Come on Labels

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ww w.come-on-label s. eu

Come On Labels

www.come-on-labels.eu

Come On LabelsCommon Appliance Policy All for One, One for All

Energy Labels

Final Publishable Report

May 2013Supporting energy labelling of products

Ensuring that accurate information are shown on the energy labels Monitoring the proper display of the energy labels at the points of sale

Developing promotional activities towards the final consumersIdentifying efficient product replacement schemes

The sole responsibility for the content of this report lies with the authors. It does not necessarily reflect the opinion of the European Union.Neither the EACI nor the European Commission is responsible for any use that may be made of the information contained therein.


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Come On LabelsCommon Appliance Policy All for One, One for All Energy Labels


May 2013

Supporting energy labelling of products: Ensuring that accurate information are shown on the energy labels

Monitoring the proper display of the energy labels at the points of sale

Developing promotional activities towards the final consumers

Identifying efficient product replacement schemes


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Content

About the project 7

Main project findings and achievements 9

Introduction 13

Legislation on energy labelling of products 16

Brief summary of the new EU labelling legislation 16

Comparison between energy label and Ecodesign requirements 19

Energy Labelling and Ecodesign legislation implementation 21

Shop visits 24

Summary of the shop visit methodology 24

Summary of findings in the shops 27

Compliance per type of shops 28

Compliance per product group 30

Examples of incorrectly labelled products as monitored during the shop visits 33

Retailer training 34

Product compliance verification and laboratory testing 35

Overview of verification procedure and market surveillance 35

Examples of known compliance tests 39

Possibilities for a European appliance test results exchange system 42

Promotion of energy labels 44

Replacement of inefficient appliances 48

Summary of mechanisms and impacts 48

Update of recent mechanisms 51

Final conference March 15th 2013, Brussels 54

Project deliverables 55

What others have said about the Come On Labels project 57


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www.come-on-labels.eu page 7

About the project

Come On Labels Common Appliance Policy All for One, One for All Energy Labels


December 2010 May 2013

Supported by the Intelligent Energy Europe programme:http://ec.europa.eu/energy/intelligent/

Czech Republic project coordinator SEVEn, The Energy Efficiency Center, www.svn.cz

www.come-on-labels.eu/o-projektu-cz/vitejte-czProject co-ordinator: Juraj Krivok, SEVEn, [email protected]

Austria Austrian Energy Agency, www.energyagency.atwww.come-on-labels.eu/zum-projekt-at/willkommen-at

Belgium Brussels Energy Agency, www.curbain.bewww.come-on-labels.eu/concernant-le-projet-be/message-daccueil-be-fr

Croatia ELMA Kurtalj d.o.o, www.elma.hr

www.come-on-labels.eu/o-projektu-hr/poruka-dobrodoslice-hr

Germany ko-Institut e.V., Institute or Applied Ecology, www.oeko.dehttp://www.come-on-labels.eu/zum-projekt-de/willkommen-de

Greece Center or Renewable Energy Sources and Saving, www.cres.grwww.come-on-labels.eu/about-the-project-gr/welcome-message-gr

Italy ENEA Agenzia nazionale per le nuove tecnologie, lenergia e lo sviluppo economicosostenibile, www.enea.itwww.come-on-labels.eu/informazioni-sul-progetto-it/messaggio-di-benvenuto-it

Latvia Ekodoma, Ltd, www.ekodoma.lvwww.come-on-labels.eu/par-projektu-lv/laipni-ludzam-lv

Malta Projects in Motion, www.pim.com.mtwww.come-on-labels.eu/about-the-project-mt/welcome-mt

Poland KAPE, Polish National Energy Conservation Agency, www.kape.gov.plwww.come-on-labels.eu/o-projekcie-pl/witamy-pl


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Main project findings and achievements

Te Come On Labels project was designed in 2009, beore most o the new energy labellinglegislation had been put in place. Troughout 2010 to 2013, new energy labelling and Ecodesignrequirements have been approved or entered orce or several product groups, such as rerigerators,washing machines, dishwashers, driers, air-conditioners, Vs, and light sources.Te Come On Labels project has been thereore in a unique position to support the properimplementation o new energy labelling among all stakeholders in 13 European countries, namely:

Market surveillance authorities:common understanding o the impacts and requirementso the legislation, and organisation o common activities, such as shop visits, expert trainingand providing consumer eedback.

Retailers and suppliers: educating and increasing their awareness on the usage o newenergy labels at the points o sales, visiting hundreds o shops and circulating a retailertraining material.

Consumers:organising widespread dissemination activities to educate consumers about theenergy labels and motivate them to purchase energy efficient products. Outcomes includeevents and seminars, air stands, leaflets and brochures, bookmarks and articles, pressreleases and posters.

Examples of the most visible and acknowledged activities include:

Working with market surveillance authorities

Each EU member state is responsible or organisingmarket surveillance activities, ensuring that the correctinormation is displayed on the energy labels, and thatenergy labels are visible in shops and other points osale. It is a well known act, however, that the level osuch activities in a number o countries is not sufficient.

Te Come On Labels project has thereore organised,or example, the ollowing activities:

Discussing common understanding o the legislation requirements, ocusing, or example, onthe meaning o individual icons displayed on the label, or the market entry definition issues,

sharing knowledge on the display o labels rom the project visits in shops, and negotiatingpossible improvement activities,organising common education activities or the inspectors, or the market actors such as theretailers and suppliers,negotiating product testing activities and the best methods or sharing such data amongauthorities in other countries.


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Collecting and sharing data on product surveillance tests

esting products to veriy the correctness oinormation published on the energy labels is oneo the key actors or ensuring that savings, declaredon energy labels, are really achieved. It is also a wellknown act that the number o tests covering allrelevant parameters is insufficient. Te project,while not testing products on its own, has made itsbest to contribute in the ollowing two ways:

Collecting inormation about product tests available publicly. Inormation on product

testing, made by the authorities in the UK, Netherlands, Sweden, as well as in Australia andUSA, has been collected, together with product testing activities o other Intelligent EnergyEurope projects. Tese have all been summarised and circulated among stakeholders withthe aim to make the knowledge on product testing more widespread.While manuacturers only test their product once or the whole EU market, authorities takereerence on the models tested rom their national markets. Te Come On Labels projecthas thereore delivered reports, summarising possibilities and experience aimed to makeEU-wide cooperation easier and activities simpler or the authorities. Te reports includethe experience in testing products in oreign laboratories, regular meetings o authorities toshare experience, regional testing approach sharing the model names o products, and the

examples o European projects, where test results became ully publicly available.

Checking label presence in shops

In order that the consumer uses energy labels as a tool or their purchasing decisions, labels need tobe visible in shops. But how ofen and how correctly are labels used in shops? Te Come On Labelsproject has organised three rounds o shops visits, each time visiting around 300 shops, monitoringthe proper presence o energy labels per shop type and product type. Outcomes included:

Monitoring the label presence per shop type, and evaluatingpossible improvements or kitchen studios, individual retailers,and general hypermarkets, where correct label display is onaverage the lowest.Monitoring the label presence per product type, showing thelowest rates or the wine coolers, but also or air-conditioners,electric ovens, and Vs.Evaluating the impact o new energy labels, which were usedalready in 2012 or more than hal o products displayed, contributing to a lower share opartly labelled products, since the new energy labels are distributed in one part only.

