Nikola Benin
COMMISSION
STAFF WORKING DOCUMENT
Full Impact
Assessment
Accompanying
the document
Proposal
for a Commission Regulation
implementing
Directive 2009/125/EC of the European Parliament and of the Council
with regard
to ecodesign requirements for air conditioners and comfort fans
{C(2012)
1364 final}
{SWD(2012)
34 final}
EN 2 EN
COMMISSION
STAFF WORKING DOCUMENT
Full Impact
Assessment
Accompanying
the document
Proposal
for a Commission Regulation
implementing
Directive 2009/125/EC of the European Parliament and of the Council
with regard
to ecodesign requirements for air conditioners and comfort fans
Lead DG:
ENER
Associated
DG: ENTR
Other
involved services: SG, ENV, CLIMA, COMP, ECFIN, INFSO, MARKT, SANCO,
TRADE, RTD,
JRC.
1.
PROCEDURAL ISSUES AND CONSULTATION
1.1
Organisation and timing
The
implementing measure for air conditioning appliances and comfort fans is one of
the
priorities
of the Action Plan on Energy Efficiency1
, and is
part of the 2008 Catalogue of
actions2
adopted by the Commission for the year 2008. A
preparatory study was conducted on
2006-2009,
the impact assessment, including two Consultation Forum meetings on 2009-2010
with the
objective of adopting ecodesign and energy labelling measures on the second
half of
2010 in
compliance with the above mentioned Directives.
The
Implementing measures are based on the Directives 2009/126/EC3
setting ecodesign
requirements
for energy-using products and 2010/30/EU on the indication by labelling and
standard
product information of the consumption of energy and other recourses by
energyrelated products.
The
Commission carried out a preparatory study on room air conditioning appliances
and
comfort
fans4
in preparation of the implementing measures.
1
COM(2006)545 final.
2
COM(2008)11 final.
3
OJ L 285, 31.10.2009, p10.
4
Service Contract to DG TREN Preparatory study
on the environmental performance of residential room
conditioning
appliances (airco and ventilation). Contract TREN/D1/40-2005/LOT10/S07.56606.
Final
Report,
March 2009. Co-ordinator: Philippe Riviere, Armines, France. Jérôme Adnot,
Laurent GrignonMasse, Sébastien Legendre, Dominique Marchio, Guillaume Nermond,
Sri Rahim, ARMINES, France.
Philippe
Andre, Laurie Detroux, Jean Lebrun, Julien L’Hoest, Vladut Teodorose,
Université de Liège
(ULg),
Belgium. José Luis Alexandre, Emanuel Sa Idmec, University of Porto, Faculty of
Eng.,
Portugal.
Georg Benke, Thomas Bogner, Austrian Energy Angency, Austria. Amanda Conroy,
Roger
Hitchin,
Christine Pout, Wendy Thorpe, BRE, UK. Stavroula Karatasou, IASA, Greece.
EN 3 EN
On 22 June
2009 and 23 April 2010 meetings of the Ecodesign Consultation Forum
established
under Article 18 of the Ecodesign Directive were held (details are provided
below).
The impact
assessment was launched in May 2009 and supported by an Interservice Steering
Group
including SG, ENV, CLIMA, COMP, ECFIN, INFSO, MARKT, SANCO, TRADE,
RTD, JRC.
The deadline for the ISG consultation from 8 June 2010 to 17 June 2010 was
extended to
24 June 2010 due to the reception of a number of absence messages. Apart from
the
cooperation taking place between the Commission services through the
Consultation
Forum
meetings and the ISG a number of bilateral contacts between officials in
various key
services
took place during the preparatory study and the impact assessment phase.
1.2 Impact
Assessment Board
This impact
assessment has been scrutinised by the Commission's Impact Assessment Board
(IAB). In
its opinion, the IAB concluded that ''the report should provide greater clarity
on
both the
methodology and the proposed requirements in order to make clear the case for
EU
intervention
on air conditioners. It should address a number of issues. First, the report
needs to
clarify to
what extent the principle of least life cycle costs for the consumers is
respected in the
proposed
measure. Secondly, it should clarify how the proposed requirements and timing
of
their
introduction relates to those applied in other major economies. Thirdly, the
report should
explain
more clearly the incentive ('bonus') system for placing on the market
appliances
which
contain refrigerants with low global warming potential. Finally, the social
impacts -
affordability
of the appliances for low income households and the effects on employment in
the EU
-need to be discussed in more depth.'' The IAB also provided a list of more
technical
comments
separate to the final IAB opinion.
The report
was completed with back-ground information on the methodology and the
proposed
requirements and explanation on the relation between the least life cycle costs
for the
consumers
and the requirements was added. A chapter on international comparison was added
and the
incentive ('bonus') for appliances using low-GWP refrigerants was explained
more
thoroughly,
partly in bringing relevant information from the Annexes to the body text. The
chapter on
social impacts was further broadened and the more technical IAB comments were
integrated
into relevant chapters.
1.3
Transparency of the consultation process
Expertise
was gathered in particular through a study providing a technical, environmental
and
economic
analysis of these appliances (from here on referred to as "preparatory
study"),
carried out
by external consultants on behalf of the Commission's Directorate General for
Energy and
Transport (DG TREN). The preparatory study took into account input from all
relevant
stakeholders including manufacturers and their associations, environmental
NGOs,
consumer
organizations, and EU Member State experts. Information on the preparatory
study
was made
publicly available through a dedicated website5
where interim results and further
relevant
materials were published regularly for timely stakeholder consultation and
input. The
study
website was promoted on the ecodesign-specific websites of DG TREN and DG ENTR.
Open
consultation meetings for directly affected stakeholders were organised on
13.2.2007,
5
Available on http://www.ecoaircon.eu/
EN 4 EN
21.5.2007,
23.10.2007 and 7.4.2008 for discussing and validating the preliminary results
of
the study.
On 22 June
2009 the Meeting of the Ecodesign Consultation Forum took place where
Commission
Service's proposals were presented building on the results of the preparatory
study.
Documents were made available in time and sent to the members of the Consultation
Forum, and
to the secretariats of the ENVI (Environment, Public Health and Food Safety)
and
ITRE
(Industry, Research and Energy) Committees of the European Parliament for
information.
The working document was published on DG TREN's ecodesign website, and it
was
included in the Commission's CIRCA system alongside the stakeholder comments
received in
writing before and after the meetings. Minutes of the Meeting of the Ecodesign
Consultation
Forum are annexed (Annex 1).
On a
parallel track Technical Committee 113 of the CEN Working Group 7 is drawing
closer
to
finalising the European standard (prEN 14825:2009) which deals with seasonal
performance
of air conditioners in the European climate. The envisaged measures would take
the results
of this work into account.
During the
impact assessment period, two main issues (regarding introduction of measures
to
reduce
direct GHG emissions and proposal for energy labelling scales) were identified
on
which
further advice was sought from stakeholders. For these purposes, Commission
Working
Documents
were sent to stakeholders on 12.04.2010 and a discussion was held in a second
meeting of
the Consultation Forum on 23 April 2010. Comments were gathered until 31 May
2010 for
the needs of the impact assessment.
1.4
Preliminary results of stakeholder consultation
Stakeholder
consultations were made on the basis of the results from the preparatory study
and the
Commission Staff Working Document, presented at the first meeting of the
Consultation
Forum on 22.6.2009. A second meeting on a few specific issues was organised
on
23.04.2010.
In the
first Consultation Forum, stakeholders largely welcomed the proposed approach.
The
meeting
agreed that energy in use, noise and the impacts of refrigerants are key
environmental
parameters
to be considered. The main discussion focused on what level of requirements
should be
applied to the various types and capacities of air conditioners including the
impact
of energy
labelling on these appliances.
Member
States largely agree with the suggested levels and the staged implementation of
requirements.
The importance of the difference between cooling need and the capacity of the
appliance
was raised. It is important to indicate both the size and capacity of the
appliance but
some Member
States did not find it useful to indicate the capacity for cooling a given
space in
square
meters, as the quality and nature of these square meters is not known6
. It was
considered
that direct GHG emissions could be addressed as well but a solution should be
found as to
how to take these leakages into account given that although leakages are
6
Many manufacturers brochures do give an
indication of the floorspace (or cubic volume) that can be
cooled,
combined with the remark that actual performance depends on room
characteristics and climate.
Many
manufacturers also indicate capacity in BTU (British thermal units), a unit
most consumers are
even less
familiar with than kW.
EN 5 EN
unintentional,
they are also unavoidable, and can only be minimised by considering the type
of
appliances and the way it is installed, serviced and discarded.
Requests
were made that all air conditioners be put in one labelling scale, as otherwise
consumers
would be guided to buy the cheapest (less efficient) product. It was suggested
that
a specific
pictogram could indicate the existence of low GWP refrigerants in the label. A
request was
made that the minimum requirements correspond with the lower levels of the
labelling
classes.
Industry
associations largely supported the Commission proposal. The industry thinks
that a
large share
of current models would be banned, but this would have to be confirmed by
measurements
in laboratories due to novelty of the new efficiency calculation method.
Although
the industry considered noise as being self-regulated by the market (consumers
requiring
low-noise appliances), noise was considered important for consumers and
information
requirements on noise for the indoor and outdoor units were supported but
minimum
requirements refused. Industry wanted to leave the regulation of refrigerants
for the
F-gas
Regulation to avoid overlapping legislation.
Industry
objected to the space heating profiles as proposed in the Working Document; it
would not
be understood by consumers or installers and appliances falling in between
categories
would not show optimal efficiency although in real life they could be
efficient.
Environmental
NGOs and consumer’s associations were generally in support of the
measure but
considered that the proposed minimum energy efficiency requirements are too
low and
proposed to go immediately to LLCC (least life cycle cost) level and to set
minimum
requirements
at benchmark level in five years from now, including the modification of the
labelling
scheme accordingly. Also, more stringent requirements on single ducts were
requested
due to their inherently lower efficiency and effects on performance caused by
intrusion
of warm air when compared with other air conditioners.
The space
heating profiles were rejected as they would not be understood by consumers but
it
was also
stated that the indication of the output power of the appliance (kW) is often
not
understood
by consumers, in particular as room sizes vary strongly from site to site.
Environmental
NGOs agreed that an important part of appliances current on the market would
be banned
but noted that the European air-conditioning sales are composed of very low
efficiency
appliances when compared to other countries. As manufacturers are operating in
a
global
market, there should be no significant cost for the industry to deliver more
efficient
appliances
also to the European market.
An opinion
was raised emphasising that more ambitious noise requirements are necessary
corresponding
to 55 dB(A) for the indoor unit.
The F-gas
Regulation was seen as focusing essentially on avoiding leakages but not
directly
promoting
alternative refrigerants. It was considered that Ecodesign could promote
alternative
refrigerants.
An overall GHG emission figure would not serve the purpose, as it is based on
the average
European energy mix. However, a specific pictogram could indicate the existence
of low GWP
refrigerants in appliances.
A second
Working document building on the earlier stakeholder comments and on selected
issues
raised during the impact assessment was discussed in the Consultation Forum on
23
EN 6 EN
April 2010.
The discussion focused on options for labelling (main issue: unified label or
multiple
labels) and options for promoting the use of low-GWP appliances (less stringent
ecodesign
requirements and/or higher labelling classification).
The second
Consultation Forum approved the approach to set minimum energy efficiency
requirements,
requested sound power level requirements and approved the proposed bonus for
appliances
using a refrigerant with low-GWP. However, generally the Forum preferred to
have only
one bonus level instead of two for different GWP-levels of refrigerants. While
some
stakeholders still preferred one single label others refused it requesting the
application
of the
Energy Labelling Framework Directive (adding pluses for appliances for which
A-level
appliances
are not cut of from the market by the ecodesign requirements) and requested
that
appliances
for which no changes in efficiency calculation method took place should not be
downgraded.
Stakeholders also requested the indication of annual energy consumption on the
energy
label and choose not to set minimum energy performance requirements on comfort
fans due to
insufficient information on efficiency and fan markets in Europe. The proposal
to
set
information requirements on comfort fans was supported.
On comfort
fans, the preparatory study showed that the energy efficiency data, mainly due
to
false
declarations, was not reliable enough to set ecodesign or energy labelling
requirements
on these
appliances. As a solution, minimum energy efficiency requirements were proposed
on the
basis of the requirements set in China and Taiwan. However, towards the end of
the
impact
assessment process, it was found that the required efficiency levels are
unattainable
when
measured on the basis of the IEC60879 efficiency measurement standard; the
proposed
levels of
the requirements would risk leading to a complete ban of most of these
appliances in
the European
market. While not being able to identify the least life cycle cost level in
line
with the
Ecodesign Framework Directive, it will be possible to set information
requirements
for the
indication of the measured efficiency of the appliances and the measurement
standard
used. This
information will help national authorities in market surveillance and will
ensure
that
possible future ecodesign and/or energy labelling requirements can be based on
reliable
data.
2. PROBLEM
DEFINITION
The current
stock of air conditioners is responsible for a significant part of the total
energy
consumed
annually by households and small commercial establishments. The previous years
have shown
a considerable sales increase of especially air conditioners and the sales are
expected to
continue rising due to (a.o.) hotter summers, higher demand in personal cooling
comfort,
increase in average purchasing power and decrease in average purchase price,
even
when the
recent economic downturn (2008-2010 est.) is taken into account.
Most
appliances sold today are low-efficient appliances although high-efficient
appliances
exist on
the market. Consequently, the life-cycle cost of air conditioners is relatively
high and
is
associated with negative impacts on the environment.
Furthermore,
the preparatory study showed that the average energy efficiency of split
package
units sold
in other major air-conditioning markets are clearly above that of 'splits' sold
in the
EU and
ample room for cost-effective improvement exists, despite the existing EU
energy
labelling
scheme. It is thought that since most other economies with major air
conditioner
markets
(Japan, USA, Australia, South-Korea and China) have established minimum energy
EN 7 EN
efficiency
requirements, manufacturers based in these countries can not anymore place
lowefficient appliances on these markets, but can still place these on the EU
market.
As
requested by Article 15 of the Ecodesign Directive, the preparatory study
identified the
relevant
environmental aspects of air conditioners. The analysis shows that most of the
environmental
impacts (and life cycle costs) are attributable to the use-phase. While
indirect
green house
emissions from energy use represent some 80-85% of the total green house gas
emissions
in the use phase, emissions from possible leakages of refrigerants amount to
some
15-20%.The
lifecycle cost (LCC) analysis shows significant reduction potential of the LCC
for
high-efficient appliances.
2.1
Baseline scenario
The
preparatory study for air conditioners provided a technical, environmental and
economic
analysis.
The study provided, amongst others, the following key elements:
–
Description of the scope of the study. This impact assessment describes the
scope of air
conditioners
in detail by adding further types and functionalities (see Annex 2);
– The
annual sales plus sales expectations up to 2030, the typical product life, and
the
installed
base (“stock”) and definition of typical or average products (referred to as
base
cases);
– Typical
heating and cooling demand up to year 2030 (based on usage patterns for three
end-use
applications (residential, small office, small retail), building
characteristics,
climates
and appliance saturation levels per year and per member state);
– The
typical seasonal energy efficiency in multiple climate zones and annual
electricity
consumption
including low-power modes;
– An
environmental analysis of the basecase appliances, identifying the main
environmental
parameters
over the product life and including the relationship between environmental
parameters
like annual electricity consumption, emissions from refrigerant leakage and
noise;
–
Description of technologies yielding reduced electricity consumption and the
additional
costs for
applying them compared to the current “market average” (basecase).
