CALL FOR EVIDENCE

FOR AN EVALUATION AND IMPACT ASSESSMENT RUN IN PARALLEL

This document aims to inform the public and stakeholders about the Commission’s work so they can provide feedback on the intended initiative and participate effectively in consultation activities.

We ask these groups to provide views on the Commission’s understanding of the problem and possible solutions, and to give us any relevant information they may have, including on the possible impacts of the different options.

Title of the initiative

Revised EU ecodesign and energy labelling requirements for refrigerating appliances with a direct sales function

Lead DG – responsible unit

DG ENER, B.3 – Buildings and Products

Likely type of initiative

Commission delegated Regulation (ecodesign)

Commission delegated Regulation (energy labelling)

Indicative Planning

Adoption expected by third quarter of 2028

Additional information

Ecodesign/Energy Labelling Review - Refrigerating appliances with a direct sales function

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

A. Political context, evaluation, problem definition & subsidiarity check

Political context

Ecodesign and energy labelling help to deliver the Clean Industrial Deal and Affordable Energy Action Plan. Ecodesign has long supported a circular economy and strengthened the EU single market for energy-related products. Its implementation has significantly reduced consumer energy bills and enhanced the EU’s energy security by lowering primary energy consumption and decreasing reliance on imports. It has also helped reduce greenhouse gas emissions, mitigating climate change cost-effectively since the energy costs avoided outweigh the investments needed.

Existing measures need to be reviewed regularly to ensure they remain relevant, efficient and effective in the light of technological and market developments. The Commission’s 2022-2024 ecodesign and energy labelling working plan ( 1 ) included the review of the ecodesign and energy labelling measures for commercial refrigeration (Regulations (EU) 2019/2024 and (EU) 2019/2018). The plan underlined that ecodesign and energy labelling should contribute more to the circular economy, for example by tackling material efficiency issues such as durability, reparability and recyclability more systematically. The first working plan under the Ecodesign for Sustainable Products Regulation (ESPR) has now been published ( 2 ). The non-completed tasks from the previous working plan not included in the transitional arrangements, including commercial refrigeration, have been carried forward to the new working plan.

Evaluation

As part of the review of the current ecodesign and energy labelling measures, the evaluation will assess how successful the Regulations have been in achieving or progressing towards their objectives (with a focus on three evaluation criteria put forward by the ‘better regulation’ guidelines, i.e. whether the measures have been effective, efficient and relevant). The relationship between the resources used and the impacts of the regulations will be analysed, looking at both the cost and the benefits for different stakeholders. ‘Coherence’ will be assessed in a proportionate manner. ‘Subsidiarity and EU added value’ will not be assessed in detail since the Regulations being evaluated are secondary legislation and these aspects were considered when drafting the main legal act.

The scope of the evaluation will be EU-wide and will cover the rules from their entry into force until now. 

Problem the initiative aims to tackle

The current Ecodesign and Energy Labelling Regulations for commercial refrigeration products were estimated, in the impact assessment, to reduce energy consumption by 19 TWh in 2030, resulting in greenhouse gas emission savings of 7.4 MtCO₂eq/yr compared to a scenario without these measures ( 3 ). However, several issues have been identified that could hinder further improvements in energy efficiency and environmental performance, including the following:

-Energy label thresholds were set based on the best data available at the time, but EPREL data now gives a current, complete and robust overview of models on the EU market, which enables the setting of label thresholds with much improved market relevance.

-The energy label and information requirements could better inform buyers about circular economy issues.

-The requirements should be updated to reflect market and technology developments to deliver all economically viable savings for products falling within the scope of the regulations. This includes developments driven by the EU F-gas regulation and economic pressures.

-Energy and environmental savings may be possible from products currently outside the scope, such as refrigerated food lockers (post-sale refrigerators used outside of supermarkets); smart vending machines; supermarket display cabinets connected to chilled water loops, and with CO2 as a refrigerant (both becoming more prominent due to F-gas rules).

-Ensuring that adjustment factors for storage temperatures and integral vs remote configurations of supermarket cabinets remain appropriate.

-Regulations could be adapted so as not to impede efforts of the food industry to achieve energy savings through adjustment of storage temperatures for frozen foods (some advocate a change from -18ºC to -15ºC to yield energy savings).

-Other aspects listed in Article 8 of Regulation (EU) 2019/2024 may also lead to additional benefits and better implementation of the rules.

Ways to simplify the legislation and reduce administrative costs will also be assessed.

Basis for EU action (legal basis and subsidiarity check)

Legal basis

The Energy Labelling Regulation (EU) 2017/1369 ( 4 ) is based on Article 194(2) of the Treaty on the Functioning of the European Union (TFEU) ( 5 ), which provides a legal basis for measures to promote energy efficiency.

