Download full policy recommendations from December 2018 (pdf)


The European Commission is currently planning ecodesign requirements and an energy label for commercial refrigerated display cabinets. The final vote is planned to take place at the end of January 2019. Recognizing that a swift adoption of the regulations is of the highest priority, we recommend to make small adjustments now, and include other important issues in article 7 "Review". They can be addressed during the first review of the regulations (5 years after coming into force). We make the following recommendations:

  1. Return to simple EEI formula with separate MEPS
    • Segmentation and correction factors result in intransparency and prevent buyers from making informed decisions
    • Current draft minimum requirements will not have notable impact on the market for certain product types even after the second tier
    • Inherent differences between product types should be taken into account with separate minimum requirements as stated in the intent of the Ecodesign draft
  2. Adapt to B2B market
    • Label shown for any form of distance selling, advertisements and technical promotional material, and explicitely also at trade fairs, not only when there is price-related or energy-related information
  3. Recource efficiency
    • Re-set minimum availability of spare parts to 10 years
    • Set the maximum delivery time of spare parts to one week - a longer time frame does not meet the requirments of the supermarket sector and is not necessary due to the highly advanced delivery infrastructure in Europe


Topten is an EU-project aiming to improve energy efficiency in household and professional appliances and speed up the switch to climate-friendly refrigerants. Objectives of the project:

Hepp, Rochat, Bush, December 2018