Energy Using Products Directive: Implementation of Lot 17

Transcription

1 Energy Using Products Directive: Implementation of Lot 17 Executive summary: The pressing need to reduce energy consumption and carbon emissions in domestic appliances presents an opportunity to engineer high performing, efficient vacuum cleaners. We agree with the European Commission that the majority of a machine s environmental impact is determined during its design. Through efficient engineering, it is possible to maintain high performance, whilst substantially reducing environmental impact. We consider that implementing the proposals contained in the Lot 17 consultant s report 1 can: limit the negative environmental impact of vacuums promote the interests of consumers, ensuring that energy use is reduced and clearly communicated ensure targets and measures are realistic, while minimising administrative and financial burdens to industry and national regulators We request that the Commission implement input power rating caps (power caps) rather than energy labels for vacuum cleaners. We suggest a phased introduction as follows: 1,1 watts in watts in 21 2 Our justification is: 1. Motor caps are cost efficient, easy to measure and a simple way for manufacturers to comply with the EuP Directive. They are inexpensive and easy for standards authorities to monitor and enforce. They maintain consumer choice at current prices. 2. Power caps will have a strong and predictable impact on energy saving. Energy labels will not guarantee energy reduction. 3. Motor caps reduce energy consumption without sacrificing performance. High pickup can be achieved with limited input power and without additional cost, safeguarding consumer choice at all price levels. 4. Energy labels can communicate lower power consumption in some categories of domestic appliances. But not in vacuum cleaners.. Energy labels stifle innovation. 1 AEA, Work on Preparatory Studies for Eco-Design, Requirements of EuPs (II). Lot 17 vacuum cleaners. TREN / D3 / Final Report 2 The power measure should be PMax, accepted (and widely communicated) standard for vacuum cleaners. 1

2 Energy Using Products Directive: Implementation of Lot 17 Introduction: The pressing need to reduce energy consumption and carbon emissions in domestic appliances presents an opportunity to engineer high performing, efficient vacuum cleaners. We agree with the European Commission that the majority of a machine s environmental impact is determined during its design. Through efficient engineering, it is possible to maintain high performance, whilst substantially reducing environmental impact. We consider that implementing the proposals contained in the Lot 17 consultant s report 3 can: limit the negative environmental impact of vacuums promote the interests of consumers, ensuring that energy use is reduced and clearly communicated ensure targets and measures are realistic, while minimising administrative and financial burdens to industry and national regulators We request that the Commission implement input power rating caps (power caps) rather than energy labels for vacuum cleaners. We suggest a phased introduction as follows: 1,1 watts in watts in 21 4 Justification 1. Motor caps are cost efficient, easy to measure and a simple way for manufacturers to comply with the EuP Directive. They are inexpensive and easy for standards authorities to monitor and enforce. They maintain consumer choice at current prices. To achieve change and ensure manufacturer participation, a simple, inexpensive and readily enforceable standard is required. Compliance and enforcement of motor caps is simple and easily regulated. For motor caps, a maximum power test would cost around 2 per test (based on three samples). A chamber to simulate environmental conditions and a power meter are the only requisites, which the majority of independent test laboratories have. This model significantly increases the number of laboratories across Europe equipped to perform such a test. Compliance with the Comité Européen de Normalisation Électrotechnique s (CENELEC) proposed energy label will be expensive with no additional environmental or consumer benefit. We estimate the cost per test for the proposed model to be around 2, per machine (based on three samples). The test is complex; only one laboratory in Europe can carry out current compliance testing due to the expense of the calibrated reference machine. Enforcing the label would require testing every machine sold in Europe and will be very costly, placing a significant administrative and financial burden on local enforcement agencies. This is certain to exclude smaller companies from the market and so reduce consumer choice. 2. Power caps will have a strong and predictable impact on energy saving. In contrast, energy labels do not guarantee energy ergy reduction. Rated power trends are easily plotted over time machine power is already communicated by most manufacturers. The graph below shows the trend from and the best possible Business as Usual (BAU) progression of power consumption in Europe s three biggest vacuum cleaner markets. It is clear: power caps would dramatically reduce energy consumption. 3 AEA, Work on Preparatory Studies for Eco-Design, Requirements of EuPs (II). Lot 17 vacuum cleaners. TREN / D3 / Final Report 4 The power measure should be PMax, the accepted (and widely communicated) standard for vacuum cleaners. 2

3 Figure 1: Average Rated Power trends. DE, FR, UK Best possible BAU consumption vs. maximum consumption under power caps 2 2 DE FR Best possible BAU forecast Rated Power (W) 1 1 UK Maximum Power consumption with Power caps Year Source: GFK (NB: For detailed market breakdown of power trends see Appendix B). Under CENELEC s proposed test method, it is possible to achieve high or low pickup performance with high or low power machines. Theoretically, a very high powered machine can achieve an A grade. Energy labels will allow manufacturers to continue producing machines that do not reduce energy consumption. With no definite minimum power rating, how can labels guarantee to deliver energy savings? Any projected energy saving is purely guesswork. Analysis of total vacuum cleaner energy consumption across Europe states the point more starkly. The BAU condition includes the implementation of energy labels contrasted against motor caps of 1,1 and 7 Watts. 3

