Industry paper on the revision of the Ecodesign Directive

CECED, DIGITALEUROPE, EPEE and Lighting Europe welcome the fact that a preparatory study has been carried out to assess the Ecodesign Framework Directive. Nevertheless, our key conclusion is that sufficient grounds do not exist at this point to pursue a revision of the Directive.

We therefore call for the current legislative framework to be maintained, and suggest to focus on initiatives to stimulate the replacement of the installed park of old and less efficient appliances.

Please find our detailed comments as follows.

1. Costs for consumers must be kept at a minimum, while allowing room for innovation

2. It is counterproductive to propose ecodesign regulations for components in products already covered by other ecodesign measures

3. Resource efficiency requirements could only be considered if the reliable, reproducible and enforceable standards to measure them exist

4. Keep energy efficiency as the basis for regulations

5. Mandatory product registration will not solve the problem of market surveillance