79

77

90

73

84

70

43

21

23

10

27

16

30

57

0% 20% 40% 60% 80% 100%

Energy class

Energy consumption

Storage

Storage volume

Temperature rise time

Freezing

TOTAL

failing the test

passing the test


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Retailer training manual

In order to improve the level o label display in shops,the Come On Labels project has prepared a retailertraining manual, educating shop assistants on theproper label display. Te manual, available in 11languages and 13 country adaptations, explains theimportance and legal requirements or label display,shows examples o proper and non-proper labeldisplays in shops, and gives concrete advice which theshop assistants can give to customers. Examples o thetraining material include:

Circulation to individual market surveillance authority inspectors

Organisation o individual retailer training seminars or retailer chains and shops Common circulation to shops with national CECED manuacturer association members

Usage o the material at conerences and events, where market actors participate

Comparing energy labelling with Ecodesign requirements

Energy labels were designed

to help consumers to choosemore energy efficientproducts rom the modelsdisplayed at the points osale. Energy class A hasbeen long understood as thebest perorming class romthe point o view o energyefficiency. However, the market developments, introduction o A+ / A+++ classes and the Ecodesignrequirements have caused that the A class is in a number o cases only the least available energy

class on the market. Te Come On Labels project has thereore produced a paper, summarisingthe range o energy classes displayed on energy labels, with the Ecodesign requirements orthe products allowed to enter the market. Tis paper has been circulated among stakeholders,authorities and market actors, to enable a more appropriate explanation o the energy efficiencyclass or individual products.

Dissemination to end consumers

Consumers and their purchasing decisions, which influence the energy consumption or manyyears ahead, are the primary target groups or energy labels. In order to ensure that the consumersdo take labels into account, they have to be ully aware about them and understand their content.

Product groupEnergy efficiency

classes shown on theenergy label

Energy efficiency

classes allowedon the market by

minimum Ecodesignrequirements

Energy efficiency

classes shown on thelabel, but not allowedby minimum Ecode-sign requirements

Washing machines A+++ / D A+++ / A B, C, D

Dishwashers A+++ / D A+++ / A B, C, D

Refrigeratingappliances

Compression type A+++ / D A+++ / A+ A, B, C, D

Absorption type A+++ / G A+++ / E F, G

Televisions A / G A / G

Light sources A / G A / C D, E, F, G


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Te proper understanding has increased in importance with the introduction o new energylabels. Te Come On Labels project has thereore organised

a widespread set o activities:

Numerous press releases and articles in general mediaPublishing leaflets, brochures, posters, or bookmarksand distributing them to end consumers via shops,inormation centres, energy agencies, libraries, etc.Organisation and participation to events, seminars,airs, and exhibitions, explaining the energy labels to

visitors and participants

Read more on the project experience and achievements in more detail

in the following chapters!

Find out more on energy labelling

and all of the project outcomes on the website:


A+++


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tion concerning products groups, such as driers, light sources and air-conditioners, or whichnew legislation was elaborated during the course o the project. Analysis o the level o surveil-

lance activities in individual countries covered by the project, with an overview o activitiesundertaken, as well as possibilities or higher level o activities, where relevant.

3) Appliance testing Te procedures and a list o known national (or regional) appliance tests (conducted mainly

within national market surveillance actions and European projects designed to perormproduct surveillance testing) have been elaborated, and circulated. A recommendation orurther activities and tools or increased level o surveillance was drafed and shared withconsortium members and other institutions and organisations on national and EU levels.

4) Retailer compliance Te proper presence o labels in shops was investigated, perormed by project partners in 13

countries. Te level o proper label display has been monitored by the product and shop type.Te growing presence o new energy labels has been monitored and its impact on label displayin shops discussed among retailers and other stakeholders. A retailer training manual has beenproduced in 11 languages and widely disseminated to urther support proper label display.

5) Promotion of energy labels DisseminationConcrete educational and inormation activities have been undertaken to disseminatecorrect and updated inormation on energy labels to final customers and retailers. A wide

range o activities have taken place, rom media presence (such as articles, press releases, Vappearances), through printed documents (e.g. leaflets, brochures, posters and bookmarks),to organisation o and participation at events, seminars, airs and conerences. Te aim was toincrease awareness and involve multipliers in circulating the outcomes on a wide basis.

6) Replacement of old appliances Even i the system o energy labelling is working properly, the replacement o old installed

appliances by new, most efficient ones, may not be as quick as desired. Te project thereoreanalysed possible policy tools evaluating the impacts on consumer purchasing decisions,environmental benefits, financial and organisational demands, and monitored previous and

current campaigns and activities organised to support an early and better replacement oproducts.

7) Final recommendations Te project experience, and its final recommendations have been elaborated and presented by

the project Final Publishable Report (this document), during the Final event, held on March15, 2013 in Brussels with high level participation o stakeholders rom all segments o marketactors, and a series o national events in all participating countries.

8) Common Dissemination Activities Activities undertaken under the leadership and on direct request rom the European

Commission, and the Executive Agency or Competitiveness and Innovation.


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Projects target groups and key actors and their involvement in the project:

State institutions

received evaluation of the legislation requirements in order to create a commonunderstanding

received information on the projects labelling surveillance activities in order toincrease awareness

participated in stakeholder education, common events, shop visits, shared theirexperience from surveillance activities

Suppliers (manufacturers andimporters)

received retailer training manuals

participated in project events

contributed to dissemination activities to end consumers and retailers

Retailers

shared their experience with the label display

took part in retailer training seminars and e-learning on label display

participated in selected dissemination activities

Consumer groups and NGOs

participated in the organisation of shop visits

helped organise dissemination activities

contributed to improved level of surveillance activities

General public benefited from improved knowledge of the energy labels

received responses to individual queries on label design and content

International organisations andother national institutions

Come on Labels project members cooperated with organisations such as EnREnergy labelling and Ecodesign working group, ADCO Labelling group, IEA 4Eand relevant Intelligent Energy Europe projects on sharing the experience andfinding solutions for improved and increased surveillance activities.


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Energy classes A+, A++ and A+++: i technical development allows it or the specificproduct these new energy efficiency classes may be introduced to the label. Classes A+, A++

and A+++ exist already or rerigerators and reezers, washing machines and dishwashers.For Vs, they will be introduced at predefined points in time.

Seven energy efficiency classes: as a principle, the energy label should show only sevenenergy efficiency classes. So, when A+++ is the highest class, the worst rating will be D,instead o G. Te upper class must be always be green and the lowest one red.

New calculation methodology: the calculation o the Energy Efficiency Index, which ingeneral is used to determine the energy efficiency class o the appliance models, has beenupdated, to better reflect the actual use o the labelled products. For example, or washing

machines it is now based on the energy consumption or both 40 and 60C cotton programmesat ull and hal load plus the consumption in low power modes.

New information on the labels:the new labels contain additional icons to highlight specificproduct eatures (such as capacity, perormance indicators, presence o an off-switch etc.).On the other hand, the washing machine and dishwasher energy label does not containthe washing perormance class any more: since all models on the market have a washingefficiency o class A, this perormance is now considered a specific minimum requirementor the placing on the market within the relevant Ecodesign regulation. In addition, theelectricity and water consumption are shown on the label in terms o annual consumption.

Language-neutral label:the new labels are the same in all EU countries, without the needor national language versions. Tis improvement is achieved by presenting the inormationthrough pictograms rather than verbally. As a consequence, there will be one single labelinstead o the ormer combination o a language specific coloured background label and alanguage neutral data strip.

Internet sales covered: the legislation specifies which type o inormation has to be listedwhen appliances are sold through the internet, catalogues or any other means that does notallow the consumer to see the product displayed, and thus to see the label.

Energy efficiency class advertised:as rom 2012, all appliance advertisements listing theprice and/or the energy consumption have to indicate the energy efficiency class, too.

Schedule of the introduction of the new energy labels: the mandatory application o the labelis usually set one year afer the entering into orce o the relevant delegated regulation. Afer thisperiod all new models placed on the market or put into service in the EU will bear the new labelat the point o sale.

Te directive and the product-specific regulations also define the responsibilities o thesuppliers, dealers, and the authorities. Tese are or example as ollows:


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Responsibilities of suppliers,who shall ensure that:each energy-related product alling under the regulation is supplied with a printed label;

a product fiche is made available;the technical documentation is made available on request to the authorities o Member Statesand to the Commission;

any advertisement or a specific model contains the energy efficiency class, i the advertisementdiscloses energy-related or price inormation;any technical promotional material concerning a specific model which describes its specifictechnical parameters includes the energy efficiency class o that model.

