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EUROPEAN COMMISSION DIRECTORATE GENERAL JRC
JOINT RESEARCH CENTRE Institute for Prospective Technological Studies (Seville) Sustainable Production and Consumption Unit
Revision of EU Ecodesign Regulation and Energy label regulation
for Household Dishwashers
1st TWG Meeting
23 June 2015, 9:00 – 18:00
Hotel Ribera de Triana
Plaza Chapina, S/N
41010 Seville,
Minutes of the meeting
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Participants List
Name Surname Organization
1 Farnaz ALBORZI Bonn University
2 Fulvio ARDENTE Joint Research Centre
3 Floridus BECK RUSZ (attending on behalf of RREUSE)
4 Rasmus BOLDSEN DG ENV, European Commission
5 Karin BOTH DIN Consumer Council
6 Alicia BOYANO LARRIBA Joint Research Centre, Spain
7 Cristina CAÑADA IDEA
8 Luise CHRISTMANN Miele & Cie. KG
9 Mauro CORDELLA Joint Research Centre, Spain
10 Gundula CZYZEWSKI BSH
11 Claudio DIODATO ELECTROLUX
12 Chloé FAYOLE ECOS
13 Klaus-Martin FORST BSH Hausgeräte GmbH
14 Kathrin GRAULICH Oeko-Institut e.V.
15 Andreas HALATSCH UBA
16 Gerhard HEILMANN ANEC/BEUC
17 Ina HOOK University of Bonn
18 Ciara LEONARD Electrolux AB
19 Angeliki MALIZOU ANEC and BEUC
20 Nicola MARCHESI Indesit Company
21 Francesca MELONI Indesit Company
22 Hans MOONS Joint Research Centre, Spain
23 Helena NILSSON Swedish Energy Agency
24 Jeremy OWENS Intertek Testing & Certification
25 Matteo RAMBALDI CECED
26 Paul RICHTER AB Electrolux (only coming day 1)
27 Ina RÜDENAUER Öko-Institut e.V.
28 Valerie SEJOURNE A.I.S.E.
29 Hans-Paul SIDERIUS Netherlands Enterprise Agency
30 Roland SIEDENTOPF Electrolux
31 Barany SOTHIRAJAH Amdea
32 Rainer STAMMINGER Universität Bonn
33 Martin STICKEL BSH Hausgeräte GmbH
34 Emilie STUMPF CECED
35 Bruno VERMOESEN BSH Home Appliances Group
36 Alejandro VILLANUEVA Joint Research Centre, Spain
37 Carsten WACHHOLZ European Environmental Bureau (EEB)
38 Oliver WOLF Joint Research Centre, Spain
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Agenda
1. Opening and welcome 9:00 – 9:15
2. Political framework of the project, timeline and status 9:15 - 9:30
3. Task 1 – Scope, definitions, legislation and standards 9:30 – 10.15
4. Task 2 – Market analysis 10:15 – 11:15
Coffee break 11:15 – 11:30
5. Task 3 - User and system aspects
Includes a presentation of preliminary results of the 2015 survey on
user behaviour in the EU
11:30 – 13:15
Lunch break 13:15 – 14:30
6. Task 4 – Technologies 14:30 – 15:30
7. End of life and material efficiency 15:30 – 16:30
Coffee break 16:30 – 16:45
8. Synthesis, next steps and planning of follow-up
Data needs for base cases, design options and policy scenarios for use
in the forthcoming environmental and economic assessment
16:45 – 17:45
9. Any other business and conclusion of the meeting 17:45 – 18:00
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Contents Overview of process for the revision of the Ecodesing and Energy labelling for Household Dishwashers .. 5
Scope and definition of product group "Household dishwashers" ............................................................... 5
Discussions on Market Data .......................................................................................................................... 8
Discussions on User behavior ........................................................................................................................ 9
Discussions on Technologies ....................................................................................................................... 10
Discussions on End of life ............................................................................................................................ 11
Future steps and scenarios .......................................................................................................................... 12
Closing of the meeting ................................................................................................................................. 14
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Overview of process for the revision of the Ecodesing and Energy labelling for Household Dishwashers
After welcoming the stakeholders and a round of introductions, JRC-IPTS presented the process
for the revision of the Ecodesign Regulation and the Energy Regulation for Household
Dishwashers (DWs).
