Policy recommendations for download (pdf, October 2019)
Recommendations in short
The existing Ecodesign and energy label regulations have entered into force in January 2013. Since then, a large part of the split air conditioners on the market are in the best class A+++ and the first A++ mobile air conditioners have appeared on the market.
In the current setting, the scales of the energy label of the mobile and split devices are different: An A++ split air conditioner is much more efficient than an A++ mobile air conditioner even though they are in what seems to appear to be the same class! The difference in energy efficiency in between the split and mobile appliances is not straightforward and is very misleading to the consumer. This issue needs to be addressed and corrected in the current revision as it has been proposed in the current draft.
The latest draft also contained for the first time, energy efficiency requirements and an energy label for comfort fans has been proposed replacing the information requirements in force. A Topten analysis of the market during the compilation of the product list for comfort fans has shown that there are great differences in the energy efficiency levels of comfort fans. It is therefore believed that these products should also be regulated using Ecodesign measures and an Energy label.
Key policy recommendations
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1. One label for all air conditioners
The merger of the energy labels for split and mobile appliances into one so that all products can be compared to one another. The actual situation is very misleading to the consumer and unfairly favours inefficient mobile air conditioners.
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2. Strong energy efficiency requirements.
Based on the findings of the preparatory study, the minimum energy performance
standards can be further tightened. For the new regulation to have a strong impact on the market and avoid that products populate the top classes shortly after the entry into force of the regulation, Topten calls for tighter MEPS.
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3. Promotion of low GWP refrigerants.
Although the F-Gas regulation has been into force for several years, there should be further measures in place to accelerate the phase-down of HFC refrigerants. A malus system that would penalise high GWP air conditioners should be considered.
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4. Alignment of the measurement metric
The use of the seasonal metric for all types of air conditioners to better reflect real-life performance. The SEER and the SCOP are consolidated metrics that take into account a range of outdoor temperatures instead of working only at full load like the EER and COP.
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October 2019