Responsibilities of dealers,who shall ensure that:each product, at the point o sale, bears the label provided by suppliers on the outside o the

ront or top o the household appliance, in such a way as to be clearly visible;household appliances offered or sale, hire or hire-purchase where the end-user cannotbe expected to see the product displayed are marketed with the specific inormation to beprovided by the suppliers;

any advertisement or a specific model contains a reerence to its energy efficiency class, ithe advertisement discloses energy-related or price inormation;any technical promotional material concerning a specific model, which describes its specifictechnical parameters includes a reerence to the energy efficiency class o that model.

Verification procedure for market surveillance purposes:

It is the responsibility o the Member States to organise the surveillance o the market and thelabelling scheme enorcement. Each Member State has its own Market Surveillance Authority andenorcement body.

In general the product compliance verification procedure consists o a series o tests that use therelevant European standards. Suppliers make the technical documentation available or inspectionby market surveillance authorities. Each Member State is required to develop its own regime and take the necessary preventivemeasures and measures aimed at ensuring compliance within a precise time-rame and, in the caseo persistent non-compliance, restrict or prohibit the placing on the market o a product.

Every our years, Member States will submit a report to the European Commission including

details about their enorcement activities and the level o compliance in their territory.


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Comparison between energy label and Ecodesign requirements

Tis chapter is extracted from the projects document Comparison of energy efficiency requirementsof the energy labels and Ecodesign legislations; published in June 2012. Full document is available

here:

http://www.come-on-labels.eu/legislation/eu-product-energy-labelling

Te EU Energy labelling o major appliances and otherproducts is a long known and appreciated tool or consumers,advising them on the energy efficiency and other unctionalperormance qualities o models which they consider or theirpurchase.

Te purpose o energy labels is to rank all models ofcertain type of products within certain energy class range,typically rom A to G, or A+++ to D and show this ranking atthe points of sale.

Te Ecodesign measures are another set o the EUlegislation that regulates the energy consumption andunctional perormance aspects o products through the settingo minimum requirements or the placing on the market or theputting into service o products. Contrary to the labelling, thislegislation is not visible to consumers, as products entering

the market shall automatically comply with the relevantrequirements.

In certain cases both legislations apply to the same producttypes: or washing machines, dishwashers, rerigerators, air-conditioning units, televisions, dryers and light sources bothenergy label and Ecodesign have been set through CommissionRegulations.In practice (at the points o sale) these types o products are displayed with the respective energylabels showing the ull range o energy efficiency classes (e.g. A+++ to D), but at the same timethe Ecodesign legislation prohibits the market entry o models below a certain minimum energy

efficiency class (e.g. worse than class A). Te summary able shown below compares the energy efficiency classes set in energy labellingand allowed by the Ecodesign requirements or the most common product types (washing machinesabove 4 kg load, dishwashers above 10 place settings). Various dates o entry o the legislation intoorce are set or each product type.


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Table: Comparison of the energy efficiency classes in energy labelling and Ecodesign requirements, as of June 2012

Product groupEnergy efficiency class-es shown on the energy

label

Energy efficiencyclasses allowed on the

market by minimumEcodesign requirements

Energy efficiencyclasses shown on thelabel, but not allowedby minimum Ecodesign

requirements

Washing machines A+++ / D A+++ / A B, C, D

Dishwashers A+++ / D A+++ / A B, C, D

Refrigeratingappliances

Compression type A+++ / D A+++ / A+ A, B, C, D

Absorption type A+++ / G A+++ / E F, G

Televisions A / G A / G

Light sources A / G A / C D, E, F, G

Note: For Vs the plus classes may be voluntarily used before they are introduced on a mandatory

basis, the label would still contain seven classes only (e.g. bottom letter would be deleted in such case).

Further energy-related products have been added since. Regulation (EU) 626/2011 on room

air conditioners has entered into orce in May 2011; requirements apply rom January 2013. ACommission delegated regulation No 392/2012 o 1st March 2012 with regard to energy labellingo household tumble driers has been entered into orce in March 2012; requirements apply romMay / September 2013. Te new energy label or tumble driers will contain A+++ / D energyclasses. At the same time, the Ecodesign regulation or this product group has been approved bythe Regulatory Committee in May 2012 and suggests limiting the market entry o D and or somemodels C class models (one year afer the entry into orce o the Regulation). Regulation (EU)1194/2012 on directional light sources has entered into orce in January 2013; requirements applyrom September 2013.Other product groups or which both the energy labelling and Ecodesign legislations are expected

in 2013 include: ovens, water heaters, heating appliances, vacuum cleaners, and commercialrerigerating equipment.


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Energy Labelling and Ecodesign legislation implementation

Tis chapter is extracted from the projects document Energy Labelling and Ecodesign legislationimplementation; published in March 2013. Full document is available here:

http://www.come-on-labels.eu/legislation/energy-labelling-legislation-in-the-project-countries

While organising the project activities, such as visiting shops to monitor the presence oenergy labels, collecting inormation about the product testing activities, disseminating energylabels to consumers and evaluating experience about product replacement schemes, one o thekey eatures o the Come On Labels project activities in all o its 13 participating countries1wasthe regular contact with the national Market Surveillance Authorities, as well as other key national

stakeholders, such as government representatives, manuacturer and retailer associations, etc.Many o the relevant project achievements, such as an overview o the presence o labels by thetypes o products and shops, or the examples o product tests, have been discussed, with the aimto improve the quality o market surveillance activities, and thereby the level o product/shopcompliance and consumer satisaction.

One o the specific project outcomes was a detailed review o the level and nature o surveillanceactivities undertaken in individual project countries.2Examples o some o the activities describedin the main deliverable are given here:

A positive example o an increase o the level o surveillance activities came rom the

Czech Republic, which has in the past visited only a limited number o shops, to veriythe presence o energy labels, e.g. our in the year 2010. In the year 2011 this increased to 18shops surveyed, and in 2012 to almost 300 shops. Overall results have been published in a pressrelease. Authority representatives confirmed to maintain this level o shop visits or subsequentyears to come. In 2011, six rerigerating appliances have been tested or electricity consumptionand all have been ound compliant with the label declaration. No other product tests are currentlyexpected.

Austriareports 70 shop visits per year, with last year identiying 70 products not beinglabelled. Tis level o shop surveillance is considered by the authorities as sufficient and

does not expect more controls in the uture. No product testing takes place in Austria, but activeparticipation to ADCO labelling group is confirmed.

In Belgium, 1,3 ull time staff equivalent work at the ministry responsible or thelegislation adaption and inspectorate responsible or its implementation, and 0,2 ull time

equivalent responsible or energy labelling related Ecodesign and environmental product issues.In 2011, some 202 shops have been surveyed, and 3330 products declared as non compliant outo almost 20 thousand surveyed. 46 products have been tested in the last our years (20092012),

1 Austria, Belgium, Czech Republic, Croatia, Germany, Greece, Italy, Latvia, Malta, Poland, Portugal, Spain, UK

2 Tose interested in more inormation on related topics, may also consult other IEE projects: ALEE II, ocusing on market surveillanceactivities, by a questionnaire, mainly related to washing machines: http://www.atlete.eu/2/market-surveillance-authorities and Ecopliant project,ocusing on Ecodesign related activities: http://www.ecopliant.eu/activity-streams/work-package-2-establishing-best-practice/ .


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mainly light sources, rerigerators and dishwashers; no sanctions have been applied, but some lampmanuacturers have adapted the product packaging. Te cost o testing is considered as a difficulty

and a reason or not conducting more product tests, and or the uture national laboratories will beencouraged to get ull accreditation.

Te national market surveillance authority in Greeceperormed 7 shop visits in 2012and 60% compliance was identified. Recommendations have been made but no fines

have been applied so ar. No products were tested due to economic restrictions. Te authority isinterested to overcome the existing barriers and to expand its activities.

