The Ecodesign of Energy Related Products Directive (EED) was adopted in 2009 as an amendment from the 2005 Ecodesign of Energy Using Products Directive and is one of the EU’s four key Directives addressing energy efficiency in stationary (i.e. non transport) end-uses (the others being the Energy Performance in Buildings Directive, Energy Efficiency Directive and the Energy Labelling Directive). The EU was a relative late comer among leading international economies in having overarching legislation to set minimum energy performance standards for equipment but since the adoption of Ecodesign it has set an impressive pace of adoption of implementing measures which are now estimated to cover 48% of all EU energy consumption. The average expected energy savings per product group addressed is projected to reach 19% by 2030, to lower energy bills by €160 billion for a €60 billion increase in equipment acquisition costs i.e. a net benefit of €100 billion and to create 0.8 million extra direct jobs for industry, wholesale and the retail sector. The projected CO2 savings from this Directive alone are estimated to reach 320 Mt CO2 equiva-lent, equal to 7% of all EU GHG emissions in 2010. This is in excess of savings projected from the EU emissions trading system.

1. INTRODUCTION TO THE EU’s
ECODESIGN OF ENERGY RELATED
PRODUCTS DIRECTIVE
Paul Waide – Waide Strategic Efficiency Ltd
EUROPEAN SUSTAINABLE ENERGY & CLIMATE POLICY
November 20th 2015

2. Summary of talk
- Context - EU energy profile and macro policy
- Scope – what the ErP covers
- History – how it happened
- Regulatory development process
- Methodology for devising regulations
- Regulated products
- Expected benefits
- MV&E
- Criticisms
- Future direction - gaps and next steps
2

3. Overarching policy goals – EU energy/GHG
targets
- The three E’s - Energy security, Economic Efficiency and the
Environment
- Energy Union paper talks of “A more integrated, secure, competitive
and sustainable European energy system”
- The EU has set itself a 20% energy savings target by 2020 when
compared to the projected use of energy in 2020 – roughly equivalent
to turning off 400 power stations
- Targets of a 20% reduction in GHG emissions and 20% of energy supply
to come from RE are legally binding – the EE target is not!
- At an EU summit in October 2014, EU countries agreed on a new, non
–binding, energy efficiency target of 27% or greater by 2030
3

4. Context - The four principal EE Directives
4
Ecodesign
Directive
Energy Labelling
Directive
Energy
Performance in
Buildings
Directive
Energy Efficiency
Directive
EU directives
on energy
efficiency

5. 5
Ecodesign ErP
ETS
IED
Regs
443/
2009,
510/
2011
TLD
EED
2012/27/EU
EPBD, ELD

6. Ecodesign – Scope
- ‘Energy-related product’, means any good that has an impact on
energy consumption during use which is placed on the market and/or
put into service
- The Directive provides for the setting of requirements which energy-
related products covered by implementing measures must fulfil in
order to be placed on the market and/or put into service
- These include Minimum Energy Performance standards (MEPS) known
as Implementing Measures in the Directive
- It contributes to sustainable development by increasing energy
efficiency and the level of protection of the environment, while at
the same time increasing the security of the energy supply
- The level of ecodesign requirements should be established on the
basis of technical, economic and environmental analysis informed by
the best-performing products or technologies available on the market
6

7. EU Ecodesign approach – some key features
• Implementing measures are derived considering all environmental
impacts of the products over their life cycle, from cradle to grave:
including energy in use, embodied energy and non energy related
environmental impacts

8. Time line of first MEPS development by
economy ED

9. EU policy development was lengthy
1976 Council of
Ministers
Recommendation
1979 Directive
on energy
labelling (EEC
79/530)
1990
Implementing
agreement for
electric ovens
1992 Directive for
mandatory energy
labelling of
household
appliances
1992
MEPS for boilers
1998 MEPS for
refrigerators
DIRECTIVE 2005/32/EC
Ecodesign requirements for
energy-using products
DIRECTIVE 2009/125/EC
Ecodesign requirements for
energy-related products
1995 first
implementation
Directive (for cold
appliances) into
effect
ENERGY LABEL
MEPS/Ecodesign
1976 1995
1992 2009