The
baseline has been adjusted for the economic crisis (see Annex 3). The downturn
is based
on PRIMES
projections which essentially describe a dip in economic activity in the year
2008-20010 and
an increasing economic activity from 2010 onwards.
The
following sections describe in more detail the inputs used to define the
baseline scenario
for
calculating future economical and environmental impacts.
2.1.1.
Scope of appliances covered
The scope was
decided on the basis of the Ecodesign Directive Articles 15 and 167
. The scope
and product
categorising were refined during the preparatory study together with
stakeholders
7
In particular Point 2 of Article 16.
EN 8 EN
in search
for a functional approach8
. However,
the particular service of double ducts9
and the
different
function of single ducts10 had to be accommodated in order to avoid the
complete
deletion of
these appliances (services/functions) from the market (see also Annex 2). As
the
Commission
Energy Labelling Directive 2002/31/EC is based on groups of appliances per
technology,
the change in approach leads to both technical and business related impacts.
Simultaneously,
no perfect market data on appliances is available and a new efficiency
calculation
and measurement method is introduced that has not yet been used in real life.
Thus, the
efficiency levels for the appliance groups in scope were based on the
least-life cycle
cost within
the limits set by the quality of the market and efficiency data, including the
consideration
of appliances with specific services/functions (single and double ducts);
The
definitions used follow the definitions used during the preparatory study and
the impact
assessment
phase as follows:
• ‘Air
conditioner’ is a device capable of cooling and/or heating indoor air using a
vapour
compression
cycle driven by an electric compressor;
• ‘Split
package’ means an 'air conditioner' in which the components of the
refrigeration
cycle are
split into one or more mountings, one (usually containing the compressor) is
installed
outside and the others are ;
• 'Window /
through-the-wall unit' means an 'air conditioner' in which the components of
the
refrigeration
cycle are a factory assembly on a common mounting to form a discrete unit
and which
is placed on a window sill or in an aptly shaped hole through a wall;
• ‘Double
duct’ means an 'air conditioner' in which during cooling (heating) the
condensor
(evaporator)
intake air is introduced from the outdoor environment to the unit by a duct
and
rejected to the outdoor environment by a second duct and which is placed wholly
inside the
space to be conditioned, near a wall;
• ‘Single
duct’ means an 'air conditioner' in which during cooling (heating) the condenser
(evaporator)
intake air is introduced from the space containing the unit and discharged
outside
this space;
• ‘Design
load’ means the declared peak cooling or heating power demand, or both, in W
that the
‘air-conditioning appliance’ can meet at the applicable extreme outdoor
temperatures;
• ‘Comfort
fan’ means an appliance designed for creating air movement around (part of) a
human body
for personal cooling comfort. This definition includes comfort fans that can
perform
additional functionalities such as lighting;
• ‘Electric
fan power input’ means the electric input power in W of a ‘comfort fan’
measured
at the
declared maximum flow rate.
A more
detailed description of the scope is provided in Annex 2
8
Ecodesign Directive Article 15, Point 2(ii).
9
Double ducts is the only type of air
conditioners that can be used e.g. in many historic buildings. 10 Single ducts
do not cool a room but only part of a room.
EN 9 EN
2.1.2.
Measurement and calculation method
A new
efficiency calculation and measurement method has been developed in parallel
with
the
preparatory study by the industry manufacturing air conditioners, thorough the
European
standardisation
organisations CEN and CENELEC (prEN14825). The European Commission
has issued
a mandate for a harmonised measurement method for the air conditioners in
scope.
The
harmonised standard will be available in 2011. Meanwhile, a transitory method
will be
used for
which a methodology, in compliance with the prEN14825, has been developed in
collaboration
with stakeholders. The main aspect of the seasonal method is that it allows
taking into
account the impact of the climate on the efficiency of the appliance.
The move
towards seasonal energy efficiency is global due to the widespread use of
inverter
technology
in split appliances. The measurement method has not yet deployed in the market
so effects
are based on calculations. For this, a prudent approach is required when
setting
efficiency
or noise or any other requirements (as there is often a link between e.g.
efficiency
and noise,
efficiency vs. the type and quantity of refrigerants used etc. that thus far is
not yet
know in
detail). The move towards the use of the seasonal measurement method is assumed
to
happen
without difficulties, if sufficient time is granted for the industry. The move
towards
the use of
the new method is supported by the fact that the industry has developed the
method
in parallel
with the preparatory study, supported by the experiences in the US in the use
of
such a
method.
2.1.3.
Relevance of product group for eco-design implementing measures
As
requested by Article 15 of the Ecodesign Directive, the preparatory study
identified that air
conditioners
fulfil the criteria for setting ecodesign requirements because they:
(1) have a
significant economical and environmental impact within the Community;
(2) present
significant potential for improvement without entailing excessive costs;
(3) are not
addressed properly by market forces;
(4) are not
sufficiently addressed by other relevant Community legislation.
The sector
is economically significant. The unit sales of air conditioners in the EU27
amount
to
approximately 4.7 million units, resulting in a combined turnover of the
air-conditioning
industry
(manufacturers, wholesale and retail) of 6.3 billion Euro in 2005. Industry
turnover is
thought to
be some 1.4 billion Euro, of which only 7% can be attributed to EU
manufacturers,
the rest is
associated with mainly Japanese, Korean and USA brands. The largest share of
total
turnover
stems from retail activities and installation/maintenance activities.
The
environmental impacts are significant. The impact assessment calculated a total
electricity
consumption of the stock of air conditioners of 30 TWh/a in 2005. This
corresponds
to a total of around 14 Mton CO2 eq. emissions (0.3% of the total CO2 emissions
in the
EU2711). This includes indirect CO2 emissions from energy use and direct
emissions
from
refrigerant leakage.
11
According the 2010 Statistical Pocketbook "EU Energy & Transport"
the EU-27 emissions in 2005 are
4521 Mton
CO2. 14 Mton are 0.3% of that.
EN 10 EN
The current
market trends are expected to lead to a continued increase in sales, energy
consumption
and environmental impact. The existing EU Energy Label is not able to reduce
the
detrimental effects of rising sales of low-efficient appliances.
The
preparatory study concluded that energy saving can be economical for air
conditioners.
For this
purpose the study proposed minimum energy efficiency requirements, information
requirements
and an updated energy label.
Based on
the information provided by the preparatory studies and this impact assessment
it
has been
concluded that air conditioners comply with the criteria listed in Art. 15 and
therefore
are subject for ecodesign and energy labelling measures.
Measures
described in this impact assessment estimate savings of approximately 11 TWh
from air
conditioners in 2020 and approximately 15 TWh/a in 203012.
2.1.4.
Refrigerants
As stated
above, the preparatory study estimated that in 2005 some 14% of the total CO2
emissions
are due to refrigerant leakages in form of direct emissions (see Annex 4). The
FGas regulatory framework (Regulation 842/2006) would provide a legal basis for
the banning
of harmful
refrigerants, as is the case e.g. with the ban of HFC-134a used in air
conditioning
systems in
vehicles (Directive 2006/40/EC) or the complete ban of HCFCs by 2014.
However, as
more than 99% of the air conditioners in scope use R410A and R407C (GWP
ranging
between 2088 and 1774) it is unlikely that appliances (and/or production lines)
could
be
converted to use e.g. low-GWP HFC's (HFO's) or natural refrigerants
(hydrocarbons or
CO2) with
GWP's ranging between 150 and 0 in the given timeframe due to commercial,
safety and
technological issues at stake.
The direct
CO2 emissions from estimated leakages being a significant environmental impact
and the
total ban of the most environmental-damaging refrigerants being not feasible on
the
basis of
the current knowledge and market situation, the Ecodesign Directive can provide
a
framework
for the promotion of the use of the most environmental-friendly refrigerants.
This
is
important also in the global context knowing that no third market succeeds
showing a better
situation;
the global (air-to-air air) conditioner market closely resembles the situation
in the
EU market
in terms of the types of refrigerants used. Any succssfull EU attempt in
promoting
the use of
more benign refrigerants could serve as an example for other markets, with
corresponding
environmental impacts.
2.1.5.
Sales and stock
Sales of
air conditioners are expected to grow from 4.7 million units in 2005 to some 9
million
units in 2020 and to 10.3 million units in 2030. This assessment is based on
expectations
for main market drivers such as increased household income (stimulates
affordability),
increased demand for personal thermal comfort and lower purchase prices
(stimulates
purchase decisions, also in non-residential sectors) and hotter climates
(stimulates
demand) and
includes a correction for reduced sales in the period 2008-2010 (effects of
economic
crisis).
12 These
values relate to minimum efficiency requirements introduced in 2012-2014.
EN 11 EN
By far the
largest market of air conditioners in the EU is Italy with 33% of EU sales,
followed
by Spain
(21%) and Greece (13%). These three countries combined form two-thirds of the
EU
market for
AC appliances. Since Greece is close to its expected maximum saturation the
main
growth for
the coming years will come from large markets such as Italy and Spain,
unsaturated
markets like France and UK, and the northern European countries for appliances
with
heating function. For further details, see Annex 7.
Figure on
share in total air conditioners sales by country (2005)
1%
1%
2%
2%
3%
6%
7%
13%
11%
21%
33%
Italy Spain
Greece
France
UK Germ any
Portugal
Hungary
Czech R.
Poland
Other
The
preparatory study identified an average product life of air conditioners of
around 12
years.
Combined with historical sales date and the expected market growth the
installed base
is
estimated to be 31 million units in 2005, growing to over 82 million units in
2020 and
almost 117
million units in 2030.
The
split-up of the market according to category of air conditioners is as follows:
Share of AC
categories in sales 2005 2010 2015 2020 2025 2030
Split
packages avg. 3.5 kW (incl. coolingonly)
86% 84% 83%
83% 83% 83%
Split
packages avg. 7.1 kW (reversible) 5% 7% 9% 9% 9% 9%
Window/wall
2% 2% 2% 1% 1% 1%
Double
ducts 1% 1% 1% 1% 1% 1%
Single
ducts 6% 6% 6% 6% 6% 6%
EN 12 EN
2.1.6.
Market structure
The air
conditioner market is global. The EU market represents approximately 7% of the
total
world
market, the largest markets being the USA and Japan13.
Virtually
all production and R&D of air conditioners is located outside the EU and is
dominated
by large multinational companies, since a large production base is vital to
keep
costs down
allowing investment in R&D. Of brand names, some 7% can be traced back to
EU
based
manufacturers, but even then the actual production of the units may have taken
place
outside the
EU.
In general,
manufacturers have difficulties in foreseeing changes in demand in markets in
which they
operate (e.g. due to changes in legislation in a given country). When new
stricter
minimum
requirements restrict the sales of appliances from existing production lines
(for
which the
return to the investment has not yet fully taken place), manufacturers shift
their
sales to
other markets where no such requirements yet restrict the sales of these
appliances.
This can
happen with lower sales prices until there is no more return to the investment.
The
European
air conditioner market has experienced this phenomenon; when minimum
efficiency
requirements have stopped low-efficient air conditioner sales in one country
(e.g. in
the US or
Japan), manufacturers continue and/or reinforce sales and marketing of
lowefficient appliances in countries outside these countries, such as in
Europe.
Figure on
the origin of brand names of air conditioners in the EU market
Japan
S-Korea USA EU Israel China
60% 13% 10%
7% 6% 5%
As regards
single duct appliances, until 2003 most of the market was serviced by Italian
companies
but after the heat wave of 2003 a large number of direct import channels from
Asia
were
opened. Stakeholders believe that, at the moment, the country of origin of most
single
ducts is
outside the EU, mostly China, even though the brand it carries is based in the
EU. A
few
companies in the EU have focused on niche products like the double duct unit.
These
'specialised'
manufacturers can be SME-sized (less than 500 employees).
Most SME-sized
companies in the air conditioner sector are found in the installer/retail
sector.
These
companies that sell, install, maintain and remove air conditioners (often small
retailers/installers
of 1-20 employees) are responsible for most of the total turnover of the
sector and
some 35.000 to 40.000 thousand jobs. The persons handling the refrigerants must
be
qualified according the requirements of F-Gas Regulation 842/2006.
It is
estimated that the EU-based air conditioner manufacturing industry employs 2000
to
2500
workers at various levels, mainly in the production of split air conditioners,
but also
including
single and double duct production. Production facilities are known to exist in
Belgium and
Czech Republic (Daikin Europe) and Italy (DeLonghi, Olimpia Splendid,
Fimer). Due
to the fact that the EU-facilities include product development (R/D will
increase,
13 The
total market of small air conditioners (room air conditioners, portables, but
also including small
packaged
air conditioners popular in the USA) is estimated by experts to be close to 71
million units
globally.
The EU sales of 4.7 million are only 7% of that total.
EN 13 EN
not
decrease), Daikin is a world-leader in product efficiency and the EU-industry
is leading in
single and
double duct efficiency, it is assumed that no negative employment effects are
to be
experienced
at national or regional levels.
2.1.7.
Electricity consumption in 2005 and 2020
The
preparatory study comes to the conclusion that the large penetration rate of
air
conditioners
leads to significant electricity consumption.
For the
year 2005, an annual electricity consumption of 30 TWh/a was calculated,
corresponding
to electricity costs of 6 billion Euro14 (with total expenditure costs some 14
billion
euro) and 14 Mt of CO2 emissions15.
It is
estimated that through awareness campaigns and the continuation of the current
energy
label for
air conditioners the average energy efficiency of air conditioners would
continue
rising
slightly until by 2030 all current split package appliances will be present in
(current)
class A,
with an average EER of around 3.5. The share of inverter appliances (capable of
running
variable speeds) is expected to be some 90%.
For the
year 2020, assuming no change in policy measures, the electricity consumption
is
assumed to
73 TWh/a, corresponding to electricity costs of 45 billion Euro and 37 Mt of
CO2
emissions.
It is
therefore concluded that, without taking additional specific action on air
conditioners, the
market
transformation towards more efficient appliances will take place only very
slowly and
the
negative impact on the environment will continue to rise.
2.2
Improvement potential and costs
The
preparatory study identified the main environmental impacts of air conditioners
over their
life
cycles. The corresponding environmental parameters of air conditioners are:
a)
electricity consumption during use;
b) leakage
of refrigerants with high GWP over the product life;
c) sound
power (noise) during use.
An
effective ecodesign option of reducing electricity consumption is the use of
inverter driven
appliances
able to adjust the performance of the appliance depending on (changing)
operating
conditions
(outdoor and indoor air temperature). This will improve the so called 'seasonal
efficiency'
significantly. A second ecodesign option is the reduction of energy consumption
of
auxiliary
functions like, standby, off-mode, reactivation function etc. These elements
are
taken into
account in the new Seasonal Energy Efficiency Calculation method (SEER for
cooling,
SCOP for heating). More details on the calculation method is given in Annexes 3
and
6.
14 Average
electricity price in the EU 2005: 0.136 €/kWh. 15 The IA assumes 458 g/kWh
electric. This is slightly above average specific EU emissions in 2003 for
EU-25 of
400g CO2 per kWh (EURELECTRIC, Environmental Statistics of the European
Electricity
Industry,
Trends in Environmental Performance 2003-2004). The IA figure is higher because
e.g.
mining
related effects are taken into account (MEEuP: plus 10%).
EN 14 EN
The
seasonal efficiency of the basecase split unit (the most commonly sold
appliance today in
Europe) as
defined in the preparatory study can be doubled against lower life cycle costs.
This
translates
into a reduction of annual electricity consumption of 46%, which compensates
the
increase in
purchase price of 50% and leads to 17% lower total life cycle cost.
