperature by an increase of the average length of the drying cycle. Consumer associations report complaints and irritation from users regarding the often very long time that a drying cycle takes. This issue may undermine the credibility of the label and is not in line with Art. 15(5) of the Ecodesign Framework Directive, which requires the implementing measures not to bring about a significant negative impact on the functionality of the product from the perspective of the user. APPLiA (Home Appliance Europe, main representative of the appliance manufacturing sector at EU level) consumer survey 29 shows that a maximum cycle time of 240 minutes for the standard cotton cycle at full load is the threshold for a cycle duration to be acceptable.

Phase out of gas-fired tumble dryers

Since 2020 there are no more gas-fired tumble dryers on the EU market 30 . The TD Energy labelling Regulation becomes therefore unnecessarily complex by including in the label information on a technology that is definitely phased-out.

Incomplete information on noise emission

The noise emission from tumble dryers is shown on the current energy label in dB(A), but no noise classes have been defined. The user is therefore confronted with an absolute value but is not able to know how good that value is. Noise emission classes have already been included on the labels for washing machines, dishwashers and refrigerators, but this is still not the case for tumble dryers.

Misalignment between the energy label of tumble dryers and the energy label of products with similar functionalities

Washer-dryers, an appliance that combines washing and drying laundry, have been included for the first time in the revised versions of the Ecodesign and Energy Labelling Regulations on washing machines 31 32 . The energy label of tumble dryers is not aligned with the dryer-part of the washer-dryer label, thus both labels using different layouts for exactly the same functionality.

2.2.What are the problem drivers?

2.2.1.Lenient energy efficiency index (EEI) 

The energy efficiency of a tumble dryer is determined by its EEI 33 . The EEI is specific for each tumble dryer model, and is calculated as the quotient between the Energy consumption (Ec) of that model (set out after testing) and the Standard Energy Consumption (SEc) of all tumble dryers on the market at a specific point in time. Ec gives the energy consumption of the specific model for which the EEI value needs to be known, and SEc gives an averaged energy consumption of all the models in the market with the same load capacity. By dividing both values, the EEI compares the energy consumption of the specific model under test with the energy consumption of all the models in the market with the same load capacity, giving an idea of how good the model under test is compared to the rest of the market. It follows from this that the lower the EEI the better the energy performance of a model.

There are currently three tumble dryer technologies: air vented, heating element and heat pump (both heating element and heat pump are in turn grouped as condenser dryers). According to section 7.2.2 of the review study, there is currently a big gap in terms of energy efficiency between heat pump tumble dryers on one side, and heating element and air vented tumble dryers on the other side. Air vented and heating element dryers are the least efficient ones because they consume over 3 times more electricity than the heat pump dryers, for which reason they have lost a significant market share. Nevertheless, in the absence of action a significant number of heating element tumble dryers will still remain in the market as explained in section 5.1, causing an excess of energy consumption and release of GHG emissions. Therefore, under the current TD Ecodesign Regulation, the EEI threshold above which tumble dryers may not be placed on the market is too high and allows inefficient dryers to remain in the market.

2.2.2.Overpopulation of the highest classes of the energy label 

The energy label of tumble dryers has not been adapted to technological progress. Section 7.2.2 of the review study explains that 99% of heat pump tumble dryers on the EU market are above energy class A, causing a congestion in the top three energy labelling classes (A+ to A+++). This makes it more difficult for consumers to distinguish between more and less efficient models and reduces the incentive for manufacturers to achieve higher energy efficiencies because they cannot be rewarded with a class higher than A+++. In addition, the A+, A++ and A+++ classes have shown to be less effective than the A to G scale in persuading consumers to buy more efficient products 34 .

2.2.3.Current calculation methods do not sufficiently represent real energy consumption from tumble dryers

The real usage and energy efficiency of tumble dryers has changed over the years, but the EEI formula has not followed that change, becoming outdated and unable to provide a value that represents real energy efficiency.

APPLiA has signalled that the current average load per cycle and the annual number of cycles used in the Ec calculation are overestimated. This is also highlighted in section 7.2.3 of the review study. Under the current TD Ecodesign Regulation, the load is determined by the average of 3 tests in full load and 4 tests at part load. Latest surveys reported in the review study find a proportion of 1 to 3 between full load and part load as well as 107 cycles instead of 160 cycles per year. The most likely cause for this change is the progressive growth in load capacity. In 1995 the average nominal load capacity of tumble dryers was 4,5 kg and the average real-life load 3 kg for 175 cycles/year 35 , in 2005 it was 5,5 and 3,4 kg respectively for 154 cycles/year (rounded to 160 in the regulation) 36 and now it is 7,7 and 4,4 kg respectively for 107 cycles. The load capacity has grown faster than the actual load.

Further, the Ec is currently based on an estimation of the average number of cycles per year with the help of consumer surveys. An energy consumption per 100 cycles instead of per year would be more informative and would allow the consumer to calculate energy consumption based on the amount of use they make of the appliance.

As far as the SEc, the current procedure overestimates the average energy consumption of the models in the market, resulting in unrealistically low EEIs. Besides lowering the value of the EEI, an overestimated SEc creates an incentive for manufacturers to increase the size of their models, because the reference SEc grows faster than the additional energy consumption resulting from an increase of the rated capacity. As it is explained in Annex 12, the rated capacity of tumble dryers has been steadily increasing since 2010 and this tendency is expected to continue in the absence of further legislative action.

2.2.4.Circular economy: insufficient availability of spare parts

A 2016 study carried out for DG Environment 37 shows that that the availability and prices of spare parts are among the major barriers to reparability. Spare parts are usually not available or it takes a long time to deliver them, creating the incentive to discard the product and replace it instead of repairing it. Some producers deliver spare parts only to their partners, thus setting market barriers for independent repairers.

2.2.5.Circular economy: insufficient repair and maintenance information

Repair and maintenance information is often not available to professional repairers, making it more difficult to diagnose and solve breakdowns and increasing the cost of repair. This problem has also been reflected in the ecodesign review study of washing machines 38 and can be assumed to be similar for tumble dryers.

2.2.6.Circular economy: insufficient information for end-of-life processing

The review study showed that information to facilitate the dismantling of components regulated in the WEEE Directive 39 (e.g. circuit boards, electronic displays) and information on the refrigerants in heat pump dryers 40 can help recyclers to maximise material recovery and reduce costs of recycling.

2.2.7.Circular economy: insufficient user maintenance information

An APPLiA consumer survey 41 shows that only 45% of the European consumers clean the lint filter every time they use the tumble dryer. The survey indicates that filters are cleaned less than once a month in 3 out of 10 cases, which is less often than required by manufacturers for an average use profile. Repairers 42  point at insufficient maintenance of the filters as one of the main reasons for breakdown of heat pump dryers. Besides, filters not properly cleaned increase energy consumption. Information on the filters is available in the user manual, but many users do not read the manual or only read part of it 43   44 .

2.3.How likely is the problem to persist?

As explained in section 5.1, energy consumption from tumble dryers will decrease due to the trend of the market towards heat pump tumble dryers. In spite of this positive evolution, in the absence of regulatory action less efficient tumble dryers will keep a significant share of sales and stock over the next two decades, limiting the reduction of energy consumption and GHG emissions.

As far as circular economy (second key problem), the review study indicates that the lifetime of tumble dryers has decreased from 14 to 12 years over the last 15 years. If no measures are taken the current average lifetime from tumble dryers is likely to remain or even to drop further. Measures in favour of reparability could reverse this trend.

3.Why should the EU act?

3.1.Legal basis

Articles 114 and 194 of the Treaty on the Functioning of the European Union (TFEU) are the legal base for measures related to the functioning of the internal market and therefore constitute the legal base for the Ecodesign Framework Directive, the Energy Labelling Framework Regulation 45 and their secondary acts. 

In addition, the Ecodesign Framework Directive lays down a set of criteria to identify energy-related products that may be subject to ecodesign measures. In the view of those criteria, the review study concludes that tumble dryers are eligible on the basis of the potential energy savings that can still be achieved through the introduction of additional cost-effective energy savings.

3.2.Subsidiarity: Necessity of EU action

Without harmonised EU requirements on tumble dryers, Member States would be incentivised to lay down energy efficiency requirements at national level. Diverse national approaches with respect to energy efficiency would be an obstacle for the internal market, because products would have to be adapted to diverging national rules, thus risking of higher compliance costs for the industry. Those harmonised EU requirements must now be updated to technological progress to ensure future relevance of the legislation.

In addition, the contribution of ecodesign to the Green Deal objectives, in particular to the achievement of carbon neutrality by 2050 and the mobilisation of industry for a clean and circular economy, would be undermined if no EU action is taken on the efficiency of energy-related products.

3.3.Subsidiarity: Added value of EU action

Ecodesign measures contribute to the global EU energy and climate objectives by influencing the characteristics of construction of energy related products. In this respect, the approach from ecodesign requirements is different than that from other energy and climate legal acts such as EED and RED 46 , which are based on the implementation by Member States of measures based on existing technologies, but do not directly require the development of the technologies themselves. Direct EU action through ecodesign rules reinforce therefore the actions taken at national level. Ecodesign measures can only be addressed at EU level since they impact directly on the product features, which uniformity needs to be assured to avoid that different national rules undermine the EU internal market for that product.

Energy labelling in turn provides a transparent tool that Member States may use to incentivise the replacement of obsolete energy-consuming products with new and more efficient ones. According to Article 7 of the Energy Labelling Framework Regulation, when Member States provide incentives to products in the scope of energy labelling measures, those incentives shall aim at the highest two significantly populated classes of the energy label. It follows from this that energy labelling provides transparency to national aid programs by setting a common classification that Member States must use to grant incentives for the purchase of products, guaranteeing that those incentives are delivered on the basis of the EU environmental common interests and not on national preferences to favour a specific technology or set of technologies.

4.Objectives: What is to be achieved?

4.1.General objectives

The general objective is to contribute to the EU’s energy and environmental objectives set in the TFEU. There are various possible synergies within this overall objective. The TFEU states that the aim of the EU energy policy includes ensuring security of energy supply and promoting energy efficiency and energy saving. Lower energy consumption is usually accompanied by a reduction in other environmental impacts including GHG and pollutant emissions as well as lower resource use and extraction.

