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International Network for Sustainable Energy - Europe

INFORSE-Europe

INFORSE - International Network for Sustainable Energy INFORSE-Europe lobbies to promote sustainable energy solutions - renewable energy and energy efficiency - which utilise decentralised approaches. All activities seek to protect the environment, and to achieve development. The members are NGOs working on grassroots level as well as on national, regional and international levels, all united on a common strategy for a long-term sustainable development with phasing out of nuclear and fossil energy use. The INFORSE network is facilitating practical and political exchange of experiences among NGOs, liaising with concerned multilateral agencies, creating political and public awareness, and seeking support for NGO activities.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

From International Network for Sustainable Energy, we welcome the opportunity to give our comments in advance of the EU Taxonomy on sustainable investments. We find that it is important to maintain the criteria for doing no significant harm, but we think the criteria has been wrongly interpreted in the case of nuclear energy and use of fossil gas. Regarding nuclear power, there is a significant harm: - If there is no safe disposal of nuclear waste during its radioactive lifetime (the time when it is more radioactive than natural materials), which for high-level nucelar waste is at least 100,000 years; - If the mining of the nuclear fuel leaves materials and effluents that are harmful to the environment; - If the risk of processing of nuclear fuel and waste as well as processing of spent fuel and other nuclear waste and of the operation of the nuclear power plants is higher than the risk associated with other forms of low carbon electricity production that are characterised as having no significant harm. We also find that the analysis used for climate effects of nuclear power with the inclusion of nuclear power in the taxonomy is insufficient. According to our understanding the evaluation used for inclusion of nuclear power in the taxonomy underestimates the front end of the nuclear energy life cycle, not considering the fact that the concentration of Uranium in the ore is tending to decrease in existing deposits and so-called reprocessing of U and Pu is an exception not a rule. Only a small part of nuclear fuel is derived from reprocessing and the assumption of reprocessing is misleading as most EU countries are not doing it. The way spills and emissions of radionuclides, accidental or routine are not properly treated in the assessment. The assessment takes handling of materials and operation as 100% safe because all the filters are onsite and everything is working as an ideal system. In real life a lot of contamination is due to spills and excursions as at the front-end stage (Uranium mining), as well as the back end (nuclear waste storages and deposits), as well as production stages of nuclear power lifecycle. Regarding fossil gas, its use gives greenhouse gases which to a much higher extent than the alternatives in the form of renewable energy. With the current development with more fracking and LNG transport, fossil gas is increasingly a source a greenhouse gas emissions and fossil gas technologies should not be included in the taxonomy for climate reasons, We urge the European Commission to include the above changes in the taxonomy as part of the revision.
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Response to Future development and deployment of Small Modular Reactors (SMRs) in Europe

4 Dec 2025

Comments from International Network for Sustainable Energy (INFORSE)-Europe regarding the deployment of Small Modular Reactors (SMRs) Introduction of SMRs and the possible decentralisation of nuclear power that comes with them raise legitimate concerns regarding risk of accidents, not least in the perspective of previous nuclear disasters (e.g., Chernobyl, Fukushima), and radiation leaks from nuclear operations and transport. The concerns are aggravated by the uncertainties, whether SMRs because of their new and experimental technology are less safe than conventional nuclear reactors, and if they are to be placed closer to population centres and infrastructure than existing nuclear reactors. INFORSE-Europe also has concerns regarding the liability issue, where existing European nuclear power plants are already inadequately insured against serious accidents. A full liability up to full costs of possible accidents should be a requirement for nuclear reactors, also for SMRs. Considering that the new Energy Commission has been tasked with support for the acceleration of the development and deployment of SMRs in Europe, but also to continue ensuring nuclear safety and safeguards, we support an immediate an update and improvement of EUs nuclear liability regime, including a new European-wide nuclear risk assessment with a detailed study of the strengths and weaknesses of the liability regimes in the EU Member States, including insurance conditions. This must result in a liability regime towards a full European liability scheme under the Euratom Treaty. Good practice can be taken from German and Austrian legislation, where nuclear operators are not exempted from liability because of war or natural disasters. Ref. Ares(2025)10584861 - 02/12/2025 The review of SMRs must also deal with radioactive waste management, including how the special radioactive waste from SMRs will be stored, transported, and disposed of. No SMR should be allowed to operate unless there is a legally binding plan in place for the final disposal of its waste, i.e., how and where, and how all related costs are covered. Questions must also be raised whether SMRs are cost-effective compared to renewable energy sources like wind power and photovoltaics. Initial investments and cost increase as seen with recent nuclear power projects may lead to increased electricity prices for the consumers. The level of government subsidies needed for SMRs must be part of the review. Subsidies should be limited to avoid unnecessary costs for electricity consumers and/or tax payers. A review must also include assessing the environmental effects of SMRs with land use including safety and evacuation zones, water use, possible thermal pollution affecting local ecosystems including aquatic ecosystems, as well as carbon emissions from construction and fuel transportation and storage. Transparency and public involvement must be guaranteed in national legislation regarding SMR development, including informed consent. Information must also include information on risks and environmental effects. INFORSE-Europe is concerned that eventual relaxed regulations to promote SMRs can compromise safety. We do not support that requirements for SMRs are relaxed compared with existing nuclear power plants, also if a legal European framework specifically for SMRs is to be established. Also rights of neighbours and for civil society must not be lower for SMRs than for other nuclear power plants. A review of SMRs must also consider their reliability and their potential for energy independence compared to renewable energies, including that reliance on nuclear energy can make the energy system vulnerable to geopolitical tensions, both regarding the fuel and uranium supply and the risk of SMRs becoming targets of cyberattacks and/or terrorism.
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Response to Nuclear Illustrative Programme

