AIR CONDITIONING
All manufacturers are required to publish the energy performance of their products in their technical manuals on the free access area of their websites. By making this information freely available it allows end users to make an informed choice when comparing products from two different manufacturers, taking into account total cost of ownership as opposed to capital costs alone. However, almost two years in to the
implementation of Ecodesign is everyone playing by the rules and how are the regulations being enforced?
Each country within the EU has a designated Market Surveillance Authority (MSA) responsible for enforcing Ecodesign. In the UK, the Office for Product Safety and Standards (OPS&S), formerly Regulatory Delivery (RD), is furnished through Ecodesign with the power to impose civil sanctions and to recover testing costs where infringements on the regulations occur. However, the OPS&S is a small team responsible for policing a whole range of regulations, not just Ecodesign. It is a risk-based regulator, meaning that it focuses on those areas which present the greatest risk to its regulatory objectives. For example, in July of this year the OPS&S issued a recall notice to a tumble drier manufacturer concerning the installation
of potentially unsafe appliances in homes across the UK. Often, infringements of the Ecodesign regulations must take a back seat when public safety issues like this occur.
What is certainly clear is that some
manufacturers are shirking their Ecodesign responsibilities, bending or ignoring the rules in order to potentially place non-compliant products on the market. Also, with the responsibility of compliance being on manufacturers, contractors, specifiers and end-users are often unaware, ill- informed or able to wilfully ignore the regulations without consequence. Not publishing the required energy performance data is the most common issue among manufacturers. This can perhaps be put down to an oversight, but when it is coupled with products being sold that are technically suspicious – in terms of stating energy efficiency ratings that would be difficult to meet given the design of the product – then it becomes a more sinister issue. The OPS&S has shown a mixed response to this issue. There is a high burden of proof within the policing of the regulations, so in many cases its hands are tied. Also, once a piece of equipment is installed, it is difficult to prove its performance either from an output or efficiency perspective given it is usually part of a larger system. The
OPS&S can intervene when the required data is not available on the manufacturer’s website, but it has no jurisdiction over foreign manufacturers. With the UK being served by many overseas-based manufacturers of air conditioning equipment, it is a common problem. In these cases all the OPS&S can do is refer the issue to its overseas counterparts, who may be slow or unwilling to enforce. The Ecodesign Directive is a ‘game changer’ and was introduced for the right reasons; to help the European Union slow down global warming by achieving its energy efficiency and carbon emissions targets. Air conditioning manufacturers rightfully come under the microscope given the nature of the products they produce. We should all be committed to limiting the environmental impact of our
products by reducing their energy consumption and impact on the planet.
What we need now is a level playing field, allowing the manufacturers who do display a proactive stance to the Ecodesign regulations to still be able to compete commercially. This requires not just the OPS&S, but the whole supply chain from end-users down to contractors, to be aware of the regulations and their responsibilities and ensure that as an industry we respect both the regulations that govern us and the planet we live on.
Elitech
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