electric Handdryer Association
eHA
electric Handdryer Association (eHA) is an association of international producers and distributors of electric hand dryers.
ID: 218079632487-85
Lobbying Activity
Response to Sustainable Products Initiative
14 Jun 2022
eHA’s Comments on the Sustainable Products Initiative – 13 June 2022
The electric Hand Dryers Association (eHA) highly welcomes the European Commission’s proposal for a Sustainable Products Policy Initiative (SPI). eHA is an international association comprising small and medium-sized electric hand dryer manufacturers, most of them European. The hand drying businesses in Europe are family-driven and comprise a mainly medium-sized industry with products that have fallen into the scope of the Ecodesign Directive and would therefore also be affected by the SPI.
Please have a look at the enclosed file.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
18 Nov 2021
EU energy efficiency directive (EED) – evaluation and review (Commission Adoption until 19 November 2021)
The members of the electric Handdryer Association (eHA) strongly support the EU’s goal to reduce EU greenhouse gas emissions by at least 55% by 2030, among other things by achieving higher energy efficiency. At the same time, each industry has challenges to overcome that need to be considered when forging the right mix of measures to achieve these goals. eHA has already commented on the European Commission’s impact assessment and seeks to re-emphasize that a significant increase in energy efficiency requires a holistic approach.
Lifecycle energy use to be considered
Specifically, sustainable reduction of energy efficiency needs to take different aspects of the energy use of the entire lifecycle of products into account. Most importantly, not only energy-using products, but also of those that may not require energy when in use, need to be taken into account: notably when they are prone to serve as substitute products for other market offers. The eHA is emphasizing this factor because its members face potential competitive disadvantages, if not actual commercial harm, due to a lack of such consideration under ecodesign measures that are derived from the current ecodesign directive. Our experience shows that the potential loss of sales due to new energy efficiency requirements will not be compensated with sales in dryers that meet higher energy efficiency levels, but part of these sales will be replaced by another drying system with a lower initial investment: Paper towel dispensers.
Hand dryers and paper towels are fully substitutable products. In the long term, hand dryers are cheaper, but the short-term investment is lower for paper towels. In the current economic situation, products that require minimal investment are more in demand. Paper towels may not be energy-consuming when in use for hand-drying, but they have a heavy ecologic footprint. The average paper towel generates 7.5gms/CO2 or 22.5 gms/CO2 per dry.
Life Cycle analysis shows that the effects of felling raw materials, transportation, manufacturing, packaging, storage on a constant loop, significantly produces a lot of CO2 into the atmosphere. One ton of virgin paper towels consumes 17 trees, 75,8 m3 of water are consumed and polluted. To reprocess this water, a lot of energy is needed. Furthermore, this ton of paper produces more than 3 tons of CO2 emissions, and requires 12 m2 of landfill space. In addition, paper towels are contaminated waste therefore they all have to end up in landfill. In the USA alone, 6,500,000 TONS of paper towels are sent to landfills each year. The decay of paper products and landfills in general produces methane gases which are 28 times more potent than carbon dioxide, therefore a real threat to global warming. They are also often put in plastic bags, creating further downstream problems in the recycling process.
The 2030 climate targets can only be reached when paying attention to the interest in keeping waste low and product lifecycles long. With the revised Energy Efficiency Directive, the European Commission should offer a toolbox that allows to take into account the environmental and energy footprint of substitute products, even if those do not belong to the energy-consuming products when in use.
Please read the full text (two pages) as attached document.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
20 Sept 2020
The electric Handdryer Association is an international, growing initiative of key hand dryer manufacturers from around the world, including European companies, most of which are family-owned and mid-size.
We, the members of the electric Handdryer Association acknowledge that climate change is a global challenge. We welcome the opportunity to comment on the Commission's roadmap to tackling the question of energy efficiency in this context. The European and global hand drying industry has a strategic interest in the decarbonisation efforts for 2050. We contribute to these goals by producing modern, innovative, and thus highly efficient electric hand dryers. These dryers save energy during their life cycles but also in comparison to other means of drying hands, such as the use of paper towels, which are produced by consuming a high volume of natural raw material and energy: One ton of virgin paper towels consumes 17 trees, uses 20,000 gallons and pollutes 7,000 gallons of water, produces more than 3 tons of CO2 emissions, and requires 40 square feet of landfill space.
Our products have long life cycles and limited replacement intervals – thus proving environmental friendliness, as waste is kept at a minimum. The 2030 climate targets can only be reached whilst paying attention to the interest in keeping waste low and product lifecycles long. The EU Commission`s intention to even increase the 2030 climate targets, resulting in the review of the legislation setting 2030 energy and climate related targets, thus seems very ambitious to us.
However, eHA encourages the EU making further progress for energy saving products in the markets. Hand dryers certainly contribute reaching this target. Any measures derived from the Energy Efficiency Directive (EED) must also take the potential effect on consumers into account, and the choices they make, e.g. for less environmentally-friendly but seemingly cheaper substitute products Changes to the current regulatory framework should also be looked at under the pandemic situation. Apart from the dire economic situation, lack of information leads to governmental advice that causes further economic harm without any scientific backing, whereas washing and drying hands properly is crucial especially during the corona pandemic.
Having stated this, eHA comes to the conclusion that there should not be change in the existing framework of the Energy Efficiency Directive on short notice and to possibly develop non-regulatory measures together with industry stakeholders. Any change in the existing framework would need to carefully assess potential consumer behaviour, effects on various industry sectors including niche sectors such as electric hand dryers, and consider the entire range of economic effects.
About eHA:
Companies supporting the alliance »electric Handdryer Association – eHA« are representing an efficient, sustainable and innovative market. Modern products in the air-based hand drying business are characterized by being environmentally friendly, efficient, and economically attractive. Together we make electric hand drying the leading system!
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