2. What is your sector specific opinion of the national Energy Efficiency Action Plans? (1/2 page per country = 14 pages maximum)

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2 ,?1=>5988.5<1 #!#!#" ($) &%)$ 1. What is the general opinion of your sector on the overall situation of energy efficiency policy in Europe related to the Energy Services Directive and related to your sector? (1 page) In the Energy Services Directive (ESD) there are a substantial number of references to the household appliance sector. Annex III brings several examples of eligible energy efficiency improvement measures that mention amongst others: heating, cooling, cooking and refrigeration systems, time control for optimized energy use, stand-by loss reduction, energy labelling schemes, creation of Energy Service Companies (ESCOs), campaigns promoting the energy efficiency or standards and norms aimed at improving the energy efficiency of appliances. In addition to the ESD, there are other product oriented policies that refer to our sector and develop more detailed measures mentioned by the Directive. Most importantly, the Green Paper on Energy Efficiency Doing more with less and Energy Labelling Directive 92/75/EEC on the indication by labelling and standard product information on the consumption of energy and other resources by household appliances. And the subsequent Energy Efficiency Action Plan which is an important step forward, and a key instrument to achieve the overall vision of the European Union in terms of a sustainable, competitive and secure energy future. For the past 10 years the white goods sector has heavily invested in the development of super energy efficient appliances. Since 1997 we have successfully run 5 voluntary agreements, on our own initiative, setting energy efficiency standards for household appliances. All CECED members have committed themselves to stop selling the least performing products, to improve the average energy performance of the overall product mix and to inform consumers how to use appliances in an energy efficient way. At the beginning of 2007 the industry announced that it would not renew the voluntary agreements because of a lack of incentives to promote the faster uptake of super efficient appliances, poor national enforcement of energy labelling and the persistent presence of nonsignatories taking advantage of their non-participation. CECED member companies have called for legislation to replace the voluntary agreements in order to secure a level playing field for our sector. In general terms, the resistance from Member States to accepting stringent requirements is a sign of a different commitment level in pushing for technological innovation and promoting its quickest diffusion into the market. That s why it is important that Member States have an obligation to meet ambitious, yet realistic goals. Without strong signals coming from the European legislation, we feel that the existing potential will not be exploited at its best and that environmental benefits will, therefore, be disappointing. 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> %

3 2. What is your sector specific opinion of the national Energy Efficiency Action Plans? (1/2 page per country = 14 pages maximum) AUSTRIA The objective of increasing the market penetration and use of energy-efficient appliances is supported by the national industry. The final energy consumption of appliances is to be reduced through greater market penetration of more efficient ones. The target group is the final energy users. Concerning white goods, the following measures have been decided (referring to National Catalogue of Energy Efficiency Measures published by the Federal Ministry of Trade, Industry and Labour (MBWA), 2007): promoting of energy-efficient household appliances (A+/A++); accelerated replacement of old household appliances through information campaigns. This point concerns among other appliances refrigerators, freezers and washing machines. The white goods industry welcomes these measures but would appreciate that a higher importance be given to the replacement of old, inefficient household appliances. Unfortunately, from the political point of view, a budget for replacement is not very likely. CZECH REPUBLIC The national indicative target of energy saving for 2016 is set at the level of GWh, which includes the overlap of 9% from the relevant volume of average energy consumption. The energy savings by sector includes: Household (31%), Industrial (24%), Transport (23%), Tertiary (16%) and Agricultural (6%). The proposed measurements related to savings are primarily aimed at buildings. This includes energy demand requirements of new and reconstructed buildings, support for regeneration of prefabricated buildings, energy passports, projects for saving energy in buildings and technological processes etc. In the area of home appliances, measurements are only stated marginally and very generally. The only mentioned terms are labelling of household appliances, eco-design and periodic checking of heating boilers and air-conditioning equipment. There are no real and exact measurements stated. 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> &

4 In general we consider the published NEEAP to be only the basic document and we would expect this material to be further elaborated. DENMARK The NEEAP statements regarding the household appliance sector could be regarded as vague. The positive statements we have encountered are the following: - the work carried out up until now, which was based on having a well-functioning market for the energy-efficient appliances, has been quite successful and will continue; - international work and cooperation, especially within the EU, has high priority; - there are no specific burdens imposed on the sector; - more advanced meters could make it easier for consumers to follow their own energy consumption. Unfortunately, the current plan doesn t foresee specific campaigns for early replacement like it did in the past. GERMANY The German EEAP does not impose additional measures. It is, in part, a collection of many old measures (ongoing for years), which were implemented in the past and will end during the ESD time frame (2016). Their impact will be assessed and the savings accounted in the plan. The measures include: the energy label, various promotional, educational and incentive programmes for renewable energy and the building sector (solar, heat pumps, insulation,...), the eco-tax, (introduced in 1999), and the eco-label "Blue Angel". There are also a couple of new measures, still to be implemented, which account for the NEEAP targets. These are: smart metering, contracting, improvement of a bicycle friendly infrastructure, and more R&D for energy efficiency. The measures directly focusing on the white goods sector are: the new energy label; the future ban of electric storage room heaters with a very long transition period (20 yrs); reference to the implementing measures of the EuP Directive 1 ; support programmes for top efficient (household) appliances. 1 Energy-using Products Directive 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9>

