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Eco design and energy labelling continues to be an area that some media love to hate. Declared energy labelling ratings have been the subject of pieces some damning pieces in both The Guardian, reproduced on BusinessGreen, and The Times recently. But is it warranted?

The prompt was a thoughtful report by the European Environmental Bureau (EEB) – Closing the Reality Gap: Ensuring a Fair Energy Label For Consumers, (Download full report here). The focus of the report was on the test standards that are currently used to demonstrate compliance with energy labels for televisions, refrigerators and dishwashers.

Manufacturers support eco-design and energy labelling and want it to be a success, although it seems that certain elements of the media find this hard to believe. In our evidence last summer to the Energy and Climate Change Committee’s inquiry immediately after the vote to leave we urged government to ensure the rules were retained in UK law. Indeed, we believe they should be linked to financial incentives to encourage more consumers to buy the most energy efficient products on the market as UK consumers in particular don’t appear to be particularly motivated by energy labels – but perhaps that’s a story for another blog.

Far from being the energy guzzlers as the somewhat histrionic Guardian article claims, televisions are more efficient than they have ever been. A typical 40inch TV today uses around 100W. At a tariff of 15p per unit of electricity, it costs about 6p to watch 4 hours of TV a day in electricity costs. Furthermore, there was no widespread overshooting of energy classes as reported in the piece. For televisions just 7 models were tested and the report acknowledged that this was not representative of the market.

EEB’s report however picked up on some important points. Existing test standards do not reflect the capabilities of modern televisions and appliances. They do not reflect real life use. Software updates may change the energy profile of some products. And there was one example of a television that appeared to reduce energy consumption during EEB’s test.

The report, and in fact the coverage around it, has highlighted how important it is for regulation, particularly very prescriptive regulation, to keep pace with technological change.

The current rules for televisions came into force in 2010. Since then dramatic technology and market change has taken place. While CRT TV’s had just about had their day back then, we hadn’t gone through full digital switchover. Flat screen technology has moved forwards leaps and bounds. Plasma technology, the only technology for large screen sets in the past has gone. LCD TV’s were backlit by fluorescent lamps but now nearly all are lit by LED’s. OLED TV is now the new kid on the block. Our TV’s have virtually all gone smart, with a huge increase in functionality by being connected to the internet and we have massively improved image quality with UHD/4k TV’s becoming mainstream and now being equipped with High Dynamic Range to improve colour rendition even further. Oh, and all this with significant reductions in energy use. There has also been a shift to larger screens as picture resolution has improved and but equally people are now watching more content on tablets and the like.

Few of these changes were anticipated in 2010, so it’s no surprise the test standards required to demonstrate compliance with existing eco design requirements are in need of an update: the eco-design rules themselves are drastically out of date.

The good news is that after a hiatus of several years, policy making under the eco-design Directive is ramping up again following the delayed publication of the Commission’s 2016-19 workplan (ironically delayed for fear of influencing the referendum following a barrage of bad press in the Eurosceptic press – see Andrew Warren’s piece here on this matter). Energy labelling rules have also been refreshed. Political agreement was reached just a few months ago.

New eco-design rules for televisions (which incorporate the refreshed energy labelling rules, reflect current technology and address many of the issues raised in the report) are near completion, with a consultation forum meeting scheduled for the 6 July. Once agreed, this will prompt new standards to demonstrate compliance. In parallel, proposals for a horizontal measure are being discussed to further reduce energy consumption when products are in stand-by mode.

The point on test standards reflecting real life is a tricky one. Ultimately every product is different and how a product is used varies from person to person. So real life use will be different for each individual. You need to have a means to compare products on a like for like basis in order to have a meaningful energy labelling system that helps to identify the best in class. That said, EEB’s report has some fair points on what the new standards should do to reflect a range of different and “new” use scenarios. Industry is open to working with them to ensure that the new standards meet expectations.

Finally, one of the other points picked up in the press was one television which appeared to lower is power use when tested. On this I would say that the report was very clear that the results were indicative. Testing is very expensive. So only a small number of models were tested for the purposes of this study. It’s why the manufacturer wasn’t named. More work will have to be done by the authorities to investigate this case.

But responsible manufacturers want a level playing field and robust enforcement of the rules (the industry sectors covered by the eco-design Directive have jointly asked the Commission in the past for measures to strengthen market surveillance) so if further evidence is unveiled suggesting outlier non-compliance than it should be addressed by the regulators. Our regulators have benefited from pooling market surveillance with European partners. It is important that when we leave the EU that our ability to monitor compliance isn’t diminished.

This piece was first published on Business Green https://www.businessgreen.com/