4.2.Specific objectives

1.Capture in-use cost-efficient energy savings from tumble dryers;

2.Contribute towards a circular economy by addressing premature obsolescence of tumble dryers;

3.Increase the effectiveness of the legislation on tumble dryers by reducing its complexity.

There are possible trade-offs between the two first objectives. The main ones are:

-Measures to increase energy efficiency might require more materials to be used for the products or materials that have bigger impacts.

-Measures to reduce the material consumed in the manufacture of tumble dryers might lead to more energy consumption in the use phase if they result in a longer lifetime of less efficient appliances.

These trade-offs will be captured by the EcoReport tool and presented in the impacts for these options in section 7.

The specific objectives 1 and 2 will contribute to the achievement of the climate-neutrality objective set out in Article 2(1) of the European Climate Law 47  (balancing Union-wide greenhouse gas emissions and removals regulated in Union law to net zero by 2050 and to achieve negative emissions thereafter) by reducing GHG emissions throughout the life cycle of the product, thus diminishing the amount of carbon to be removed from the atmosphere in order to achieve the balance between GHG emissions and removals mandated by the European Climate Law.

5.What are the available policy options?

The available policy options focus on the implementation of measures that maximise the contribution of tumble dryers to energy efficiency without imposing significant burden to manufacturers or costs to end-users, as set out in Article 15(5) of the Ecodesign Framework Directive. The main target of those options is to accelerate the phasing out from sale of less efficient tumble dryers, so that this process is completed by 2026 rather than 2050, which would be the case in the absence of action. This will be achieved by setting reachable minimum requirements on energy efficiency, which would be just enough to phase-out heating element and air-vented tumble dryers, plus the least efficient heat pump appliances. Pushing towards more demanding energy efficiency targets would not be adequate in the view of the little perspective of improvement of heat pump technology, and would risk of slanting the market towards high-end and less affordable products.

Figure 5-1 shows the overall intervention logic and the links between drivers, problems, objectives and measures. The options displayed in figure 5-1 are of complementary nature and do not overlap with each other. Different combinations of such options will be assessed in section 6, although as later explained in the introductory part of that section, PO2 is a mandatory measure from the Energy Labelling Framework Regulation and must be included in any of the combination of policy options under assessment. Figure 5-1 shows that PO2 and PO3 address the same problem and contribute to the same specific objective of reducing in-use energy consumption, although they achieve this by different means that will be explained in further detail in section 5.2. PO4 in turn, is focussed on extending the lifetime of the product and will reduce the amount of embedded energy rather than the in-use energy, which in fact will slightly increase under this option.

Figure 5‑1. Schematic overview of drivers, problems, objectives and measures and their interlinkage

5.1.What is the baseline from which options are assessed?

The electricity prices and carbon intensity that are used as input to this impact assessment are taken from the EU Reference Scenario 2020 (REF2020). More details about further input data and analytical models are provided in Annex 4. REF2020 models EU and Member States energy developments up to 2050, on the basis of current global and EU market trends and incorporating the effect of the “Clean Energy for All Europeans Package” 48 . Policies that are not legally implemented are not part of REF2020. In order to cater for future fluctuations of the different parameters relevant for the modelling in this IA, a sensitivity analysis based on the MIX scenario is run in Annex 8, with higher energy prices and lower carbon intensity vis-à-vis REF2020.

As indicated in section 1.1, it is expected that the effect of the future ESPR on the baseline will be modest. First, the new products in scope of the ESPR do not consume energy during their use, and therefore the increase in energy in scope will primarily relate to embedded energy (manufacture, distribution and EoL of products), which is a minor part (18%) of the energy use during the lifecycle of tumble dryers. Second, the totality of the embedded energy will not correspond to the EU but will be shared between EU and non-EU countries depending on the split of production. Third, producers are subject to ETS pricing and other regulatory measures that mean that they are likely to have less room for improvement compared to non-EU producers. Finally, the time frame to agree the ESPR, develop and adopt secondary legislation and for it to come in force will mean that substantial impacts could not be expected for the next ten years. These factors mean that any changes caused by the ESPR to the EU energy baseline for tumble dryers can be expected to be minimal. Major differences from the BAU will come from the energy prices side rather than from the ESPR.

5.1.1.Stock

Under the baseline, the market share of heat pump tumble dryers will significantly grow, but inefficient air-vented and heating element appliances will still remain beyond 2040. Gas-fired dryers have already been phased-out and do not appear in BAU.

Figure 5-2.Projected stock of tumble dryers installed with shares of heat pump (HP-C), condensing (HE-C), vented (HE-V) and gas-fired (GAS) under BAU (source: based on calculations by Viegand Maagøe, see Annex 4).

5.1.2.Environmental parameters

The evolution of the stock displayed in Figure 5-2 will make final energy consumption (that includes embedded energy consumed during production, distribution and EoL) from tumble dryers decrease by 16% in 2040 with respect to 2020, from 12,5 TWh/year down to 10,5 Twh/year. The reduction of total energy consumption is smaller than the reduction of in-use energy consumption (23%) because heat pump dryers are more complex and difficult to produce and dismantle, increasing the consumption of embedded energy.

Figure 5-3. Total energy consumption under BAU (including embedded energy)

The reduction of electricity consumption results in a subsequent decrease of GHG emissions by 46% in 2040 compared to 2020 levels. The progressive reduction of the carbon intensity of the electricity mix leverages the reduction of electricity consumption, causing the GHG emissions to drop faster than the energy consumption (46% against 16%), to level off by 2040 due to the assumed stabilization of the share in the EU energy mix of carbon-free electricity generation.

Figure 5-4. Greenhouse gas emissions (including embedded energy)

5.1.3.Economic parameters

The total turnover of the industry has been increasing since 2010 supported by growing sales and higher product prices resulting from the technology shift to heat pump dryers. This trend is expected to continue.

Figure 5-5. Manufacturers turnover

As far as user expenditure, it will remain constant in the mid-term because the increase of sales on the one hand and the higher purchase costs that are a consequence of the shift to the more expensive heat-pump technology on the other hand, are offset by the reduction of in-use energy costs due to the better efficiency of the new appliances. By 2045, user expenditure will grow again as the technological improvements from heat pump tumble dryers stagnate.

Figure 5-6. User expenditure

5.2.Description of the policy options 

The following table displays the correspondence between problems, measures and policy options.

Table 5-1. Correspondence between problems, measures and policy options

The policy options will mostly affect manufacturers, which will need to adapt their products to the new ecodesign requirements, although PO4 will also have an impact on repairers. Around 160 manufacturers are estimated to produce tumble dryers in the EU. The number of repair companies is estimated to be 747, employing an average of 2 people per company 49 . An SME test is carried out in Annex 10.

5.2.1.Policy option 1 (BAU): business as usual

The BAU corresponds to the baseline scenario explained in section 5.1.

5.2.2.Policy option 2 (PO2) – lenient option: energy labelling measures

PO2 consists of two measures, explained in the following sections 5.2.2.1 and 5.2.2.2.

5.2.2.1.Rescaling the energy label

The energy label will be rescaled, as mandated by the Energy Labelling Framework Regulation, with an empty A class for models with an EEI equal or below 45. The adjustment makes the current A+++ class roughly equal to the new B. G will be the lowest energy class. Table 5-2 compares the current label classes on the left with the proposed new classes on the right.

The rescaling of the label could have been fulfilled by defining an A class with an EEI threshold of 50 instead of 45, as the EEI of the existing best-in-class model according to the latest data is 51. This would have ensured that the A class is empty because currently no models reach an EEI of 50, but it would also have allowed manufacturers to place new models in class A with very little energy efficiency improvement with respect to the current models. For this reason, the EEI threshold for the proposed A class has been set by subtracting 10% from the EEI of the best-in-class model, in order to incentivise manufacturers to develop appliances that are significantly more efficient than the current ones.

Table 5-2. Current and proposed energy class classification 50

Table 5-2 shows that the proposed class B is narrower than the rest of the classes. Initially it was considered to have class B as wide as classes C to E. This nevertheless shifted class A from an EEI ≤ 45 to an EEI ≤ 40, a level considered too demanding on the basis of the expected improvement potential for heat-pump systems. An alternative would have been to move all classes upwards towards less demanding values, but a detailed analysis of the existing data showed that many products that are close to the edge between classes would be promoted to a better class. In particular those on the edge between B and C, would fall into B instead of into C, thus lessening the incentive to improve. As result of all these considerations it was finally decided to narrow class B to 10 EEI points and set class A at 45. The configuration of the energy label has been intensively discussed with stakeholders.

All stakeholders supported the revision of the energy label, although not all of them agreed on the proposed approach. APPLiA, supported by some Member States, challenged the threshold for class A on the basis that it is very difficult to achieve and argued that it will not incentivise manufacturers efforts to achieve better classes.

5.2.2.2.Improving real-life representativeness of the energy efficiency formula

Following the conclusions of the review study, the EEI formula (Ec/SEc) will be adapted to real-use by expressing its value in relation to 100 drying cycles instead of per year, and by increasing the share of half-load cycles vis-à-vis full-load cycles.

The curve for SEc will be adapted to better fit the current distribution of models and to ensure that larger dryers are not unduly favoured by the metrics. Figure 5-5 shows that the current SEc curve is too steep to be representative of the market, as it is significantly above the energy consumption values of the current models, and that the distance between the models and the curve grows with the rated capacity. As pointed out in section 2.2.3, this leads to the perverse effect that increasing the size of a tumble dryer makes it easier to comply with the EEI threshold. This would be corrected with the new SEc curve proposed. Figure 5-5 also shows that the SEc proposed in the review study is steeper than the SEc proposed in this IA. This is because the latter is based on more recent data that were not available during the review study. The SEc in the review study used data from between 2013 and 2016, and the data used in this IA are extended to 2019. The new, flattened SEc curve is a consequence of the increasing presence on the market of heat pump tumble dryers with higher energy efficiency, growing from 51% of sales in 2016 to 73% in 2019.

