Ecodesign and Energy Labelling Working Plan 2022-2024 – new products, a boost to ecodesign efforts… and the foundation for an EU repair index
By On 30 March, the European Commission published its much-awaited Ecodesign and Energy Labelling Working Plan 2022-2024, which sets out the priorities for the implementation of this EU policy. The plan includes bright prospects for new rules that will drive further energy savings, and stresses the need to make up for the delays in the development of regulations for several products.
An EU-wide repair index for phones and tablets, mandatory rules against the planned obsolescence of printers, energy-efficiency requirements for electric vehicle chargers… The European Commission has ambitious plans to continue expanding its product design requirements in the upcoming years, as shown in the Ecodesign and Energy Labelling Working Plan 2022-2024.
Among the priorities, the Commission plans to extend ecodesign and energy labelling to five new product groups, explore the possibility to introduce a repair index for mobile phones and tablets, and catch up on the delays it has accumulated in recent years in developing new product-specific regulations and updating the existing ones. However, it is not all positive: important products such as 5G base stations will remain unregulated. Whether the Commission’s plan is successful will also depend on officials prioritising the reviews of regulations for key products such as home boilers, air conditioners and computers.
The Plan looks promising on paper, but will it make our products more sustainable? Below are our main takeaways from the 2022-2024 Working Plan.
Delay is the name of the game
Ecodesign and energy labelling regulations have proven to be powerful tools in making products more durable and energy-efficient, bringing about 311 Mt CO2 equivalent emissions in 2020 alone. Such is the success, that the European Commission will extend its scope beyond ‘energy-related devices’ to virtually all products on the market in a new blanket regulation pending approval by the European Parliament and the Council (expected to be in force in a couple of years).
Paradoxically, the EU is not dedicating enough resources to properly implement the ecodesign policies already in place, affecting some 30 different types of ‘energy-related’ products, a legal definition that includes, among others, household appliances, consumer electronics, and water pumps.
As a result of poor funding, very concerning delays have accumulated over the years, with no new product-specific measures adopted since 2019. From the previous Working Plan, covering the period from 2016-2019, only 25% of the announced measures were adopted. Out of the ten new products the previous Plan promised to cover, not a single one was regulated.
Even the latest Working Plan was adopted two years late: it was supposed to cover the 2020-2024 period, not 2022-2024.
The Commission is now faced with the challenging task of catching up with the backlog from the previous Plan: a total of 38 of the promised implementing measures still need to be reviewed and updated.
There is a light at the end of the tunnel: the Commission seems to be aware of the importance of ramping up efforts as the 2022-2024 Plan stresses the need to avoid delays as a ‘key lesson learned’.
Five new products and a repair score are in…
The Commission plans to explore the savings potential of five new product groups in the coming years: radiators and convectors, professional laundry appliances, professional dishwashers, external power supplies, and electric vehicle (EV) chargers.
Five is a disappointingly low number. That said, it is excellent news that, in line with NGO calls, ecodesign will apply to crucial products such as EV chargers, accompanying the large-scale deployment of electro-mobility infrastructure.
For mobile phones and tablets, minimum requirements on durability, upgradeability and recycling are planned to be introduced by the end of this year. Revised design rules will be based on EN 45554,
The Commission also hints at the introduction of an EU-wide repair index, inspired by the one France put in place in 2020. If confirmed, this would be a vital first step towards improving information and labelling of products – starting with those already covered by energy labelling, and extending it to more devices. This would work alongside material efficiency requirements, guiding consumers towards more repairable products.
The Commission also plans to regulate new important horizontal aspects related to ‘durability, firmware and software’, which would affect all ‘energy-related’ products under the Ecodesign and Energy Labelling regulations. Lack of software updates after a few years is a common source of planned obsolescence, which needs to be addressed.
Finally, the Commission has also listed standardisation as one of the main horizontal priorities of the Working Plan, pointing to the important role standards play in providing test methods to manufacturers and helping demonstrate compliance of products. Nonetheless, the Plan also mentions the lengthy standard development process, and the looming possibility that they might not be ready in time to support the new legislation.
…but important products have been left out
Unfortunately, most of the products shortlisted in the preliminary preparatory study were ultimately left out. The exclusion of mobile phone network antennas (base stations) is particularly disappointing, as this means the deployment of 5G will remain unchecked in terms of energy and material consumption. Other home and enterprise network equipment is only mentioned in a footnote with a vague reference to identifying the ‘most efficient ways of regulating them where appropriate’. Professional cooking appliances were also skipped, even though food delivery is a growing business. Swimming pool heaters, responsible for huge levels of energy use, are missing too.
Furthermore, while the Working Plan acknowledges the importance of market surveillance and legislation enforcement, it does not provide any concrete proposals to discourage non-compliance and free-riding.
Home boilers, air conditioners, and computers need to be fast-tracked
Including certain new product groups under the ecodesign umbrella is highly beneficial, but the Commission must first clear the backlog of measures whose implementation was largely delayed – prioritising the products that bring the greatest energy savings. Measures for heating products, air conditioners, computers and water pumps hold enormous energy saving potential, yet their reviews have been kept in the waiting room for way too long. They must be placed on a fast track immediately.
Last but not least, the European Union should urgently secure the sufficient resources needed to ensure a smoother implementation of the Ecodesign Directive and, in the future, of the Ecodesign for Sustainable Products Regulation.
The new Ecodesign for Sustainable Products Regulation, which the Commission adopted in March, is set to be a watershed moment in making sustainable products the norm. However, the final regulation will only be agreed by EU governments and members of the EU Parliament two to three years from now.
Meanwhile, the Commission cannot afford to idly stand by. Ecodesign and energy labelling rules have applied to ‘energy-related’ products since 1994, and brought impressive results. In the upcoming years, the Commission can stimulate the uptake of even more energy efficient appliances, make sure that electric vehicle chargers comply with robust requirements… and give Europeans a first taste of a right to repair. The Working Plan is the first step in this quest – it is time for Commission officials to roll up their sleeves and give a decisive push to ecodesign.