The presentation was finished by highlighting the coming steps of this process. The deadline for
sending written comments on the preparatory studies through the BATIS system was set on 31th
July 2015. A second Technical Working Group meeting is planned for 17 November 2015.
Scope and definition of product group "Household dishwashers"
A brief summary of the current and prosed definition and scope for this product group was
presented. The main differences were highlighted and brief explanations of the reasons behind
were included as reported in the Preparatory Report. During the presentations, only relevant
figures and facts found during the investigations were commented but stakeholders were invited
to comment on any aspect or issue they considered of relevance.
The text on the scope and definition was introduced and several questions were addressed to
stakeholders regarding several aspects to start the discussions.
The first point of discussion regarding the scope was centered in the exclusion of household
machines batteries-operated from the scope. The reason behind this exclusion is the lack of the
relevance of this type of machines on the market. Stakeholders welcome the proposal but pointed
out the need of clearly indicating that it is applicable to DWs that are solely operated by batteries
and not to those appliances that either have a battery as one of their components to operate
auxiliaries or those that can be both mains-operated and operated by batteries (e.g. battery back-
up).
Secondly it was discussed the ways the scope can refer to the intended use of DWs (household,
professional or semi-professional). A proposal was presented making differentiation by scope of
Low Voltage Directive (household appliances) vs Machinery Directive (professional appliances).
It was pointed out that no reference to the intended use is needed in the scope of the household
DWs as the newly proposed definition of this product group already excludes those machines
intended to be used for professional and semiprofessional uses by means of the Declaration of
Conformity (DoC) in accordance with the Low-Voltage Directive 2066/95/EC. However, it was
also commented that the difference between the intended uses is not explicitly mentioned in the
DoC, although it is only applicable to household type machines, and it does not explicitly
mention the exclusion of non-household appliances as the current scope does. This fact could
cause confusion and will be checked carefully.
Finally, it was proposed to delete the mentioning of built-in appliances in the scope. This
remark is considered irrelevant as this type of machine should comply with the same
requirements that other types of DWs covered by the scope of the regulations. Stakeholders
welcome the proposal but they pointed out that the Energy Label Directive should be checked
before the final drafting to determine if it requires explicit mentioning of built-in
The definition proposed included several changes that were thoroughly discussed. The proposed
definition consists of three parts: the first one describes the functions of the DWs and the ways in
which the cleaning can be carried out, the second one highlights the inclusion or non-inclusion of
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the drying process at the end of the cycle and the third one points out the main intended use of the
DWs as household appliance by means of the Declaration of Conformity.
General agreement was expressed regarding the definition point that includes the main
functions of DWs, since it is pretty close to the definition already in place. That means to rinse,
clean and dry dishware, glassware, cutlery and cooking utensils by chemical, mechanical, thermal
and electric means.
Several opinions were given regarding the allowances of cycles with or without drying process
at the end of the cycle. Some stakeholders found that drying is one of the main functions of the
DWs and that this process should be always included. If not, it would be possible to sell DWs
without the drying function. Other stakeholders consider that the proposed definition is in line
with the definition in the Standard EN50242/IEC60436 and that it reflects the real-life and market
where there are programs that do not carry out a drying process at the end of the cycle (e.g. short
or fast programs focus on cleaning and not on drying processes). The purchase of a DW without
the drying function is not possible. All DWs should demonstrate their performance by
compliance with the Energy label and Ecodesign regulations that require testing against the
standard program including both cleaning and drying processes.
The discussions about the scope and definition of DWs were followed by discussion on the
current standard on the performance for DWs: EN50242/IEC60436 and the revision
activities that are taking place.
Stakeholders informed that the revision activities of the standard were almost finished and
strengthened the importance of aligning the new regulation with this last revision. Among the
modifications proposed for the standard EN50242/IEC60436 are for example the inclusion of
pots and pans and plastic dishware in the load. It was also pointed out manufacturers will
develop/optimize programs that reach the updated requirements conform the adoption of the new
standard.