Figure 5-5. Standard Energy Consumption SEC current, review study and proposed as well as indicative distribution of kWh/cycle for the 3 main dryer technologies

Annex 5 provides a thorough explanation of the EEI formula and the proposed modifications. The EEI limit set in the TD Ecodesign Regulation would need to be adapted to the new formula 51 .

The new SEc curve was subject to intense discussion at the stakeholder meetings. NGOs wanted it to be a horizontal line so that the rated capacity played no role at all in the rating, and industry wanted, on the contrary, the slope to remain steep. The new and more robust data extended to 2019 helped to achieve a final solution on which all stakeholders could agree.

5.2.3.Policy Option 3 (PO3) – ambitious option: new energy efficiency limits

PO3 raises the level of ambition by setting a more ambitious EEI threshold (only tumble dryers with EEI ≤ 85 will be allowed to remain in the market) based on the new EEI formula described in section 5.2.2. This EEI threshold will phase out air-vented and heating element tumble dryers, as well as the worst-performing heat pump tumble dryers.

Small tumble dryers with a rated capacity equal to or under 4,5kg do not feature enough space to fit a heat pump system and are therefore less efficient, will be exempted from the scope of PO3. This is because their inclusion would eliminate such dryers from the market and thus prevent their installation where needed, namely small dwellings with little space available.

Figure 5-6 shows the level of ambition of PO3. With the new method for the calculation of EEI proposed in PO2, the current EEI threshold would be set at 181, which would correspond to class F. The proposed EEI threshold of 85 would coincide with the limit of class D with C and would phase-out not only heating element and air vented tumble dryers, but also the least performant heat-pump models. Since no tumble dryers could be placed on the market below class D, classes E to G would only be used by tumble dryers of 4,5 kg or less of rated capacity, which as pointed out above would be exempted from the ecodesign rules.

Figure 5-6. Comparison current and proposed EEI limit

In the current context of higher energy prices, energy savings become more interesting and the question raises on whether it would have been economically interesting to increase the proposed level of ambition by further lowering the EEI threshold. Section 8.4 shows that, due to the moderate expectations about future energy efficiency improvements on the basis of heat-pump technology, a more stringent EEI threshold would have been costly to achieve, making the option uneconomic.

As far as the views from stakeholders, PO3 was supported by various Member States and NGO’s. The latter also proposed to raise the level of ambition by setting the EEI threshold at 80 instead of 85. Some NGO’s even proposed an EEI threshold of 60, which would only allow tumble dryers placed in classes A, B and a part of class C to be placed in the market. APPLiA did not support the EEI threshold of 85 but accepted it, provided that it applies at the end of a long transitional period of five years after the entry into force of the TD Ecodesign and Energy Labelling Regulations. In this respect, APPLiA proposed a two-tier implementation, the first tier applying 18 months after the entry into force of the legislation and the second 36 months after the first tier. On the opposite side, some Member States and NGOs proposed to have a single and short implementation date to avoid confusion.

5.2.4.Policy Option 4 (PO4): circular economy

PO4 aims to reduce embedded energy consumption by implementing the following resource efficiency measures:

-mandatory availability of critical spare parts for 10 years after ceasing the production of a model, with a maximum delivery time of 10 working days. The TD Ecodesign Regulation will include two separate lists of spare parts for the manufacturer to make available, one with spare parts available to both users and professional repairers and a second one only including spare parts available to professional repairers. Main argument to restrict specific spare parts to professional repairers are safety concerns, as indicated below.

-mandatory access to repair and maintenance information to facilitate the repair activities of independent repairers;

-availability of information for enhanced disassembly/recovery of WEEE-components and refrigerants: dismantling information must be available, on a free access website, regarding access to any of the components of the product referred to in point 1 of Annex VII of the WEEE Directive. The information shall include the dismantling steps, tools or technologies needed to access the components, and shall be available for at least 15 years after the placing on the market of the last unit of a product model;

-permanent marking of the refrigerant type in the nameplate of heat-pump tumble dryers (air-vented and heating element tumble dryers do not use refrigerant). In addition, the refrigerant type and its GWP shall be available in the user manual and the product information sheet;

-user information on the location of the filters and the need to clean them regularly shall be clearly visible on the appliance.

PO4 will not internalise the external costs in the purchase price, which would raise consumer expenditure, but will rather reduce the environmental footprint of embedded energy by reducing the scrapping of appliances thus slowing down the pace of production.

In general stakeholders support PO4, although there are different views on how long spare parts should be made available. NGOs and consumer associations favour 12 years, while industry recommends 7 years. Members States, NGOs and consumer organisations have proposed extensions to the proposed list of available spare parts and want them to be available for both professional repairers and consumers and not only the former. APPLiA does not support the inclusion of spare parts for the heat-pump system because it is not a cost-effective solution, and indicates that some spare parts must not be available to the general public, as there are safety issues related to their handling, for instance risk of electric shock.

NGOs and consumer associations have proposed to fit the appliance with an automatic indicator to inform the user when the filters should be cleaned. The benefit of that feature is nevertheless uncertain. Several tumble dryer models already include an indicator 52 , but more knowledge about its benefits and costs is needed to be able to develop suitable ecodesign requirements. APPLiA points out that the sensor, its integration into the electric circuit and the development and implementation of the associated software would entail significant costs.

5.2.5.Complementary measures

The complementary measures increase the clarity of the legislation and reduce unnecessary requirements without entailing any environmental, economic or social impacts, and will be taken into the legal amendment regardless of the preferred policy option. These measures are:

-simplifying the layout of the energy label: the new label will be simplified by mirroring the dryer-part of the new washer-dryer label (see figure 5-6). Only energy class, electricity consumption per 100 cycles in kWh, load capacity in kg and cycle time in hours:minutes for cotton dry cycle will be displayed. The icon of the powering energy will disappear since gas fired tumble driers are no longer on the market and the remainder are electric, and the condensation efficiency classes will also disappear. Instead, the minimum condensation efficiency will be raised to 80%, but this will not entail any impact because all new models on the market reach that efficiency;

-replacing the low-power factors of the EEI formula by minimum values for low power modes. This will also imply excluding tumble dryers from the scope of the Standby Regulation to avoid regulatory redundancy;

-introducing noise-emission classes on the label starting with A at < 60 dB(A) and ending with D at ≥ 68 dB(A). A bandwidth of 4 dB(A) is used for the distribution of classes, as for washing machines and washer-dryers; 

-removing gas-fired dryers from the energy label;

-setting a cap of 240 minutes to the duration of the cycle, to avoid consumer complaints on performance.

Figure 5-6. Left: current washer-dryer label (showing wash and wash&dry cycle information). Right: proposal for similar tumble dryer label (water consumption not needed for drying only cycle)

5.2.6.Transitional period for the implementation of the policy options

In order to give stakeholders (industry, standardisation organisations, retailers) time to adapt to the new requirements, a transitional period for the application of the chosen policy option has been envisaged. PO2 measures would be implemented in 2025, this is 18 months after the foreseen date of entry into force of the legislative amendment. For PO3, there would be an additional transitional period of 18 months (mid-2026). The total transitional period would then be 36 months after the date of entry into force of the revision of the legislative amendment.

5.3.Options discarded at an early stage

5.3.1.Voluntary agreement

According to the Ecodesign Framework Directive, voluntary agreements must get priority over legislative actions, provided that objectives are met in a quicker and more cost-effective manner. A voluntary agreement has nevertheless been ruled out on the basis of the following arguments: first, the opinions within the stakeholders about some of the key aspects included in the policy options are very divergent, and in the view of those opinions a voluntary agreement is unlikely to satisfy a significant part of stakeholders, mainly a good number of Member States and NGOs. Moreover, the energy efficiency targets proposed by the industry are significantly less demanding than the targets proposed in this IA and would undermine the achievement of the objectives set out in section 4. Finally, the industry has not shown any interest in putting forward a proposal of voluntary agreement. The Commission has therefore taken the view that the industry is not ready to adopt a voluntary agreement that is at the same time representative of the vast majority of stakeholders, demanding in terms of energy efficiency, and which can be in place before the date of application of a legislative amendment.

5.3.2.Modification of the verification tolerances

From the review study and dialogue with stakeholders it follows that the current tolerances are in line with the accuracy of the current testing procedures, conclusion that has been confirmed by a round robin test run by the main manufacturers during 2017. There is therefore no reason to modify the verification tolerances.

6.What are the impacts of the policy options?

This section describes the impacts of each policy option. Modelling principles follow the MEErP (Methodology for Ecodesign of Energy-related Products) 53 . The analytical model has been specifically developed for impact assessments by the external consultant Viegand Maagøe, and the assumptions have been systematically crosschecked with stakeholders, in particular with the industry. Future energy prices and carbon intensities follow the EU Reference Scenario 2020. More information on the methodology followed and the assumptions underlying each policy option are provided in Annex 4.

In the view of the current context of energy crisis the use of REF2020 scenario, which features very moderate energy prices, raises the question on whether the analysis based on that scenario is realistic. Increasing electricity prices pushes up consumer expenditure and could call for further and more ambitious measures to offset the growing energy bill. Annex 8 already includes a sensitivity analysis based on the MIX scenario 54 , with higher energy prices and lower carbon intensity vis-a-vis REF2020. However, even the prices from the MIX scenario are too low compared to the latest ones. Since there is no modelling available corresponding to the current situation and therefore a fully-fledged IA cannot be carried out, a preliminary affordability analysis is conducted in section 8 to have a first and general overview on how ecodesign and energy labelling measures could be modified to respond to a situation of escalating electricity prices.

Notes regarding the assessment of the impacts

-For the analysis of the impacts, PO2 will be included in all combinations of policy options because the rescaling of the label is a mandatory requirement.

-None of the policy options are assumed to change the total stock estimated for BAU. PO2 and PO3 only vary the share of the different types of tumble dryers. 

-PO4 does not change the distribution of the stock, only the lifetime of tumble dryers, which is assumed to increase from 12 to 14 years, and the costs associated to repair.

-PO4 increases the repair costs from 5€/year under BAU to 8€/year.

-User expenditure consists of the sum of the purchase costs (which includes end-of-life costs that are normally paid by the user through a levy at purchase), running costs (energy costs during operation of the appliance), and maintenance and repair costs.

