Revision of the EU ecolabel criteria for dishwashers...AEAT in Confidence AEAT/ENV/R/0750 Issue 1...

AEAT in ConfidenceAEAT/ENV/R/0750 Issue 1

AEAT in Confidence

Revision of the EU ecolabelcriteria for dishwashers

A report produced for Department for theEnvironment, Food and Rural Affairs

August 2001

AEAT in Confidence AEAT/ENV/R/0750 Issue 1

AEAT in Confidence AEA Technology ii

Title Revision of the EU ecolabel criteria for dishwashers

Customer Department for the Environment, Food and Rural Affairs

Customer reference

Confidentiality,copyright andreproduction

AEAT in Confidence

This document has been prepared by AEA Technology plc inconnection with a contract to supply goods and/or services and issubmitted only on the basis of strict confidentiality. The contentsmust not be disclosed to third parties other than in accordance withthe terms of the contract.

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Report number AEAT/ENV/R/0750

Report status Issue 1

AEA Technology EnvironmentE6 CulhamAbingdonOxonOX14 3EDTelephone +44 (0)1235 463156Facsimile +44 (0)1235 463001

AEA Technology is the trading name of AEA Technology plcAEA Technology is certificated to BS EN ISO9001:(1994)

Name Signature Date

Author J Poll

Reviewed by P Dolley

Approved by S J Richardson


AEAT in Confidence AEA Technology iii

Executive Summary

Ecolabelling, or environmental labelling, is a guide to consumers which helps them makeinformed environmental choices about the products and services that they require. The EUecolabelling scheme is one of a number of ecolabelling schemes that set criteria for productsand services. EU ecolabel criteria for dishwashers were established in 1993, and were revisedin 1998. A further revision needs to be conducted during the year 2001.

One manufacturer has obtained an ecolabel for the criteria established in 1998.

The main environmental impacts for a dishwasher occur during the use phase. Consequentlythis revision set more stringent requirements for both energy consumption and waterconsumption. As noise is becoming a more important environmental issue, the noiserequirements were also made more stringent. Other changes made the environmental criteriain areas such as use of flame retardants, and take-back and recycling, much more similar tothose set in the recent revisions of criteria for other electrical products. In addition, ascleaning and drying performance are important issues for consumers, the requirements herewere also increased.

The new criteria will be valid for five years. The next revision will give particular attention toissues such as energy consumption, flame retardants, the availability of replacement parts, andtest procedures, including third-party testing.


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Contents

1 Introduction 1

2 Background information 2

2.1 DEFINITION OF THE PRODUCT GROUP 22.2 MARKET AND SALES 32.3 LIFE-CYCLE CONSIDERATIONS 32.4 EXISTING ECOLABELS 42.5 APPLICATIONS FOR ECOLABELS 52.6 TEST METHODS 52.7 SOURCES OF DATA 6

3 Environmental issues 6

3.1 ENERGY SAVINGS 73.2 WATER CONSUMPTION 93.3 PREVENTION OF EXCESSIVE USE OF DETERGENT 113.4 CLEANING AND DRYING PERFORMANCE 113.5 NOISE 123.6 FLAME RETARDANTS 143.7 TAKE-BACK AND RECYCLING 153.8 LIFE-TIME EXTENSION 153.9 PACKAGING 153.10 OTHER POSSIBLE CRITERIA 16

4 The new criteria 16

4.1 ENERGY CONSUMPTION 164.2 WATER CONSUMPTION 174.3 DETERGENT USE 174.4 CLEANING PERFORMANCE AND DRYING PERFORMANCE 174.5 NOISE 174.6 TAKE-BACK AND RECYCLING 184.7 LIFETIME EXTENSION 184.8 APPLIANCE DESIGN 184.9 USER INSTRUCTIONS 184.10 CONSUMER INFORMATION 184.11 OTHER POSSIBLE CRITERIA 194.12 TEST REQUIREMENTS 19

5 Views of interested parties 19

5.1 VIEWS OF INDUSTRY 195.2 VIEWS OF CONSUMERS 21


AEAT in Confidence AEA Technology vi

5.3 VIEWS OF RETAILERS 215.4 HOW THE ECOLABEL PROFILE COULD BE RAISED 21

6 Conclusions 23

Appendices

APPENDIX 1 MARKETS AND SALES FOR DISHWASHERS


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AEAT in Confidence AEA Technology 1

1 Introduction

Ecolabelling, or environmental labelling, is a guide to consumers which helps them makeinformed environmental choices about the products and services that they require.Ecolabelling makes a positive statement that identifies products and services as being lessharmful to the environment than similar products or services used for a specific function. It isalso fundamentally different from the setting of minimum product standards or requirements;the key difference is that ecolabelling is intended to reward environmental leadership.

Ecolabelling is based on a life cycle assessment which considers the impact on theenvironment at every stage of the product’s life cycle from cradle to grave. Criteria are thenestablished on the key environmental effects and identify products that have a substantiallylower environmental impact. Criteria are also established on performance in order to ensurethat ecolabelled products are fit for use and perform to the same standards as other products inthe category. The criteria are reviewed and possibly made more stringent at regular intervals(usually three years) to allow for improvements in environmental performance.

The EU ecolabelling scheme1 is one of a number of ecolabelling schemes which set criteriafor products and services. EU ecolabel criteria for dishwashers were first set in 1993, andwere revised2 in 1998. They set key criteria for energy consumption, water consumption, anddetergent use. When the current criteria were set in 1998, it was stated at the ecolabelRegulatory Committee that the next revision would need to pay particular attention to thefollowing areas;

• Reducing water and energy consumption• Encouraging designing a dishwasher to facilitate the recycling and reparability of its

component parts• Assessing the issues for packaging.

As the criteria for dishwashers now need to be revised, this report has been produced toaccompany the Commission Decision on the new criteria.

The development of ecolabel criteria involves widescale consultation with ecolabel competentbodies3 in each Member State, other members of the consultation forum (for exampleenvironmental groups, retailers and European consumer associations), the manufacturerapplying for the current ecolabel, and the main trade association4. Comments were alsoreceived from other organisations, including the UK Consumers’ Association. Copies of thediscussion documents, and the draft criteria were also made available at the EU ecolabelinternet site. Possible criteria were then discussed at two ad-hoc working group (AHWG)

1 Regulation (EC) No 1980/2000 of the European Parliament and the Council of 17 July 2000 on a revisedCommunity Eco-label Award Scheme. OJ L 237, 21 September 2000, page 12 Commission Decision 98/483/EC establishing the ecological criteria for the award of the Community eco-labelto dishwashers. OJ L 216, 4 August 1998, page 123 Information on competant bodies and members of the consultation forum is available at the EU ecolabelinternet site: http://europa.eu.int/comm/environment/ecolabel/index.htm4 Information and comments were obtained from both the European trade association (CECED) and from otherEuropean manufacturers of dishwashers



meetings5, and the views expressed in these meetings enabled the final criteria to bedeveloped.