General agreement was expressed about the non-inclusion of half load cycles in the standard
program (Eco) although evidences demonstrate that users do not always fully load DWs similar
to the standard protocol. It was pointed out that the inclusion of half load in the testing program
can be regarded as counterproductive and a wrong signal to the consumers. On the contrary, it
was pointed out the importance of making consumers be aware of the multiple benefits of
dishwashing full loads. Education of consumers on this aspect should be done by all the parties
involved in the project: manufacturers, detergent industry, authorities, consumer associations, etc.
Concerning the loading of the DWs, it was commented the differences between the volumetric
load and the mass load. Currently standard EN50242/IEC60436 is based on mass load. However,
consumers consider that they fully load DWs based on a volumetric basis. The main difference
between both loadings comes from the difficulties for setting pots and pans into the ranks. This
problem is expected to be worked out in the future as the new revision includes pots and pans into
the place setting requirements.
Mismatches in the nomenclature and the requirements between the regulation and the
standard were brought on the table. Currently the regulation requires the performance of the DWs
to be tested against the mostly/highly use program by the consumers and it is called "standard
program". However, the standard requires DWs to be tested against the Eco-program and asks for
the inclusion on this name on the selection panel.
Regarding this issue, stakeholders asked for harmonization between the names, highlighting the
advantages and disadvantages of adopting the name Eco in both regulation and standard. It was
stated that the Eco name can be a good candidate for both documents because consumers are
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already used to it, it can easily identify the program in the selection panel and communicates the
fact that it is the most efficient program regarding energy and water consumption simultaneously.
On the other hand, in the Regulation the “standard program” refers to the program that cleans
normally soiled tableware and should be the one that is mostly used by consumers.
As disadvantages of including more than one program in the testing, it was mentioned that
although a combination of programs would give a better picture of the energy and water
consumption as well as the cleaning and drying performance of the DW, it would not be possible
to set just one program as default program (what is also required by the regulation) and it would
significantly increase the testing costs. According to the last data, Eco, automatic and short
programs are among the mostly used ones. However, automatic programs are difficult to be
standardized to fulfil the requirements of a testing program.
Another mismatch between the regulation and the standard refers to soiling in the testing
program. According the regulation the standard program should be designed for cleaning
normally soiled tableware while the Eco program is tested with heavily soiled dishware.
Additionally, it was pointed out that the type of soil is revised in the new standard to better match
the real life.
Finally discussion was focused on how the revision of the standard will affect the Energy
Efficiency Index (EEI) and other values to be reported in the Energy label. Although it was
pointed out that the revision was recently finished (two months ago) and that manufacturers have
started to test according to the new conditions, it is still too early to accurately report the
differences. It is expected that the changes in the testing conditions could lead to incomparable
values and therefore a way to communicate the changes to the consumers and a method to
calculate possible equivalences between the new and the old EEI values should be investigated.
Verification and uncertainty tolerances were the next point of discussion. The new test
procedures could imply new uncertainties and then it may be advisable to revise the tolerances for
verification included in the Regulation text, especially for market surveillance. Also absolute
uncertainties should be taken into account with respect to the bandwidth of the energy label
classes. There is already a working group (TC59X) that is dealing with this topic and its chairman
(Mr Stammiger) offered to provide some information. Regarding this issue, the changes in the
test procedures are not expected to lead to a higher uncertainty, but this fact should be confirmed
by the results of Robin Round Tests (RRTs). At this point, it was pointed out the importance of
RRTs to set the most appropriate value for the uncertainty tolerances. If excessively large
tolerances were set then this would allow room for manufacturers to claim better performance
standards than the products were capable of achieving. This would lead to misleading information
given on the Energy labels and undermine the Ecodesign objectives.
No additional tolerances on noise are required because verification is already included in the
standard. Verification procedure of the noise is however being revised and a shift towards the 1+3
procedure (if non-compliance) is under consideration.
Regarding the double rounding detected in the current standard and energy regulation, it was
stated that the revision should align to a specified method on how to do the rounding and not only
to ISO 80000-1:2009 "Quantities and units, Part 1: general". Translation of the standards into the
different languages should also be carefully done and revised as it seems to be one of the sources
of misunderstanding.