-For the calculation of turnover, a 47%/39%/14% split of the consumer price has been assumed between industry/retailer/tax, based on estimates from the sector. 

-Price increase are fully carried over to the consumer.

-The impact on employment for manufacturers and retailers is estimated from the turnover, with a correction for changes in labour productivity as explained in Annex 4. Based on historical manufacturing data, an increase of 1% in turnover will lead to a 0,6% increase in workforce, and a 1% decrease in turnover leads to a 1,6% decrease in workforce.

-Only direct and indirect jobs in the production and distribution chain are considered, i.e. including employment generated in suppliers and business services but excluding induced employment effects due to spill-overs on other sectors.

-Figures on industry turnover and employment comprise both the manufacturing and repair sectors. For policy options including PO4, the repair sector figures corresponding have been disaggregated from the rest of the industry to illustrate the influence of spare parts availability on that sector.

6.1.PO2 – lenient option: energy labelling measures

6.1.1.Environmental impacts

Rescaling the energy label will have two effects, one on industry and the other on the consumer: on the industry, it will incentivise the development of better performing tumble dryers and on the user, it will contribute to a moderate replacement of purchases of air vented and heating element tumble dryers by heat pump systems. This will increase the presence of heat pump tumble dryers on the market and will subsequently yield some energy savings and a limited reduction of GHG emissions. The difference of energy consumption between BAU and PO2 is small, first because PO2 does not bring a massive replacement of other models by heat pump tumble dryers, as no new mandatory energy efficiency thresholds are put in place, and second because no strong improvements are expected on energy efficiency per unit as heat pump is already a mature technology. Even under BAU the share of heat pump tumble dryers increases over time, and the gap between BAU and PO2 will progressively diminish, by 2050 only around 300.000 out of a total stock of 76 million heat pump tumble dryers would remain.

The reduction of total energy caused by PO2 with respect to BAU (1,9% in 2040) is slightly smaller than the reduction of in-use energy (2,5% in 2040) due to the more complex production of heat-pump tumble dryers, with higher embedded energy and associated GHG emissions than the simpler air vented and heating element systems. Cumulative GHG emissions slightly increase in 2030 due to embedded energy, but are offset in the longer term by savings of in-use energy.

Figure 6-1. Total energy consumption for PO2 and BAU

Table 6-1. Environmental impacts for BAU and PO2

6.1.2.Economic impacts

The rescaling of the energy label will not bring about a significant change on manufacturers and retailers turnover with respect to BAU, just a small increase on both due to the larger share of heat pump tumble dryers and their associated higher prices. By 2050 there will still be some turnover difference between BAU and PO2 due to the slightly higher market share and better energy efficiency of heat pump appliances.

As far as user expenditure, it presents some particularities. In the periods 2025-2028 and 2038-2050 user expenditure is bigger for PO2 than for BAU. In the first period, the short time elapsed since PO2 applies does not allow the in-use savings to offset the higher purchase prices. Between 2038 and 2050, BAU will have gained a significant share of heat pump tumble dryers thus reducing the distance with PO2, for which the small difference of in-use energy savings between both scenarios cannot offset the higher prices still paid due to PO2. Between 2028 and 2038, the in-use energy savings with PO2 will be enough to offset the higher purchase prices and will be lower than with BAU.

Figure 6-2. User expenditure for PO2 and BAU

Table 6-2. Economic impacts for PO2 and BAU

6.1.3.Social impacts. Employment

Employment for PO2 follows a trend similar to turnover, namely a small increase with respect to BAU which remains more or less stable until the end of the considered period.

Table 6-3. Employment (manufacturers + retailers) in EU for PO2 and BAU

6.2.PO2 + PO3 – ambitious option: rescaling of the energy label and new energy efficiency limits

6.2.1.Environmental impacts

New energy efficiency limits will prevent the placing on the market, as of 2026, of appliances with an EEI > 85, namely heating element, air vented and the least efficient heat pump tumble dryers. This results in an important reduction of total energy consumption with respect to BAU (11% in 2040), which is nevertheless smaller than the reduction of in-use energy (14% in 2040) due to the complexity of heat-pump tumble dryers, as explained in section 6.1.1. The levelling of energy consumption around 2040 arises as heat pump tumble dryers will be close to reach the 100% of the existing stock and only minor energy efficiency gains will take place after that. After 2040, the difference between BAU and PO2+PO3 becomes smaller but remains significant because under BAU there will still be around 2 million heating element tumble dryers in use beyond 2050.

The cumulative GHG emissions displayed in table 6-4 show that the higher carbon footprint of heat pump appliances will initially produce an increase of GHG emissions over BAU, although the gap will progressively reduce due to the better efficiency of heat pump systems.

Figure 6-3. Total energy consumption for PO2+PO3 and BAU

Table 6-4. Environmental impacts for PO2 and BAU

6.2.2.Economic impacts

The stricter ecodesign measures will bring a steep increase in manufacturers turnover compared to BAU during 2026, when PO3 enters into application and heat pump tumble dryers make up 100% of sales. After 2026, the gap between both scenarios becomes smaller and by 2050 reaches its minimum value within the period of analysis, when sales of heat pump tumble dryers in the BAU scenario are maximised.

User expenditure will sharply rise during 2026 due to the sudden increase of prices caused by the immediate phase-out of non-heat pump tumble dryers, although in-use energy savings will quickly and progressively offset the price increase, fully offsetting it by 2031. After 2031, the savings from PO2+PO3 compared to BAU reach their maximum in 2040 and then progressively decrease until 2050, when heat pump tumble dryers under BAU will have reached 97% of the stock.

Figure 6-4. User expenditure for PO2+PO3 and BAU

Table 6-5. Economic impacts for PO2+PO3 and BAU

6.2.3.Social impacts. Employment

Employment follows a trend similar to turnover. There is a significant increase with respect to BAU but the difference decreases as heat pump tumble dryers gain market share under BAU.

Table 6-6. Employment (industry + retailers) in EU for PO2+PO3 and BAU

6.3.PO2 + PO4 – rescaling of the energy label and circular economy measures

6.3.1.Environmental impacts

Until 2031, the impact of PO2+PO4 in energy consumption comes solely from PO2 (rescaling of the energy label). From 2032 onwards, PO4 starts to yield energy savings as some of the tumble dryers sold during 2025 fail and are repaired instead of being discarded, reducing the sales of new appliances and consequently the consumption of embedded energy. The energy savings from PO4 reach a maximum in 2039, when the vast majority of tumble dryers sold in 2025 have failed because reaching the end of their lifetime (14 years) and need to be replaced. The total energy consumption will then increase due to the energy embedded in the production of new tumble dryers, which activity needs to be speeded up to replace the old devices. Energy consumption will reach a peak in 2047 and will decrease again afterwards. That peak will remain nevertheless lower than PO2, because new tumble dryers will also be repaired instead of discarded and this will be reflected in less units being produced and subsequently less embedded energy.

Figure 6-5. Total energy consumption for PO2, PO2+PO4 and BAU

Table 6-7 displays PO4 as standalone policy measure in order to observe the trade-off between the increase of in-use energy consumption caused by the longer lifetime of tumble dryers and the decrease of embedded energy consumption during production and EoL. PO4 increases by 0,05 TWh/year the in-use energy consumption in 2040, but this is more than offset by the 0,61 TWh/year decrease of embedded energy consumption, so that the total energy saving is 0,56 TWh/year. This same effect occurs with PO2+PO4.

Table 6-7. Environmental impacts for PO2+PO4 and BAU

6.3.2.Economic impacts

From 2025 until 2034 industry turnover increases with respect to BAU due to two separate effects: on the one hand, the expected increase of sales revenues combined with a higher average price per unit as heat pump tumble dryers tend to dominate the market; on the other hand, the increase of repair costs per unit due to the application of PO4 (repair costs are included as part of the industry turnover in this model). In 2034 sales start to decrease as the share of failing tumble dryers that are repaired increases, bringing turnover down until 2039, in which the production speeds up to replace the tumble dryers reaching the end of their lifetime and to satisfy the new stock being needed. A new peak is reached again in 2046 and the process repeats, although the overall turnover values are somewhat higher due to the increase of sales.

The increased activity in the repair sector contributes to mitigate the turnover reduction in the industry due to the deceleration of the production. The growth of turnover in the repair sector is related to both the continuous increase of the stock of tumble dryers and the increase of the repair expenses per unit. For retail turnover, which is based exclusively on the sales of appliances, the drop of sales is not mitigated in any way, resulting in a net loss of cumulative employment by 2040.

User expenditure undergoes similar changes as industry turnover, namely a first phase of growth until 2034 due to the combined action of higher prices, increase of sales and additional repair costs, to drop by 2034 due to the reduction of sales induced by the extension of the lifetime of the appliances.

Figure 6-6. User expenditure for PO2, PO2+PO4 and BAU

Table 6-8. Economic impacts for PO2+PO4 and BAU

6.3.3.Social impacts. Employment

Employment for PO2+PO4 behaves similarly to turnover, this is an increase until 2034 due to a growth of repair activity that does not greatly affect sales, to drop afterwards as long as tumble dryers start to fail in a significant number. In 2039 employment grows again due to the need to increase manufacturing activity to replace the tumble dryers reaching the end of their lifetime. Nevertheless, with PO2+PO4 employment will not recover the levels under BAU due to the total reduction of the sales of new appliances. As for turnover, table 6-9 shows that repair activity contributes to mitigate the manufacturing job losses that are the consequence of the reduced production.

Table 6-9. Employment (industry, including repairers + retailers) in EU for PO2+PO4 and BAU

6.4.PO2 + PO3 + PO4 –rescaling of the energy label, new energy efficiency limits and circular economy measures

6.4.1.Environmental impacts

Until 2031, the decrease in energy consumption follows the same curve as described in section 6.2.1 for PO2+PO3, as the benefits from PO4 are only realised in the long term. From 2032 onwards, PO4 starts to impact as described in section 6.3.1, resulting in the combination leading to the biggest energy savings across all policy option combinations.

