Discussion Report: EU Ecolabel for...

Discussion Report: EU Ecolabel for Refrigeration

Date September 2008

AEA Energy & Environment


Project summary

The purpose of this pilot project is to link the work of the Eco-design of Energy-using Products (EuP) Directive, with the development of EU Ecolabel criteria. The idea behind this initiative is that with both policy instruments requiring a similar information base for their operation, the work from the EuP preparatory studies can be utilised to develop EU Ecolabel criteria. This would mean that resources would be used effectively, as work will not be duplicated. This study comprises two phases:

1. Firstly, a comparison between two policy instruments, the EU Ecolabel and the Eco-design of Energy-using Products (EuP) Directive.

2. Secondly, utilising the data from the EuP preparatory studies to develop EU Ecolabel criteria. The first phase, now complete, had two purposes:

• To identify the similarities and differences between the two policy instruments commenting on these in terms of whether differences are significant and if so, whether these can be addressed and suggesting how,

• Assuming a positive outcome to the first point, recommending six products from the list of completed EuP Preparatory Studies to take forward to the criteria development process.

The conclusion of the first phase was that the similarities the two policy instruments share, including their development of underpinning life cycle evidence bases and stakeholder consultation means that EuP Preparatory Studies can inform the development of ecolabel criteria. Using a version of the ecolabel product group Prioritisation Methodology previously devised for the Commission’s ecolabel scheme, it identified the six EuP products to take forward into the criteria development process. The six products are:

1. Personal Computers – desktop and computer monitors 2. Personal Computers – laptops 3. Office lighting 4. Domestic lighting 5. Domestic refrigeration 6. Washing machines

Phase two of the project will develop streamlined ecolabel criteria for six product groups, utilising the evidence base gathered for the Eco-design of Energy-using Products preparatory studies. Streamlined criteria will focus on the main environmental impacts EuP products have, and will also cover the environmental impacts not identified in EuP study, but have been highlighted elsewhere as having a significant environmental impact. All criteria documents and discussion papers will be circulated to Competent Bodies and stakeholders. There will be two meetings of the ad-hoc working group (AHWG) for each product group. The timescales for the development of the criteria sets is as follows:

• September 2008 - distribute discussion paper

• 15th – 16

th October and 12

th – 13

th November 2008 - First AHWGs

• April 2009 – distribute second draft of discussion paper and criteria documents

• May 2009 - Second AHWGs

• March 2010 – Final criteria documents

Further information about the work is available from [email protected] and [email protected]


Table of contents

1 Introduction 1

1.1 EuP Directive and preparatory studies 1

2 Product Definition 3

2.1 EuP Definition 3

2.2 Relevant EN ISO standards 3

2.3 Current Ecolabel definition 4

2.4 Proposed definition 4

3 Market Overview 5

3.1 Ownership 5

3.2 EU Production 6

3.3 EU Trade Data 7

3.4 EU Consumption 8

3.5 Stock and energy consumption in EU 25 10

3.6 Other Aspects 13

3.7 Consumer behaviour 16

4 Life cycle impacts 17

4.1 EuP study environmental impact findings 17

5 Proposals for Ecolabel Criteria 18

5.1 Product group definition 18

5.2 Energy Efficiency 18

5.3 Global Warming Impact 19

5.4 Noise 19

6 Possible streamlined criteria 22

6.1 Reduction of ozone depletion potential (ODP) of refrigerants and foaming agents 22

6.2 End of life management 22

6.3 User Instruction 22

6.4 Packaging 23

6.5 Information appearing on the ecolabel 23

6.6 Heavy Metals and Flame Retardants 24

AEA Energy & Environment 1

1 Introduction

This discussion paper for Refrigerators is part of a pilot project to develop streamlined ecolabel criteria for six products groups, by utilising the evidence base gathered in the Eco-design of Energy Using Products (EuP) preparatory studies.

The discussion paper consists of six sections:

• Section 1: introduction to the product and a brief summary of the EuP Directive and EuP preparatory studies

• Section 2: a review of product definitions

• Section 3: presents a summary of economic and market analysis from the EuP preparatory study

• Section 4: present a summary of environmental assessment results from the EuP project team

• Section 5: ecolabel criteria proposals informed by the EuP study

• Section 6: ecolabel criteria proposals for additional criteria that are not covered by EuP, and are based on the current ecolabel criteria

1.1 EuP Directive and preparatory studies

The directive 2005/32/EC on the Eco-design of Energy-using Products (EuP) is a framework for setting eco-design requirements for energy using products. The aim of the Directive is to reduce the environmental impact of energy using products. Those products that are compliant with eco-design requirements will be ensured free movement of products in the EU.

The products covered so far have been chosen based on them meeting the following criteria:

• The product represents a significant volume of sales and trade (more than 200,000 units a year with EC) and,

• The product has a significant environmental impact, and

• The product has significant potential for improvement without entailing excessive costs

For the products that are chosen a preparatory study will be produced. The purpose of a preparatory study is to provide information that the Commission need to know in order to decide if a product should be considered for implementing measured under the EuP. Each preparatory study is structured so that it contains eight stages.

There are several similarities between the data collected for EuP in the eight sections and the evidence base that is required to develop EU Ecolabel criteria. The similarities are that both EuP and EU Ecolabel consider the following aspects:

• Product definition

• Economic and market analysis

• Consumer behaviour

• Technical analysis of existing products Obtaining the above data is a time consuming task, firstly to collect the data and secondly to gain agreement of the work from stakeholder consultation. Developing the preparatory studies takes between 11 and 21 months to complete and therefore to get maximum benefit from the work, the European Commission have commissioned this pilot study to utilise the data collected to develop EU Ecolabel criteria.