Discussions were held on low-power modes and how they can be regulated. It was pointed out
that low-power modes should be regulated. Additionally, it was highlighted that whatever the
approach is chosen, it should be kept in mind the development of the market towards demand-
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response DWs with a bunch of new “smart” functions that should be regulated too. Low-power
modes and other functions should be regulated because although they do not consume large
amounts of energy (e.g delay start consumes approximately < 4kWh/year per DW), they are on
for long periods of time (in the case of the delay start) and in a large number of DWs in Europe.
Moreover, this type of functions is also relevant in the smart appliances that are getting more
popular in the European market. The discussions on how the low-power modes can be regulated
highlighted two different ways: through a horizontal target included in the stand-by regulation
(EC) No 1275/2008or in the network standby regulation or through a vertical approach setting
limitations in the Ecodesign regulation. Regardless the approach to be implied, there was a
general agreement that double regulation should be avoided.
One stakeholder pointed out that the advantage of setting a horizontal target is the harmonization
with other products that have similar low power functions. In this way, a cap on the maximum
energy consumption would set up for each of the low-power modes in the Stand-by regulation.
DWs are included in Annex I of this regulation and listed as one of the energy-using products
covered by that Regulation. However, and as pointed out for several stakeholders, DWs have
functions that do not fall under those included into the stand-by regulation due to several reasons
such as for example a limited duration. This is the case of the delay function. Therefore, a vertical
approach is needed including the requirements in the Ecodesing regulation. It should be checked
if specific requirements for these kinds of functions are necessary for DW or if they should be
included into the formula that calculates the EEI.
Discussions on Market Data
The collected market data were briefly presented and feedback regarding the accuracy of those
data was requested to be sent in written comments through BATIS.
The importance of the market data was highlighted and pointed out that accurate data are needed
to properly set the most representative base cases of the European market and to be used in the
coming tasks of this project and later on in the Impact Assessment. The selected base case(s) will
also influence the bill of material. During the presentation two base cases were proposed: a 12 or
13ps DWs as representative of the full-size machines and a 9ps DW as representative of the slim-
line DWs.
Regarding the capacity of the DWs, it was pointed out that the revision of the testing performance
standard will affect the number of place settings per model although place setting will continue
to be the capacity indicator. In the new revision of the standard, place settings will not only be
defined as a set of crockery, glass and cutlery but some pots, pans and cooking utensils will also
be included. This fact makes that the current capacity might be different from future revised
capacity for the same DW model. (e.g. a DW with a current rated capacity of 12ps could be
ranked as a 11ps with the new standard).
It was commented that although initially the tendency of the market related to the capacity seems
to be growing, limits are about to be reached. This is due to the limitation of the DW volume to
be fitted into the kitchen furniture and confirmed by the fact that not all the companies
manufacture 13ps DWs.
Finally, stakeholders pointed out the importance of promoting the use of DWs vs. the hand
dishwashing since DWs comparatively save water and energy. This fact seems to be relevant
even when the large DWs are not fully loaded.
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Discussions on User behavior
A brief presentation of the main results and trends observed from an independent user survey
carried out in the last months was presented by Mr Stamminger. This study was welcomed by the
stakeholders. A round of clarifications and related questions took place afterwards.
The most remarkable issues pointed out that:
- pre-rinsing of each item is carried out by 33% of the DWs users. This fact significantly
increases the amount of water consumed and off sets environmental benefits of using a
DW. It was not yet correlated if pre-rinsing is mainly done by small families that use less
often DWs (e.g. single member families conduct 2.7cycles/week vs. 7cycles/week in
families with or more than 4 members)
- the mostly used programs are normal (44%), eco (22%), short (10%) and intensive
(8%). These data highlight the importance of the short and automatic programs.
Additionally, it was commented that the total sum of those programs which run at lower
temperature is higher than 50% and this number is probably increasing with new
machines with the Eco-program as default program getting on the market.
- users do not welcome long lasting programs. Long lasting programs are not even
chosen to be run at night, likely because users do not like to let the DWs running without
control. Noise emissions seem not to be an issue for dishwashers running at night.
- however, if users would know that cycles with a longer time can save energy and water,
they would be more willing to accept longer cycle times. The survey shows that the
consumer is not informed about the Sinner cycle. It was mentioned that mainly the drying
phase is responsible cycle time of dishwashers.
