ITALIAN COMMENTS
on the Commission proposals for possible Ecodesign and EU Energy Label
measures for domestic coffee machines
Italian position on the Commission proposals
We welcome the statement, included in the Commission proposals for possible
ecodesign and EU energy label measures for domestic coffee machines, that “for this
particular product, as for most domestic appliances, energy labelling is expected to be
as least as effective as setting minimum requirements. But it is the combination of both
that supports EU and Member State action and will hopefully add a ‘consumer and
retailer pull’ to the ‘market push’ of eliminating the worst on the market”.
Eventually the paramount role of the energy labelling in promoting energy savings
starts to be recognised also by the Commission, along with the importance of an
approach coupling labelling with ecodesign requirements.
But to support, and even improve, the impact of the ecodesign and energy labelling on
the Community market, the implementing measures should be based on an
unambiguous approach, measurable quantities and verifiable parameters and on a
simple and transparent calculation systems.
Although the approach of integrating direct and indirect energy use in policy measures
for energy-related-products is worth discussing and the attempt to reduce food waste is
sharable for the economical and ethical implications, the practical application to
domestic coffee machines within PROPOSAL 2 presents unacceptable and ambiguous
elements that make the approach inapplicable to the setting of mandatory provisions.
Italy has the following opinion about the three presented proposal for implementing
measure for household coffee machines:
1. PROPOSAL 3: we consider this proposal the only one currently acceptable,
although addressing the standby consumption of household coffee machines. In our
view, this immediately applicable option would give the Commission some time to
define a more appropriate labelling measure and an additional set of ecodesign
requirement for household coffee machines.
2. PROPOSAL 2: we consider the proposal inappropriate for addressing the energy
efficiency of coffee machines, due to the high uncertainty and ambiguity of the
integrated approach including elements outside the control of coffee machine
suppliers. In addition, we also strongly disagree on the setting of the ecodesign
requirement (minimum efficiency requirement) at or even beyond the BAT, since
this largely exceeds the mandate of Directive 2009/125/EC and is not supported by
any life cycle cost consideration.
3. PROPOSAL 1: possible complement to PROPOSAL 3, although it does not address
all household coffee machine types.
When, following our suggestion of re-focusing the proposed implementing measures for
household coffee machines, we recommend to the Commission:
(a) to further analyse and reconsider the appropriateness of building mandatory
provisions of a EU market-oriented legislation on an integrated approach that is
based on default (i.e. average) non-measurable quantities, that can vary with the
time and the improvement of the consumable production process(es)
(b) to separate the impact of the consumables (that can not be influenced by a
technological improvement of the coffee machines) from the evaluation of the
energy efficiency of the coffee machines. Only measurable impacts under the
control of the machine suppliers and enforceable by public Authorities should be
taken into consideration.
Since consumables are in most cases responsible for a higher energy consumption than
the energy consumed by the coffee machine itself, instead of PROPOSAL 2 we would
welcome revised policy measures for example setting clear, transparent, measurable and
verifiable ecodesign requirements aimed at improving the conservation of the coffee
after the brewing phase (and thus limiting the waste of coffee) and the proper dosage
(filter coffee machines are very exposed to over dosage by the consumer), accompanied
by a machine-oriented labelling scheme. Should the Commission be willing to address
also the impact of the energy consumption of filters/pads and capsules another specific
horizontal policy measure could be prepared.
Therefore far from being forgotten, the results of the analysis and calculation of the
energy consumption of coffee production and procurement included in PROPOSAL 2
could be successfully used by the Commission as supporting evidence for such
requirements.
It should be anyway clear that in no cases the energy and environmental impact(s) of
materials out of the control of the coffee machine suppliers should be considered in
policy measures addressing coffee machines, especially if the outcome of such measures
is the phase out of specific coffee machine types.
Specific comments on Commission proposals for domestic coffee machines
In the following the specific Italian comments on the possible ecodesign and energy
label measures described in PROPOSAL 2 are presented. Additional comments will be
directly presented during the Consultation Forum.

The approach of addressing the consumption of other important resources, beyond
the direct energy consumption, has been successfully applied to previous energy
labelling measures, i.e. for washing machines and dishwashers where the annual
water consumption of each model in the standard washing cycle is shown on the
label and addressed in the ecodesign requirements. But for these wash appliances
the water consumption is measured under test conditions that keep main parameters
(ambient and wash temperature) and consumables (quality of water, quality and
amount of detergent, type and amount of textile load) stable, in order to exclude
them from the evaluation of the energy and water consumption and of the functional
performance of the washing machine.
In the approach followed for coffee machines this principle is not applied. The
energy consumption of a coffee machine includes in fact the measurement of the
actual amount of ground coffee beans and of the filtering/portioning system used in
the defined coffee cycle.