It should be noted that whilst the EuP preparatory reports contains useful data from which to propose ecolabel criteria, they do not contain all of the data in the necessary format to develop ecolabel

2 AEA Energy & Environment

criteria. For example, there is information on sales by appliance category, as well as information on the range of energy efficiencies, but what is not included is an overlay of market data on these ranges of energy efficiencies. It is the combination of this data that would allow an assessment of how much of a market place could meet a certain ecolabel criterion. This example applies similarly to other environmental issues.

Any differing data needs between what the EuP preparatory studies provide and what is required for the EU Ecolabel, will be noted in the conclusions from the pilot study. These conclusions can then be used to guide the specification for what should be included in a EuP report.


2 Product Definition

This first section presents a review of the different definition that are currently used to define cold appliances (refrigerators and freezers) across a number of Directive, Standards and Labels, so as to inform what should be the definition to be used in the Ecolabel criteria to be as inclusive as possible.

Lot 13 of the European Commission EuP preparatory studies is for domestic refrigerators and freezers, also known as “cold appliances”. The product definition used for this EuP lot is based mainly on the Energy Labelling Directive 94/2/EC definition.

2.1 EuP Definition

The product definitions that exist for domestic refrigerators and freezers are largely based on European Standards and the Energy Labelling Directive, including the EuP definition, which is based on the Energy Labelling Directive 94/2/EC.

The EuP and Energy Labelling Directive definition for cold appliances is shown in Box 1 below.

Box 1: EuP Definition and Energy Labelling Directive 94/2/EC

� Category 1 - Household refrigerators, without low temperature compartments

� Category 2 - Household refrigerator/chillers, with compartment s at 5 oC and/or 10

oC

� Category 3 -Household refrigerators, with no-star low temperature compartments (< 0 o

C or ice box)

� Category 4 - Household refrigerators, with low temperature compartments (*), (i.e. < 6 oC)

� Category 5 - Household refrigerators, with low temperature compartments (**), (i.e. < 12 oC)

� Category 6 - Household refrigerators, with low temperature compartments (***), (i.e. < 18 oC)

� Category 7 - Household refrigerator/freezers, with low temperature compartments *(***), (i.e. < 18

oC and a freezing capacity of 10Kg/100 litre in 24h)

� Category 8 - Household food freezers, upright

� Category 9 - Household food freezers, chest

� Category 10 - Household refrigerators and freezers with more than two doors, or other appliances not covered above.

Star classification as defined in Directive 94/2/EEC:

2.2 Relevant EN ISO standards

European Standard EN ISO 15502:2005 “Household refrigerating appliances”

The definition of “refrigerating appliances” in the European Standard EN ISO 15502:2005 “Household refrigerating appliances – Characteristics and test methods” is:

Factory assembled insulated cabinet with one or more compartments and of suitable volume and equipment for household use, cooled by natural convection or a frost-free system whereby the cooling is obtained by one or more energy-consuming means.


EN ISO 15502:2005 defines then inter alia the two main types of refrigerating appliances:

• Compression type refrigerating appliances: refrigerating appliances in which refrigeration is effected by means of a motor driven compressor

• Absorption-type refrigerating appliance: refrigerating appliances in which refrigeration is effected by an absorption process using heat as energy source

The main appliances categories are defined as:

• Refrigerators: refrigerating appliance intended for the preservation of food, with one of the compartments suitable for the storage of fresh food

• Refrigerator-freezer: refrigerating appliance having at least one compartment suitable for the storage of fresh food (the fresh food storage compartment) and at least one other (the food freezer compartment) suitable for the freezing of fresh food and the storage of frozen food under three-star storage conditions. Refrigerator-freezers are then classified in:

a. Refrigerator-freezer type I – having a single, user- adjustable temperature control device for regulating the temperatures of the fresh food storage compartment and of the food freezer compartments

b. Refrigerator-freezer type II – having user-adjustable means for the separate regulation of the temperature of the fresh food storage compartment and of the food freezer compartments

• Frozen food storage cabinet: refrigerating appliances having one or more compartments suitable for the storage of frozen food

• Food freezer: refrigerating appliance having one or more compartments suitable for freezing foodstuff from ambient temperature down to a temperature of – 18C and which is also suitable for the storage of frozen food under three-star storage conditions

European Standard EN153 -2006

The European Standard EN153 2006 - “methods of measuring the energy consumption of electric mains operated household refrigerators, frozen food storage cabinet, food freezers and their combinations, together with associated characteristics” defines domestic refrigerators and freezers as “electrical mains operated household refrigerating appliances”.

2.3 Current Ecolabel definition

The other main definition is the existing European Eco-label (2004/669/EC) defines the product group in article 2 as follow:

2.4 Proposed definition

Considering the three definitions as described above, it is clear that the current eco-label definition is the least restrictive, as it currently doesn’t break the appliances out into different types (i.e. refrigerator, freezers and refrigerator/freezer), temperature classes, sizes or shapes. This means that it can remain constant in time and be inclusive of new type of appliances and new technologies.

We propose to keep the current eco-label definition, as it is not contradictory to the EuP definition. This means that the data in the EuP study can be used to make criteria proposals, as the data has been collected under a definition that is inline with the current EU Ecolabel definition.

Box 2 – Ecolabel Definition The product group «refrigerators» shall comprise all electric, mains-operated household refrigerators, frozen food storage cabinets, food freezers and their combinations. Appliances that may also use other energy sources, such as batteries, shall be excluded.


3 Market Overview

The purpose of the EuP project’s market analysis is to gauge whether a product type is significant in terms of sales. The EuP Directive itself identifies sales of 200,000 units per year as signifying a product as being important.

The ecolabel has a slightly different need for market data whereby such information is used to gauge whether a product is applicable equally across the EU or is confined to a handful of member states. It is also important for the ecolabel to understand how the market has been changing over the year and how it might change in the future.

