Joint industry position paper on ENER Lot 30

EXECUTIVE SUMMARY

CECED, DIGITALEUROPE EPEE, JBCE and JRAIA call upon the European Commission to carefully consider the provisions set out in the current Working Document for ecodesign requirements for ENER Lot 30, especially with regard to motors included in other products and information requirements for motors which are exempted.

We believe that motors in products, which are already covered by existing ecodesign requirements, should be excluded from the scope of this Lot in order to avoid unnecessary doubleregulation.

Furthermore, information requirements for exempted products should be deleted for motors fully integrated into products that are outside of the scope of Lot 30, as they create an unnecessary administrative burden and could result in the publication of commercially sensitive data.

Lastly, we call upon the Commission to revise the timing of the various implementation tiers to allow for sufficient preparatory time for manufacturers to adapt to the new requirements.