Trade association LightingEurope commented on the publication of the Regulation (EU) 2017/1369 setting a framework for energy labeling and repealing Directive 2010/30/EU.
The Regulation establishes deadlines to replace the current A+, A++, A+++ energy efficiency classes with an A to G scale and a product database, consisting of a compliance part and a public online portal.
To apply the new classes, millions of lighting products will need to be relabeled in a short period of time. LightingEurope restates that at least a 24 months period for companies is needed to implement new labels on products, so that unnecessary costs and packaging waste can be avoided.
The Lighting industry asks the Commission to consider the correct boundaries for future energy classes to avoid that the future highest classes remain empty for the next decade.
A delegated act for labeling on lighting products shall be adopted in 15 months which will detail scope, timelines and product classes. LightingEurope will continue to cooperate with the European Commission to provide data on the specifics of the lighting industry and work towards a smooth transition.
LightingEurope will also be taking part in the expert group created by the European Commission, that will set up a product database as of January 2019 to enable market surveillance authorities of Member States to enforce labeling requirements.
In an earlier statement, LightingEurope commented:
The purpose of the energy labeling system as introduced by the EU is to drive the market towards more energy efficient products. So far, the energy labeling legislation for lighting products was focused on consumers. The objectives were 1) to educate consumers on the energy use of the available lamps and 2) to motivate them to choose for the most energy efficient lamp.
With regards to the education purpose, the draft proposal of the new label is counterproductive, as it will only confuse consumers. Lamps that consumers have bought with label A or A+ are now relabeled to G, while the efficiency of the lamp has not changed. Consumers might think “I always thought that I bought the best lamp, and now it is only G. Am I being fooled?”
This is directly related to the motivation of consumers. Since it will demote most lamps to lower energy efficiency classes, little choice will be left for consumers. This takes away the usefulness of the label for a consumer, so energy efficiency will not be considered anymore when buying a lighting product. As a result, the label will be disregarded.
Such a situation is completely the opposite of what is actually envisaged with the idea of an energy labeling system. Therefore, it is recommended to rescale the lm/W values in the proposal to clearer values, so that customers will not get confused or demotivated.