The EuP Task 2 report (Economic and Market Analysis) captures data from PRODCOM and GfK market research database. The following sections summarise the key points made in the report.

Cold appliances are split into 10 categories as follow:

� Category 1 - Household refrigerators, without low temperature compartments

� Category 2 - Household refrigerator/chillers, with compartment s at 5 oC and/or 10

oC

� Category 3 -Household refrigerators, with no-star low temperature compartments (< 0 o

C or ice box)

� Category 4 - Household refrigerators, with low temperature compartments (*), (i.e. < 6 oC)

� Category 5 - Household refrigerators, with low temperature compartments (**), (i.e. < 12 oC)

� Category 6 - Household refrigerators, with low temperature compartments (***), (i.e. < 18 oC)

� Category 7 - Household refrigerator/freezers, with low temperature compartments *(***), (i.e. < 18

oC and a freezing capacity of 10Kg/100 litre in 24h)

� Category 8 - Household food freezers, upright

� Category 9 - Household food freezers, chest � Category 10 - Household refrigerators and freezers with more than two doors, or other

appliances not covered above.

Throughout this report, cold appliances are referred to in term of four categories as follow:Category 1: Refrigerators (which combine all appliance in categories 1 to 6)

Category 7: Refrigerator/ Freezer (which combine all appliance in categories 7 &10)

Category 8: Freezer upright

Category 9: Freezer chest

Please note that unless stated that the data are specifically for EU 15 or EU25, the EuP study has taken into consideration the enlargement of the EU from 15 Member States to 25 countries in 2005.

3.1 Ownership

In Figure 1 below it can be seen that the rate of household ownership for refrigerators across the EU15 in 2004 is saturated, reaching 100% and even beyond, with almost 21% of household owning two refrigerators.

For Freezers, Figure 2 shows that the ownership rate is around 50% and this has been stagnating since 2000. This is supported by a 1 million household growth, which generated just 300,000 units sold for the same period, which lead the authors to estimate that the ownership rate is unlikely to go beyond this in the future.

In Figure 1 and Figure 2 the red line is the linear progression of ownership rate as estimated by the EuP project team. The blue is an illustrative representation of refrigerators stock. The EuP Study report notes that by the year 2005 refrigerator ownership had saturated i.e. that all those households that want one have one. They illustrated this observation via Figure 1 below that includes two different methods to determine ownership. Quite how the study authors derived the data for the graph is not clear, what is important is the fact that both plots show essentially the same information.


Figure 1: Refrigerators ownership (EU – 15)

Source: EuP Lot 13 Task 2 report, table 2-27

Figure 2: Freezers ownership in EU 15


3.2 EU Production Data on the production of refrigerators and freezers in the EU 25 is presented below in Table 1 for countries where information was available, although not all countries reported data. From the data below, largely from 2005, it can be noted that Italy has the highest national production, followed by Spain, Hungary and Germany. It should be noted that the EuP study authors state that the level of uncertainty in the data is unknown.


Table 1: EU-25 Production of refrigerators and freezers, 2005 (‘000 units)

Country Refrigerators Freezers Total

AT 260 270 530

BE 600 75 675

BG (1997) 21 0.8 21.8

CY - - -

CZ 480 - 480

DE 1,150 550 2,050

DK (2004) 1,100 400 1,500

EE (2003) n.a. n.a. n.a.

EL 140* - 140

ES 1,841 379 2,220

FI 15 20 35

FR 60 40 100

IE - 5 5

IT 5,496 1,890 7,386

LV n.a. n.a. n.a.

LT 500* - 500

LU - - -

HU 1,310 780 2,090

MT - - -

NL - - -

PL 1,460 100 1,560

PT (2006) 300* - 300

RO (2006) 800 100

SI (2003) 1,100 250 1,350

SK n.a. n.a. n.a.

SE 305 165 470

UK 721 325 1,046

EU 27 Total 18,009 5,350 23,37 * Refrigerators and freezers Note: in bold 2005 information from US specialised magazine


3.3 EU Trade Data

Table 2 below shows the EU25 trade data in terms of imports and exports for refrigerators in 2005 extracted from Eurostat. For refrigerators we can see that the EU-25 is a net importer in terms of volume with a net import in excess of 7 millions units in 2005. Unfortunately the data reported by the EuP study is based on Eurostat’s data, which is only partially complete as data is missing for freezers, and for “combined refrigerators-freezers, with external doors”. From Table 2, it can be noted that Italy (who are the main producers in Europe as stated above) was by far the largest exported in the EU 25, with 2.7 million units exported, almost 40% of its production. Germany and the UK exported more than 1 million units in 2005. In term of imports, the UK is the largest importer with almost 2.5 million units in 2005, followed by France with almost 2 million units. Spain, Italy and Germany are the only other Member States that have imports in excess of 1 million units in 2005.

This data shows that the European market is significant in term of cold appliances units being manufacture and imported, and the ecolabel could play a major role in ensuring that the environmental impacts of these appliances are minimised.


Table 2: Imports and exports of domestic refrigerators in Europe in 2005 (units)

Refrigerators Exports Refrigerators

imports

AT 37,712 245,481

BE 215,032 551,374

DE 1,084,939 1,705,481

DK 93,980 245,549

GR 178,274 370,911

ES 268,919 1,111,126

FI 7,650 158,397

FR 114,090 1,949,107

IE 11,415 156,924

IT 2,742,093 1,227,220

LU 19,642 16,888

NL 353,535 773,076

SE 514,306 283,301

UK 1,454,559 2,478,255

PT 23,375 156,964

CY 47 28,382

CZ 448,286 384,107

EE 1,796 23,300

SI 429,377 60,741

SK 5,067 69,330

HU 720,522 137,603

MT 17 8,027

LV 6,037 45,228

LT 35,938 24,360

PL 718,721 191,341

Net Intra EU Import values

3,381,651 7,824,075

Source: Source: EuP Lot 13 Task 2 report, table 2-2 and table 2-3

3.4 EU Consumption

The EuP preparatory study uses data extracted from GfK database. The sales data is presented for 2001 and 2004 by energy rating and separating the western from the newer eastern Member States, it should be noted that only countries that reported data for 2002 and 2004 are represented (i.e. four countries for the east). The last column in Table 3 below presents the data for all eight eastern Member States considered by GfK.