Te situation in Germanyis more ragmented, since the surveillance activities take placeby individual ederal states. Te recast o the German legislation on labelling, as a reaction

to the EU Energy Labelling directive recast, has strengthened the role o market surveillance, e.g. byintroducing the requirement to set up a market surveillance plan, and reporting requirements. Anexample rom the ederal state Hesse includes a cooperation between the authorities and retailers,not only in ensuring correct labelling but also actively promoting efficient appliances. In Bavaria,laboratory testing o LED lamps is envisaged or 2013, related both to the energy labelling andEcodesign requirements. Rhineland-Palatine reports on 211 shop visits (including both first-time andollow-up visits) and 18 cases o administrative fines conducted. Baden-Wuerttemberg ocused on anagreement between the ederal states ministry o environment and the local authorities, including aspecific target or conducting market surveillance and establishing a management system comprisingboth labelling in shops and product testing. Results o activities are shared on a national level in the

Bund-Lnder working group, and internationally within the ADCO group on market surveillance.

Te Italiansurveillance authority is planning to implement a programme o checks onlighting products in the period 20132014 as part o a Memorandum o Understanding

with the Italian Union o Chambers o Commerce, in cooperation with the chambers o commercein the area. Tis includes the inspection o manuacturers and distributors as well as carrying outtests in selected laboratories. In general it is expected that suppliers must provide the technicaldocumentation o the controlled product and, in case o doubt, the demonstration o compliancethrough the results o laboratory tests. Te monitoring costs are borne by the Authority. While ewproduct tests take place in Italy, or 20132014 about 70 light sources are planned to be tested. As

or the cooperation and international inormation exchange opportunities, Italian representativesappreciate the co-unding o market surveillance actions by the EU programmes and the EuropeanCommission offer o both financial support and the opportunity to meet with other Authoritiesand related institutions to share experience, compare procedure and when possible results. Also,EU centralised market surveillance actions and studies, developed by the European Commissionsuch as the 2008 shop survey, or the unding o Round Robin tests are welcomed.

One o the countries where little labelling compliance verification activities take place isLatvia, where no product testing and limited shop visits take place. However, Latvia can

benefit significantly rom international cooperation. Te Nordic project, ocusing on marketsurveillance o the Nordic countries, also invites Baltic countries or cooperation and the Latvianauthority has confirmed its interest to receive the results and learn rom its best practice.


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Shop visits

Summary of the shop visit methodology

Tis chapter is extracted and adapted from the projects document Proper appliance labelling in

shops; published in June 2011. Full document is available in 11 languages here:

http://www.come-on-labels.eu/displaying-energy-labels/appliance-labelling-in-shops

Te proper presence o energy labels at the point o sale, or specific inormation on cataloguesand or internet sales, is crucial to allow consumers to make an educated choice o their newappliances. Te experience shows that the presence o labels on appliances in many shops is in general

high around the European Member States. However, significant problems still exist in relation tospecific product groups or distribution channels.

Te essential elements o the implementation o energy labels in Member States are defined inthe EU energy labelling ramework directive and in the product-specific implementing directivesor regulations, and in the general market surveillance regulation 765/2008/EC. European lawdefines the responsibilities o suppliers and dealers as ollows:

Suppliers placing on the market or putting into service products covered by a delegated actsupply a label and a fiche in accordance with this Directive and the delegated act.

Dealers display labels properly, in a visible and legible manner, and make the fiche available

in the product brochure or other literature that accompanies products when sold to end-users.

Furthermore, in cases where the consumer cannot be expected to see the product displayed,such as in catalogue or online selling, dealers must provide to their customers the inormationthat is included in the energy label.

According to the European legal ramework, the European Member States are required toensure proper labelling o the products through market surveillance (verification actions). Shop

visits are one possible action to ensure retailer compliance.


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Enforcement of the proper presence of labels in shops:Member states shall:

Ensure that suppliers and dealers ulfil their respective duties. Assign institutions to perorm market surveillance (such as planning and executing product

compliance verification and retailer compliance verification) and endow them with sufficientcompetences and resources.

Draw up market surveillance programmes. Lay down rules or assigning penalties to inringements o the Directive. Ensure external border control. Report to the Commission every our years about their enorcement activities and the level

o compliance in their territory.

Verification activities: Verification aims to answer the question whether a supplier or dealer complies with the

obligations o the ramework directive and the implementing directives or delegatedregulations.

European legislation describes the essential elements o the product compliance verification(through a two Step appliance testing). No general procedure is oreseen or veriying whetherdealers ulfil their obligations (e.g. shop visits). Tese procedures are lef to each MemberState ollowing the principle o subsidiarity, although Regulation 768/2008/EC makes themarket verification mandatory or Member States.

Shop visitsTe institution/s responsible or veriying proper appliance labelling in shops should carry outinspections in order to veriy the compliance with the legislation provisions. Te decision about the size o the sample or the different shop categories can be done onthe basis o (i) a statistical analysis, (ii) previous experience and knowledge, or (iii) individualcomplaints rom consumers.

Te check o the correct label presence in the shops should ollow the same procedure or everyvisit in order to make inspection results comparable. As there is no European law speciying howshop visits should be conducted, the Come On Labels project has developed some recommendations,based on the experience o other projects and its own surveys.


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Te procedure or visiting shops should take three steps: Preparation, inspections and ollowup.

Shops: procedure for the inspections

Preparation

Appliance selection, shop selection and check-list elaboration.

Inspections

Visit shops and record the labelling status.

Inform shop of next steps.

Follow up

Assess the results and process them (in case of sanctions).

Feedback of the results to the shops.

Store the results for the next shop/appliance selection.

Report the results.

Te proper label display or the products should be recorded ollowing the check list (see nexttable) and the shop should be inormed about the next steps to be carried out by the nationalAuthority afer the conclusion o the inspection. Te ollow-up depends on the verificationprocedure established in the national legislation.

Table: Proper position of the label

Appliance Position

GeneralIn the clearly visible position specified in the relevant implementing directive or

regulation.

Refrigerators, freezers

and their combinationsThe label shall be placed on the outside of the front or the top of the appliance,

in such a way as to be clearly visible.Washing machines

Dishwashers

Televisions On the front, in such a way as to be clearly visible.

Tumble driers

On the outside of the front or the top of the appliance, in such way as to be clearly

visible, and not obscured.Combined washer-driers

Air conditioners

Ovens

On the door (outside) of the appliance in such a way as to be clearly visible and not

obscured. For multi-cavity ovens, each cavity shall have its own label, except a cavity

which does not fall within the scope of the harmonized standards.

Lamps The label shall be placed or printed on, or attached to, the outside of the individualpackaging of the lamp. Nothing else shall obscure it or reduce its visibility.


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Internet sites and mail order catalogues checkIt is important that customers unable to see the product (and thereore the label) displayed are

provided with the essential inormation about the products beore the purchase.Internet sales and mail order catalogues check can be approached in the same way as shop

inspections. Te list o inormation to be checked is included in the product specific implementingmeasure.

Checking of product advertisementsAccording to the new energy labelling ramework directive, any advertisement or a specificproduct shall contain the energy efficiency class, i energy-related or price inormation is disclosed.Tereore, one o the market surveillance actions is also to veriy i the energy class is alwaysproperly mentioned on the advertisements.

Summary of findings in the shops

Tis chapter is extracted and adapted from the summary of the projects three rounds of shop visits,

organised between December 2011 and February 2013. Full document is available here:

http://www.come-on-labels.eu/displaying-energy-labels/status-of-appliance-labelling

Within the Come On Labels project, each o the 13 project partners have visited at least 20selected shops three times during the project. During the entire duration o the project, over 900points o sales have been visited and monitored.

Te first round o shop visits took place between December 2011 and February 2012 andincluded 290 shops.

Te second round o shop visits was conducted within the period o July 2012 to October2012 and included 331 shops.

Te third round took place in January and February 2013 and included 305 shops.


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Note: the size of the sample and the sampling characteristics result in a shop sample that is not

representative of the EU appliance market or of the distribution of the shop types. Te project visit

results therefore are only indicative of some trends and highlight some of the problems with the labeldisplay, but do not represent the full situation of the household appliance retailers both at EU and

national levels.

