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Is that an elephant in the corner of the room?July 2008

by Cedric Sloan Director General, FETA

Yes, and its name is the framework directive for setting Eco-Design Requirements for Energy Using Products (EuP for short).

The HEVAC Association has recognised directive 2005 / 32/EC as legislation likely to have great impact upon the building service sector, and will be giving increased priority to addressing these implications. This is not going to be an easy or simple task - even member states are finding it difficult to cope with the scope and pace of developments. UK is doing better than most with both DEFRA and BERR involved in the process, however some nations have yet to engage with the European Commission (EC) officials leading on the directive.

The development of the legislation since its inception in 2005, and transposition into national statutes from 2007, appears logical. In 2006, the EC held an information workshop on implementation of the directive and a Consultation Forum was established to address implementing measures and their impact assessments. A Working Plan, based on the initial list of priority products was effective from July 2007. This generated 19 studies into product groups, (called Lots) of which 10 were of direct concern to building services.

Consultants were tasked with these studies and they were required to engage with industry and hold Workshops to recommend ways to improve environmental performance of the products. This, in turn, would allow the EC to propose relevant implementing measures/impact assessments to the Consultation Forum for acceptance by a Regulatory Committee.

These studies have been completed for some Lots (eg: office lighting), while they are ongoing for others (e.g.: residential room conditioning). Some industry bodies in the UK have been content with the approach (e.g.: the Lighting Industry Federation on domestic lighting), just as others dispute the interim findings (e.g.: the Fan Manufacturers Association on fans).

Input to the studies by industry and member states has been patchy. Dissemination of findings was restricted to websites (each study has its own website) and to those attending Workshops. Hence, dissatisfaction has been generated by those coming to the process late and disagreeing with previous discussions. The tight deadlines imposed by the EC resulted in reports being filed at odds with industry views, or even with many parts of a sector being unaware of the debateable findings.

Some of the time pressure is due to the elections for a new European Parliament being scheduled for Spring 2009. From May 2009 there is expected to be a six-month pause in legislative activity, hence the desire to press forward over this winter with a range of measures, and a deluge of consultative documents should be anticipated from September 2008 to satisfy this timetable.

The momentum of this directive is not waning. In May 2008, a Forward Work Plan for the next 3 years was tabled, dividing the effort across 3 departments in Brussels: the Directorate Generals for Environment, Enterprise and Energy & Transport respectively. The fact that it has to be shared by 3 major directorates in the EC points to the scale of endeavour ahead. Hence, the Elephant in the Corner.

The animal has tusks too. Not only will compliance with the EuP be a requisite for CE marking, but there are also indications that the provisions under the EU Energy Labelling Scheme and Energy Star ratings will be considered in tandem with EuP implementing measures. In other words, the EuP directive will have far reaching consequences for a wide variety of product manufacturers supplying the European domestic and commercial markets.

For greater detail on the directive, the process and progress, the best website is that of DGTREN.


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