Figure 6-7. Total energy consumption for PO2+PO3+PO4, PO2+PO3 and BAU

Table 6-10. Environmental impacts for PO2+PO3+PO4 and BAU

6.4.2.Economic impacts

The fluctuating evolution of turnover explained in section 6.3.2 for PO2+PO4 also takes place for PO2+PO3+PO4, although with differences linked to the greater presence of heat pump tumble dryers in the market. This causes turnover for PO2+PO3+PO4 to grow faster than for PO2+PO4 in the periods of increasing turnover, and to go down faster in the periods of decreasing turnover. This can be verified by comparing the yearly values in tables 6-10 and 6-11.

User expenditure also follows the same pattern as PO2+PO4, yet for PO2+PO3+PO4 consumer costs in the mid-to-long term are in general smaller due to bigger energy savings.

Figure 6-8. User expenditure for PO2+PO3+PO4 and BAU

Table 6-11. Economic impacts for PO2+PO3+PO4 and BAU

6.4.3.Social impacts. Employment

The behaviour explained in section 6.3.3 with respect to PO2+PO4 applies here, with the particularity that job creation until 2035 is stronger than for PO2+PO4 because heat pump appliances are more labour intensive than other tumble dryers, although later job losses are also more significant.

Table 6-12. Employment (industry, including repairers + retailers) in EU for PO2+PO3+PO4 and BAU

6.5.Additional impacts jointly assessed for all policy options

6.5.1.Payback period (affordability)

Payback period is calculated first by subtracting the yearly savings for each policy option (energy savings and savings due to the extension of the lifetime of the appliance) from the yearly increase of costs with respect to BAU (additional repair costs). The annual differences are multiplied by a discount factor of 4% and accumulated to the previous ones to get, for each year, the net present value of the total savings at the moment of purchase of the appliance. For each year that the difference has been computed, it is compared to the purchase costs. The payback period is given by the year in which the net present value of the savings offset the extra cost.

For PO2, the increase of the purchase price is offset by the energy consumption savings, over an average payback time of 3,4 years. This is significantly below the estimated lifetime of 12 years. For PO2+PO3 the pay-back time is 4,1 years, still significantly below the 12-year lifetime. The energy savings are considerably higher for PO2+PO3 than for PO2, although the increase of the product price delays the time of recovery of the investment. PO2+PO4 and PO2+PO3+PO4 have longer payback periods because the in-use energy savings yielded by PO2 and PO2+PO3 respectively are not sufficient to offset the additional repair costs of 1,7 €/year from PO4. The benefit of repair is nevertheless noticed after the appliance is 12 years old, because this is when the lifetime is extended by two years in the assessment, from 12 to 14. The respective payback periods are 12 and 12,1 for PO2+PO4 and PO2+PO3+PO4, which are still lower than the 14-year average lifetime considered for any combinations of policy options incorporating PO4.

Table 6‑13. Affordability of each policy option

6.5.2.Costs

6.5.2.1.Compliance costs

Compliance costs in a specific year have been computed multiplying the yearly sales by the increase in average unit price vs BAU from table 6-10. In the absence of data on costs incurred by the industry related to making available spare parts, 50% of the repair costs per unit used for the payback period have been considered to be compliance costs, considering that for each repair, 50% of the cost corresponds to the price of the component (equivalent to 13,8 €) and 50% to manpower and travel costs. Costs to the manufacturer for making available spare parts are then 13,8 €/unit, which must be added to the total compliance costs for PO2+PO4 and PO2+PO3+PO4. This increase of compliance costs will be compensated by less manufacturing costs due to the reduction in the number of units produced.

Table 6‑14. Compliance costs by measure

Other minor compliance costs which are not expected to influence the turnover are:

- Making available repair and maintenance information, as well as information on recycling following the new circular economy requirements. Manufacturers will be nevertheless able to offset the additional cost by charging a proportionate fee to repairers for the availability of repair and maintenance information.

- Updating the information on availability of spare parts and recyclability on the manufacturers websites or importers. The TD Ecodesign Regulation already requires certain inf    ormation to be provided on the websites of the manufacturers and in the technical documentation, thus being assumed that the additional required information could be updated at negligible extra cost for the manufacturers.

6.5.2.2.Administrative costs

Administrative costs are defined as those costs borne by businesses, citizens, civil society organisations and public authorities as a result of administrative activities performed to comply with administrative obligations included in legal rules.

There will be extra administrative costs due to the update of the Declaration of Conformity (DoC) for the existing models. This update will be necessary following the reclassification of the products according to the rescaled energy label and the modification of the process for the calculation of the EEI. In addition, the new class will also need to be declared in EPREL. A time of 0,50 hours has been estimated for the update of the DoC and additional 0,50 hours for the update of EPREL information. Those times are multiplied by the estimated number of existing models (5.772) 55 and by the EU average hourly labour cost for 2021 (32€/h) 56 , resulting in a total of 184.704 € (around 0,01% of the manufacturing turnover). For new models, the administrative costs are business as usual and they do not need to be quantified as new costs.

In addition, there will be administrative costs due to relabelling, as suppliers will have to provide two labels instead of one for a period of 6 months at a cost of 0,3 EUR to print a label. For 2,8 million household tumble dryers sold in 6 months, this means a total cost of approximately 851.550 € for suppliers to temporarily provide a second label for a transition of one label to another.

The total of these administrative costs (around €1m) are one-off costs representing around 0.05% of turnover in the year that they occur. There are no recurrent administrative costs.

6.5.3.Indirect employment

A good understanding of the employment effects of the measures on the society would require general equilibrium economic modelling. In any case, the likely effect is small enough to be difficult to identify with any certainty at the economy-wide level. The dominant economic impact is expected to arise from the avoided expenditure on energy by consumers due to the improved performance of the products, resulting in a net saving that will be spent in other areas of the economy. Although it cannot capture many of the likely interactions, a first indication of the scale of the effect is given by taking account of the differing employment intensity of the energy supply sectors and the general economy. It is assumed for the purpose of the assessment that these do not change in the coming decades. Estimates of employment intensity for the relevant sectors calculated from Eurostat data are: for the electricity, gas, steam and air conditioning supply sector (NACE D), 0,9 jobs/M€, and for the rest of the economy, 8,1 jobs/M€.

Table 6-12 provides the direct employment of the different policy options as calculated in the previous sections, the indirect employment and the net balance. The reduction of in-use and embedded energy consumption destroys employment in the energy generation sector, but the additional budget available to consumers due to both the reduction of the energy bill and the delay in the purchase of new appliances generates employment on the rest of the economy.

Table 6‑15. Cumulative employment on the tumble dryer sector, on electricity supply and on the rest of the economy and final net employment

6.5.4.Competitiveness 

PO3 is the option with the most significant impact on manufacturers since it will them adapt their facilities to 100% heat-pump tumble dryer production. Nevertheless, as heat pump tumble dryers are already being placed in the market in large quantities it is not expected that the needed adaptations will have any impact on their competitiveness. In this context, the only issue that companies may encounter in their adaptation to the new ecodesign requirements is the time needed to convert their production facilities. This aspect is addressed in this IA by providing a transitional period.

The other sector that may be affected by the policy options, in particular by PO2+PO4 and PO2+PO3+PO4, is the repair industry, made up of SMEs with an average of two employees 57 per company. In this case however, the repair industry will benefit, as their turnover will be increased without any additional investment. 

In the view of the above and of the indications provided in Tool#21 of the Better Regulation Guidelines, it is considered that no further assessment of impacts on competitiveness is needed in this IA.

6.5.5.Fundamental rights 

The policy options under assessment do not entail any negative impact on fundamental rights as laid down in the Charter of Fundamental Rights of the European Union 58 . Only positive impacts can be expected, first on the right to environmental protection thanks to the reduction of GHG emissions, and second on the right to consumer protection, resulting from the enhanced reparability of the products, the expected reduction of the energy bill, and the better consumer information consequence of the improvement of the energy label. 

6.5.6.Geographical distribution 

PO2+PO3 and PO2+PO3+PO4 will eliminate the least performant and cheapest tumble dryers from the market. Member States with lower household incomes are more vulnerable to the increase of prices accompanying those policy options than Member States with higher household incomes like France or Germany. This also happens to a lesser extent with PO2 and PO2+PO4. The penetration rate of tumble dryers in Southern Member States is low and it will be Eastern Member States, which account for 20% of EU tumble dryer ownership as displayed in Figure A12-2 in Annex 12, that are likely to be more negatively affected by the rising purchase costs. Section 6.5.1 shows that the increase of the prices will be offset by energy savings, which in principle would make the more ambitious policy options also interesting in Easter Member States. Nevertheless, the calculations have been carried out with average EU prices, but the reality is that energy costs greatly vary between Member States, and according to the prices for the second semester of 2021 taken from Eurostat 59 , Eastern European Member States generally have lower electricity prices than those in Western Europe. 

To identify the electricity price threshold that would make the different policy options interesting at national level, the same methodology as in section 6.5.1 can be used, keeping the same parameters but imposing a 12 or 14-year payback (depending on the average lifetime of a tumble dryer under the different policy options). This gives the threshold for the electricity price that would allow to offset the purchase costs within the lifetime of the appliance via savings in the operating costs. This shows that the minimum energy price to offset purchase costs in 14 years for PO2+PO3+PO4 is 0,14 €/Kwh, which would leave Croatia, Bulgaria and Hungary as the only Member States where this policy option would not bring benefits because they have lower electricity prices. These three countries have a very minor share (around 2%) of the EU market of tumble dryers. For PO2+PO3, the threshold would be 0,11 €/Kwh and only Hungary would not benefit from that option because of its very low electricity prices.

It can be concluded therefore that, in general, the impact of the policy options would not bring benefits with historic electricity prices in a limited geographical area which accounts for a very small share of the market. In the current context of much higher electricity prices analysed in section 8.4, it is possible that the abovementioned countries would also benefit under the most ambitious policy options.

7.How do the options compare?

The options identified are individually assessed against the two first specific objectives set out in Section 4. Each option is assessed for its effectiveness in achieving those objectives, its efficiency in doing so and its coherence. The third objective is addressed by measures that will be included in any of the policy options, and therefore it does not need to be addressed.