The data presented in Table 3 shows that in 2004 the overall sales of refrigerators exceeds 14 millions units (total west plus total east in Table 3). Comparing the data from 2002 and 2004, sales rose by nearly 8% in western Member States and 17% for the eastern states. In essence the refrigerator market is a replacement market.

The sales data also shows a growing dominance of Energy Label A and above classified refrigerators in the market between 2002 and 2004. Energy Label class A represents more than half (56%) of the total EU market, with class A+ representing 5.5% in 2004. This corresponds with a noticeable decrease of Energy Label class B and below on the market, this was especially clear in Eastern Europe where class B represented 58% of the sales in 2002, compared with 32% in 2004.

It should be noted that A+ and A++ categories were added to the Labelling Directive 94/2/EC by the Directive 2003/66/EC in 2003.


Table 3: Refrigerators sales for 2002 and 2004 (units)

Total West Total East

(CZ, HU, PL, SK)

Total East (CZ, EE, HU,

LT, LV, PL, SI, SK)

2002 2004 2002 2004 2004

A++ 5,552 20,811 0 25 25

A+ 125,509 724,853 282 41,140 56,297

A 4,651,801 6,865,883 345,144 932,093 1,138,703

B 4,455,311 3,730,621 761,130 494,211 559,360

C 1,695,030 798,017 193,774 70,694 81,535

D 106,789 40,800 1,692 787 1,002

E 18,626 5,330 357 93 93

F 10,350 1,902 286 1 1

G 13,719 5,973 18 0 1

Unknown 459,304 236,929 12,799 7,157 20,192

Total 11,541,991 12,431,119 1,315,482 1,546,201 1,857,209

Source: Source: EuP Lot 13 Task 2 report, table 2-4

For freezers the data is presented in Table 4 below and shows that a total of 4.17 millions units were sold in 2004 across Member States. An 8% increase of total freezer sales can be seen between 2002 and 2004 for the west. Looking at the breakdown by energy rating, the data for freezers shows a net increase of class A and above (45% of the market), but Class B still represents more than 26% of the market across Europe.

Table 4 Freezers sales for 2002 – 2004 (units)

Total West

Total East (CZ, EE, HU, LT, LV, PL, SI, SK)

2002 2004 2004

A++ 10,380 38,868 27

A+ 67,977 394,515 10,869

A 1,099,347 1,392,590 21,495

B 1,062,780 1,048,746 64,152

C 826,865 766,549 46,630

D 231,020 179,529 31,086

E 207,871 62,742 2,383

F 37,305 14,777 548

G 27,122 11,215 30

Unknown 116,869 82,664 1,266

Total 3,687,536 3,992,194 178,485

Source: Source: EuP Lot 13 Task 2 report, table 2-6

Looking at the type of cold appliances, Figure 3 below shows the split in the market place between the various categories of appliance. It is clear that category 7, refrigerator/freezers have seen a steady increase in market penetration between 1995 and 2005 from ~ 40% to ~60, whilst categories 2, 3, 6 and 10 have all but disappeared.


Figure 3: Spilt of category on the market 1995-2005

Categories 1-6 are refrigerators, Category 7 Refrigerator/freezer, Category 8 Freezers upright, Category 9 Freezers chest, Category ten refrigerators and freezers with more than 2 doors Source: EuP Lot 13 Task 2 report, figure 2.45

The Energy Labelling Directive rating of appliances has had a significant impact on the market, and as the data below in Figure 4 presents, within a ten year period, around 80% of all cold appliances are now rated A or above compared with less than 5% in 1995. A+ rating already represents more than 15% compared with less than 5% for the rating A++. It is worth noting that the current ecolabel criteria require appliances be Class A + and above to qualify, which represents just over 20% of the market in 2005.

Figure 4: Distribution of energy efficiency classes for all categories

Source: EuP Lot 13 Task 2 report, figure 2.54

3.5 Stock and energy consumption in EU 25

The EuP preparatory study estimates the past and current stock for refrigerators and freezers across the EU 25 with the associated energy consumption. The overall estimated energy consumption of the appliances is estimated to be in excess of 100TWh in 2005.

Table 5 and Table 6 show the data for future trends, these are based on a business as usual scenario, which is presented in task 7 of the EuP preparatory study. Business as usual (BaU) scenario was developed on the assumption that cold appliance manufacturers have achieved high technology progress and energy efficiencies in the last 10 – 12 years, driven by a number of mandatory and


voluntary policies within the EU. However the EuP project team argues that future improvements will be harder to achieve and will only be implemented if it is justified by the market demand. It concluded that without new policy measures, there will be no penetration of new technologies in this BaU scenario. The assumptions underlying the scenarios can be found in Box 3 below. The main assumption being that the market share of A+ and A++ appliances gradually increases and dominates the market by 2030.

Table 5: Stock and energy consumption for refrigerators in EU25, business as usual scenario.