The report compares the current EU ecolabel criteria for dishwashers with those set by otherecolabels, such as the German BlueAngel and the Nordic Swan. It then discusses theenvironmental and technical issues involved with possible changes to the ecolabel criteria,and presents the new criteria. These criteria were subsequently agreed by the European UnionEcolabelling Board (EUEB) and the Regulatory Committee of the EUEB at their meeting inJune 2001.

2 Background information

This chapter of the report provides information on a number of factors, including thedefinition of the product group, the life-cycle considerations which enabled ecolabel criteriato be established, and a brief comparison of the EU ecolabel with other ecolabels fordishwashers. It also identifies suitable test procedures which could be used to determine if adishwasher was able to meet the specific values set by possible criteria.

2.1 DEFINITION OF THE PRODUCT GROUP

The definition of the product group ‘dishwashers´ used in setting the ecolabel criteria is;

“Electric mains-operated household dishwashers sold to the general public.Appliances that may also use other energy sources, such as batteries, or have nointernal heat source, are excluded”.

This definition of a dishwasher only covers dishwashers intended for use in households. Thisis because a number of criteria are related to requirements determined by the energy label, andthe energy label legislation for dishwashers indicates that it only covers householddishwashers.

The energy label sets requirements for any size (number of place settings) of dishwasher.This means that any criteria which are developed will apply to any household dishwasher.

5 Minutes of these meetings are available at the EU ecolabel web site;http://europa.eu.int/comm/environment/ecolabel/index.htm



2.2 MARKET AND SALES

This section summarises the information on markets for dishwashers contained in Appendix Iof this report.

Although sales of other consumer durables such as washing machines and refrigeratorsremain relatively constant as the market is now saturated, the yearly sales of dishwashers haverisen significantly since the early 1990’s. The market for dishwashers can be characterised asan initial acquisition market, with many consumers buying their first dishwasher rather thanjust replacing their old one. The overall average market saturation in the EU is 38%, and thisranges from about 50% in some EU countries, such as Austria, Germany and Sweden, to onlyabout 25% in some other EU countries, such as the UK.

There are about 10 important producers in Europe, but most of the dishwashers sold in the EUare produced in either Germany or Italy. The two main sizes of machine which are sold arethose with either 8 or 12 place settings. Nearly 90% of dishwashers sold in the EU are 12place setting machines, and a large proportion of other sales are dishwashers with 8 placesettings. Small dishwashers (4 place settings) are becoming more popular in some EUMember States, but they currently represent less than 2% of current dishwasher sales.

The following generic types of dishwasher are referred to in this report;

• Large – over 10 place settings• Medium – 6 to 9 place settings• Small – up to 5 place settings.

Dishwashers can be either free-standing or built in to existing kitchen cabinets, and it appearsthat sales of each type throughout the EU are about 50%. However, data indicates that, forexample, a higher percentage of built-in units are sold in the Netherlands.

2.3 LIFE-CYCLE CONSIDERATIONS

A life-cycle analysis (LCA) of a dishwasher was conducted6 when the first ecolabel criteriawere being developed in 1992. Table 1 shows the percentage contribution of the life-cyclestages to the total environmental impact.

6 Ecolabelling criteria for dishwashers. PA Consulting Group, May 1992.



Table 1: Summary of the Life-cycle analysis of a dishwasher

Production Distribution Use Disposal TotalEnergy 1.8 0.3 97.9 <0.1 100Critical air volume 1.6 0.6 94.7 0.1 100Critical water volume 0.8 0.9 97.0 1.3 100Solid waste 4.3 2.1 88.0 5.6 100Water consumption 3.2 0.3 96.5 0.0 100

This identifies that the overall environmental impact of a dishwasher is dominated by the usephase, and that energy and water consumption during use are significant environmentalfactors. Consequently the ecolabel criteria which were developed in 1993 were aimed atpromoting reductions in both energy and water consumption. A further key criterion aimed atreducing water pollution by preventing unnecessary detergent consumption was introducedwhen the criteria were revised in 1998.

Although overall dishwasher performance has been improved since the LCA was conductedin 1992, there have been no significant changes in dishwasher design since then.Consequently, it is unlikely that improvements in energy and water consumption during theuse phase which have occurred since 1992 will have any significant effect on the originalconclusion that most of the environmental impacts of a dishwasher occur during the usephase.

2.4 EXISTING ECOLABELS

In addition to the EU ecolabel, there are a number7 of other ecolabels which have set criteriafor dishwashers. These include Germany (the Blue Angel), and the Nordic countries (NordicSwan). All of these ecolabels include criteria on energy consumption, water consumption,and take-back and recycling. Table 2 compares the types of criteria in the European ecolabelsfor dishwashers. This shows that the main difference between the current EU ecolabel andthe other European ecolabels is that the current EU ecolabel does not have a criterion on theuse of flame retardants.

7 Information from the Global Ecolabelling Network (GEN). http://www.gen.gr.jp



Table 2: Comparison of EU ecolabel with other ecolabels

EU 1998 Blue Angel, July 1999 Nordic Swan, October1999

Energy consumption 10 or more place settings –Energy label class A or BLess than 10 place settings –Energy label class A, B or C

Energy label class Afor any number ofplace settings

Linear equation (values arelower than 1998 EUecolabel values formachines with 12 or lessplace settings, but higher for13 or more place settings)

Water consumption Linear equation Linear equationValues are less than1998 EU ecolabel, butdifference reduces asnumber of placesettings increases

Linear equationValue is less than 1998 EUecolabel for up to 9 placesettings, and higher for 10or more place settings

Detergent use Markings on the detergentdispenser

No criteria Linear equation based onnumber of place settings

Noise < 55 dB(A) for free standingmodels< 51 dB(A) for built-in models

< 49 dB(A) for built-inor free-standing models

< 59 dB(A) free standing< 51 db(A) for built-inmodels

Cleaningperformance

More than 0.88 tested usingEN 50242 (i.e. A, B or Cmarking for energy label)

More than 1.12 testedusing EN 50242 (i.e. Amarking for energylabel)

More than 0.90 tested usingEN 50242

Drying performance More than 0.78 tested usingEN 50242 (i.e. A, B or Cmarking for energy label)

More than 0.93 testedusing EN 50242 (i.e. Aor B marking forenergy label)

More than 0.70 tested usingEN 50242

Flame retardants No criteria List of substances thatcan not be used incertain parts

A list of flame retardantsthat can not be added toplastic materials.

Take-back andrecycling

Criteria Criteria Criteria

The main points to note from this table are that the current Blue Angel requirements forenergy consumption, water consumption and noise are much stricter than those set by thecurrent EU ecolabel. The Blue Angel also sets higher performance standards for bothcleaning and drying performance than the current EU ecolabel.

2.5 APPLICATIONS FOR ECOLABELS

There have been no applications for either the Blue Angel or Nordic Swan ecolabels.However, one manufacturer of smaller (8 place) dishwashers applied for an EU ecolabelunder the existing criteria in December 2000.

