The study, by the Ecofys consultancy, proposes joint enforcement programmes by EU states and more government-funded surveillance of rogue firms, paid for by heavier fines on the estimated 10% of product lines that mislabel their goods.
“The level and form of penalties need to be dissuasive, possibly reflecting the amount of total value of energy lost due to non-compliance,” the paper says.
It also recommends naming and shaming energy label cheats and holds open the option of measures such as third-party certification and manufacturer obligations, depending on the circumstance.
“If these funding options turn out to be insufficient, other mechanisms would need to be put in place that result in more substantial funding, for example a manufacturers’ obligation,” the report says.
The European employers’ confederation BusinessEurope declined to comment on the new proposals but Andrea Voigt, director of the European Partnership for Energy and the Environment (EPEE), said that better market surveillance was “extremely important for our members as these products are currently not being policed.” EPEE represents the heating, cooling and refrigeration industry.
“It doesn’t make sense to have higher requirements and energy labels if nobody is then testing whether the indications are correct,” Voigt commented.
Stephane Arditi, a senior policy officer for the European Environment Bureau (EEB), an environmental NGO, also welcomed the proposals. “We think that there are plenty of good recommendations by the study team and we support their overall approach,” he told EurActiv.
“They clearly assessed that the [existing] legislation was positive in terms of achieved savings, the potential to achieve more, and the effects on Europe’s industry and economy,” he said. An Ecofys proposal for a mandatory producer’s register to improve market monitoring, was particularly significant, he added.
Energy label colours and classes
But it will be the paper’s proposed overhaul of energy label classes which grabs attention from industries that invest heavily, and sometimes controversially, in lobbying for their products to be given a green hue.
At present, energy labels are coloured from red to green and classed from 'D' to 'A+++' to reflect a products’ energy saving potential.
With product lines such as washing machines though, all models are clustered within the ‘A’ to ‘A+++’ ranges, arguably giving a misleading impression of best performers, and offering companies little incentive to improve their performances.
Firms such as Bosch, Siemens and Electrolux which have invested more in energy saving innovations are thought to favour a shake-up of the labels, which currently colour all ‘A’-classed products green.
“We’ve got evidence from consumer organisations that the addition of ‘+’ signs creates confusion,” Arditi said. “Going from an ‘A+’ to an ‘A++’ product is less appealing to consumers than going from a ‘B’ to an ‘A’.
The Ecofys report says that “the closed A-G [efficiency] scale is the easiest to comprehend and is the most motivating for consumer investment decisions.” Re-grading that scale is the paper’s preferred option, with four possible label lay-outs signposted in the paper, which will now be tested in consumer field trials.
Paul Hodson, the head of the EU’s energy efficiency unit, implicitly endorsed this approach at a meeting to launch the International Energy Agency’s roadmap for efficient buildings technology last week.
“We can’t go to ‘A+++++++’ so we need to change the system somehow,” he said. “How can we do that? Perhaps with [more] product information.”
One key demand from environmental and consumer groups has been for the incorporation of product information into a format that can be easily scanned or otherwise accessed by customers or sales attendants on their smart phones.
The new report says that such Quick Response (QR) codes have “an interesting potential,” but that it is “probably premature” to legislate for them before field trials.
Arditi argues that as well as ending the need for paper labels, such e-labels offer the potential for extra product information.
“The report’s authors have been quite shy about more systematic consideration of internet instruments to enrich the information we convey to consumers,” he said. “It is a missed opportunity, especially as the labels will last for 10-15 years.”
The Ecofys report also suggests reassessing the use of ‘problematic icons’ on labels for TVs, fridges and washing machines, and labelling products for energy consumption per cycle, per year, for products that are not used continuously.
More generally, “higher energy using appliances should not be unfairly favoured,” as sometimes happens with larger products, the report says.