Refrigerator stock

Million units

Total Stock energy

consumption GWh/year

Unitary Stock energy

consumption kWh-

appliance/year

1990 151 91,419 606

1995 164 85,761 524

2000 174 80,321 461

2005 182 71,067 391

2009 191 65,596 343

2014 203 59,582 294

2019 213 56,023 263

2025 225 54,098 240

2030 236 49,726 211

Source: EuP Lot 13 Task 7 report, tables 7.15 – 7.17

Box 3 – Business as Usual assumptions

For refrigerators: � Efficiency classes A, A+ and A++ will represent the totality of the market in 2009 � In 2009 class A will account for 70% of the market, class A+ 26% and class A++ 4% � The market share of higher efficiency classes will gradually improve until 2030 when

class A+ appliances will dominate the market with 75% of share and class A++ with 25%

For Freezers:

� In 2005 there was still a significant presence of class B and C models (together representing 50% of the market) and a notable penetration of class A+ (25%)

� In this situation a gradual phase out of class B is expected until 2020, and a parallel significant and steadily penetration of the classes A+ (70% in 2030) and A++ (30% in 2030) appliances.


Table 6 Stock and energy consumption for freezers in EU25, business as usual scenario

Freezer stock

Million units

Total Stock energy

consumption GWh/year

Unitary Stock energy

consumption kWh-

appliance/year

1990 54 39,337 722

1995 67 41,315 621

2000 77 39,810 520

2005 81 34,986 431

2009 85 31,074 366

2014 88 26,651 301

2019 92 24,129 262

2025 97 23,036 237

2030 103 21,745 212

Source: EuP Lot 13 Task 7 report, tables 7.18 – 7.20

Figure 5 below shows that the unitary energy consumption for refrigerators has plummeted since the early 1980. The EuP study calculated that the stock unitary consumption decreased from 839kWh/appliance to 388kWh/appliance reduction of 54%.

For freezer the unitary energy consumption passed from 1,388 kWh/appliance in 1995 to 432 kWh/appliance in 2005, a reduction of 67%.

Figure 5: Refrigerators unitary stock energy consumption trends EU 15 (1995-2005)


Figure 6 shows the maximum, minimum and average annual energy consumption in KWh/year for category 7 (refrigerator/freezers), which is the category dominating the market. It shows that the maximum annual energy consumption for refrigerators was reduced by half between 1999 and 2000, which resulted in a consistent reduction in the average annual consumption between 1998 and 2005. However, it can be noted that the minimum annual energy consumption varied little between 2000 and 2005.


Figure 6: Maximum, minimum and average annual energy consumption for refrigerators-freezers


3.6 Other Aspects

A) Refrigerants

The author of the EuP Lot 13 study stated that the most dramatic changes in technology for cold appliances (refrigerators and freezers), has been the type of refrigerants, which were one of the most important environmental impacts of the appliances, mainly due to their ozone depletion potential (ODP) and global warming potential (GWP). Whilst energy in use is a significant impact, refrigerant properties are also important. The EuP study analysed the CECED database 2005 and found that currently there are just two types of refrigerants agents being used on the market HFC, which is used in less than 10% of the models on the market, and HC which is used in excess of 90% of the model on the market.

� ODP is calculated using CFC11 which has a normalized value of 1 (100 year basis). HFCs have a maximum ODP of 0.11, whereas HC has no ozone depletion potential at all.

� The GWP is calculated using CO2 which has a normalized value of 1 (100 year basis). HFC has a GWP range from 124 to 14,800, and HC has a GWP of less than 3.

Based on the current ecolabel criteria which set a ODP of 0 and a GWP of less than 15, this means that only models that are using HC as a refrigerants can comply with the criteria.


Figure 7: Evolution of refrigerant replacement


C) Purchase Price

As mentioned in section 2.4 within a ten year period, around 80% of all cold appliances are now rated A or above compared with less than 5% in 1995. A+ rating already represents more than 15% compared with less than 5% for the rating A++. This is despite the higher market price for such appliances as shown in Table 7 and Table 8; a class A refrigerator is 25% more expensive than a class B, and a class A+ is more than 50% more expensive. For a freezer the comparison is somewhat lower (Table 8) but still significant with models in class A 15%, and A+ 30% more expensive than class B models.

Table 7: Refrigerators price comparison by category

Total West East E. 4

2002 2004 2002 2004

Weighted average 481 457 360 316

A++ 444 516 N/A 627

A+ 439 534 695 420

A 538 496 394 342

B 4503 392 358 273

C 411 358 308 224


Table 8 Freezers price comparison by category

Total West East E. 4

2002 2004 2004

Weighted average 376 339 288

A++ 717 556 425

A+ 460 458 373

A 437 368 330

B 368 311 284

C 295 253 243



D) Product Storage Volume

The EuP Lot 13 study found that the storage volume of appliances in category 1 (refrigerators) and category 8 (upright freezer) has increased on average by 10% since 1995, but no change for category 7 (refrigerator/freezers) and a slight decrease for chest freezers, as presented in Figure 8. The authors note that a 10% increase in capacity would result in an increase in energy consumption of 4 to 6%.

Figure 8: Capacity development in terms of average net volume


A product development seen in category 7 (refrigerator/freezers) and category 10 (appliances with more than 2 doors) is the use of one thermostat and one compressor. Since this technology improvement has been introduced it represented more than 60% of appliances in category 7 in 2005 compared to none in 1995, as shown in Figure 9. The EuP study failed to state what impact this has on the energy requirement of appliances.

Figure 9: Combination of number of compressors and thermostats in category 7



3.7 Consumer behaviour

For the EuP Lot 13 study, the consultant had an extensive consumer survey completed. Almost 2,500 households were interviewed across ten European Member States (Czech Republic, Estonia, Finland, France, Germany, Hungary, Italy, Poland, Spain, and United Kingdom). The aim of the survey was to identify how cold appliances were used and handled in real life, so that it can be compared with the standard test conditions and to gather a more realistic impression of environmental impact.

The survey confirmed that almost 100% of household have a refrigerator and that 21% reported having a second refrigerator. It also highlighted that the second refrigerator is often older (around 1.4 years older) than the primary refrigerator, and reported that on average refrigerators and freezers are kept for ten years or more.

