Water Heaters: First Step to Closing the Loophole, But We're Not Done Yet. 
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Water Heaters:
First Step to Closing the Loophole, But We're Not Done Yet. 
To the ECOS member organisations

Dear all,

Earlier this year we discovered, what could be, a significant loophole in the EU regulations for Ecodesign (no. 814/2013) and Energy Labelling (no. 812/2013) requirements for water heaters.
We are pleased to report that we have made significant progress towards closing this loophole by supporting technical documents meant to be used to implement the regulations.
What was the loophole?
Many water heaters sold on the EU market have several operating modes, and therefore one water heater can have several different energy consumption levels. For example, an “eco-mode” consumes less energy than normal operating conditions.  
As no reference had been made in the regulations regarding which mode the appliances shall be tested in, manufacturers have been able to test their water heaters in the least energy consuming mode, even if this mode is seldom selected by consumers in normal conditions of use.
This loophole also allowed manufacturers to label their products with the best energy class possible (e.g. A+).
ECOS fiercely denounced this loophole which would lead to both misleading information to consumers and not deliver the expected energy savings (Read the full story here).
What have we done?
Responding to our criticism regarding the legislative loophole, the Commission has agreed to refer to and provide a definition of the mode in which the appliance should be tested in the Transitional Methods[1] on water heaters.
The so-called ‘out of the box-mode’ is defined as follows:
The ‘out of the box-mode’ is defined as the standard operating condition, setting or mode set by the manufacturer at factory level, to be active immediately after the appliance installation, suitable for normal use by the end-user. Any change to a different operating condition, setting or mode, if applicable, shall be the result of an intentional intervention by the end-user (except for smart control function aiming at reducing energy consumption). (Official Journal of the European Union, Page 25)
What else needs to be done?
While ECOS sees this as significant step towards closing the legislative loophole, we are not done just yet. We must now work to ensure that the same definition and reference to the ‘out of the box-mode’ is incorporated in future harmonised standards which will be replacing the transitional methods. Only then will the loophole be closed.
How can we avoid this loophole in the future?
Water heaters are not the only relevant product where this loophole can be taken advantage of, as a number of consumer products come in different settings and operating modes.

ECOS is therefore advocating to make the definition of the settings in which a product is tested a legal requirement in the Ecodesign and Energy Labelling directives currently under revision. Only this will ensure fair competitiveness, consumer transparency and expected energy savings to come true.

[1]The European standards are expected to provide methods of measurement and calculation of energy efficiency to help manufacturers comply with the Regulations and compliance check by public authorities. As this is not ready yet, The European Commission has had to develop a so-called Transitional Methods, in cooperation with stakeholders.
Photocredit: WikiHow
If you have any questions or would like to know more about the project, please contact our Energy Policy Officer Christoforos Spiliotopoulos

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