GEN – 845.00. In 2015, the European Commission paper on ‘Ecodesign for energy-related products integrated into other energy-related products’ was discussed during a Consultation Forum. It provides for an interpretation and could serve as basis for further discussion. Throughout the past two years, industry views and proposals have evolved. Recently, some associations have re-entered discussions on this subject and propose a distinction between ‘bespoke’ and ‘catalogue’ products. Eurovent members are asked to critically reflect on this subject and to share their views with the Secretariat.
By 2015, it was realised that some Ecodesign Regulations apply to both stand-alone products and products integrated into other products. Questions regarding the responsibility for the compliance for the integrated product were asked.
These and other questions were very much highlighted during the review of the motor regulation (640/2009) and fan regulation (327/2011). These reviews have been confronted with delays. The publication of the revised motor regulation is expected soon and the revised fan regulation would appear in 2018.
The Commission discussion paper supports the view that products integrated in other products must comply with Ecodesign requirements.
At that time in 2015, different opinions existed. Some manufacturers of end-products argued that using products that comply with Ecodesign requirements do not necessarily improve the energy efficiency of the end-product. It would also involve double testing (including for market surveillance purposes). This was commonly referred to ‘double regulations’ and now often referred to as ‘cascading regulations’.
Renewed discussion on the interpretation?
Some manufacturers within the associations CECED, EHI and EPEE are covering different products and have developed their initials views in a joint position. The joint position makes a distinction between ‘bespoke’ and ‘catalogue’ products. CECED, EHI and EPEE have been and are advocating this distinction towards the European Commission and Member States.
Bespoke products are products that are specifically designed for, and ordered by, to fit into a product of an Original Equipment Manufacturer (OEM).
If an OEM integrates off-the-shelf catalogue products, the OEM will have to accommodate the Ecodesign requirements that apply.
This interpretation offers the possibility to develop and review Ecodesign Regulations, both for products that are integrated in products that are subject to Ecodesign regulation and products that are not subject to Ecodesign regulations.
The upcoming revisions of the fan and motor Ecodesign Regulations is likely to result in a revision of the original Commission interpretation.
The discussion will come up and, with time, the European Commission interpretation is expected to evolve. The Eurovent Product Groups and Eurovent Commission are asked to consider if the proposed distinction between ‘bespoke’ and ‘catalogue’ products could be supported.
Related documents and links
All related documents and articles can be found in the respective sections in the right sidebar.
- GEN – 845.01 – CECED-EHI-EPEE working paper February 2017
- GEN – 845.02 – CECED-EHI-EPEE presentation to ADCO 2017-04-26/27
- GEN – 578.01 – EU Commission discussion paper
- GEN – 597.02 – Minutes EU Consultation Forum 2015-04-29
- Activity reports Administrative Cooperation on Ecodesign and Energy Labelling (ADCO E 02647)