OpenLobby.EU
Explore

Bund für Umwelt und Naturschutz Deutschland e.V. , Friends of the Earth Germany

BUND e.V.

BUND (Friends of the Earth Germany) is a non-profit, non-partisan, and non-confessional federal grassroots NGO with about 500,000 members and supporters.

Lobbying Activity

Response to Ecodesign requirements for external power supplies

6 Nov 2018

We support the revision of the External Power Supplies regulation, in particular the extension of the scope to multi-voltage EPS. We regret that the proposal has not been made more ambitious, notably in terms of resource efficiency, as described below. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. Wireless chargers have not been integrated in the scope. We believe it is essential to consider this rapidly emerging category and potentially significant new source for energy waste. Inefficient design can have a resource efficiency impact in terms of adverse thermal effects (overheating) that can cause device malfunction or damage. Cheap inefficient wireless chargers on the EU market could reduce mobile phone lifetimes, as well as having poor lifetimes themselves. We call on the Commission to issue a standardisation request as soon as possible to define testing approaches for these products. We also ask for the integration of an early-revision clause, to be able to regulate these within a few years’ time. We regret that a 10%-load active efficiency requirement is not included in the proposal and think that an information requirement is a minimum and essential to be able to address this in the next revision. We also regret that this regulation has not been better integrated to the Circular Economy strategy of the European Union. In particular, we believe that this regulation should include a requirement for the EPS to be reparable with widely available tools, so that independent repairers would be able to repair an EPS rather than having to discard it as WEEE. We also think that the European institutions should play an active role in promoting the interoperability of supplies and EPS/chargers. It is clear that standardising and reducing the quantity of EPS and chargers in use would have a positive impact on material efficiency, reducing EPS electronic waste potentially by up to 500 000 tons, as well as extending lifetime, enhancing reliability and decreasing weight by up to 30. Moreover, this would potentially have a significant impact on embedded energy, corresponding to a non-negligible fraction of the energy that can be saved during the use stage. Additionally, this should contribute to cost savings for consumers, reducing the need to buy a new EPS each time a small ICT device is acquired. This revision is therefore a perfect opportunity that should be grasped.
Read full response

Response to Review of ecodesign requirements for household dishwashers

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission but call on the European institutions to reinforce several of the provisions in discussion. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. Energy efficiency We are concerned about the lack of ambition put forward on the energy efficiency aspects. On Ecodesign, the proposed first tier sets the efficiency levels as already in place today, meaning that no improvement will be actually implemented until Tier 2 in 2024. Although we support the inclusion of a Tier 2, the proposal for 2024 has been set at a very unambitious level. Tier 2 deviates from the least life cycle cost principle of the Ecodesign Directive, and cannot be accepted. The level of Tier 2 needs to be set at an adequate level, corresponding to at least class D of the new label (EEI of 50). Moreover, classes of the energy label have been relaxed, making it easier to climb out of the red bottom classes. This is regrettable, and a threat to the longevity of the new label. Besides, the proposed scale risks contravening with Labelling Regulation 2017/1369 which states that Class A should be empty and the BAT situated in Class B. As a matter of fact, the A class may not be empty from the start since heat pump dishwashers mentioned in the benchmarks may already be in A. Finally, we are convinced that the test method used for the declaration of the Energy Label should be representative of real-life use as much as possible. The appropriate scenario would include testing different programmes or a combination of programmes and functions, selected on the basis of consumer habits, instead of continuing using the eco programme for the labelling purposes as proposed. Resource efficiency We strongly support the measures addressing material efficiency and urge the European institutions to maintain ambition on this important issue. Some requirements seem to have been relaxed as the process progresses, which is not acceptable. We call on the below changes to the proposal: - Extend the spare part availability to a minimum of 10 years We strongly support the inclusion of a minimum period of spare part availability as this is fundamental for material efficiency and market surveillance purposes. Spare parts should be available during the average product lifetime or for 10 years minimum. Further, whilst we support the list of spare parts now included in the document, we suggest that batteries are also added. - Shorten the delivery time of necessary spare parts and strengthen the wording of the provision We strongly support requirements for spare part maximum delivery time, but the timeframe of 15 working days should be further reduced to avoid this time-lapse to become a reason for consumers to replace their product. The wording should be reinforced by mentioning that spare parts are available to retailers, repairers and consumers. Finally, the verification requirements allow manufacturers three chances to meet the delivery time requirement, plus the option of a “force majeure” justification. This is too loose in our opinion. - Reintroduce the unrestricted access to repair and maintenance information We are disappointed to note the barriers now put in place to access repair and maintenance information. We call on the European institutions to reintroduce the “unrestricted access to appliance repair and maintenance information to independent operators”. - Target non-destructive disassembly Finally, it is essential that the ease of access to key components targets non-destructive disassembly for the purpose of repair, rather than dismantling only for material recovery.
Read full response

