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CLASP

CLASP improves the energy and environmental performance of the appliances & equipment we use every day, accelerating our transition to a more sustainable world.

Lobbying Activity

Meeting with Robert Nuij (Head of Unit Energy)

13 Oct 2025 · Exchange of views on ecodesign and energy labelling policies

Response to Verification of suppliers and other operational aspects for the functioning of product database - EPREL

21 Nov 2023

CLASP welcomes the opportunity to provide comments for the labelling of energy related products (ErP) - Operational details for the functioning of EPREL and the product database. We have two comments to make that are related with each other. In page 4, paragraph (21): "Dealers are required to visibly display, including for online distance selling, the label provided by the supplier and to make product information sheets available to customers" we would delete "provided by the supplier". We think that retailers should be able to retrieve the label directly from EPREL if they wish to. In paragraph (22): "Article 5 of Regulation (EU) 2017/1369 requires dealers to visibly display, including for online distance selling, the supplier's label." Related to the previous comment, here we would delete "supplier's" so that dealers can display, if they want, the label retrieved from the EPREL website.
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Response to Energy labelling requirements for electronic displays

21 Sept 2023

CLASP welcomes the European Commissions initiative to review the ecodesign and energy labelling regulation for electronic displays, and we are thankful for the opportunity to offer feedback. We agree that the main aspects listed in the consultation document all deserve attention. We look forward to contributing on many aspects such as the balance of stringency between larger and smaller products, the separate energy categories for standard dynamic range and high dynamic range, or the update of the test procedure. Regarding allowances: - We would be wary of an allowance regime for additional functions in low power mode (smart wake, fast start etc.). The European regulation did not grant allowances for fast start from standby and the European televisions quickly met user expectations of start-up time within the standby allowance of 0.5W. We expect the same to apply to smart wake if allowances are avoided; - We understand that most manufacturers have been unwilling to invest in developing ABC features that would qualify for the 10 % allowance included in the current regulations. This is likely one of the reasons why new models stagnated in the lower efficiency classes. While we still believe that an ABC feature has to be well controlled to effectively be used by the viewers (rather than disabled) and deliver energy savings savings, we suggest that re-assessing the potential savings linked to this feature may justify a higher allowance, which in turn may encourage manufacturers to improve those features. Concerning the development of appropriate notification methods for energy consumption: it seems technically and economically viable to incorporate energy monitoring and on screen / wi-fi notified data as a feature on mid to high-end electronic displays. The volume production would then make this innovation trickle down to low end products. This may be an option to explore as this small addition seems likely to have positive impacts. We would like to suggest a few other points that we believe the review should consider: - We are aware of dramatic trend to increase the default brightness in the pre-set viewing modes in recent models. We strongly recommend that the European Commission and stakeholders should reflect on how this unnecessary trend can be contained. - The new viewing habits should be investigated: as the average time spent on screens increased over the past few years and watching scheduled broadcasting declined in favour of on demand streaming, we need to better understand the impact of those changes on the energy consumption linked to electronic displays. We look forward to collaborating with the European Commission and their consultants for the review of the regulations of electronic displays and remain at your disposal should you have any questions or comments on the above.
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Response to Mercury – review of EU law

8 Sept 2023

CLASP thanks the European Commission for the opportunity to comment on the review of the EU law on Mercury. The EU has led the global transition to efficient and mercury-free lighting in recent years by phasing-out general-purpose fluorescent lighting across Europe in 2023, and supported by the regions extensive LED manufacturing sector. The current proposal, which is meant to harmonize existing mercury-related regulations, falls short of its mandate to protect people and the planet from mercury pollution, by setting a 2027 phase out date for the manufacture for export of select fluorescent lamps. This proposal would allow fluorescent manufacturers to continue producing obsolete, toxic triband phosphor linear and non-linear lamps for export to less regulated economies for over 4 more years. Given the EU political commitments on chemicals and climate, the mercury content in potentially exported lamps, the global momentum on policy actions to phase-out fluorescents, and the opportunity to grow clean EU jobs by investing in LEDs, the EU should as soon as possible move towards banning the exports of all (mercury-containing) lamps which are banned in the EU market. Please find CLASP comments in the attachment.
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Response to Ecodesign requirements for cooking appliances (review)

26 May 2023

To DG Ener: Thank you for the opportunity to provide comments to the review of Ecodesign and Energy Labelling requirements for cooking appliances. Please find CLASP, CECU, Kyoto Club and Respire's comments attached.
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Response to Environmental impact of mobile phones and tablets - Ecodesign

