Mr. François LAMOUREUX
Directeur Général des Transports et de l’Energie
Commission Européenne
Rue de la Loi, 200
B-1040 BRUSSELS
31 August 2002
RE: Revision of the European energy label for cold appliances.
Dear Mr. LAMOUREUX,
The European Council for an Energy Efficient Economy, eceee
(www.eceee.org), strongly recommends that the Energy Label for Cold
Appliances not be modified along the lines proposed by CECED, which
suggests adding A+ and A++ categories to the A- G scale. The A- G label
has been a very powerful instrument for promoting energy efficient
domestic appliances and a pillar of Europe’s energy efficiency policy. The
recognition level has been shown to be very high among consumers.
It is a well known fact that improvement of energy efficiency can contribute
to both an improvement in the standard of living and an improved
environment. Continual significant increases in energy efficiency is
essential to the creation of a sustainable future.
One of the safest and most fruitful ways of achieving this is through the
voluntary participation of consumers making educated choices about home
appliance purchases. The European Union has been a leader in this respect
and the A-G labelling system for household appliances has become a model
for many other countries and regions of the world. This system embodies a
significant investment both in money and in customer confidence and has
taken a considerable amount of time to establish. This investment must not
be wasted.
We consider that a change suggested by CECED is likely to jeopardise the
nature and the impact of the European energy label and could ruin what has
become an effective policy tool. It will undoubtedly cause confusion and
reduce the label’s effectiveness. Europe can not afford to corrupt an energy
efficiency programme that has been shown to deliver, both in terms of
energy reduction, improved energy security policy and mitigation of
greenhouse gas emission.
The eceee recognises that the existing labelling system has weaknesses.
This has been pointed out by the eceee in the work for the European Climate
Change Programme (ECCP). Experience shows that it is too difficult and
time consuming to upgrade efficiency categories. The labelling system must
be “dynamic”. The eceee views it as positive that the European
Commission now brings this necessary characteristic to the fore and
suggests a revision which would capture technological developments over
time. This essential change must not however confuse or spoil the design of
the label. Experience shows that established informational systems like
labels should not be changed without thorough pre-testing. The proposed
change in design should at a minimum be tested in focus groups and ideally
in larger customer samples before it is introduced. Even given pre-testing,
we are very sceptical to a policy which opens for periodic changes in the
label’s design.
We understand the motivation for the proposed modification. The
distribution consumption (efficiency) of appliances has moved since the
introduction of the label while the label categories have remained the same.
This has created a situation in which the label no longer segments in
satisfactory way appliances of the same class. It is obvious that the label
will quickly become meaningless unless there is an accommodation for
evolution in appliance energy efficiency. This ought to be accomplished
through a periodic revision of the ranges of consumptions, which define the
categories A, B, C, D, E, F and G. Creating an algorithm to do this is not
technically difficult. The eceee has recommended a methodology and would
gladly discuss it with the Committee.
The most important points are:
 Europe should strictly hold to the current label format (A to G),
avoiding the risk of negatively affecting acceptance and
comprehension.
 The labelling system should be changed to a dynamic system to
accommodate and drive change in the distribution of energy
consumption (efficiency) for a given category of appliances over
time.
 The labelling categories for cold appliances, i.e., the criteria for
categorization as A, B, C, D, E, F, or G should be updated
immediately.
eceee remains at your disposal to continue this discussion. We will gladly
provide you and your staff with any complementary information you may
need on this labelling issue.
Sincerely yours
François Moisan
Chairman of eceee
Copies are sent to:
Gunther Hanreich
Luc Werring
André Brisear
Matthew Kestner
Members of the labelling committee (electronic copy only)