The Table
below gives the outcome of the preparatory study as regards the calculation of
efficiency
(EER and SEER) for the basecase (2005 unit), LLCC and BAT. Values for double
ducts (not
given in the preparatory study but developed with experts and stakeholders
during
the impact
assessment), the market average of 2010 and the benchmark for 2010 (the
benchmark
differs from BAT since BAT is the outcome of a theoretical exercise of what the
maximum
efficiency can be, the benchmark is closer to what is best of currently
available).
Table on
cooling efficiencies16
Split_rev 3.5
kW
Split_rev
7.1
kW
Split_cooling
only
Single duct
Double duct
EER SEER
EER SEER EER SEER EER EER
Basecase
(no
inverters)
3.1 (2.8)
2.9 (2.70 2.9 (2.5) 2.3
LLCC 4.3
(5.4) 3.9 (5.3) 3.2 (4.0) 2.8
BAT 5.8
(6.50 5.8 (6.5) 5.8 (6.1) 4.4
(category
not
assessed
separately
in
prep.study)
2010 market
average
3.3 (4.1)
3.03 (3.8) 2.94 (3.6) 2.3 2.15
EU
benchmark (5.1) 3.15 (evap.
cooling)
2.64 (dry
air),
3.15 (evap.
cooling)
World
benchmark
(appliances
available
in
third
markets)
7.1
The table
gives efficiency values for cooling performance only. Heating performance
usually
follows the
same trend line as cooling performance and leads to COP/SCOP values as stated
in Table
below.
Table on
heating efficiencies17
Split_rev 3.5
kW
Split_rev
7.1
kW
Single duct
Double duct
COP SCOP COP SCOP COP COP
Basecase
(no
inverters)
3.40 2.60
3.20 2.50
LLCC 4.50
4.00 4.30 4.00
BAT 5.70
4.80 5.70 4.90
(heating/category
not assessed
in
prep.study)
16 EER
values are measured values. SEER values for basecase, LLCC and BAT are
calculated indicative
values (not
measured) based on the approach used in the preparatory study. SEER values for
2010
market
average and EU benchmark are based on simplified calculations made during the
impact
assessment
and based on the approach of the preparatory study. SEER values for world
benchmark are
declared
values by manufacturers on the basis of third country efficiency measures
(different
temperature
settings and without noise requirements). Double duct market average and (dry
heat
exchanger)
benchmark as presented by industry, evaporative cooling benchmark (3.15) based
on
analogy
with single duct. 17 COP value for single duct 2010 market average assumed in
the IA to be comparable to the 1 tier
ecodesign
requirements. EU benchmark level indicated as presented by industry. COP value
for double
duct 2010
market average and EU benchmark as presented by industry.
EN 15 EN
2010 market
average
3.54 (2.80)
(included in
splits 3.5
kW)
1.80 2.40
EU
benchmark 4.00 3.40 2.60 3.10
World
benchmark
(appliances
available
in
third
markets)
4.60 4.00
Cut-off
percentages
At the LLCC
value of SEER 5.4 (for split reversible) the corresponding EER is close to
4.318.
In the
Eurovent database 2010 an EER of more than 4.3 corresponds to 2.4% of the
population,
meaning that 97.6% will be phased out19.
A SEER
value of 3.6 would represent a cut-off of 75%. Note that these cut-off
percentages
are based
on a dataset and are not sales weighted. It could be that the real market
average is
more
efficient than calculated on the basis of the Eurovent dataset, thereby
reducing the cutoff percentages. However, as the average energy efficiency of
appliances in the EU market is
not as high
as in other countries, minimum efficiency requirements on appliances in the EU
market
should be set with caution. A second reason is that making a unit more
efficient can
increase
the noise level, which could set a constraint to the setting of minimum energy
efficiency
requirements. However, this relationship is not undisputedly observed from data
on
available
models. In the past, manufacturers have found ways to simultaneously reduce
noise
and
increase efficiency until the efficiency levels come very close to what is
technologically
possible.
Annex 4 gives more information on the specificities of the relation between
sound
power level
and efficiency.
For single
duct and double ducts, requirement levels specific to these appliances have
been
identified
with experts and stakeholders; the requirement levels applied on splits would
ban
all of
these appliances from the market.
2.3 Energy
labelling
The air
conditioner industry has some experience in voluntary agreements (Eurovent
Certification
in 2004) but does not endorse this option anymore due to its failure to deliver
the
expected
results. The main reason is a concern for "free-riders" (which in the
globalised
market of
air conditioners appears as a justified concern: only 7% of sales can be
attributed to
EU-based
companies). There are also brands that may "exist" for only one year.
The
importers
of these short-lived brands place low–cost low-efficient products into the EU
market at
the start of the cooling season and return the next year under a different
brand name
and agency.
Such free-rider behaviour is difficult to control and imposes economic damages
to other
participants in a voluntary agreement.
18 For
indicative purposes, the impact assessment is using a relationship between EER
and SEER values
as
calculated in the preparatory study (for the average EU climate). Although the
relationship depends
on the
specific technical design option applied and the category of appliance,
conversion factors were
identified
for indicative purposes (for splits with inverter SEER = 1.25*EER, for splits
without inverter
SEER =
0.9*EER). 19 The average of the EER of 1643 reversible split package units in
the 2010 Eurovent database is 3.25.
The
standard deviation is 0.529. The population is fairly close to a normal
distribution, therefore the
cut-off
percentages can be calculated using the normal distribution function.
EN 16 EN
The
continuation of the present labelling scale has following deficiencies:
1. The
current scaling is not effective in identifying the state-of-the-art
appliances. In
the group
of split package appliances, the current class A is already achieved by over
50% of
models in 2005, and expected to increase to over 60% in 201020. However,
this
efficiency level is still low in comparison with the existing potential. The
current
scheme does
not allow consumers to identify differences in energy efficiency within
this class
A-group. Still, split appliances with much higher efficiencies than the
current
A-threshold efficiency level (A-class is EER=3.20 vs. the highest EER in the
database =
5.7) could be purchased in this group with lower life cycle cost for the
consumer.
The same trend applies to other appliances such as single duct appliances.
For the
niche product double duct appliances (less than 1% in sales) this trend can
not be
observed21.
2. The
current energy label is based on steady-state efficiency (EER/COP) failing to
address
savings that can be achieved by good part load efficiency of air conditioners
(many air
conditioners operate in part load most of the time);
3. The
current energy label scheme does not take into account the low power modes
like
standby, crankcase heating, etc. which would lead to unaddressed savings
potential.
The Energy
Labelling Framework Directive adds a complication that has to be
accommodated,
without negative impact on the clarity of the label for the consumer or on the
industry.
The ecodesign requirements setting the framework for energy labelling, the
efficiency
classes22 for split appliances can be defined to ensure continuous improvement
in
efficiency
of best split appliances, with the impact of downgrading close to all currently
labelled
split appliances under Directive 2002/31/EC. Double ducts and single ducts23 do
not
reach the
high efficiency levels of split appliances due to the inherently lower efficiency
and
different
service/function provided by these appliances. As the Energy Labelling
Framework
Directive
does not foresee the downgrading of the existing appliances24, additional
classes
must be
added on top of the existing label. However, in order not to send wrong signals
to the
consumer25
the highest reachable energy efficiency class for single and double ducts could
be
identified
as A+ (while the inherently more efficient split could go up to A+++).
2.4 Future
trends
The major
non-EU air conditioner markets show that the most popular appliances (split
package)
can be made much more energy efficient than those available in the EU market by
applying
known and cost-effective techniques. For single ducts (and possibly double
ducts
too), an
important trend is the application of evaporative cooling, which can improve
cooling
output at
little or at no extra energy input. It does however require the addition of
water that
20 Values
for 2005 based upon available models, values for 2010 based on analysis of Eurovent
Certification
database for split package units (not sales weighted data). 21 There is no
sales data available to allow trend analysis; data on double ducts is based on
stakeholder
information.
22 E.g. the label could step up every 2 years from A to A+++ in order to
harvest on the available efficiency
worldwide,
while the most efficient appliance available on the EU market only reaches the
A class. 23 Nor does it make sense in setting SEER/SCOP-based requirements in
the lack of inverter driven units. 24 E.g. when minimum energy efficiency
requirements can not be set higher than today's 'A'. 25 That is, indicating
single and double ducts as comparatively more efficient than split appliances.
EN 17 EN
can either
be extracted from condensate that forms on the evaporator or as a separate
water
tank to be
filled in with tap water. A future trend is also the use of inverters, which
has also
been taken
into account in the business as usual scenario. These trends have been included
into the
base line as a slight increase in average energy efficiency of appliances and
an
increase in
share of inverters (which raises the average seasonal performance of
appliances,
more
information is provided Annex 3.
No clear
trend can be seen in the use of low GWP refrigerants but some first steps in
this
direction
have been some small-sized single ducts with hydrocarbons. However, these
appliances
represent less than 1% of the total market. Application of hydrocarbons as
refrigerant
is complicated due to various safety concerns (see more on Annex 4). For common
HFC
appliances refrigerant losses (e.g. through leakage during installation,
operational life
and
improper handling at end-of-life) correspond to GHG emissions of some 15-20% of
the
total GHG
emissions. Unfortunately, leakages can not be avoided (see Annex 4) which is
why
the most
effective measure to minimise those emissions would be the replacement by
refrigerants
with lower Global Warming Potential, when these refrigerants would be available
for wider
use. While the F-Gas Regulation, inter alia, focuses on containment of high GWP
refrigerants
used in these appliances by improving installation, servicing, maintenance and
end-of-life
aspects, ecodesign can complement this framework by ensuring that the use of
low-GWP
refrigerants becomes as attractive as possible, without compromising the total
green house
gas emissions (for more, see Annex 4).
2.5
Relevant legislation
In many
countries (main countries being Japan, USA, Australia, China) air conditioners
are
subject to
measures covering energy efficiency and noise.
In 2002, the
EU introduced mandatory energy labelling of air conditioners (Directive
2002/31/EC)
but due to delays in the development of the measurement standard, the label
could only
be implemented from the year 2004. Currently over 50% of air conditioners are
estimated
to be in the top energy label class A26. These developments are a combination
of
three main
elements; the energy label, minimum efficiency requirements in third countries
(around
this same efficiency level) and in particular due to strong technological
development
during the
last ten years (control technology, more efficient components and scientific
development
in thermodynamics in general). Furthermore, the EU Energy Label does not
address
part load performance although these appliances run most of the time in part
load
conditions.
As said
above, many countries (Japan, USA, South-Korea, Taiwan, China, Australia) have
implemented
mandatory minimum energy efficiency requirements for air conditioners (on all
types,
except single ducts), which makes the EU the largest AC market in the world
without
minimum
efficiency requirements. This has led to a situation where low-efficiency air
conditioners
that can not be sold anymore in other markets, are produced in these third
countries
and placed on the market in the EU. The minimum requirements that apply in
these
countries
are set at levels well above the average efficiency of EU appliances. Seasonal
energy
efficiency (SEER) is already implemented in the USA and Canada, and other
countries
26 For
'double ducts' the share of appliances in class A is not known. As the annual
sales are low (40.000
units),
these appliances were not treated separately in the market data used in the
preparatory study.
However,
there are models available in energy class A on the basis of web search.
EN 18 EN
are
expected to follow. For international comparison of minimum energy efficiency
and
labelling
requirements, see Annex 5.
As to low
power modes of these appliances, the current Commission Regulation on standby
and off
mode excludes air conditioners from the list of products covered.
In 2004,
Eurovent Certification established a voluntary agreement with its members to
ban
energy
label class G appliances from the certification program as of January 2004.
According
to a
Eurovent position paper of 2005, labelling classes E and F could be banned in
2008 and
class C and
D from 2010 onwards (depending on capacity). However, to date, these bans have
not been
implemented (for further, see Chapter 2.3).
Another
voluntary initiative is the EU Ecolabel which has defined criteria
(2007/742/EC) for
heat pumps,
including air-to-air heat pumps. Three manufacturers (Daikin, Mitsubishi and
Sirius)
have been awarded the label but these products are air-to-water appliances
(covered by
Lot 1 on
central heating boilers). Therefore the EU Ecolabel is considered not to be
relevant
in this
impact assessment (on air-to-air air conditioners).
The types
of air conditioners proposed to be regulated are used in buildings covered by
the
recast
Energy Performance of Buildings Directive27. The Directive prescribes measures
to
improve the
energy efficiency of heating and cooling installations of buildings including
air
conditioning
systems. Member States are required to set up regular inspections for air
conditioning
systems with a rated output larger than 12 kW and are thus outside the scope of
the
ecodesign measures discussed in this report. In addition Member States may set
up
measures to
improve efficiency of smaller systems as well. The development of minimum
efficiency
requirements and/or energy labelling will facilitate these goals.
Given that
the ecodesign requirements will not lead to changes in technology that would
have
impact on
installation or maintenance, there will be no impact on the Buildings
Directive.
More
efficient appliances will lead to lower energy consumption within the house
(household)
but they
will not have impact on the efficiency of the house itself.
The F-gas
Regulation sets a framework for the maintenance of appliances employing
halogenated
refrigerants as used in air conditioners in scope of this report. The
Regulation is
to be
revised in 2011 but does not include changes in its current content that could
impact the
foreseen
ecodesign or labelling regulations (such as banning of certain types of
refrigerants or
altering
significantly the requirements on maintenance).
2.6 Market
and regulatory failures
A main
reason for the persistent sales of low efficiency air conditioners is that
end-users base
their
purchase decisions on purchase costs rather than life cycle cost of the
product, a situation
which is
not helped by the current practice not to fully include environmental costs in
energy
cost. Also,
the information on energy efficiency of equipment available to persons buying
air
conditioners
is limited, which introduces asymmetrical information. Cost-effective
improvement
potentials for the end-user are therefore often not realised. Another problem
are
split
incentives, where the person buying the equipment (for example the building
owner)
does not
bear the operation costs, such as a tenant paying the electricity bill.
27 OJ L
153, 18.6.2010, p. 13.
EN 19 EN
2.6.1
Regulatory failure
The current
Commission Directive 2002/31/EC on air conditioners has achieved in the last
six
years an
energy efficiency improvement of some 28%28. However, as the air conditioner
market is a
highly global market, part of the EU efficiency improvement is estimated to
have
happened
due to strict minimum energy efficiency requirements in other major economies.
Also, due
to the very low efficiency level defined for 'A' for most types of appliances,
the
label does
not help guiding consumers towards the most efficient appliances. Furthermore,
the
planned
voluntary Eurovent Certification has never been implemented (mainly due to the
difficulty
in the EU markets dominated primarily by non-European industry) and no
(air-toair) labels have been awarded under the EU Ecolabelling scheme
(2007/742/EC). This
regulatory
failure due to an outdated labelling scheme and inexistent voluntary action
creates
a market
vacuum without adequate incentives to further improving energy efficiency of
air
conditioners
and consumers are not able to differentiate between best products on the basis
of
their
energy efficiency.
In
addition, the current highest energy label class A is close to minimum energy
efficiency
requirements
applicable in many other major air-conditioning markets (single duct units
excluded,
since these are typical for the EU market). Manufacturers experience little
incentives
to offer more efficient appliances, even though this could be done close to
zero
additional
cost to the manufacturer and would bring significant savings to the consumer
and
reduce CO2
emissions.
2.6.2
Negative externality
All
environmental costs are not included in electricity prices. That is why
consumer (and
producer)
choices are made on the basis of lower electricity price not reflecting
environmental
costs for
the society.