28 Sept 2022

CLASP welcomes the European Commission’s initiative to establish ecodesign and energy labelling measures for mobile phones and tablets. We largely support the proposed drafts and are thankful for the opportunity to provide feedback on those drafts and for some of the recent evolutions that are in line with our previous comments. We would however like to insist on some points and provide a few suggestions concerning the draft regulations. Energy Labelling: We welcome the choice of the European Commission to integrate the repairability class on the label, along with more information on the durability of the model. We also support the transparency provided by the integration of the detailed information on the product rating in the product information sheet. We are however concerned that the current version of the Commission’s proposed repairability rating still excludes the consideration of the price of spare parts. While we understand that this is a complex issue, the impact of this parameter on consumer’s decision is too significant to ignore. As already mentioned, examples already exist of labels that do take into account the price of spare parts. The French repairability index, which cover this parameter, puts extremely valuable resources and experience at the disposal of the Commission. ADEME’s July 2021 Preparatory study for the introduction of a durability index also mentions the label Longtime as another example of criteria that include the price of spare parts (this label even includes the price of conveyance of spare parts). We strongly recommend that the Commission considers ways to integrate the price of spare parts into the reparability score. The mandatory publication on free access websites of the maximum pre-tax price of spare parts, as proposed in the draft ecodesign regulation, should facilitate the integration of this information into the repair score. Ecodesign: We are concerned that limiting the mandatory access to some of the information and spare parts to professional repairers represents a missed opportunity to significantly facilitate the repair by end users, including in repair cafés. Where only professional repairers can access critical information, end-users face unnecessary additional costs and barriers, in particular in remote areas where professional repairers may be less accessible. An intermediary step could be to make repair information and spare parts (the full list in 1.1 (1) a)) available to end-users only 18 months after the model is put onthe EU market for the first time. Repair and maintenance information not freely accessible means that 1) the fee to be defined by manufacturers may discourage consumers from repairing their phones and 2) organisations that used to make repair information accessible to all may no longer be able to share that information for copyright reasons, making the situation less favourable to repair by independent repairers and end users than it currently is. Similarly, allowing manufacturers, importers or authorised representatives to charge “reasonable and proportionate fees” for access to the repair and maintenance information is problematic in that is creates additional costs for the repairers and ultimately for the end-user, and could represent a deterioration compared to the current situation by increasing intellectual property rights issues for third parties that may publish the repair and maintenance information on freely accessible websites. The criteria suggested in the draft regulation to define whether a fee is reasonable is not precise and objective enough to be applied, and would be dependent on the brand, model (popularity and sales volumes), location of the repair store etc. It could create equity issues between remote areas and densely populated areas. We strongly recommend the deletion of such fees.
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Response to Energy labelling requirements for space and combination heaters (review/rescaling)

31 Mar 2022

We are thankful for the opportunity to comment in view of the launch pf the Impact Assessment Study for the revision of the ecodesign and energy labelling regulations for space and combination heaters. Concerning the proposed scenario for the ecodesign regulation, we are concerned that the proposed efficiency levels are not aligned with the climate target of the EU. We find that the climate mitigation scenarios as well as the interest of European citizens cannot be well served by the proposed levels and we recommend that the minimum requirement for seasonal heating energy efficiency should be set at 110% for all technologies to rapidly shift the market towards efficient decarbonised heating as of 2025. We welcome and support the revision of the energy labelling regulation and applaud the effort made to base crucial aspects of the proposal on consumer research. We recommend that the scale should be adjusted to align with minimum requirement for seasonal heating energy efficiency of 110%, which may allow sufficient granularity in the highest classes to fit low temperature regime on the same scale as medium temperature regime. Moreover, we recommend that the promotion of “hydrogen readiness” on the label should be abandoned, and that the shift to the new label should take place as soon as possible. Detailed comments are provided in the attached document.
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Response to Review of ecodesign requirements for standby and off mode electric power consumption