In parallel the EuP team completed a questionnaire survey with cold appliances manufacturers. The results are presented in task 2 and task 3 of lot 13.

Some of the more interesting findings from this survey were that, when asked which features was a priority for them, both consumers and manufacturers agreed on lower energy consumption for refrigerators and freezers alike. However, when looking at the next top three priorities manufacturers and consumers had different ones:

• Consumer priorities were for fridges lower running costs, easy or automatic defrosting and improve storage possibilities, for freezers there were very similar with easy/ automatic defrosting, lower running costs and very good cooling or freezing performances.

• Manufacturer’s priorities for refrigerators were greater load capacity, improved cooling control and improved storage possibilities. For freezers there were lower price of the appliance, greater load capacity and easy/automatic defrosting.

The survey’s findings thus helps us better understand where the next key development of cold appliances might be in the near future and understand how it might impact on the overall environmental impact of cold appliances. For example for both refrigerators and freezers one of the manufacturers’ priorities is to increase capacity. As mentioned above in section 2.6 d) a 10% increase could result in a 4 to 6% energy consumption increase of appliances.


4 Life cycle impacts

This section presents a summary of the methodology and key findings of the EuP study lot 13 in terms of the environmental impact of refrigerators and freezers. We will be using these finding in section 5 to develop the ecolabel criteria.

The EuP domestic refrigerators and freezer task 5 report identified a base case specification for four appliance types, which can be found in the EuP study task 5 p 34 and 35:

� Refrigerator (category 1) � Refrigerator/freezer (category 7) � Chest Freezer (category 8) � Upright freezer (category 9)

These base case specifications were modelled using the EcoReport LCA tool to establish the environmental impacts for each category. The base case specifications were broadly representative of the EU market average for each category.

The EuP lot 13, task 5 report presents the environmental impact for all four appliance categories. The type of impacts, magnitude and the life cycle phase of the product (production, distribution, use and end of life), are fairly consistent for all four-appliance categories.

4.1 EuP study environmental impact findings

The environmental impact in each of the four categories has been modelled using the EuP Ecoreport. The results are presented to show the impact of all models across the EU-25. The results can be found in the EuP preparatory study task 5 p46 to p 56.

The main findings of the modelling using EuP database for the LCA are presented in Box 4.

Box 4: EuP Ecoreport results summary

� The Production and Use phases are responsible for the majority of environmental impacts;

� For the Use phase, energy consumption and water use are the most relevant (for both process and cooling), while for the Production phase the wastes are more relevant;

� Regarding emissions in air, the Use phase is most relevant for greenhouse gases, and acidification, while for the production phase yields higher impact of Persistent Organic Pollutants (POP), heavy metals and PAHs; and the Distribution phase is important for particulate matter (three times the total of Production and Use Phases) and VOCs.

Source: EuP lot 13, task 5 p 45

The EuP Ecoreport is an LCA software tool specifically developed for use in EuP studies. A number of assumptions were made by the EuP team to complete the LCA and any data gaps were also reported.

To benchmark and validate the results generated using the EuP Ecoreport, the EuP team completed a second LCA based on the category 7base case specification product using the SimaPro software.

The conclusion was that the findings using SimaPro were consistent with the outputs from the EuP Ecoreport; both identified the use phase as having the greatest environmental impacts that are largely attributable to energy consumption. However the significance of the in use phase varied with it being responsible for almost three quarter of all impacts with SimaPro, compared to half using the EuP Ecoreport. The study authors did not consider these differences significant in that the use of one tool rather than the other would not have changed their findings and recommendations.


5 Proposals for Ecolabel Criteria

This section discusses proposals for ecolabel criteria drawing on the data and information available in the EuP Lot 13 study report. It discusses only those issues covered by the work in support of EuP.

Given though that the ecolabel considers a wider range of issues than EuP, these additional aspects are discussed in Section 6 drawing on the criteria development experience for other ecolabelled product groups.

5.1 Product group definition

Based on the review presented in section 2, we are proposing to keep the current eco-label definition, as it is not contradictory to the EuP definition. This means that the data in the EuP study can be used to make criteria proposals, as the data has been collected under a definition that is inline with the EU Ecolabel definition.

Proposed Ecolabel Definition

The product group «refrigerators» shall comprise all electric, mains-operated household refrigerators, frozen food storage cabinets, food freezers and their combinations. Appliances that may also use other energy sources, such as batteries, shall be excluded

5.2 Energy Efficiency

The following options are proposed for discussion with the ad-hoc working group (AHWG):

Option 1 –

Keep the original energy efficiency criterion as in the present EU Ecolabel decision (2004/669/EC).

The appliance must have an energy efficiency class of A+ or A++ as defined in Directive 94/2/EC, and as amended by Directive 2003/66/EC

(It should be noted that the EuP study forecasted that A+ appliances would represent 26% of the market by 2009).

Option 2 –

The appliance must have a minimum energy efficiency class of A++ as defined in Directive 94/2/EC, as amended by Directive 2003/66/EC

(This is based on the EuP study forecast that Energy rating of A++ will to represent 4% of the market by 2009).

The current energy efficiency index for categories A, A+ and A++ as per the Energy Labelling Directive are presented in Table 9.

Table 9: Energy Efficiency Index

Energy Efficiency Index (I) Energy efficiency class

30>I A++

42> I >30 A+

I > 42 A

Source: Commission Directive 2003/66/EC Energy Labelling of household electric refrigerators, freezers and their combination

Proposed criteria

We propose to retain the existing requirement, as the numbers of products sold with an A++ rating remains low at 4%. Given that the award of the ecolabel is dependent on the assessment of additional environmental aspects, the actual numbers of products able to meet an ecolabel specification set at A++ would be somewhat less than 4%.