2.6.3
Asymmetric information and myopia
Most
consumers base their choice of equipment rather on purchase price and other
factors like
availability,
service and 'trusted' brand names than energy cost. Few people realise that
energy
cost can be
up to 70%-90% of total life cycle cost (which includes purchase, installation
and
maintenance).
The reasons are often related to the complexity or lack of information
understandable
for consumers. The necessary technical information may be available
somewhere
(e.g. on a web site or in a technical documentation) but is hard to locate
and/or
understand.
2.6.4 Split
incentives
This market
failure occurs where investment costs and running costs are borne by different
parties.
This is the case in many rented apartments and spaces where the landlord
reduces
investment
costs by choosing low-cost and low-efficiency appliances and the tenant is
confronted
with higher running costs.
28 The 1999
EERAC study concluded that the average EER of a split package air conditioner
at that time
was EER
2.5. The 2010 average EER of split package units is close to EER 3.2. The
improvement is
therefore a
factor 1.28 (3.2/2.5) or 28%.
EN 20 EN
In case the
tenant is the buyer of the air conditioner, he/she may be forced to use
portable less
efficient
appliances because structural changes to the apartment/space may not be
allowed.
Some
municipalities with historical centres have even forbidden the use of split
package air
conditioning
appliances (even if these are more efficient in general than single package
appliances),
leaving only double duct models or (portable) single duct models as alternative
type of
appliances.
2.7 Subsidiarity
The
principle of subsidiarity as is defined in Article 5 of the Treaty establishing
the European
Community
intends ensuring that decisions are taken as closely as possible to the
citizen; the
Union
should take action only in areas which fall within its exclusive competence and
which
lead to a
more effective action if taken at national, regional or local level.
It is to be
expected that Member States may want to take individual (non-harmonised) action
on air
conditioners to speed up the increase in energy efficiency of appliances. This
possibility,
in the absence of EU action, is strengthened due to the continued introduction
and
tightening
of minimum requirements in third countries. Such action would hamper the
functioning
of the internal market and lead to high administrative burdens and costs for
manufacturers,
in contradiction to the goals of the Ecodesign Directive.
Such
individual Member State action would be taken closer to the citizen but would
fail in
ensuring
level playing field in the internal market. Measures introduced under the
Ecodesign
and Energy
Labelling Directives help bringing down barriers and simplifying existing rules
to
enable
everyone in the EU - individuals, consumers and businesses - to make the most
of the
opportunities
offered to them by having direct access to 27 countries and 480 million people.
The two
Consultation Forum meetings have shown unanimous Member State approval for EU
wide
regulatory framework for air conditioners.
2.8 Legal
basis for EU action
The
Ecodesign Directive and, more specifically its Article 16, and the Energy Label
Directive
provide the
legal basis for the Commission to adopt implementing measures reducing energy
consumption
of air conditioners and in guiding consumers towards the most efficient
appliances.
3.
OBJECTIVES
As laid out
in Section 2, the preparatory study has confirmed that a cost-effective
potential for
reducing
energy consumption of air conditioners exists. There is potential for reducing
noise
and providing
incentives for the use of low-GWP refrigerants. This potential is not realised
with the
current market measures and initiatives, as outlined above.
The general
objectives are therefore to develop a policy which corrects the regulatory and
market failures,
and which:
– reduces
energy consumption and CO2 emissions due to use of air conditioners following
Community
environmental priorities, such as those set out in Decision 1600/2002/EC or in
the
Commissions European Climate Change Programme (ECCP) and;
EN 21 EN
– promotes
energy efficiency hence contribute to security of supply in the framework of
the
Community
objective of saving 20% of the EU's energy consumption by 2020.
– ensures
the free movement of affected products within the internal market.
The
specific objectives are to:
– remove
least efficient products from the market;
– promote
market take-up of the most energy efficient air conditioners in the scope;
– provide incentive
for manufacturers for the investments on appliances with low-GWP
appliances
without inappropriately compromising with total green house gas emissions.
The
operational objectives are to address the problems resulting from the current
labelling
scheme and
comply with the requirements laid down in the Ecodesign Directive, Article 15:
a) there
shall be no significant negative impacts on the functionality of the product,
from the
perspective of the user;
b) health,
safety and the environment shall not be adversely affected;
c) there
shall be no significant negative impact on consumers in particular as regards
affordability
and life cycle cost of the product;
d) there
shall be no significant negative impacts on industry's competitiveness;
e) in
principle, the setting of an ecodesign requirement shall not have the
consequence
of imposing
proprietary technology on manufacturers;
f) no
excessive administrative burden shall be imposed on manufacturers.
Consistency
with other EU policies
Increased
market take up of energy efficient air conditioners through the introduction of
minimum
energy efficiency requirements and a revised energy labelling scheme will
contribute
to reach the 20% energy savings potential identified by 2020 in the Energy
Efficiency
Action Plan (COM(2006)545) and to the binding target on -20% GHG.
Improving
efficiency of air conditioners belongs to one of the key objectives defined in
the
Community
Lisbon Programme for 2008-2010 (COM(2007)804), the promotion of an
"industrial
policy geared towards more sustainable consumption and production" as
further
developed
in the Action Plan on Sustainable Consumption and Production and Sustainable
Industrial
Policy (COM(2008)397)29.
The
European Economic Recovery Plan published 26.11.200830 mentions energy
efficiency
as one of
the priorities and in particular promotes the rapid take-up of "green
products": The
Commission
will urgently draw up measures for other products which offer very high
29
Published 16.7.2008.
30 COM
(2008)800
EN 22 EN
potential
for energy savings such as televisions, domestic lighting, refrigerators and
freezers,
washing
machines, boilers and air-conditioners.”
In January
2008 the European Commission proposed to implement the 20-20-20 targets. This
‘climate
and energy package’ was agreed by the European Parliament and Council in
December
2008 and became law in June 2009. An increased take up of efficient air
conditioners
will also contribute to the non-ETS targets under the GHG Effort Sharing
Decision
supporting the savings decision the Member States have agreed for 2020.
4. POLICY
OPTIONS
4.1 Air
conditioners
In order to
address the issues and meet the targets identified in Section 3 it is important
that
the
increasing energy consumption of air conditioners is curbed and that the other
relevant
environmental
parameters are addressed.
The
following policy options to improve energy efficiency of these appliances have
been
assessed.
4.1.1
Option 1: No EU action (baseline scenario)
This option
assumes no further measures for air conditioners in the EU. The existing energy
label for
air conditioners would continue to exist, without alterations. This option
would have
the
following implications:
The market
and regulatory failures would persist, although the EU Energy Label to some
extent
would continue increasing public awareness on the importance of energy
efficiency
(the
current trend in rising share of class A and appliances with inverters will
continue).
However,
consumers would not be able to differentiate between high-efficient (beyond
class
A) and
average-efficient appliances. The increasing average efficiency in third
countries due
to their
minimum energy efficiency requirements could also contribute to this objective
in
Europe,
without however, reaching the same average efficiencies as in these countries.
However,
the opposite could also happen with low-efficient appliances placed in the EU
market as
they could not anymore be sold in other markets. This option is included in the
impact
assessment as the baseline scenario which assumes a slight increase in average
efficiency
of air conditioners. While the impact of this option is described in more
detail in
Section 2,
the following can be summarised:
Energy
consumption of air conditioners will raise from 30 TWh/a in 2005 to 73 TWh/a in
2020, an
increase of 243%. This is due to the combined effect of a continued sales
increase
and a
slight but diminishing increase in average energy efficiency.
It is to be
expected that Member States may want to take individual (non-harmonised) action
on air
conditioners to speed up the increase in energy efficiency of appliances. This
possibility,
in the absence of EU action, is strengthened due to the continued introduction
and
tightening
of minimum requirements in third countries. Such action would hamper the
functioning
of the internal market and lead to high administrative burdens and costs for
manufacturers,
in contradiction to the goals of the Ecodesign Directive.
The
specific mandate of the Legislator would not be respected.
EN 23 EN
This option
is described in the analysis of air conditioners as baseline scenario and
serves as a
reference
for calculation of savings
4.1.2
Option 2: Self regulation / voluntary agreement
This option
assumes the introduction of voluntary agreements by the industry.
For the
reasons explained in the chapter 2.3, the industry has stated its preference
for a clear
legal
framework and level playing field to ensure fair competition based on
regulatory
measures.
The
specific mandate of the legislator would not be respected.
The option
of voluntary agreements is discarded from further analysis.
4.1.3
Option 3: Mandatory energy labelling scheme (Labelling only)
This option
envisages revision of the energy labelling of air conditioners, without the
introduction
of minimum energy efficiency requirements.
A revised
energy labelling scheme would help to increase the market penetration of more
energy
efficient products by providing incentives for innovation and technology
development,
and help
consumers to make cost effective purchasing decision by addressing running
costs
more
properly. It would also allow upgrading the energy efficiency measurement
method in
addressing
seasonal efficiency and auxiliary power consumption.
However, a
labelling scheme alone would not prevent the entering of low-efficiency
appliances
into the EU market as described in the section on 'Market Failures'.
Consequently
there is a
high risk that market transformation towards high-efficient air conditioners
would
take place
only very slowly at the corresponding detrimental impact on environment and
life
cycle cost
for consumer.
4.1.4
Option 4: Ecodesign requirements only
This option
considers the setting of requirements on the main environmental parameters
energy,
sound power level and refrigerants, without changes in the current energy
labelling
scheme.
According
the Ecodesign Directive minimum energy efficiency requirements should be set at
- or close
to - the least life cycle cost point. The preparatory study has shown that the
LLCCpoint lies at efficiency levels beyond the current Energy Label class A. As
such, no
meaningful
minimum energy efficiency requirements can be set, if the current Energy
Labelling
Directive is kept in force (if the current A would be retained, then ecodesign
requirements
should be set at lesser level than the current A, meaning the net effect would
be
minimal).
The repeal
of the current energy label for air conditioners would solve the problems
caused by
the
combination of the old scheme and new minimum requirements, but would not
stimulate
the market
penetration of energy efficient products by providing incentives for innovation
and
technology
development, and it would remove the instrument to help consumers to make cost
effective
purchasing decision by addressing running costs. Minimum efficiency
requirements
alone can
not achieve these goals.
EN 24 EN
Despite of
the apparent deficiencies of this option on efficiency requirements, its
impacts are
analysed in
Section 5 in conjunction with the other options in order to allow transparent
comparison
of impacts of options. To ensure comparability, the same levels are applied as
in
the Option
5. However, only one set of introductory dates is applied.
The
ecodesign requirement levels for minimum efficiency have been identified by
taking into
account the
following aspects:
•
availability and quality of the market data;
• EU air
conditioner market situation (both average and BAT efficiency levels
considerably
lower in
the EU than in other markets);
• novelty
of the seasonal efficiency measurement method (Not yet used in practice in
Europe.
Only the US has seasonal requirements in place for heating but with different
temperature
settings and without noise requirements);
• relation
between the efficiency and sound power level, which will only be fully known
after the
application of the new measurement method on a sufficiently large quantity of
appliances.
As to the
setting of requirements on maximum sound power level of air conditioners, only
limited
data is available, as presented in Annex 4. There is no data on the impact of
the use of
the new
seasonal efficiency measurement method on sound power level of appliances.
Also,
there are
no sound power level requirements yet in place in other markets that could
guide this
work.
However, while noise is an important factor in the case of air conditioners, a
prudent
approach to
sound power level requirements is required, as there is often a link between
e.g.
efficiency
and noise, efficiency vs. the type and quantity of refrigerants used etc. that
exceeds
the level
of detail required for the analysis (the preparatory study describes the
current state of
knowledge).
Nonetheless, some improvement on the average noise level is thought to be
feasible
and for these purposes, the industry has made an estimate for sound power level
requirements
in taking into account of the uncertainties related to the limited data and the
novelty of
the efficiency measurement method used on most appliances, as follows:
Table on
maximum sound power level for air conditioners
Room
air-conditioners Single ducts and double ducts
Peak
cooling/h ≤ 6
kW
6 < Peak
cooling/h ≤12
kW
Peak
cooling ≤ 6
kW
6 < Peak
cooling ≤ 12
kW
Indoor
Outdoor Indoor Outdoor Indoor Indoor
dB(A) 60 65
65 70 65 70
The impact
of such sound power level requirements would have to be monitored when the
foreseen
measures would be revised. The implementation of the new seasonal efficiency
measurement
method and the measurement data gathered during the implementation phase
would help
to reconsider the levels of such possible future requirements.
As to the
setting of minimum requirements on refrigerants, low-GWP refrigerants have been
freely
available since the invention of air conditioners but several factors continue
limiting the
use of
these refrigerants in the type of appliances in the scope. Due to safety
reasons the
allowed
charge of natural (hydrocarbon-based) refrigerants is small and the EU F-Gas
Regulation
842/2006 aims at controlling environmentally damaging refrigerants, and double
regulation
should be avoided. There is currently not enough market share of appliances
using
EN 25 EN
low-GWP
refrigerants that warrants setting minimum requirements. Feasible is , is a
mechanism
to promote the use of low-GWP refrigerants.
A 'bonus'
could be implemented in form of a reduction of the level of the minimum
efficiency
requirements
on appliances using low-GWP refrigerants. To use low-GWP refrigerants in air
conditioners
in scope requires investments in R&D, in new production facilities and in
modified
components (especially when flammable refrigerants are used). The bonus would
allow
manufacturers to allocate more of their resources towards the investments on
the use of
low-GWP
refrigerants instead of towards energy efficiency. This could facilitate the
market
take up of
these substances.
To give an
idea of the impact of such requirements, two possible outcomes can be
considered.
The first
outcome is described in the baseline analysis and assumes no change in uptake
of
low-GWP
refrigerants. The second outcome is described in Section 5.3 in form of a
'sensitivity'
analysis on the use of low-GWP refrigerants and is based on a scenario of 50%
of
appliances
using low-GWP refrigerants in 2015. The overall contribution of direct
emissions
to total
greenhouse gas emissions drops by 2030 from an average of 19% in the 'outcome
1' to
an average
of 0.1% in the 'outcome 2', and absolute direct emissions drop from around 9.4
mton CO2 to
0.1 mton. This alternative scenario does not incorporate the reduction of
energy
efficiency,
since lower efficiency also involves a reduction of amount of refrigerants (and
vice
versa)
which would further complicate the analysis. Therefore, it can be concluded
that
depending
on the level of the uptake of the low-GWP refrigerants a maximum saving
potential
of around 9 mton of direct CO2 emissions could be expected. The reduction in
indirect
emissions (electricity use) depends on how many appliances actually use the
bonus
for milder
ecodesign requirements.
The bonus
would work as follows: Appliances using low-GWP refrigerants would be allowed
a reduction
on the energy efficiency requirements, making these less stringent. The benefit
of
this
approach is that the extra investments of manufacturers needed to apply low-GWP
refrigerants
can be recouped through smaller investments in high energy efficiency.
Appliances
using the bonus would show lower direct CO2 emissions (low-GWP refrigerant
applied)
but would also show higher indirect emissions (the energy efficiency is lower).
Therefore
the height of the bonus should strike a balance between this raising and
lowering of
emissions.
This balance lies for most appliances at some 10% reduction of energy
efficiency
requirements:
A smaller bonus of for example 5% would lead to lower overall emissions, but
stakeholders
considered this too small an incentive for manufacturers to invest in. A higher
reduction
of 15% on energy efficiency requirements would make investments more
attractive,
but would
lead to higher overall emissions since the savings from low-GWP refrigerants do
not weigh
up against the higher indirect emissions due to lower energy efficiency.