5 The support programmes will most likely be "soft" programmes (communication/information/educational campaigns) rather than cash-back or other financial incentives. In general the NEEAP provides a good overview of all ongoing and future measures but it is not a catalyst for new ones. GREECE An advanced draft has been sent to the Commission, with clear indications that alterations are to be forthcoming. HUNGARY The Hungarian EEAP foresees financial support for the replacement of old energy consuming household appliances either in the form of a rebate or a low interest loan. Between 2008 and 2016, GWh/year is expected to be saved through this measure. The programme is expected to begin the 3rd quarter of Other tools being utilised are: the establishment of the energy efficiency consultancy network; the preparation of study material concerning energy efficiency for primary and secondary school education. Furthermore, the plan aimes at raising consumers awareness about energy labelling of water heaters, boilers and air-conditioners. ITALY The Italian NEEAP is quite favourable toward the household appliances sector. The major rate of energy saving in 2016 is assigned to improvement measures in the residential sector (56,830 GWh/year, of which 5,330 is for cold and wet appliances). It foresees: replacement of dishwashers by class A appliances; replacement of refrigerators and freezers by class A+ and A++ appliances; replacement of clothes washing machines by superlative class A appliances. EFFICIENCY IMPROVEMENT MEASURES Refrigerators and freezers: 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> (

6 By 2010 Information programmes Adoption of minimum efficiency standards (EuP) By 2016 Information programmes Incentives for installing high efficiency appliances Incentives for early replacement of obsolete appliances Adoption of minimum efficiency standards (EuP) Washing machines and dishwashers: By 2010 Information programmes to promote class A+ (for washing machines) or A (for dishwashers) Adoption of minimum efficiency standards (EuP) By 2016 Agreements with domestic appliance industry for development and marketing of washing machines superior to class A+ (for washing machines) and A (for dishwashers) from 2011 Information programmes Incentives for installing high efficiency appliances Incentives for early replacement of obsolete appliances POLAND In general, the Polish EEAP is coherent and the majority of the proposed measures will depend on the market mechanisms. The most important energy efficiency improvement measures, interesting for Domestic Appliance Industry, are: A) Promotion of rational energy consumption in the residential sector, with priority given to: changing old energy inefficient domestic equipment with new energy efficient one; use of tax incentives for manufacturers of domestic equipment and for consumers; measures concerning promotion and proper display of energy labels; design, creation, sale, use and disposal of products that consume energy in a manner that ensures the highest possible energy efficiency at a given level of cost. B) Increasing the proportion of energy saving products available in the market, with priority action such as: information campaigns aimed at replacing inefficient products with energy efficient ones. 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> )

7 C) Economic energy management programme in the public sector. D) White certificates scheme introduction of a mechanism for obtaining, cancelling and trading in certificates confirming action has been taken to save energy as a way to promote energy saving behaviour. E) Information campaigns, training and education in the area of energy efficiency improvement. The white certificates scheme is described in detail in the NEEAP and will also be implemented in the Polish Energy Efficiency Act. On the contrary, the tax credits system is only mentioned as one of the measures and might not be implemented in the Act. ROMANIA In general terms, the preparation of the National Energy Efficiency Action Plan dedicated to the promotion of the use of energy efficient household appliances can be considered as a positive step forward and the measures presented as justified and feasible. However, the document should be improved in order to gain precision and to include additional sub-measures. A presentation of the good points and suggestions for improvement are listed below. The good points include: presence of measures related to market surveillance with regards to the display of an energy label for household appliances (the categories for which the label is applied); consumer information campaigns about the energy efficiency of household appliances were carried out by the authorities; initiative for a future Governmental Decision which will include an incentive of 50 EUR/appliance for the replacement of large household appliances based on the energy efficiency criteria which is due to be adopted in The points where the Plan can be improved include: extension of market surveillance activities in order to determine if the energy label is correctly used; providing more visibility and continuity for consumer informational campaigns; the proposal for the Governmental Decision granting bonuses for the replacement of old refrigerators, washing machines and air conditioners can be more detailed as regards: calendar of the adoption, total available budget, etc. Another suggestion is to grant differentiated bonuses, according to the energy efficiency class of the equipment purchased (e.g.: 50 EUR for A class refrigerators, washing machines and air conditioners, 75 EUR for A+ refrigerators, 100 EUR for A++ refrigerators). 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> *

