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CECED: Let's Avoid Logistical Nightmare of 24 Appliance Labels for Europe
Mar 28, 2014
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CECED, the European appliance industry association, issued its comments on the first findings and recommendations of the study team on the evaluation of the energy labeling and ecodesign directives. CECED's remarks address the appliance energy labeling-related aspects in the report.

CECED agreed with one of the primary conclusions of the report, that “consumer understanding should be the chief concern for future label revisions.” However, CECED said, testing shouldn't be limited to an exercise in which consumers are simply asked to vote for a label layout.

"Consumer understanding must be tested over the lifetime of the energy label," CECED wrote. To be sure a label is workable and understood, "Consumers should thus be confronted with scenarios of transition."

CECED commented on the reports contention that an A to G scale was preferable to a numeric, open scale, or one that adds more "plus" symbols.

"It is sensible that the A to G scale scored best as it has been the unique label consumers were confronted with for years," CECED noted. "However it has to be recalled that there is no outrageous difference among scales: all options scored from 90 to 95%. It confirms the need to further test the different options as recommended."

The EU consists of a 28 Member States, with different rates of new label adoption and product distribution, which makes it inevitable that old labels and new labels will appear on retail floors at the same time during the transition period. This is a problem that policy makers need to address in their review.

CECED also agreed strongly that "a sustainable approach is needed to allow planning certainty and maximize manufacturers’ investments in new technologies," as the report stated.

CECED disagrees, however, with the recommended reintroduction of national languages for the label.

"Abandoning the language neutrality of the label would entail switching back to 24 different labels (one for each official language). In a single market where products cross borders at any time, this would be a logistical nightmare and raise concerns of enforceability because of increased risks of incorrect label use.

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