Energy Efficiency Labelling of Household Appliances ... - RELEEL

Ministry of Economy,
Labour and Energy
Republic of Croatia
CARDS 2004
RELEEL
APPROXIMATION OF EU RENEWABLE ENERGY LEGISLATION AND
ENERGY EFFICIENCY LABELLING
REPUBLIC OF CROATIA
Feasibility Study for Energy Efficiency Labelling Certification Body
Consortium of:
RELEEL
Energy Efficiency Labelling of
Household Appliances
FEASIBILITY STUDY
Version: 6 Date: February 2009 Page I/16
iC consulenten ZT GesmbH
Schönbrunner Straße 297
1120 Vienna, Austria
tel. +43 (1) 521 69-0
fax +43 (1) 521 69-180
a.helbl@ic-group.org
February 2009
M:\27_ENE\07136_CROATIA_RENEW_ENERG3\4_DOKS\42_AUS_DOKS\LABELLINGREPORT\090217_REPORT_APPLIANCELABELLING_FINALDRAFT.DOC

EU RENEWABLE ENERGY LEGISLATION & ENERGY EFFICIENY LABELLING
Feasibility Study on EE Labelling Certification Body February 2009
CONTENT
1. The Energy Label ...............................................................................................1
1.1 Overview..............................................................................................................1
1.2 Addressed Household Appliances........................................................................1
1.3 The Labelling Obligation.......................................................................................2
2. The Role of a National Certification Body ........................................................3
2.1 Laboratory, Certification, Notification....................................................................3
2.2 Requirements from EU Directive ..........................................................................4
2.3 Other Tasks of Certified Testing Laboratories ......................................................4
2.4 European and Worldwide Dimension ...................................................................5
3. Implementation of the Directive in the EU – examples of Austria and
Germany .............................................................................................................6
4. The Situation in Croatia .....................................................................................7
4.1 Existing Legal framework .....................................................................................7
4.2 Existing institutional framework ............................................................................8
4.3 Problems Encountered Earlier and Current Status...............................................8
4.3.1 Field tests results .................................................................................................9
4.3.2 Implementation Questionnaire..............................................................................9
4.3.3 Questionnaire Results........................................................................................10
4.3.4 Findings .............................................................................................................12
5. Recommendation for Croatia ..........................................................................12
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1. THE ENERGY LABEL
1.1 OVERVIEW
The Energy Efficiency Label is a mandatory consumer information
on electric household appliances sold, hired or hire-purchased in
EU countries according to the Council Directive 92/75/EEC of 22
September 1992 on the indication by labelling and standard product
information of the consumption of energy and other resources
by household appliances 1 . It is featured as a self-sticking paper
label showing the energy efficiency information of the appliance.
The legal basis for appliance labelling is given with several directives
of the European Union in order to support the purchase and
the development of efficient electric household appliances.
The member states have implemented these directives into national
regulations and so did Croatia, which will be elaborated in
the following chapters.
The label shows characteristic parameters of the labelled appliance,
e.g. concerning the energy consumption, the water consumption,
the usable volume capacity, the cleaning performance
or the spinning performance.
The important issue in labelling is the classification of the appliance into energy efficiency
classes from “A” to “G” (refrigerators and freezers from “A++” to “G”). The assigned efficiency
class is additionally marked with a distinct colour. Thus, the client is able to make an easy,
fast and direct comparison of various types. Therefore, all presented appliance types in a
dealer’s showroom have to be labelled.
The main goal of the label is to inform the market. Other legislation like for instance Directive
2005/32/EC of the European Parliament and of the Council of 6 July 2005 2 establishing a
framework for the setting of eco-design requirements for energy-using products deals with
the eco-design requirements for products. This is part of the IPP, the Integrated Product Policy
of the European Union 3 .
1.2 ADDRESSED HOUSEHOLD APPLIANCES
Figure 1: Label for
lamps as example for
energy label. Source:
directive 98/11/EC
The labelling in compliance with 92/75/EEC is statutory for nine types of electric household
appliances:
- Refrigerators, Freezers and their Combinations 4
- Washing Machines 5
1
OJ L 297, 13.10.1992, p. 16, last amended by Regulation (EC) No 1882/2003 of 29 September 2003, OJ L
284, 31.10.2003, p. 4
2
OJ L 191, 22.7.2005, p. 29; last amended by Directive 2008/28/EC of 11 March 2008, OJ L 81, 20.3.2008, p.