7.1.Effectiveness

Effectiveness refers to the extent to which the proposed policy options combinations would achieve the objectives set out in Section 4. Effectiveness has been assessed from two angles: cumulative energy savings (Effect1), which will also lead to a proportionate reduction of GHG emissions and acidification, and resource efficiency (Effect2) in terms of cumulative reduction of fuel use (coal/lignite, petroleum products, natural gas and biomass/waste) and cumulative reduction of material use for the production of tumble dryers. Besides the impacts considered in Effect2, further impacts related to resource efficiency/circular economy will be assessed in Annex 7. The values used for the calculation of the efficiencies are cumulative, and the periods of analysis are from 2025 (year of implementation of the policy option) to 2030 and from 2025 to 2040.

Table 7‑1. Effectiveness of the different measures

Table 7-1 shows that all measures lead to a reduction of energy consumption (Effect1), with PO2+PO3 achieving the greatest savings in terms of in-use energy. PO2+PO3+PO4 is the option that delivers the largest total energy savings due to the extension of the lifetime of the appliances and the subsequent reduction of manufacturing activity.

As far as Effect2, PO2+PO3 yields the biggest mass of fuel saved due to the reduction of in-use energy consumption, and PO2+PO4 is the option that saves more material because enhanced reparability reduces the level of production.

Considering jointly both Effect1 and Effect2, PO2+PO3+PO4 appears as the best option, as it is the best in Effect 1 (considering total energy) and also Effect2 (considering the sum of fuel and material savings). For Effect2, PO2 and PO2+PO3 have been scored as neutral because they decrease the mass of fuel consumed but increase the material used by a similar amount.

Trade-offs

Table 7-1 shows a trade-off between the extension of the lifetime of the appliances and the increase of in-use energy consumption. By 2040 PO2+PO3 saves 0,32 Twh more in-use energy than PO2+PO3+PO4. This is because PO4 extends the lifetime of tumble dryers by two years, from 12 to 14, resulting in less efficient appliances remaining in use for a longer time. Nevertheless, the embedded energy saved by the PO4 component largely offsets the excess of in-use energy consumed, and the net balance is 2,5 Twh in favour of PO2+PO3+PO4. The trade-off happens as from 2034, when tumble dryers start to fail. There is also a similar trade-off between PO2 and PO2+PO4, although in this case the replacement of conventional tumble dryers by heat pump tumble dryers is significantly lower, which means that the in-use energy consumption difference between PO2 and PO2+PO4 due to the extension of the lifetime of the appliances is almost insignificant.

7.2.Efficiency

This section assesses the benefit generated per monetary unit spent by the consumer for each policy option with respect to BAU, or in other words, the efficiency of consumer expenditure in generating the benefits addressed in section 7.1, namely in-use energy savings (Effic1), embedded energy savings (Effic2), fuel savings (Effic3) and material savings (Effic4).

The analysis performed in section 6.1 already shows that the investment carried out by the consumer in newer and more energy-efficient equipment following the application of PO2 and PO3, reduces in-use energy, GHG emissions and fuel consumption. Circular economy measures included in PO4 in turn, reduce consumer expenditure in new equipment, leading to a subsequent decrease in the use of embedded energy, material for manufacturing and GHG emissions, but at the same time have a negative influence on in-use energy consumption. In other words, the variation of in-use energy consumption is due to an investment made by the consumer on both the purchase of new equipment (which decreases in-use energy consumption) and on repair costs (which increases it), whereas the reduction of embedded energy is solely the consequence of an investment on repair costs. It is convenient therefore to assess in-use energy savings and embedded energy savings separately, as they are the consequence of different investments from the consumer. On the same basis, fuel and manufacturing material consumption will also be assessed separately. Consequently, consumer expenditure for calculating Effic1 and Effic3 will add both the purchase of new equipment and the repair costs, whereas for Effic2 and Effic4 only repair costs will be used.

The values used for the calculation of the efficiencies are cumulative rather than annual, because of the time gap between the year of the consumer investment and the return on that investment, which takes place over several years until the end of the lifetime of the appliance. A yearly value would not catch the effect of an investment made on that year, which will take place over the next years. It seems therefore more appropriate to use accumulated values over a period of analysis rather than a yearly value, as the former will give a more representative figure. The periods of analysis are from 2025 (year of implementation of the policy option) to 2030, and from 2025 to 2040.

Table 7‑2. Efficiency of the different measures

The first aspect to be noted from table 7-2 is that PO2+PO4 features negative Effic1 and Effic3 values for 2040 (shown in red). This does not mean that PO2+PO4 is inefficient, but happens because the total consumer expenditure for PO2+PO4 is smaller than for BAU, since the economic saving due to lengthening the lifetime of the appliance offsets the increase of purchase and repair costs. The consumer investment with respect to BAU is therefore negative compared to BAU and turns the efficiency value also negative, meaning that PO2+PO4 is able to save in-use energy and fuel even with a consumer expenditure that is smaller than BAU. The negative net investment only happens in the long term, and therefore only for 2040 and not for 2030, as circular economy measures are noticed from 2034. Apart from this particular case, PO2+PO3+PO4 is the most efficient policy option as regards Effic1 and Effic3, as each € invested by the consumer will save 13,3 Kwh of in-use energy and 47,1 tons of fuel in 2040.

As far as Effic2 and Effic4, the only policy options producing positive efficiencies in the long term are PO2+PO4 and PO2+PO3+PO4, as they are the only ones that produce embedded energy savings and therefore allow to reduce the material used during the production phase. PO2 and PO2+PO3 are not efficient at reducing material use or embedded energy because the complexity of manufacturing heat pump tumble dryers increases the embedded energy used throughout the whole period of analysis.

7.3.Coherence with other EU policies and legislative framework

7.3.1.Coherence with the overarching objectives of EU policies

The proposed measures are fully consistent with energy and environmental EU policy goals such as set out in the Green Deal. In particular the options contribute explicitly to the EU’s climate ambition for 2030 and 2050 and mobilising industry for a clean and circular economy as discussed in that Communication. The options have also been assessed to ensure as far as possible a simplification of requirements in line with Better Regulation goals. Nevertheless, some of the measures are more consistent than others with the Green Deal objectives. In particular, PO2 and PO3 will produce an increase of embedded energy that will result in total energy consumption going up in the first three to five years of application of the measures, with a corresponding increase of GHG emissions. This is later offset by means of better energy efficiency. Since the circular economy measure contributes to reduce embedded energy, it can be concluded that including PO4 will enhance coherence with the Green Deal objectives. PO4 will also enhance coherence with the European Climate Law, since circular economy has been recognised as one of the essential elements to achieve climate neutrality.

7.3.2.Coherence with Article 15(5) of the Ecodesign Framework Directive

All policy options fulfil the criteria set out in Article 15(5) of the Ecodesign Framework Directive, as shown in table 7-4.

Table 7-4. Evaluation of policy options in terms of their impacts compared to the baseline (BAU)

All policy options are coherent with Article 15(5) of the Ecodesign Framework Directive, although with different degrees. In particular, PO2 and PO3 lead to an initial increase of purchase prices and consequent negative impact on consumers, which is later offset by means of better energy efficiency. PO4 does not increase prices and is therefore somewhat more coherent with Article 15(5) than the other two. However, PO4 on its own would lead to very limited benefits, being necessary to combine it with more effective measures.

7.4.Coherence with the proportionality and subsidiarity principles

Subsidiarity has already been assessed in section 3. All policy options have implications for the design and characteristics of the products and are therefore better addressed at EU rather than national level in order to ensure the correct functioning of the internal market.

As far as proportionality, as indicated in section 5, the most ambitious policy options PO2+PO3 and PO2+PO3+PO4 will accelerate the current market tendency towards a growing share of heat pump tumble dryers. Heat pump tumble dryers have been marketed for over a decade and can be considered as a mature technology, although some moderate future improvements on energy efficiency are expected to take place. The EEI proposed will only remove a part of the current market of heat pump tumble dryers besides heating element and air vented appliances, but will still leave 63% of the current models in the market. This implies that PO3 is proportional to the objectives, yielding energy savings whilst not setting targets that are difficult to achieve and that could significantly raise production costs causing affordability problems or too long payback times. Nevertheless, both PO2 and PO3 have short-term negative impacts on user expenditure and energy consumption, as indicated in sections 7.2 and 7.3.

There will be additional but very limited one-off administrative costs because there is no modification of the certification procedure. These have been calculated in section 6.5.2.2.

Concerning national authorities, there is no modification of the current market surveillance framework and therefore no additional burden.

8.Preferred option

8.1.Preferred policy option

Based on the analysis presented in sections 6 and 7, PO2+PO3+PO4 is the preferred policy option from the point of view of effectiveness. This option provides the largest energy savings and GHG emissions reduction potential. PO2+PO3+PO4 is also the best option regarding total material (fuel + manufacturing) saved.

From the point of view of efficiency, PO2+PO3+PO4 the best option, with the highest in-use energy and fuel savings per monetary unit invested, and the second highest savings of primary energy and material used for production after PO2+PO4.

When efficiency and effectiveness are jointly considered, it looks clear that PO2+PO3+PO4 is the most balanced option, as it is as efficient as PO2+PO4, and is significantly more effective.

Table 8-1. Summary of cumulative values for the preferred policy option (PO2+PO3+PO4)

A more detailed summary of the results for the preferred policy option is displayed in Annex 3, including a monetisation of GHG emissions.

8.2.REFIT (simplification and improved efficiency)

A number of the measures proposed in this impact assessment will simplify the application of the legislation and reduce the legislative burden, in particular:

-The simplification of the layout of the energy label by aligning it with the washer dryers label will reduce labelling costs for manufacturers and increase understanding for consumers. 

-The availability of documentation at the manufacturers’ website concerning dismantling and recycling will make it easier for EoL processers to comply with the WEEE Directive. 

-Legislative redundancies as regards low power modes are avoided by removing tumble dryers from the scope of the Horizontal Standby Regulation and adding the corresponding requirements in the TD Ecodesign Regulation.

-The number of test runs for the calculation of the condensation efficiency under the TD Ecodesign Regulation will be aligned to the number of test runs set out in the harmonized standard EN 61121:2013 60 , thus removing ambiguity and legal uncertainty.