4 Feb 2022

Thank you for the opportunity to provide comments on the ecodesign requirements for standby and off mode electric power consumption. We welcome the revision of this regulation and would like to provide some comments and suggestions for your consideration. Please find attached our detailed comments on the following topics: 1. The need for consistency in the power allowance of non-HiNa equipment and equal power allowance for normal standby and non-HiNa networked standby. 2. A clarification of the inclusion of equipment functioning as static and/or permanent installations and that can be powered both by the mains or by a battery, to avoid a loophole in the regulation. 3. A proposed revision of the wording of the definition of equipment covered under this regulation. 4. Finally, we highlight the importance of mesh-WiFi-connected products and suggest that the European Commission should consider their coverage under the standby regulation. We remain at your disposal should you have any questions on this contribution.
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Response to Electrical equipment – Revoking exemptions for mercury in single capped (compact) fluorescent lamps for general purposes

21 Jul 2021

Please see the attached file with our comments. Thank you and kind regards.
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Response to RoHS deleting exemptions for mercury in double-capped linear fluorescent lamps for general lighting purposes

16 Jul 2021

Please see the attached file with our comments. Thank you and kind regards, CLASP Europe
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Response to RoHS exemption 6

16 Jul 2021

Please see the attached letter which provides our comments on this product group. Thank you and kind regards, CLASP Europe
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Response to RoHS exemption for the use of mercury in other discharge lamps for special purposes

12 Jul 2021

CLASP fully supports the comments submitted by the EEB on this product group. The global markets for UV LED technology are growing very rapidly and consequently the Exemption should be re-evaluated in three years, rather than granting a five-year exemption with no expiry date. As noted in one market report cited by EEB, “Amid the COVID-19 crisis, the global market for UV LED Technology estimated at US$378.6 Million in the year 2020 is projected to reach a revised size of US$3 Billion by 2027. We have all witnessed the amazing innovation and rapid improvement in LED technology that has occurred over the last 3 years. The Commission is better-off not tying its hands with a five-year extension on any of the mercury-lighting product categories, because LED alternatives are already on the market and will continue to expand their market share over the coming few years. Thank you.
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Response to RoHS exemption for mercury in metal halide lamps

12 Jul 2021

CLASP fully supports the position of the EEB for mercury in metal halide lamps. More specifically, we also recommend that the exemption for Quartz Metal Halide (MH) lamps be discontinued, with a 12 month transition period. Exemptions for Ceramic Metal Halide Lamps up to and including 250 Watts as well as all metal halides over 250 watts, can be allowed to be reviewed in 3 years. When we look back at the incredible innovation and improvement in LED technology over the last three years, we do not feel any 5 year extensions are justified - all exemptions that are sustained should be limited to 3 years, with the RoHS Expert Group continuing to monitor improved availability, performance and price of LED retrofit lamps for metal halide lamps and consider an expiry date as soon as possible. Thank you.
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Response to RoHS exemption for mercury in other high pressure sodium lamps for general lighting purposes

12 Jul 2021

CLASP fully supports the recommendations of the EEB, namely discontinuing the exemption for HPS models up to 400 Watts with a phase-out period of 12 months. For models over 400 watts, the exemption should be reviewed in 3 years or less. Since LEDs (and mercury-free HPS lamps) are widely available now that can replace high-pressure sodium lamps (up to 400 watts) as well as other low-wattage HIDs such as metal halides, we urge the European Commission to consider these findings and work to develop an expiry date for this category of mercury-containing lamps. Thank you.
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Response to RoHS exemption for mercury in non-linear tri-band phosphor lamps

12 Jul 2021

Our feedback consists of two parts: 1) The attached PDF letter which we have uploaded 2) An Excel database of mercury-free LED products that are designed and marketed as direct, drop-in replacements for fluorescent U-bend lamps. Please click on this link to access the file: https://cleanlightingcoalition.org/wp-content/uploads/sites/96/Database-of-LED-U-bend-retrofit-tubular-lamps.xlsx Thank you.
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Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

