The story first broke a couple of years ago, when Dyson argued to scrap the Energy Labelling regulation. The reason was because the test method that underpins the regulation discriminates against bagless vacuum cleaners. Typically, dust bags that are filled during their use affect the performance of vacuum cleaners, a result which is not applicable to bagless models. Since the test method dictates that vacuum cleaners are tested with an empty dust bag, Dyson’s advantage of bagless vacuum cleaners would not be recognised.
Dyson’s proposal to altogether scrap a regulation which delivers significant benefits to consumers and the economy is a bad idea. The Ecodesign and Energy Labelling regulations for vacuum cleaners are expected to save 19 terawatt hours (TWh) per year by 2020, which is equivalent to the electricity produced by 26 medium size coal power plants. But the Dyson case highlights an issue that goes well beyond vacuum cleaners: how much do test methods that provide the basis for the EU Energy Label classification reflect the way products actually operate and are used in real-life? Now, the ECJ’s ruling follows the train of thought that test methods should be “as close as possible to actual conditions of use”.
The main objective of the Energy Label is to provide a classification of products on the market based on their performance. This in turn helps consumers reduce their energy consumption costs and lower their environmental impact. For the comparison to be fair, product performance should be tested under the same conditions so that test results are reliable. In the optimised conditions of a laboratories, real-life usage cannot be replicated to the fullest, nor can they capture every single consumer’s variable behaviour. Even though producing reliable and repeatable results are necessary characteristics of a test method, they are not sufficient. If the sole purpose of the Energy Label was just a comparison, then classifying a product as ‘’A’’ or ‘’C’’ would make no difference, as long as it performs better than a product classed as a ‘’D’’. However, the consumer that bought a class “A” product does not only expect to find out which model is better than the other, but at the end of the month also expects to see an energy bill that corresponds to class “A”.
That is why ECOS has long been arguing for the development of test methodologies that are representative of real-life behaviour of consumers and products as much as possible. Taking this criterion into systematic consideration together with the need for repeatable and reliable test methodologies will effectively contribute to providing the most relevant information to consumers possible, then leading to meaningful purchasing decisions.
Ecodesign requirements for the durability of vacuum cleaners come into force already this September, but we still lack a test method with a partly-filled dust bag to support them. This is an excellent opportunity for test developers to demonstrate they are up for the task of improving test methods.
(Image credit: Travis Wise/Flickr)