Policies & Issues

Eco Design Directive

 

What is it?

The Ecodesign Directive 2009/125/EC establishes a framework for the setting of eco design requirements on Energy related Products (ErP) addressing all environmental aspects from a life cycle perspective.  Examples of such energy related products include lighting equipment, motors, pumps, refrigerators, computers, TVs, air conditioning and ventilation systems or machine tools.

The Ecodesign Directive empowers the Commission to adopt, via comitology, so-called 'implementing measures' following the conduct of a preparatory study and impact assessment, a structured consultation process of stakeholders and of Member States  and following the European Parliament’s and Council’s right of scrutiny on draft measures. The major stakeholder consultation body is the so-called 'Consultation Forum, which gathers interested parties to voice their opinions on envisaged implementation activities.

Preparatory studies are carried out on the basis of the so-called MEErP methodology that has been specifically derived from the Directive for the purpose of implementation. On the basis of the outcome of the preparatory study, the Commission may suggest ecodesign requirements on environmental aspects of a given product group that have been identified as being of significance according to the criteria of the Directive (article 15).

Alternatively, the targeted product group can propose a voluntary agreement subject to recognition by the Commission.

While the initial Directive drew up a first list of product groups to be targeted by 2010 directly, the Commission is since required to regularly establish Working Plans that set out an indicative list of priority products for the adoption of implementing measures during a certain period of time. The latest (draft) Working Plan relates to the period 2012-2014.

 

Why is it important?

Orgalime industries are by far the most affected sectors, as it represents the entirety of producers of almost all (+/- 39) product groups currently targeted by the Ecodesign Directive and its implementation process.  As such, Orgalime is a member of the Consultation Forum.

The first implementation measure was adopted in December 2008, notably on standby and off mode electric power consumption.  This was then followed by the adoption of some further 15 implementing measures for a different range of equipment, including battery chargers and external power supplies, lighting equipment, electric motors, circulators, fans, refrigerators, washing machines, dishwashers or set top boxes.

The first set of final implementation measures is also subject to revision and the working plan(s) for the subsequent years will also be set up.

Finally, the Ecodesign Directive itself may be subject to further review.

In addition, the Ecodesign Directive and its ongoing implementation represents a major contribution to the EU’s energy, climate change and resource efficiency policies.

 

Our viewpoint

Orgalime industries are committed to the objectives of the Ecodesign Directive and related EU Energy Labelling legislation.

Based on the experience gained with the Ecodesign Directive in our industries so far, Orgalime aims to:

  • Contribute to the establishment of an ambitious while realistic and workable programme for the implementation of the Directive.
  • Secure clear and unambiguous scope of implementing measures and the use of harmonised European standards.
  • Secure realistic timelines for implementing measures, allowing industry to adapt to the necessary changes to products and production processes.
  • Secure a consistent and evidence based application of all criteria and procedural elements of the Directive (especially article 15 and its criterion of “significant environmental improvement potential”) for the further implementation.
  • Secure the consistency of implementation measures and coherence with other EU environmental legislation.

While the 2012 review study confirmed the prematurity of an amendment of the Directive at this stage, another review may take place together with the review of the Energy Label Directive in 2014.  If this appears to be a sensible approach, given the complementary roles of the two instruments, we believe that the current backlog in implementation should be cleared before opening up for another round of review discussions.  Indeed, we advocate  first completing the ongoing implementation following earlier working plans and to improve enforcement so as to demonstrate the success of the Directive before launching the implementation procedure on new product groups or extending its scope to non-energy-related products.  It is vital to secure efforts and investments made by industry in the ongoing implementation process: these should not be undermined by the review of the Ecodesign Directive and/or its implementation activities.

 

How we’ve been engaged

Orgalime closely followed the legislative process of the Ecodesign Directive and its reviews.

As the ‘only’ targeted sector so far, Orgalime industries have actively contributed to all implementation activities to date, from the setting up of any working plan, the development of the MEEuP/MEErP methodology, the preparatory studies or draft voluntary agreements for the different targeted product groups up to the preparatory review studies on the framework Directive itself.  Our industries have made the effort and the necessary investments to comply with the requirements given in any finally adopted implementing measures.

Orgalime is a member of the Consultation Forum and the Eco Design Working Group set up to discuss any implementation issue.  Orgalime is also actively involved in the preparation of the amended Working Plan for 2012-2014 and the evaluation of the Eco Design Directive on the basis of the experience gained from its implementation so far.

In addition, Orgalime provides overview tables that inform on the state of play of the implementation process of the Ecodesign Directive, which are updated on a regular basis, and provides an exchange platform for all European sector organisations targeted by the Directive.

 

Useful links

 

 

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