48
3
http://ec.europa.eu/enterprise/eco_design/index_en.htm
4
Commission Directive 94/2/EC of 21 January 1994, OJ L 45, 17.2.1994, p. 1; last amended by Commission
Directive 2006/80/EC of 23 October 2006, OJ L 362, 20.12.2006, p. 67
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- Electric Tumble Driers 6
- Combined Washer-Driers 7
- Dishwashers 8
- Electric Ovens 9
- Air-Conditioners 10
- Lamps 11
The labelling of vacuum cleaners and electrical water boilers has been under discussion in
2007 12, 13 . The energy efficiency labelling of water boilers has been introduced in the Czech
Republic only.
By a regulation the European Union implemented in 2008 a programme for the energyefficiency
labelling of office equipment 14 (the Energy Star programme 15 ) in a similar manner
as the Eco label scheme 16 , which was established by regulation 17 in 2000. Both programmes
are not mandatory for manufacturers and suppliers.
Besides the energy-efficiency labelling the European Union also sets up minimum energy
efficiency requirements for
- Fluorescent Lighting 18
- Electric Refrigerators, Freezers and Combinations thereof 19
- Hot-Water Boilers fired with liquid or gaseous fuels 20
- Household and Office Equipment in Standby and Off Mode 21
1.3 THE LABELLING OBLIGATION
Based on the EU directives, the supplier (the manufacturer or his authorized representative)
is responsible to submit specific data of the energy efficiency class of his appliance. All data
given on the label and datasheet are to be appraised after the relevant regulations of harmonised
European standards.
5 Commission Directive 95/12/EC of 23 May 1995, OJ L 136, 21.6.1995, p. 1; last amended by Commission
Directive 2006/80/EC of 23 October 2006, OJ L 362 20.12.2006, p. 67
6 Commission Directive 95/13/EC of 23 May 1995, OJ L 136, 21.6.1995, p. 28; last amended by Commission
Directive 2006/80/EC of 23 October 2006, OJ L 362, 20.12.2006, p. 67
7 Commission Directive 96/60/EC of 19 September 1996, OJ L 266, 18.10.1996, p. 1; last amended by Commission
Directive 2006/80/EC of 23 October 2006, OJ L 362, 20.12.2006, p. 67
8 Commission Directive 97/17/EC of 16 April 1997, OJ L 118, 7.5.1997, p. 1; last amended by Commission
Directive 2006/80/EC of 23 October 2006, OJ L 362, 20.12.2006, p. 67
9 Commission Directive 2002/40/EC of 8 May 2002, OJ L 128, 15.5.2002, p. 45; last amended by Commission
Directive 2006/80/EC of 23 October 2006, OJ L 362, 20.12.2006, p. 67
10 Commission Directive 2002/31/EC of 22 March 2002, OJ L 86, 3.4.2002, p. 26)
11 Commission Directive 98/11/EC of 27 January 1998, OJ L 71, 10.3.1998, p. 1; last amended by Commission
Directive 2006/80/EC of 23 October 2006, OJ L 362, 20.12.2006, p. 67
12 „Das Energielabel für Elektro-Hausgeräte“, published by ZVEI, Frankfurt am Main, Juli 2007.
13 http://ec.europa.eu/enterprise/electr_equipment/legislat.htm
14 Regulation (EC) No 106/2008 of 15 January 2008, OJ L 39, 13.2.2008, p. 1
15 http://www.eu-energystar.org/de/index.html
16 http://ec.europa.eu/environment/ecolabel/index_en.htm
17 Regulation (EC) No 1980/2000 of 17 July 2000, OJ L 237, 21.9.200, p. 1
18 Directive 2000/55/EC of 18 September 2000, OJ L 279, 1.11.2000, p. 33 last amended by Directive
2008/28/EC of 11 March 2008, OJ L 81, 20.3.2008, p. 48
19 Directive 96/57/EC of 3 September 1996, OJ L 236, 18.9.1996, p. 36; last amended by Directive 2008/28/EC
of 11 March 2008, OJ L 81, 20.3.2008, p. 48
20 Directive 92/42/EEC of 21 May 1992, OJ L 167, 22.6.1992, p. 17; last amended by Directive 2008/28/EC of 11
March 2008, OJ L 81, 20.3.2008, p. 48
21 Commission Regulation (EC) No 1275/2008 of 17 December 2008, OJ L 339, 18.12.2008, p. 45
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The supplier has to provide the data label to the dealer free of charge.
The energy efficiency label (see figure 1) consists of a general coloured label, which is independent
and neutral from the supplier. Every dealer can obtain these from a national service
point free of charge (Germany), while the appliance’s supplier is obliged only to provide the
data label, specifying his appliance’s data.
All for purchase offered appliances in the dealer’s showroom have to be labelled. In case of
non-labelling the dealer is to be punished by a fine or dissuasion.
The label has to be placed at the appliances front or top outside, clearly visible and not covered.
This is also valid for built-in types. In case of teleshopping, internet shopping, catalogue
selling or other non-direct selling of appliances the dealer has to guarantee, that potential
purchasers are informed before conclusion of a contract.