- the consumer survey also showed that information before purchase is mainly gathered
online.
- items mostly cleaned by hand are pots and pans. The main driver for not putting pots
and pans in the dishwasher is believed to be the lack of space in the dishwasher (as they
occupy a lot of space), the scarcity of these utensils in comparison to cutlery, glass and
plates and the fact that these items usually should be readily available. The inclusion of
pots and pans in the new standard could lead to a different configuration of the baskets
and ranks in a dishwasher. This is important to compare data which are now attributed to a
number of place settings with future requirements that can be related to number of place
settings as well.
- The consumer criteria (parameter of decision) for purchasing a machine have been
confirmed by a stakeholder and the results of a German survey that was focused on energy
consumption and durability.
Further analysis will be done which will provide more in-depth knowledge of consumer
behaviour and the reasons that trigger this behaviour e.g. a further breakdown related to
household size or to the age of the machine.
The consumer survey data will be compared with previous AISE consumer survey results which
show a penetration rate on the European market of 60%, a frequency of use of 4.3 cycles/week
and a loading of 90%. AISE also provides tips to consumer on how to use best a dishwasher from
the environmental point of view.
One stakeholder raised the question if the cost of energy and water use should be presented on the
label. This question had not been put forward in the consumer survey. The consumer survey did
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show however that the consumer is particularly interested in consumption values when buying a
new machine, but the question in the survey did not explicitly ask for the cost of these
consumption values.
It has been questioned if there should be a differentiation in cleaning performance and if this
should indicated on the label. Nowadays the minimum cleaning requirement is a cleaning
performance class A. Some consumer organizations, such as Stiftung Warentest, provide a
differentiation in cleaning performance. This differentiation is, however, not only based on
testing the Eco-programme but also other programs such as power wash, fast wash, etc. It seems
however that the consumer is currently satisfied with the cleaning performance of the
dishwashers. This will be cross-checked with the latest consumer survey data.
The topic of consumer education has been discussed. Some stakeholders pled for campaigns and
consumer responsibility (no pre-rinsing, low temperature programs and full capacity use), while
others remark that not everything should be left to consumer education. There is already a lot of
information available and at the disposal of the consumer that can even be considered excessive.
Moreover, the difference in cost between the different programs is too small to convince the
individual consumer changing the program s/he is used to use.
In real life, the energy consumption of all programs is lower than the energy reported in the user
manuals or in the energy label because of a lower load in weight (i.e. usually less weight in the
machine than in the standard protocol, even when loaded volumetrically full). Less weight
automatically leads to lower energy consumption as less mass has to be heated up.
Regarding the display of consumption values on the machines, it was remarked that not all
dishwasher have a display which makes it difficult or impossible to display certain information or
consumption values before or after the program cycle as certain manufacturers already do. The
consumption values of all programs should be included in the user manual. However, these
values are not always specified accurately as broad ranges of values can be provided. The
rationale for putting ranges of consumption values instead of exact values is that the dishwashing
circumstances can vary (circumstances which can be specific for every user) and lead to varying
consumption values (e.g. half load). For automatic programs there is no other way than providing
a range of values. A solution could be to put one specific value in the booklet and add that this
can vary under changing circumstances. This would give the consumer the opportunity to
compare different programs. Further, it was stated that the product fiche cannot be obtained
anymore once the model is not on sale anymore.
A registration database could help in collecting and maintaining information.
Due to the large combination of options in the program, reporting all the energy consumption
values for all the programs and different combinations thereof in the manual would be too much.
A QR-code could be a solution as proposed by one stakeholder. A comment on this QR-code was
that a difference should be made between consumer information and which information should be
put on the label. A QR-code is also not known by all consumers.
Information on the label or product fiche is sequenced in a certain order which, according to a
stakeholder, not always makes the best sense. It was proposed to develop a template or a
standardized lay-out for information in the manual.
Discussions on Technologies
During the presentation general approaches to reduce the energy and water consumption were
presented together with technologies to achieve these savings. The intention was to identify base
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cases and technologies which are currently on the market and which are best available
technologies (BAT). Further an example of the outcome of lifecycle costing calculations was
presented. An insight on changes in the bill of materials (BOM) during the last years was
requested.
