This document discusses moving towards a systems approach in ecodesign and energy labelling regulations. It provides an overview of some challenges in regulating systems compared to individual products, including assessing system efficiency, identifying responsible parties, and challenges for market surveillance authorities. Examples of studies on specific systems like heating/water heating packages, lighting systems, and pumps are mentioned. Views from the EU Commission emphasize that ecodesign regulations currently apply to individual goods placed on the market, but can also cover systems if they are put together on location. Moving towards more systems approaches could increase energy savings but also introduces complexity around testing, compliance, and enforcement.

1. Towards a systems approach in Ecodesign and
Energy labelling
– How to make the political ambition a reality?
eceee Partner Event – European Copper Institute
17 June 2021

2. Source
Why this workshop?
| Systems approach in Ecodesign and Energy Labelling - ECI workshop 17 June 2021
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Distance:
-224 Mtoe
by 2030
Regulating
Systems:
- 290 Mtoe
by 2030
Ecodesign
Regulation:
- 230 Mtoe
by 2030
MOTORS
- 72 Mtoe
LIGHTING
- 19 Mtoe …
CABLES
- 6 Mtoe
additional

3. Many political actors have identified the need
to thinking beyond products
• Advised looking for opportunities at systems level (up to
functional system) >>link
MEErP
(2011)
• Recommends that energy saving potential of product
systems could be better exploited >>link
EU Commission
Technical report
(2014)
• Urges the Commission to include more system-level
opportunities >>own initiative report and >>EPRS IA
EU Parliament
(2018)
• Package label for space and water heaters
• Preparatory studies have considered system approaches
Ecodesign & Energy
Labelling
| Systems approach in Ecodesign and Energy Labelling - ECI workshop 17 June 2021
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4. | Systems approach in Ecodesign and Energy Labelling - ECI workshop 17 June 2021
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“If it were easy,
we would have done it
already”
Complexities are inherent to each system.
Ignoring them comes at a cost.

5. Focus for today’s discussion
Product
policies
Other
regulations and
policy tools
| Systems approach in Ecodesign and Energy Labelling - ECI workshop 17 June 2021
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6. Agenda
10:30 Welcome and introduction (Diedert Debusscher, ECI)
10:40 A review of systems approaches in Ecodesign and Energy Labelling
(Fiona Brocklehurst, Ballarat Consulting)
11:00 Transforming product efficiency policy into system efficiency policy
(Hans-Paul Siderius, Netherlands Enterprise Agency)
11:10 Views from the EU Commission
(Ronald Piers De Raveschoot, ENER.B3)
11:20 Case study: Pump systems (Michael Könen, Europump)
11:30 Discussion and Q&A
11:50 Wrap up and next steps
12:00 Adjourn
7 | Systems approach in Ecodesign and Energy Labelling - ECI workshop 17 June 2021

7. A REVIEW OF SYSTEMS APPROACHES IN
ECODESIGN AND ENERGY LABELLING
Fiona Brocklehurst, Ballarat Consulting
17 June 2021

8. Outline
• Systems vs products
• Operational regulations
• Studies to date
• Findings from studies:
• Points in favour
• Common issues and possible solutions
• Ways forward?
2 | Presentation title and date

9. Systems vs products
Products Systems
Sold individually Assembled or installed
Mass produced Could be ‘standard set’ of components
but could be unique
Needs measurement standard/
transition methodology – generally
developed
Needs measurement standard/
transition methodology – not always
available
Performance can be measured in a lab Performance needs to be measured
in-situ or modelled
Manufacturer/supplier has
responsibility
Installer/designer has responsibility
| ECI and eceee workshop on systems in ecodesign 17 June 2021
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10. Regulations to date:
heater and water heater package energy labels
| ECI and eceee workshop on systems in ecodesign 17 June 2021
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11. European studies to date
| ECI and eceee workshop on systems in ecodesign 17 June 2021
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Walk in cold room
Case study method for heating system
Initial prep study 2011. Current review study JRC study 2016

12. European studies to date
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Lighting systems
Points system
Prep study completed 2017
Prep study completed 2017

13. European studies to date
|| ECI and eceee workshop on systems in ecodesign 17 June 2021
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Pumps
Solar photovoltaics
Review study completed 2018
Prep study completed 2019, supporting study ongoing?

