Similarities

Ecodesign and energy labelling measures are driving changes in the design and marketing of the products that they target. These changes relate almost entirely to saving energy, as the two legal instruments are deployed to help foster greater energy efficiency and reduce energy demand. It is perhaps little wonder then that the measures are being developed in tandem: they are working to achieve the same goals. But they are also complementary in the way that they are creating change.

Both ecodesign and energy labelling measures target ‘energy-related’ products. These are products that use energy but may affect energy usage too. Electric showers, for instance, are already included but shower heads could become a future target as they can influence the energy an electric shower consumes. Not only this, the measures work together to ‘push’ and ‘pull’ changes in the marketplace. This is how they complement one another. To date, specific ecodesign requirements have acted as minimum energy performance standards that products must comply with. This is a way of tackling the ‘bottom’ of the market (the least efficient products) and pushing it ‘up’. Energy labelling seeks to ‘pull’ the market by providing consumers with more product information and appealing to their values, encouraging them to buy the most efficient ‘A’, ‘A+’, etc. products.

Distinctions

The measures are, however, individually distinctive. While both target energy-related products, ecodesign measures have a potentially greater reach and transformative effect. This reflects the way ecodesign is defined; as a concept, it seeks to lessen the impacts that products can have on the environment throughout their lifecycles or ‘from cradle to grave’. The implication is that ecodesign legislation need not be restricted to setting minimum energy performance standards for products but could impose requirements pertaining to, for example, resource efficiency or managing CO2 emissions in supply chains. That is not to say that labelling is limited to energy. The framework is clear that labelling applies to the provision of information on energy consumption and, where relevant, other essential resources during use. However labelling does not share the same reach as ecodesign.

A further difference is that energy labelling measures set requirements for manufacturers and retailers. This is not the case for ecodesign measures, which apply to manufacturers, their authorised representatives and importers but not to retailers.

Ecodesign legislation is similar to EU product safety legislation concerned with ensuring the same requirements apply across the Single Market. In these instances, the affixing of the CE marking is a requirement, likewise the preparation of EC Declarations of Conformity, compilation of technical documentation and conformity assessment. With the exception of compiling technical documentation, energy labelling legislation does not specify such requirements. Manufacturers must instead supply a complete EU energy label with every product and make a ‘label’ available – a listing of technical information (eg energy efficiency class, annual energy consumption). Separate requirements must be met by retailers, notably making the energy label visible at point of sale and including product energy efficiency class in advertisements.

Important differences

There are, then, a number of differences between ecodesign and energy labelling measures even though we are seeing proposals for both put forward at the same time. For retailers, an important difference is that energy labelling legislation places obligations upon them. This is not the case with ecodesign legislation, which applies to manufacturers and has the potential to set wide-ranging requirements not just energy performance measures.

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