2.6 TEST METHODS

The test method for dishwashers is EN 50242 which was developed for the dishwasher energylabel. However, one issue which needs to be considered is that it is possible that a test,conducted by different laboratories, can show different results for the same machine. This is



because of the tolerances used in the tests, including factors such as ambient temperature,temperature of the incoming water, and the thermostat. These can lead to a difference of oneclass (and sometimes to two class differences). In addition, different interpretations of thetolerances can also result in a difference of one class in the final result.

In addition to the test tolerances, production tolerances can also be high as 10-15%.Consequently, the recent revision of the ecolabel for washing machines takes into account thetolerances in both manufacture and testing by specifying that the average result obtained fromtesting three machines should be less than the ecolabel requirement, and the efficiency classindicated on the energy label shall correspond to this mean value. There does not appear to beany reason why a similar requirement could not be adopted for dishwashers.

2.7 SOURCES OF DATA

The main European trade association, CECED, has produced databases showing the energylabelling markings for a number of domestic appliances. Although the energy label fordishwashers was introduced in 1997, it was only implemented in most Member Statesduring1999 (two years implementation period). This means that CECED has not yet beenable to produce a database which could be used in establishing criteria. However, they hopeto produce such a database during the year 2001. Consequently the information presented inchapter 3 has been obtained from the ELDA database. This is based on dishwashers on themarket in Denmark but is considered by CECED to be representative of dishwashers on themarket in the EU.

All the information presented is based on measurements determined using the test procedureEN 50242 used for the energy label for dishwashers.

3 Environmental issues

An objective of the EU ecolabel is to encourage manufacturers to market machines withreduced overall environmental impacts, with the aim of helping consumers make informedchoices based on sound environmental information. In order to be awarded the EU Eco-labela dishwasher needs to comply with criteria, developed from life cycle considerations, whichare aimed at promoting reductions in energy and water consumption, and a reduction in waterpollution through reduced detergent consumption. Other important factors which need to beconsidered are noise levels and the issues regarding flame retardants. In addition, asperformance is an important issue for consumers, it is also necessary to consider if criteriawhich reduce energy and water consumption will still enable a dishwasher to achieve asatisfactory cleaning and drying performance.



3.1 ENERGY SAVINGS

Energy consumption was identified by the life-cycle analysis as having a significantenvironmental impact. However, the electricity consumption of a 12 place dishwasher hasreduced from 2.5 kWh/cycle in the late 1970’s to less than 1.1 kWh/cycle in the late 1990s(the current A rating for a 12 place setting machine is < 1.06 KWh/cycle) which is a reductionof over 50% in the last 20 years. The current EC ecolabel criteria set a requirement for;

• Machines with 10 or more place settings to meet either class A or B for the energylabel (less than 1.25 kWh/cycle for a 12 place machine),

• Machines with less than 10 place settings have to meet either class A, B or C (lessthan 1.03 kWh/cycle for an 8 place machine).

These levels are much easier to achieve than those set by the Blue Angel scheme where alldishwashers have to achieve an A energy rating.

The main manufacturers trade association, CECED, established a voluntary agreement acrossthe EU on sales of dishwashers in November 1999. The first stage of this requiresparticipants to stop producing, and importing into the Community Market, dishwashers whichbelong to the energy efficiency classes E, F and G (for >=10 place settings) or F and Grespectively (for <10 place settings) by 31 December 2000. The second stage requiresparticipants to stop producing, and importing into the Community Market, dishwashers whichbelong to the energy efficiency class D (for >=10 place settings) or E respectively (for <10place settings) by 31 December 2003.

Table 3 shows the energy efficiency of dishwashers on the market, in terms of the number ofmachines in each category. This shows that over 35% of large dishwashers on the markethave an A energy rating.

Table 3: Energy efficiency of dishwashers on the market

Number of place settingsEnergyconsumption < 5 6 - 9 10 or more

A - 1 49B - 1 29C 1 1 36

D or worse 2 7 14Total 3 10 128

Source: ELDA database (Denmark), November 2000

As over 35% of large dishwashers already achieve an A energy rating, setting a new criterionbased on an A rating offers little incentive to manufacturers to either apply for an ecolabel orto continue to reduce energy consumption. Similar situations for both washing machines andfridges resulted in the recent revisions of the criteria for both washing machines and fridgessetting an A+ criteria for energy consumption. This A+ rating is 10% lower than the A ratingand is intended to provide a clear incentive to manufacturers on the potential market



advantage of developing machines which can meet this criterion. A similar approach could beused for larger dishwashers.

An A+ class rating of 10% better than the A rating for large dishwashers would set a target of0.96 kWh/cycle for a 12 place setting machine (the current A rating for a 12 place dishwasheris < 1.06 KWh/cycle). Although no dishwasher currently meets this target, one manufactureris producing a 12 place setting dishwasher with an electricity consumption of 0.99 kWh/cycle.This is 5% better than the A requirement, and suggests that setting an A+ level of 5% wouldpotentially enable this manufacturer to apply for an ecolabel in the knowledge that they wouldmeet the criteria for the proposed 5 year lifetime of the revised criteria. Improvements inexisting technologies could enable an A+ requirement of 10% to be reached for largedishwashers within the proposed 5 year lifetime, but this would mean that no dishwashers inthe main sector of the market could qualify for an ecolabel until the time when the nextrevision starts to be considered.

Although a significant percentage of large dishwashers currently on the market have an Aenergy rating, Table 3 shows that the majority of both medium and small dishwashers on themarket currently have an energy rating of D or worse. The energy label formula fordishwashers makes it more difficult for smaller dishwashers to achieve an A energy rating,and this has meant that manufacturers have tended to concentrate on reducing the energyconsumption of larger dishwashers. Developments used to reduce the energy consumption oflarger dishwashers, such as the use of sensor technology, can also be used to reduce theenergy consumption of smaller dishwashers, but it is highly unlikely that these would enableany smaller machine to achieve an A+ for energy consumption. Consequently, lower energyefficiency requirements have to be set for smaller dishwashers. The data in Table 3 indicatesthat one of the seven medium size (6 to 9 place settings) dishwashers achieves an A rating.An A rating would be a much stricter requirement than the current requirement for either A, Bor C for this size of dishwasher, and would also be compatible with the Blue Angel setting forthis size of dishwasher. A potential applicant for the ecolabel produces medium sizeddishwashers which have a B energy rating, but these would need to be re-designed to achievean A energy rating.

Table 3 also shows that none of the small (less than 5 place settings) dishwashers on themarket currently achieves either an A or B rating. There are also technical problems inachieving an A rating for a small (up to 5 place settings) dishwasher. Consequently, an A orB requirement for small dishwashers would still provide an incentive for further development,and would still be a stricter requirement than the current EU ecolabel rating of A, B or C forthese machines.