8 SLOVAKIA The NEEAP of Slovakia from our industry point of view is creating conditions for the transformation of the white goods market in favour of high energy efficient appliances (refrigerators and freezers) from 2008 to Resources are supposed to be created via an energy efficiency fund base which is foreseen in the new, currently drafted law. Possible start: July Unfortunately, due to the limited resources it will be applied to support A++ products only. SLOVENIA Slovenia plans to save at least 9% of energy consumption of at least GWh annually between 2008 and The savings of 941 GWh (2% of energy consumption) are planned to be achieved by The National Energy Efficiency Action Plan for defines the execution of 27 provisions by sectors. Our opinion is that NEEAPs in other countries are more oriented to their industry sector than the Slovenian NEEAP. In the USA, for example, their NEEAP gave some incentives for energy efficient products made in America. More than one year ago we strived for tax incentives for energy efficient products but it was hard to convince customers to buy them. Lack of enforcement may jeopardize all efforts and ambitions included in a good law. Any system interested in securing a high degree of compliance needs an effective and properly working enforcement structure. It is a common position within the household appliances industry that national governments are not currently policing the market to ensure that all products and producers comply with defined rules. The authorities must guarantee fair competition by policing the market in an effective way. SPAIN The NEEAP distinguishes between domestic and office equipment. Regarding white goods, the most important issue brought into the NEEAP is the renovation plan for domestic appliances called Plan Renove which started in 2005 and is foreseen until For the 1 st phase, , the plan received 213 million. In the 2 nd phase , million of public funds have been earmarked. 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> +

9 Plan Renove has proven to be a good tool to replace old inefficient appliances with new efficient ones of energy class A or higher and it has also educated users and sellers about energy labelling. Because it is mandatory legislation, specific courses have been given to sellers. In view of the specific outline of each sector, the capacity for saving and improvement in energy efficiency is set out based on: investment in more technologically advanced equipment (renovation or new technologies) through audits, investment aid, financing, R&D incentives, promulgation of legislative measures in the sphere of standardization, labelling, establishing specific consumption thresholds, etc., so as to put pressure on the market to move towards more efficient usage; communication actions (educational campaigns, changes in behaviour, training, dissemination of causes and effects, etc.). SWEDEN Reference is made to a desire to reduce household electricity consumption but no measures have been specified for white goods. Major savings potential is envisaged in continuing to convert direct-acting electricity and to reduce electricity consumption that way. Possible future means of control are indicated in chapter 3.4. Those that touch upon our activities are the programme for more efficient electricity use and technology purchasing. The proposed ideas are not specified. For example, it would be possible to recommend that the Swedish Environmental Management Council s purchasing criteria should be required in all public procurement. The savings potential on white goods seems to be calculated on the basis of the assumption that everyone who changes white goods upgrades the energy class of their products by one stage. This assumption is rather pessimistic. Dishwashers have improved from energy class D in 1999 to A for virtually all products today. Refrigerators/freezers have improved from C in 1996 to A today. Change of inefficient, years old, product into the most energy-efficient one allows average energy saving of around 40%. According to GFK's survey, Sweden has the oldest stock of white goods in the EU. Despite this, the Swedish authorities choose not to prioritise these products. Energy classification of buildings in chapter the classification system does not take into account installations in the property, either for white goods or other installations. The Swedish Environmental Management Council s purchasing criteria could be the guide here. Energy efficiency enhancement in municipalities and county councils - no mention of white goods here either. If municipal housing companies used the Swedish Environmental Management Council s purchasing criteria as requirements for procurement, great gains could be made. The difference in energy consumption between a refrigerator in class A and one in class A+ is around 20%. With the volumes procured by the public sector, this makes a big difference. The difference in energy consumption compared with the products replaced is around 45%. 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9>,

10 UNITED KINGDOM The Action Plan sets out the package of policies and measures the UK has put in place to deliver improvements in energy efficiency and to meet the 9% energy saving target by 2016 under the EU s Energy End-Use Efficiency and Energy Services Directive. Since the UK expects to exceed the 9% target, there are no new proposals in the Action Plan and it is therefore more of a summing up exercise. Positive measures brought into the plan are: 1. Code for Sustainable Homes which includes energy efficient household appliances; 2. Announcement of the close cooperation between the government and the Energy Saving Trust; 3. Emphasis on raising awareness of energy efficiency issues internationally (Gleneagles, G8); 4. Acknowledgement of lack of consumer awareness of energy efficient measures (several campaigns launched such as Act on CO2). Issues of concern: 1. The Action Plan does not include any new initiatives; 2. Emphasis on the Energy Efficiency Commitment (3 rd phase) where household appliances do not play a prominent role; 3. Emphasis on the Code for Sustainable Homes which is only aimed at increasing the energy efficiency of new homes; 4. Emphasis on Part L of the Building Regulations which does not affect household appliances; 5. Emphasis on Energy Performance Certificates which do not include household appliances; 6. Improved metering to be implemented only in the next decade. 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> $#