Response to Review of energy labelling for household dishwashers

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission but call on the European institutions to reinforce several of the provisions in discussion. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. Energy efficiency We are concerned about the lack of ambition put forward on the energy efficiency aspects. On Ecodesign, the proposed first tier sets the efficiency levels as already in place today, meaning that no improvement will be actually implemented until Tier 2 in 2024. Although we support the inclusion of a Tier 2, the proposal for 2024 has been set at a very unambitious level. Tier 2 deviates from the least life cycle cost principle of the Ecodesign Directive, and cannot be accepted. The level of Tier 2 needs to be set at an adequate level, corresponding to at least class D of the new label (EEI of 50). Moreover, classes of the energy label have been relaxed, making it easier to climb out of the red bottom classes. This is regrettable, and a threat to the longevity of the new label. Besides, the proposed scale risks contravening with Labelling Regulation 2017/1369 which states that Class A should be empty and the BAT situated in Class B. As a matter of fact, the A class may not be empty from the start since heat pump dishwashers mentioned in the benchmarks may already be in A. Finally, we are convinced that the test method used for the declaration of the Energy Label should be representative of real-life use as much as possible. The appropriate scenario would include testing different programmes or a combination of programmes and functions, selected on the basis of consumer habits, instead of continuing using the eco programme for the labelling purposes as proposed. Resource efficiency We strongly support the measures addressing material efficiency and urge the European institutions to maintain ambition on this important issue. Some requirements seem to have been relaxed as the process progresses, which is not acceptable. We call on the below changes to the proposal: - Extend the spare part availability to a minimum of 10 years We strongly support the inclusion of a minimum period of spare part availability as this is fundamental for material efficiency and market surveillance purposes. Spare parts should be available during the average product lifetime or for 10 years minimum. Further, whilst we support the list of spare parts now included in the document, we suggest that batteries are also added. - Shorten the delivery time of necessary spare parts and strengthen the wording of the provision We strongly support requirements for spare part maximum delivery time, but the timeframe of 15 working days should be further reduced to avoid this time-lapse to become a reason for consumers to replace their product. The wording should be reinforced by mentioning that spare parts are available to retailers, repairers and consumers. Finally, the verification requirements allow manufacturers three chances to meet the delivery time requirement, plus the option of a “force majeure” justification. This is too loose in our opinion. - Reintroduce the unrestricted access to repair and maintenance information We are disappointed to note the barriers now put in place to access repair and maintenance information. We call on the European institutions to reintroduce the “unrestricted access to appliance repair and maintenance information to independent operators”. - Target non-destructive disassembly Finally, it is essential that the ease of access to key components targets non-destructive disassembly for the purpose of repair, rather than dismantling only for material recovery.
Read full response

Response to Ecodesign requirements for electronic displays and televisions

6 Nov 2018

The revision of the 2009 TVs measure is finally coming to an end, which we welcome. The Commission proposal brings various improvements, such as the extension of the scope to displays, a revised scale with classes A and B empty to drive innovation, a double scale, which gives the right amount of attention to the High Dynamic Range (HDR) feature, stricter standby requirements, etc. We also have a number of suggestions on how to improve the text further. Note that most of our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Extend the regulation scope We call on the European institutions to remove several exemptions from the scope, notably the exemption for electronic displays where the main function of the display is status display or control or function activation, the exemption for digital photo frames, and the numerous exemptions for signage displays. In the previous drafts, electronic displays integrated into other products were made easily accessible to facilitate their dismantling, which is not the case anymore. We urge the European institutions to reintroduce this provision. - Finetune the proposed Energy Label The Energy Label should contain indication of the annual energy consumption, in a prominent position, to be consistent with the new Energy Labelling Framework Regulation. We have doubts regarding the proposed External Power Supplies (EPS) icon in terms of comprehensibility and influence on purchasing decisions. Other options could be added, such as the time during which spare parts will be made available by the manufacturer. - Reinforce the clause on software updates We strongly support the requirement that the power demand of the product will not increase after a software or firmware update when measured with the same test standard originally used for the declaration of conformity. However, the exception that this is allowed with the “explicit consent of the end-user” significantly weakens this requirement. In the STEP report, an increase in energy consumption of 31% to 37% was observed after software updates for three of the seven television models tested. We believe that prior to being asked to provide consent, the user shall be notified of a possible increase of energy use and in which circumstance or functionality that increase will occur before starting the update and should have right to refuse an update. In the event that the user disables energy saving functionality (either directly or indirectly, for example via a change in picture settings), the user shall be informed of the resultant increase in energy usage, and it shall be possible for them to re-enable this functionality without a factory reset. - Reinforce the resource efficiency provisions by targeting easier repair Ease of access should target non-destructive disassembly rather than dismantling only. The European Commission has put forward innovative provisions to facilitate the repair of several domestic appliances as part of the Package of measures to be adopted by the end of the year and we disagree with the idea that TVs and displays should be under a different regime. Moreover, on dismantling, the reference to WEEE results in key display parts not being addressed (e.g. PMMA boards and internal power supplies) and some display technologies neither (e.g. OLED). - Limit the use of halogenated flame retardants We firmly believe that the use of halogenated flame retardants should not be permitted in the enclosure and stand of electronic displays, as proposed in the July 2018 draft from the European Commission. We strongly disagree with the idea that this should be kept for another policy discussion. The negative impact of using halogenated flame retardants in televisions and displays does not need to be proven anymore and it needs to be urgently addressed.
Read full response