In addition to the ECOS-EEB-Coolproducts-CLASP position paper submitted in April to the team in charge of the Preparatory study for the Ecodesign and Energy Labelling Working Plan 2020-2024 (attached), we would like to add some further comments and recommendations for the next steps of the adoption and implementation of the 2020-2024 Ecodesign and Energy Labelling Working Plan. Concerning the small network equipment for home and office use, we would like to point the Commission to the IEA’s Total Energy Model for Connected Devices (https://www.iea-4e.org/edna/tem/), which can be useful in that it gives a good overview of the upstream energy consumption associated to those devices. A lot remains to be done at the level of the small equipment in home and offices and their interactions with the servers. We therefore particularly welcome the proposed integration of this group into the 2020-2024 Working Plan. It is unclear whether wall-mounted USB sockets would be part of the universal external power supply group. We recommend to explicitly include them, since initial evidence shows that the number of installed units increases rapidly. They become built-in consumption for the homes and offices that they are integrated in. Electric vehicle chargers were disregarded because it was deemed too early to establish measures. As noted in previous comments, we suggest that early action would be more efficient than postponement to influence the design of these chargers to avoid the deployment of inefficient infrastructure and future lock-in effect. The diversity of systems may be a challenge but it seems feasible to set rules that would influence their development without blocking innovation, such as limiting the loss between the primary source of power and the battery. We suggest that the Working Plan should aim at reinforcing market surveillance to ensure the forecasted savings are achieved. The possibility to extend the use of the EPREL database to products without an energy label should be explored should it prove to facilitate the work of MSAs. Another potential benefit of integrating all products covered by ecodesign to EPREL is that it could facilitate the European Commission to detect when a regulation should be revised and rapidly set new requirements at the appropriate level. Lastly, we want to recognize and strongly support the ambition of the initiative as presented in the roadmap. The efficiency and importance of ecodesign and labelling in reducing the European carbon emissions is well established – and recognised in the EU Green Deal and the new Circular Economy Action Plan. Those EU product policies also have an impact beyond Europe, as they are often referenced in international benchmarks and can be a useful inspiration for policy makers in other economies. We are concerned that despite the importance and abundance of the work to be done, this os not reflected in the allocation of resources and the ecodesign team of the European Commission seems to be significantly under-resourced to cover such a broadening scope. We therefore strongly suggest that the ecodesign team should be strengthened in order to avoid further delays, while being able to cover in parallel the revisions of existing measure and the expansion of the scope both to new product groups and to new aspects – while strengthening market surveillance, as noted in the roadmap.
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Response to Energy labelling omnibus amendment of 2019 regulations

3 Nov 2020

CLASP is thankful for the opportunity to provide comments on this draft omnibus Amendment for the energy labelling measures. We have prepared a few comments expressed in the attached PDF which offer suggestions for areas where revisions to this Amendment may be considered for the following three product groups: - Light sources; - Refrigerating appliances; - Refrigerating appliances with a direct sales function. We remain available for any follow-up questions. Best regards
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Response to Ecodesign omnibus amendment of 2019 regulations

3 Nov 2020

CLASP is thankful for the opportunity to provide comments on this draft omnibus Amendment for the ecodesign measures. We have prepared a few comments expressed in the attached PDF which offer suggestions for areas where revisions to this Amendment may be considered for the following three product groups: - Light sources - Refrigerating appliances - Refrigerating appliances with a direct sales function. We remain available for any follow-up questions. Best regards
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Response to Review of energy labelling for household cold appliances

13 Nov 2018

Thank you for the opportunity to provide comments on the draft energy labelling regulation for household refrigerating appliances. Overall, CLASP wishes to express our support for the Commission’s proposal. We however would like to offer here a few suggestions for areas where we suggest revisions may be considered. 1 Delay to the implementation CLASP does not support the decision to delay the entry into force of the energy labelling regulation from 2020, as it was originally proposed, to 2021. Everything should be done to respect the Energy Labelling Regulation 2017/1369, which foresees that new labels are displayed in shops by end 2019. We therefore call for the first tier to be enforced as early as possible, but no later than early 2020. 2 Impact of the new test standard and ambition of the requirements Our analysis of Australian data indeed showed that the proposed requirements on bottom mounted frost-free refrigerator-freezers would be 15% less ambitious than they appear to be, because of the change in volume measurement method alone. This could cause the top classes to be populated early after the application of the new label, especially with an implementation date in 2021 and a situation in which the energy label would need to be rescaled earlier than anticipated. We therefore urge the Commission to review the proposed thresholds at the earliest opportunity with product performance data measured according to the new test standards. 3 Reviewing measurement tolerances We recommend that the revision clause should explicitly mention the assessment of the appropriateness of smaller tolerances. 4 Absence of indicators of performance in dynamic state We strongly recommend to follow the spirit of the preamble of the framework regulation for Energy Labelling and the same logic as Australia and China by adding an information requirement or a performance requirement that would reflect the load processing efficiency as described in IEC 62552:2015 and introduce dynamic conditions in the way refrigerator performance in tested in Europe without affecting the reproducibility and repeatability of the energy consumption test. We believe that it is important for the credibility of the European product policy to attempt to not completely overlook important aspects of the normal operation of the regulated equipment. Our tests showed that such a measurement could shed light on significant discrepancies between the performance of some appliances in steady state vs. dynamic state. 5 Correction factors – still too many and too high We regret that, despite the simplification of the regulation through abandoning product categorisation, the formula for energy efficiency index remains complex and includes many correction factors. The call from many stakeholders for starting without grey classes from the beginning (meaning changing the F and G boundaries) should be considered and could be achieved by removing the correction factor for built-in appliances. 6 Limited provisions on resource efficiency The 2015 EU action plan for the Circular Economy (COM(2015) 614) identifies ecodesign and energy labelling as crucial policy tools to facilitate the transition towards a sustainable economy: The Commission will specifically consider proportionate requirements on durability and the availability of repair information and spare parts in its work on Ecodesign, as well as durability information in future Energy Labelling measures. We regret that no icons that could help consumers buy more durable, reparable products have been envisaged. 7 Scope of coverage - exclusion of mobile appliances Mobile refrigeration appliances are not excluded from the current regulation and we do not support their exclusion from the revised regulation. We are concerned that their exclusion might create a loophole and recommend removing them from the list of exclusions. Please find attached the extended version of our comments.
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Response to Review of ecodesign requirements for household cold appliances

