309
Standards may involve voluntary commitments, such as US Energy Star (US
Environmental Protection Agency 2015 ), or sector voluntary agreements used in the
EU (2009/125/EC), US (US Department of Energy 2015a ), Australia and New Zealand
(E3 2015a ); regulatory requirements, such as EU Energy Using Products (2009/125/
EC) and Energy Labelling Directives (2010/30/EU), and Australia and New Zealand
Minimum Energy Performance Standards (E3 2015b ), and US Federal energy effi -
ciency standards (US Department of Energy 2015b ); or regulatory benchmarks, such as
Japan’s ‘top runner’ programme to ensure all best technologies are adopted over time
according to leading products on the market (Energy Conservation Centre Japan 2015 ).
As technological development and innovation occurs relatively rapidly, energy
effi ciency requirements are typically organised into a succession of chronological
‘tiers’ over which requirements are ratcheted up. To comply producers may either
need to retain technical documentation and test reports showing that their products
meet each of the applicable criteria (as in the EU and Australia), or in some cases
may be required to submit their products themselves for testing and certifi cation (as
under US Energy Star requirements). Non-compliant products may either lose their
certifi cation status and must withdraw or change energy labels used, or ultimately,
if mandatory standards are involved, producers may face fi nes and sales blocks.
The most complex challenge for producers is to understand and keep pace with
the future energy implications of technological development. With the pace of technological advancement, energy effi ciency standards are updated every few years to
ensure improvement vs. ‘business as usual’. Such assessments consider and compare estimates of total energy use for any potential improvements, considering
power consumed, usage time, and number of units of a product in use to calculate
estimates of total electricity consumption (TEC).
To engage in this process, producers need in-depth understanding and available
research on their consumer usage behaviour, and the energy implications of different technology scenarios, to consider energy implications at the early stages of
product development, and also to engage with and gain the understanding of stakeholders such as environmental and consumer NGOs. Predicting power consumption
of future technology 3–4 years in advance, considering the timescales for developing new regulations, involves large amounts of risk for producer. Where it may not
be clear the extent to which a new energy effi cient technology may be suitable, or
what implications it may have, further research and development may be needed.
Unless producers engage in continuous dialogue with policy makers and NGO
stakeholders at an early stage, regulations and standards may be developed based on
only rudimentary understanding of their products and services, which may not
result in optimal solutions to energy effi ciency and may impede innovation.
Compliance with energy standards appears relatively straight forward in comparison to substance compliance (discussed above) and Extended Producer
Responsibility (EPR) (discussed below). This is because standards are uniformly
applied and relatively easy to assess. The challenge for producers is to anticipate
and even infl uence the direction of future energy policy and standards. If producers
are unable to keep pace and comply with these evolving standards, they may be
forced to withdraw many of their products, as recently observed for vacuum cleaners that could not meet 1,800 W power cap within the EU (BBC 2014 ).
16 Practical Implications of Product-Based Environmental Legislation
Standards may involve voluntary commitments, such as US Energy Star (US
Environmental Protection Agency 2015 ), or sector voluntary agreements used in the
EU (2009/125/EC), US (US Department of Energy 2015a ), Australia and New Zealand
(E3 2015a ); regulatory requirements, such as EU Energy Using Products (2009/125/
EC) and Energy Labelling Directives (2010/30/EU), and Australia and New Zealand
Minimum Energy Performance Standards (E3 2015b ), and US Federal energy effi -
ciency standards (US Department of Energy 2015b ); or regulatory benchmarks, such as
Japan’s ‘top runner’ programme to ensure all best technologies are adopted over time
according to leading products on the market (Energy Conservation Centre Japan 2015 ).
As technological development and innovation occurs relatively rapidly, energy
effi ciency requirements are typically organised into a succession of chronological
‘tiers’ over which requirements are ratcheted up. To comply producers may either
need to retain technical documentation and test reports showing that their products
meet each of the applicable criteria (as in the EU and Australia), or in some cases
may be required to submit their products themselves for testing and certifi cation (as
under US Energy Star requirements). Non-compliant products may either lose their
certifi cation status and must withdraw or change energy labels used, or ultimately,
if mandatory standards are involved, producers may face fi nes and sales blocks.
The most complex challenge for producers is to understand and keep pace with
the future energy implications of technological development. With the pace of technological advancement, energy effi ciency standards are updated every few years to
ensure improvement vs. ‘business as usual’. Such assessments consider and compare estimates of total energy use for any potential improvements, considering
power consumed, usage time, and number of units of a product in use to calculate
estimates of total electricity consumption (TEC).
To engage in this process, producers need in-depth understanding and available
research on their consumer usage behaviour, and the energy implications of different technology scenarios, to consider energy implications at the early stages of
product development, and also to engage with and gain the understanding of stakeholders such as environmental and consumer NGOs. Predicting power consumption
of future technology 3–4 years in advance, considering the timescales for developing new regulations, involves large amounts of risk for producer. Where it may not
be clear the extent to which a new energy effi cient technology may be suitable, or
what implications it may have, further research and development may be needed.
Unless producers engage in continuous dialogue with policy makers and NGO
stakeholders at an early stage, regulations and standards may be developed based on
only rudimentary understanding of their products and services, which may not
result in optimal solutions to energy effi ciency and may impede innovation.
Compliance with energy standards appears relatively straight forward in comparison to substance compliance (discussed above) and Extended Producer
Responsibility (EPR) (discussed below). This is because standards are uniformly
applied and relatively easy to assess. The challenge for producers is to anticipate
and even infl uence the direction of future energy policy and standards. If producers
are unable to keep pace and comply with these evolving standards, they may be
forced to withdraw many of their products, as recently observed for vacuum cleaners that could not meet 1,800 W power cap within the EU (BBC 2014 ).
16 Practical Implications of Product-Based Environmental Legislation