10. Cool Appliances
(2003) clarified the
value proposition
underpinning the
need for a
framework
Directive on
product energy
Efficiency.
Demonstrated a
savings potential of
38% in residential
electricity demand

11. Ecodesign Legislative Process
11

12. Test methodology
Product categories
Efficiency Metrics
Performance thresholds
MEPS
There is a hierarchy of technical needs
underpinning MEPS and labels

13. The MEErP steps for conducting an
Ecodesign preparatory study
MEErP Structure
Task 0
Quick Scan
Task 1
Scope
Task 2
Markets
Task 3
Users
Task 4
Technologies
Task 5
Base case
(LCA/LCC)
Task 6
Design options
Task 7
Scenarios

14. 0
200
400
600
800
1000
1200
1400
0 50 100 150 200 250 300 350 400
Life-CycleCost€
Energy Savings in kWh/year
Life-Cycle Cost
Ecodesign MEPS set at the least life cycle cost
MEPS

15. Energy flows in the EU
15

16. Source: VHK
EU Ecodesign product studies

17. ErP Regulated product groups
- Air conditioners and comfort
fans
- Circulators
- Computers
- Domestic cooking appliances
- Electric motors
- External power supplies
- Household dishwashers
- Household tumble driers
- Household washing machines
- Industrial fans
- Lighting products in the
domestic and tertiary sectors
- Local space heaters
- Space heating equipment
17
- Water heaters
- Power transformers
- Professional refrigerated storage
cabinets
- Refrigerators and freezers
- Simple set-top boxes
- Solid fuel boilers
- Standby and off mode of
household and office equipment
- Network standby
- Televisions
- Vacuum cleaners
- Ventilation units
- Water pumps
- Sound & imaging equipment

18. Products in the pipeline
18
Lot Product Status
3 Displays Working document issued
7 Battery chargers and external power supplies Working document issued
12 Commercial refrigerators and freezers Working document issued
15 Solid fuel small combustion installations Draft regulation issued
20 Local room heating products Draft regulation issued
21 Central heating products using hot air to distribute heat Working document issued
24 Professional washing machines, dryers and dishwasher Working document issued
27 Uninterruptible power supplies (UPS) Prep study completed
28 Wastewater pumps Prep study completed
29 Clean water pumps (larger than those under Lot 11) Prep study completed
30 Motors and drives (outside scope of Regulation 640/2009) Working document issued
31 Compressors Working document issued
32 Windows Prep study ongoing
33 Smart appliances Prep study ongoing
ENTR1 Refrigerating and freezing equipment (non-domestic) Draft regulation issued
ENTR4 Industrial and laboratory furnaces and ovens Working document issued
ENTR5 Machine tools Draft voluntary agreement
ENTR7 Steam boilers Prep study completed
ENTR8 Power Cables Prep study completed
ENTR9 Enterprise Servers Prep study ongoing
JRC Taps and showers Prep study ongoing

19. EU Ecodesign approach – some key features
• Among all the major economies the EU’s Ecodesign Directive has
taken the broadest approach to analysing and attempting to
capture energy savings through regulation (or negotiated voluntary
agreements)
• End-uses are assessed at the major service provision or functional
level and “horizontal” measures are often set e.g.:
 1W standby power limit across all products
 The requirement for electric motors to reach a higher efficiency
level if sold without an integrated variable speed drive than with
one
 The fans directive, which covers all electric fans from 500kW to as
little as 150W
 The lighting directives that cover all domestic lighting or all
tertiary lighting
• All products providing the same service are in the same category

20. Sales
Efficiency
Standards and
labels
No standards or
labels
Standards only
Minimum standards
"push" the marketEnergy Labels "pull"
the market
Market transformation theory

21. 0
10
20
30
40
50
60
A+++ A++ A+ A B C D E F G
Marketshare(%)
Energy-label class
2011 (sample)
2003
1993
MEPS
2009
MEPS
1998
20022010
MEPS
2013
Evolution of the EU refrigerator market

22. Overall efficiency of an incandescent
lamp = 2%
© OECD/IEA -
2008
Example of energy lost during conversion
and transmission. Imagine that the coal
needed to illuminate an incandescent light
bulb contains 100 units of energy when it
enters the power plant. Only two units of
energy eventually light the bulb. The
remaining 98 units are lost along the way,
primarily as heat.
IRR of a CFL >
180%
©2009 Navigant Consulting, Inc.
Slide contents courtesy of the IEA Source: Sebastian Moffatt, CONSENSUS Institute

