ECOS Discussion Paper: Circumvention of ecodesign and energy label requirements

Circumvention of test methods is not a new topic for energy-related products, but an increasingly prominent one in current regulatory and standardisation fora. The relevant provisions on circumvention and defeat devices included in the recently-published energy labelling Regulation (EU) 2017/1369 have prompted debates and led to initiatives with the view to address it. However, moving from the provisions in the horizontal regulation to their implementation in product-specific regulations and standards merits systematic consideration.

To that end, ECOS has developed a discussion paper aiming to promote a wider understanding of the issues surrounding circumvention and help enable a productive debate on options to tackle and reduce it. The scope of this paper is the policy area of ecodesign and energy labelling. We set out what circumvention is, what drives suppliers to choose that option and some of the challenges that must be faced to tackle it. We identify many of the varied ways in which it has been and is being at least partially addressed. Finally, we set out some options to stimulate discussion of how it can be tackled more comprehensively, systematically and effectively in future.

We hope that the paper would serve its purpose and facilitate a comprehensive, systematic and effective consideration of circumvention at all tiers of the ecodesign framework: regulation, standardisation and market surveillance.

You can find our discussion paper here.