Industry answer to Commission paper on products integrated into other energy related products

Promote innovation instead of double regulation

The issue of setting ecodesign requirements on components integrated in products that are already themselves covered by ecodesign measures is a priority concern for our industry. This recent practice, is endangering freedom to innovate without any benefit for either consumers or the environment.

We believe that this approach is flawed for the following reasons:

1. Manufacturers should be able to choose the best combination of components whilst ensuring the ecodesign requirements for the final equipment are met

2. Regulating components does not necessarily lead to a more energy-efficient products from a least life cycle cost perspective

3. The proposal’s effect on spare parts will endanger their availability, thereby hampering reparability and lifetime of the final product

4. A “one size fits all” approach, when setting requirements for components used in a number of different applications, will not deliver the expected results in terms of energy savings