Memorandum submitted by the Energy Saving
Trust
The Energy Saving Trust is pleased to respond
to the Environmental Audit Committee's Inquiry on Environmental
Labelling. The Energy Saving Trust was established as part of
the Government's action plan in response to the 1992 Earth Summit
in Rio de Janeiro, which addressed worldwide concerns on sustainable
development issues. We are the UK's leading organisation working
through partnerships towards the sustainable and efficient use
of energy by households, communities and the road transport sector
and one of the key delivery agents of the Government's climate
change objectives. Our response focuses on energy labelling of
products, a key activity of the Energy Saving Trust and those
areas of specific interest to the Committee where we can make
informed comment. Please note that this response should not be
taken as representing the views of individual Energy Saving Trust
members.
1. PRODUCTS REQUIRING
LABELLING
The Sub-committee would like to investigate which
products are currently subject to environmental labelling, both
compulsory and voluntary, and whether further products or sectors
should be included under an environmental labelling scheme.
It is important to provide consumers with clear
and consistent information to allow them to make informed purchasing
decisions and avoid harm both to individuals and the planet. We
share the Committee's concerns that the proliferation of new environmental
labels could undermine the delivery of environmental benefits.
However, there is good evidence that well-designed labelling schemes
operated by independent and trusted sources, such as the Energy
Saving Trust, can and do make a real difference in delivering
positive changes to consumer purchasing behaviours. In our opinion,
the greatest success in changing behaviour through environmental
labelling is likely to be achieved by investing in existing labels
with a proven track-record.
There are several national and international
ecolabelling schemes already in operation around the world, such
as the Blue Angel in Germany, which was the world's first ecolabel
scheme, the Scandinavian Nordic Swan scheme and since 1992 the
EU Flower scheme which aims to ultimately supersede national schemes.
In general, we agree with the approach adopted by the UK Government
to support the EU ecolabel rather than creating a single new UK
ecolabel, which will require considerable resource to develop
and promote. However, we believe that there is a case for rationalisation
of the ever-increasing number of labels, whilst investing in existing
UK certification and labelling schemes that focus on addressing
specific environmental challenges caused by products, such as
energy usage. Theoretically such labels could be brought closer
together through a "family" approach which we discuss
in Q3.
We believe that consumer-facing labels, supported
by other approaches, are required to inform consumers and change
purchasing behaviours across different market sectors. However,
although different labelling schemes in the same sector may be
supported by industry, they are more likely to confuse consumers
who want to be able to identify instantaneously the most environmentally
friendly products without having to read and assimilate data.
There is therefore a strong rationale to focus efforts on existing
labelling and certification schemes with a proven track record
in influencing behaviour change.
In our opinion the widespread labelling of energy
using appliances and energy saving products will lead to reduced
energy demand, an associated carbon reduction and lower overall
energy bills and is therefore a key delivery mechanism for three
of the four UK energy policy goals:
— to put ourselves on a path to cutting
CO2 emissions by some 60% by about 2050, with real progress by
2020;
— to maintain the reliability of energy
supplies; and
— to ensure that every home is adequately
and affordably heated.
Energy labelling of products should therefore
remain a priority for UK Government. Using downstream energy labels
for electrical products is clearly a complementary activity to
upstream decarbonisation of the UK generation sector.
However, energy labelling also needs to be underpinned
by other policy mechanisms, for example by regulating the most
energy inefficient products out of the market place and incentivising
the most efficient products. Well-designed labelling and certification
will act as a driver for manufacturers to develop more efficient
appliances that will then allow Governments to remove the least
efficient, and would help target any fiscal incentives Government
might wish to provide to the best products. In this respect we
note that closer links between energy labelling schemes and the
Carbon Emissions Reduction Target would yield greater energy/carbon
savings. Most importantly a successful label needs to be marketed
through communication channels relevant to the target audience.
Without this activity consumers are unlikely to recognise or value
a label and therefore its impact will be negligible.
We strongly support the mandatory labelling
of energy using products such as electrical appliances, boilers,
homes and vehicles. However, we believe there is also a further
need to more easily identify the most efficient products for consumers
through a mechanism that can respond more quickly to fast-moving
markets than the European and/or international standards that
will allow more progressive governments to move ahead faster than
less environmentally motivated countries. Given the increasingly
global nature of markets, this will also incentivise the roll-out
of more efficient products internationally. In the UK, we believe
this is best done by the expansion of the Energy Saving Trust's
Energy Saving Recommended (ESR) certification and labelling scheme
rather than the creation of new schemes, particularly those that
are ISO14024 self-declared Type II schemes (see below).
ESR is a voluntary scheme designed as a
"good to best practice" label that signposts consumers
to the most energy saving products in the market. It aims to endorse
a maximum of the top 20% of the market in any one product category,
thereby acting as a "quality mark" for lower energy
consumption. Consequently it is both dynamic and flexible and
can therefore respond to market developments and innovation far
more quickly than other labels in the same arena (eg EU Energy
Star, EU Energy Label.[19]
It is especially helpful to consumers as it easily identifies
the most efficient products without individuals having to read
and assimilate data. It not only complements the A-G labelling
system but adds considerable value by identifying "best in
class" for those product categories where there is currently
a proliferation of A-rated appliances and facilitates continuous
improvement of standards (as opposed to a more stop-start approach
through international standards). Essentially products should
be required to meet minimum standards but in addition a differentiator
is then also required to identify the best, most efficient, least
damaging products. In the case of energy, ESR is that differentiator.