4 Business as Usual 11W cap only 11W and 7W caps Figure 2: Graph showing the effect of energy labels (Business as Usual) against power caps on power consumption in the European market. 3. Energy caps reduce energy consumption without sacrificing performance. High pickup can be achieved with limited input power and without additional cost, safeguarding consumer choice at all price levels. In vacuum cleaners, there is no direct correlation between pickup performance, separation efficiency, and motor power. Some high performing vacuums already meet (or are close to meeting) the proposed caps at 1,1 and 7 Watts, such as the Numatic Henry (12W), the Vorwerk Kobold (9W), the Electrolux Envirovac (8W) and Dyson s DC24 (6W). Power caps can achieve EuP objectives within a short timeframe and, crucially, without sacrificing performance and cost to the consumer is limited. Two to three years of product development before compulsory compliance is a realistic timeframe. Cleaning performance could be monitored via performance test results, such as existing pickup and dust emission tests (IEC standard 6312). Consumers will be confused if performance and energy consumption are combined in the test methodology for energy labels. Consumers may assume that an A grade machine would clean their carpet better than a B grade machine. However, Appendix A shows clearly that cleaning performance is in no way dependent on rated motor power, and therefore it is misleading to combine performance and energy consumption data in a label. 4. Energy labels can communicate lower power consumption in some domestic appliances. But not in vacuum cleaners. Dyson agrees that the objectives of the energy labelling proposal and the EuP Directive overlap. We agree that in principle energy labelling can encourage manufacturers to develop less power-hungry products whose energy use is predictable, such as refrigerators, dish washers and freezers. But, for example, it hasn t worked for washer dryers. The UK s National Measurement Office proved that faulty test methods led to exaggerated and confusing energy saving claims in AEA, Work on Preparatory Studies for Eco-Design, Requirements of EuPs (II). Lot 17 vacuum cleaners. TREN / D3 / Final Report 6 Eco-Design: the integration of environmental aspects into product design, with the aim of improving the environmental performance of the energy using product throughout its life cycle. European Commission website, Eco-Design summary 4

5 Energy labels only work for products when meaningful tests can be defined, implemented and enforced. CENELEC s proposed test method for vacuum cleaners has been in development for over ten years, but is still unrealised. Why? The test is too complex and difficult to reproduce consistently across different test laboratories. The current IEC 6312 tests for vacuum cleaners are designed (and agreed across the industry) to be repeatable. A fridge or washing machine regulates its own energy consumption, but individual users determine how long a vacuum is in use and therefore how much energy is consumed. Defining vacuum test methods involves numerous interactions and variable parameters. For example, the distribution of dust and the type of surface being vacuumed. It is already contentious simply for standard pickup tests. CENELEC s proposed vacuum energy label test is based on a flawed assumption: that vacuuming behaviour adjusts to the performance or pick up of a machine. There is no evidence to prove that people using a high performing machine spend less time cleaning. The final version of the consultant s Lot 17 report cites hours vacuuming per year as an agreed average, irrespective of the machine s performance or energy efficiency. 7 And how do you define clean? It is impossible to remove 1% of dust out of a carpet, more variables (hence more complexity) are required. Consequently, the test result misrepresents actual energy consumption (over time) used by a vacuum cleaner owner. Adding energy efficiency as a measure introduces so much variability that the measure becomes meaningless. Our overriding concern is that CENELEC s proposal relies on unreproducible, unrepresentative tests. This will lead to complex, unreliable and confusing energy labels.. Energy labels stifle innovation An engineering specification should outline a machine s desired deliverables. It s the job of the engineer to decide how this is achieved. However, the test method for energy labels encourages manufacturers to develop machines dedicated to getting a good energy label, rather than excelling at their primary functions removing dust and dirt in the case of vacuum cleaners. Dyson experienced this first hand while launching its washing machine in 2. The machine was rated against one specific test which became known as the golden cycle by manufacturers. Manufacturers went to a great deal of effort to engineer machines that performed well at this cycle, when in fact other cycles (cotton at 4 degrees, for example) were more commonly used by consumers. With Dyson s larger 7kg capacity and its Contrarotator technology, the Dyson machine could deliver an A grade wash at 4 degrees centigrade, but we could not easily communicate this through the grades in the energy label. Energy labels were used heavily as marketing tools in stores. Consumers were making what they felt was a good choice based on a cycle they would use infrequently. Energy labels skewed innovation towards one specific test, sacrificing performance and innovation throughout the rest of the machine. For vacuum cleaners, introducing energy labels could incentivise manufacturers to engineer machines that conform to marketing rather than engineering objectives. Power caps are transparent: for both manufacturers and consumers AEA, Work on Preparatory Studies for Eco-Design, Requirements of EuPs (II). Lot 17 vacuum cleaners. TREN / D3 / Final Report, P31

6 APPENDIX A: Dust removal performance p and power The following graphs (IEC 6312 dust removal from hard floors with crevices, and carpet tests) show no direct correlation between dust removal performance and motor power. Machines with both high and low rated motor power can achieve the same IEC performance as shown with the highlighted boxes. IEC 6312 Hard Floor with Crevice Pickup Vs Rated Motor Power 12 IEC 6312 Dust removal from Hard Floor from Crevices (%) Rated Motor Power(W) IEC 6312 Dust removal from carpet Vs Rated Motor Power IEC 6312 Dust removal from carpet (%) Rated Motor Power(W) 6

7 APPENDIX B: Power trends in Germany, France and UK Unit Share Germany Rated Power Trends Based on GfK MAT data Estimated GfK coverage 9% Germany s power trend shows an alarming growth in higher powered machines at 23W and 24W, and a reduction in vacuum cleaners powered by 18W and lower motors UNKNOWN Max rated power Unit Share (%) France Rated Power Trends Based on GfK MAT data Estimated GfK coverage 9% In France, again, there is a trend towards more powerful 2W and above machines as well as a reduction in vacuum cleaners powered by 18W and lower motors UNKNOWN Max Rated Power (W) 3% 3% 2% 2% 1% UK Rated Power Trends % % % UNKNOWN Unit Share (%) Based on GfK MAT data Estimated GfK coverage 9% The UK market shows a larger range of powers, with some growth in very low powered machines, but also an increase of 2W machines Rated Power (W) 7