8.3.Application of the ‘one in, one out’ approach

As explained in section 6.5.2.2, there will be around 1 M€ administrative costs linked to the modification of the energy efficiency classes, which obliges manufacturers to draft an updated DoC for each model and makes suppliers to have to update the corresponding data in EPREL. No potential cost savings in administrative activities performed by businesses were identified that could be included in the current revision of the legislative framework on tumble dryers.

8.4.Overview in the context of current energy prices

Energy prices are sharply increasing due to the current situation of political instability. This increase, which was not foreseen when the review study was carried out, could encourage the introduction of more stringent ecodesign measures, because higher prices would push up operating costs and would call for even more demanding policies on energy efficiency. For instance, a stricter EEI lower than the proposed 85 could have been set for PO3.

It is not possible at this stage to make a fully-fledged evaluation of impacts considering current energy prices because the available scenarios have not yet been updated with those prices in time to be included in this report. It is however possible to carry out an analysis of the impact on affordability (payback period) of introducing additional ecodesign measures. Affordability is a key parameter as it measures directly the impact of the measures on the consumer. Other impacts such as lowering energy consumption or GHG emissions can only improve with the inclusion of stricter ecodesign measures, but this does not mean that the latter are affordable or economically viable.

The analysis in this section considers a stricter PO3 (PO3str) with an EEI ≤ 71, so that only tumble dryers belonging to the A to C classes of the energy label instead of A to D can be placed on the market. The affordability analysis is carried out for PO2+PO3str+PO4 with both REF2020 prices and the more recent EU electricity prices (2 semester 2021) for household consumers made available by Eurostat 61 . The latter are assumed to remain constant over the period of study, from 2025 to 2050. Electricity prices will in reality vary with time, but it is not possible to predict that variation reliably. Using fixed energy prices can give an idea of whether stricter ecodesign requirements could be justifiable. The result of the affordability analysis is given in table 8-1. 

Table 8‑1. Affordability under higher energy prices

The inclusion of stricter ecodesign measures with REF2020 and with 2021 electricity prices is not cost-efficient, because the purchase price of tumble dryers will increase by 17% and the energy savings will not offset the increase in purchase cost. Figure 8-1 shows that with the higher electricity prices the Least Life Cycle Cost is in class D, which will be excluded from the market by setting the minimum EEI = 71. The purchase price dominates the life cycle cost for the high efficiency appliances, and above class D it is no longer cost-efficient to set stricter requirements, with the energy prices considered.

Figure 8-1. Costs distribution by energy label class with 1st semester 2021 prices

Nevertheless, as energy prices increase payback periods get significantly shorter and at a price of 0,340 €/Kwh payback period it is 13 years. Thus for prices consistently above 0,340 €/Kwh, more stringent ecodesign limits are interesting from a consumer point of view. This context of high prices needs to be nevertheless sustained in order to reduce the payback time below the average lifetime of tumble dryers.

9.How will actual impacts be monitored and evaluated?

The main tool to verify compliance with ecodesign and energy labelling requirements is the market surveillance carried out by national authorities. Further, homogeneity of market surveillance actions at EU level is guaranteed by the Administrative Cooperation Groups, under which MSAs and the Commission meet several times per year with the objective to ensure efficient, comprehensive and consistent market surveillance across the Union.

In addition, surveillance activities are supported by the Commission through EEPLIANT3, which is a Horizon 2020-funded project with a budget of €6,85 million 62 , involving a consortium of MSAs. The project runs from June 2019 until November 2023 and includes a work package on tumble dryers 63 . In the frame of EPPLIANT3, MSAs carry out market surveillance activities on their national markets and make recommendations that can be used later by national authorities in their regular enforcement activities. Those activities are focused on document inspections, analysis of the content of web-shops, verification of EPREL data and testing of appliances. 

The summary of the results on tumble dryers is the following: on the document inspection chapter, the rate of non-compliance has been high, either due to missing documents or errors in the information provided. However, after MSAs enquiry a significant amount of information was returned, which proves the positive effect of enforcement on documentation quality. Regarding online sites inspections, the results have not been positive due to the general lack of knowledge about the legislative requirements on websites. EPREL inspections show acceptable results, being the percentage of tumble dryers not present in EPREL remarkably reduced through enforcement, from 24% to 11%. On the negative side, the percentage of missing entries for each model is still high. Finally, as far as testing, the percentage of dryers with severe problems is low. However, it must be noticed that the time for discussions between MSAs and economic operators is sometimes very long.

All in all, EPPLIANT3 has identified specific parameters with different levels of compliance. MSAs will need to take the EPPLIANT3 conclusions into account in order to optimise efforts by focussing on those specific issues where level of compliance is deficient. This will also apply to the enforcement of the upcoming TD Ecodesign and Energy Labelling Regulations.

Finally, the revised TD Ecodesign and Energy Labelling Regulations will include a review clause that will mandate, inter alia, the evaluation of the effectiveness and regulatory efficiency and relevance of the revised regulations 5 years after their entry into force. The results of this evaluation, which will involve the acquisition of independent market data as well as extensive stakeholder consultation, should be presented to stakeholders and Member States in the Ecodesign and Energy Labelling Consultation Forums. In addition, the European Commission will be regularly analysing the latest updated data of the database EPREL, in order to monitor the evolution of the market as regards of energy efficiency, condensation efficiency, refrigerants used in the appliances and level of noise. This will allow the Commission to early detect possible technical improvements that can be assessed in future revisions.

Annex 1: Procedural information

1.Lead DG, Decide Planning/CWP references

DG ENER, PLAN/2019/5480 (Ecodesign) and PLAN/2019/5479 (Energy Labelling), Commission Ecodesign and Energy Labelling Working Plan 2022-2024 (C/2022/2026 final).

2.Organisation and timing

A draft of the impact assessment report was submitted on 21 March 2022 to the members of the Ecodesign and Energy Labelling Interservice Steering Group, involving the following DGs: SG, AGRI, BUDG, CLIMA, CNECT, COMM, COMP, DEFIS, EAC, ECFIN, ECHO, EMPL, ENV, ESTAT, FISMA, GROW, JRC, JUST, IDEA, MOVE, REFORM, REGIO, RTD, SANTE, SJ, TAXUD. A meeting took place on 4 April. There were no major comments, DG CLIMA asked to include in the impact assessment report that the latest proposal for a revised F-gas Regulation would ban the use of F-gases from 2025 in heat pump tumble dryers, In addition, DG CLIMA also asked to better reflect what is already prescribed in Article 12 of the F-gas Regulation to avoid contradictions or duplications.

3.Consultation of the RSB

The RSB was consulted on 25 May 2022. Prior to that, an upstream meeting took place on 21 March 2022, in which the Board provided several recommendations to DG ENER, highlighting in particular the need to ensure coherence with related initiatives, the importance to consider scenarios in line with the “fit-for-55” package, the relevance of the cost-benefit analysis as basis for the adoption of choices on the policy options and the inclusion of sensitivity analysis on crucial parameters.

4.Evidence, sources and quality

The departing point for this impact assessment is the review study carried out by the consultant Viegand Maagoe, finished and handed over to the Commission in May 2019. The review study provides some of the input data used for the baseline scenario and the modelling of the different policy options related to sales, stock and product prices, all of them split by product type. Sales data have been purchased to GfK, a reputed company in the field of data provision and analysis for the consumer goods industry. Stock data have been derived from sales and average lifetime for each product family. Average lifetime has been extensively discussed with APPLiA, the main industry interlocutor at EU level.

The EPREL database established by the Commission, which gathers information about all the models placed on the market since 2010, has been consulted for confirmation of data on energy efficiency and condensation efficiency per model.

Electricity prices and carbon intensity have been obtained from REF2020, in order to ensure coherence and consistency of the impact assessment baseline scenario with existing energy policies. The REF2020 electricity prices have nevertheless proved to be unrealistic in the context of the current energy crisis with escalating energy prices. Unfortunately, at the time of finalisation of this impact assessment no scenario incorporating the influence of the new situation on the energy market was available. For this reason, section 8.4 has been included in this IA, featuring a preliminary analysis on how higher energy prices could influence the configuration of the policy options and the choice of the preferred option. The electricity price taken for this analysis is the EU average electricity price of the second semester of 2021, which is still below current prices but it is the latest officially available for the whole EU. In the absence of information about the future evolution of electricity prices, it has been assumed that the electricity price considered in the analysis is fixed throughout the whole period. This assumption, even being a simplification, does not prevent drawing valid conclusions about the policy option to be chosen in a context of sharp rise of energy prices.

Annex 2: Stakeholder consultation (Synopsis report)

1.Review study and stakeholder consultations

The review study was launched in October 2017 and was completed in May 2019. It covered a technical, environmental, and economic analysis performed according to the MEErP methodology, in order to assess the need to update the requirements for household tumble dryers and to identify the corresponding policy options.

The study was developed in an open process, taking into account inputs from relevant stakeholders including manufacturers and their associations, environmental NGOs, consumer organisations and Member States. During the study, two open stakeholder consultation meetings were organised at the Commission premises in Brussels on 26 June 2018 and 4 December 2018. Drafts of the study were discussed at these meetings, reviewed and validated with input from stakeholders. A review of different consumer surveys was also presented as part of the results, including one carried out by APPLiA in 2018. Annexes VII and X of the review study present a thorough overview of the contributions from stakeholders to both meetings.

In addition, a dedicated open public website was set up on which the interim results and other relevant material were published. The purpose of the website was to facilitate the monitoring of the status of the study, get related information and be able to track the meetings taking place.

2.First Consultation Forum on 18 September 2019

The Consultation Forum consists of a balanced representation of Member State representatives, industry associations and NGO’s, in line with Article 18 of the Ecodesign Framework Directive.

A Consultation Forum specifically on tumble dryers was held on 18 September 2019. The Commission services prepared two Working Documents with separate ecodesign and energy labelling requirements, which were based on the policy options described in section 7.2.2 of the review study report (Table 60 of that study). The documents were circulated to the members of the Consultation Forum and were also provided to the secretariat of the Environment, Public Health and Food Safety (ENVI) Committee of the European Parliament for information. The minutes, working documents and stakeholder comments received in writing before and after the Consultation Forum meeting were posted on CIRCABC 64 . 11 documents with comments were received from the following stakeholders and Member States: APPLiA (providing three documents with comments), ANEC, ECOS (on behalf of ECOS, Coolproducts, EEB, Topten, Right to Repair, Rreuse), Denmark, Germany, France, Sweden, Austria, Bulgaria and the Netherlands.