2. THE ROLE OF A NATIONAL CERTIFICATION BODY
2.1 LABORATORY, CERTIFICATION, NOTIFICATION
This chapter is thought to be a short glossary to define the used terminology.
When speaking about a certification body for energy efficiency it comes down to a testing
laboratory, which is able to execute energy tests according to the appropriate standards and
issue a test report.
Customers of a testing laboratory could be for example:
▪ Manufacturers of household appliances, who do not have a testing laboratory of their
own
▪ Public market surveillance, who wants to proof the manufacturers’ specifications to protect
end users against incorrect indications and other market participants against advantage
in competition by wrong advertising messages
▪ Competitors, who want to make sure, that an other market participant does not gain
advantage by wrong statements
▪ End users (e.g. consumer rights protection agencies), who want to recheck the manufacturers’
specifications
In any case the test report shall be accepted as certificate in court, whenever someone goes
on trial. Therefore the testing laboratory shall be accredited by a certifying body to be independent
and carry out tests in compliance with appropriate standards (e.g. ISO/IEC 17020 22 ,
ISO/IEC 17021 23 , ISO/IEC 17024 24 , ISO/IEC 17025 25 , ISO 15189 26 , and EN 45011 27 ).
22 EN ISO/IEC 17020:2004 – General criteria for the operation of various types of bodies performing inspection
23 ISO/IEC 17021:2006 – Conformity assessment - Requirements for bodies providing audit and certification of
management systems
24 ISO/IEC 17024:2003 – Conformity assessment - General requirements for bodies operating certification of
persons
25 ISO/IEC 17025:2005 – General requirements for the competence of testing and calibration laboratories
26 ISO 15189:2007 – Medical laboratories – Particular requirements for quality and competence
27 EN 45011:1998 – General requirements for bodies operating product certification systems (ISO/IEC Guide
65:1996)
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EU RENEWABLE ENERGY LEGISLATION & ENERGY EFFICIENY LABELLING
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Certifying bodies are usually public institutions like federal ministries or already established
federal institutes nominated by national laws.
A testing laboratory, which is accredited by a certifying body, is a certified body.
Notification is an act whereby a Member State (its certifying body respectively notifying authority)
informs the Commission (of the EU) and the other Member States that a body, which
fulfils the relevant requirements, has been designated to carry out conformity assessment
according to a directive. Notification of Notified Bodies and their withdrawal are the responsibility
of the notifying Member State.
Lists of EU directives, which require notified bodies, and lists of notified bodies as well as
notifying authorities can be found on the NANDO (New Approach Notified and Designated
Organisations) web site 28 .
2.2 REQUIREMENTS FROM EU DIRECTIVE
Based on the EC Directive 92/75/EEC and its daughter regulations the authorities have primarily
to assume that suppliers’ labelling statements on appliances’ energy efficiency is correct.
The EU member states are obliged to implement the directive into national legislation.
There is no explicit obligation to create a national certification body with regard to energy
efficiency.
Nevertheless it makes sense to install a body, which is accredited and certified to carry out
independent energy efficiency tests for the purposes pointed out in the chapter above. This
might be a national testing laboratory, a state inspectorate or even a foreign testing laboratory
(if the amount of tests expected will not cover the necessary investment).
2.3 OTHER TASKS OF CERTIFIED TESTING LABORATORIES
Within European countries it is statutory for electrical appliance suppliers
to apply certain safety marks (CE, ÖVE, DVE, ENEC or similar)
on their products, showing evidence that the appliance has been
tested in order to state the conformity to national and international
norms and standards. These tests are consisting of lab testing of
appliance types and of factory inspections according to ISO/IEC
17020 29 . A safety mark represents therefore a safety certificate and
a test report.
Furthermore, in the field of electro-technological safety at least the
EC Directives
- 2006/95/EC – Low Voltage Directive 30
- 2004/108/EC – Electromagnetic Compatibility (EMC) 31
Figure 2: Some national
safety marks
for electrotechnical
products
28 http://ec.europa.eu/enterprise/newapproach/nando/index.cfm?fuseaction=notifiedbody.main
29 EN ISO/IEC 17020:2004 – General criteria for the operation of various types of bodies performing inspection
30 Directive 2006/95/EC of 12 December 2006 on the harmonisation of the laws of Member States relating to
electrical equipment designed for use within certain voltage limits, OJ L 374, 27.12.2006, p. 10
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do require an accredited certification and inspection body, which are notified (“Notified Body”)
to the European Commission by the member states.
A list of Notified Bodies in EU member states for EMC can be found on the EC website 32 .
