GEN – 824.00. For the first meeting, the European Commission brought ‘Suppliers’ together to discuss the content and functioning of the future EU product database. Additional meetings are going to follow involving the ‘Public’ and ‘Market Surveillance Authorities’. The objective is to get the database operational by 1 January 2019 as requested by the framework Regulation 2017/1369, sticking to its requirements. The Eurovent Team has attended the meeting and summarised its outcome and key results for members.
1st meeting of the ECF Sub-group – Suppliers on the product registration database for EL, 15 September 2017
European Commission DG Energy: Nuij, Tosoratti,
European Commission DG Mobility: Lammens + 5 IT/database colleagues
Member States: BE (2), DK, DE (3 from Fraunhofer), FI, FR (2), IT, NL, PT, SW, UK
Associations: BEUC, CECED (4), CEN, Digital Europe (2), ECOS, EHI (3), EHPA, EPEE, Eurovent, EVIA, Lighting Europe (4), Orgalime, ReUse, Topten
The IT staff explained the first 20 slides of the EPREL assumptions (see GEN 824.02). The architecture of the database (slides 21-25) was not covered.
The European Commission explained the obligations and way in which suppliers can enter data into the database (supplier administrator, organisation, department, users).
The discussion on the contents can be summarised as that the database would stick to the requirements of Regulation 2017/1369 as outlined in the article 12.5. The issue of rescaling will for most products appear at a later stage.
The compliance part of the database is accessible only to Market Surveillance Authorities and to the European Commission. It shall contain the technical documentation. It is possible that a template will be developed to cover the mandatory parts of the technical documentation.
The requests for including additional information into the database has been rejected (especially by NL and IT).
The suggestion to extend the database to products under Ecodesign Regulations is not considered useful at present. It should be noted that Topten has asked if its own database could be integrated into the one of the European Commission.
EHPA asked to refer to certification in the database so that it could also be used to check if products would qualify for incentive schemes. This was rejected because this would open the discussion on the ‘quality difference’ among certification schemes: Some would just be an endorsement of manufacturer declarations others would comply with different modules under decision 2008/768.
It became obvious that the energy labelling of space heaters (2013/813) would be complex because this regulation provides for the labelling of space heater combinations. Each combination would need to figure in the database. The same would apply to products belonging to a range.
Comments can be provided to Nuij, Tosoratti and Lammens until 30 September 2017
Indicative list of future meetings
- 2017-10-24 Ecodesign Consultation Forum (ECF) Sub Group ‘Market Surveillance Authorities’
- 2018-03-15 ECF Sub-group ‘Suppliers’
- 2018-03-31 ECF Sub Group ‘Market Surveillance Authorities’
- 2018-05-15 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’
As mentioned in GEN 810.00, for 7 out 16 regulations dealing with consumer products, the industry association CECED is actively accompanying the development of EPREL. For heating and cooling related regulations, the Fraunhofer Institute has suggested to the Commission to make use of VDI 3085, the heating developments are closely monitored by EHI.
Depending on the speed with which the database EPREL would develop, it may become necessary for companies to prepare for introducing product data (for each product in a range) into the database. This may result in a temporary peak in administrative work when the practical details of the database are finalised. This can be expected from mid-2018 onwards.
Eurovent will indicate to the European Commission that it should stick to the requirements of the Regulation.
It will be a challenge for both the Commission and suppliers to realise the database according to the Regulation on time. Additional data and references (e.g. to certification) would not prove helpful and may provide for confusion.
At present the extension of the EPREL database to products under Ecodesign will not be considered.
Manufacturers of domestic air-conditioners (626/2011), residential ventilation (1254/2014), professional refrigeration (2015/1094), space and water heaters, including heat pumps (811/2013, 812/2013) can timely prepare for the impact of rescaling.
Related documents and links
All related documents and articles can be found in the respective sections in the right side bar.
- GEN 810.00 – Framework Regulation 2017/1369 on Energy Labelling
- GEN 824.01 – Assumptions and questions
- GEN 824.02 – Assumptions (as used during the 2017-09-15 presentation)
- Text of the regulation 2017/1369