Te Figure below compares the share o shops visited in the first, second and third round oshop visits. While the total number o shops visited has changed, the shares during the first andsecond round o shop visits remained similar. During the third round o shop visits, electronicsuperstores and kitchen/urniture studios were visited slightly more ofen. On the other hand, lesselectric specialists were inspected whereas the share or general hypermarkets/cash and carry aswell as mail order and internet shops remained similar to the previous rounds.

The % share of shop types visited in 1st, 2nd and 3rd round of shop visits

Compliance per type of shops

It should be noted, that compliance per shop category differs considerably rom country to countryand only reers to the number o ully correctly labelled products partly or incorrectly labelledproducts are not considered here. For the third round o shop visits, the highest overall shopcompliance was ound in Germany (77%), Croatia (73%), Spain (65%), Poland (63%), and theUK (55%). Te lowest overall compliance was ound in Malta (37%), Belgium (32%), and Greece(31%).

0%

10%

20%

30%

40%

1st set of shop visits 2nd set of shop visits 3rd set of shop visits

22%

35%

20%

15%

8%

22%

38%

18%

14%

8%

24%

30%

24%

14%

8%

Electronicsuperstore

Electric specialist Kitchen studio /Furniture stores

Generalhypermarkets /Cash and Carry

Mail order andinternet shops


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Average shop compliance rates in 1st, 2nd and 3rd round of shop visits Summary per shops

In addition to that, ull compliance also varies greatly according to the type o shop, rangingrom as low as 26% in kitchen studios/urniture stores to 70 % in electronic superstores.

Overall, kitchen and furniture studios are the shop type with the lowest share o properlyenergy labelled products ollowed by general hypermarketsand electric specialistshops. In thecase o kitchen and urniture studios the situation worsened when comparing all three roundso shop visits, and only 26% o all appliances were labelled properly in the last round (30-33%in the previous shop visit rounds). General hypermarkets showed a similar trend with an overallcompliance just reaching 50% during the third round o shop visits. Tis led to the conclusion that

shops that are selling a large variety o products perorm differently when it comes to displayingenergy labels properly. Tis depends mainly on the type o products offered, the turnover ospecific models, the supply o energy labels by the manuacturer/importer, and knowledge o shopassistants, etc.

Results o the third round o shop visits urther show that compliance in electronic superstoresremain high (70%) and relatively stable compared to the first (76%) and second (71%) round oshop visits. However, significant differences could be observed when comparing the individualcountries. In countries such as Austria, Croatia, Czech Republic, Germany, Italy, Poland, Spain,and UK, compliance or this shop type is above 80% whereas in some o the other countries thecompliance is much lower: around 45% in Greece, and Malta 39%.

Electric specialists account or 31% o all shops visited by the project consortium. Overallcompliance in this shop category has again improved or the second consecutive time. 56% o allappliances in shops o this type were labelled correctly, compared to 52% in the second round oshop visits and 48% in the first round. Compliance in this shop category differs significantly romcountry to country and also depends on the individual shops visited. For example, compared tothe second round o shop visits, compliance or this shop type in Germany went down rom ca.80% to 59% (probably as a result o purposeully selecting shops suspected to be non-compliant).Compliance in Greece, Malta and Belgium remained on a low but stable level, whereas in Croatiathe situation urther improved with ca. 78% o all shops in this category displaying energy labelscorrectly.

0%

20%

40%

60%

80%

100%

1st round 2nd round 3rd round

not labelled

Partly / Incorrectly labelled

Labelled correctly54% 52% 52%

13%11% 14%

33% 38% 34%


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In total, 60149 appliances were checked during the third round o shop visits. In the first roundo shop visits, some 51 thousand products were checked. In the second round o shop visits, ca.

76 thousand products have been surveyed. Tese numbers exclude lamps which usually have theenergy labels printed on the product packaging. In total 68% of the appliances surveyed were labelled correctly, 14% labelled partly/incorrectly and 18 % not labelled at all (weighted average). In general, there is a significantdifference o compliance levels between traditional white-goods such as rerigerating appliances,washing machines, dishwashers, and appliances that are ound less ofen in households or whichhave carried the energy label or a shorter time, and/or are sold in different types o shops, such asair conditioners, electric ovens, tumble driers.

Te most common examples of labels not being correctly displayed include:

Labels covered with other stickers, advertising materials, or price tags Labels placed inside the appliance, on the side or on the back

DIY labels, hand written labels made by retailers Labels sealed in a plastic envelope, not accessible to consumers in shops For old labels only the data strip is displayed or only the background with the coloured

arrows but with no figuresLabels not matching the appliances

wo labels or one appliance in some cases also both the old/new labels, both showing adifferent energy class.

For internet shops, some o the prescribed data is missingUsage o non-existing energy classes, such as A+++++ or A+++-20% in internet sales, whereit is used as the energy class indication.

During all three rounds o the shop visits, inormal interviews with shop assistants wereconducted in some shops in several countries in order to gather eedback on why labels were notdisplayed ully in certain shops or or certain products types. Tese interviews have been done ona voluntary basis - not as a ormal project deliverable. Retailers have been, however, indicating thefollowing reasons for not showing the labels correctly:

Te national system o the distribution o energy labels to shops influences the availability olabels. In countries, where labels are not distributed by supplier associations, the responsibilityo individual suppliers to deliver the two parts o the old labels could be lower.

Sometimes the energy label is sealed in a plastic bag, which neither the retailers nor theconsumers want to open in the shop, since it could be perceived that the specific model is aused product, or that other parts included in the bag could be lost.Sticking a label onto the product could leave glue residues on the surace o the product,when the label is removed.

Te aesthetics o the labels on the products, mainly or built-in appliances and in kitchen/urniture shops.Te use o the shops own eco labels or retail stores. Tese labels, placed on selected products,are made clearly visible and are ofen part o marketing activities o the retail store. However, the


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criteria or selection are not always made available and in any case this behaviour is in contrastwith the obligations o the retailers established in the energy labelling ramework directive.

Arguments o having no interest in labels, as i the label were simply a matter o choice.Slow turnover o some products, resulting in presumably old models being displayed thatwere placed on the market beore the new legislation entering into orce.

Mandatory presence o energy class inormation generally unknown to managers o e-commerceshops general catalogue websites and in product advertising since this is a new provision.Claiming that a different legal entity is selling the products to consumers, than the onedisplaying the products in the shop.

Market share of new energy labelsIn all three rounds o shop visits, the share o old and new labels has been monitored and compared.

It needs to be mentioned though that during the first round o shop visits non-labelled Vs andwine storage appliances were not taken into consideration as their market entry date could not be

verified during the visits (only products with the label were counted).In the first round o shop visits (depending on the product category) between 42% and 54% o

the appliances with the possibility to bear the old or the new labels were ound with a new labelwhile between 46% and 58% were still equipped with the old label. In the second round o shop visits, it was observed that the share o new energy labels hasincreased in general in all concerned product categories. Tis was particularly visible in the case oelevisions or which ormerly no label was available. In this category a high share o products waslabelled with the new energy label right rom the start.

During the third round o shop visits, the previously observed trends could be confirmed as theshare o new energy labels urther increased considerably in all our product categories. Between71% and 82% o dishwashers, washing machines, and rerigerating appliances are now equippedwith a new label. Similarly, 72% o Vs ound during the shop visits now have a new energy label.Tis a remarkable increase particularly compared to the first round o shop visits during whichonly 28% had a new energy label and 72% were not labelled at all.

Display of the new energy label Summary

1st round of shop visits

2nd round of shop visits

3rd round of shop visits

54%

42%46%

28%

60% 58% 57% 57%

82%75% 72% 72%

0%

20%

40%

60%

80%

Refrigerating Washingmachines

Dishwashers TVs


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Examples of incorrectly labelled products as monitored

during the shop visits

Labels displayed at wrong place.

Wrong energy class declaration.

Label covered by other document, combination of an old and new label.


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Retailer training

In order to contribute to the improvement o theproper display o energy labels in shops, the ComeOn Labels project has prepared a Retailer trainingmanual, summarising the ollowing inormation:

Explanation o the content and importance oenergy labelsGuidance on the proper label displayFacts and tips on the labels and energy efficiencyor consumers.