Some examples for Notified Bodies are: OVE Testing & Certification (Austria), VDE Prüf- und
Zertifizierungsinstitut (Germany), TÜV (Germany, Central Europe), SGS (Switzerland).
However, within the field of energy efficiency of appliances there is no certified body in Austria
and Germany. Nevertheless the mentioned Notified Body OVE 33 will carry out energy
efficiency tests as an independent third party.
2.4 EUROPEAN AND WORLDWIDE DIMENSION
CENELEC, the European Committee for Electrotechnical Standardisation, deals with standards
in the electrotechnical field.
The topic of Energy Efficiency in Standardization has been addressed within the Communication
’Integration of Environmental Aspects into European Standardisation’ adopted by the
Commission on 25 February 2004 and presented to the Council, the European Parliament
and the European Economic and Social Committee 34 .
However, the Second Strategic Energy Review “Securing our Energy Future” (Energy Efficiency
Package, November 2008) has again addressed the topic. On 13 th November 2008
the European Commission has come up with the proposal for a directive on the indication by
labelling and standard product information of the consumption of energy and other resources
by energy-related products 35 :
The aim of the recast of Council Directive 92/75/EEC of 22 September 1992 on the indication
by labelling and standard product information of the consumption of energy and other resources
by household appliances and repealing Directive 79/530/EEC, hereafter referred to as
the “Energy Labelling Directive” or “ELD”, is to extend its scope, currently restricted to
household appliances, to allow for the labelling of all energy-related products including the
household, commercial and industrial sectors and some non-energy using products such as
windows which have a significant potential to save energy once in use or installed (means of
transport are excluded).
In the United States the topic of energy efficiency at appliance labelling
was addressed within the Rule concerning disclosures regarding energy
consumption and Water Use of Certain Home Appliances and Other Products
Required Under the Energy Policy and Conservation Act (“Appliance
Labelling Rule”), Federal Register: April 3, 2000 (Volume 65, Number 64),
Rules and Regulations, Page 17553-17579 with regard to the ENERGY
Figure 3: Energy
Star label
STAR, a label created by the U.S. Environmental Protection Agency and the U.S. Department
of Energy to help consumers save money and prevent air pollution. However, the
31
Directive 2004/108/EC of 15 December 2004 on the approximation of the laws of the Member States relating
to electromagnetic compatibility, OJ L 390, 31.12.2004, p. 24
32
http://ec.europa.eu/enterprise/electr_equipment/emc/cblist.htm
33
http://www.ove.at/
34
COM(2004) 130 final; http://ec.europa.eu/enterprise/standards_policy/environment_standardisation/ index.htm
- chapter 4.4.3
35
COM(2008) 778 final; http://ec.europa.eu/energy/strategies/2008/2008_11_ser2_en.htm
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ENERGY STAR has often been criticized to have only small impact, because of the missing
verification of criteria and the missing classification.
3. IMPLEMENTATION OF THE DIRECTIVE IN THE EU – EXAMPLES OF
AUSTRIA AND GERMANY
The Austrian Law on Electrical Engineering (“Elektrotechnikgesetz” 36 ) is prescribing that the
relevant Federal Ministry may define energy efficiency measures by bylaws.
This Law is also defining the item of energy efficiency in its article 1 paragraph 7 and article
8.
Furthermore, article 32 UWG 37 (Law against unfair competition) states that the Federal Ministry
of Economics and Labour may also set bylaws for certain products in order to keep them
for sale while visualizing the quality of products only.
The Bylaw on Household Appliance Labelling (‘Haushaltgeräte-Kennzeichnungs-Verordnung
38 ) is therefore an implementation of two laws,
• the Law on Electrical Engineering (“Elektrotechnikgesetz”)
• and the Law against unfair competition (“UWG”).
It is an umbrella bylaw, several daughter-bylaws has been created already, regarding:
39, 40
- Refrigerators, Freezers and their Combinations
- Washing Machines 41
- Electric Tumble Driers 42
- Combined Washer-Driers 43
- Dishwashers 44
- Electric Ovens 45
36
Bundesgesetz über Sicherheitsmaßnahmen, Normalisierung und Typisierung auf dem Gebiete der Elektrotechnik
(Elektrotechnikgesetz 1992 – ETG 1992); StF: BGBl. Nr. 106/1993; idF: BGBl. I Nr. 136/2001
37
Bundesgesetz gegen den unlauteren Wettbewerb 1984 – UWG; StF: BGBl. Nr. 448/1984; idF: BGBl. I Nr.
