DIGITALEUROPE Comments Energy Efficiency Labelling

Proposal for establishment of a product database

The regulatory proposal suggests that the EU Commission shall establish a database for the following purposes:

(a) to facilitate the market surveillance authorities in carrying out their tasks under this Regulation;

(b) to provide the Commission with up-to-date energy efficiency information of products for reviews of energy labels;

(c) to provide the public with information about products placed on the market, their energy labels and product information sheets;

(d) to enable suppliers to comply with their obligations under Article 3(1a) points (a) and (b)

(e) to enable dealers to comply with their obligations under Article 3(2) point (b) (ii);

DIGITALEUROPE supports the improvement of market surveillance, however we do not believe that the establishment of database would assist with objective (a) above.

On the contrary, the introduction of the product database requirement would undermine the self-declaration principle behind the Energy Label, by introducing a mandatory registration step to the conformity declaration process. DIGITALEUROPE believes this should not be the way forward in establishing a Digital Compliance system in the EU, as already pointed out in the attached position paper.

As also outlined in the conclusions of the EU Parliament initial appraisal of the EU Commission impact assessment, DIGITAL EUROPE questions the balance of stakeholder opinions that have been considered. Industry stakeholders have not been consulted in any potential solution for any of aforementioned purposes. It is not clear why the EU Commission at this moment is of the opinion that a mandatory database is the best way forward.