ECOS and ANEC have joined forces in this position paper which addresses the issue of measurement uncertainty and verification tolerances, as an overarching issue affecting Ecodesign and Energy Labelling products.
In order to assess compliance with the regulations, and issue labels under the Energy Labelling regulations, product manufacturers must perform tests on their products to determine what energy performance they will declare. Every measurement value deriving from these tests is subject to a level of uncertainty, due to uncontrollable factors (limitations of the test methodology, environmental factors in laboratories, equipment, etc). Similarly, as part of the verification process set in the aforementioned regulations, Member State authorities test products put on the market to verify the declared compliance. For the purposes of this procedure, the regulations set a level of tolerance, a sort of “allowance” on the values obtained by tests. The decision on the level of tolerances is political.
These two distinct concepts are often misinterpreted: it has been acknowledged that some manufacturers use tolerances to achieve higher energy labelling classes or to meet the Ecodesign requirements by adding the value of tolerances on top of the measured values. This may result in products being less efficient than the regulations permit and above the uncontrollable “uncertainty” value.
This position paper provides the contribution of ECOS and ANEC to the ongoing discussion with a view to ensure that the distinction between the two concepts is clarified, that further abuse is avoided, and that verification tolerances are not set arbitrarily, but based on measurement uncertainty. This would allow grasping real energy savings from product use and not just on paper.