79/2007
38
Verordnung des Bundesministers für wirtschaftliche Angelegenheiten über Grundsätze der Verbrauchsangaben
bei elektrisch betriebenen Haushaltsgeräten (Haushaltsgeräte-Verbrauchsangabenverordnung); StF:
BGBl. Nr. 568/1994; idF: BGBl. II Nr. 421/2004
39
Verordnung des Bundesministers für wirtschaftliche Angelegenheiten über Anforderungen an die Energieeffizienz
von elektrischen Haushaltskühl-, -tiefkühl- und -gefriergeräten und entsprechenden Kombinationen
(Kühlgeräte-Energieeffizienzverordnung); StF: BGBl. II Nr. 316/1997
40
Verordnung des Bundesministers für wirtschaftliche Angelegenheiten über Verbrauchsangaben bei elektrischen
Haushaltskühl- und -gefriergeräten sowie entsprechenden Kombinationsgeräten (Kühlgeräte-
Verbrauchsangabenverordnung); StF: BGBl. Nr. 569/1994; idF: BGBl. II Nr. 103/2005
41
Verordnung des Bundesministers für wirtschaftliche Angelegenheiten über Verbrauchsangaben bei elektrischen
Haushaltswaschmaschinen (Waschmaschinen-Verbrauchsangabenverordnung); StF: BGBl. Nr.
580/1996; idF: BGBl. II Nr. 192/2007
42
Verordnung des Bundesministers für wirtschaftliche Angelegenheiten über Verbrauchsangaben bei elektrischen
Haushaltswäschetrocknern (Wäschetrockner-Verbrauchsangabenverordnung); StF: BGBl. Nr.
579/1996; idF: BGBl. II Nr. 192/2007
43
Verordnung des Bundesministers für wirtschaftliche Angelegenheiten über Verbrauchsangaben bei elektrischen
kombinierten Haushalts-Wasch-Trockenautomaten (Wasch-Trockner-Verbrauchsangabenverordnung);
StF: BGBl. II Nr. 62/1998
44
Verordnung des Bundesministers für wirtschaftliche Angelegenheiten über Verbrauchsangaben bei elektrischen
Haushaltsgeschirrspülern (Geschirrspüler-Verbrauchsangabenverordnung); StF: BGBl. II Nr. 182/1999;
idF: BGBl. II Nr. 192/2007
45
Verordnung des Bundesministers für Wirtschaft und Arbeit über Verbrauchsangaben bei Elektrobacköfen
(Elektrobacköfen-Verbrauchsangabenverordnung); StF: BGBl. II Nr. 475/2003
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- Air-Conditioners 46
47, 48
- Lamps
The Federal Ministry of Economics and Labour supervises the market on the basis of the
Law on Electrical Engineering.
The correctness of energy efficiency labels are to be examined by the Ministry’s own investigation
or by detailed tests to be performed by a notified body (e.g. an accredited test laboratory).
As the bylaw is deriving also from the Law against unfair competition, dealers using wrong
energy efficiency labels may be fined in case of proved false statements.
In case of proved false statements the supervising body has to impose an administrative fine
per every act up to EUR 2 900. Moreover, competitors can file a lawsuit after civil law in order
to gain indemnity (whereas the amount of damage is hard to prove), or to claim injunctions
for omissions.
In Germany „Energieverbrauchskennzeichnungsverordnung“ (Decree on Energy Consumption
Labelling 49 ) was enacted by the Federal Ministry of Economy and Technology with 30
October 1997. The Decree defines that the label has to be placed at the appliances front or
top outside, clearly visible and not covered. This is also valid for built-in types. In case of
teleshopping, internet shopping, catalogue selling or other non-direct selling of appliances
the dealer has to guarantee, that potential purchasers are informed before conclusion of a
contract.
4. THE SITUATION IN CROATIA
4.1 EXISTING LEGAL FRAMEWORK
In Croatia the EU appliances labelling legislation has been transposed into the Energy Act,
which in Article 13 specifies the obligations of the equipment suppliers and retailers. Suppliers
are obliged to specify the energy consumption of the equipment in its technical documentation.
It is further obliged to ensure the energy label to the retailer and on the request of the
State Inspectorate to submit the technical documentation to the inspection. Retailers are
obliged to make energy label visible. If the selling mode is such that it is not possible, it must
be ensured that the buyers are introduced with the data from the label.
The appliance labelling system in Croatia is established based on the Energy Act by the Ordinance
on the labelling of energy efficiency of household appliances (OG 133/05). It estab-
46 Verordnung des Bundesministers für Wirtschaft und Arbeit über Verbrauchsangaben bei Raumklimageräten
(Raumklimageräte-Verbrauchsangabenverordnung); StF: BGBl. II Nr. 421/2004
47 Verordnung des Bundesministers für wirtschaftliche Angelegenheiten über Verbrauchsangaben bei elektrischen
Haushaltslampen (Lampen-Verbrauchsangabenverordnung); StF: BGBl. II Nr. 311/1999; idF: BGBl. II
Nr. 310/2002
48 Verordnung des Bundesministers für Wirtschaft und Arbeit über Anforderungen an die Energieeffizienz von
Vorschaltgeräten für Leuchtstofflampen (Vorschaltgeräte-Energieeffizienzverordnung); StF: BGBl. II Nr.