Assessment and verification: The applicant shall provide a copy of the technical documentation referred to under article 2 paragraph 1 of Commission Directive 94/2/EC as amended by Commission Directive 2003/66/EC. This documentation shall include the reports of at least three measurements of energy consumption made according to EN 153 which itself shall be performed in accordance with the test guidelines as detailed in CECED's Operational Code. The arithmetic mean of these measurements shall be less or equal to the above requirement. The value declared on the energy label shall not be lower than this mean value and the energy efficiency class indicated on the energy label shall correspond to this mean value.

5.3 Global Warming Impact

The current ecolabel criterion on Global Warming applies to the refrigerants circuit and foaming agent used for the insulation of the appliances, and is set at GWP< 15.

As discussed in section 2.6 a), based on the current ecolabel criteria only models using HC as a refrigerants can comply with the GWP and the ODP criterion, in 2005 HC is used in more than 90% of all models on the markets. The global warming potential of HC is less than 3 (over 100 year basis),

Proposed GWP criterion

The findings from the EuP study seems to indicate that the GWP of refrigerants and foaming agent could be set to a lower level then the current GWP 15. We would like to discuss this with stakeholders as what the lower value should be set at.

Assessment and verification: The applicant shall declare compliance of the product with these requirements. The applicant and/of his suppliers, as appropriate, shall indicate to the Competent Body assessing the application which refrigerants and foaming agents have been used and details of their global warming potential.

The question that we would like to put to the AHWG product stakeholders is what is the lowest reasonable limit that can be set for GWP?

5.4 Noise

The current EU Ecolabel for cold appliances sets 40dB as the noise criterion.

The EuP study found that when considering all four appliances categories almost all models have a noise level below 45dB (A). The lowest noise level recorded was 33dB(A), which is classified as a very low.

Figure 10 below shows noise as a function of volume for category 1-6 and Figure 11 for category 7 & 10 (the largest category on the market). The data shows that there are numerous models with noise level below the 40 dB(A) level, and that this holds true for the majority of sizes. Table 10, presents for all appliance categories the minimum, maximum and average for noise and net volume. The data in Table 10, Figure 10 and Figure 11 shows that the average noise is between 37 and 42 dB (A) centering on 40 dB(A).

Considering whether the criterion value could be lowered for noise, it is worth looking back at the findings of the background document supporting the development of the current ecolabel criteria. The following was noted regarding noise:

“ Investigation of the Energie Plus database suggested that a reduction to 40dB(A) was possible but that a reduction below this value would be inadvisable. If the ecolabel were to be pitched at a lower level it would reduce the number of A+ and A++ products able to satisfy the requirement. This is not helpful given that the key criterion for fridges is energy efficiency and that the ecolabel's energy efficiency requirement is already set at a high level”.

It is obviously not in the interest of the Ecolabel to further limit the number of appliances that could be eligible to apply by setting an overly selective noise requirement.


Table 10: Noise for cold appliance categories in CECED 2005 database

Net Volume (litre) dB (A)

Categories Minimum Maximum Average Minimum Maximum Average

1 88 403 231 33 46 38

2 150 390 314 33 40 37

3 67 155 123 35 41 39

4 45 155 91 35 40 38

5 106 290 145 35 44 39

6 118 202 150 34 42 39

7 98 627 277 33 48 40

8 45 335 177 35 45 40

9 57 572 254 37 49 42

10 160 501 289 32 45 40

1-6 45 403 223 33 46 38

7& 10 98 627 277 32 48 40

1 door 98 382 184 32 44 38

2 doors, 1 compr 170 627 292 32 48 41

2 doors, 2 compr 180 522 315 34 44 40

Source: EuP Lot 13 Task 6 report, table 6.4

Figure 10: Noise as function of the total net volume for Categories 1-6 in the 2005 CECED database



Figure 11: Noise as function of the total net volume for Categories 7 & 10 in the 2005 CECED database


Proposed criterion

We suggest that the current criterion of 40dB(A) be lowered to 38.

The measurement of the noise level and the information relating to noise shall be provided in accordance with Council Directive 86/594/EEC (2), using EN 28960 standard.

The question is by setting a lower noise criterion, would that potentially have an impact on:

• The energy efficiency that could be achieved otherwise – it is not clear whether there is a relationship between energy efficiency and noise.

• The number of larger appliances able to meet the ecolabel requirements.

We welcome your views.


6 Possible streamlined criteria

The following criteria are all the criteria within the current Refrigeration EU Ecolabel (minus those in section five). At the first meeting we will discuss which of the following (if any) should be included in the streamlined criteria proposals.

6.1 Reduction of ozone depletion potential (ODP) of refrigerants and foaming agents

The refrigerants in the refrigerating circuit and foaming agents used for the insulation of the appliance shall have an ozone depletion potential equal to zero.

The use of CFCs and HCFCs as refrigerants and for the production of foaming agents in new equipment and their placing on the market is not permitted under Regulation 2037/2000/EC.

6.2 End of life management

6.2.1 Life time extension

The availability of compatible replacement parts and service shall be guaranteed for 12 years from the time that production ceases.

Assessment and verification: The applicant shall declare compliance with this requirement.

6.2.2 Take-back and recycling

The manufacturer shall offer free of charge, the take-back for recycling of the appliance and of components being replaced, except for items contaminated by users (e.g. appliances originating from medical or nuclear establishments).

In addition, the appliance shall meet the following criteria::

• The manufacturer shall take into account the disassembly of the appliance and provide a disassembly report. Amongst others, the report shall confirm that:

� Joints are easy to find and accessible,

� Electronic assemblies are easy to find and to dismantle,

� The product is easy to dismantle by using commonly available tools,

� Incompatible and hazardous materials are separable.

• Plastic parts heavier than 50 grams shall have a permanent marking identifying the material, in conformity with ISO 11469. Excluded from this criterion are extruded plastic parts.

