Product energy efficiency: now we can do anything, what should we do next?

12 October, 2020

Reading time: 5 minutes

Fiona Brocklehurst

Ballarat Consulting, CREDS associate

A recent BEIS call led CREDS associate Fiona Brocklehurst to explore the energy saving potential of a range of policy options.

The Department for Business, Energy & Industrial Strategy (BEIS) issued a call for evidence on energy related products in the summer and I co-ordinated CREDS’ response.

Energy related products are defined as energy-using products, for example lighting, heating and cooling, appliances, motors, and products that affect energy use such as windows, tap and showers. Of the many policy tools available to increase the sustainability of energy related products, in the last decade or so the UK Government has chosen to rely almost completely on two EU-wide policies.

Once the UK concludes withdrawal from the EU at the end of this year, what should happen next, given that the Government’s intention is to go further than EU regulations? The BEIS consultation focused on current policy, framed by these two EU regulations.

  • Ecodesign regulations – which set minimum performance standards for products. These largely relate to on energy but also sometimes other factors, for example a minimum lifetime for light-emitting diodes (LEDs). They also have the potential to set requirements relating to aspects of a product’s resource efficiency, such as durability, repairability, recyclability and ease of material recovery.
  • Energy labels – which require information to be provided at the point of sale in a standard format – always on energy or energy efficiency but also sometimes on other information such as dimensions of the product, cleaning performance or noise output.

There’s also one UK specific policy – the Energy Technology List (which applies to energy related products in non-domestic use) which was covered in a separate consultation.

This, then, is one of the multitude of policy areas upon which the UK Government needs to decide its agenda following the end of the transition period from the EU. The call for evidence was explicitly intended to feed into this process. BEIS recognised that this is an important topic for climate targets and for the sustainability agenda more generally, quoting that these “are important as energy-related products account for approximately 55% of total (non-transport) energy use in the UK”.

Many of the questions in the call related to particular product groups. In particular whether there is scope to set better Ecodesign requirements for products that have already been regulated at an EU level (the UK Government’s stated intention is to raise ambitions for these regulations beyond those adopted in the EU), and whether to increase the coverage for Ecodesign and energy labels by adding new products for the UK. CREDS colleagues contributed valuable technical information and expert opinion on some of these – as you can see in the complete response.

I, with support from Brenda Boardman, Nick Eyre, and Tina Fawcett, concentrated on the broader topics of the call:

  • how energy labels can be made more useful for consumers
  • how UK market surveillance activities can be made more effective in ensuring regulatory compliance
  • whether additional policy levers could be considered to increase the energy, carbon and resource efficiency potential of energy-related products.

We also chose to submit evidence on the bigger question which was not included in the call for evidence – what should the UK Government’s priorities be for policies on energy related products, once outside the EU?

In summary, CREDS proposed that there are three major options for the UK in order to increase energy savings from products. These are:

  1. enhanced enforcement of the existing regulations
  2. using existing regulations as a basis for additional UK-specific policy action
  3. developing UK-specific regulations.

The expense, complexity and time taken to fully realise savings from these options increases markedly moving from option 1 to option 3 (Table 1). Our response argues that there is considerable scope for energy savings even from simply improving enforcement of the existing ecodesign and energy label regulations in the UK. A particular area of concern is that the UK appears not to be checking compliance of the energy label online or in store, as this reduces the effectiveness of the energy label to change consumer behaviour. There is also room for improvement in terms of ecodesign market surveillance: so together these should increase the effectiveness of existing policies at relatively low cost.

In addition, there are considerable risks to UK consumers and manufacturers in moving away from EU standards (option 3).

We strongly recommended fully exploiting the savings potential of options 1 and 2 before considering option 3.

Table 1: Three possible options to increase energy savings from energy using products
Option Timescale to implement Cost (£) to implement Actors and skills needed Risks
1. Enhanced enforcement Months Tens to hundreds of thousands Office for Product Safety and Standards, Local authority trading standards None
2. Additional supporting policy Months – years Depends on policy, less than option 3 Central government, policy makers, technical expertise Resistance from business, depending on measure
3. UK-specific regulations 4 years plus Several million Central government policy makers, deep technical expertise Serious trade issues, additional costs to UK consumers, additional costs to manufacturers.

These policy options are all described in detail with supporting evidence in the full response from CREDS.

Banner photo credit: Peter Geo on Unsplash

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