Submitted upon the invitation of Ecofys on behalf of the European Commission
General remarks
REHVA supports the main principles of the Ecodesign and Energy Labelling Directives. They can give the opportunity to end-users to assess products by using clear and sustainable criteria, lead industry towards higher competitiveness, high quality and sustainability, and provide indirectly all stakeholders with guidance. The principles of the Directives serve as solid background to lead the way towards a fair and rewarding legislation and benefit the whole EU in achieving the energy efficiency targets. Energy labelling has clearly improved the market situation of several consumer products and accelerated their development towards the right direction. However, some deep concerns must be expressed on many features of the legislation developed or under development within the Ecodesign and Energy labelling framework as described in the recent position paper.
REHVA recommendations:
- Ecodesign and Energy Labelling regulations have to be coordinated with other linked legislation (EPBD) and product certification processes including the work of CEN. Contradictory and parallel definitions of the overlapping certification criteria should be clarified and avoided in the future.
- Stakeholders should be involved during the entire regulatory process and informed about changes within the legislation.
- The problem of contradictions between health, environmental and energy efficiency requirements has to be handled. Health, sustainability and the life cycle approach should be taken into account within the Ecodesign and Energy Labelling directives.
- EU level support is necessary in the field of market surveillance and in the development of a tailor made information service system about the quickly changing regulations, especially serving the needs of SMEs.