14. European studies to date
| ECI and eceee workshop on systems in ecodesign 17 June 2021
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Power cables
Building Automation and Control systems
Prep study completed?
Prep study completed 2015

15. Different applications, different technologies:
common threads?
| ECI and eceee workshop on systems in ecodesign 17 June 2021
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16. Advantages
| ECI and eceee workshop on systems in ecodesign 17 June 2021
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SAVINGS
€
€
CO2
kWh
CO2
kWh

17. Other advantages
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Industry support
Potential for job growth?
Enabling MS grant schemes
Consistency across EU

18. Common issues
and possible solutions
Need:
• System measurement standard or transitional methodology
Identify if missing early on and develop
• Consistent Methodology/Tool To Calculate System Efficiency
Identify if missing and develop as part of preparatory study
• Easy access to component data
EPREL? Member State database? Industry data base?
Digital product passport?
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19. Change in responsibility for compliance
Possible solutions: new business models? Specialist insurance?
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MANUFACTURER/
SUPPLIER
INSTALLER/
DESIGNER

20. Market surveillance issues
and possible solutions
• Uncertainty on legal mandate to check installations
EC advise on interpretation
Member States review/revise permissions
• Inspecting multiple installations vs few samples of a product
Grouping into ‘standard’ types? Technical documentation? Modelling?
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x 3 vs x 1000?

21. Market surveillance issues
and possible solutions
• Notification when put into service
Database of installations?
• Retaining energy label
Digital Building Logbook? Digital product passport?
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22. Where next?
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Ecodesign and
Energy Label
working plan?
Sustainable Products
Initiative?
EPBD and EED
revisions?

23. Thank you
| Presentation title and date
17
Report available at:
https://help.leonardo-energy.org/hc/en-us/articles/360020752319--Cu0274-A-review-of-systems-
approaches-in-Ecodesign-and-Energy-Labelling-report
Cable review report at:
https://help.leonardo-energy.org/hc/en-us/articles/360020746299-Potential-Ecodesign-regulation-for-
economic-cable-conductor-sizing-in-buildings

24. Transforming
product efficiency
policy
into
system efficiency
policy
eceee – European Copper Institute
Towards a systems approach in Ecodesign
and Labelling: How to make a political
ambition a reality?
17 June 2021
Hans-Paul Siderius
Netherlands Enterprise Agency

25. What do you need for energy efficiency measures?
2
• Scope
• Addressee(s)
• Efficiency metrics and requirements
• Test methods for verification and compliance

26. What is a system?
3
General definition: a regular interacting or interdependent group of
items forming a unified whole (an entity made of several parts)
Definition for systems policy:
a functional unit that consists of two or more physical parts that
need to be assembled at the location where the system is used.

27. Are systems included in ecodesign and energy
labelling?
4
• Ecodesign defines a product as: any good that has an impact on
energy consumption during use which is placed on the market
and/or put into service.
(Note that a good can consist of several physical units)
• Placing on the market: product produced in a factory and
installed at the end-user.
• Putting into service: parts (produced in a factory) are
assembled (and installed) on location at the end-user.
• Energy labelling regulation defines a system as: a combination
of several goods which when put together perform a specific
function in an expected environment and of which the energy
efficiency can then be determined as a single entity.

28. Classification of systems
5

29. Main challenges in regulating systems
6
• Assessing systems
• Checking compliance:
- Practical aspects: can addressees be identified, testing on location,
reproducible results?
- Regulatory powers: may be limited related to the scope, territorial
jurisdiction or powers of market surveillance authorities

30. Approaches in assessing systems
7
• Black box: test the system like a product
• Modular: test parts and combine the results
• Procedural: “quality management” of (sizing,) assembly and
installation
• Statistical: monitoring; measurement of energy consumption
and performance when the system is in use
• Modelling: mathematical model of parts of the system, or
scale model