Hot-fillAlthough the energy label is based on cold-fill of a dishwasher, there are environmentalbenefits in using hot-fill when efficient oil or gas fired boilers are used to heat the water. Thisis because they have a better efficiency in use of primary fuel when compared to heatingwater using electricity (however the situation may be different in countries that use renewableenergy, such as hydropower, to a large extent). Over 90% of dishwashers are already suitablefor connection to a hot-fill supply, and the only change required for dishwashers whichcurrently can not use a hot-fill supply is to use a different material in the connection pipe.

Stand-by consumption



The German ‘Blue Angel’ scheme sets a maximum stand-by consumption for both “end ofprogramme” and “off” modes, but neither of these modes is defined. However, the stand-byconsumption of a dishwasher is small when compared to the energy consumption in use; forexample some dishwashers have timers which enable them to operate during the night. Inaddition, all dishwashers have an off switch, and do not use any energy when switched off.

There is no clear definition of stand-by consumption for a dishwasher, and there is also noagreed method for measuring it. There is also no published voluntary agreement which couldbe used as a basis for setting a criterion in this area. In addition, the criterion on userinstructions requires manufacturers to inform users on the levels of any stand-by consumptionwhich may occur. Consequently it is difficult to see how a criterion on stand-by consumptionof a dishwasher could be developed. However, the relationship between stand-byconsumption and new functions such as blue-tooth connectivity is an issue that could beconsidered in the next revision of the criteria for dishwashers.

3.2 WATER CONSUMPTION

Water consumption was identified by the life-cycle analysis as having a significantenvironmental impact. However, the amount of water used by a dishwasher has reduced byabout 75% in the last 20 years. The main reason for the reduction in water consumption is todevelopments which have reduced energy consumption. Table 4 shows that there is a generalcorrelation between water consumption and energy use; for example A energy rateddishwashers generally use less water than B energy rated dishwashers.

Table 4: Water consumption of large dishwashers

Water consumption (% of large dishwashers)Energy rating

< 15 litres 15-17 litres > 17 litresA 24 10 3B 4 16 3C - 18 10D - 1 9E - - 2


All of the current ecolabels for dishwashers set a criterion for water consumption which uses alinear formula based on the number of place settings. Table 5 shows the calculated waterconsumptions for 8 and 12 place setting machines for the current EU, Blue Angel and NordicSwan criteria.

Table 5: Water consumption criteria

8 place settings (litres) 12 place settings (litres)EU ecolabel < 15.2 < 18.4



Blue Angel <14.3 < 16.8Nordic Swan < 15 <20

This shows that for dishwashers with 12 place settings, the current EU requirement of < 18.4litres is now significantly higher than the water consumption figures which can be achievedby A energy rated machines.

Although there is a correlation between energy consumption and water use, the use ofadditional water can enable a better cleaning performance to be achieved in a shorter time.This means that it is necessary to assess the relationship between water consumption, washingperformance and energy consumption before the values for a criterion on water consumptioncan be decided. Table 6 shows that over 60% of dishwashers with 12 place settings and an Aenergy rating achieve either an A or B for cleaning performance whilst using less than 15litres of water.

Table 6: Cleaning performance of dishwashers with 12 place settings and an A energyrating

Cleaning performance (number of machines)Water consumption

A B C or worse< 15 litres 18 11 -15-17 litres 4 12 -> 17 litres - - -


As A energy rated 12 place dishwashers using less than 15 litres of water can produce a levelof cleaning performance (A or B) which is acceptable to consumers, this suggests that there isscope to significantly reduce the current ecolabel criteria of over 18 litres. In addition, asignificant reduction in a criterion on water consumption may not be necessary as a 12 placedishwasher would be unable to meet the proposed A+ energy rating if its water consumptionwas too high.

As all the European ecolabels use a linear formula based on number of place settings to set arequirement for water consumption, one option would be to develop a new formula whichtook account of the current water consumption of both 8 place and 12 place machines.However, the formula used by the German ‘Blue Angel’ sets similar water consumption ratesfor small (less than 5 place settings machines) to the current EU ecolabel but lower values forthe larger machines. Consequently this may be the best option even though largerdishwashers can easily meet the current requirements (< 17 litres for a 12 place settingdishwasher).



3.3 PREVENTION OF EXCESSIVE USE OF DETERGENT

The current EU ecolabel criterion promotes a reduction in water pollution through reduceddetergent consumption – a key issue identified from life cycle considerations. This requiresmarkings on the detergent dispenser which enable the user to adjust the detergent quantityused according to the type and amount of dishes to be washed and its degree of soiling.However, the availability of different types of detergent, for example normal or concentratedpowders, makes it more difficult for the detergent container to be suitably marked for all typesof detergent. Consequently, as the instructions provided with the detergent should enable theuser to determine the required quantity of detergent to be used, it is difficult to see how thiscriterion could be changed.

3.4 CLEANING AND DRYING PERFORMANCE

Ecolabelled dishwashers must achieve an acceptable level of performance if they are to beacceptable to consumers. The current ecolabel criterion for both cleaning performance anddrying performance is either A, B or C as measured using test method EN 52402. This is alower performance requirement than that for the German ‘Blue Angel’ scheme which setsrequirements of A for cleaning performance and A or B for drying performance using testmethod EN 52402.

Although A energy rated machines can achieve a class A for both washing performance anddrying performance, it appears unlikely that an A+ energy rated machine could achieve bothclass A for cleaning and class A for drying. This is because overall energy consumption ,cleaning performance and drying performance are related. However, it is more likely thatmachines with an A+ energy rating could achieve both a cleaning performance of class B anda drying performance of class B.

Lower levels of cleaning and/or drying performance can be achieved more easily if amanufacturer wishes to design a dishwasher able to meet an A+ energy rating. However,cleaning and drying performance are likely to be important issues for consumers. This meansthat they may well prefer to purchase dishwashers which achieve high levels of cleaning anddrying rather than those which achieve an A+ for energy consumption, but only achieve a Dfor cleaning and/or drying.

Although the ecolabel is not a performance standard, the data in Table 6 indicates that 12place machines with an A energy rating can achieve an A or B rating for cleaningperformance. These dishwashers are also able to achieve either an A or B rating for dryingperformance. However, dishwashers with an A energy rating which also achieve an A ratingfor cleaning performance can require a cycle time of up to 3 hours, and this is not acceptableto some consumers. Thus if the Ecolabel wishes to set an average performance, this requiresa dishwasher to achieve at least a B for both cleaning performance and drying performance.A requirement for either A or B for both cleaning performance and drying performance wouldencourage manufacturers to develop dishwashers which are both highly energy efficient andprovide a cleaning and drying performance which meets current consumer expectations.



3.5 NOISE

Noise is becoming more important on the environmental agenda. However noise levels fromdishwashers have reduced, and Table 7 shows that the current levels are significantly lowerthan a typical figure of about 70 dB(A) for a dishwasher produced in the early 1990’s.