210/2001
49 Energieverbrauchskennzeichnungsverordnung vom 30. Oktober 1997 (BGBl. I S. 2616), zuletzt geändert
durch Artikel 1 der Verordnung vom 19. Februar 2004 (BGBl. I S. 311) – EnVKV auf Grund des Energieverbrauchskennzeichnungsgesetz
vom 30. Januar 2002 (BGBl. I S. 570), zuletzt geändert durch Artikel 169
der Verordnung vom 31. Oktober 2006 (BGBl. I S. 2407) – EnVKG
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lishes the system of energy efficiency labelling of refrigerators, freezers and combinations
thereof, washing machines, dryers and combinations thereof, dishwashers, ovens, sources
of light and air conditioners. This Ordinance came into force by 17 th November 2005 and has
had a transition period until 1 st May 2006. The new Ordinance (OG 130/07) was adopted in
2007 after amendments of the Energy Act, but no significant changes were made.
4.2 EXISTING INSTITUTIONAL FRAMEWORK
Croatian Energy Act provisions and the Ordinance on the labelling of energy efficiency of
household appliances is direct transposition/translation of relevant EU directives. Therefore,
Croatian legal framework does not impose the direct explicit obligation to create a national
certification body. Hence, until now there is no national certification body with regard to energy
efficiency in Croatia established.
The main stakeholders in the field of household appliances’ EE labelling are:
- the State Inspectorate as fully established inspection body empowered by the provisions
of the Ordinance and
- national suppliers of relevant appliances that are obliged to provide label to appliances
distributors/retailers
- national distributors/retailers that are obliged to male labels visible
There is only one appliance manufacturer in Croatia – Končar-Kućanski aparati d.o.o. It has
its own testing laboratory, but only for electric ovens. Other appliances are tested abroad.
Furthermore, Končar-Electrical Engineering Institute is a private testing laboratory, which is
an accredited institution according to the requirements of the Quality Management norm
HRN EN ISO/IEC 17025 50 by the Croatian Accreditation Agency and in terms of electrotechnological
safety. However, the Končar- Electrical Engineering Institute is not an accredited
and fully equipped testing lab in terms of energy efficiency of household appliances, although
they show high interest to become one.
4.3 PROBLEMS ENCOUNTERED EARLIER AND CURRENT STATUS
Basing on the reports mentioned in the ToR p. 9 the following situation was criticized that
before the Ordinance’s date of coming into power (1 st May 2006):
- Text of Labels do not fully respond to the Ordinance on EE Labelling on Household
Appliances
- Only Black and White coloured tags have been used for the labels
- Sometimes base tags were not shown at all
To prove existence or non-existence of these problems, the Consultant has performed both,
field tests by coincidence as well as a hearing of delegates of industry and retail (which took
place on January 15 th , 2009 in the MoELE, for Minutes see Appendix).
50 ISO/IEC 17025:2005 – General requirements for the competence of testing and calibration laboratories
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4.3.1 Field tests results
Field test performed in winter 2008/2009 has given no proof of a.m. problems. Generally the
products available on Croatian market are properly and visibly labelled. Based on the field
visits to several retailers of household appliances, it can be concluded that all appliances
have required energy efficiency labels. Furthermore, when it comes to online catalogues
available in Croatian Internet domain, all the examined sites do have information on energy
efficiency rating for various products. The sites analysed are those of main suppliers/producers
of relevant appliances in Croatia – Gorenje, www.gorenje.hr, Candy,
www.candy.hr, Končar Kućanski Aparati, www.koncar-ka.hr and Whirlpool, www.whirlpool.hr.
4.3.2 Implementation Questionnaire
Following the Hearing, the Consultant has decided to perform expert interviews resp. questionnaires
on the potential implementation of a National Certification Body
The questionnaire has been sent out to:
• The State Inspectorate of Croatia
• A number of household appliance suppliers, i.e. manufacturers, distributors
o Končar – Kućanski Aparati d.o.o.
o CANDY
o Gorenje
o Whirlpool
• A potential Testing and Certification Laboratory
o Končar - Electrical Engineering Institute
These three groups of addresses received the following questions
4.3.2.1 Questions to State Inspectorate
1.) As KONČAR Institute is not an EE Testing Laboratory, but KONČAR - KA has got a lab for their own
product EE testing (ovens only), where does the State Inspectorate let perform tests in case of suspicion?
Which appliances where?
2.) How much suspicion tests is the State Inspectorate performing per year?
