Quercus - Associação Nacional de Conservação da Natureza
Quercus
Quercus - ANCN (www.quercus.pt) was founded in 31st of October 1985 and it is a non profit, independent environmental non-governmental organization.
ID: 737714210149-06
Lobbying Activity
Response to Ecodesign and energy labelling working plan 2020-2024
1 Jun 2021
The ecodesign and energy labelling policies have enabled achieving a quarter of the EU’s emission reduction targets to date and nearly half of the EU’s 2020 energy savings. These policies have the potential to significantly contribute to the Green Deal, bringing important GHG emission reductions but only if they are used to their full capability and level of ambition. This is currently not the case: chronic delays are hampering the successful implementation of this policy, as highlighted by the European Court of Auditors in January 2020 and evidenced by the timing for the adoption of this Working Plan. The plan is supposed to cover the period 2020-2024 but it will probably not be adopted before the end of 2021, with a two-year delay. The measures included in the previous Working Plan (2016-2019) are also delayed, and not a single new implementing measure has been adopted since the Von der Leyen Commission took office 1.5 years ago. Such delays are unacceptable, the Commission should urgently prioritise this file within its services and dedicate adequate human resources to the development of product measures.
The climate and environmental emergency must mean that all potential energy, CO2 emission and material savings are reaped as early as possible. The prioritisation exercise between the introduction of new regulations and the reviews of existing regulation proposed in the roadmap is therefore not acceptable and not justifiable by the lack of resources within the Commission to correctly implement the policy. Timely revision of existing regulations is responsibility of the legislator, and so is to assess the adequacy of setting new legal requirements for other products in view of achieving the climate objectives the Commission has committed to.
The Working Plan should also clearly set out the timetable for each measure: the current lack of clear timing and prioritisation has led to a substantial accumulation of draft measures which have not been presented or concluded and have significantly stymied the achievement of product policy objectives to date.
Regarding the preparatory study for the Working Plan 2020-2024 in particular, we strongly recommend to only consider science-based and objective evidence in the selection process leading to the establishment of a shortlist. The proposed shortlist was developed ‘in a dialogue/in agreement with the European Commission’ (Task 4 report). While we understand the need for some pragmatism, political aspects should not be considered at this preparatory stage; we insist on the importance of transparency and objectivity being main drivers for the technical assessment of the product selection.
Looking at the savings potential and the expected development of certain products and technologies, we propose an alternative shortlist, keeping the majority of the products selected by the study team but introducing four crucial product groups that have been discarded despite their environmental relevance: base stations, electric vehicles chargers, universal batteries and heaters for outdoor spaces. Find the reasoning and full alternative shortlist proposal in the position paper attached.
Furthermore, we strongly believe that the Working Plan should foresee the development of horizontal material efficiency requirements for a broader set of energy-related products. This should lead to the introduction of repairability requirements for an enlarged set of household electrical appliances, by means of an overarching regulation similarly to the existing one on standby energy consumption – in line with the Commission’s ambition to progressively make sustainable products the norm and the forthcoming Sustainable Products Initiative.
Finally, 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 could be explored should it prove to facilitate the work of MSAs.
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