12 May 2025

Comments and Proposals from International Network for Sustainable Energy Europe to EU nuclear illustrative program (PINC) 2025. International Network for Sustainable Energy Europe (INFORSE-Europe) is a network of 60 independent organisations working for the transitions to a world based on sustainable energy. We find that the PINC must change from a one-technology evaluation of nuclear energy technologies to evaluate nuclear energy technologies in a system perspective and in the context of the challenges that Europe and the world faces. This must include climate change and the need for a fast and affordable phase out of fossil fuels, security of supply with independence from problematic suppliers of all forms of energy, the current security problems that Europe faces, as well as the need for long-term sustainable solutions. The PINC2025 must take an open view of future developments with scenarios with different levels of use of nuclear technologies. Within the AR6 of the IPCC (2022), a growing number of scenario studies show that the Paris goals can be met while phasing out nuclear energy. The reason is that the scenarios increasingly are based on the reality on the ground where nuclear energy delivers too little, too late, against a too high cost and risk, to be relevant for effective and fast climate action. We need an energy transition towards zero- and low-carbon solutions that can deliver fast, scale up fast, are as low-cost as possible, and do not increase other environmental or safety risks. It is important that PINC 2025 remains realistic in its capacity development assumptions. A realistic estimate of net added/closed capacity until 2040 shows that realistic new built in EU will be around 5.5 GW while closures will be around 60-80 GW. This should be included in the PINC 2025. If PINC 2025 is based on growth expectations of EU nuclear power, it is very likely to contribute to political distractions towards nuclear that will delay and hinder alternative and effective climate action, leaving behind political disappointment as well as large decarbonisation holes to be filled, just before the 100% decarbonisation goals of the electricity sector are to be met in 2040 - 2050. The call for evidence for PINC 2025 claims there are market failures in the deployment of nuclear energy projects. It is important to stress it is not a market failures that there is a lack of private investment capital when realistic, risk-adjusted return on investments expectations do not favour investments in nuclear power. Progress of finding solutions to the problem of radioactive waste is slowing down and is becoming increasingly costly. The problems with radioactive waste should be reported and discussed in the PINC2025. For new projects, incl. SMR projects, regulation should be worked out that obliges waste management to be solved before operation of new waste producing activities are allowed. Also this should be included in the PINC 2025. It is high time to have a debate of the nuclear liability regime, aiming at an EU-wide homogeneous system for nuclear liability with unlimited liabilities and a financial security limit that is realistic in relation to actual need for cash flow in the aftermath of a nuclear accident. This needs to be in place before plans for new nuclear capacity are put into operation. Finally, we find that the proposed process for producing PINC 2025 is too fast. Important is that the European Commission, the national governments, the corporate world and indeed all citizens of the European Union receive a realistic update about the position of nuclear energy in the total framework of the energy transition. This needs more time than is suggested in the call for evidence. In the attached file, see more details and further issues we propose to cover in the PINC2025. For documentation behind the findings and proposals, contact INFORSE-Europe, see www.inforse.org/europe
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