The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 ( 6 ) is based on Article 114 of the Treaty on the Functioning of the European Union, the legal basis for measures for the functioning of the single market.

With these acts, Parliament and the Council have given a legislative mandate to the Commission to regulate the environmental performance of energy-related products and in particular their energy efficiency.

Practical need for EU action

The EU legislation for these products requires the Commission to review the legislation against technological progress. Action to update these rules can only be taken at EU level. There may be aspects not covered by the legislation for which EU Member States might wish to act. If the EU did not act in these areas, EU Member States could set their own rules for unregulated aspects and products. This would create fragmented rules due to the complexity of the technical aspects that could disrupt the functioning of the internal market.

B. Objectives and policy options

The main objective of the legislative framework is, within the single market, to reduce the products’ environmental impacts –including greenhouse gas emissions – in a cost-effective manner, in particular through greater energy efficiency. The impact assessment will assess at least the following main aspects:

1.measurement and test methods,

2.requirements for energy and material efficiency,

3.aspects of energy labelling, including the energy label scale,

4.the scope of products covered,

5.other environmental impacts.

The impact assessment will address at least the following policy options:

1.no EU action (‘business as usual’),

2.voluntary agreements,

3.revised ecodesign requirements, e.g.

a.scope extension,

b.revision of the requirements in light of technological developments and better market data (EPREL),

c.information requirements,

d.revised material efficiency requirements, possibly including durability, remanufacturing and reparability, recyclability and recycled content.

4.Revised energy labelling requirements, e.g.

a.updated energy efficiency classes,

b.information on circular economy aspects,

c.feasibility of refining the classification of products, inter alia considering the difference between integral and remote cabinets.

C. Likely impacts

If more stringent ecodesign requirements are established, they may lead to increased acquisition costs, higher prices and increased turnover for manufacturers, wholesalers and retailers. These changes in economic activity are likely to lead to comparable changes in employment. Any changes in material efficiency requirements would be mirrored in manufacturers’ obligations under Directive (EU) 2024/1799 on common rules promoting the repair of goods. Energy labelling is likely to increase competition on performance in respect of key features shown on the label, in particular energy efficiency.

The main environmental impacts for this product arise from use-phase energy consumption. Lower energy use will weaken the associated negative environmental impacts, reduce consumer costs and lower the turnover of the energy supply industry. Energy efficiency requirements will aim at achieving the lowest lifecycle consumer cost level so that the expected cost savings would offset the product price increase.

Other environmental requirements could increase upfront costs. The economic impacts of requirements affecting product lifetime will depend on consumers choosing to prolong product life, for example by repair, and the cost of doing so. Extended lifetimes will lead to lower product sales and turnover.

Competitiveness is not expected to be impacted since the requirements will apply to all equivalent products. Impacts could occur if there is a specialisation in a specific product segment or price point. Turnover changes are not expected to alter the profitability of economic operators. A focus on streamlining registration and product categories aims to yield a reduction of burden on suppliers.

D. Better Regulation instruments

Impact assessment and evaluation

A back-to-back evaluation and impact assessment will be conducted to support the preparation of this initiative and to inform the Commission’s decision. The evaluation is expected to be finalised in Q4 2025. The impact assessment is expected to be reviewed by the Regulatory Scrutiny Board in Q4 2026.

Consultation strategy

The consultation aims to inform the public and stakeholders and to collect their feedback on the planned initiative. To carry out the analysis, the aim is to collect qualitative information (technologies available, views of buyers, suppliers and environmental organisations, etc.) and quantitative data (EPREL data, market data on sales and prices, lab test results).

-This call for evidence will be followed by a public consultation that will be launched on the ‘Have your say’ portal ( 7 ). The consultation will be available in all EU languages and will be open for a 12-week period.

-Progress of the work on the evaluation and impact assessment will be presented to the Ecodesign and Energy Labelling Forum. The Forum brings together Member States, industry associations and civil society representatives, enabling them to provide input throughout the process.

-The draft legislative proposal will be subject to a four-week feedback period and a World Trade Organisation (WTO) notification as part of the regular adoption procedures.

Why we are consulting?

To give stakeholders an opportunity to comment on experience with the implementation of the current Regulations for commercial refrigeration appliances and on the main options identified for the impact assessment, and to provide further input on any market or technology developments.

Target audience

Experts and representatives of any relevant interested parties, including industry associations (manufacturing, retail, installation and repair businesses), individual companies, environmental and consumer organisations, national authorities and private individuals.