Te document is available in 11 languages and 13 national adaptations on the project website:http://www.come-on-labels.eu/displaying-energy-labels/retailer-training-manual

Over 1000 copies o the training material have been printed and circulated; numerous electronicsamples have been circulated to retailers, suppliers, authorities and other interested stakeholders.Examples o the usage o the document include:

Retailers: Individual training sessions or shop assistants rom individual shops and shop chains, Inclusion into retailers education and e-learning schemes

Manufacturers: Common distribution o the material to individual suppliers, either by individual

manuacturers, or in cooperation with the national manuacturer association

Authorities: Distribution to individual inspectors located around the country Organisation o common events and seminars or inspectors or the retailers

Consumer NGOs etc

Common awareness raising about proper labels display

In total, over 2600 shop assistants, representatives o over 830 shops, as well as some 70surveillance inspectors, suppliers and other stakeholders rom around the EU have benefited romthe retailer training manuals.


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Product compliance verification and

laboratory testing

Overview of verification procedure and market surveillance

Tis chapter is extracted and adapted from the projects document Appliance testing procedures and

good practice; published in June 2011. Full document is available in 11 languages here:

http://www.come-on-labels.eu/appliance-testing/energy-consumption

Afer the publication o the new labelling directive 2010/30/EU in 2010, a number o Regulations

ollowed, setting new labels or major energy-related products. Contemporarily, the EcodesignRegulations published in 2009 established minimum requirements that products shall ulfil to beplaced on the EU market. Te compliance with all these requirements needs to be verified as wellas the products conormity with the label declarations.

Unortunately in the last decade market surveillance activities have been developed only insome Member States and in most cases in a discontinuous way. Starting in 2009, the EuropeanCommission has supported some pan-EU actions through the financing o specific projects withinthe Intelligent Energy Europe Programme. Te specific ADCO (Administrative Cooperation)Groups on Labelling and on Ecodesign have also been set.

It is also worth noting that one o the new legislative requirements or the EU Member States,

included in Directive 2010/30/EU is to prepare (every our years) a report to the Commissionincluding details about their enorcement activities and the level o compliance in their territory.Tis should include inormation on appliance compliance testing, which this chapter is dealingwith.

The procedure to be followed in EU Member States

Whether in the case o an old implementing directive or a new delegated regulation, the verificationprocedure is based on a two-step approach: in Step 1 the check is perormed on one unit o themodel; in case o suspected non-compliance Step 2 is then developed checking three additionalunits o the same model.


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Depending on the parameter to be verified, a verification tolerance (that takes into considerationthe uncertainty in the laboratory measurements) is applied to the measurements carried out in the

two Steps. In this respect it is worth noting that while in the old labelling directives the toleranceaccepted in Step 1 was larger than that accepted in Step 2, to take into account also the production

variability, in the new delegated regulations tolerances are in most cases the same in both Steps oreach verified parameter.

Table: Summary of the EU verification system and tolerances for energy consumption for the new labelling and

Ecodesign requirements

ApplianceImplementing

regulation Standard

Verification procedure

Step 1 Step 2

Units Tolerance Units Tolerance

(n) (%) (n) (%)

(new) Energy labelling scheme

Refrigerators&freezers 1060/2010/EU EN 153 1 10% 3 10%

Washing machines 1061/2010/EU EN 60456 1 10% 3 6%

Dishwashers 1059/2010/EU EN 50242 1 10% 3 6%

Ecodesing requirements

Refrigerators&freezers 643/2009/EC EN 153 1 10% 3 10%

Washing machines 1015/2010/EC EN 60456 1 10% 3 6%

Dishwashers 1016/2010/EC EN 50242 1 10% 3 6%

Te European standardisation bodies (CEN, CENELEC, ESI) have the task o drawing up thecorresponding technical specifications (i.e. the measurement standards), compliance with which

will provide a presumption o conormity with the legislation. Such specifications are reerred toas harmonised standards. In this respect:

products manuactured in conormity with harmonised standards are presumed to becompliant to the essential requirements;

standards are not mandatory, they remain voluntary. Alternate paths are possible butthe producers have an obligation to prove their products are compliant to the essentialrequirements;

standards must offer a guarantee o quality with regard to the essential requirements o theEU legislation;

national Authorities are still responsible or the market surveillance on their territory and totake all appropriate measures to avoid (and even withdraw) non-compliant products romthe national markets.


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Existing legal obligations for Member States on market surveillance

Te New Legislative Framework (NLF), the modernisation o the New Approach or marketingo products, was adopted in Council on 9th July 2008 and finally published in the Official Journalon 13th August 2008. It consists o two complementary instruments, Regulation 765/2008/ECon accreditation and market surveillance and Decision 768/2008/EC establishing a commonramework or the marketing o products.

Te objective o the packageis to acilitate the unctioning o the internal market or goods andto strengthen and modernise the conditions or placing a wide range o industrial products on theEU market. Te package:

introduces better rules on market surveillance to protect both consumers and proessionals

rom unsae products, including imports rom third countries. Tis particularly applies toprocedures or products which can be a hazard or health or the environment or instance,which in such a case will be withdrawn rom the market;

enhances the confidence in and quality o conormity assessments o products throughreinorced and clearer rules on the requirements or notification o conormity assessmentbodies (testing, certification and inspection laboratories) including the increased useo accreditation; a reinorced system to ensure that these bodies provide the high qualityservices that manuacturers, consumers and public authorities need;

enhances the credibility and clarifies the meaning o CE marking. In addition the CEmarking will be protected as a community collective trade mark, which will give authoritiesand competitors additional means to take legal action against manuacturers who abuse it;

establishes a common legal ramework or industrial products in the orm o a toolboxo measures or use in uture legislation. Tis includes provisions to support marketsurveillance and application o CE marking, amongst other things and it sets out simplecommon definitions (o terms which are sometimes used differently) and procedures whichwill allow uture sectoral legislation to become more consistent and easier to implement.Te provisions are split or legal reasons, but must be considered in parallel, as they are ully

complementary and together orm the basis o consistent legal ramework or the marketingo products.

Te legislation also sets the obligations o the Member States regarding the organisation o themarket surveillance. Member States in act shall: establish appropriate communication and coordination mechanisms between their market

surveillance authorities establish adequate procedures entrust market surveillance authorities with the powers, resources and knowledge necessary

or the proper perormance o their tasks ensure that market surveillance authorities exercise their powers in accordance with the

principle o proportionality


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Come On Labels


establish, implement and periodically update their market surveillance programmes periodically review and assess the unctioning o their surveillance activities.

In conclusion, a set o recommendations can be drawn or the definition and implementationo an effective verification procedure or the EU legislation on energy-related products:

set a clear, transparent and precise procedure, to be largely publicised to all market actorsand thoroughly ollowed by the national Market Surveillance Authority. Tis should include(the list is not exhaustive):

the use o an appropriate measurement method and test conditions the commitment to run the 2 Steps o the verification procedure as set by the relevant EU

labelling/Ecodesign product specific measures

the verification o all parameters requested by the legislation provisions (e.g. energyefficiency class, energy consumption, water consumption, capacity). All parameters havethe same importance when product compliance is considered.

in case o ailure o Step 1, the supplier should be given the possibility either to accept theresults and go or an immediate remedy action or to ask or the development o the secondStep.

oresee and support the discussion with the supplier about the possible reasons or non-compliance: the understanding o the non-compliance causes is as important as theidentification o non-compliant products;

define staged and timely corrective actions to be applied by the national Market SurveillanceAuthority: such actions should always ollow the identification o a non-compliant productand should possibly include an initial approach to the product supplier or the correction othe product declaration(s), ollowed by i and when considered necessary the applicationo penalties or sanctions (effective, proportionate and dissuasive) down to the obligation toremove the non-compliant product(s) rom the market;

set a working plan or the market verification, to be announced to all market actors, topublicise the concept that no products will be orgotten and that market verification is a

routine action and not an exception.