Table 7: Noise levels for dishwashers

A energy rated dishwashers with 12 place settings<48 dB(A) 48-49 dB(A) 50-52 dB(A) >52 dB(A)

Built-in 13% 53% 31% 3%Free-standing - - 83% 17%


The measured noise levels for built-in dishwashers are lower than those for free-standingdishwashers. This is because the Energy Label test method (EN 50246) requires built-indishwashers to be tested inside a suitable cabinet and this reduces the level of noise emissionsmeasured outside the cabinet. Consequently it is necessary to set higher values for free-standing dishwashers than the values set for built-in dishwashers.

The current EU ecolabel criterion sets a requirement of < 55 dB(A) for free-standing modelsand <51 dB(A) for built-in models. The data shown in Table 7 indicate that over 65% of Aenergy rated built-in dishwashers, and over 80% of A energy rated free-standing dishwashersmeet the current EU ecolabel requirements. Table 7 also indicates that some built-inmachines can meet the German ‘Blue Angel’ criteria of < 49 dB(A). However, as measuresto reduce noise increase the cost of a machine, consumers may not be willing to pay formachines which have noise levels of less than 48 dB(A).

The information in Table 7 suggests that the existing values could be lowered to < 50 dB(A)for built-in dishwashers, and to < 53 dB(A) for free-standing dishwashers. These valueswould be achieved by 65% of A energy rated built-in dishwashers, and 80% of free-standingdishwashers. These levels are still higher than that set by the Blue Angel for all dishwashers,but they are acceptable to industry.

The potential environmental impacts of the materials used to reduce noise emissions also needto be considered. It is likely that these materials perform two functions; thermal insulationand noise reduction. The Blue Angel sets a criterion on insulating materials which requiresthem to be classified as not carcinogenic or suspected of causing cancer. The criterion alsostates that ceramic mineral fibres with a content of alkali metal oxides or alkaline earth metaloxides of < 18 weight per cent must not be used.

Although the EU ecolabel was not initially intended to be used to set health and safetycriterion, the new regulations have identified the need to consider health and safety issues.The main potential health and safety impact of the insulating material is likely to be fromemissions of dust when the dishwasher is dismantled or shredded during the recyclingprocess. However, this is likely to be a very small percentage of the total environmentalimpact of a dishwasher. Consequently, as ecolabel criteria should consider the main impacts,there appears to be no justification to set a criterion for the insulating materials.



3.6 FLAME RETARDANTS

Fire safety is an integral part of fire precautions. Fire precautions minimise the number of,and damage from, fires by reducing their initiation and limiting their propagation, meaningthat life, health and property are protected. Flame retardants enhance the fire safety level ofcombustible materials like plastics, and are used in the circuit boards of electrical andelectronic equipment. However, careful design can reduce the possibility of a fire startinginside the equipment, and also the possibility of a fire spreading outside the equipment.

Different types of flame retardants are better suited for different types of applications. Theirsuitability depends on factors such as the material to be flame-retarded, the fire safetystandards with which the material must comply, and cost considerations. Brominated flameretardants are often the most cost effective flame retardant when both performance and costare considered. In addition, the lower concentrations of brominated flame retardants requiredfor most applications means that they are less likely to affect the physical and mechanicalproperties of the materials they are added to than other types of flame retardants.

Brominated flame retardants (BFRs) have attracted considerable interest over the past fewyears because of their alleged persistence in the environment. A report8 from the WorldHealth Organisation recommended that they should not be used where suitable replacementsare available, and the Swedish National Chemicals Inspectorate (KEMI) has proposed thattwo groups of BFRs - polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers(PBDEs) - should be phased out within five years. However, it is important to recognise thatBFRs can achieve a high standard of fire safety, and a study9 has identified that the benefits offlame retardants in reducing the risk from fire outweighs the risks to human health. There arealso health concerns about some types of alternative flame retardants.

This is a complex area for an ecolabel to deal with. A working group of fire codeenforcement officials in the USA, the USA Environmental Protection Agency, the SwedishNational Chemicals Inspectorate and the Swedish Environmental Protection Agency areassessing options to replace flame retardants which cause unacceptable harm to theenvironment while maintaining a high level of fire protection. In co-operation with thisprogramme, the major European Green labels, including the EU ecolabel, will recognise thatenvironmental quality, fire safety, and health are of equal priority and will establish criteriaaccordingly. Recommendations from this programme will be presented to eco-label schemesas evidence that technologies have achieved significant improvements in fire safety, healthand environmental quality.

There is no criterion on flame retardants in the current EU ecolabel for dishwashers. Allplastic materials which are in close proximity to electric current and switches need to containflame retardants for fire safety reasons. The areas where flame retardants will be used indishwashers include circuit boards, the supports for contacts, switches, thermostats and thecasings of timers. The recent revisions of the EU ecolabel criteria for other electricalproducts, such as washing machines, include restrictions on a number of flame retardants aspart of a criterion on take-back and recycling, and a similar criterion could be introduced for 8 International programme on chemical safety; environmental health criteria 205: Polybrominated dibenzo-p-dioxins and dibenzofurans.9 Risks and benefits in the use of flame retardants in consumer products. Report by UK Department of Trade &Industry, URN 98/1026, January 1999.



dishwashers. This criterion also considers health impacts from all types of flame retardantthrough the use of risk phrases. However, future ecolabel revisions will need to concentrateon the wider health and environmental issues regarding flame retardants, particularly if firesafety standards are considered to be an important issue.

3.7 TAKE-BACK AND RECYCLING

This is an area which will be covered by the proposed Directive on waste electrical andelectronic equipment (WEEE), and this will set requirements for dishwashers. The text usedin the recent revisions to the EU ecolabels for washing machines and fridges appears to coverall requirements, including the requirements on flame retardants.

3.8 LIFE-TIME EXTENSION

The current criteria for both washing machines and fridges include a criterion on life-timeextension. This requires the manufacturer to offer a commercial guarantee that thedishwasher will function for at least 2 years, and to ensure the availability of compatiblereplacement parts for 12 years from the time that production ceases. Consequently there is aneed to consider if a similar criterion should be included for dishwashers.

The issues surrounding lifetime extension are complicated. In common with many electricalgoods, the life cycle profile of dishwashers is such that the key environmental impacts occurduring the in-use phase. For dishwashers, 90%+ of impacts are due to electricity, water anddetergent consumption. Many machines (including dishwashers) are designed and tested tohave a long life; this may translate to many years of service before the product fails andrequires repair. Depending how the product has failed it may be possible to effect a repair byreplacing the faulty component, thus making the product fully operable once more. Indeedthe product could go on to give many more years of reliable operation before it fails again.Clearly, from a life cycle perspective, repairing a product reduces the environmental impactsattributable to resource depletion – rather than buy a replacement, new machine the consumersimply buys a new component.

Although it can be argued that, from an environmental perspective, the ecolabel should notencourage the indefinite repair of old dishwashers because newer dishwashers will be moreenergy efficient, there is no significant evidence to suggest that using a dishwasher for over12 years is environmentally damaging. The requirement to provide replacement parts for upto 12 years is also acceptable to the industry. However, this issue could be considered inmore detail during the next revision of the ecolabel criteria for dishwashers.