On behalf of International Network for Sustainable Energy – Europe, I would like to thank the European Commission for the important work of formulating guidelines, a taxonomy, for investments compatible with climate and environmental targets, including the Paris Agreement. We are concerned that some are proposing to allow nuclear power to be included as an option for financing in this taxonomy. Nuclear new-build represents a high-risk technical, regulatory and investment option, with a marked tendency for significant delay and cost over-run. The slow implementation of nuclear energy into the power system and limited scalability over the short-term in comparison with renewable energy options significantly questions the effectiveness of further investments in new nuclear. Nuclear power is vulnerable to unforeseen natural disasters or through human or engineering-based fault conditions, including accidental or deliberate harm. Accidents by nature or accidental can cause radiologically catastrophic. Whatever one’s view of the risks and benefits of nuclear, it is clear that the possibility of catastrophic accidents or incidents, and consequent economic liability, must be factored into energy policy decision-making. When considering the entire nuclear life-cycle (including mining, transport, enrichment, plant construction, operation, dismantling, and waste management), nuclear is significantly more carbon intensive than renewable options such as windpower. In addition, the production of radioactive waste, including the unresolved issue of nuclear waste management, places nuclear technology counter to the key ‘Do No Significant Harm’ (DNSH) principle. This is because, despite 70 years of operation and research, the nuclear industry has yet to provide proven and sustainable methods of management that neither increases radioactive waste volumes nor decreases the potential risk to the environment. In conclusion, we are convinced that nuclear power is not included as a viable solution in the taxonomy for investments. On behalf of International Network for Sustainable Energy – Europe, EU Transparency register no. 776468828438-74 Gunnar Boye Olesen Coordinator
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Response to Ecodesign requirements for external power supplies

13 Nov 2018

INFORSE-Europe, Europåean network for NGOs supporting sustainable energy, supports 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 and waste electricity. 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 further think that the European institutions should play an active role in promoting the inter-operability 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.
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Response to Review of energy labelling for household dishwashers

13 Nov 2018

INFORSE-Europe, European network for NGOs promoting sustainable energy, would like to support the draft Energy Labelling regulation proposed by the European Commission but call on the European institutions to reinforce several of the provisions in the proposal. 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. We are concerned about the lack of ambition put forward on the energy efficiency aspects: 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 programs or a combination of programs and functions, selected on the basis of consumer habits, instead of continuing using the eco program for the labelling purposes as proposed.
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Response to Review of ecodesign requirements for household cold appliances

13 Nov 2018

INFORSE-Europe, European network of NGOs supporting sustainable energy, would like to support the draft Ecodesign regulation proposed by the European Commission. We also propose below amendments to the proposal. 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. - 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%. - 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.
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Response to Review of energy labelling for household cold appliances

13 Nov 2018

INFORSE-Europe, European network of NGOs promoting sustainable energy, would like to support the draft Energy Labelling regulation proposed by the European Commission. We also propose amendments to improve the proposal.. 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. - Fine-tune 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.
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Response to Review of ecodesign requirements for household dishwashers

12 Nov 2018

From INFORSE-Europe, European network for civil society organisations promoting sustainab energy, we would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission, but we also 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 energy efficiency within 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 proposed Tier 2 is set at a very unambitious level. Tier 2 deviates from the least life cycle cost principle of the Ecodesign Directive, and should not 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). 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 time frame of 15 working days should be further reduced to avoid this time-lapse to become a reason for consumers to replace their product. In addition, 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.  
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Response to Review of ecodesign requirements for lighting products

9 Nov 2018

We would like to support the draft Ecodesign regulation 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. 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.
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Response to Energy labelling for electronic displays

7 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 these 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. 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. The user should have right to refuse an update. Furthermore, 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.
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Response to Ecodesign requirements for electronic displays and televisions

7 Nov 2018

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 the 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, remove exemptions 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. Moreover, 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. 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. The user should have right to refuse an update. Furthermore, 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, for the European institutions to
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Response to Review of energy labelling requirements for lighting products

6 Nov 2018

From INFORSE-Europe, we would like to support the draft 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.
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