Memorandum submitted by Waterwise
Waterwise is an independent, not-for-profit,
nongovernmental organisation which promotes water efficiency and
conservation in the UK. Our primary aim is to develop a framework
for sustained water efficiency for all mains use of water, and
to reverse the upward trend in household consumption by 2010.
To achieve our aims, we are building an economic, social and environmental
evidence base for water efficiency, and we also promote water
efficiency though co-ordination of existing initiatives and through
the development of collaborative projects. We work in partnership
with water companies, regulators, governments, retailers, manufacturers,
other NGOs, the public, the media and with other stakeholders.
Waterwise's work has been welcomed by the UK governments, the
water industry, and the water regulators. Waterwise is the only
NGO to sit on the Environment Minister's Water Saving Group.
INTRODUCTION
Interest in the "labelling" of products
and/or services to enable environmentally preferable purchasing
has grown over the past few years, and has now reached a level
where there are too many "labels" but at the same time
not enough. Waterwise therefore welcomes this inquiry, which comes
at a time during which decisions are being made about the role
of product labelling in water demand management.
Present levels of water consumption in UK households
are not sustainable given current trends in urbanisation, population
growth and new build, as well as shifts toward single-person living
and water intensive lifestyles. With water scarcity adaptation
being a crucial component of climate change adaptation for the
UK, water product labelling or the provision of information which
will enable consumers to reduce water wastage is essential.
The UK will not be successful in adapting to
climate change if water scarcity is not addressed. Supply side
measures such as reservoirs (more of which Waterwise accepts will
be needed), will alone not be enough to meet increasing future
demand—water efficiency and conservation are an absolute
necessity for future water security in the UK. But if consumers
are not aware of the existence water efficient products, or if
they are unable to identify such products because of a lack of
information, adaptation to water scarcity will fall short and
the UK will struggle to meet rising water demand.
1. Definitions, provision of information,
and the role of labels
1.1 It is first necessary to clarify what
is meant by "environmental label". Not only are consumers
(and policymakers) confused about the various claims communicated
to them via "labels", but labels themselves are confusing
in the various forms they take. Which are authoritative and of
value? Various label types include:
— Ecolabels (eg EU Flower), which try
to encompass various environmental criteria into one label.
— Single issue ratings, which try to
provide the consumer with at-a-glance performance for a certain
environmental criterion (eg EU Energy Label).
— Endorsements and awards, which are
marks of approval and recognition from an organisation (eg the
Waterwise Marque).
— Retailer labels (eg M&S Air Freight
label), which try to communicate one or more aspects of "greenness"
to the consumer; etc.
1.2 What is important to remember is that
labels such as those listed in 1.1 are not the only means by which
to encourage greener purchasing: point-of-sale information (eg
water consumption figures provided in Currys' washing machine
consumer guide), online product databases and tools (eg Waterwise's
listing of the water use of all dishwashers and washing machines
currently available on the UK market), manufacturer websites and
brochures (eg Bosch consistently includes water use information
in product brochures and online), and other methods serve the
same purpose as labels.
1.3 Where a market does not supply what
is deemed to be necessary information (eg the rate of water consumption
of various water using products), a label or other form of interference
is necessary to correct this market failure. Interference is made
with the hope of shifting the market toward a certain desired
outcome. But labels are not always the best way to solve market
failure. Other means may be just as successful:
— Legislation and regulatory requirements.
— Public-private partnerships and initiatives.
— Incentives such as tax breaks and
rebates.
— Government procurement policies;
etc.
1.4 Though labels are a sure way of providing
consumers with information, there is an actual danger of providing
too much information which may lead to sensory overload and which
may then turn consumers off from all labels. As such, Waterwise
believe labels should be considered as one of a basket of options
for addressing market failure.
1.5 Furthermore, any label which does (or
will) exist must be accompanied by consumer education, and it
must also be backed by trusted authorities who can validate the
claims of the label.
2. Products requiring labelling
2.1 During the past few years, there have
been discussions at the policymaking level about whether or not
there exists a need for a water efficiency labelling scheme for
taps, toilets, showers, dishwashers, washing machines, and other
water using products. As a result:
— Defra have contracted Waterwise to
examine whether or not there is a need for a water efficiency
label for washing machines and dishwashers. The study will report
by the end of 2007.
— Waterwise are presently conducting
an analysis of water efficiency labels in other nations, focusing
on market effect, consumer recognitions, programme structure,
and success/failure. The study, which is being funded through
the Market Transformation Programme, will report by the end of
2007.
— Other studies have also been commissioned
to examine consumer attitudes to water saving, and to look at
what consumers would like to see in a label or database.