3.9 PACKAGING

The packaging used for dishwashers is similar to that used for washing machines; mostmachines use cardboard top and bottom trays held together by plastic straps. The plastic strapis unlikely to be made of PVC. Cardboard packaging already includes recycled material.



The current EU ecolabel for dishwashers has no criterion on packaging. Packaging representsa very small proportion (less than 0.5%) of the total environmental impact of a dishwasher. Inaddition, the recent revisions of the criteria for both washing machines and fridges did not setcriteria for packaging. Consequently, as ecolabel criteria should consider the main impacts,there appears to be no justification to set a criterion for packaging.

3.10 OTHER POSSIBLE CRITERIA

There are a number of other areas where criteria could be introduced.

• Use of lead free solder – Manufacturers are looking at alternatives, but it may not bepossible to replace the use of lead solder in dishwashers during the next two to threeyears.

• PVC - Although there are environmental concerns about PVC, it is only used inspecial components in dishwashers; insulation material for cables, and for water-hoses. The amounts used are small, and the PVC can be recycled. In addition, there isno other material with the same properties in terms of recyclability, inflammabilityand costs.

• Paint and coatings – These represent a very small proportion of the totalenvironmental impact of a dishwasher.

All of these possible criteria will have a very small effect on the overall environmental impactof a dishwasher.

The development of ecolabel criteria should consider the main impacts for the product groupidentified through life cycle considerations. Consequently introducing criteria which have aminor environmental impact is not only unattractive to applicants, but will also achieve littleby way of reducing environmental improvement.

4 The new criteria

This chapter of the report briefly describes the criteria which were agreed through discussionat the AHWG meetings, and the reasons why they were adopted.

4.1 ENERGY CONSUMPTION

The proposed criterion is;

• Energy label rating of A+ (10% better than A) for large dishwashers (over 10 placesettings)

• Energy label rating of A for medium dishwashers (6 to 9 place settings)• Energy label rating of A or B for small dishwashers (up to 5 place settings)



For large dishwashers, an A+ requirement which is 10% above the A rating is a clear stepabove the energy label, is compatible with other ecolabels, and provides an incentive tomanufacturers. One manufacturer already produces a large dishwasher which is 5% betterthan the requirement for the A energy rating. In addition, a tolerance level of 10% means thatif a dishwasher achieved an A+ rating of 10% it would definitely be an A rated dishwasher.

A requirement that the dishwasher is suitable for connection to a hot-fill supply is proposedbecause of the potential environmental advantages in using hot-fill when efficient oil or gasfired boilers are used to heat the water. Over 90% of dishwashers are already suitable forconnection to a hot-fill supply.

No requirement is proposed for stand-by consumption because there is no published voluntaryagreement. In addition all dishwashers have an off switch, and do not consume any electricitywhen they are switched off.

4.2 WATER CONSUMPTION

The proposed criterion on water consumption uses the same formula as that used by the BlueAngel. This sets values which are lower than that set by the current EU ecolabel formula.However, large dishwashers now on the market can easily meet the Blue Angel requirements.

4.3 DETERGENT USE

No change is proposed to the existing criterion because the availability of different types ofdetergent makes it more difficult for the detergent container to be suitably marked for alltypes of detergent. The instructions provided with the detergent should enable the user todetermine the required quantity of detergent to be used.

4.4 CLEANING PERFORMANCE AND DRYING PERFORMANCE

The proposed criterion for both cleaning performance and drying performance sets levels ofeither A or B. These require a higher level of performance than the current EU ecolabelcriteria. This is to encourage manufacturers to develop dishwashers which are both highlyenergy efficient and provide a cleaning and drying performance which meets currentconsumer expectations.

4.5 NOISE

The proposed criterion sets values of < 50 dB(A) for a built-in dishwasher, and < 53 dB(A)for a free-standing dishwasher. These are lower than those set by the current EU ecolabel.However, the value for a built-in dishwasher is still higher than that set by the Blue Angel forall dishwashers.



A requirement that information on noise levels must be shown on the energy label has beenadded to the proposed criterion on noise. This means that there is now no requirement for aseparate criterion on noise information.

4.6 TAKE-BACK AND RECYCLING

There is no criterion covering flame retardants in the current EU ecolabel for dishwashers.Consequently, the proposed criterion is similar to that used in the recent revision of theecolabel criteria for washing machines (similar text has been used in the recent revisions ofother ecolabels). This covers both the use of flame retardants and requirements for take-backand recycling. However, a requirement for manufacturers to make a disassembly reportavailable to third parties (such as recyclers) has been added.

The criterion includes a requirement that “incompatible and hazardous materials areseparable”. This refers to a requirement in Annex II of the draft WEEE Directive whichstates; “as a minimum the following substances, preparations and components have to beremoved from any separately collected WEEE”. Consequently, this requirement identifiesthat substances listed in Annex II of the draft WEEE Directive must be removable.

4.7 LIFETIME EXTENSION

The proposed criterion is the same as that included in the recent revision of the EU ecolabelcriteria for washing machines.

4.8 APPLIANCE DESIGN

The proposed criterion is the same as that used in the current EU ecolabel for washingmachines.

4.9 USER INSTRUCTIONS

The proposed criterion is similar to that used in the current ecolabel. Minor changes havebeen made to make this criterion more similar to that adopted in the recent revision of the EUecolabel criteria for washing machines. In addition, the user instructions now also have toprovide information on the availability of spare parts, and indicate the reasons why thedishwasher has been awarded an ecolabel.

4.10 CONSUMER INFORMATION

This is presented in the new format, and now states that the dishwasher was awarded anecolabel because it has very low energy consumption.



4.11 OTHER POSSIBLE CRITERIA

No criteriaare proposed in areas such as use of insulating material, packaging, and use ofPVC. Any criteriawhich are set as in these areas will do little by way of environmentalimprovement and will simply create an additional hurdle for applicants to navigate. A longlist of criteria requirements, seeking to cover all the impacts attributable to a given product,merely constitutes an unnecessary barrier to the scheme’s wider adoption.

4.12 TEST REQUIREMENTS

The test methodology for obtaining an ecolabel for a washing machine, i.e. an average of atleast 3 measurements using the energy label test procedure, is proposed for this revision of theecolabel criteria for dishwashers.

5 Views of interested parties

This chapter of the report discusses the reasons why there have been few applications for anecolabel for dishwashers.

5.1 VIEWS OF INDUSTRY

The current EU Ecolabel for Dishwashers has so far succeeded in attracting only oneapplicant, the Greek firm Morris who applied for a 8 place settings machine in December2000. However, the major producers of dishwashers appear to show little interest in the label.The reasons for this are based on both a general attitude towards ecolabelling and somespecific circumstances for wet appliances and dishwashers that introduced further thresholdswith regard to ecolabelling of dishwashers.