3.) How many would it be in a future Croatia-based independent full equipment EE testing lab?
4.) What is the typical cost per test the State Inspectorate pays to the private labs?
5.) How many working days does a test require (from test-purchase until report finalization)?
6.) What is the legal base of EE labelling controlling of retail and suppliers in Croatia?
7.) How are the juridical way and the penalty fine in case of false-statement on labels in Croatia?
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4.3.2.2 Questions to Appliance Manufacturers / Distributors / Importers
1.) How many individual own products is your company annually required to test on their EE class according
to the Croatian/EU EE Labelling Ordinance?
2.) Which product types are those of the nine/ten EE relevant?
3.) Where are EE tests performed for your company, if not in own labs?
4.) How many EE tests are performed in total per year in your own test lab?
5.) How many tests are commissioned to other labs?
6.) What is the typical cost per EE test in own lab / in other labs?
7.) How many working-days does a test require (from delivery until report finalization) in own lab / in
other lab?
8.) What are/ would be the investment cost and the annual maintenance cost and the annual personal
costs for the establishment of a full EE testing lab for all own products?
4.3.2.3 Questions to (Potential) EE Testing Laboratory
1.) What would be the investment cost and the annual maintenance cost and the annual personal costs
(incl. teaching) for the establishment of a full EE testing lab for all EE relevant products?
2.) How long would the establishment require?
3.) How much personnel would be required?
4.) How many tests per year would make the operation of a full EE test lab economically reasonable?
5.) How many potential clients you would expect?
4.3.3 Questionnaire Results
The following answer has been received by the State Inspectorate.
Economy inspectors from State Inspectorate are controling energy efficiency labelling of appliances
and other documentation related to energy efficiency based on the provisions of the Energy Act and
article 11 of the Ordinance on energy efficiency labelling.
We emphasise that control of the above mentioned Ordinance implementation is done through
administrative control, mostly together with control of compliance with requirements of other directives
and ordinances that appliances must fulfill.
When it comes to energy efficiency requirements or energy efficiency labelling, until now, we did not
take any samples of appliances to make tests to determine if energy efficiency requirement are
fulfilled.
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Končar Kucanski Aparati has answered as follows:
1.) How many individual own products is your company annually required to test on their EE class according
to the Croatian/EU EE Labelling Ordinance?
We commission energy efficiency lab tests only for electrical ovens two times a year for 7 product
lines with individual energy efficiency characteristics.
2.) Which product types are those of the nine/ten EE relevant?
Electrical Ovens (and Electrical Heaters (filled with water))
3.) Where are EE tests performed for your company, if not in own labs?
Own labs: Electrical Ovens
Other: Laboratory TCL (Slovenia)*
4.) How many EE tests are performed in total per year in your own test lab? Approx. 20
5.) How many tests are commissioned to other labs? N.a.
6.) What is the typical cost per EE test in own lab: 200–300 EUR / in other labs: 1 000 EUR
7.) How many working-days does a test require (from delivery until report finalization) in own lab / in
other lab? 4 days per test
8.) What are/ would be the investment cost and the annual maintenance cost and the annual personal
costs for the establishment of a full EE testing lab for all own products? N.a.
*) TCL - Testing and Certification Laboratory of GORENJE d.d.
Partizanska cesta 12, 3320 VELENJE, Slovenia
tel: +386 3 899 2661, fax: +386 3 899 2660
e-mail: tcl@gorenje.si; http://www.tcl-labs.com/
Končar - Electrical Engineering Institute has answered as follows:
1.) What would be the investment cost and the annual maintenance cost and the annual personal costs
(incl. teaching) for the establishment of a full EE testing lab for all EE relevant products?
Investment: 850 000 EUR; Maintenance 10 000 EUR p.a.; Personnel: 100 000 EUR p.a.
2.) How long would the establishment require? Approx. 1 year
3.) How much personnel would be required? Min. 2 full-time employees
4.) How many tests per year would make the operation of a full EE test lab economically reasonable?
90 products
5.) How many potential clients you would expect? State Inspectorate, Consumer Protection Agencies,
Few manufacturers (mainly KONCAR Kucanski Aparati and competitors)
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4.3.4 Findings
Following the preliminary results based on only one answer, a full equipped EE Test and
Certification Laboratory as integral part of a National EE Labelling Certification Body has a
investment requirement of 850 000 EUR and regular costs of 110 000 EUR p.a. for personnel
and maintenance. Both values are not confirmed.
Furthermore, it is calculated that 90 tests per year are economically sufficient. In order to
amortise the investment as well as operation & maintenance with 15 years a test would cost
approx. 2 000 EUR in average.
This seems comparatively high when comparing this amount stated in the answer of Končar
KA, which reported to pay in average 1 000 EUR for external lab tests.