11 $" Which are the top 10 policy measures and best practices to promote energy efficiency in your sector? (1 page) - Revision of the energy label The energy label has turned out to be a success story; however, most of the products have now reached the top class of the energy labelling scheme. CECED proposes a new open-ended labelling scheme which can be dynamically updated to accommodate the continued improvement of our products. The new classes, marked with digits instead of numbers, would be added at the top. At the same time, the least performing class would be phased-out at the bottom. (for more details see CECED Position paper from 12 Dec. 2007) - Early replacement of 188 million old, energy inefficient appliances that are still in use in European households through: o tax credits to consumers or carefully constructed long term consumer cash-back and rebate schemes - Uptake of super efficient appliances is still, unfortunately, very low 2 due to the main barriers of the initial purchase price and the long payback period. In most cases, lower income pushes consumers to buy less energy efficient appliances. Moreover, a vast majority of consumers use their home appliances until they break. Their sense of accepting innovation is not the same as ICT equipment, for example. Consumer awareness is also a major barrier to diffusion of efficient appliances as the environmental benefits are not always clear to consumers. - Enforced market surveillance too many governments are not stopping careless or unscrupulous operators from marketing products that claim better energy efficiency than actually delivered. National governments must guarantee fair competition by enforcing the law and ensuring that product declarations are genuine. Effective legal enforcement can be achieved only if: o adequate administrative resources are made available; o administrative procedures are streamlined; o dissuasive sanctions are foreseen. - White certificates schemes - A system of white certificates would require energy companies to invest, in proportion to their market share, in the promotion of energy efficiency, such as through measures that would result in consumers replacing energy inefficient equipment with new highly energy efficient appliances. 2 In 2007 market share of cooling appliances of A+ energy class was 18,5 % (GfK data for AT, BE, DE, ES, FR, GB, IT, NL, PT, SE), while for A++ below 5 %. 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> $$

12 - Promotion of the international convergence of measurement standards to reduce investments required for new products and promote the diffusion of the best available technologies in the emerging markets. - Balanced combination of EPBD 3 and EuP requirements for installed products such as water heaters. EXAMPLES OF GOOD PRACTICES Tax credits for consumers (Italy) - The authorities encourage substitution of old refrigerators and freezers with A+ and A++ class appliances. 20% of the appliance cost, with a ceiling of 200, is allowed deducted from the personal income tax. January - October 2007 sales figures of A+ cooling appliances were more than double in comparison with the previous year. White certificates schemes (Italy and under discussion in other countries such as France and Poland). Rebate schemes (Spain) - Plan Renove de Electrodomesticos was initiated in 2006 and is now in the second phase with a budget of mln. In 2008, customers who buy energy efficient products will be eligible for subsidies depending on the appliance type purchased. So far the 2008 plan covers: refrigerators, freezers and refrigerators-freezers of class A and higher, washing machines of energy class and washing performance classified as A, class A ovens, induction and gas hobs. Awareness raising campaigns o Time to Change (United Kingdom by AMDEA) o Forgó Morgó (Hungary by CECED Magyarország) o Hausgeräte plus (Germany by ZVEI and utilities). Buyback programs (Brazil) in September 2008 the federal governments plans to launch a programme to subsidise the purchase of 10 million refrigerators for low-income citizens. Consumers will have to retire their old refrigerators in order to get credits to purchase subsidized refrigerators. The new refrigerators will be exempt from federal taxes and their acquisition will be financed through credits provided by state-owned bank Caixa Economica Federal. Sanction system (Australia) 3 EPBD Energy Performance of Buildings Directive 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> $%

13 4) Please give some background information on your organization and your members. (1 page) CECED represents the household appliance industry in Europe. Its member companies employ over 200,000 people, are mainly based in Europe, and have a turnover of about 40 billion. If upstream and downstream business is taken together, the sector employs over 500,000 people. Direct Members are Arçelik, BSH Bosch und Siemens Hausgeräte, Candy Group, De Longhi, Electrolux Holdings, Fagor, Gorenje, Liebherr, Indesit Company, Merloni Termosanitari, Miele, Philips, Saeco, SEB and Whirlpool Europe. CECED s member associations cover the following countries: Austria, Belgium, Czech Republic, Denmark, Estonia, France, Germany, Greece, Hungary, Italy, Latvia, Lithuania, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Spain, Sweden, Switzerland, Turkey and the United Kingdom. 2F;DE?A@@7?C; /@;C=H /<<?9?;@9H 67E9> $&