Government consultations - almost always lengthy documents - are important for trade associations as they provide great opportunities for the industry to comment on current Government thinking and legislative proposals.

In the case of AMDEA, because white goods are pan-European, this also means keeping an eye out for EU consultations. To start the year, AMDEA provided its views to the UK Government on the European consultation on how best to modernize the A to G energy label. Next on the agenda is consolidating a response to a UK consultation aimed at reducing the quantity of hazardous and non hazardous waste batteries going to landfill, and increasing the recovery of the materials they contain.

Then, just before Christmas, came a consultation which directly impacts on all of our members. This consultation is looking into ways of making all energy-using products more energy efficient and environmentally sustainable. This may sound familiar - indeed, similar work is being done in Europe on this very same topic.

The constraints

Whether consultations come from the UK or the EU, it's important for AMDEA to let the decision-makers know what can and can't be achieved. It's all well and good to have targets, but if they are ill thought out, they become meaningless. Sometimes, upon close analysis, unforeseen consequences of legislative proposals have not been considered by the Government.  Take the case of electric showers. Studies are being conducted in Europe recommending ways to improve the environmental performance of this product. However, the apparent test methodology used in the study for electric showers is unrealistic even though the energy efficiency is high. The result of trying to test a shower as if it was a hand washing unit could have the unintended consequence that would lead to UK-style electric showers being banned in 2012/2013. AMDEA has been lobbying for this not to happen and has gained some changes to the proposal being put before the European Commission.

More often, consultations are used by trade associations to convey to the Government the realities of the market and what can be achieved by the industry.  In the UK consultation mentioned above, the Government has listed innovative technologies which could be employed to make energy-using products even more energy efficient. AMDEA will be making the point that in the white goods sector, the energy savings made over the last ten years have been immense and its ability to improve its products even further without major technological breakthroughs is limited. Achievable targets should be set, but these should not emphasise any one particular technological option. The industry itself should pick the technologies which suit their needs and costs best.

Monitoring the market

The other point AMDEA will be making is on the issue of surveillance. When we agree on certain standards to be applied across Europe and then find that authorities fail to enforce these, this would give an unfair advantage to those who place illegal non-compliant goods on the market to the detriment of those who respect the rules. These businesses are in the minority, but the authorities must guarantee fair competition by monitoring the market in an effective way.

AMDEA will also be making the point that there are other factors, beyond manufacturers' control, which hinder the increased usage of energy efficient products in UK homes and which need to be considered. These include, for example, the tendency for some consumers to replace an appliance with an even bigger, more energy-intensive one.

Finally, the energy efficiency goals to be set for the coming years for energy-using products need to be achievable and need to be accepted by the market. The aim is to get energy efficient products into UK homes and this requires a range of initiatives from manufacturers, retailers and consumers and also from the Government.

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