Response to Energy labelling for electronic displays

6 Nov 2018

The revision of the 2009 TVs measure is finally coming to an end, which we welcome. The Commission proposal brings various improvements, such as the extension of the scope to displays, a revised scale with classes A and B empty to drive innovation, a double scale, which gives the right amount of attention to the High Dynamic Range (HDR) feature, stricter standby requirements, etc. We also have a number of suggestions on how to improve the text further. Note that most of our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Extend the regulation scope We call on the European institutions to remove several exemptions from the scope, notably the exemption for electronic displays where the main function of the display is status display or control or function activation, the exemption for digital photo frames, and the numerous exemptions for signage displays. In the previous drafts, electronic displays integrated into other products were made easily accessible to facilitate their dismantling, which is not the case anymore. We urge the European institutions to reintroduce this provision. - Finetune the proposed Energy Label The Energy Label should contain indication of the annual energy consumption, in a prominent position, to be consistent with the new Energy Labelling Framework Regulation. We have doubts regarding the proposed External Power Supplies (EPS) icon in terms of comprehensibility and influence on purchasing decisions. Other options could be added, such as the time during which spare parts will be made available by the manufacturer. - Reinforce the clause on software updates We strongly support the requirement that the power demand of the product will not increase after a software or firmware update when measured with the same test standard originally used for the declaration of conformity. However, the exception that this is allowed with the “explicit consent of the end-user” significantly weakens this requirement. In the STEP report, an increase in energy consumption of 31% to 37% was observed after software updates for three of the seven television models tested. We believe that prior to being asked to provide consent, the user shall be notified of a possible increase of energy use and in which circumstance or functionality that increase will occur before starting the update and should have right to refuse an update. In the event that the user disables energy saving functionality (either directly or indirectly, for example via a change in picture settings), the user shall be informed of the resultant increase in energy usage, and it shall be possible for them to re-enable this functionality without a factory reset. - Reinforce the resource efficiency provisions by targeting easier repair Ease of access should target non-destructive disassembly rather than dismantling only. The European Commission has put forward innovative provisions to facilitate the repair of several domestic appliances as part of the Package of measures to be adopted by the end of the year and we disagree with the idea that TVs and displays should be under a different regime. Moreover, on dismantling, the reference to WEEE results in key display parts not being addressed (e.g. PMMA boards and internal power supplies) and some display technologies neither (e.g. OLED). - Limit the use of halogenated flame retardants We firmly believe that the use of halogenated flame retardants should not be permitted in the enclosure and stand of electronic displays, as proposed in the July 2018 draft from the European Commission. We strongly disagree with the idea that this should be kept for another policy discussion. The negative impact of using halogenated flame retardants in televisions and displays does not need to be proven anymore and it needs to be urgently addressed.
Read full response