ESR has been particularly effective in helping
UK Government drive up the energy performance of a range of consumer
appliances, particularly in white goods. For example, sales of
A-rated and above cold appliances have risen from 1% of the total
market in 1996 to around 70% in 2006 and in the wet appliances
market the increase has been from 1% in 1996 to 86% in 2006. In
conjunction with the first Energy Efficiency Commitment (EEC1)
and building on previous grant and support schemes run by the
Energy Saving Trust, it also enabled Government to include condensing
boilers in building regulations.
ESR now covers seven sectors and 28 individual
product groups resulting in over 2,500 certified products from
201 registered companies (as detailed in Appendix 1). An expansion
of ESR to include household consumer electronics, homes and cars
would build upon the Government's announcement of the phase-out
of energy-guzzling light bulbs and efforts to strengthen European
product standards. The development of ESR is essential to not
only encourage manufacturers to innovate and improve the performance
of their products but also to increase engagement and help consumers
purchase the most efficient/lowest carbon products.
In addition to the products currently covered
by ESR, we believe that expansion of the scheme to cover the following
seven product types should be a priority and as such we are currently
developing product standards for each of these (although this
does not guarantee implementation, which is dependent on stakeholder
support and funding):
— Domestic Pipe Insulation.
— Passive Flue Gas Heating Recovery
Devices.
— New Build Domestic Homes.
— Existing Build Domestic Homes.
We are also in the early stages of compiling
a medium-term strategy by the end of 2007 to inform what further
product groups we go into in the future, once those above have
been completed. The strategy will be completed during the rest
of 2007. This could include the extension of ESR to consumer electronics
and cars to deliver environmental benefits, although the fast-moving
consumer electronics market would need to be managed particularly
carefully.
2. WHAT SHOULD
BE SHOWN
UNDER A
LABELLING SYSTEM
The Sub-committee would like to assess which criteria
should be illustrated by an environmental label, and how overlaps
between different concerns could be adequately dealt with. The
Sub-committee would also be interested in investigating how environmental
labels could best convey information accurately and usefully to
the consumer. Given the EAC's recent focus on climate change and
related issues, the Sub-committee would be particularly interested
to hear about the development and merit of labels which demonstrate
the carbon footprint of a product—i.e. the carbon emitted
during its production, storage and transportation.
The International Standards Organisation has
developed an ISO standard (14020) on Environmental Labels and
Declarations—General Principles, which is basically
a set of general operating principles for environmental labelling
schemes. The package of nine general principles for environmental
labels sets the standard for best practice and in our opinion
creates a useful tool for assessing labels. We support these principles
as detailed below:
| Ref | Principle
|
| 1. | Environmental labels and declarations shall be accurate, verifiable, relevant and not misleading.
|
| 2. | Procedures and requirements for environmental labels and declarations shall not be prepared, adopted, or applied with a view to, or with the effect of, creating unnecessary obstacles to international trade.
|
| 3. | Environmental labels and declarations shall be based on scientific methodology that is sufficiently thorough and comprehensive to support the claim and that produces results that are accurate and reproducible.
|
| 4. | Information concerning the procedure, methodology, and any criteria used to support environmental labels and declarations shall be available and provided upon request to all interested parties.
|
| 5. | The development of environmental labels and declarations shall take into consideration all relevant aspects of the life cycle of the product.
|
| 6. | Environmental labels and declarations shall not inhibit innovation, which maintains or has the potential to improve environmental performance.
|
| 7. | Any administrative requirements or information demands related to environmental labels and declarations shall be limited to those necessary to establish conformance with applicable criteria and standards of the labels and declarations.
|
| 8. | The process of developing environmental labels and declarations should include an open, participatory consultation with interested parties. Reasonable efforts should be made to achieve a consensus throughout the process.
|
| 9. | Information on the environmental aspects of products and services relevant to an environmental label or declaration shall be available to purchasers and potential purchasers from the party making the environmental label or declaration.
|
| |
ISO 14024 on Environmental Labels and DeclarationsEnvironmental
Labelling—Principles and Procedures and the equivalent for
Type II and Type III effectively classify three different environmental
labels as below.
| Ref | Definition
|
| Type I | Voluntary, multiple-criteria-based third party programme that awards a license which authorises the use of environmental labels on products indicating overall environmental preferability of a product within a particular product category based on life cycle considerations.
|
| Type II | A self-declared environmental claim is an environmental claim that is made, without independent third party certification, by manufacturers, importers, distributors, retailers or anyone else likely to benefit from such a claim.
|
| Type III | Quantified environmental data for a product with pre-set categories of parameters based on the ISO 14040 series of standards, but not excluding additional environmental information provided with a Type III environmental declaration programme.
|
| |
In our view, there is a real risk of "greenwash"
from organisations seeking to gain a competitive advantage from
being perceived as green whilst paying only "lip-service"
to the issue and clearly this will be far greater with Type II
schemes. The implementation of detailed procedures for calculation,
effective monitoring and robust compliance testing through an
independent organisation, as in the case of ESR, would be required
to provide confidence in this type of label. This has been identified
as a major issue when engaging with consumers by Linguistic Landscapes
in the recent report Warm Words II: How the climate story is
evolving and the lessons we can learn for encouraging public action
which analyses the language of climate change.