31. Mapping systems and regulatory solutions
8
System
class
Main elements of energy efficiency measures
Scope & addressees
Efficiency metrics &
requirements
Verification & test methods
①
Manufacturers of (parts
of) the system.
Efficiency of the parts
and of the system.
Measurements on the parts of
the system; modelling to provide
results for the system (in a
variety of usage conditions).
②
Manufacturers of the
parts.
Efficiency of the parts. Measurements on the parts.
③
Manufacturers of the
identical and/or critical
parts of the system.
Assemblers/installers of
the system.
Efficiency of the
(identical/critical) parts.
Efficiency of the system
as assembled and
installed.
Measurements on the
(identical/critical) parts.
Modelling to calculate system
efficiency as assembled and
installed.
④
Manufacturers of the
parts.
Assemblers/installers of
the system.
Efficiency of the parts.
Quality (control) of the
assembly/installation.
Measurements on the parts.
Check on the quality (control) of
the assembly/installation.
⑤ Assemblers/installers of
the system.
Quality (control) of the
assembly/installation.
Check on the quality (control) of
the assembly/installation.

32. Outlook - recommendations
9
• Estimate the savings potential.
• When assembly has a large impact:
- Include assembler as addressee and focus on quality of the
assembly (quality management).
- Include (regulatory) option to regulate standardization of the
assembly.
• For quality control look at approaches used in buildings.
• Use modelling in the verification of systems if the variety in
conditions and systems is large:
- Include the model in the regulation.
- Indicate how third party calculations or simulations are to be
verified.

33. Thank your for your attention.
Questions?
hans-paul.siderius@rvo.nl
10

34. Energy
Workshop
"Towards a systems approach in Ecodesign and
Energy Labelling“
Exchange of views
17 June 2021
Ronald Piers de Raveschoot
Policy officer
DG ENER, B.3.

35. Energy
Reminder: Ecodesign legal basis
➢ Article 114 of the TFEU – Objective: functioning
of the internal market / free movement of goods
➢ Approximation / harmonisation => Consistency
of laws, regulations, standards and practices, so
that the same rules will apply to businesses that
operate in more than one member state
➢ Ordinary procedure : Legislative proposal from
the Commission => Adoption by legislator (EP +
Council)
➢ The act may foresee that the Commission adopts
implementing measures

36. Energy
• Consequences:
The rules have to be met when the regulated (individual)
product is placed on the EU market, i.e. when it is « made
available » the first time.
• « Blue guide » says
• Already Manufactured
• An offer or an agreement between the parties for the transfer
of ownership.
Normally the EU manufactuer or the importer are responsible.
Ecodesign also includes « putting into service ». It is a
different moment. Whatever comes first.
=> Applies e.g. when the ensuer buys the components
separately and puts them into service => he is the
manufacturer => conformity assessment, Declaration of
conformity and CE marking.

37. Energy
• What do we mean by systems approach ?
• Look at the efficiency of « complex / extended
products », e.g. pump + motor + VSD
• Look how well the (extended) product is suited to
the system with which it interacts, e.g. proper
sizing of a fan.
• Improve the energy efficiency and the system
design
Increasing
beenfits
Increasing
complexity

38. Energy
• Some EU experiences
❖ Heating/water heating package label
• To be delivered by the installer who puts the
components together
• Mitagated experience
➢ Difficulties of enforcement
➢ Not know the the public and installers in general
• => Decided to give it more time, try to simplify
(e.g. IT tool collecting data from EPREL)

39. Energy
• Solar panels
• State of Play: IA ongoing => CF September
• Ecodesign: PV Modules & inverters
• Energy Label: PV module + Installer label for the system:
module + inverter + cabling + shadows, inclination +
orientation, = with the offer.
• Discussion points:
➢ Enforcement difficulties
➢ Influence of climate?
➢ Influence of orientation?

40. Energy
Challenges (1)
• Instead of product manufacturer, the responsible person is often an installer
who puts the extended product together: this is a much broader range of
actors, more difficult to identify, to inform, to train, to survey, etc. No or
little representation.
• Less efficient inspections and more demanding for the limited MSAs
resources: verification can only take place installation by installation, instead
of model by model (one model can represent millions of products placed on
the market)
• Some MSAs do not have the legal powers to visit the installations
• How can MSAs be aware of the existence of new installations in the field?
• How to measure efficiency on site (no laboratory conditions, instruments,
legal value…) ?