A BOM was promised to be provided as an average of at least 5 manufacturers once the base
case has been set.
An average lifetime of 12.5 years for life cycle cost calculations has been accepted, but a
distinction should be made regarding expected lifetime which depends on the use, repair and
maintenance, and warranties and thus cannot be guaranteed by the manufacturers, for example in
form of a lifetime indication on the Energy label.
Regarding the setting of a base case and possible design options for improvement, it was
stated that the base case is merely a virtual machine and the design options are technical solutions
that different manufacturers can choose to achieve certain requirements. It is important that the
focus for improvement options is not only on water and energy consumption, but it should take
other parameters such as noise, lifetime, cleaning and drying performance into account as well. It
was mentioned that information about Best Not yet Available Technologies (BNAT) could be
drawn from an investigation of recent patents although care has to be taken as some of these
patents will never be applied in the commercial market. A mathematical model of a dishwasher
could also help in investigating what happens if you change insulation, motors, etc.
A discussion on sensor technology occurred. Soil sensors are not allowed to be used during the
measurements to define consumption and performance levels according to the standard protocol.
This technology should thus not be taken into account for a base case neither as an improvement
option. Therefore, it could be taken into consideration to propose 2 base cases: a standard base
case (related to the standard measurement protocol) and a real life base case (where sensoring can
be included). Another option could be to allow sensoring in the standard protocol which could
bring the eco-program testing even closer to real life conditions. Previously, it was however
explicitly asked in the mandate to exclude sensoring from the standard protocol. Reproducibility
in the different labs would be one of the main difficulties if sensoring was to be included. The
application of a sensor could also differ from program to program. A load sensor is not seen
necessary as a lower load automatically leads to lower consumption values by some stakeholders,
whereas others discussed that a possible Ecodesign requirement could be all for DW requiring the
existence of a sensor to achieve savings during real-life usage in all programmes.
Discussions on End of life
In this session particular issues relating to end-of-life were discussed.
Regarding spare parts there seems to be a large differentiation between manufacturers: some
provide spare parts up to 10-15 years after production while other producers provide no
information or claim spare part availability below 8 years after production.
When repair costs are calculated, not only the cost of the spare part should be taken into account,
but also the costs for the professionals/technicians to fix the appliance, transport and stock of
spare parts. Producers sometimes have to produce again spare parts if not available anymore. If
spare parts are held in stock, it is sufficient that they comply with the Regulations which were in
place when they were produced. If new spare parts are to be produced, they must comply with the
current Regulations. Electric motors have been put on the table as an example.
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It is clear that repairing would extend the lifetime of an appliance. Some stakeholders proposed as
a first step to have information requirements like price and availability of spare parts. Such
information requirements should also facilitate identification of early failures. Regarding early
failures, it seems that there are no specific components which are failing systematically.
Some stakeholders proposed that recognized repair centres should have extended information
access such as access to software, repair manuals, etc. Manufacturers are concerned however
about the accountability after repair by a non-brand professional and point especially to safety
and confidentiality issues. Opening up the information of service manuals, software, hardware,
etc. to other stakeholders in the market would require a complex administration system as
otherwise this information would become public domain.
Even if some companies do design their appliances for reparability, this does not seem to be the
common approach. It is mentioned that Ecodesign should discard the worst appliances from the
market, also regarding reparability. Facilitating reparability could be established by a request for
reversal disassembly of certain components.
Regarding information requirements, it was proposed that recyclers should have access to
information e.g. by an RFID tag. This issue about an RFID tag has been discussed in the
development of the WEEE Directive and has been discarded there. One of the reasons is that the
lifetime of an RFID tag cannot be guaranteed along the lifetime of a dishwasher. According to
WEEE, manufacturers should provide recyclers with the necessary information. However,
manufacturers claim that recyclers have never come back to them with information requests.
Recyclers usually know well how to treat the appliances. However, heat pump equipped
appliances could provoke difficulties for recyclers as recyclers for white good appliances are not
always certified to also treat appliances with F-gases. It was also noted that it is not clear what the
recycling technology will be in about 15 years when currently produced machines will end up at
the recycler site. At the moment, many/most of the materials can be sorted out by the recycler
without any marking, although it was also stated that recycling technologies differ a lot between
recyclers. Furthermore, it is not only the quantity, but also the quality of recycled materials which
is important to enhance the value of the materials at the end of the waste stream.