Analysis
has shown
that with a 10% bonus the overall emissions of an appliance with a bonus (lower
efficiency
but also lower direct emissions) stays on the same level as appliances without
bonus (that
meet stricter efficiency levels).
As shown
Chapter 5.3.2 and in Annex 4, a bonus of 5% would lead to lowest total CO2
emissions
out of the four levels considered (5, 10, 15 and 20%). However, a 5% bonus
would
be lower
than the measurement tolerances used (8% vs. 10%), which would hardly
incentivise
manufacturers
for the necessary investments. This was confirmed by the industry response
showing
that such a low bonus would not provide a reduction of energy efficiency levels
important
enough to encourage manufacturers to invest on the use of low-GWP refrigerants.
This is why
a bonus of 10% is proposed.
EN 26 EN
It is
considered that a reduction of 15% of the minimum energy efficiency
requirements
would be
risky in lowering the level of ambition for energy efficiency too much and
broadening
the energy efficiency reduction almost twice to the lowest measurement
tolerances.
The impact
of such a bonus would have to be monitored when the foreseen measures would
be revised.
The implementation of the new seasonal efficiency measurement method and the
data on
appliances using various types of refrigerants gathered during the
implementation
phase would
help to reconsider the levels, or the existence, of such possible future
requirements.
This information could also facilitate the possible development of horizontal
requirements
on F-gases within the F-gas regulatory framework.
4.1.5
Option 5: Combined ecodesign requirements and energy labelling
This option
combines the setting of minimum energy efficiency requirements with the
introduction
of a revised labelling scheme. The impossibility of combining energy efficiency
requirements
with the current energy labelling scheme has been discussed under Option 4.
The main
benefits of simultaneous introduction of minimum efficiency and (revised)
energy
labelling
requirements are that:
– removal
of the least efficient models from the market is guaranteed;
– labelling
scheme is adapted to the levels of the ecodesign measure ensuring the label's
long-term
function as a market tool to drive up the air conditioner efficiency;
– synergic
impact of the pushing effect of the eco-design specific requirements and the
pulling
effect of a functioning labelling scale, as demonstrated on the basis of the
qualitative
but well experienced relation illustrated in Figure 4.5.1. This leads to long
term
improvement
of stock efficiency (minimum efficiency requirements define a threshold that
in practice
will not be lowered in the future, only raised);
– part load
performance and auxiliary energy consumption can be taken into account on
appliances
for which a new basis of establishing energy efficiency is desirable (split,
window and
wall units) leading into higher real-life savings;
– auxiliary
energy consumption can be taken into account on appliances for which rescaling
is not
possible/necessary (double and single ducts);
– complies
with the demand of stakeholders for a harmonisation and rationalisation of both
measures.
Figure on
cumulative impact of ecodesign and labelling
EN 27 EN
Source:
IEA, P. Waide, International use of policy instruments: country comparisons,
Copenhagen, 05 April
2006.
Ecodesign
requirements
The
ecodesign requirements on efficiency were proposed by the preparatory study and
conformed
by the impact assessment study. The least life cycle cost level was SEER/SCOP
4.30-4.0
for split, EER 2.80 for single ducts and EER 2.60 for double ducts. Ecodesign
requirements
slightly lower than the LLCC level were finally proposed for following reasons:
• the
SEER/SCOP measurement and calculation method is new, so the efficiency of
existing
appliances
is not yet precisely known but will be known only when a sufficient number of
appliances
has been tested;
• the
impact of the maximum sound power level requirements on the efficiency
requirements
is not
fully understood but will be known only when a sufficient number of appliances
has
been
tested;
•
low-quality data on appliance efficiency was available, in particular on double
ducts;
• in
comparison with close to all other air conditioner markets, the proposed
minimum
energy
efficiency are the most demanding in the world.
For these
reasons, a cautious approach was taken in order to avoid a set of requirements
impossible
to be complied with.
Requirements
in seasonal efficiency are set on split, wall and window units and in full load
on
single and
double ducts. While the split units are mainly equipped with inverters, the
single
and double
ducts are not.
The
ecodesign requirements on sound power level were requested by stakeholders and
proposed by
industry during the impact assessment period. The identified levels took into
account the
uncertainties stemming from the new calculation method and the (probable)
relation
between energy efficiency and sound power level. Instead of ecodesign
requirement
on
refrigerants, as explained above, a bonus was proposed to reduce the energy
efficiency
EN 28 EN
requirements
of those appliances using low-GWP refrigerants. The bonus provides an
innovative
approach to promoting manufacturers that are willing to invest on more
environmental-friendly
refrigerants.
The
introduction of the SEER/SCOP-based energy efficiency requirements requires
time for
testing of
both new and all existing appliances. The industry has indicated it needs at
least 18
months for
these (re-)tests. Following three sub-options for combined introduction of
minimum
energy efficiency requirements and labelling are considered. The options differ
as
regards the
timing (implementation date) of measures. The second tier measures always
follow
after two years behind the first tier. The three different options reflect the
differences
in savings
that will occur if the measures are introduced at different dates:
1. The
first sub-option considers an immediate introduction of requirements on 2011
given that
entry into force of the measures is expected at earliest at the end of 2010.
This option
relies on the fact that industry has been part of the preparatory study and
impact
assessment starting from 1996, although it is claimed that no re-testing of
appliances
has taken place yet. This option is preferred by environmental NGOs and
some Member
States.
2. The
second sub-option assumes introduction of measures two years after entry into
force in
2012. This date is a compromise between the above and the below suboptions.
This option has not received any particularly strong opinions from the
stakeholders.
3. The
third sub-option (with entry into force of first requirements on 2013) would
give
industry
most time to adapt to the requirements. This option is favoured by most
industry
and by some Member States.
The
introduction of the new energy label is also linked to testing of models and
would
therefore
follow a similar path of sub-options.
Energy
labelling requirements
The energy
labelling requirements were discussed during the preparatory study and the
impact
assessment
and aligned with the ecodesign requirements. On split appliances, they will
allow
showing 'A'
for the current European benchmark and for 'A+++' for the world benchmark.
With the
gradual introduction of plusses on top of the 'A', the industry will be able to
quickly
move
towards the most efficient technology available. The uncertainties stemming
from the
new
seasonal energy efficiency measurement method were taken into account in the
definition
of
efficiency levels for labelling classes.
On single
and double ducts, as no downgrading of appliances was possible, an 'A+' class
was
defined on
top of the existing A-G label. The A+ class was defined on the basis of the
benchmark
value for these appliances. This will ensure that these (inherently) less
efficient
appliances
are not shown as more efficient than the rest of the air conditioners that are
more
efficient
solutions for the cooling of a room.
Consequently,
the options and sub-options considered in the impact analysis are as follows:
EN 29 EN
1. BAU:
Business-as-Usual, i.e. continuation of current policy measures at Member
State and
EU level and no further action at EU level. This option assumes the
continuation
of the current energy label for air conditioners;
2. Energy
Label-only: this option would include the revision of the existing Labelling
Directive
without ecodesign requirements. No stakeholder has expressed support to
this option
but for transparency it's impacts will be analysed without further suboptions;
3.
MEPS-only: this option would include the setting of Ecodesign requirements for
minimum
energy efficiency, noise and information under the Ecodesign Directive.
No stakeholder
has expressed support for this option but for transparency its impacts
will be
analysed together with other options. No sub-options are considered;
4. MEPS
2011-2013 + Labelling: introduction of minimum energy efficiency
requirements
in 2011 and 2013 combined with the introduction of a revised energy
label. This
sub-option would start savings immediately but would leave very short
time for
industry to re-test appliances measured under the new seasonal efficiency
measurement
method. This sub-option is favoured in particular by environmental
NGOs and
some Member States and objected by industry;
5. MEPS
2012-2014 + Labelling: introduction of minimum energy efficiency
requirements
in 2012 and 2014 combined with the introduction of a revised energy
label. This
sub-option is a compromise in between the sub-options 4 and 6 with no
particularly
strong support or opposition by any party;
6. MEPS
2013-2015 + Labelling: introduction of minimum energy efficiency
requirements
in 2013 and 2015 combined with the introduction of a revised energy
label. This
sub-option would leave most time for the industry to retest appliances on
which the
new seasonal efficiency requirements are applied. This option is preferred
by most
industry and objected by environmental NGOs and some Member States.
4.2 Comfort
Fans
As to
comfort fans, the heart of the issue is the lack of robust data on the
performance of fans
sold in the
EU. The preparatory study recognised this problem, and proposed as possible
solution
the setting of minimum efficiency (and noise) requirements as applied in China
and
Taiwan.
These values were thought to be attainable (since applied in the manufacturing
country of
origin for comfort fans) leading close to 1 TWh/a savings by 2020.
However,
during the impact assessment study it became apparent that the results of fan
efficiency
established using IEC 60879 are not compatible with the Chinese requirements.
Additional
input from stakeholders and experts revealed that there is no certainty to what
actual
measurement standards are applied when the performance of fans is declared and
whether the
fans actually meet the Chinese requirements. This removed the basis for the
proposal to
introduce minimum efficiency requirements in line with the Chinese legislation.
In the
second Consultation Forum meeting three options were considered:
1) Setting
efficiency requirements at similar level as in China/Taiwan with risk of
removing
virtually all comfort fans from the EU market;
EN 30 EN
2) Setting
requirements at lower levels than proposed in the preparatory study with loss
of savings
potential. However, the insufficiency of data and test results would result
in
'blindly-set' requirements with corresponding risk of lost savings or banning
of
appliances;
3) Setting
information requirements only for the indication of the measured efficiency
of the
appliance and the measurement method used. Savings would be postponed
until the
setting of minimum efficiency and/or labelling requirements but the
information
requirements would help supporting national authorities in their market
surveillance
activities and provide sound basis for energy efficiency data for any
future
measures. Information requirements will not lead to any considerable
administrative
burden, as the efficiency tests will provide this information for each
model
anyway. While today appliances include information based on EER and COP,
they will
include information based on SEER and SCOP after the coming into force
of
requirements.
The third
option was chosen, as options 1 and 2 were considered unacceptably risky.
As the
setting of product information requirements is not estimated to differ
significantly from
the
baseline scenario in terms of costs against the obvious benefits, this option
is not further
analysed.
5. IMPACT
ANALYSIS
5.1
Economic impacts
Energy
The total
energy consumption of air conditioners without further measures is expected to
rise
due to the
increase in sales and the modest increase in average energy efficiency (BAU or
baseline).
The rise of efficiency will finally level off near 2030 because the sales are
expected
to
stabilise.
The
sub-options 'MEPS+Label' (requirements set for years 2011-2013, 2012-2014 and
2013-
2015) lead
to the highest savings of maximum 10 TWh (approximately 10% savings of
baseline).
It is assumed that once the tier 2 is achieved, energy efficiency continues
rising
because of
the effects of the revised Energy Label.
Figure on
electricity consumption per sub-option
EN 31 EN
Electricity
(TWh/a)
30
40
50
60
70
80
90
100
2005 2007
2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029
Label_only
MEPS_only
(12-14)
MEPS-11-13_Label
MEPS-12-14_Label
MEPS-13-15_Label
Baseline
Figure on
total EU expenditure (sales and stock costs)
10
20
30
40
50
60
70
80
2005 2007
2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029
Expenditure
(billion /a)
Label_only
MEPS_only
(12-14)
MEPS-11-13_Label
MEPS-12-14_Label
MEPS-13-15_Label
Baseline
The total
expenditure (combined costs of purchase costs of new appliances and running
costs
of existing
appliances - installed base) is expected to rise due to the sales increase. The
increased
energy efficiency will increase the average purchase price and reduce the
running
costs. The
total costs are lower than the costs of the baseline scenario (no measures
taken),
therefore
all options show a positive net effect. The maximum savings are some 3.7% in
2030
(compared
to baseline), which correspond to around 2 billion euro/a.
Figure on
turnover (total chain, excluding electricity companies)
EN 32 EN
0
5
10
15
20
25
2005 2007
2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029
Turnover -
total sector (billion/a)
Label_only
MEPS_only
(12-14)
MEPS-11-13_Label
MEPS-12-14_Label
MEPS-13-15_Label
Baseline
The
turnover of the whole sector (manufacturing industry, wholesale and
retail/installers) is
expected to
increase for each option when compared to baseline. The main reason is the
increase in
average purchase price. The largest share of turnover is realised by the
installers/retailers
sector (some 40% of total).
Large
manufacturers
The air
conditioner market is a global market characterised by competition on product
purchase
cost (requires mass production), energy efficiency (requires investment in
R&D),
noise
abatement (requires investment in R&D) and design/extra features (requires
investment
in
R&D). Most manufacturers are large multinational companies who invest
heavily in
achieving
the best results for those markets that have set stringent minimum efficiency
and
other
product requirements in a number of third countries.
SME-sized
manufacturers in the EU
As
indicated above, the overwhelming majority of air conditioners sold in the EU
are
produced by
large multinational companies. SME-sized companies may be involved in the
production
of these air conditioners as OEM suppliers, but stakeholders suggest that all
these
companies
and their production locations are outside the EU, primarily in China and
Japan.
One
Japanese manufacturer maintains two production sites in the EU, one in
Oostende,
Belgium,
the other in Plzen, Czech Republic, to overcome shortcomings in the supply of
units
to the EU
(market demand may shift rapidly due to heat waves31). Each site employs some
1200
people. The site in Belgium employs 70% blue-collar workers and 30%
white-collar32.
Both sites
produce air conditioners above and below the threshold of the scope.
There are
however a few SME-sized manufacturers of air conditioners in the EU focussed on
producing
niche-products like double duct units - a market niche where sales are so low
that
31 Source:
http://www.daikin.pl/news/items/europeanproductiontodouble.jsp 32 The
facilities are owned by Daikin Europe located in Oostende, Belgium and in
Plzen, Czech Republic.
The
information dates from 2004/2005.
EN 33 EN
the main
market players appear to neglect this product group. Ttwo double duct
production
facilities
are known33. The actual number of employees is not known but it is estimated
that
less than
500 employees are involved in the production of these air conditioners. Also
here the
trend of
moving production to low-wage countries in Asia is foreseen.
There are
also air conditioner production facilities in Italy that produce mainly single
ducts.
The
production of single ducts is part of a much larger international Italian
company whose
total size
exceeds that of SME's34. An unknown portion of single ducts sales by this
manufacturer
are imported products, which makes estimating the EU workforce complicated.
However,
the portion of the company involved in single duct production and marketing may
very well
be within SME-size.
The total
number of employees worldwide (both EU and non-EU, OEM and suppliers)
involved in
manufacturing is believed to be close to some 13.000 people.
The impact
assessment could not quantify a full cost estimate of the effect of the options
on
this
industry since information on the costs of compliance is considered proprietary
information.
However, given the fact that these companies continue investing in innovation
and new
products instead of focusing on low-cost mass production indicates that minimum
efficiency
requirements will be rather of their benefit than disadvantage; the products
manufactured
by these companies meet the considered minimum efficiency requirements.
Retailers
and installers
Retailers
and installers are mostly SME-sized companies with often a limited number of
employees.
The impact of the proposed measures will drive up the average purchase price of
the
product, but this extra cost can be passed on to the end-user. No increased
installation
costs are
expected (installation cost does not depend on the efficiency of the product).
The total
number of employees in the retail chain (from wholesale, distribution to
installers
and
maintenance) is believed to be just fewer than 37.000 people.