3.Stakeholders comments during and after the consultation forum

The comments on the two Working Documents are summarized as follows:

-Scope: it was discussed if small capacity dryers should be left out of the scope of the TD Ecodesign Regulation. Two NGOs and three Member States proposed to include them with different rules in order to make it possible for them to continue being marketed, consisting of either less stringent EEI limits or a correction factor. Two Member States proposed to also include in those specific rules household tumble dryers that can be powered by batteries. Further, APPLiA and three Member States proposed to explicitly state that the regulation would not apply to products covered by the Machinery Directive. The option assessed in this IA is to include small tumble dryers in the scope, although exempting them from the new EEI limits.

-Name of the standard programme: APPLiA and some Member States supported to rename the standard cotton programme used during testing as ‘Eco’, to align tumble dryers with washing machines and to make clear to consumers what the best programme is in terms of energy efficiency. APPLiA also emphasizes that there should be some flexibility for manufacturers. For instance they should be allowed to additionally indicate the drying target and/or the type of textile: e,g, "cotton eco cupboard dry" and/or “cotton eco”. ECOS does not support the use of “eco” for the standard programme, but instead the use of the term “standard/normal”, since it would ensure that more consumers instinctively use that programme. In addition, NGOs and two MS representatives called to regulate other programmes or at least to regulate the most commonly used programme rather than the most efficient. This point needs to be discussed further with stakeholders before the legislative proposal is formalised, noting in the meantime that the final decision does not have any relevance for the assessment in this IA.

-Cycle time duration: two NGOs and five Member States proposed to regulate the duration of the standard programme to avoid extensively long cycle times. Moreover, two Member States proposed to limit the duration of the wrinkle guard function. A Member State proposed to include these requirements in a review clause for future updates of the legislation. As result of the discussion, a unique cap to the duration of all programmes is proposed in this IA. 

-Energy Efficiency Index (EEI) requirements: the NGOs and five Member States proposed to set very stringent EEI requirements. Among them, five NGO’s proposed EEI ≤ 80, with two NGOs proposing a second tier with EEI ≤ 60. The proposal in this IA is EEI ≤ 85, since this is the value that would phase out condenser and air vented dryers and even some of the least efficient heat pump tumble dryers. For further energy savings, incentive to manufacturers by means of the rescaling of the label is considered to be sufficient.

-EEI intervals in the energy label: nearly all stakeholders proposed to revise the current intervals, first to cater for the revision of the minimum EEI level and second, to make the distribution among all classes more even whilst making them consistent with a verification tolerance of 6%. Two Member States and APPLiA commented that the proposed intervals do not incentivise manufacturers to produce class A tumble dryers as the class is very hard to reach. The options considered provide a good balance between expected energy efficiency gains and the amount of effort that is necessary to achieve those gains.

-Calculation of Standard Energy Consumption per cycle (SEc): two NGOs proposed to align the calculation of SEc with the ecodesign and energy labelling legislation on washing machines and APPLiA commented that current correction factors are too high and would prevent tumble dryers reaching class A.

-Condensation efficiency: two Member States proposed to set two stages to reach a more demanding minimum condensation efficiency, with 90% applicable from 2024. In addition, one Member State proposed to remove the split between full and half loads for the calculation of the average condensation efficiency (‘C’), since the conditioning cycle that is run in every test is able to level differences between both. APPLiA proposed to rescale the condensation efficiency classes by making them wider than the proposal. The IA keeps a minimum condensation efficiency of 80%, as it is considered that higher values could significantly increase the average price of tumble dryers, and because the benefit of efficiencies higher than 80% would only be noticed in very reduced enclosures with a very high humidity. Condensation efficiency classes have been removed.

-Spare parts availability requirements: NGOs and five Member States proposed to extend the list of available spare parts so that they are aligned to the lists provided in the washing machine ecodesign Regulation. In addition, the NGOs and three Member States proposed that spare parts should not only be available to professional repairers but also to end-users. APPLiA proposed to reduce spare parts availability time to 7 years to avoid unnecessary waste and stock, while two NGOs proposed to extend it to 12 years, which is the average lifetime of tumble dryers. Three Member States proposed to keep the European Commission proposal of 10 years. Two NGOs proposed to specify the definition of professional repairers in a way that it does not exclude credible repair actors. APPLiA also advised against the inclusion of the heat pump system in the list of spare parts, because the high costs and complexity of the replacement would mean the repair would not be cost-efficient. With this background, it is proposed that the TD Ecodesign Regulation include a list of spare parts that is similar to that in the Ecodesign Regulation on washing machines, since many of the components are of similar nature, and completing this list with components that are specific from tumble dryers. For safety reasons, the list should differentiate between parts available for consumers and parts restricted to professional repairers. Finally, the availability period should be 10 years, which is considered a reasonable mid-point. 

-Disassembly requirements: two NGOs proposed to include disassembly requirements for the materials and components listed in Annex VII of the WEEE Directive, in particular as regards the heat pump. Materials and components shall be easily disassembled with relevant information disclosed by manufacturers. APPLiA pointed out that replacing the heat pump is too costly and complex and that the environmental savings are not worth the replacement. The TD Ecodesign Regulation should not mandate tumble dryer design requirements to make disassembly easier because this measure could have a negative impact on costs. Nevertheless, enhanced information for disassembly and recyclability of the product will need to be available by manufacturers on a public website. 

-Filter maintenance requirements: two NGOs and one Member State proposed to include a requirement for the appliances to automatically signal when the filter needs to be cleaned and to provide guidance information on proper cleaning to avoid micro-plastic release. An alternative is to signal in a visible part of the appliance the need to periodically change the filters. 

-Low power mode requirements: APPLiA, two NGOs and three Member States proposed to include low power mode requirements in the TD Ecodesign regulation and remove them from the Horizontal Standby Regulation, in line with other ecodesign regulations such as washing machines. 

-Requirements on the use of high GWP refrigerants: two NGOs proposed the implementation of a rating system penalising the EEI when using high GWP refrigerants, as well as adding information to consumers about the type and GWP of the refrigerant. One Member State supported the inclusion of information about the refrigerant. 

-Requirements to restrict the use of halogenated flame retardants: two NGOs proposed to integrate restrictions on these chemicals for the largest components of the tumble dryer, as it has been done for the electronic display regulation. Product marking could be used as a complimentary tool. Nevertheless, the use of halogenated flame retardants is a crosscutting issue that should be addressed from horizontal legislation, and it has been considered that the TD Ecodesign Regulation is not the appropriate framework to address it.

-Implementation dates: five Member States and two NGOs proposed to align implementation dates for both ecodesign and energy labelling regulations, otherwise it would create confusion and market surveillance issues. APPLiA and one Member State proposed to implement ecodesign requirements in two tiers, the first applying 18 months after the entry into force of the legislation and the second 36 months after the first tier. 

-Verification tolerances: APPLiA and a Member State representative proposed to add tolerances for full and half-load, and for networked and information display standby modes. However, verification tolerances are consistent with the accuracy of the current testing methodologies as confirmed via a Round Robin Test carried out by several manufacturers in different testing facilities.

-Pictograms in the energy label: five Member States proposed to remove from the energy label the pictogram indicating the type of tumble dryer, since gas dryers have been phased out and all of them are electric. One Member State proposed to add a pictogram indicating the GWP of the refrigerant and two NGOs proposed to add pictograms on guarantee period and spare parts availability. 

4.Publication of the Call for Evidence and stakeholders feedback

For this IA, a derogation has been granted and therefore no 12-weeks Open Public Consultation has been carried out. A Call for Evidence has nevertheless been published on the Have your Say Portal 65 on 21 January 2022, and the feedback period finished on 18 February 2022. A total of 9 comments were received from the following stakeholders: EIA, AIG, APPLiA, ZERO, ECOS, ANEC/BEUC, VDZ, EMMA/ENPA and Principia Association. The feedback to the call for evidence does not deviate from the opinions summarised in Section 3 of this Annex. The comments provided are the following:

-Energy efficiency threshold: ANEC/BEUC pledges for setting out a stricter EEI. 

-High global warming potential refrigerants: EIA, ZERO and ECOS ask for the consideration of measures restricting the use of refrigerants with high global warming potential. 

-Rescaled label: APPLiA states that it is not necessary that A class in the new label is empty at the beginning, and that intervals between classes should be narrowed down. ANEC/BEUC does support that A class should be left empty in order to incentivise technical development. 

-Transitional periods: APPLiA asks not to phase out tumble dryers in current classes F and G before 2026. ANEC/BEUC does not support a two-tier approach and asks the measures to be implemented in one time and as soon as possible. 

-Availability of spare parts: generally supported by industries and environmental NGO’s, although with different levels of ambition.

-Noise: ANEC/BEUC asks for an introduction of noise limits.

5.Second Consultation Forum on 10 March 2022

A second Consultation Forum took place on 10 March 2022, with the main objective of updating stakeholders on the progress of the IA and gathering their opinion about some specific issues that still needed discussion. The issues related to the application of energy labelling and ecodesign requirements in two stages, the list of spare parts, the denomination of the programme under test and the incorporation of low power modes in the TD Ecodesign Regulation. Stakeholders generally agreed to the approach proposed by the Commission to each of the topics. NGO’s and a number of Member States asked for the merging of the two stages for the application of the requirements in a single one, 18 months after the entry into force of the amendments to the TD Ecodesign and Energy Labelling Regulations.

Annex 3: Who is affected and how?

1.Practical implications of the initiative

The TD Ecodesign and Energy Labelling Regulations will apply to the manufacturers established in the EU and to importers of equipment produced by other manufacturers which are not established in the EU, which will need to comply with the requirements summarised in table A3-1.

Table A3-1. Summary of Energy Labelling and Ecodesign requirements

2.Summary of costs and benefits

Table A3-2. Overview of Benefits (total for all provisions) as compared to the baseline– Preferred Option

Table A3-3. Overview of costs (total for all provisions) as compared to the baseline– Preferred Option

Relevant sustainable development goals