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Examples of known compliance tests

Tis chapter is extracted and adapted from the projects document Summary list of test resultscarried out on household appliances; published in three editions (8/2011, 5/2012 and 3/2013). Full

documents are available in two languages here:

http://www.come-on-labels.eu/appliance-testing/appliance-tests-2011-2013

Te Come On Labels project has collected inormation about product testing undertaken orcompliance verification o the product energy labels. Tis inormation is shared by the projectpartners in 13 European countries with stakeholders such as national surveillance authorities,manuacturer and retailer representatives, consumer organisations, media, etc. Te main goal o this Deliverable is to increase European-wide implementation and control oenergy labelling and Ecodesign measures or appliances by:

collecting and circulating results o the European testing results; contributing to increased attention o the National Authorities through a better awareness o

the impact o the energy labelling on the national energy efficiency; giving concrete guidance to EU and National Authorities or an increasingly effective

labelling implementation; highlighting a shared procedure or the verification o the manuacturers energy labelling

declarations including reerencing to a methodology or laboratories accreditation andmodels selection.

The testing activities collected and explained in the three editions of thisdocument include:

ALEE project, Intelligent Energy Europe project, 200920114

Te project has ocused on testing rerigerating appliances or their compliance with the (old)energy label declarations and it was the first European wide testing activity or market surveillance.80 randomly selected rerigerating appliances were tested in selected laboratories. Te projecthas brought specific examples o product test results and confirmed the technical easibility andeconomic affordability o market surveillance.

Te final test results show that 80% o appliances subjected to testing and or which testing hasbeen concluded complied with the energy consumption and the energy efficiency class declarations.

4 www.atlete.eu


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Come On Labels


But when all five parameters under verification are taken into consideration 57% o models do notcomply with at least one o the tested parameters.

All test results and test reports or each model are publicly available on the project website andhave been shared with the EU Member State Market Surveillance Authorities, media, experts andstakeholders.

UK National Measurement Office, 20102012 Te National Measurement Office (NMO) tested rerigerators, rerigerator-reezers andreezers or compliance against the energy labelling and Ecodesign requirements. welve models were purchased rom on-line and high street retailers and sent to anindependent accredited test house or examination. Four o them were subject to urther testingto veriy suspected non-compliance: all our ailed the additional tests and were thereore subject

to enorcement actions and sanctions. In the worst case, the test report identified a 120 percentagedifference between the measured and claimed energy consumption.

UK Energy Saving rust, 20102012 Te UKs Energy Saving rust Recommended (ESR) voluntary product labelling scheme isan example o an Environmental Product Inormation Scheme encompassing its own compliancetesting, enorcement activity and evaluation o product compliance.

In 20102012 ES verified the compliance o 24 rerigerating appliances: energy consumptionand storage volume were tested but not the other parameters relevant or the energy labelling(storage temperature, temperature rise time and reezing capacity). Te aim was to veriy the (old

or new) energy labelling declarations and the compliance with the ESR minimum requirements(EEI corresponding to A+ class). As ar as the energy consumption is concerned, 4 models out o the 6 or which a Step 2 test(on 3 additional units o the same model) would have been necessary show a difference betweenthe declared and the measured value largely exceeding the permitted tolerance o the relevantlabelling scheme, while or the other two models the difference is almost negligible. Results o thetests were negotiated with the respective manuacturers and in case o their disagreement, the Step2 (three additional units tested) would have been undertaken. Models considered non-compliantwere removed rom the ES Recommended promotion scheme and results were also shared withthe national market surveillance authority.

Spain IDAE tests, 2008 2011 In Spain IDAE, the Institute or the Diversification and Saving o Energy, manages a nationaldatabase o efficient domestic appliances including the models eligible or the governmental rebatescheme. Compliance verification actions on the declared labelling parameters were run on these modelsaccording to the EU legislation and the relevant harmonised standards. IDAE has acquired romthe manuacturer a sample o the products to be tested that were sent to LCOE (the Official CentralLaboratory). In general, model selection was based on a higher probability o non-compliance. It is worth noting that since only one unit o each model has been tested, no ormal conclusionsabout the compliance with the labelling declaration can be drawn rom the test results.


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Spain ANFEL tests, 20102011 Te Spanish Association o Domestic Appliances Manuacturers, ANFEL, is active in supporting

market surveillance by denouncing non-compliant household appliances and relevant suppliers.Examples o their activities include publishing the results o tests o two models o rerigerator-reezers, accused o not being compliant with the energy label declaration, requesting the nationalAuthorities and the national subsidy scheme organisers to remove these rom the list o modelseligible or the subsidy.

Nordic project: 2011Te aim o the project, financed by Te Nordic Council o Minister and started in 2011, is to

develop the collaboration among Nordic countries or market surveillance, to check the accuracy othe inormation declared on the energy label and i the product ulfils the Ecodesign requirements

or Sweden, Norway, Denmark, Finland and Iceland.Although limited additional inormation is available on the technical characteristics o theappliances tested, this is a good example on how tests developed in one country could be used asthe basis or a market surveillance action in a number o other EU countries.

Te Netherlands: testing in German laboratoryAnother example o the successul use o test results achieved in a laboratory o a different

country is included in the Authoritys Annual report 2009, Energy label compliance in theNetherlands. As reported, most o the tests on household appliances were done in the Germanlaboratory VDE located in Offenbach. Te testing o appliances ollowed a European procurement

procedure, afer which VDE Offenbach (and NO Apeldoorn) were selected to carry out testsin 2009. On the basis o random sampling several appliances rom each category were tested toestablish the compliance with the energy labelling. Tis example demonstrates the possibility oconducting testing in a cooperation between a MSA and laboratory rom different countries.

Intelligent Energy Europe projects 20122014Several European projects are currently developed with the aim to veriy the compliance othe energy consumption and other parameters o certain product groups with the energy labeldeclarations, and/or the Ecodesign requirements. Currently (spring 2013) these projects are:

ALEE II: 50 models o washing machines, all energy labelling and Ecodesign requirementswill be verified, results to be published in 2014,

Ecopliant:motors (3050 models), external power supplies (10 models) and 5 models otertiary sector lamps. Aggregated results expected in 2014,

PremiumLight: ocusing on high quality CFL and LED light sources, 6080 models, testresults expected in 20132014,Euro opten MAX:high efficiency LED lamps, V and tumble drier models, results in 2014,MarketWatch: product categories to be decided, based on high risk o non-compliance,results expected in 2014,ComplianV: 125 Vs and 75 monitors to be tested or energy labelling and Ecodesignrequirement compliance, results expected in 2014.


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Possibilities for a European appliance test results exchange system

Tis chapter is extracted and adapted from the projects document Proposal of European appliancetest results exchange; published in May 2013. Full document is available here:

http://www.come-on-labels.eu/appliance-testing/results-exchange

Market surveillance activities concerning energy labelling and Ecodesign requirements orenergy-related products around the EU is ragmented and systematically carried out only in asmall number o EU member States. Te low level o surveillance can however endanger the overallEU goals on energy efficiency, consumer protection and air competition.

Te main barriers perceived by national Authorities or a more effective market surveillanceaction include the lack o financial resources, lack o expertise, lack o national accredited test

laboratories and a scarce coordination o surveillance actions and sharing o inormation and testresults among Member States.

Project partners have thereore collected the list o testing activities undertaken in individualcountries (see chapter above), but also prepared a document including inormation that couldsupport national Authorities inormation exchange in order to achieve a higher level o marketsurveillance, without increasing the human and financial resources. wo main findings aredescribed in this document, the new 2013 Product saety and market surveillance package and asummary o the elements already included in the existing legislation.