Administrative
burden
The
proposed ecodesign measure includes requirements to provide information on the
efficiency
of the appliances and the measurement methods and calculations. The energy
labelling
measure includes the provision of an energy label and a technical fiche. There
is no
change in
administrative burden related to EER/COP-based ecodesign requirements but some
do in
relation to SEER and SCOP based requirements. However, as the new measurement
and
calculation
method for SEER/SCOP simply replaces the current provision of EER/COP-based
information,
and as the use of the measurement method readily provides the content for the
requested
information anyway, administrative burden is considered limited. The new energy
labelling
requirements (label and fiche) simply replace the existing energy labelling
requirements
without adding any significant burden to manufacturers or to retailers.
Compliance
cost and timing
33 These
companies are Olimpia Splendid and Fimer, both Italian-based. 34 This is the
Italian-based company DeLonghi whose product portfolio is much much larger than
air
conditioners
alone.
EN 34 EN
Manufacturers
need time to make the necessary investments in order to ensure that appliances
comply with
the legal requirements. However, as the question is mainly in increasing the
current
production (e.g. of appliances with efficiencies not yet sold in the EU) the
effort for
the
investment of new production lines is limited, and on the R&D even less
important.
However,
appliances for which the efficiency must be measured in SEER/SCOP must all be
re-tested,
as the measurement method has not yet been used in real life. A normal design
cycle
for air
conditioner industry is 5 years. For larger equipment (higher capacities like
multipslit)
the
redesign cycle is longer. Also, test capacity (laboratory time) is limited,
meaning that a
very quick
introduction (< 1 year) or requirements is not feasible. Industry has
proposed a
minimum
period of 18 months to prepare for the first tier requirements.
Impact on
internal market
EU level
measures will ensure a well functioning internal market for the industry and
consumers
and helps to avoid market distortions due to possible introduction of national
measures by
some Member States. It is expected that imports of air conditioners to the EU
continue as
in the past, with the difference in minimum and average efficiency, as most
(global)
air conditioner manufacturers already have in their product offer efficiencies
above
the level
of the minimum efficiency requirements proposed. No significant changes in
trading
patterns
are expected due to the measure as such. However, possible changes in market
shares
of the main
producers can not be excluded, as it depends on the market and investment
strategies
implemented by individual manufacturers.
5.2 Social
impacts
Job
creation
The number
of employees is only calculated for the baseline scenario, since sales are kept
constant
for all options and absolute sales are believed to be the prime determinant in
job
creation.
It is
estimated that the ecodesign measure will not lead to direct job losses. As to
retail chain
(from
wholesale to maintenance), the number of jobs is primarily a function of the
absolute
sales
volume and not by the level of the efficiency of the appliances sold. As to
jobs in R&D
and
manufacturing, companies involved in double duct production are operating in a
market
niche in
which focus is on higher quality and higher efficiency appliances. Raising the
level
of
efficiency of appliances will not change business opportunities on the short
term as
manufacturers
already produce these appliances. As to single ducts, most of the production
has already
shifted to low-wage countries although there still is one manufacturer in the
EU
(there are
many imported products). No EU air conditioner manufacturer produces
lowefficient air conditioners. Thus, raising efficiency levels will have
minimum impact on EU
jobs.
Extra job
creation by setting demanding targets is not expected for the EU, nor outside
the
EU, since
additional R&D is not needed (efficient technologies already exist) but for
some
niche
products like double ducts some extra efforts can be expected. However, this
effort can
not be
quantified on the basis of the available data. Anyhow, companies involved are
already
using
innovation and new technologies to adapt their products to the foreseen
requirements.
The double
duct manufacturers are SMEs with a number of personnel involved in R&D
being
limited
with expected additional jobs not surpassing 500 positions.
EN 35 EN
No major
impacts on employment in manufacturing or in installation sectors are expected,
as
the
proposed measures will not lead to changes in the production in the EU (these
appliances
representing
the high-efficiency products) or in the technology of the appliances (e.g.
increased
use of inverters or better components in appliances has no impact on
installation
work). The
installation requirements will remain unchanged.
Employees
in sector (all) ('000)
0,0000
1,0000
2,0000
3,0000
4,0000
5,0000
6,0000
7,0000
8,0000
9,0000
10,0000
2005 2007
2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029
Baseline
Affordability
As to the
methodology in assessing social impacts, the preparatory study indicates that
in
general an
increase in efficiency of an appliance is accompanied by an increase in
purchase
price. The
same mechanism is applied in this IA Report. On the basis of information of the
preparatory
study, the average purchase price of new sales is increased as the efficiency
goes
up. Some
other corrections on the purchase are also applied, such as a price decrease
due to
improved
production efficiency, reduction of production costs and depreciation of
tooling
costs, etc.
The impact of the price increase due to efficiency increase and the price
decrease
due to
higher overall production efficiency are combined into a single purchase price.
Several
aspects can be considered as follows:
Some 2/3 of
all appliances in scope are purchased by the commercial or service sector
(shops,
hair
dressers, cafes, bars, restaurants, hotels/motels, small offices, training
institutions and the
like).
These sales are predominantly split package units.
It is
estimated that the sales to private consumers represent some one third of unit
sales. Close
to all
single ducts are sold to private consumers, since this 'plug-and-play' unit
allows
spontaneous,
impulse-driven sales (sales are particularly high during heat waves) without
the
need for
permanent installation.
Double
ducts are a niche product (sales are less than 1% of overall unit sales) used
mainly in
buildings
of which no modifications on the building shell are accepted, such as in
historic
buildings.
EN 36 EN
Most of the
non-commercial sales of the split appliances are by house owners, as these
appliances
require permanent installation. Most low-income consumers are not house owners.
If, against
the odds in the light of the split incentive, a house owner would invest in an
efficient
air conditioning appliance for the benefit of a tenant, the (often low-income)
tenant
would
benefit from lower running costs.
Low-income
consumers that wish to buy these appliances will face higher purchase prices
but
the
life-cycle cost will be reduced, which benefits in particular low-income
consumers (also
due to asymmetric
information and myopia). Member States, banks and/or financing institutes
may offer
specific schemes for the purchase of efficient appliances. This may happen in
particular
in the future, if the climate change continues warming the planet.
The total
cost to acquire a split or double duct appliance is composed of the purchase
and the
installation
cost. Ecodesign requirements do affect the purchase price but not the
installation
costs.
The
measures keep intact the current available categories of products, where single
ducts are
the most
affordable way of acquiring cooling capacity. Besides, if the
purchase/installation
price would
be too high for a low-income consumer, there are alternatives for cooling, such
as
cooling
fans, which are only a fraction of the purchase price of air conditioners and
have no
installation
cost, and have very low running costs compared to air conditioners.
No impacts
on health have been identified.
All
scenarios show a reduction of expenditure, meaning that even if purchase price
levels
increase
(which is expected will happen) the reduction of electricity costs outweigh the
initial
price
increase, lowering the total cost of ownership.
Due to the
increase in average efficiency the average purchase price of new products is
expected to
rise. The preparatory study provided the background analysis of the price
increase
per
efficiency increase.
The
following average purchase prices apply to air conditioners at the basecase,
LLCC (Least
Life Cycle
Cost) and BAT (Best Available Technology) level of energy efficiency. Note that
the
basecase level is without inverters and that for double ducts the preparatory
study did not
provide
details. The price and efficiency information on double ducts is based on
information
provided by
stakeholders during the impact assessment.
Table on
affordability: basecase, LLCC and BAT
Avg.
purchase price (EUR)
In 2005
prices
Base case
LLCC BAT
Split
package avg 3.5 kW35 (€) 683 1035 1398
SEER 2.8
5.4 >6
35 Window
and wall units were not separately assessed in the preparatory study but
performance and
pricing are
considered comparable to that of an average split package of an equal capacity.
EN 37 EN
Split
package avg 7.1 kW (€) 1385 2084 3351
SEER 2.7
5.3 >6
Single
ducts (€) 389 530 1235
EER 2.3 2.8
>4
Double duct
(€) 1000 1250 1750
EER 2.1
2.35 >2.7
The overall
purchase price increase of air conditioners (all categories combined) for the
options
considered is presented below.
Figure on
average purchase price
Average
purchase price (EUR)
0
200
400
600
800
1000
1200
1400
2005 2007
2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029
Label_only
MEPS_only
(12-14)
MEPS-11-13_Label
MEPS-12-14_Label
MEPS-13-15_Label
Baseline
Note that
for the option 'MEPS-only', the purchase price goes down after the 2nd tier.
This is
caused by
an ongoing reduction of purchase price (which is common to all options) that is
not
compensated
for by increasing efficiency (this option assumes no further efficiency
increase,
which
normally drives purchase price up, as is the case in the other options,
including
baseline).
EN 38 EN
5.3
Environmental impacts
5.3.1
Indirect emissions
The graph
below shows the CO2 equivalent emissions for the options considered (covers CO2
emissions
from electricity consumption and green house gas emissions (GHG) from leakage
of
refrigerants over the product life).
EN 39 EN
Figure on
CO2 emissions
5
10
15
20
25
30
35
40
45
50
2005 2007
2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029
CO2
Emissions (mton CO2/a)
Label_only
MEPS_only
(12-14)
MEPS-11-13_Label
MEPS-12-14_Label
MEPS-13-15_Label
Baseline
The share
of direct GHG emissions ranges from 15% (baseline 2005) to 24% (MEPS 11-
13_Label,
2030). The increase of the percentage value is caused by a decrease of indirect
emissions
(less electricity consumption) which increases the relative share of direct
emissions.
5.3.2
Direct emissions
Analysis of
"Low-GWP refrigerant" options
In the
policy Options, the share of appliances using low-GWP refrigerants was kept
limited.
For many
air conditioners, propane is not a viable alternative because of its
flammability and
restrictions
for use in larger quantities. Other low-GWP refrigerants (CO2, HFO's) are not
(yet)
readily available and the consequences as to pricing and performance are not
sufficiently
known.
Therefore, a conservative estimate of a 5% share of "low-GWP"
appliances in the
sales of
new split units was assumed for 2020. For double ducts and single ducts, a
higher
estimate of
15% in 2020 was assumed because the charges are smaller on average. For both
groups a
gradual increase (normal distribution curve) was assumed36. The leakage rates
are
assumed to
stay constant (3% per annum for splits, 1% per annum for double/single ducts
and
5% at
end-of-life of all appliances). Combined with increasing efficiency the charges
will
become
higher (larger heat exchangers require more refrigerant) and the indirect
emissions
will be
lower, which leads to an overall increase of direct emissions. The impacts can
be seen
in the
below table.
Table on
BAU scenario direct GWP emissions
Policy
options
Direct
CO2eq. by refrigerants 2005 2010 2015 2020 2025 2030
36 Both
split and packaged units assume a standard deviation of 4 years, with a 50% of
target pivot point
at year
2020. The target value is 10% low-GWP sales share for the splits (achieved in
2027) and a 25%
target of
low-GWP sales share for packaged (achieved in 2029).
EN 40 EN
(mton
CO2/a)
Baseline
2,2 3,5 4,9 6,6 8,5 9,4
Label_only
2,2 3,5 5,0 6,7 8,8 9,9
MEPS_only
(12-14) 2,2 3,5 5,0 6,8 8,7 9,4
MEPS-11-13_Label
2,2 3,5 5,0 7,0 9,3 10,5
MEPS-12-14_Label
2,2 3,5 5,0 6,9 9,2 10,3
MEPS-13-15_Label
2,2 3,5 4,9 6,8 9,0 10,2
Share of
direct emissions 2005 2010 2015 2020 2025 2030
Baseline
15% 16% 17% 18% 19% 19%
Label_only
15% 16% 17% 19% 20% 21%
MEPS_only
(12-14) 15% 16% 18% 20% 21% 20%
MEPS-11-13_Label
15% 16% 18% 21% 23% 24%
MEPS-12-14_Label
15% 16% 18% 21% 23% 24%
MEPS-13-15_Label
15% 16% 17% 20% 22% 23%
The effect
of a possible transition towards the use of low-GWP refrigerants was not
calculated
in the
context of policy options, as the application of such refrigerants is entirely
optional.
However,
for illustrative purposes, it is insightful to assume a scenario in which 50%
of new
appliances
will use refrigerants with low GWP in 2015 gradually increasing to 100% in 2020
(50% in
2020 is chosen, as this comprises a significant share of appliances and it
allows
making also
short-term effects visible before 2030, although this scenario should be
considered
unlikely in the light of the information available for this report) . . The
calculated
impacts are
shown in the below table.
Table on
direct GWP emissions if 50% sales share of low-GWP refrigerants in 2015, 100%
in
2020
50% of new
appliances are lowGWP at start of MEP
Direct
CO2eq. by refrigerants
(mton
CO2/a)
2005 2010
2015 2020 2025 2030
Baseline
2,2 3,5 4,5 3,6 1,3 0,05
Label_only
2,2 3,5 4,5 3,6 1,3 0,05
MEPS_only
(12-14) 2,2 3,5 4,5 3,6 1,4 0,05
MEPS-11-13_Label
2,2 3,5 4,5 3,7 1,4 0,05
MEPS-12-14_Label
2,2 3,5 4,5 3,7 1,4 0,05
MEPS-13-15_Label
2,2 3,5 4,5 3,6 1,3 0,05
Share of
direct emissions 2005 2010 2015 2020 2025 2030
Baseline
15,1% 15,8% 15,5% 10,4% 3,3% 0,1%
Label_only
15,1% 15,8% 15,7% 10,8% 3,5% 0,1%
MEPS_only
(12-14) 15,1% 15,8% 16,7% 11,8% 3,9% 0,1%
MEPS-11-13_Label
15,1% 15,8% 17,0% 12,5% 4,4% 0,2%
MEPS-12-14_Label
15,1% 15,8% 16,7% 12,2% 4,2% 0,2%
MEPS-13-15_Label
15,1% 15,8% 16,1% 11,7% 4,0% 0,1%
These
calculations assume that the energy efficiency is not reduced when compared to
the
assumptions
in the policy options. If this were the case the direct emissions could drop
but the
indirect
emissions (from electricity consumption) could increase, and the overall
combined
effect on
GHG emissions could be lower.
EN 41 EN
Low-GWP
bonus and Energy Label ranking
A
GWP-related bonus linked to Energy Label performance (ie. a low-GWP appliance
would
be awarded
a higher energy label class) is considered suboptimal, with few or no
advantages
and major
drawbacks, as the label would not anymore convey the right information to
consumers
about comparative energy efficiency of the appliance (as some stakeholders
argued, the
label would be misleading, as the factual information on the energy efficiency
is
distorted
by the characteristics of the refrigerant). Also, it would hamper the
monitoring of the
progress of
the energy efficiency of appliances and the choice of a higher labelled
appliance
would risk
not leading to higher savings for the consumer. Linking a GWP-bonus to
ecodesign
requirements ensures that the consumer always benefits from the fact that out
of
appliances
of similar efficiency the one using a low-GWP refrigerant is always a better
option
for the
environment (subject to setting the level of the bonus so that total emissions
are not
increased).
Cumulative
savings
Cumulative
savings for electricity range between 40 to 70 TWh by 2020. By 2030, savings
increase to
146 vs. 228 TWh of electricity.
Electricity
savings (TWh/a) 2005 2010 2015 2020 2025 2030
Baseline
Label_only
0,0 0,0 -1,3 -7,8 -22,0 -42,6
MEPS_only
(12-14) 0,0 0,0 -11,3 -50,4 -103,7 -146,1
MEPS-11-13_Label
0,0 0,0 -17,2 -69,1 -147,1 -228,4
MEPS-12-14_Label
0,0 0,0 -11,5 -55,7 -126,8 -202,9
MEPS-11-14+_Label
0,0 0,0 -10,6 -53,8 -124,3 -200,4
MEPS-13-15_Label
0,0 0,0 -5,8 -40,5 -102,7 -173,7
(Negative
values correspond to savings)
By 2020,
the Options save up to a maximum of 1.2 billion EUR. The expenditure increases
to
0.8 billion
(mainly due to increase in purchase price). By 2030, savings range in between
21
to 26
billion EUR (all savings).
