GEN – 889.00. On 12 March 2018, the meeting of the Consultation Forum Sub-group ‘Suppliers’ took place. The European Commission presented an initial ‘demo’ and is looking for comments by the industry. Eurovent has suggested that the Commission prepares a short YouTube video to show how the database functions.
ECF Sub-group ‘Suppliers’, 12 March 2018
- European Commission DG Energy: Michiels, Nuij (chairman), Tosoratti
- European Commission DG Mobility: Guedes, Lammens, Miralles + 1 colleague
- Member States: CZ, DE (2), DK (2), FI, FR, IT, NL, NO, SW, UK (2)
- Associations: APPLiA (previously CECED – 4), BEUC, Digital Europe, EHI (2), EPEE (2), Eurovent (2), EUnited, EVIA, Lighting Europe (5)
Who will be concerned
Suppliers are the manufacturers or their representatives in Europe that will need to upload the data into EPREL.
Uploading data will be required for five product groups (within the scope of Eurovent) that must comply with Energy Labelling Regulations. The summary of the data that will have to be uploaded can be found in the ‘EPREL exchange model’:
- Professional refrigerated storage cabinets (Regulation 2015/1094)
- Workspace forum 5.8, see page 87
- Residential ventilation (Regulation 1254/2014)
- Workspace forum 5.15, see page 111
- Air-conditioners (Regulation 626/2011)
- Workspace forum 5.16, see page 118
- Space heaters, including heat pumps (Regulation 811/2013)
- Workspace forum 5.19 – see pages 138-139 (packages) 154 heaters
- Water heaters, including heat pumps (Regulation 812/2013)
- workspace forum 5.20 – see pages 163 and 167
Suppliers meeting summary
To prepare the meeting, on 5 March 2018, the Commission provided participants with revised assumptions titled ‘EPREL Assumptions- version 2.8’ (attached as GEN – 889.01).
A joint industry paper, co-signed by Eurovent, was provided to the Commission (see GEN – 884.00).
The main concern of the associations representing manufacturers is the timely availability of pilots for testing EPREL. The Commission indicated that a pilot to test ‘system-to-system’ communication would become available by mid-July. To guarantee security, confidentiality and the integrity of the ‘system-to-system’ communication, it would function using an IT certificate scheme.
The use of eDelivery will be mandatory and a guide will become available by July 2018.
The revised assumptions (GEN – 889.01) were then reviewed.
The template to register as a supplier, rules on how to, and which data to upload, etc. will be defined in an Implementing Act. The draft for this Implementing Act will be available in April 2018. Comments and suggestions can be provided to the Commission (Nuij). The Implementing Act will be adopted with the ‘Winter package’ in November 2018.
For suppliers, it is important to note that they must validate their users. This means that suppliers will have to define their users and their ‘tree of rights’. This cannot be checked by the system! It is understood that it would be possible for a third party to be appointed by a supplier to enter data into EPREL.
On 11 April 2018, a meeting of the ESF Sub-group ‘Market Surveillance Authorities’ will take place, where the possible link to ICSMS, the EU communication system for the pan-European market surveillance, and the possible link to EPREL will be addressed. Robert Nuij indicated that there would be no link between ICSMS and EPREL. Market surveillance remains a competence of the Member States. Possibly, depending on proposals by Member States, the Commission could fund an action to see if EPREL could function within some market surveillance actions. Market surveillance itself is not within the remit of EPREL.
Besides a number of comments on the lifecycle of products, equivalence models of products, package labels (applies only when put on the market as such) registration of suppliers etc., reference was made to the American database, its accessibility and the data herein: https://www.regulations.doe.gov/certification-data/#q=Product_Group_s%3A*
This was commented upon orally by the Italian representative. Those not familiar with this database are recommended to have a look at it.
The demonstration using lamps as an example proved to be very useful as it gave an idea of how the system would work and how uploading would function. A set of (poor) screenshots is enclosed as GEN – 889.02 to give a flavour of how it will work.
The structure is quite simple:
- Fiche/Label (Fiche in future to be known as Product Information Sheet)
- Technical documentation
- Equivalent models
After the meeting, Eurovent asked the Commission to prepare a short video and make this available on the EPREL collaborative workspace, so that manufacturers can get a better understanding of what will be expected of them. The Commission has indicated it would do so. Other associations supported this request.
The Commission has indicated that it would be available for sectorial meetings or meetings relating to specific product groups. The main point here is to have the correct type of persons around the table: IT staff that is used to dealing with data inside the company and the related security aspects.
Indicative list of future meetings
- 2018-04-11: ECF Sub-group ‘Market Surveillance Authorities’ and ECF Sub-group ‘Public’
- 2018-07-15: ECF Sub-group ‘Suppliers’
- 2018-09-15: ECF Sub-group ‘Public’
- 2018-10-15: ECF Sub-group ‘Suppliers’
- 2018-11-01: Start of introduction of data into EPREL by manufacturers
Update on ecodesign (see also GEN – 882.00)
At the end of the meeting, a brief update was given on the other ecodesign and energy labelling related files. Instead of individual introduction of measures, the European Commission aims to have a new ‘Winter Package’ available by November 2018. This package will include the five priority product groups with revised Ecodesign & Energy Labelling measures for lighting, displays, household refrigerators, dishwashers, and washing machines. For these products, ‘Inception Impact Assessments’ have been released, of which the 4-week stakeholder commenting period has now ended.
The Impact Assessment Board has been replaced by the Regulatory Scrutiny Board. The other product groups that are intended to be scrutinised include in the planning: external power supplies, welding equipment, compressors, computers, servers/data centres, fans, commercial refrigeration and electric motors. Of these, only the electric motors have passed the Regulatory Scrutiny Board stage and should by now be subject to Inter Services Consultation.
The Commission will investigate if products that passed the Impact Assessment Board would have to be submitted Regulatory Scrutiny Board. If this would not be the case, the procedure for some products may progress swifter.
The uploading of EPREL should start in November 2018 and for the products that are subject to energy labelling and that are available on the market be ready by 31 December 2018.
Manufacturers are strongly recommended to identify who will do this job within their company, most likely these persons will be found in the IT departments.
Even though the exact method regarding uploading is not yet available, it can be recommended that the identified persons already look at how the datasets (mentioned in the relevant pages in the EPREL Collaborative workspace document – see ‘who will be concerned’) and how these datasets can be gathered in view of a future transfer. It would be useful for these persons to familiarise themselves with eDelivery. The screenshots of the ‘Demo’ should give them a very first idea of what would be required. This would best be achieved before the summer break.
Eurovent will ask Eurovent Certita Certification if a service could be developed to help manufacturers in compiling and entering data. If this would be possible, it would be a type of service similar to the way in which the US DoE database is supplied with data.
Once the information becomes more tangible the issue will also be discussed within the Product Groups. It may be appropriate to look at the requested data at their next Product Group meetings.
Related documents and links
All related documents and articles can be found in the respective sections in the right sidebar.
- GEN – 889.01 – EPREL Assumptions – Version 2.8
- GEN – 889.02 – Demo – Screenshots (for lamps, poor quality, one can also refer to the mock up for washing machines in GEN – 889.01)
- GEN – 889.03 – EC presentation 2018-03-12
- GEN – 884.00 – European Registry for Energy Labelling (EPREL)
- GEN – 882.00 – Update legislative developments
- The EPREL Collaborative Workspace
- Impact assessments
- 2018 tentative schedule for the Regulatory Scrutiny Board
- US DoE database