2.2 Outside the UK policymaking sphere,
water labelling has advanced during the past year:
— In September 2006, Waterwise launched
the Waterwise Marque, the first award scheme in the UK to highlight
water efficient products. Fifteen products, ranging from an ultra
low flush toilet to drought resistant turf, currently carry the
Marque which is awarded annually to products which save water,
eliminate water waste, and/or promote water efficiency and/or
conservation. The original intention of the Marque was to kick-start
the market and to catalyse the development of a national water
efficiency labelling scheme.
— In April 2007, the Bathroom Manufacturers
Association announced the development of a voluntary Water Efficiency
Labelling Scheme, based on minimum water consumption requirements,
which will cover WCs, flushing cisterns, taps and combination
tap assemblies, shower controls and baths.
— Waterwise have been informed of various
schemes which certain retailers are currently developing to highlight
water efficient products.
2.3 At the European level, the July 2007
Communication from the Commission to the European Parliament and
the Council on "Addressing the challenge of water scarcity
and droughts in the European Union" recognised that:
Labelling is an effective way to provide targeted
information to the public on water performance and on sustainable
water management practices. The marketing of ever more efficient
devices or "water-friendly" products should be encouraged.
The Commission concluded that "the possibility
of expanding existing EU labelling schemes whenever appropriate
in order to promote water efficient devices and water-friendly
products" should be examined.
2.4 Given the long-standing interest in
water efficiency labelling in the UK, combined with climate change,
population growth, new build, and ever more water hungry lifestyles
all threatening the UK's water supply, Waterwise believe that
now is the time to examine whether a nationwide (or perhaps EU
wide) water efficiency labelling scheme is necessary, what such
a scheme might look like, and what benefits such a scheme could
bring. Alternative options should also be considered.
2.5 Waterwise argue that there is a need
for a nationwide, comprehensive water efficiency labelling scheme
for the following reasons:
— A water efficiency label would empower
consumers to make their own decisions in terms of what products
to buy, and would enable them to purchase products which would
help them to mitigate (eg water efficient showerheads help save
water and energy) and adapt to (eg water efficient households
maximise gain from a scarce resource) climate change.
— Builders, developers, and specifiers
presently have no place to turn to for information on what water
using products will enable them to meet the various levels of
the Code for Sustainable Homes. A nationwide label would be a
useful tool to support the success of the Code in ensuring new
homes are water efficient.
— Government procurement is one of
the most powerful ways of moving markets toward sustainability.
A label would enable governments to specify which water using
products must be purchased, thereby creating a large demand for
water efficient products, driving down prices and increasing availability
of such products on the mass market.
— A nationally accepted label would
be a useful tool for local councils, water utilities, and other
bodies who may wish to link cash rebates, tax breaks, and other
financial incentives to water efficient products.
— A national label could endorse (or
otherwise) any other claims which manufacturers or retailers may
be making about their products' sustainability with respect to
water resources.
— A national label would raise the
public's awareness of water supply and the need for water efficiency
and conservation.
3. What a labelling system should look like
3.1 The purpose of any label is twofold:
First, to provide consumers with the information necessary to
make a sustainable purchasing decision should they want to; and,
second, to drive the market toward subscribing to the requirements
of the label, thus achieving market transformation. In theory,
a label will eventually cease to exist once the market is transformed.
3.2 Drawing on water efficiency labelling
experiences in other countries, we conclude that there is no significant
difference in impact between a rating (eg Australia's mandatory
one to five star label) and an endorsement (eg the USA's WaterSense);
nor between voluntary (eg Israel's Blue Dot) and mandatory (eg
Singapore's rating scheme) schemes. What is important is that:
— the scheme is bought into and supported
by all major stakeholders (eg water utilities, governments, manufacturers,
retailers, etc) who also market the scheme and use it actively
in their programmes;
— the organisation which administers
the scheme markets it well, and the organisation is well funded
so that proper marketing and consumer education are possible;
and
— the label is not seen as a solution
to the problem of unsustainable water consumption, but rather
as one tool in a toolbox of options which together can build an
enduring solution or support societal shift.
3.3 Any type of water efficiency label would
be welcome as long as the above three points are met. In addition,
consideration would have to be made over the interaction between
any such water efficiency label with the existing EU Energy Label
and the Energy Saving Recommended endorsement logo. However, concerns
over the interaction between energy and water should not prevent
the establishment of a water efficiency label as this interaction
can easily be harmonised:
— For products that use both energy
and water, more often than not there will be synergies between
the two elements and not conflicts (eg washing machines rated
"A" for energy use less water than those rated "B"
or "C").
