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Topten International Group

TIG

Mission Topten is a consumer-oriented online search tool, which presents the best appliances in various product categories. The key criteria are energy efficiency, impact on the environment, health and quality. As a communication tool it helps to show how our energy consumption causes climate change and what we can do to reduce our impact. It is also a powerful instrument to influence manufacturers. Topten was launched in 2000 in Switzerland. Since then, 14 additional European national Topten sites have been established, thanks to the European IEE-projects Euro-Topten, Euro-Topten Plus, Euro-Topten Max and the Horizon 2020 projects Topten ACT, ProCold and HACKS. Each Topten website provides a selection of best appliances from the energy efficiency point of view. More information can be found on the Euro-Topten Max-Report. Topten information targets consumers (pictures, functions, price, no complex calculation, for products available locally in their country) and large (...)

Lobbying Activity

Response to Review of the energy labelling for professional refrigerators

31 Mar 2025

Topten International supports including Scientific and Healthcare refrigeration products in ecodesign and energy labeling regulations. We also welcome stricter Minimum Energy Performance Standards (MEPS) to reflect recent market advancements. The full feedback is available in the attached PDF.
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Response to Energy labelling requirements for local space heaters (review)

1 Sept 2022

Topten welcomes the merging of regulations for room appliances with the same function into one energy label and the corresponding widening of the scope to include electric joule room heaters and comfort fans. Especially in the context of a challenged economy, the market cannot afford to misdirect consumers who often believe that class A models even of different room heating technologies are similarly efficient; true efficiency – and long-term cost savings – should be clearly reflected by a higher class rating. Inefficient technologies, on the other hand, should be clearly identifiable by low energy class ratings through the merged label. Incentivize innovation through setting stringent class thresholds: Current benchmarks show that the energy class thresholds as they are proposed in the Working Document need to be tightened in order to incentivize innovation (see below for comparison to current BAT products). For both heating and cooling class scales, market improvements until the entry into force of the regulation should be taken into account when adjusting the thresholds and ensuring that class A is initially empty. For example, of the 213 heat pumps and reversible air conditioners currently listed on www.Topten.eu, up to 26 models already reach the proposed class A. The best model reaches an EEI value between 343 and 381 (depending on the correction factors for control features), by far exceeding a proposed class A threshold of 290. For the cooling function, no air conditioners currently reach the proposed class A. However, proposed class B is already too populated – and is likely to be even more so upon entry into force of the merged regulation – and should be tightened. Keep the calculation of the energy efficiency index simple: The Working Document proposes correction factors in the calculation of the energy efficiency index across all technologies that incentivise the integration of control features. This not only adds unnecessary complexity but also poses the risk that such control features will be added in low quality by manufacturers in order to improve the calculated EEI – while not truly reducing or even increasing the overall energy consumption of the product. Topten recommends eliminating both this risk and the correction factors in the EEI calculation. Keep the efficiency calculation simple and transparent for consumers and advertise the control features separately. Provide complete product information sheets: There are gaps in the data required in the product information sheets. These documents should display the energy efficiency index and all factors influencing it, especially a list of all applicable control features (should the latter remain part of the EEI calculation). The draft regulation should focus on closing this gap and by doing so provide more transparency to consumers and market authorities. Comfort fans – give the energy label and MEPS a fair chance: The energy labelling and MEPS for comfort fans in the EU are new and have the goal to stop environmental dumping of inefficient models into the market. The draft regulation proposes class thresholds that are already significantly exceeded by BAT models. The new regulation will only have a fair chance to move the market if class A is set to be empty upon entry into force – both for ceiling and non-ceiling fans – and if the lower classes are not rendered obsolete by Tier 1 of the MEPS. To simplify matters, we also recommend harmonising the future EU MEPS with the 2022 Chinese MEPS. A more detailed analysis as well as supporting market data are available in the attached PDF document.
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Response to Energy labelling for refrigerating appliances with a direct sales function

17 Dec 2018

The regulation for refrigerating appliances with a direct sales function has been discussed since 2007 and is now close to being implemented, thus triggering significant energy savings that have been left untapped so far. Already a factor of about 2-5 exists in the energy efficiency between the most efficient and average models on the market (Source: Topten). Rapid advances are possible through non-proprietary existing technologies alone. For the Energy Labelling, the following adaptations are most important to maintain the ambition and effectivity of the regulation: Entry into force: no postponement past 1 September 2020 Adaptation to B2B market: the requirement that the label be presented in proximity to the price or other technical details is not sufficient as many manufacturers and dealers do not show this information in the first place. Manufacturers - while normally not being direct sellers - should also be required to show the label as their websites often serve as decision making platform, an important part of the sales process. Calculation of Energy Efficiency Index (EEI): the new parameters and segmentations for temperature classes and climate classes make the EEI calculation intransparent and make it harder for buyers to spot truly efficient products. We support a return to the original EEI formula structure of the 2014 draft and the setting of different minimum requirements to take into account inherent differences between product types. Further background and recommendation are detailed in the attached document.
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Response to Ecodesign for refrigerating appliances with a direct sales function

17 Dec 2018

The regulation for refrigerating appliances with a direct sales function has been discussed since 2007 and is now close to being implemented, thus triggering significant energy savings that have been left untapped so far. Already a factor of about 2-5 exists in the energy efficiency between the most efficient and average models on the market (Source: Topten). Rapid advances are possible through non-proprietary existing technologies alone. For the Ecodesign, the following adaptations are most important to maintain the ambition and effectivity of the regulation: Entry into force: no postponement past 1 September 2020 Calculation of Energy Efficiency Index (EEI): the new parameters and segmentations for temperature classes and climate classes make the EEI calculation intransparent and make it harder for buyers to spot truly efficient products. We support a return to the original EEI formula structure of the 2014 draft and the setting of different minimum requirements to take into account inherent differences between product types. Resource Efficiency: In order to have a true impact on the market, the minimum availability of spare parts should be re-set to 10 years. As for the maximum delivery time, taking into account the needs of the supermarket and sales segment in case of product deficiency and the speed of the current delivery market, we ask the maximum delivery time to be set to one week. Further background and recommendation are detailed in the attached document.
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Response to Review of ecodesign requirements for household dishwashers

12 Nov 2018

We would like to support the draft Ecodesign regulation proposed by the European Commission but call on the European institutions to reinforce several of the provisions in discussion. Since the ISC draft, the format of the Regulation with clear Tiers and entry into force for each of these dates has been changed. It is not clear in the current draft what is supposed to enter into force when (points are defined in the last article of the Regulation). Our main points of concern are the following: - 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). 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. The preparatory study stated that the average lifetime of a dishwasher is 12.5years. 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. The word "dismantle" should be removed and replaced by "disassemble" to promote repair.
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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. - 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, and it is important that they can be quickly identified and subjected to timely sanctions, we suggest introducing a mid-term check during the test. - Raise ambition on product disassemblability 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 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. - 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, and it is important that they can be quickly identified and subjected to timely sanctions, we suggest introducing a mid-term check during the test. - Raise ambition on product disassemblability 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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