It was asked to stakeholders to provide specific end of life requirements as this would fit into
other programs such as the resource efficiency roadmap and the 7th
environmental action plan.
Future steps and scenarios
In this session, preliminary opinions on future policy options were probed.
It was shortly discussed how the new energy label should look like. The new energy label will
depend on the outcome of the review of the energy label Directive which could propose to go
back to an A-G scale with classes A and B unpopulated in the beginning. It is advised to not take
into account redundant classes in the energy label. A differentiation for the consumer should be
provided. The new classes will also depend on the outcome of the new standard. The bandwidth
of the classes is strongly dependent on the precision and the uncertainty of the measurements.
It has to be checked if it is necessary to have different requirements for tabletop machines,
slim-line and full-size machines. Also dishwashers which are actually two dishwashers in one
should be addressed. It should also be checked if the requirements can be set independent of
capacity or at least be sure that for bigger machines it would not be easier to reach more efficient
energy classes.
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It was discussed if it would be necessary to have an ecodesign requirement for water
consumption. Average water consumption is already very low and further reduction is not
necessary. A requirement on water consumption is thus not seen necessary. Moreover, if a
requirement on water consumption would be in place, it could be that the rinsing water would be
reduced. Currently, the performance of rinsing is not addressed in the standard. It was also
mentioned that by automatic dishwashing less water is usually used than by hand dishwashing.
Regarding the definition of the energy consumption on the label per cycle or per year it was
stated that reporting per cycle could be more consumer specific as some consumers do higher or
lower number of cycles per year (variations between 130-350 cycles per year depending on the
household size). Therefore, a display of consumption per year, based on 280 cycles, could be
misleading. Per cycle could also be misleading because the energy label only refers to the eco-
programme. An option to work out this problem could be to indicate that the energy consumption
per cycle explicitly refers to the eco-programme. Moreover, it has been shown in a consumer
survey that about 70% of the consumers do not know what means “per annum”.
On the contrary, another stakeholder stated that it would be better to state the consumption “per
annum” as it would give a reference value to the consumer that s/he can easily compare. It was
added, that s/he probably does not know how many times s/he uses the dishwasher per year and
that the difference in energy consumption per cycle could be too small to be considered a clear
reference value for the consumers.
Regarding cycle time, some stakeholders want a limitation of the cycle time for the eco-
programme and a display of the cycle time on the label. Other stakeholders claim that it should
first be checked if the previous Regulation is working, i.e. checking if the eco-programme is used
more nowadays because of the clear marking and being the default program. Moreover, the
consumer could be more willing to accept longer cycle times if he would be better informed
about the associated energy savings.
The cycle time of the program can also be seen as a competitive parameter and therefore it could
be useful to be displayed on the label. A display of the cycle time on the label had been proposed
in the previous revision, but had been discarded at the last moment. Care should be taken
however that we do not create a race for the shortest timing on the back of energy and water
consumption. Currently the timing of the programs can be found on the manufacturer’s websites,
in the manuals and in consumer organisation reviews.
Regarding smart-grid ready appliances providing demand-response functions it is mentioned
that currently neither rules nor standards are available so it seems impossible to introduce such
technology. Standards regarding connectivity parameters are however under development and
almost ready and the first appliances that include this technology will come on the market, even
providing more “smart” functions than only demand-response. Horizontal work on smart
appliances which goes beyond household appliances is on-going. An additional problem
indicated regarding smart grid and smart grid appliances is the fact that currently there is no smart
grid, so no smart grid appliances are available or can be used. On the other hand, there is no need
for a smart grid if no smart grid appliances are available.
The promotion of the smart appliances has been discussed. Providing a bonus in the EEI for smart
grid-ready appliances could be misleading for the consumers. The EEI parameter should be kept
as transparent as possible for the consumer. The energy label should be an information tool and
not a marketing tool for this kind of appliances.
14
Closing of the meeting
The participants are asked to carefully check the minutes that will be distributed shortly after the
meeting and provide written comments through the BATIS system before 31 July. The next TWG
meeting will be in Brussels at 17 November 2015.