Response to Review of ecodesign requirements for household cold appliances

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission. We also listed below recommendations on how to further improve the proposals. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Accelerate implementation of requirements We regret the one-year delay on all application dates compared to the previous drafts. Everything should be done to respect the Energy Labelling Regulation 2017/1369, which foresees that new labels are displayed in shops by end 2019. - Finetune the scope We welcome the definition of the scope, especially the reinstatement of wine coolers and minibars with glass doors. We still see a risk of potential gaps in the combined scopes of these regulations and that for professional and commercial appliances. - Simplify the Energy Efficiency Index Formula We regret that the formula for the energy efficiency index has not been simplified and streamlined. We firmly believe there are too many correction factors and bonuses. The ‘built-in factor’ should especially be removed. We also consider that thee frost-free correction factor is too generous and should not exceed 5%. - Design of the Label We believe that only one indicator should be kept for the storage volume of all compartments together. We regret that no icons that could help consumers buy more durable, reparable products have been envisaged. Moreover, the call from many stakeholders for starting without grey classes from the beginning (meaning changing the F and G boundaries) should be considered. - Strongly reinforce provisions on resource efficiency We support requirements looking at facilitating fridges’ repair and recycling. The proposal in discussion remains very shy compared to what is proposed for dishwashers and washing machines and we call for an alignment on these. This would mean enlarging the provision on the ease of disassembly, allowing the easy access to ann exhaustive list of key components for repair. The availability of spare parts should be extended so that all spare parts important for repair are available during the average product lifetime or for 10 years minimum. We also consider that that the maximum delivery time for spare parts should be reduced. And finally, we believe that a clause on “unrestricted access to repair and maintenance information” should be included.
Read full response

Response to Review of energy labelling for household cold appliances

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission. We also listed below recommendations on how to further improve the proposals. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Accelerate implementation of requirements We regret the one-year delay on all application dates compared to the previous drafts. Everything should be done to respect the Energy Labelling Regulation 2017/1369, which foresees that new labels are displayed in shops by end 2019. - Finetune the scope We welcome the definition of the scope, especially the reinstatement of wine coolers and minibars with glass doors. We still see a risk of potential gaps in the combined scopes of these regulations and that for professional and commercial appliances. - Simplify the Energy Efficiency Index Formula We regret that the formula for the energy efficiency index has not been simplified and streamlined. We firmly believe there are too many correction factors and bonuses. The ‘built-in factor’ should especially be removed. We also consider that thee frost-free correction factor is too generous and should not exceed 5%. - Design of the Label We believe that only one indicator should be kept for the storage volume of all compartments together. We regret that no icons that could help consumers buy more durable, reparable products have been envisaged. Moreover, the call from many stakeholders for starting without grey classes from the beginning (meaning changing the F and G boundaries) should be considered. - Strongly reinforce provisions on resource efficiency We support requirements looking at facilitating fridges’ repair and recycling. The proposal in discussion remains very shy compared to what is proposed for dishwashers and washing machines and we call for an alignment on these. This would mean enlarging the provision on the ease of disassembly, allowing the easy access to ann exhaustive list of key components for repair. The availability of spare parts should be extended so that all spare parts important for repair are available during the average product lifetime or for 10 years minimum. We also consider that that the maximum delivery time for spare parts should be reduced. And finally, we believe that a clause on “unrestricted access to repair and maintenance information” should be included.
Read full response

Response to Review of ecodesign requirements for lighting products

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission, and particularly the phasing out of T8 lamps, the important product information that will be made accessible in the EU product database, and the revised verification tolerance levels. We also have the below recommendations on how to further improve the proposals. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Accelerate implementation of requirements We do not support the decision to delay the entry into force of the Regulations by a year, to 2021. The measures should take effect in 2020 as originally proposed in the November 2017 draft. We particularly oppose the nine-month transition period offered for relabelling products in shops until June 2022. It is much longer than is necessary and conflicts with Energy Labelling Regulation 2017/1369 which states that new labels should be displayed in shops by the end of 2019. - Expand the chromaticity boundaries defining “white light” We urge the European institutions to ensure that the light chromaticity boundaries defining the scope of coverage be expanded, so as not to create the risk of a loophole (i.e. products placed on the market which are just outside the white-light boundaries, that would still look like white light but would escape all requirements). - Set the L factor at 1.0 instead of 1.5 We warn about the too high “end-loss factor” L for LEDs in the formula for efficacy requirements. There will be hardly any impact on household products in the low and medium lumen ranges, where efficiency can be substantially improved. - Introduce a mid-term check in the new accelerated endurance testing proposal We welcome the new lifetime testing proposal, which combines endurance switching cycles with lumen maintenance. Since we believe that some of the poor-quality products will fail in the first few hundred hours of testing, we suggest introducing a mid-term check during the test to ensure that products of the lowest quality can be even more quickly identified and subjected to timely sanctions. - Raise ambition on product dismantlability The provision on the possibility to remove the light sources and control gears without mechanical damage by the end-user from any product containing them is too weak: dismantling (not disassembly) is now foreseen, and only for market surveillance purposes. This is a big step backwards and we call on the reintroduction of the initial proposal which was supported by several Member States in December 2017.
Read full response