23. EU phase-out of incandescent lamps
• EU Heads of State adopted the phase-out policy in March 2007 and
the Ecodesign regulation was issued in April 2009
• For frosted lamps they only permit EU energy label class A lamps or
better to be sold from September 2009 but for clear lamps the
requirements are phased in such that all clear GLS were precluded
from sale by September 2012 and that from September 2016 all
clear lamps of whatever type and cap (base) have to be label class
C or better
• The last factor in the decision over the timing was a detailed
analysis of the impact of the EU phase-out combined with those
elsewhere (US, Canada, Australia, Switzerland, Philippines, etc.) on
the global supply of CFLi and other substitutes

24. Global phase-out of incandescent lamps:
Implied demand for CFLs
0
1000
2000
3000
4000
5000
6000
7000
8000
1990
1993
1996
1999
2002
2005
2008
2011
2014
2017
2020
2023
2026
2029
CFLidemand(millionunits)
ROW Reference
EE/FSU Reference
LATAM Reference
China PO2
Korea Reference
Japan 2012
ANZ Tier1 only
Canada: Tier1 only
USA EISA
Europe TREN Opt1 Slow
Source: IEA

25. EU residential electricity consumption from 1990:
BAU and projected Ecodesign scenarios
-39%

26. EU primary energy consumption from 1990:
BAU and projected Ecodesign scenarios
-32%

27. EU primary energy consumption from 1990:
breakdown of projected Ecodesign savings

28. Ecodesign Directive – summary of expected impacts
• Over 30 products now regulated covering 48% of all EU
primary energy use – more in the offing
 Projected savings of 19% of all EU primary energy use by
2020
 €110 bn net saving on consumer expenditure (ca. € 170 bn
gross saving, € 60 bn extra acquisition cost)
 €54 bn extra revenue for industry, wholesale and retail
sector
 0.8 million extra direct jobs for industry, wholesale and
retail sector
 320 Mt CO2 equivalent (7% of 2010 EU-total) less greenhouse
gas emissions
 Savings and impacts will increase and become deeper by
2030

29. Degree of alignment of equipment MEPS

30. Degree of alignment of equipment energy
performance test procedures

31. Implementation of market surveillance
at the national level
Under Regulation (EC) 765/2008 EU countries must ensure effective
surveillance of their markets. They are required to guarantee:
• the monitoring of products placed on the market;
• the marking and documentation requirements have been respected;
• products have been designed and manufactured in accordance with EU
harmonisation requirements;
• market surveillance authorities have the necessary powers, resources,
and knowledge to perform their functions;
• procedures are put in place for following up complaints and monitoring
accidents;
• market surveillance programmes are established, implemented, and
periodically updated;
• the functioning of surveillance activities is reviewed and assessed at
least every four years

32. CentralGovernment
Ministry
Retailers, Manufacturersand ProductVerification Sampling
Testing Laboratories
MarketSurveillance
Authority (MSA)
Transpositionof Directive
andPolicy
Surveillance
Enforcement
Testing/Certification/
Monitoring
Market Surveillance Institutional linkages:
typical case

33. Challenges to the proper functioning of the
market surveillance system
Several factors affect the market surveillance authorities'
ability to check whether products made available in the EU are
in accordance with EU law:
• supply chains may be very complex and encompass several
countries
• economic operators may be located in a country different to
those in which products are made available. Often, they are
located outside the EU
• consumers may purchase products through the internet
• MSA capacity and resources may be constrained
• compliance verification may be technically difficult to verify

34. Criticisms – busybody bureaucrats!
34

35. More substantive concerns
There are (or have been) concerns expressed about:
- the calibre of MV&E
- administrative capacity in MS and the Commission
- budget allocations
- the speed of regulatory throughput
- the quality of the evidence base and asymmetry of information
- overly optimistic impact assessments
- the choice of least life cycle cost as the benchmark
- the lack of weight given to environmental impacts other than the use
phase and other than energy
- the suitability of product performance test procedures
- the influence of lobbying
35