Product Safety and Market Surveillance package 2013

Published in February 2013 this new package describes the possible improvements and utureorganisation o the Market Surveillance Activities in the EU. While mainly ocusing on the saetyo products, it also relates to energy labelling and Ecodesign legislation. Elements addressed by theMSA Packageinclude:

Increased effort or communication between the authorities on an international level,Easier identification and traceability o products under surveillance,Sharing product related surveillance activities among the authorities to avoid duplication oefforts

Promoting and sharing the results o tests among Member States

Summary of the elements already existing in current legislation

Other aspects covered by the existing legislation that are briefly described in the document include:

ADCO Administrative Co-operation Working Group Te tool or market surveillanceauthorities to meet, share and discuss experiences related to product surveillance activities.Meetings take place twice a year, two separate sub-groups exist, concerning energy labelling andEcodesign (in some countries headed by the same organisations, in others by different ones).


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Obligation of suppliers to provide MSA with technical specifications of the productssuppliers shall provide upon request o national Authorities the technical documentation,

supporting energy labelling declarations and compliance with the Ecodesign requirements.

Univocal product identification overview o legislation requirements to univocallyidentiy each model o the products covered by energy labelling and/or Ecodesign measures.

Use of tolerances legislation should clariy that measurement tolerances are or verificationpurposes only and should not be used by suppliers or achieving a better energy labellingranking or to comply with Ecodesign requirements.


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Come On Labels


Promotion of energy labels

Energy labels have proved to be one o the most effective energy effi ciency mechanisms. Teybring easy to understand guidance to the consumers at low cost to the stakeholders. With the new energy labels entering the shops since 2011 and with the list o appliancesand products bearing the energy labels increasing, there is a constant need to help and supportconsumers in using the inormation on the energy label to make inormed purchasing decisions. For this reason, the project partners organised a wide list o dissemination activities andsought to involve other national organisations in order to ensure that consumers will have accessto inormation explaining the content o energy labels. Examples o activities undertaken include media appearances in printed, electronic andbroadcast media; organisation o and appearance at events, seminars, and conerences; elaboration

and circulation o printed leaflets, brochures, posters, and bookmarks. Examples o some o theproject dissemination activities can be ound below.

For the ull list o dissemination activities, please visit the project website:http://www.come-on-labels.eu/promoting-energy-labels/examples-of-promotion-activities

(Please note that the examples feature one sample only from each participating country. Each project

partner has, however, organised a wide set of activities, typically including printed materials, events,

media outcomes, etc.)

Country: AustriaDate: March 2012

Name and type of activity:Information leaflet to consumers circulated by retailersDescription:100 000 copies o leaflets circulated to shops around Austria, incooperation with the retailer association.

Country: BelgiumDate: March 2012

Name and type of activity:Series of information materials on energy labelsDescription:Specific set o leaflets designed or each product group with a newenergy label, explaining its content. Circulated via events, airs, consultationsand seminars.


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Country: Czech RepublicDate: June 2011

Name and type of activity:Publication on new energy labelling elaborated with energy utilityDescription:One o the first consumer oriented publications on the new energylabels, published afer the legislation entered orce. Produced in cooperationwith a major energy utility, which made it available to its customers.

Country: CroatiaDate: June 2012

Name and type of activity:

Organisation of energy days around Croatian municipalitiesDescription: A series o stands, events and inormation centre visitshave been organised in Croatia, to inorm consumers all aroundCroatia on the new energy label content and meaning.

Country: GermanyDate: August 2012


Press release summarising the results of national shop visitsDescription: A press release published in Germany, summarising the resultso the first two round o the shop visits, resulted in numerous articles beingpublished and inorming the public about the state and importance o labeldisplay in shops.

Country: Greece

Date: September 2012


Retailer training to shop chain assistantsDescription: Te retailer training was delivered in Greece in cooperation withmajor shop chain representatives, improving their knowledge on the properlabel display in shops.


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Country: Portugal

Date: April 2012 / February 2013


Series of national V broadcasts via Green Minute programmeDescription: Several broadcasts on national V and Radio stations, aswell as daily papers in Portugal enabled the partner to inorm a widerange o consumers about the emergence o new energy labels.

Country: SpainDate: January June 2012


Set of articles explaining labels to end consumers and retailersDescription: Set o articles published in Spanish media resulted in an increasedawareness on both energy labelling in general, and on the status o labeldisplay in shops.

Country: United KingdomDate: November 2011


Leaflets on energy labels disseminated via shops, events, housing associationsand direct delivery to thousands of homesDescription:Leaflets were produced by the UK project partner, instructing userson labels. Leaflets were disseminated through energy centres and consumerinormation services, with a recommendation rom the national energy authority.

In total, over 580 thousand leaflets, brochures, posters and other in-

ormation materials have been printed and distributedwithin the project by its partners.

In addition, over 115 articles and media and event presentations(printed, online, V, radio, seminars) have been released with more then3 million readers and viewers around the EU.

Regular inormation about the project progress has been also circu-lated to over 220 individual stakeholders on international level by seveneditions o a project newsletter, which was published in English and inpart in Portuguese and Greek languages.


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Early replacement means the replacement o an (old) installed appliance although it is still working.Whether it is environmentally beneficial, depends on the type o appliance. It is measured by the

environmental payback period which denotes the time afer which the environmental impact othe cumulative energy savings outweigh the additional environmental impact rom the prematuredisposal o the old appliance. For the replacement o an average rerigerator-reezer combinationmanuactured in 2000 by a corresponding A++ appliance, this period is only about 2 years in termso cumulative energy demand and global warming potential.

Te ollowing instruments are suitable to promote early and / or better replacement:

Informational Instruments

Communication of life cycle costsTis means consumers are given inormation on the financial savings they can achieve throughoutthe product lie cycle by purchasing a highly efficient appliance. It has the advantage that a generalenvironmental benefit o a product is converted into an individual benefit or the consumer.However, the argument is mainly valid or better replacement, and less so or early replacement.

Market overviews and product databasesMarket overviews and product databases such as www.topten.eu acilitate the purchase process byproviding potential purchasers with an overview o efficient products, their eatures and prices,and eventually their lie cycle costs under average conditions. Hence, they are rather a tool or

better replacement. Tey may be provided by different actors, such as national energy agencies,manuacturers associations, NGOs or other independent bodies.

Additional voluntary labellingIn addition to the mandatory EU energy label, there are voluntary ecolabels both on an EU leveland in some nation states. Te goal is to particularly reemphasize highly efficient products orproducts that, beyond the energy savings, meet urther environmental and quality criteria. Tismeasure can especially promotebetter replacement.

Information campaigns

Inormation campaigns are relatively inexpensive. Teir effectiveness, however, is difficult to assess.Just like voluntary labelling, they are generally more effective in combination with other tools. Onthe other hand, many other instruments need to be accompanied by inormation campaigns inorder to draw consumers attention to the existence o that instrument.

Measuring energy consumptionTe measurement o the energy consumption o appliances in a private household is an appropriatemeasure to promote early replacement. Firstly, it may raise the consumers awareness to an associatedcost. Secondly, it can orm an integral part o a replacement programme. For example, in-housemeasurement may be used to determine the eligibility o a household / appliance to participate ina subsidy program.


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Financial incentives

Financial incentives can address the dilemma when the reduced energy costs could make adifference or low-income households and businesses, while they ofen lack the finances or theupront investment.

Direct subsidies to consumersTe basic idea is to provide consumers o particularly efficient appliances (who are at the same timedisposing o an old appliance) with a financial reward. Tis is one o the most popular instruments.Examples o national programmes abound, and there are even more examples o programmes setup by trade, manuacturers or energy companies.I the measure is limited in terms o time or budget, rather early replacementwill be stimulated. I

it is planned on a long-term basis (i.e. over several years), better replacementis promoted more orless ad infinitum, thus bringing orward alling prices and a longer-term market transormation.

Fiscal incentives for consumersax incentives have been extremely successul or major household appliances in Italy. But in othercountries, they are rarely applied or household appliances. Tis is probably due to the comparablylow purchase price o these devices, and, as a result, o the high administrative costs. ax benefitsthereore are primarily applied in the building sector, relating to equipment such as boilers, waterheaters or air-conditioning systems (which are or will be also covered by the EU energy label).

Indirect subsidiesIn the case o indirect subsidies, as practised in the Eco-point system in Japan or the Korean

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