Expenditure
savings (billion EUR) 2005 2010 2015 2020 2025 2030
Baseline
Label_only
0,0 0,0 0,0 -0,5 -2,9 -8,3
MEPS_only
(12-14) 0,0 0,0 1,5 -1,2 -10,1 -21,0
MEPS-11-13_Label
0,0 0,0 1,4 -0,3 -9,2 -25,7
MEPS-12-14_Label
0,0 0,0 1,6 0,5 -7,8 -23,5
MEPS-11-14+_Label
0,0 0,0 1,2 0,3 -7,7 -23,5
MEPS-13-15_Label
0,0 0,0 0,7 0,8 -6,2 -21,1
(Negative
values correspond to savings)
As a
conclusion, the sub-option 'MEPS-12-14+_Label' offers savings comparable to the
other
sub-options
without unnecessary burden (from retesting of appliances due to the new
efficiency
measurement method) to the industry that would occur in options introducing the
first tier
requirements earlier. Additionally, earlier introduction of EER/COP based
minimum
efficiency
requirements could be considered in order to ensure that the least efficient
appliances
will be removed from the markets at an earlier stage.
Overlap
with other measures
EN 42 EN
No
significant overlap with other ecodesign measures has been identified. Lot 1
covers heat
pumps
connected to hydronic systems. Lot 10 covers fans for domestic ventilation (not
for the
recirculation
of indoor air). Lot 21 covers air heaters but not the types using vapour
compression
cycle. Lot 11 focuses on fans above 125W and some of these fans could be used
in outdoor
units. However, savings from the Lot 11 fan measure are estimated negligible in
the context
of air conditioners.
5.4
International comparison
One of the
objectives of this measure is to bring the EU requirements closer in line with
the
international
levels. Today, the EU market is the only major air conditioner market without
minimum
requirements. However, each market has its specificities, such as the level of
saturation,
share of different types of air conditioning appliances due to different
climates
(temperature
and humidity), technical requirements, etc. For these reasons, direct alignment
of
requirements
with third countries could lead to negative impacts in the EU market. However,
third
country legislation and market reality has been taken duly into account through
the
stakeholder
consultation during the preparatory study. As a result, the considered EU
requirements
are among the highest in the world although they may not be identical to any of
the minimum
energy efficiency requirements in place in third countries, including
requirements
on noise and the promotion of low-GWP refrigerants, which has not yet been
implemented
elsewhere in the world.
No minimum
energy efficiency or energy labelling requirements on single ducts or double
ducts are
known to exist in the world on the basis of the preparatory study or the impact
assessment.
These products are typical for the EU market, particularly in Southern-Europe,
but are
rare or insignificant in other major air conditioning markets, hence probably
the lack
of
requirements on these appliances. However, it is known that Australia is
considering the
introduction
of requirements on single ducts once the present preparatory process to develop
requirements
on air conditioning appliances within the EU has delivered its results.
As to other
air conditioners, as shown further in Annex 8, minimum efficiency or energy
labelling
requirements on air conditioners have been traditionally based on efficiency
measurement
standards on full load (EER/COP). However, the introduction and rapid
development
of control technology during the last two decades has made this type of
measurement
standards outdated, even misleading as an indicator of efficiency in real use.
This is why
the US, as the first nation in the world, introduced efficiency requirements on
split
package air conditioners on the basis of seasonal performance and Japan and
South
Korea are
in a process of doing so, in line with the US and the EU. One of the main
driving
forces
behind these developments is the air conditioner industry that has realised the
shortcomings
of the EER/COP-approach. Today, the use of seasonal efficiency measurement
standard is
requested by all stakeholders, and it is expected that the rest of the
countries will
gradually
move towards the use of seasonal efficiency (However, to ensure a more robust
international
comparison, the preparatory study, and as also briefly treated in Annex 8,
includes
comparisons based on EER).
On the
basis of the methodology agreed during the preparatory study, the proposed
values for
minimum
requirements of SEER 3.6/4.3 equal to about EER 2.9/3.4 (assuming the use of
inverters).
That is, the proposed first tier requirements (SEER 3.6) equal to about the
average
level of
requirements available in the world (requirements ranging between 2.2-3.7). The
proposed
second tier requirements are equal to the US requirements. Only the Japanese
requirements
on smaller power range are higher than in Europe.
EN 43 EN
As to
heating efficiency (SCOP), the proposed requirements are understood to be below
the
Japanese
top-runner requirements but are still aimed at phasing out low-efficient
products,
keeping
high-efficient appliances on the market.
The IA
Report shows that redesign of appliances for the EU market is most likely not
an issue
since
equipment fulfilling the proposed EU requirements is already available in the
world
(major air
conditioner manufacturers are global players). However, for retesting of appliances,
the
industry and test laboratories estimate the need of a preparatory period of
some 18 months
(page 25).
This estimate is based on the experiences from the standardisation work run by
the
industry in
parallel with the preparatory study.
5.5 Summary
and conclusion
The
analysis on air conditioners shows that the economic, social and environmental
impacts
of the
options and sub-options save between 7 - 16 TWh in 2030 and between 2.9% - 5.4%
in
expenditure
without job losses. However, industry needs time to test new and retest
existing
appliances
for which minimum energy performance requirements are set on the basis of
seasonal
energy efficiency (more than 90% of existing and new appliances).
As the
analysis shows, the difference in timing does not affect significantly the
level of
savings.
The option (MEPS 12-14 + Labelling) has second highest savings and guarantees
that
industry has enough time to prepare for the first requirements. It therefore
seems to offer
an
appropriate combination of ambition and feasibility.
The below
summary table on main impacts of the considered options is presented below.
Full
summary
table can be found in Annex 9.
Electricity
savings (Twh/a) 2005 2010 2015 2020 2025 2030
Baseline
Label_only
0 0 -1 -1,9 -3 -4
MEPS_only
(12-14) 0 0 -5 -9,4 -10 -7
MEPS-11-13_Label
0 0 -6 -12,9 -16 -16
MEPS-12-14_Label
0 0 -5 -11,337 -15 -15
MEPS-13-15_Label
0 0 -3 -9,3 -14 -14
Expenditure
savings (bio EUR) 2005 2010 2015 2020 2025 2030
Baseline
Label_only
0,0% 0,0% 0,0% 0,5% 1,1% 1,7%
MEPS_only
(12-14) 0,0% 0,0% -0,7% 2,3% 3,5% 2,9%
MEPS-11-13_Label
0,0% 0,0% -0,7% 1,8% 3,9% 5,1%
MEPS-12-14_Label
0,0% 0,0% -1,0% 1,5% 3,7% 4,9%
MEPS-13-15_Label
0,0% 0,0% -1,7% 1,0% 3,4% 4,6%
37 The
Regulatory Committee on 31 May 2011 voted to decrease the GWP bonus from the
proposed 15%
to 10% and
to chage some levels of the efficiency requirements for air conditioners,
except single and
double duct
air conditioners as follows: the first tier requirement for appliances with GWP
of refrigerant
> 150
for < 6 kW was increased from SCOP 3.20 to SCOP 3.40, the second tier
requirement for
appliances
with GWP of refrigerant > 150 for < 6 kW was increased from SEER 4.30 to
SEER 4.60 and
from SCOP
3.50 to SCOP 3.80 and for appliances with GWP of refrigerant > 150 for 6-12
kW the
requirement
was increased from SCOP 3.50 to SCOP 3.80. The impact of these changes on the
expected
combined savings from the energy labelling delegated regulation and this
ecodesign
implementing
regulation is estimated to be additional savings of somewhat below 1 TWh by
2020,
increasing
by this amount the previously expected savings of 11 TWh by 2020.
EN 44 EN
CO2 savings
(Mton CO2) 2005 2010 2015 2020 2025 2030
Baseline
Label_only
0,0 0,0 -0,2 -0,7 -1,3 -1,6
MEPS_only
(12-14) 0,0 0,0 -1,6 -3,1 -3,8 -3,3
MEPS-11-13_Label
0,0 0,0 -2,1 -4,3 -5,8 -6,3
MEPS-12-14_Label
0,0 0,0 -1,7 -3,8 -5,5 -6,0
MEPS-13-15_Label
0,0 0,0 -1,0 -3,3 -5,1 -5,6
The assumed
electricity price is based on the electricity price used in the preparatory
study for the EU 27 = 0,136
Eur/kWh.
The
analysis on comfort fans showed that the lack and low quality of efficiency
data does not
allow
setting ecodesign or energy labelling requirements on comfort fans. However,
information
requirements can be set for the display of the efficiency of the appliance and
of
the
measurement standards used. This information will facilitate the gathering of
the
efficiency
data that will allow considering the setting of requirements at a later stage.
6.
MONITORING AND EVALUATION
The main
monitoring element will be the tests carried out to verify correct rating and
labelling.
Monitoring of the impact on appliances should be done by market surveillance
carried out
by Member State authorities. Effective market shift towards upper labelling
band
will be the
main indicator of progress towards market take-up of more efficient air
conditioners.
The increase in sales of appliances using low-GWP refrigerants will provide an
indicator
for the impact of the bonus and will allow considering the usefulness of the
bonus,
its
possible continuation and the suitable level of the bonus.
The
appropriateness of scope, definitions, concept and possible trade-offs will be
monitored
by the
ongoing dialogue with stakeholders and Member States. The main issues for a
possible
revision of
the proposed energy efficiency requirements and the labelling scheme are:
– follow up
of the appropriateness of the new seasonal energy efficiency rating (SEER) and
possibly
improved test standards (mandate CEN/ CENELEC) and measurement accuracy
(tolerances),
including the possible application of SEER on single and double ducts;
– possible
revision of the energy efficiency and sound power requirements, impact of the
bonus for
appliances using low-GWP refrigerants, labelling classification scheme and
labelling
categorisation, taking into account the impact of other air conditioner related
Ecodesign
Lots;
–
implementation of further measures on possible direct leakages (obligatory
leakage
detection,
refrigerant bonuses etc).
Taking into
account the time necessary for collecting, analysing and complementing the data
and
experiences related to the implementation of the minimum efficiency and sound
power
level
requirements, the bonus and the labelling scheme, and the time needed to assess
technological
progress, including the impact of the information requirements on comfort fans,
a review of
the main elements of the framework could be presented 5 years after entry into
force of a
labelling scheme.
EN 45 EN
ANNEX 1 –
MINUTES OF CONSULTATION FORUM MEETINGS
EUROPEAN
COMMISSION
DIRECTORATE-GENERAL
FOR ENERGY AND TRANSPORT
DIRECTORATE
D - New and Renewable Energy Sources, Energy Efficiency & Inn
Energy
efficiency of products & Intelligent Energy – Europe
Brussels,
03/07/09
TREN/D3/IGS
(2009)
MINUTES
of the
Consultation
Forum on implementing measures with regard to Ecodesign and energy
labelling
for room air-conditioning appliances, local air coolers and comfort fans on 22
June 2009
Centre
Albert Borschette (CCAB), Brussels.
Participants:
see Annex 1
The
Chairman opened the meeting by recalling the aim of the proposed two implementing
measures
which is to improve the energy efficiency of the appliances in question, hence
contribute
to the 20% energy efficiency target set for 2020. The Commission Staff Working
Document on
a possible Commission Regulation implementing Directive 2005/32/EC with
regard to
air-conditioning appliances, local air coolers and comfort fans (Annex 2) lays
done
the
principles to set minimum requirements phasing out the less efficient models
from the
market,
including a revision of the labelling scheme on air-conditioning appliances in
order to
drive the
market towards more energy efficient models.
A power
point presentation38 on the key aspects of the Commission Staff Working
Document39
was presented. In general, the approach proposed was welcomed by the
stakeholders
and it was agreed that the details of the efficiency calculation method would
be
further
specified and agreed based on a working group to be launched after the meeting.
Stakeholders
were welcomed to express their interest in participating this technical working
group.
Scope
ECOS
(European Environmental Citizens' Organisation for Standardisation), speaking
in the
name of
environmental NGO's40, was worried about allotting a separate class for LACs
and
RACs41,
which could lead to increased sales of the more inefficient LACs. EPEE was
concerned
about LACs being in a separate category, as RACs would also be facing much
38 See
Power Point presentation discussed during the meeting and available on CIRCA.
39 Annex 2.
40
Including INFORSE (International Network for Sustainable Energy), EEB (European
Environmental
Bureau),
CAN (Climate Action Network Europe), Greenpeace European Unit, WWF-Europe. 41
LAC = local air cooler; RAC = room air-conditioning appliance.
EN 46 EN
higher
requirements than LACs and requested that DDs42 and window units be considered
as
RACs also
below 2.2 kW output level. CECED requested the power limit for LACs should be
indicated
in input power rather than in output power.
IT agreed
with the scope as proposed but emphasised that DDs and SD43s are different
appliances:
DDs are an important type of an appliance used in historical buildings, where
no
outdoor
units are allowed due to local legislation, while SDs are movable and serve
other
purposes.
IT also unfolded that fixed DDs can cool a room while SDs can not and that
these
appliances
also exist with heating function, while window units are not movable and are
very
rare in the
EU. If SDs and DDs were removed from the market, a group of consumers would
be deprived
from the service provided by these appliances. IT saw no need to change from
input power
to output power but to define DDs as LACs.
ANEC
understood that LACs may need to be kept in a separate category but that their
sales
should not
be promoted due to their low efficiency. ECOS requested reducing the use of
LACs and
even to ban if possible, especially the window and through-the-wall units,
which
are not
needed. Eurovent was concerned that if installed DDs are considered LACs, it
would
lead to a
replacement of all split units by DDs and suggested that split DDs be
classified as
package
DDs. CECED explained that if this was to happen it would have already happened,
as the
price difference already exists. Also, this is not likely to happen due to the
different
service
that the appliances provide.
The Chair
concluded that window and through-the-wall units seem to be less important for
the
markets
while SDs and DDs serve a specific purpose, DDs being closer to RACs than LACs.
As a
complement, the lower efficiency of DDs should be clearly indicated to the
consumer in
the energy
label.
NL
requested that the CF44 category 'other fans' be specified so that all other
types of comfort
fans would
be included in this category.
Parameters
for Ecodesign measures
The Chair
introduced the subject in summarising that the preparatory study identified
three
environmental
parameters; energy in use, noise and the impacts of refrigerants. No further
environmental
parameters were identified by stakeholders for the planned Ecodesign
measures.
The Chair stressed that it is important to ensure that no overlapping
requirements
are set
with other Community law.
Requirements
on energy efficiency
ECOS
reported that the proposed minimum energy efficiency requirements are too low;
when
the
requirements are in force in the EU in five years from now the levels of
ambition in third
countries
is already far higher. ECOS proposed to quickly go to LLCC level and to set
minimum
requirements at benchmark level in five years from now, including the
modification
of the
labelling scheme accordingly. ANEC required more stringent requirements on LACs
due to
their inherently lower efficiency compared with RACs. The UK supported the view
of
low
ambition level in relation to the benchmarks. EPEE informed that in Japan there
are
42 DD =
double duct.
43 SD =
single duct.
44 CF –
Comfort fan.
EN 47 EN
energy
efficiency targets for industry and that minimum requirements on
air-conditioning
appliances
can not be further proposed due to building structure limitations; design of
appliances
would be very difficult if highest possible efficiency levels were required.