36. • Across the EU there are about 80 full time equivalent staff working
on Ecodesign and Energy Labelling compliance administration in the
30 EEA Member States and perhaps the same level are involved in
store inspection to ensure labelling compliance
• Non-compliance levels are often not known or are not reported when
they are known but it appears that more than 10% of the energy
savings potential from Ecodesign measures is being lost
• Penalties for non compliance are often weak and are likely to be
weak deterrents. The average maximum imposable fine (where
specified) is just €41k and can be as low as €320
• Total EU/EEA-wide expenditure on equipment energy performance
regulatory compliance appears is ~€7 million per year i.e. about
€0.014 per capita and is only about one 2000th of the value of the
energy being lost from non-compliance
•
Monitoring, verification and enforcement –
findings from a CLASP study of 2012

37. Expected changes in the two ErP Directives
• Both the Ecodesign and Energy Labelling Directive have just
undergone a review process:
• In July 2015 the European Commission tabled a legislative proposal
for a revised Energy Labelling Directive
 The objectives and main principles of the current Directive remain
untouched
 the proposal ‘clarifies, strengthens, and extends’ the scope of the
current Directive’s provisions
• A revision of the Ecodesign Directive seems less likely in the short
term than the revision of the Energy Labelling Directive
• There is on-going discussion about how it will work with the EU’s
Circular Economy initiative and about the next work plan

38. Products under discussion for 2015-17 WP
38
Product Group Savings potential in 2030
(TWh, primary energy)
Other environmental
impacts, including
resource efficiency
1. Building Automated Control Systems 30 ++
2. Electric kettles 12 ++
3. Hand dryers 12 +
4. Lifts 8 ++
5. Materials for the construction of
greenhouses
7 ++
6. Photovoltaic systems (panels and
inverters)
6 ++
7. Refrigerated containers 6 ++
8. Hair dryers 5 +
9. Toasters 4 +
10. High pressure cleaners 3 +++
11. Signage displays 2,6 (in 2020) ++
12. Hot drink vending machines 1 +
13. Base stations for internet and phone
networks
not available +
14. Internet routers not available ++
15. Mobile phones/smart phones not available +++
16. Wireless chargers for consumer products not available ++

39. The degree to which Ecodesign treats the
system is important but is a limitation
3.3 5
50
28
0
10
20
30
40
50
60
Old (Mercury vapour
125W)
New (Ceramic Metal
Halide 70W)
Annualcost(Euros)
Electricity cost
Lamp replacement
cost
Source: Philips/IEA

40. Systems level savings potentials are huge:
• ~10% of all EU electricity consumption from optimised electric
motor systems alone
• ~80% of lighting energy consumption
• ~22% of building energy consumption from building automation and
controls alone
• Also considerable savings opportunities for HVAC; power cables;
etc.
• Currently Ecodesign is only applied to address products or
components but mostly not how they are used together so there is
a regulatory gap

41. Complex products also pose challenges
• Such as:
 machine tools
 professional wet appliances
 data centres/servers
• One option being considered is development of a modular “points”
system to help rank heterogeneous products Ecodesign performance

42. 0
200
400
600
800
1000
1200
1400
0 50 100 150 200 250 300 350 400
Life-CycleCost€
Energy Savings in kWh/year
What should the policy target be?
Least life cycle cost or beyond?
Should we account for technology learning?

43. Technology learning effects could be
factored in to bridge the gap

44. Some suggestions for future focus
• Invest in improving the asymmetry of information – the quality
of evidence and data needs to be strengthened and so do the
analytical tools used to estimate the impact of design changes
• MS need to invest in MV&E – it is among the cheapest means of
providing energy services and should be treated as seriously as
supply-side options
• Means need to be found to realise the savings potentials from
product systems either through extending Ecodesign or a new
policy instrument
• Product performance test procedures need to be fully fit for
purpose and timely – no more “Volkswagen moments”

46. One last thought…
Efficiency is a renewable resource!
We can keep getting more from the
well

47. Links and Contacts
Paul Waide – Director
Waide Strategic Efficiency Ltd
4 Winster Avenue
Manchester M202YG
UK
Tel: +44 161 883 0508
Mb: +44 7794 141 848
Em: paul@waide.co.uk

48. Energy flows in the EU
48