Appendix C Questionnaire

WATER EFFICIENCY LABELLING AND STANDARDS (WELS) SCHEME – Consultation paper
Cullin Innovation Pty Limited submission
Appendix C: Questionnaire
The following are extracts of the questions posed in this discussion paper. Please provide your
comments in the spaces provided.
Chapter 4: Changes to the fee structure
Question 1 (page 7):
Registrants: What would assist in streamlining registration for your organisation?
□ No Comment
Comment:
Send notice of renewal via mail or email 30 days prior to registration end.
Include declaration and check boxes to indicate license currency and no
modifications.
Chapter 4: Proposed changes to registration
Question 2 (page 14):
What is your preferred registration option and why? You may like to estimate the impact
of each of the registration options on your business, taking into account the number of
models and registrations you are likely to utilise in 2012/13 and the administration costs
involved.
□ No Comment
Comment:
Option 4. We currently only have one registered product and this is the most
cost effective option for us. We also believe this is the most fair and transparent
method. There will be less ripping off in the system and this will further reduce
administrative costs.

Question 3 (page 14):
If your preference is for option 3 (product sub-categories), are the proposed subcategories
in Table 4.3 on page 12 appropriate? Can you suggest how the sub-categories
can be made more relevant?
□ No Comment
Comment:
We support option 4
Question 4 (page 14):
Do all products that you sell have a unique code? For businesses that do not
employ a unique code for their products, does this create difficulties? In your
opinion, what is the most effective way to separately identify individual
models/variants registered under the WELS scheme?
□ No Comment
Comment:
Every product we sell has a unique name and code.
It is our opinion the most effective way to separately identify
product is by product name and code.
Question 5 (page 15):
Is there a need for sets of minor products under the new arrangements?
Why/why not?
□ No Comment
Comment:
Sets of minor products will be difficult to administer and will only add to
administrative costs.

Question 6 (page 15):
Do you supply sets of minor products? If so, what percentage of your business
do these products constitute?
□ No Comment
Comment:
No. We do not sell sets of minor products.
Question 7 (page 15):
Are the criteria for sets of minor products appropriate? If no, please provide
reasons.
□ No Comment
Comment:
We think the criteria are ok but the category is unnecessary and not cost
effective if option 4 is adopted.

Question 8 (page 16):
Do you have a preference for a particular renewal system - fixed (e.g. annual)
or flexible (e.g. 1, 2 and 3 years)? Why?
□ No Comment
Comment:
We would prefer a flexible 1, 2 or 3-year option. This gives the option to pay the
fee that is best matched to the products likely life cycle or modification
requirements.
Question 9 (page 17):
For transitioning to the new fee arrangements, do you prefer that registrations
commence from the date of inception of the new scheme, or an option that staggers
commencement of new registrations?
□ No Comment
Comment:
We would prefer to transition to the new fee arrangement by staggering the
commencement to the date of first registration.

Question 10 (page 18):
Which of the two options for treatment of existing fees at the commencement of the new scheme do
you consider the most appropriate and/or administratively straightforward for you? Why?
a) Existing fees are pro-rata credited and the total amount returned is collected through higher fees,
or
b) Existing fees are not credited to individual registrants, but their retention used to lower fees.
□ No Comment
Comment:
We consider the existing fees are pro-rate credited and the total amount
credited is collected through higher fees.
Question 11 (page 20):
What is your preference for grandfathering provisions, and why? Should grandfathering
be indefinite, with the Minister able to specify a date of ‘no further supply’, or should
there be a specified period of grandfathering after the WELS standard is changed?
□ No Comment
Comment:
We recommend there is a specified period of grandfathering with the minister
being able to extend the period on a case-by-case basis.

Question 12 (page 20):
Should flow controllers be removed from the WELS scheme or should
registration of these products become mandatory? Please provide reasons for
your answer.
□ No Comment
Comment:
We consider it should be mandatory for flow controllers to be registered.
Flow controllers are often used in shower roses and can potentially be the
week link in the chain.
Chapter 5: Proposed changes to compliance and administration of the WELS scheme
Question 13 (page 22):
Is there anything else you would like to see for WELS compliance (e.g. new
penalties or offences and different compliance responses)?
□ No Comment
Comment:
Having every individual product clearly identified with a name and unique
number will make infringement much easier to detect. Civil action will be
more cost effective and provide a better deterrent.