Eurovent
informed that there is a difference in efficiency between small and large
appliances
and stated
that there is no SCOP data available from third countries or from European test
laboratories.
SE, the UK
and DE stated that it is difficult to comment on the level of ambition, as the
cutoff levels are not known and as the testing procedure is not yet clear. SE
offered its expertise
in testing
appliances in lower temperatures and suggested to start the labelling scale
from the
level of
the minimum requirements of the first stage. The Chair agreed that no empty
classes
should be
accepted.
For
clarity, a comparison of minimum requirements between the US and the proposed
EU
requirements
was shown indicating that the levels are comparable and corresponding about to
the level
of the present A labelled appliances in the EU. It was also shown that mini
split
products
sold in the US were considerably more efficient than the ones sold on the EU
market. The
reason is the existing minimum requirements on mini splits in the US. It was
also
explained
that the proposed levels of the requirements will be very ambitious for
non-inverter
technology
but clearly less demanding for inverter technology banning about 60-65% of RAC
appliances
currently on the market.
Eurovent
considered that also a big part of inverter appliances would be banned but this
would have
to be confirmed by measurements in laboratories. ECOS agreed that an important
part of
appliances current on the market would be banned but that the European
airconditioning sales are composed of very low efficiency appliances. ECOS
confirmed that
based on
their knowledge the US reconsiders reviewing the current minimum requirements.
As
manufacturers are the same in all markets, there is no significant cost for the
industry to
deliver
more efficient appliances also to the European market.
Eurovent considered
that the comparison with the US markets is not appropriate as the
appliances
are different and the building restrictions may differ. It also takes time to
depreciate
R&D costs and to invest on new product categories. Also, the number of
R&D
personnel
is limited. The Chair welcomed further information on this issue for the needs
of
the impact
assessment.
FR proposed
that, in order to give time for the industry, the first requirements could be
introduced
very quickly at lower level and the second requirements later on with very high
level of
ambition. ANEC supported a very rapid introduction of requirements as, e.g. in
Germany,
the sales of air-conditioning appliances grow annually by 8%. EPEE considered
the
2 year
space between the introduction of the requirements is too short a period given
the
redesign
cycle of 3-5 years.
IT
requested that the levels of the minimum requirements correspond with the lower
levels of
the
labelling classes.
On CFs, it
was explained that the proposed levels corresponds with the minimum
requirements
in China, except as to values for minimum requirements for ceiling fans, which
were
incorrect and would be corrected. For ceiling fans, US and Taiwan have higher
values
but they
are based on a different (non-international) measurement standard. For the
European
EN 48 EN
requirements,
it is important to use an international standard, which is also used in China,
as
most CFs
sold in Europe originate from China. The preparatory study was not able to
acquire
sufficient
data to suggest second tier requirements despite of serious attempts. Despite
of the
fact that
the savings from the CFs are only between 0,5-1 TWh by 2020, it was considered
important
to clean the market from the worst appliances and to stop even worse appliance
entering
into the European market, in particular, as the Chinese minimum requirements do
not
apply on
exported products. Also, the sales of CFs strongly increase with heat waves due
to
very low
purchase price.
It was
suggested to stick to the proposed fan impeller classes in order to be in line
with the
international
standard. It was also informed that the proposed levels of requirements for
ceiling
fans were not correct in the Commission Staff Working Document due to a writing
mistake,
which would have to be corrected.
NL enquired
why SFP was not used and on what the benchmark values were based. It was
replied
that the SFP is useable when a fan is ducted while service value is more
adapted for
duct-free
systems; for CFs, only velocity of the air is relevant, not pressure.
Benchmarks exist
also in
China although there is no statistical data to back these levels in the
European markets.
NL further
queried if it made sense in setting BAT levels on this basis. The Chair agreed
that
it would be
necessary to consider whether benchmarks could be set on CFs.
The UK
regretted that second stage requirements were not possible and wondered why the
requirements
on tower fans were so much lower than on other types of fans. It was confirmed
that
because of the different shape of the fan blade of tower fans, they were
inherently less
efficient
than other CFs. They provide directional air flow due to which they use less
floor
space and
are used for more targeted ventilation purposes. The same approach is taken in
the
minimum
requirements in China.
Noise
EPEE
expressed its dislike for minimum requirements on noise, as noise is considered
to be
self-regulated
by the market; consumers require low-noise appliances. In any case, noise
requirements
should be divided in three classes with appropriate power ranges. ANEC voiced
an opposite
opinion emphasising that more ambitious noise requirements are necessary
corresponding
to 55 dB(A) for the indoor unit. IT wondered if noise requirements are
necessary
given that energy efficiency and noise are competing entities. EHI, supported
by
ANEC,
articulated that high noise is not necessarily related with low energy
consumption, and
noise is
essential for consumers alike with noise from other energy using products. ANEC
declared
the importance of noise in particular as these appliances are also used in
rooms,
where
silence is primordial, such as bed rooms. ECOS asserted that there is a large
variety of
noise
levels on the market and that the benchmark allows higher requirements on
noise.
Eurovent
reminded that the benchmark depends on the size of the appliance. CECED
interpreted
that noise is important for consumers and expressed its support for information
requirements
on noise for the indoor and outdoor units but refused minimum requirements.
CECED
disclosed that the benchmark level does not correlate with size and technology.
The Chair
concluded that noise requirements are necessary for the benefit of the consumer
but
they should
be set at reasonable levels in order to avoid possible harm for technological
development
on energy efficiency. The Chair considered the proposed noise requirements low
in
comparison with the benchmarks of 46dB(A) and 55 dB(A).
EN 49 EN
GWP Refrigerants
The
Commission staff presented the main elements of the F-Gas Regulation. The
Regulation
covers the
use of HFCs, PFCs and SF6 in all their applications, except air conditioning in
vehicles.
The objective of the Regulation is to contain, prevent and thereby reduce
emissions
of
fluorinated greenhouse gases covered by the Kyoto Protocol. The application
domains are
refrigeration,
air-conditioning, heat pumps and fire protection units. It puts the onus of
responsibility
on operators to prevent leakage of F-gases and to repair any detected leaks as
soon as
possible. All F-gas containers will have to be labelled and recovered by
certified
personnel
for the sake of recycling, reclamation or destruction. Certification programmes
aim
at making
installers aware of the dangerous substances in appliances and to ensure
adequate
treatment.
ECOS
clarified that F-gas Regulation focuses essentially on avoiding leakages but it
does not
promote
alternative refrigerants and that Ecodesign could promote alternative refrigerants.
ECOS,
supported by IT and the UK, explained that an overall CO2 figures would not
serve
the
purpose, as it includes the whole European energy mix. However, a specific
pictogram
could
indicate the existence of low GWP refrigerants in appliances.
EPEE
elucidated that appliances with low GWP refrigerants do not necessarily reach
the same
efficiency
as appliances with traditional refrigerants. If CO2 would be indicated, the
proposed
approach
would be appropriate.
DK stressed
that installing should happen by certified installers in line with the practice
in
Denmark. DK
agrees with the Working Document that CO2 should not be regulated but the
Regulations
should require that installation be made by professionals. Commission services
disclosed
that the F-gas Regulation already deals with these problems in requesting air
conditioning
appliances to be installed by certified personnel, including maintenance,
service
and
recovery of refrigerants. As to the regulation of low GWP refrigerants, it was
noted that
the
Ecolabel provides with 15% lower energy efficiency requirements on appliances
with low
GWP
refrigerants than for other appliances. CECED expounded that whether the 15%
figure
is
'correct' or not is difficult to know; it is possible that appliances with low
GWP refrigerants
are already
as efficient as appliances with traditional refrigerants. A bonus relative to
the
GWP level
achieved could be more appropriate. EHPA asserted that the environmental impact
is
negligible with direct emissions of refrigerant due to leakages and at
demolition being only
4% of the
average EU total equivalent warming impact (TEWI) of air-conditioners and heat
pumps.
IT added
that knowing the direct emissions could be useful for the consumer but a
solution
should be
found to indicate CO2 in the case of hermetically sealed appliances; leakages
only
happen when
an appliance is broken or when the installation is badly handled. It may be
necessary
to add an additional category of hermetically sealed compressors. Eurovent
supported
the specification of hermetically sealed appliances (as in F-gas Regulation)
independently
from technology.
CECED,
supported by the UK, voiced the importance in leaving the regulation of
refrigerants
for the
F-gas Regulation to avoid overlapping legislation. Products with low GWP
refrigerants
should be
promoted. This was supported by DE. Hydrocarbons are used today in 99% of
refrigerators
with an equal efficiency to other refrigerants, while the efficiency of these
appliances
used to be some 30% lower at the beginning when hydrocarbons were introduced
in
refrigerators; shift to low GWP refrigerants is possible, e.g. propane for
LACs. EHPA
supported
the CECED view but requested to be cautious in ensuring that safety and energy
EN 50 EN
efficiency
do not deteriorate. EHPA also confirmed that the use of low GWP refrigerants in
air-conditioning
appliances is not as easy as in refrigerators. It was confirmed that
hydrocarbons
are already used in some split units in Australia and China. Eurovent confirmed
that the structure
of the appliance is not decisive but safety, e.g. in the use of propane; what
ever the
decision, industry will need time to innovate with new technologies.
The Chair
concluded that the regulation of refrigerants should be left for F-gas
Regulation and
that a CO2
label could be counterproductive due to misleading information it would
provide.
Leakages is
an issue that could be dealt with at the level of information requirements to
be
displayed
on the packaging and technical documentation of the product to inform
installers
and
consumers. Suggestions in these lines were welcomed by stakeholders. Also, no
bonus on
low GWP
refrigerants should be given in the energy label, as it focuses on the energy
consumption
of the appliance. However, it should be considered on how to give such a bonus
through the
Ecodesign information requirements.
Energy
labelling
The Chair
recapitulated the main issues based on the Commission Power Point presentation45.
It was also
outlined that a solution should be found for the problem of oversizing, which
costs
up to
10-15% of the energy bill. Oversizing up to a factor of 7 is not uncommon (e.g.
in
apartments).
Currently installers do not make a heat balance of the dwelling in two-thirds
of
the cases
and when it is done it is often overstated. Although the load profiles S, M, L
are just
different
names for output power classes (in kW) they would have the advantage of easier
communication
between consumers, better comparability between units and above all –when
accompanied
by appropriate promotion at MS level—they could help in fighting the one-onone
replacement (in kW) that is the current practice
EHPA
responded with distaste to the proposed space heating profiles (S, M, L…) for
the
alignment
of the heating function of heat pumps between Lots 1 and 10; it would not be
understood
by consumers or installers. Also, EHPA, supported by Eurovent, stated that
appliances
falling in between categories would suddenly show inefficient although in real
life
they could
be very efficient. It is better that manufactures indicate the heat load for
which
appliances
are suitable in terms of kWh/year. ANEC confirmed that the proposed symbols
would not
be understood by consumers and stressed that also the indication of the output
power of
the appliance (kW) is illegible for consumers, in particular as room seizes
strongly
vary
between Member States.
ANEC
suggested considering indicating the size of the room in m2 or m3, as the
customer
knows the
room to be cooled down. This is also supported by recent tests made by Stiftung
Warentest.
Eurovent expressed its preference for output power (kW) of the appliance, as it
is
clear for
installers, and consumers will be able to learn its meaning, while m2 and m3
refer to
wide range
of different real life conditions e.g. in the Northern and Southern Member
States
of the EU.
The proposed heat load profiles (S, M, L…) would force manufacturers to
optimise
appliances
for these fixed points, which is not the purpose of Ecodesign. EPEE supported
in
comparing
the difference in cooling load e.g. in a room directly under a roof and in the
ground
floor. BE
and SE went against the indication of (S, M, L…) and BE considered the
indications
of kWs
important but understood that consumers would also like some indication of the
size of
45 Slides
14 -15.
EN 51 EN
the room to
be cooled. ANEC supported proposing to indicate the power consumption per
year and
the range of room sizes and types to be cooled.
NL reminded
about the importance of the difference between cooling need and the capacity of
the
appliance; the expression in kWs is not appealing for consumers. It is
important to indicate
both the
size and capacity of the appliance but it is not useful to indicate the
capacity for
cooling a
given space in square meters, as the quality and nature of these square meters
is not
known.
CECED agreed that the indication of kWs is complicated for consumers but
reminded
that this
information must be enforceable and understandable for market surveillance
authorities.
If the label would include the indication of the range of usage e.g. in m2, it
would
still not
be enforceable nor would it mean the same thing in different climates and in
different,
e.g. in old
and new buildings. For example, if a space of 150m2 need to be cooled; all
appliances
at least from three different ranges of capacities would do, depending on the
nature
of the
building/room and the climate.
EPEE
reiterated in comparing the proposed M class heating capacity for old (90m2)
and new
(230m2)
buildings – and climate is not yet even considered in this range; capacity of
the
appliance
provides the most correct information. EHI added preferring also output power,
which is
understood by specialists being responsible for installation of RACs. DK
requested
indicating
the price of the annual energy consumption, as consumers are becoming more and
more aware
of the price of energy.
On the
labelling scale, DK, supported by ANEC, EHPA and Eurovent, stated that if RACs
and LACs
are put in two separate labelling scale, consumers would be guided to buy the
cheapest
(less efficient) products; RACs and LACs should be in the same scale. Also, it
was
suggested
that a specific pictogram could indicate the existence of low GWP refrigerants
in
the label
and EHI and Eurovent proposed indoor and outdoor noise to be displayed on the
label.
The Chair
intervened in concluding that if RACs and LACs were presented in one labelling
scale there
would be a need to identify the range of capacity or usage for the appliance.
The
consumer
need to be told for which conditions the appliance is optimised and link the
A-G
labelling
accordingly. Also 'second-choice' usage conditions could be indicated with
information
on the corresponding (lower) labelling category. The choice of the number of
alternative
space cooling/heating profiles indicated could be left for manufacturers as
long as
the
corresponding energy labelling classes are displayed, identifying e.g. between
optimum,
minimum and
maximum range of usage. The Chair invited stakeholders' further suggestions.
IT reminded
that the more there are size categories the more there are tests to be made,
which
is
impossible for Member States. The Chair agreed that the amount of points to be
measured
must be
limited.
EN 52 EN
Annex 1:
List of participants
Surname
Name Organization
AKKERMAN
Floris Federal Institute for Materials Research
and testing
ANTOINE
Pascal EHI
BAERT Els
EPEE
BALDONI
Giulia Eurocommerce
BISSON
Evelyne Délégation française
BLICKWEDEL
Peter Federal Ministry for the Environment …
BONCHEV
Bontcho mINistry of Economic & Energy
BÖTTCHER
Christiane Stiftung Warentest
BOYE OIESEN
Gunnar INFORSE Europe
BRISCHKE
Lars dena
CALLEWAERT
Philippe EUROVENT
CLIQUOT
Nathalie EEB
CREVECOEUR
Guibert Federal Public Service Economy
DE GROOT
Maya
DIERYCKX
Martin EUROVENT
DUPLAT
Françoise ORGALIME
ESTVANIK
Andrej slovak delagation
FABBRI
Mariangela WWF EPO
FORSEN
Martin EHPE
GALSGAARD
Christen EUROVENT
GRÖGER Jens
ÖKO-INSTITUUT
HERRERIAS
Enrique Fundacion para el foment ode la
innovation
industrial
IPAVEC
Edvard Ministry of the Environment
KALLIOMÄKI
Pekka Ministry of the Environment
EN 53 EN
KATAOKA
Osami EPEE
KULBAS
Heikki Ministry of Economic Affairs & Comm
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