— For products which may conflict,
eg electric showers which are by design water efficient but which
do use more energy, understandings can be developed between the
administrators of the energy label and those of the water label—resulting
in a compromise on the overall labelling of the product. Alternatively,
consumers can simply be shown that a product is good on energy
but bad on water and then be left to make their own decision.
3.4 There is also scope for creating a joint
water-energy label (see 4.3 below).
4. The case for rationalising labels
4.1 Labels are supposed to correct market
failures, ie they are supposed to provide information to the consumer
which might influence their purchasing decision but which is not
provided by the market for various reasons. Labels are supposed
to enable, and in order to do so they cannot be overly complicated
and they certainly should not be conflicting.
4.2 Particularly in the case of food labels
(eg organic, fair trade, etc) and also as most recently seen in
the proliferation of carbon labels (eg X kg CO2, air freighted,
carbon neutral, offset, etc), too much information can lead to
overload which may only confuse the consumer and turn her or him
off from caring about the sustainability of a product. Therefore,
there is an argument for rationalising similar and, in particular,
conflicting labels.
4.3 As mentioned in 3.4, there is scope
for creating a joint energy and water label. Energy consumption
and water consumption are closely related in many ways, and both
energy efficiency and water efficiency are important aspects of
climate change mitigation and adaptation. Where the two conflict,
there should be a label which weighs both together so that the
consumer does not have to choose over water or energy. Where they
do not conflict there are no problems in labelling for both.
4.4 One further option for overcoming label
overload might be to designate a body to be responsible for providing
consumers with information about the various labels already in
existence. This body could also review the veracity of claims
made by labels, and advise consumers generally on the sustainability
of products.
4.5 In theory, the existing Defra-funded
Market Transformation Programme (MTP) could take forward the remit
described in 4.4. The MTP supports the development and implementation
of UK Government policy on sustainable products and is charged
overall with reducing the environmental impact of products across
the product life cycle. Extending their remit to provide consumer
information and to review labels would not be difficult, although
it would require a shift to a more consumer-friendly approach.
4.6 In its present incarnation, the MTP
displays some inefficiencies:
— Its website is difficult to navigate
and not friendly toward policymakers, retailers and manufacturers,
the media, or individual consumers.
— There is little transparency of operation.
— Quite often work is subcontracted
to contractors who then subcontract to other contractors which
creates confusion over quality of work.
— The development of the MTP research
programme involves little stakeholder input (eg many major retailers
and manufacturers do not even know that the programme exists).
— The programme is energy heavy and
often neglects other issues like water scarcity; etc.
4.7 Therefore, though the MTP would be an
appropriate vehicle through which to provide consumers with information
on environmental labels, the programme would first have to be
reshaped and streamlined to improve transparency, functionality
and general ethos.
5. International labelling
5.1 With respect to the possibility of the
introduction of a water efficiency label, and based on discussions
Waterwise have had with those responsible for water efficiency
labels in other countries, we believe the introduction of an international
water efficiency label would not necessarily be a good idea.
5.2 National markets for water efficient
products vary tremendously from county to country. For example,
water efficiency aerated showerheads are quite common in the Australian
market but much less so in the UK. Similarly, in both the USA
and Australia top load washing machines still dominate the market,
whereas front loaders are dominant on the UK market. For these
reasons, water efficiency labels should be tailored to the market
in which they operate.
5.3 But because we live in a world in which,
for example, Australian showerheads are sold in the UK and European
toilets are exported to the USA, it is crucial that water efficiency
labels in various nations are aligned to a certain extent. Because
there are internationally excepted testing standards for some
water using products, alignment with various water efficiency
labels would not be onerous. One further option might be to introduce
a liaising panel to ensure that communication flows between labelling
organisations, manufacturers, retailers and other stakeholders.
CONCLUSIONS
Water is a crucial element to both the mitigation
of and the adaptation to climate change. If actions are not taken
now to manage water demand, the future security of the UK's water
supply will not be stable. Water efficiency and conservation are
essential to securing our future supply, and simple technological
and behavioural changes can save significant volumes of water.
The concept of a water efficiency label which
is UK- or EU-wide, voluntary or mandatory, a rating or a mark
of approval, needs to be examined further in the context of climate
change mitigation and adaptation, and in the context of future
security of supply. Furthermore, because energy and water are
so closely linked, it is crucial that the two elements be considered
together for a possible joint label.
Any water efficiency label that may be developed
should not be expected to have impact on its own: consumer education,
marketing, other incentives such as cash rebates, legislation,
and stakeholder engagement, as well as other actions, are all
necessary in order to achieve a sustainable rate of water consumption.
With climate change, urbanisation, population,
and water hungry lifestyles all on the rise, a water efficiency
label would be a step in the right direction toward a future in
which water supply is secure and valued.
October 2007
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