Ecodesign and Energy Labelling Working Plan 2020-2024 (GEN - 1221.00)

Analysis, recommendation, and selected product groups and horizontal activities

GEN - 1221.00. The preliminary analysis of product groups and horizontal initiatives as well as complementary analyses and recommendations have been published in advance of the stakeholder meeting on 26 March. Among the product groups relevant to Eurovent are swimming pool heaters and smart sensors that could become subject to Ecodesign measures. Air curtains are not selected. More important are the horizontal issues that could face all manufacturers: lightweight design, recycled content, ecological profile, durability, scarce and critical raw materials, firmware and software.


The carried out by Viegand Maagøe, VHK and Oeko-Institut started in March 2020 and is now expected to finish by mid-2021. The study has analysed 31 product groups and horizontal initiatives analysed. Half of these could be candidates for inclusion in the final Working Plan.

The second stakeholder webinar takes place on 26 March 2021, 10:00-13:00h.

Preliminary analyses of the product groups and horizontal initiatives

The report of this Task 3 is not yet fully complete.

One will find in here the analysis of air curtains (page 152-161). Swimming pool heaters and industrial sensors are not yet covered.

Of more importance are the horizontal initiatives: lightweight design, recycled content, ecological profile and durability. The aspects of scarce and critical raw materials, firmware and software are not yet covered.

The first four horizontal initiatives are described in the page 184 to 268 and would benefit from the attention of many product groups as with time these initiatives are likely to confront them. Table 116 on page 180 gives an overview of the material inputs for products sold in the reference year 2010, in kton/a. Included are room air conditioners, ventilation units, fans above 125W, professional and commercial refrigeration. Table 120 on page 207 gives the amount and type of plastics consumed annually in ErP sold in EU27+UK 2010 for different product groups.

For the ecological profile the study developed a proposal for an Ecodesign points system designed to complement the existing MEErP methodology. This is rather surprising because the Commission (DG Environment) had developed Product Environmental Footprint methodologies with a Life Cycle Analysis according to ISO standards. These ISO standards are referred to in the study but then this is complemented by referring to the EU Ecolabel for hard floor coverings and hybrid models. This part of the study does require attention.

The deadline to comment on this report is 9 April 2021.

The draft Task 3 reports on swimming pool heaters, industrial sensors, firmware and software all dated 19 March 2021 can be found on the project website.

Recommended actions

Because the horizontal initiatives, if adopted, would systematically have to be analysed and considered in preparatory and review studies, the members are asked to consider these timely in the product groups.

Related documents and links

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