Sub-conclusion

40 Ecodesign Directive version 2.0 – From Energy Efficiency to Resource Efficiency

5.2.2 What made it possible to include the durability requirements for vacuum cleaners?

Vacuum cleaners are a good case example in terms of adopting resource efficiency requirements.

However, on other aspects it is perhaps not as good an example. Firstly, the process of setting the requirements was quite lengthy. Secondly, the durability requirements were introduced quite late in the process, and therefore they were not included in the Stakeholder Consultation Forum. Still, there are relevant lessons to learn from this case study, on what made it possible to set these requirements?

The fact that durability was emphasised in the preparatory study laid the basis for including requirements in the implementing measure. As expressed by the policy officer currently involved,

“What is relevant for vacuum cleaners is that the preparatory study already identified that there was an issue of durability with vacuum cleaner” (Deurwaarder 2014). As mentioned earlier, for resource efficiency to be part of and in focus in the preparatory study, it needs to be approached in MEErP. This has been attempted in the study about implementing material efficiency into MEErP and the EcoReport tool. However, as the review of this study also suggested, the alterations and changes made in MEErP and the EcoReport tool are minor. Therefore, they alone will probably not ensure the implementation of resource efficiency requirements into the Ecodesign Directive.

Durability was not proposed in the preparatory study as one of the first impact categories to set requirements to nor were the durability requirements included in the first version of the

implementing measures. The reason why the durability requirements ended up in the final version of the implementing measures anyway might be that resource efficiency had come on the political agenda with the publication of the flagship and roadmap to resource efficiency. Hence, DG Environment might have seen a possibility to push the resource efficiency agenda in the case of vacuum cleaners.

A policy officer from DG Environment indicated that they (DG Environment) played an important role in getting the durability requirements included in the implementing measure, “We have been pushing for the inclusion of durability requirements on the hose and the electric motor that was finally accepted…” (Pekar 2014). Moreover, an industry stakeholder (Edsjö 2014) emphasised the fact that the implementing measure was developed simultaneously with the Energy Labelling also had a positive impact for the implementation of the durability requirements. Because some of the industry stakeholders were interested in getting the Energy Label and in exchange were willing to accept the durability requirements in the implementing measure, “We thought it would be

damaging if they scraped the energy labelling because of the ecodesign, it was a risk as we saw it”

(Edsjö 2014). Hence, the fact that part of the industry was interested in getting the Energy Label, made them more inclined to accept the implementation of durability requirements in the implementing measure.

Finally, it was possible to include the requirement, because there already existed an industry standard for the durability of the motor and for the hose. As expressed by the policy officer, “it was possible (to set the requirements) because there are in fact measurement methods” (Deurwaarder 2014). These standards are important to ensure that the requirements can be measured and verified, and that they thereby are enforceable. However, because the durability requirements were introduced so late in the process there will be an additional study to examine, if the measurement methods are actually the right ones.

Ecodesign Directive version 2.0 – From Energy Efficiency to Resource Efficiency 41 cases it ended up as requirements in the final version of the voluntary agreement and implementing

measure. In other words, it was not only because resource efficiency was included in the preparatory study that resource efficiency requirements were adopted.

The studies also indicated that the resource efficiency requirements were implemented late in the process after pressure from internal and/or external stakeholders. Hence, pressure from these stakeholders was crucial for implementing the resource efficiency requirements. In both cases, the possibility to convince the industry by different means made it possible to include the requirements.

In the voluntary agreement for imaging equipment, it was possible to convince the industry to expand the scope of the agreement, because if they did not accept the voluntary agreement they would be facing regulation. This speaks in favour of voluntary agreements as a platform, where it is easier to include broader environmental parameters, because the industry is interested in avoiding regulation. However, this has not been the case for all voluntary agreements. An example is the voluntary agreement for complex set top boxes, which only includes energy requirements. In the case of vacuum cleaners, parts of the industry were keen on attaining the EU Energy Labelling, and therefore in fear of this falling apart accepted the durability requirements.

In both cases, the requirements were included after resource efficiency had come on the political agenda through the publication of the flagship and roadmap on resource efficiency. Hence, the fact that resource efficiency had come on the political agenda played a role in getting the resource efficiency requirements implemented. The two studies also revealed that the existence of

measurement and test standards and ecolabelling schemes were important for the implementation of resource efficiency requirements. It needs to be measurable requirements that can be enforced and monitored when the products are put on the market, which leads us to one of the challenges in connection with the resource efficiency agenda, namely that some resource efficiency requirements can be hard to measure and thereby enforce. Table 6 provides an overview of the main findings in the two case studies.

Imaging equipment Vacuum cleaners

Resource efficiency was identified as significant

in the preparatory study Durability included in the preparatory study and considered significant

Schemes (Energy Star, EPEAT and Ecolabels) existed already covering resource efficiency requirements

Measurement standard existed on durability of the motor and the hose

Pressure from stakeholders Pressure from DG Environment A wish from the industry to avoid regulation in

the form of implementing measures Willingness from parts of the industry Resource efficiency on the political agenda

TABLE 6 IMPORTANT ASPECTS FOR THE INTRODUCTION OF RESOURCE EFFICIENCY REQUIREMENTS IN THE TWO CASE: THE IMPLEMENTING MEASURE FOR VACUUM CLEANERS AND THE VOLUNTARY AGREEMENT FOR IMAGING EQUIPMENT.

Recommendations:

 Ensure that resource efficiency parameters are included in the preparatory study through changes in MEErP.

 Maintain pressure from the stakeholders and the Commission to include resource efficiency.

 Maintain political attention on resource efficiency.

 Focus on developing measurement standards, test standards and verification measures for resource efficiency.

 Increase collaboration and knowledge sharing between the Ecodesign Directive and the voluntary schemes, such as Energy Star EPEAT and the Ecolabels.

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6. Barriers and Drivers for the