Question 14 (page 22):
What do you think of the current level and focus of WELS compliance
activities?
□ No Comment
Comment:
If no one has been penalized as yet manufacturers and sellers
will remain blasé.
Question 15 (page 23):
Do you agree with the requirement that all advertising for WELS products must
have WELS information? If yes, why?
□ No Comment
Comment:
Yes I agree strongly that all advertising for WELS products must have WELS
information. Many consumers make their decision to by solely based on
advertising. When they get to the shop they may find the product is not the best
rated product but they are emotionally committed to purchase it anyway.

Question 16 (page 23):
Is there another way to monitor the advertising requirement? If yes, how?
X□ No Comment
Comment:
Question 17 (page 24):
How do you access registration information about products (e.g. through the
Gazette, through the public database or otherwise)?
□ No Comment
Comment:
Public database.
Question 18 (page 24):
Where would you like to access registration information about products? Why?
□ No Comment
Comment:
Public database. It is logical and easy to navigate.

Chapter 6: Other proposed changes and further scheme development
Question 19 (page 25):
Do you support the ability of WELS inspectors to enter premises without paying a fee if
there is one?
□ No Comment
Comment:
Yes
Question 20 (page 25):
Do you support more extended holding of evidentiary material? Why or why not?
□ No Comment
Comment:
No. The matter needs to be resolved quickly. If an entire shipment is in dispute
this can have a significant impact on a business cash flow.

Question 21 (page 26):
How much detail of alleged breaches do you think should be publicised?
□ No Comment
Comment:
All of the above.
Question 22 (page 27):
Do you support follow-up check testing being at the cost of the registrant of the ‘failed’
product? Why or why not?
□ No Comment
Comment:
We support follow up check testing being at the cost of the registrant of failed
products, provided WELS reimburse the registrant it the product is subsequently
found to be compliant.

Question 23 (page 27):
Do you have any concerns about any ‘person’ being able to apply for registration of a
WELS product provided they can supply required test results, WaterMark certification
etc? If yes, please outline your concerns.
□ No Comment
Comment:
Yes. Our main concern is that it removes the link between the owners of the
intellectual property and the manufacturer. There are many examples of
factories making extra product and selling to mates at reduced cost. It is
important for us that the person seeking registration discloses their
manufacturer and proves they have the right to register and sell the product.
Question 24 (page 27):
Do you think the WELS Regulator should have any specific functions? Why or why not?
X□ No Comment
Comment:
Question 25 (page 28):
Do you have any concerns about information sharing between WELS and other
government agencies? If yes, please provide details.
□ No Comment
Comment:
No

Question 26 (page 28):
Does the definition of ‘supply’ also need to cover any other aspects? If yes, please provide
details?
X□ No Comment
Comment:
Question 27 (page 28):
Have you experienced any issues with the current definition of ‘supply’? If yes, in what
instances.
□ No Comment
Comment:
No

Question 28 (page 29):
Do you consider that WELS should be more closely aligned with WaterMark and/or the E3
energy rating scheme? Please provide justifications for your response.
□ No Comment
Comment:
WELS should be more closely aligned with WaterMark because they both deal
with water. E3 should remain separate. Consumers purchase white goods for
different reasons. Such as people on tank water that use mains electricity will
have a different priority to someone on mains water but using a generator or
solar for power etc. The efficiency of the water and power should be indicated
separately.
Question 29 (page 29):
Should the scheme be eventually split between plumbing and whitegoods products and if
so, in what timeframe?
□ No Comment
Comment:
Yes. ASAP
Question 30 (page 29):
Do you see value in a single ‘sustainability’ label? Why? Who would derive the most
benefit from such a label?
□ No Comment
Comment:
The water and power labels should be kept separate. Consumers purchase white
goods for different reasons. Such as people on tank water that use mains
electricity will have a different priority to someone on mains water that use a
generator or solar for power etc. The cost of water and power will not rise
proportionally.

Question 31 (page 30):
Please provide any other comments or suggestions that you would like to make about
improving the WELS scheme.
□ No Comment
Comment:
Thanks for the opportunity for input.