It is a well known fact (documented in several other studies regarding market impact ofecolabelling) that the major European white goods industry is at its best neither for or againstthe EU Ecolabel. There are many reasons for this attitude, the main reasons being:

1) The image of the Ecolabel does not fit in marketing strategies of companies. The fact thatprevious, more lenient, versions of the label for white goods have attracted applicants thatonly just made it past the hurdle criteria has scared off other potentially interested partieswith better scoring appliances. These parties did not want their product to be presented asbeing on the same level of environmental performance as “competing products with anEcolabel” 10. A stringent ‘new Ecolabel’ might take away this image-problem, but it takestime for consumers to get familiar with the added value of new labels.

10 The introduction of a graded label (on the agenda of the EC and the EUEB for a long time now) might takeaway this argument for non-application.



2) The advantages of an Ecolabel do not outweigh the disadvantages. Industry experiencesproblems in attaining the label and using the label:

a) Attaining the label: The time needed to attain a label is perceived as too long since the‘time to market’ of products is getting shorter. Industry considers that the process ofdevelopment of criteria and the award procedures are slow and non-transparent. Inaddition, the fact that companies have to pay for the label (initial award costs and afee) also forms a hindrance (for both big and small companies, for different reasons).Companies also prefer longer periods of validity of criteria (now three years ingeneral) for developing strategies with regard to labelling.

b) Using the Label: The validity of a single application for the EU Ecolabel throughoutEurope is recognised as an advantage, but this is of limited use as in many marketswhere national labels (like Nordic Swan, Blue Angel) are better known than the EUEcolabel. In addition, the presence of an environmental label is still seldom of primeinterest to the consumer during the buying process, especially when consumers are notfamiliar with the label.

The fact that in certain markets (countries) companies do apply for national ecolabels and notto the ‘competing’ EU Ecolabel is mainly due to the status of the national label in thoseparticular markets. The Nordic Swan Ecolabel is a well known example of a highly successfullabel on a national level. Companies recognise the market impact of this label and respond toit by applying for it. In these cases the label is not an instrument for discernment anymore buthas almost become (or in practice already is) a ‘market standard’. The EU Ecolabel howeverdoes not share this market impact and is thus less relevant for companies. Reasons for thehigh market impact of the national label may be the stringency of criteria, the use of the labelby other market parties (retailers, government, etc.), consumer perception of the label, etc.

White goods and dishwashers in particularApart from these general aspects of ecolabelling, the main emphasis of the white goodsindustry (including dishwashers) lies more with other policy and market instruments. Thesepolicy and market instruments are the Voluntary Agreement on Dishwashers and the EUEnergy Label for Dishwashers. Voluntary approaches, rather than mandatory minimumefficiency requirements, are favoured by CECED. They have sought to self-imposeVoluntary Agreements (VA) for improving energy efficiency of wet appliances, starting withwashing machines and recently (November 1999) followed by dishwashers. Compliance ismonitored by submitting production data of appliances and their energy efficiency to anindependent third party. CECED believes this will improve the general energy efficiency ofdishwashers by 20 % by the year 2002 when compared to the reference year 1996. In this wayCECED plays its part in EU energy efficiency policy, the use of Ecolabels is considered to becompany policy.

Since the introduction of the Energy label for Dishwashers in 1999 the market has shown arapid spread of A-rated dishwashers similar to developments in the washing machines andcold appliances market. Combined with the VA on dishwashers this might lead to congestionof appliances in the upper efficiency classes. However, the fairly recent11 introduction of the 11 Dishwashers were among the first batch of products to be labelled, but mainly due to delays in thedevelopment of the applicable EN test standard the Energy Label was only publicised in 1997, with fullimplementation during 1999.



Energy Label means that industry is not inclined to make changes to the Energy label in thecoming years. Industry prefers to gain more experience with the label and its effectiveness onthe market before a revision of Energy Label classes is even talked about and which in itself isa process that could take years.

Apart from the congestion in high efficiency classes there are other, more urgent problemsrelated to the use of the Energy Label. One of the most urgent problem the white goodsindustry now faces is the correctness of declarations on the Energy Label. For several yearsproducers and consumers associations have contested each others outcomes of product tests(tests of washing machines sometimes showed differences of one class or more in energyefficiency and / or product performance) which led to an intensification of research in thisfield. This research recently led to the conclusion that with the current standards it is virtuallyimpossible to contest a claim for a certain energy efficiency or performance class. Thetolerances of testing seem to lie beyond the maximum allowable tolerances of 15 % (oneappliance tested) and 10 % (three appliances tested). CECED, recognising the problem, hasrecently (January 2001) introduced a “Code of Appliance Testing” that is aimed at minimisingdifferences in test results for washing machines, dishwashers and cold appliances betweenlaboratories. This Code is open for all interested parties to join.

5.2 VIEWS OF CONSUMERS

The main concern for Consumers’ Associations is the correctness of declaration, alreadymentioned in the paragraphs above. The problems with testing dishwashers have not so farbeen as persistent as for testing of washing machines, but differences in test results of oneenergy class have already been documented. The Code of Appliance Testing is a way toimprove correctness of declarations and is open for Consumers’ Associations to join.

5.3 VIEWS OF RETAILERS

EC marketing studies have reported that retailers are reputedly asking for a wider selection ofecolabelled electrical goods to stock. However, for most countries, retailers rely on andsupport the strategies of the producer of the appliance and do not develop an ecolabel-strategyof their own. This means that retailers certainly appear to have placed little or no pressure onmanufacturers to obtain ecolabels for their products.

The recent revision to the ecolabel Regulations now enables retailers to apply for the ecolabelfor products sold under their own brand name. However, even for those countries whereretailers have a large influence in product availability because they carry their own brands,and so have the opportunity to develop their own strategies, they have so far shown very littleinterest in doing this.

5.4 HOW THE ECOLABEL PROFILE COULD BE RAISED

Since the introduction of the EU Energy label for dishwashers (effectively in 1999) thepercentage of dishwashers with an A-rating for energy efficiency has shown considerableincrease. Combined with the effort aimed at reducing fleet average energy consumption



(CECED Voluntary Agreement) it can be expected that congestion in the upper energyefficiency classes will take place. Experts predict that the Energy Efficiency classes will notbe changed for a couple of years to come. An EU Ecolabel for only the “10% better than A”-appliances could be a way for companies of discerning their very efficient dishwashers fromother dishwashers in the same A energy efficiency class.

One way of identifying a unique selling point would be to combine an Ecolabel with aproduct rebate scheme. In some countries the most energy efficient appliances are eligible forfinancial rebates which lower the purchase price. However, industry (and retailers) are ingeneral not in favour of such kind of product promotion. Some of the drawbacks that arementioned in this context are: Can the government impose extra (Ecolabel) costs on acompany that wants to make use of the rebate-scheme? In addition, the rebates distort themarket (expensive appliances become cheaper and drive sales away from appliances that werea little bit cheaper from start).

Ecolabels, including the EU Ecolabel, can act as “Environmental Benchmarks” for Industry.This fact should be recognised more often, which is problematic since the success of a label ismeasured in numbers of applicants and not in number of “engineers that use the Label criteriaas guidance in product development”. The benchmarking effect strengthens the argument thata more stringent Label might be more successful than a lenient one in raising generalenvironmental performance.