• Plastic parts shall not contain PBB or PBDE flame retardants. Plastic parts shall not contain chloroparaffin flame retardants with chain length 10-13 carbon atoms and chlorine content > 50 % by weight (CAS No 85535-84-8). The applicant shall declare compliance with this requirement.

• The type of refrigerant and foaming agent used for the insulation shall be indicated on the appliance, near to or on the rating plate, to facilitate possible future recovery.

Assessment and verification: With reference to the above the applicant shall declare compliance of the appliance with these requirements. The applicant shall provide the Competent Body assessing the application with a copy of the disassembly report. The applicant and/or his supplier or suppliers, as appropriate, shall indicate to this Competent Body, which refrigerants and foaming agents have been used.

6.3 User Instruction

The appliance shall be sold with an instruction manual, which provides advice on the correct environmental use and, in particular:


• The following text on the cover page or first page: «Information on how to minimise environmental impacts is given in this manual.»

• Recommendations for optimal use of energy in the operation of the appliance, including:

o Guidelines concerning the placing or installation of the appliance, amongst others, stating the minimum dimensions of free space around the appliance needed to ensure sufficient circulation of air, and also indicating that where the consumer has the possibility, significant energy savings can be achieved by placing the appliance in an unheated or less heated location;

o Advice that the consumer should avoid placing the appliance next to any heat source (such as ovens, radiators, etc.) or in direct sunlight; advice that, where relevant, the consumer should consider insulating the appliance from wall or under floor heating sources;

o advice that the thermostat setting is dependent on the ambient temperature and therefore, the temperature setting should be checked by using an appropriate thermometer (explanation on how to proceed should be provided);

o Advice that hot foodstuffs should be allowed to cool down before placing in the appliance, as the steam from the foodstuffs contributes to the icing up of the evaporator unit, but that the cooling period, however, should be as short as possible for health and hygiene reasons;

o Advice that the evaporator unit should be kept clean from thick layers of ice and that frequent defrosting facilitates the removal of the ice cover;

o Advice that the sealing of the door should be replaced when not functioning properly;

o Advice that when moving the appliance sufficient time should be allowed before switching it on again;

o Advice that the condenser on the back of the appliance and the space underneath the appliance should be kept clean from dust and kitchen debris;

o Information that ignoring the issues mentioned above will lead to higher energy consumption and therefore higher running costs.

• Advice that any damage to the condenser (heat-exchanger) on the back of the appliance, or other events leading to exposure of the refrigerant to the environment, should be avoided because of potential environmental and health risks. The manual shall specifically mention that sharp objects (such as knives, screwdrivers, etc. should not be used for removing ice as they could damage the evaporator unit.

• Information that the appliance is made of parts and materials, including fluids, which are reusable and/or recyclable.

• Advice on how the consumer can make use of the manufacturer's take-back offer.

Assessment and verification: The applicant shall declare compliance of the appliance with these requirements. The applicant shall provide the Competent Body assessing the application with a copy of the instruction manual.

6.4 Packaging

Packaging shall meet the following requirements: a) All packaging components shall be easily separable by hand into individual materials to facilitate recycling b) Where used, cardboard packaging shall consist of at least 80% recycled material Assessment and verification: The applicant shall declare compliance with the requirement and provide a sample(s) of the packaging to the awarding Competent Body as part of the application.

6.5 Information appearing on the ecolabel

Information appearing on the eco-label:


Box 2 of the eco-label shall include the following text:

• low energy consumption,

• minimised global warming potential,

• low noise.

Assessment and verification: The applicant shall declare the compliance of the product with this requirement, and shall provide a copy of the eco-label as it appears on the packaging and/or product and/or accompanying documentation.

6.6 Heavy Metals and Flame Retardants

If a criterion on heavy metals and flame-retardants was to be included in the revised ecolabel criteria for Refrigeration, it is likely that the same proposal as for the Television Ecolabel would be put forward. The draft for which is as follows:

(a) Cadmium, lead, mercury, chromium 6+ or poly-brominated biphenyl (PBB) or poly-brominated diphenyl ether (PBDE) flame retardants, as listed in Article 4(1) of Directive 2002/95/EC of the European Parliament and of the Council, shall not be used in the television unless the applications of those substances are listed in the Annex to that Directive as exempted from the requirements of Article 4(1) of that Directive or unless their maximum concentration value is equal or lower to the threshold specified in that same Annex. For PBBs and PBDEs the maximum concentration value shall be <0.01%.

(b) Plastic parts shall not contain flame retardant substances or preparations containing substances that are assigned or may be assigned, at the time of application, any of the following risk phrases:

· R45 (may cause cancer),

· R46 (may cause heritable genetic damage),

· R50 (very toxic to aquatic organisms),

· R51 (toxic to aquatic organisms),

· R52 (harmful to aquatic organisms),

· R53 (may cause long-term adverse effects in the aquatic environment),

· R60 (may impair fertility) or

· R61 (may cause harm to the unborn child),

as defined in Council Directive 67/548/EEC. This requirement does not apply to flame retardants that on application change their chemical nature to no longer warrant classification under any of the R-phrases listed above, and where less than 0.1 % of the flame retardant in the treated part remains

Assessment and verification:

The flame retardants that are used, if any, shall not have been assigned any of the above risk phrases nor shall they be named in Annex 1 to Directive 67/548/EEC or its subsequent amendments regarding the classification, packaging and labelling of dangerous substances. Any flame retardants that are used in plastic parts >25g must be specified in the application documentation by giving their name and CAS number.


The Gemini Building Fermi Avenue Harwell International Business Centre Didcot Oxfordshire OX11 0QR Tel: 0845 345 3302 Fax: 0870 190 6318 E-mail: [email protected],uk

www.aea-energy-and-environment.co.uk

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