Tolerances: Who should use them and how

A legal loophole is allowing manufacturers to inflate the performance of energy-consuming household products. A whistle-blower has now come forth saying that this problem is widespread in the lighting industry.

As it stands, manufacturers and importers are responsible for declaring the energy efficiency of their TVs, fridges and other products regulated by the EU Ecodesign Directive and Energy Labelling Directive. Authorities are then responsible for testing those claims and are entitled to apply a margin for error, or ‘tolerance’, to allow for variations in the accuracy of their lab tests. It has now come to light that companies are taking advantage of allowances intended for use exclusively by state authorities.

The ECOS-EEB led campaign Coolproducts goes into the details in full explains: Tolerances vary by product, but are typically around 10% in Europe. The rules are old, testing technology has moved on, yet over-generous tolerances remain.

Christoforos Spiliotopoulos, Policy Officer from ECOS, says even if tolerances were reduced, EU regulators never intended firms to take advantage of them, but never specified this with sufficient legal clarity.

The issue of measurement uncertainty and verification tolerances is 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.

Our position paper written together with ANEC goes into full detail about the issue of measurement uncertainty and verification tolerances here.