Response to Review of energy labelling requirements for lighting products

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission, and particularly the phasing out of T8 lamps, the important product information that will be made accessible in the EU product database, and the revised verification tolerance levels. We also have the below recommendations on how to further improve the proposals. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Accelerate implementation of requirements We do not support the decision to delay the entry into force of the Regulations by a year, to 2021. The measures should take effect in 2020 as originally proposed in the November 2017 draft. We particularly oppose the nine-month transition period offered for relabelling products in shops until June 2022. It is much longer than is necessary and conflicts with Energy Labelling Regulation 2017/1369 which states that new labels should be displayed in shops by the end of 2019. - Expand the chromaticity boundaries defining “white light” We urge the European institutions to ensure that the light chromaticity boundaries defining the scope of coverage be expanded, so as not to create the risk of a loophole (i.e. products placed on the market which are just outside the white-light boundaries, that would still look like white light but would escape all requirements). - Set the L factor at 1.0 instead of 1.5 We warn about the too high “end-loss factor” L for LEDs in the formula for efficacy requirements. There will be hardly any impact on household products in the low and medium lumen ranges, where efficiency can be substantially improved. - Introduce a mid-term check in the new accelerated endurance testing proposal We welcome the new lifetime testing proposal, which combines endurance switching cycles with lumen maintenance. Since we believe that some of the poor-quality products will fail in the first few hundred hours of testing, we suggest introducing a mid-term check during the test to ensure that products of the lowest quality can be even more quickly identified and subjected to timely sanctions. - Raise ambition on product dismantlability The provision on the possibility to remove the light sources and control gears without mechanical damage by the end-user from any product containing them is too weak: dismantling (not disassembly) is now foreseen, and only for market surveillance purposes. This is a big step backwards and we call on the reintroduction of the initial proposal which was supported by several Member States in December 2017.
Read full response

Response to Post 2020 light vehicle CO2 Regulation(s)

22 Mar 2018

Bewertung des Bund für Umwelt und Naturschutz Deutschland e.V. zum EU-Kommissionsvorschlags für CO2-Grenzwerte für Pkw und leichte Nutzfahrzeuge nach 2021 Siehe angehängte Datei
Read full response

Response to Energy labelling requirements for computers and computer servers

22 Feb 2018

The inception impact assessment document provides a very good introduction to the topic, and we are very supportive of most of the statements made. The best policy option for consumers and the environment is indeed option 3. We would like to insist on three key points: 1/ Ecodesign requirements should be pursued, but thoroughly revised and reinforced to better reflect current technologies and practices. - Measuring computers in a more active state than idle would ensure that the requirements are closer to real life use and the potential savings really reaped. - Carefully designing requirements on standby modes, so that no ‘modern standby’ unduly escapes Ecodesign limits, is a critical aspect. - Most of the power allowances (for graphic adders, tuners, additional memory storage, etc.) should also be revisited and substantially adjusted, since there are technological solutions to avoid the energy use from these adders when they are not in operation. - The current exemption of requirements for high-end PCs needs to be deleted, because it creates a too high risk of free ride for configurations that then become more and more mainstream. In particular, powerful gaming computers should be covered (as game consoles are), since the saving potentials are massive for these types of products. - Durability, reusability, and recyclability requirements are also of paramount importance. For mobile products, the share of the production and end of life phases is dominant in their ecological life-cycle. Hence the need to tackle these issues that become increasingly significant for consumers. 2/ An Energy Label for computers will be a very welcome addition. It is obvious that most (private and professional) consumers do not have a clear idea of the energy use from computers, and the difference between models and configurations on the market. Only an energy label can fil this gap. The Label can be based on a similar methodology/measurement than Ecodesign. From our analysis, there is sufficient differentiation on the market to allow for a scale of 7 energy classes for desktops, and possibly slightly less (e.g. 5) for laptops. The label can also be used to display durability information. 3/ We agree that tablets could be removed from the scope of energy efficiency requirements and labelling (as they are intrinsically low consuming), however we are fully opposed to exempting them from durability requirements. Issues of poorly performing and changeable batteries, lack of recyclability, and rapid obsolescence are fully relevant for tablets and should be tackled.
Read full response