Ecolabels also serve a role in procurement processes. The effect of public procurement in thewhite goods sector should however not be overrated: There are not that many officialinstitutions that buy washing machines on a regular basis or in large quantities. But with ageneral policy towards using Ecolabels in procurement processes in mind white goods shouldsimply not be left out.

CECED has conducted scenario studies12 (based upon stock model analysis) in which theeffect of three scenarios in average EU electricity consumption of dishwashers werecalculated (“no progress”, “realistic” and “ambitious”). The fleet average energy efficiency ofnew machines in 2000 (equal to ‘no progress’) is estimated to be around 1.13 kWh/cycle. Therealistic progress scenario assumes an average energy efficiency of new appliances in 2010 of0.94 kWh/cycle (-11% of energy class A threshold) and 0.78 kWh/cycle in the ambitiousscenario for 2010 (-26%). Which one of these targets will be realised depends on manypolitical and strategic decisions that go far beyond the scope of this study. The relevance forEcolabelling purposes is that the future targets indicate potential for improved energyefficiency of new appliances and thus gives a basis for a “better than A” approach.

12 “EU Electricity Consumption of Selected Appliances: Stock Model Projections 2010”, CECED, BrusselsFebruary 2001.



6 Conclusions

Ecolabelling, or environmental labelling, is a guide to consumers which helps them makeinformed environmental choices about the products and services that they require. It is basedon a life cycle assessment which considers the impact on the environment at every stage ofthe products life cycle. Criteria are then established on the key environmental effects, whichfor dishwashers are energy consumption, water consumption and use of detergent. The criteriaare then reviewed and possibly made more stringent at regular intervals (usually three years)to allow for improvements in environmental performance.

The EU ecolabelling scheme is one of a number of ecolabelling schemes. Criteria fordishwashers were introduced in 1993, and were updated in 1998. The first application for theEU ecolabel was made at the end of the year 2000, but there have been no applications toother European ecolabel schemes for dishwashers.

One of the key environmental impacts of a dishwasher is energy consumption during use.The electricity consumption of a 12 place dishwasher has reduced by over 50% in the last 20years. A significant proportion of larger dishwashers now achieve an A energy label rating,and so the criteria for these dishwashers follows the methodology used during the recentrevisions of the ecolabel criteria for both fridges and washing machines by setting an A+(10% better than A) requirement (the current ecolabel requirement is A or B).

The energy label formula makes it more difficult for smaller (less than 10 place settings)dishwashers to achieve an A energy label rating, and there would also be technical problemsin achieving an A+ rating for these dishwashers. Consequently, lower energy efficiencyrequirements have been set; an A rating (compared to the current A, B or C requirement) formedium sized dishwashers, and an A or B requirement for small (up to 5 place settings)dishwashers.

Dishwashers now have to be suitable for connection to a hot-fill supply. However, nocriterion has been set for stand-by consumption because there is no industry voluntaryagreement which could be used as a basis for setting a criterion.

Water consumption is another of the key environmental impacts of a dishwasher, and this hasreduced by about 75% in the last 20 years. A large dishwasher with an A energy ratinggenerally uses less water than a dishwasher with a B energy rating, and over 60% of largedishwashers with an A energy rating achieve a high level (A or B rating) of cleaningperformance whilst using less water than that required by the current ecolabel requirement.Consequently the criteria for water consumption has been reduced (the formula is now thesame as that used by the Blue Angel ecolabel for dishwashers), and the standard of cleaningperformance has been raised to a level which is more acceptable to consumers. In addition, ahigher drying performance now also has to be achieved.

Detergent use is the third of the three key environmental criteria. However, no changes havebeen made to the criterion in this revision because the availability of different types of



detergent would make it difficult for the detergent container to be suitably marked for alltypes of detergent.

The development of ecolabel criteria now requires more emphasis to be placed on health andsafety issues. Noise is becoming more important on the environmental agenda, but noiselevels for dishwashers now on the market are significantly lower than levels for dishwashersproduced ten years ago. The procedure used to measure noise levels means that built-indishwashers have lower measured noise levels than those for free-standing dishwashers. Thenew criterion (<50 dB(A) for a built-in dishwasher, and < 53 dB(A) for a free-standingdishwasher) are both lower than those set by the current ecolabel.

The current criteria did not include any requirements regarding flame retardants. The issuesregarding flame retardants have been well discussed by ecolabel competent bodies in the past,and the criterion adopted in this revision is the same as that set during recent revisions of theEU ecolabel criteria for both washing machines and fridges. However, the issue of fire safetywill need to be considered in future revisions of ecolabel criteria for all electrical andelectronic products.

The criterion on take-back and recycling is now also the same as that set during recentrevisions of the EU ecolabel criteria for both washing machines and fridges. In addition, acriterion on life-time extension is now included, and this is also the same as that set duringrecent revisions of the EU ecolabel criteria for both washing machines and fridges. There arealso a number of minor changes to other criteria. Manufacturers now have to make adisassembly report available to third parties, and provide information to consumers that thedishwasher has been awarded an ecolabel.

No criteria have been set in a number of areas, such as packaging, as these represent a verysmall proportion of the total environmental impact of a dishwasher, and ecolabel criteriashould consider the main impacts of a product group which were identified through the life-cycle analysis.

This revision of the criteria for dishwashers has also identified a number of areas which willrequire particular attention when the criteria are next reviewed. These are:

• Energy consumption, including stand-by energy• Flame retardants• Third party testing, laboratory standards and testing procedures (according to EN ISO

17025), tolerances of energy consumption measurements• Duration of the criteria• Duration of the availability of spare parts (and associated issues such as the price of

repairs)• PVC.

Although the European white goods industry is not opposed to ecolabels, there may be nonew applications for the revised ecolabel. The current industry view is that voluntaryagreements on removing the least energy efficient dishwashers from the market enable agreater environmental improvement from dishwasher use to be made than applications for theecolabel. This is because a voluntary agreement applies to a significant percentage ofdishwashers on the market, but an ecolabel could only be obtained by a small percentage of



dishwashers on the market. The dishwashers from the current applicant do not meet the newcriteria, and would require significant development to meet the new requirements. There arealso no larger dishwashers that currently meet the A+ requirement for energy efficiency, andalthough these criteria will be valid for 5 years, it could be at least another 3 years before anylarge dishwasher is able to achieve an A+ for energy efficiency whilst meeting the newrequirements for both cleaning and drying performance. In addition, manufacturers may alsoconsider that the EU ecolabel is less well known than national ecolabels, and this is an issuethat the EU ecolabel will need to consider if it is raise its profile with manufacturers.

AEAT/ENV/R/0750 Issue 1

AEA Technology

Appendices

CONTENTS

Appendix 1 Markets and sales for dishwashers

AEAT/ENV/R/0750 Issue 1

AEA Technology

Appendix 1Markets and Sales forDishwashers


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