13 Nov 2018

Thank you for the opportunity to provide comments on the draft ecodesign regulation for refrigerating appliances. Overall, CLASP wishes to express our support for the Commission’s draft ecodesign regulation for household refrigerating appliances. A. Key provisions which CLASP supports in this draft regulation: A.1 Extension of the scope to wine storage appliances – we support the inclusion of wine storage appliances with and without glass doors. A.2 Reduction of the correction factors – CLASP supports the decision of the Commission to remove or lower some of the correction factors used in the current regulation. A.3 Switch from the categories towards an approach based on compartments – CLASP supports this shift toward an approach that is more realistic and representative of functionality. B. Key provisions where CLASP has concerns for this Delegated Act: B.1 Delay to the implementation of requirements CLASP does not support the decision to delay the entry into force of the ecodesign regulation from 2020, as it was originally proposed, to 2021. Article 7 of Regulation 643/2009 requires a review “no later than five years after its entry into force”, i.e. August 2014. A swift revision and adoption of a new regulation could have led to revised requirements entering into force in late 2017. Energy efficiency requirements for domestic refrigeration in Europe have not evolved since July 2013. While we understand that manufacturers may need more time to bring redesigned products to the market, the proposed requirements are based primarily on 2015 data, without taking into account the potential impact of a redesign. We therefore call for the first tier to be enforced as early as possible, but no later than early 2020. B.2 Impact of the new test standard and ambition of the requirements We are concerned that the influence of the new test standard on the volume declaration has not been sufficiently analysed and may impact the declared efficiency for some types of appliances. Our analysis of Australian data indeed showed that the proposed requirements on bottom mounted frost-free refrigerator-freezers would be 15% less ambitious than they appear to be, because of the change in volume measurement method alone. B.4 Absence of indicators of performance in dynamic state We strongly recommend the addition of a test outside of the steady state conditions used for the measurement of energy consumption. Such a test could be useful as one of the tools for the detection of circumvention. More specifically, we regret that the proposed draft does not include the declaration of load processing efficiency in the information requirements. It is part of the 2015 IEC standard and other economies include this parameter in the declaration of performance. We believe that it is important for the credibility of the European product policy to attempt to not completely overlook important aspects of the normal operation of the regulated equipment. Our tests showed that such a measurement could shed light on significant discrepancies between the performance of some appliances in steady state vs. dynamic state. B.5 Correction factors – still too many and too high We regret that the formula for energy efficiency index remains complex and includes many correction factors. Based on our tests we strongly recommend that the frost-free correction factor should not exceed 5%. We also strongly recommend that the ‘built-in factor’ should be removed, especially if the definition allows for appliances “equipped with an integral factory-finished face” to be considered as built-in. B.6 Limited provisions on resource efficiency We support requirements looking at facilitating the repair and recycling of refrigerators However, the proposal under consideration is very limited compared to what is proposed for dishwashers and washing machines, and we recommend aligning refrigerators with these other household appliances.
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Response to Review of ecodesign requirements for lighting products

9 Nov 2018

Please see the attached file with our comments on the draft ecodesign requirements for lighting products. Thank you.
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Response to Review of energy labelling requirements for lighting products

6 Nov 2018

Dear DG ENER - please see attached comment from CLASP Europe in the attached PDF file. Thank you.
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