Response to Review of ecodesign requirements for computers and computer servers

22 Feb 2018

The inception impact assessment document provides a very good introduction to the topic, and we are very supportive of most of the statements made. The best policy option for consumers and the environment is indeed option 3. We would like to insist on three key points: 1/ Ecodesign requirements should be pursued, but thoroughly revised and reinforced to better reflect current technologies and practices. - Measuring computers in a more active state than idle would ensure that the requirements are closer to real life use and the potential savings really reaped. - Carefully designing requirements on standby modes, so that no ‘modern standby’ unduly escapes Ecodesign limits, is a critical aspect. - Most of the power allowances (for graphic adders, tuners, additional memory storage, etc.) should also be revisited and substantially adjusted, since there are technological solutions to avoid the energy use from these adders when they are not in operation. - The current exemption of requirements for high-end PCs needs to be deleted, because it creates a too high risk of free ride for configurations that then become more and more mainstream. In particular, powerful gaming computers should be covered (as game consoles are), since the saving potentials are massive for these types of products. - Durability, reusability, and recyclability requirements are also of paramount importance. For mobile products, the share of the production and end of life phases is dominant in their ecological life-cycle. Hence the need to tackle these issues that become increasingly significant for consumers. 2/ An Energy Label for computers will be a very welcome addition. It is obvious that most (private and professional) consumers do not have a clear idea of the energy use from computers, and the difference between models and configurations on the market. Only an energy label can fil this gap. The Label can be based on a similar methodology/measurement than Ecodesign. From our analysis, there is sufficient differentiation on the market to allow for a scale of 7 energy classes for desktops, and possibly slightly less (e.g. 5) for laptops. The label can also be used to display durability information. 3/ We agree that tablets could be removed from the scope of energy efficiency requirements and labelling (as they are intrinsically low consuming), however we are fully opposed to exempting them from durability requirements. Issues of poorly performing and changeable batteries, lack of recyclability, and rapid obsolescence are fully relevant for tablets and should be tackled.
Read full response

Response to Review of ecodesign requirements for standby and off mode electric power consumption

22 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/f7YJpN We are in favour of Option 3 because Ecodesign & Energy Labelling requirements for standby and network standby help mitigate climate change and help EU citizens save on their bills. Our paper includes proposals on how to go further.
Read full response

Response to Review of energy labelling for household cold appliances

22 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/vtaonZ We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for domestic cold appliances help mitigate climate change and help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate these products in a Circular Economy, notably by introducing requirements on spare parts and recyclability. Our paper includes proposals on how to go further.
Read full response

Response to Review of ecodesign requirements for household cold appliances

22 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/vtaonZ We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for domestic cold appliances help mitigate climate change and help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate these products in a Circular Economy, notably by introducing requirements on spare parts and recyclability. Our paper includes proposals on how to go further.
Read full response

Response to Review of energy labelling requirements for lighting products

22 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/NSvjpG We are in favour of Option 5 because Ecodesign & Energy Labelling requirements for lighting help mitigate climate change and help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate lighting in a Circular Economy, notably by introducing requirements on the removability of light sources and control gears. In our paper, we have listed additional measures we think that the European Commission should be taking or maintaining to increase lighting lifetime.
Read full response

Response to Review of energy labelling for household dishwashers

22 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/baHJFq We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household dishwashers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the proposed reparability and recyclability requirements. Our paper includes proposals on how to go further.
Read full response

Response to Review of ecodesign requirements for household dishwashers

22 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/baHJFq We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household dishwashers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the proposed reparability and recyclability requirements. Our paper includes proposals on how to go further.
Read full response

Response to Regulatory measure on the review of energy labelling for household washing machines and washer-driers

22 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/7XeaF8 We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household washing machines and washer driers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the proposed reparability and recyclability requirements. Our paper includes proposals on how to go further.
Read full response

Response to Review of ecodesign requirements for household washing machines and washer-driers

21 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/7XeaF8 We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household washing machines and washer driers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the proposed reparability and recyclability requirements. Our paper includes proposals on how to go further.
Read full response

Response to Changes to greening rules and clarifications of certain other direct payments' rules

11 Jan 2017

Das Greening ist kein Förderprogramm für den Leguminosenanbau. Dass sollte über die 2. Säule geschehen. Als praktizierender Landwirt bin ich überzeugt, dass wir eine ökologische Infrastruktur in der Feldmark benötigen, die ohne Pestizide auskommen muss. Daher hat Kommissar Hogan recht, Pestizide auf auf ökologischen Vorrangflächen zu verbieten. Damit steigt auch die gesellschaftliche Akzeptanz für die GAP. Gesellschaftliches Geld nur für gesellschaftliche Leistungen. Jochen Dettmer, Agrarpolitischer Sprecher des Bund für Umwelt und Naturschutz Deutschland e.V. (BUND), Landwirt in Sachsen-Anhalt, Deutschland
Read full response

Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

7 Dec 2016

BUND e.V. welcomes the Commission’s proposal on the 3rd RDE package – as well as this public consultation – as a timely step in the right direction to tackle particulate emissions from Gasoline Direct Injection cars and strengthen the RDE test procedure. However, we are particularly concerned by two issues: - Firstly, the extension of RDE to measure PN emissions must be implemented without delay under the proposed timetable, i.e. 2017 for new types and 2018 for all new vehicles. Any slippage of either of these dates is unacceptable and would lead to delaying urgent investment needed to ensure the growing fleet of direct gasoline injection petrol cars meets the Euro 6 limit on the road. - Secondly, both the actual RDE test results and the maximum declared values for manufacturers must be made available in the public database in line with the Commission proposal. Any weakening of these important access to data provisions will seriously undermine RDE 3 and public information. There are orders of magnitude difference in emissions for vehicles fitted with gasoline particle filters and not, and drivers should be provided with this information. BUND e.V. considers the current draft text of the proposed 3rd RDE package to be the minimum acceptable to be effective. If there is any further weakening of the text during discussions in TCMV on the 20th December, BUND e.V. and many other stakeholders, including possibly the European Parliament; will have legitimate concerns as to the suitability of the new regulation and whether we should seek to have it rejected. There are several areas of potential improvements that should be made to the text, ideally now, or certainly before the 2nd step of RDE is introduced in 2020. These are: - Addressing ultra-fine particles (sub-23-nm) something the Commission recognises in recital 14. Further work is needed to extend measurement to these most dangerous to health emissions in order to include them by 2020 at the latest. - The approach used to account for higher cold-start emissions (point 27 in annex 2) should be replaced with a more accurate weighting process of their fair share in an average urban trip. Furthermore the possibility to use an up to 30s idling period between the engine start and the first movement of the vehicle (point 25 in annex 2) is a loophole to severely underestimate cold-start emissions of gasoline engines, and should be closed. - As regards regeneration events, BUND e.V. asks the TCMV to remove the possibility to use Engine Control Unit (ECU) data for detection of such evens to ensure RDE results cannot be manipulated by carmakers (point 19 of annex 2). The exhaust temperature should be used instead. We welcome recital 17 that allows updates of Ki factors to be closer to real-world situations, but the Commission should establish a public database with more realistic values from independent tests. - The conformity factors should be reviewed annually. BUND e.V. believes that the above changes will ensure that the on-road emissions tests are robust and accurately represent vehicles’ performance on the road.
Read full response

Response to Criteria to identify endocrine disruptors for biocidal products

27 Jul 2016

BUND (Bund für Umwelt und Naturschutz Deutschland e.V.)/Friends of the Earth Germany calls on the EU Commission to make significant changes to the proposed criteria for identifying endocrine disrupting chemicals (EDCs). The current proposal fails to address this pressing public health threat and fulfil the legal mandate to protect the health of humans, animals and the environment from exposure to these chemicals in our daily lives. The proposed criteria require such a high amount of evidence that it will be nearly impossible to identify more than a small number of substances posing a threat to human health & environment from hormone disruption. In contrast, current lists of potential EDCs include over 800 substances. Over 1300 scientific studies link exposure to EDCs to spiralling rates of hormone-related cancers such as breast or testicular cancer, fertility problems, diabetes, obesity & behavioural problems in children. The World Health Organization has called EDCs a ‘global threat’. The health costs of diseases associated with EDC exposure are estimated at 158 billion € yearly in the EU. The Commission has ignored the majority of respondents to its 2015 public consultation who supported the most effective use of science to protect humans and wildlife, especially vulnerable groups such as pregnant women, babies and children. In the 7th Environmental Action program, the EU committed to minimising EDCs exposure. To achieve this goal, the following major aspect needs to be changed: The Commission proposes to identify EDCs only if they are known to have adverse effects in humans or wildlife not intended to be affected. The word ‘known’ means to have proof. Demanding such proof weakens the current law which says to regulate those substances that ‘may’ cause harm (like for carcinogens that ‘may cause cancer’). Such a high burden of proof blocks expert opinion about the likelihood of an effect and is unacceptable, as it is likely to result in damage to humans and the environment before action is taken. This contradicts the precautionary approach enshrined in the EU Treaty and built into the biocide & pesticides laws. It also clashes with the current successful approach of identifying & ranking carcinogens and chemicals toxic to reproduction according to the level of evidence. Substances should be identified as EDCs when they are known or presumed to have adverse effects. Only this approach is consistent and coherent with the EU biocides law which says biocides should not be allowed on the market if they “are considered as having endocrine-disrupting properties that may cause adverse effects in humans”. The Commission should act on the existing scientific evidence and the best option for health is an approach with 3 categories (confirmed; suspected and potential EDC). The proposal must be rectified to ensure a high level of protection for health and the environment, preventing endocrine-related diseases for Europeans and averting damage from our ecosystems. France, Sweden and Denmark have already expressed their disagreement http://goo.gl/oU3QDS. The world’s leading experts on EDCs - the Endocrine Society https://goo.gl/MNE4c7 and other scientists http://goo.gl/u0LtIl have strongly criticised the proposal, as have certain industry sectors who believe the criteria should be stronger to identify and phase out potentially harmful materials http://goo.gl/pmYHkh. EDCs are a threat to our society’s current & future public health and prosperity. Europe should take a leading role in regulating EDCs, as this will stimulate innovation so that all industries in the various sectors develop and use better and safer alternatives. Our everyday exposure to these chemicals – in our food, cosmetics, homes, countryside, work places, schools, & hospitals, must stop to protect the health of current and future generations.
Read full response