In that case, an own establishment of a fully equipped EE Test and Certification Laboratory
can hardly be recommended under the assumption of own cost coverage.
However, if the state resp. the MoELE is interested in supporting consumer protection and
energy efficiency an annual subsidy of 90 000 EUR would help to offer tests to a marketable
level of 1 000 EUR in average per test.
Furthermore the MoELE shall guarantee that State Inspectorate would order a defined
amount of tests per year, e.g. 60 tests, additionally.
5. RECOMMENDATION FOR CROATIA
As a result of the meeting, questionnaires and investigations performed earlier, the Consultant
and the Beneficiary tended to propose a system for Croatia, as follows:
The existence of a National Certification Body for Energy Efficiency is deemed required
for Croatia by the major stakeholders. However, the request for such body is
not legally imposed nor there is a huge and urgent need for it. Namely, the State Inspectorate
did not submit any appliance sample for testing, there were no such requirements from
consumer right protection organisations, there is only one domestic manufacturer with testing
laboratory for only one type of appliances, while for others tests are made abroad at reasonable
price. Currently, only distributors demonstrated the need for such body, purpose of
which would be control of competition products when there is a doubt in the verity of label
data.
It should be also noted that there is no legal obligation to test products on energy efficiency
characteristics specified in labels before being placed on the market – the control
of obligation to display energy efficiency label is only legally imposed and is performed
for the products already available on the market based on the provisions of the Energy Act.
The Energy Act entitles the State Inspectorate to control compliance with display obligation.
If the obligation is violated, appliance suppliers and distributors as well as their authorised
representative will be penalised with a fine.
Furthermore, there are no legally prescribed remedies against appliance suppliers that
give false data in energy efficiency labels of their products in Energy Act or in the Ordinance.
In other words, if the inspection body, i.e. State Inspectorate express a suspicion in
the verity of label data, it could request testing but it could not impose any penalties for false
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statements! Hence, the first step towards energy efficiency labelling body establishment
should be completing legislative framework to ensure verity of data on labels and to penalise
offenders. This would contribute to the fight against unfair competition.
For completion of institutional framework for energy efficiency labelling, there is no need for
establishment of completely new body – Croatia should, in this case, rely on its existing
capacities. This is in similarity with other EU countries. Moreover, the Republic of Croatia
should use the existing capacities of:
• The State Inspectorate (in the field of Market Surveillance on fulfilling the Ordinance)
• A Testing and Certification Laboratory (equipped for Energy Efficiency Labelling
Tests of all devices)
Their operation should be combined with operation of other bodies responsible for product
safety, compliance with technical requirements of products and conformity assessment. In
Croatia, these activities are performed by the bodies that have obtained authorisation from
the competent body (Ministry) and Croatian Accreditation Agency based on the fulfilment of
requirements defined in the special technical regulations. It is especially important to establish
cooperation with Croatian Standard Institute and State Office for Metrology.
The role of State Inspectorate is well established, but needs to be strengthened by completing
legislative framework – prescribing fines for false data given on the labels and imposing
obligation to State Inspectorate to request testing in case of suspicion or by
random regular inspection of the market.
The next question was how a testing and certification laboratory could be established in a
financial and economic way. Firstly, it is important to distinguish between certification body
and the testing laboratory. Regarding the labelling, the key issue is to ensure that the information
given on labels is correct. Hence, certification body is not necessarily needed
while testing laboratory is. Many stakeholders’ opinion is that each country should have at
least one certified laboratory for all the fields. In Croatia, the logical choice is to appoint
Končar - Electrical Engineering Institute as energy efficiency testing laboratory. This
Institute has a certification department which issues certification for electrical appliances
compliance. The Institute has adequate equipment for appliances testing, and would only
need to get some additional equipment if they would do the EE testing. The Institute would
need to expand their work, but that they are willing to get all the necessary equipment and
accreditations such as is the usual practice in other countries. For this purpose, significant
investments would be needed. The questionnaire showed that for economic operation of
such laboratory approximately 90 products are considered to be tested annually. Following
these data, costs of testing would be higher than in neighbouring countries (e.g. Slovenia)
and this would be a serious business disadvantage. Therefore an in-depth cost-benefit
analysis should be additionally performed, also with input from foreign laboratories. Hence, if
this laboratory is of interest of the Republic of Croatia, some form of state support is
needed in order to make the laboratory equal player in the competitive market. It is
recommended that this is done through legislation rather than through subsidies – there
should be an obligation to test certain number of appliances for the purpose of market surveillance.
And last, but certainly not the least is to answer the question why testing laboratory might be
of State interest? It will be in line with the overall strategic commitment to improve en-
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ergy efficiency; it will contribute to the fair competition, development of the competitive
market and consumer rights protection.
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