41. Energy
Challenges (2)
• Putting into service is taking place at given moment, after which the
requirements do not apply. How can the MSA be informed and be present
at that very moment ?
• Consequences for non-compliance: once installed and put into service, the
“illegal” product cannot be removed from the market any more. Can a
MSA stop an entire industrial installation because a pump is not
compliant?
• Legal barrier : the Regulation specifies that « verification can be achieved
directly on the product or on the basis of the technical documentation”
• Multiplicity of actors in complex projects: Difficulty to find ‘one’ responsible
in case of non-compliance

42. Energy
Design /
engineering
office
Multiplicity of actors
General
contractor
Subcontractor 1:
electrical installation
Subcontractor 2:
mechanical installation
Subcontractor 3:
hydraulic part
Supplier 1: pump
Supplier 1: motor
Supplier 3: VSD
Client
Enduser

43. Energy
Review study of water pumps : proposed approach
• Current scope: ‘water pump’ = component = bare shaft pump = hydraulic
part of a pump
 Efficiency measured as MEI (Minimum Efficiency Index)
• The extended product = hydraulic part + motor (+ VSD if any) = ‘water
pump unit’
 Criterion = EEI (Energy efficiency index)
Pump
Bare shaft
pump
Transmission
e.g. coupling
Electric
Motor
Electric
Motor
Desired
work
Mains
Hydraulic
circuit
System
beyond the
pump unit
Extended product
(‘water pump unit’ –
EEI)
(VSD)
Current scope
(‘water pump’ –
MEI)

44. Energy
How can we save energy in variable flow
applications ?
VSD
Mains
Pump
Pump
Coupling
Electric
Motor
Electric
Motor
Desired
work
Hydraulic circuit
VSD, motor at reduced speed Desired
flow and
pressure
Same MEI
=> High EEI
=> Low EEI (60%)
Situation 1
(traditional, with
throttle valve)
Situation 2 (with
VSD)
Pump
Pump
Coupling
Electric
Motor
Electric
Motor
Desired
work
Mains
Hydraulic circuit
No VSD, motor at full speed
Valve
Desired
flow,
high
pressure
Desired
flow and
pressure
Destroyed
energy
Energy saved
in the system

45. Energy
44% 35% 15% 6%

46. Energy
• We consider using EPA for pumps for which there is a clear benefit of using a
VSD, i.e. for single stage pumps and booster sets
• We consider keeping the current approach (MEI) for pumps for which there is no
or uncertain benefit of using a VSD (e.g. multistage pumps)
• We keep MEI in other cases also (not mutually exclusive)
• The EEI requirements are set so that a VSD is needed to meet the requirement
=> this enables considerable energy savings in the system beyond the pump
itself, through:
• Ensuring that load variations are achieved by adjusting motor speed rather than
by destroying energy in throttling valves
• The use of a load profile with several load points, as representative as possible
of real pump operation
• Reducing motor speed in case of oversized pump
• Adjusting the pump to the required load point via motor speed control rather
than via pump trimming
How to generate more savings ?

47. The Extended Product Approach for water
pumps
Michael Könen – Europump
17.06.2021

48. 2
Source: Dr. Sönke Brodersen, KSB SE & Co. KGaA, October 2020
The Chronicle
Michael Könen - Europump
17.06.2021

49. 3
MEI for water pumps
(EN 16480)
IE Classification for
converters
(IEC 61800-9-2)
IE classes for
motors
(IEC 60034-30-1)
PDS Standard (IEC 61800-9)
IES classes for motor + CDM
Product Approach – Components at the nominal duty Point
Michael Könen - Europump
17.06.2021

50. 4
Pinput
Phydraulic
ηmot ηpump
IE-Class MEI-Level
Efficiency and demand – Regulatory levers
Michael Könen - Europump
17.06.2021

51. 5
Pinput
EEI-Level
Phydraulic-demand
Pno demand
ηmot ηpump
IE-Class MEI-Level
Efficiency and demand – Regulatory levers
Michael Könen - Europump
17.06.2021

52. THE Real Extended Product Approach
6
IE classes for CDM
IE classes for
motors
MEI for water pumps
Extended Product Approach (Europump EPA JWG)
EEI determination for centrifugal pumps
Michael Könen - Europump
17.06.2021

53. 7
The pump application
Michael Könen - Europump
17.06.2021

54. 8
Summary
Michael Könen - Europump
17.06.2021

55. Contact details:
Michael Könen
Tel. +49 6233 86-1893
E-mail: michael.koenen@ksb.com
Thank you