Response to Criteria to identify endocrine disruptors for plant protection products

27 Jul 2016

BUND/Friends of the Earth Germany calls on the EU Commission to make significant changes to the proposed criteria for identifying endocrine disrupting chemicals (EDCs). The current proposal fails to address pressing public health threat and fulfil the legal mandate to protect the health of humans, animals and the environment from exposure to these chemicals. The proposed criteria requires such a high amount of evidence that it will be nearly impossible to identify more than a small number of substances posing a threat to human health & environment from hormone disruption. In contrast, current lists of potential EDCs include over 800 substances. Over 1300 scientific studies link exposure to EDCs to spiralling rates of hormone-related cancers such as breast or testicular cancer, fertility problems, diabetes, obesity & behavioural problems in children. The World Health Organization has called EDCs a ‘global threat’. The health costs of diseases associated with EDC exposure are estimated at 158 billion € yearly in the EU. The Commission has ignored the majority of respondents to its 2015 public consultation who supported the most effective use of science to protect humans and wildlife, especially vulnerable groups such as pregnant women, babies and children. In the 7th Environmental Action program, the EU committed to minimising EDCs exposure. To achieve this goal, 2 major aspects need to be changed: 1) The Commission proposes to identify EDCs only if they are known to have adverse effects in humans or wildlife not intended to be affected. The word ‘known’ means to have proof. Demanding such proof weakens the current law which says to regulate those substances that ‘may’ cause harm (like for carcinogens that ‘may cause cancer’). Such a high burden of proof blocks expert opinion about the likelihood of an effect and is unacceptable, as it is likely to result in damage to humans and the environment before action is taken. This contradicts the precautionary approach enshrined in the EU Treaty and built into the biocide & pesticides laws. It also clashes with the current successful approach of identifying & ranking carcinogens and chemicals toxic to reproduction. Substances should be identified as EDCs when they are known or presumed to have adverse effects. The Commission should act on the existing scientific knowledge and the best option for health is an approach with 3 categories according to the level of evidence. 2) The Commission proposes widening the current exemption for those pesticides identified as EDCs into a major loophole. Changing `negligible exposure’ to ‘negligible risk´ would allow continued uncontrolled exposure to these EDCs. This is unacceptable. The Commission has gone beyond their identification task, weakening the law by reintroducing specific risk assessments for pesticides identified as EDCs in the future The proposal must be rectified to ensure a high level of protection for health and the environment, preventing endocrine-related diseases for Europeans and averting damage from our ecosystems. France, Sweden and Denmark have already expressed their disagreement http://goo.gl/oU3QDS. The world’s leading experts on EDCs - the Endocrine Society https://goo.gl/MNE4c7 and other scientists http://goo.gl/u0LtIl have strongly criticised the proposal, as have certain industry sectors who believe the criteria should be stronger to identify and phase out potentially harmful materials http://goo.gl/pmYHkh. EDCs are a threat to our society’s current & future public health and prosperity. Europe should take a leading role in regulating EDCs, as this will stimulate innovation so that all industries in the various sectors develop and use better and safer alternatives. Our everyday exposure to these chemicals – in our food, cosmetics, homes, countryside, work places, schools, & hospitals, must stop to protect the health of current and future generations.
Read full response