Requirements on Consumer Information about Product ... - ANEC

Consumer Information about PCF
according to the current status of standards. Results probably can’t just be transferred. An
eye has to be kept on this aspect.
It may be generally concluded for type III labels that
• they or EPDs are not suitable for consumer information. As aforementioned, private
consumers generally prefer declarations that are much simpler than those developed in
the framework of ISO 14025 and implemented in national or international EPDschemes;
• in EPDs, benchmarking or scaling schemes are not available. Therefore, it is not
possible to judge the relative environmental performance of a product compared to
another one of the same product group. This also bears the risk that a product appears
to be climate friendly only because an EPD is available, hence, misleading consumers
and customers.
5.2.3 Mandatory labels in the context of PCF
Mandatory labelling (energy efficiency, CO2-emissions)
For some product groups there exists an established mandatory labelling scheme concerning
energy demand and/or CO2-emissions:
• for household appliances (Directive 92/75/EEC): includes household lamps, washing
machines, dishwashers, tumble dryers and cooling appliances: besides the display of
the electricity demand per year or per process (e.g. per washing cycle), it is also
displayed how much water is used per process (if applicable) and to what extent the
aspired function is fulfilled (e.g. cleaning performance). The used A-G rating scheme
proved to be very instructive to support consumers in the purchase of energy efficient
appliances. After the proposed revision the EU energy label will lose value as for
specific products only A grades, like A, A+, A++ and A+++ could be used. The addition
of CO2e emission data would not add to the benefit of the EU energy label as they are
directly correlated to the electricity consumption. Apart from the risk that the different
electric grids of the different EU countries may cause difficulties: a low CO2e emission
could be caused by a high energy standard or by a high degree of nuclear power within
the power plant mix. Therefore, it would be better – if at all – to use the European
electricity mix with its specific CO2e emissions for all EU countries as bases.
• for cars (Directive 1999/94/EC): besides the demand of fuel per 100 kilometre, the
CO2 emissions per kilometre for a new car have to be displayed at the point of sale
and in advertisements, brochures etc. The displayed data refer to the so called
European driving cycle, which is a defined mixture of inner-city, outer-city and highway
driving. Probably no consumer actually will drive according to this driving cycle in
reality. Hence, the figures only give limited support to consumers. Furthermore, it has
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