We share the concept that since coffee constitutes 90% of the LCC of a coffee
machine and a part of that cost is in energy any reduction in the coffee consumption
would imply a major reduction in the energy consumption due to the preparation of
a coffee beverage, but the approach followed in PROPOSAL 2 calculations includes
elements that are outside the control of the coffee machines suppliers: the amount of
coffee in each filter/capsule/pad depends on the coffee supplier and not on the
coffee machine supplier. And the latter are also not responsible for the packing
material (paper, plastic, aluminium, etc.) selected by the ground coffee beans
suppliers.
The feeling is that through the “integrated approach” the Commission is attempting
to define also policy measures for coffee suppliers, therefore an “integrated
suppliers approach” is actually proposed.
This approach and its implications are worth discussing but we cannot accept that
requirements for consumables’ suppliers are hidden in a policy measure addressing
coffee machine suppliers

The proposed measures should provide consumers with a picture of the brewing
coffee service able to address their choice towards more efficient models, but the
energy label defined in PROPOSAL 2 fails in providing this picture because the
ranking depends on the sum of the direct and indirect energy consumption resulting
from the integrated approach, where the contribution of the consumables is
preponderant. Since the energy requirement of the ground coffee beans is the most
important of the three components the resulting message will be misleading for the
consumer:
1. by showing that the coffee machine is not the responsbile for most of the energy
consumption of the overall coffee preparation it moves the attention of the
consumers from the machines to the consumables. Although this may be
considered a positive outcome of the proposed legislation, it may on the contrary
create the perception that since drinking coffee is energy consuming the best
way to save energy is limiting the coffee consumption; in other words the best
way to save energy is not a technological improvement but the limitation of a
service. We do not believe that this is the scope of the energy labelling nor of the
ecodesign Directive;
2. it will not address consumers towards more energy efficient coffee machines,
but on models that use a lower amount of consumables;
3. it presents the indirect energy content of the coffee beans on the basis of a
default average value that does not take into account the specific characteristics
of the coffee bean real life cycle and the possible modifications with time. For
example it is does not allow to distinguish the reduced energy content of
biological coffee, or of coffee produced by advanced farmers using almost only
RES1, or coffe coming from specific producing countries. We wonder if the
repercussion of the proposed Regulations on the EU commerce of coffee beans
and expecially on small scale coffee producers (such as those in in Central
America) has been carefully evaluated or will be evaluated in the IA.
4. is not under the control of the coffee machines suppliers, but only by the
consumables suppliers;
5. the shown impact of the filters, pads and capsules is based only on fixed average
values and only paper and aluminium are addressed in the proposed legislation.
Instead capsules can be made of plastic (that in turn can be either impermeable
or permeable to oxigen but they are not pads) and also of bio-degradable plastic
permitting the disposal of the pad and the exhausted ground coffee beans within
See document for example document: “Measuring and Managing the Environmental Cost of Coffee
Production, Victor Julio Chavez A., David I. King, Richard B. Chandler, Raul Raudales, Rich
Trubey, and Carlin C. Chandler
1
the compost. At the same time pads are not always made of paper but also of
alumium (and are not permeable to oxigen, but may become permeable if a set
of small holes are made during the production phase); not to mention composite
aluminium/pastic materials for pads/capsules (Figure 1).
Figure 1: examples of plastic oxigen permeable capsules (left), plastic biodegradable capsule
(cenrtre) and of aluminium pads (right)
Finally, coffee filters for drip filter machines can also be made of plastic and
being reusable for some time, but not foreever (not fully mechanical metal
filters) (Figure 2).
Figure 2: example of reusable plastic coffee filter
We would like also to highlight that the same coffee machine can accept
filters/pads/capsules of different materials and with a different amount of ground
coffee depending on the consumable suppliers merketing strategy.
Finally some coffee machines are able to use both capsules and (soft) pads
through the use of specific stainless steel “adaptors” (Figure 3).
Figure 3: example of stainless steel adaptors for coffee machines

Presence of a hard off switch: is an electronic switch also acceptable?

Testing method: the proposed test method and included (engineering) calculations
are complex and quite different from the CENELEC method under preparation
following the a mandate by the Commission. Some of the default values for the
specific machine type have no justification in the Commission CF document. It
appears that these default valued have been set in order to achieve a diversification
of the different types of coffee machines suitable for the implementation of the
proposed policy measures.

The proposed energy labelling scheme has a limited “dynamic approach” because
the label ranking ends with class A+. A more rational distribution of the energy
efficiency index would have resulted in additional energy efficiency classes and a
better differentiation of the coffee machine models, especially when coupled with
also a more rational ecodesign minimum efficiency requirements (see out above
comments on this issue)
Rome, 14 December 2011