Inevitably those companies with the strongest balance sheets
will be the ones most likely to be able to afford to invest in
voluntary labelling schemes including embodied carbon labels (which
are self-selecting) and these may not have the lowest carbon products.
In this respect we also note that products produced locally, often
by smaller businesses, might be lower carbon than those imported
from international markets and may be unfairly disadvantaged as
they are unable to afford to invest in such labelling; although
of course this will not always be the case.
Adverse publicity resulting from "greenwash" schemes
is likely to have a detrimental impact on the effectiveness of
robust and credible schemes. We believe greater control over such
schemes, in addition to existing practices such as the Advertising
Standards Agency is worth considering. Specific examples of mandatory
and voluntary approaches are provided below.
Invariably the type of information that should be shown on
a labelling system depends on the type of label and the target
audience. The best placed organisations to determine this are
consumer-facing organisations that already understand and proactively
engage with consumers through multi-channel approaches.
We believe that it is important for businesses to understand
and reduce the embodied carbon ie the carbon footprint of their
products. This can be undertaken and incentivised without the
need for a consumer facing label. A consumer facing label illustrating
the embodied carbon of a product might help leverage corporate
action, however any such labels would need to be developed in
a consistent manner to other relevant consumer facing labels in
order to avoid confusion and is clearly best done through independent
and trusted consumer facing organisations in a clear and consistent
manner.
Consumers need to be signposted to the lowest carbon products
in a meaningful way that is easy to understand. If not done correctly
there is a risk with embodied carbon labels (as with any label)
that this doesn't happen and that consumers dis-engage from successful
labelling schemes. For instance, many consumers won't understand
what "embodied" carbon means, how it is calculated or
whether X gCO2 is good or bad. The level of understanding of consumers
in relation to their impact on climate change including the products
they purchase needs to be raised to enable the concept of embodied
carbon to become meaningful. Research shows that most consumers
do not understand carbon labelling or embodied energy and that
it currently doesn't affect their decision making, but they do
understand energy saving (particularly in the context of money
saving) and consider this when purchasing lighting and white goods
but considerably less (if at all) in the case of other products,
particularly consumer electronics.
As with any label the key will be to develop a consumer-facing
and highly visual labelling system that consumers can see and
understand immediately and will encourage consumers from all walks
of life to engage with the concept of embodied carbon (even though
the term itself may not be used explicitly) and take action through
the purchasing of products with lower embodied carbon. However,
isolated product labelling won't allow consumers to make an informed
choice about, for example, which crisp manufacturer produces a
lower carbon product than the other. A simple carbon saving recommended
label identifying the lowest carbon products in any one product
sector would be far more effective for a consumer-facing label
but would need far wider coverage to be successful.
We support the development of a life-cycle evidence base
that would allow the setting of standards in key consumer-facing
sectors such as food and drink, passenger transport, buildings
and appliances etc, which will require Government leadership.
In this respect the creation of a new Products and Materials Unit
in Defra is helpful. We also note that in some areas, such as
food, the relativity of constituents and their impact (eg salt,
fat, sugar, vitamins) is far more complex.
A key issue when considering carbon labels is whether the
in-use phase (ie the energy consumed/carbon emitted during the
actual use of a product as opposed to that during its production,
storage and transportation) should be included or excluded in
a carbon label standard. We are concerned that the inclusion of
the in-use phase with embodied carbon in a single label would
be detrimental to changing consumer behaviour and advocate that
it be excluded from any carbon label.
The "single number" that would be provided by an
"embodied + in-use" carbon label would have to represent
some kind of average, which invariably will not reflect actual
individual consumer use. For instance, at a basic level a carrot
could be eaten raw, cooked in a microwave, boiled in a large saucepan
of water etc. Other concerns include:
— Reporting average use in itself is not a trigger
that will influence individual behavioural change.
— There can be large qualitative differences between
saying "x gCO2 went into putting this product on the shelf"
and "using this product in accordance with a standard methodology
will result in y gCO2 emissions"
— For some products, there are no in-use phase emissions
(eg crisps), whilst for others, typically where energy use is
significant and direct (eeg EU labelled goods, cars) there are
already agreed standards. For the other products in between (shampoo,
cleaning products, food etc) there are considerable unknowns and
variants.
— It is widely recognised that data on the in-use
phase is sparse and much more difficult to obtain than the embodied
carbon of a product. Additional methodologies for assessing the
in-use phase for each product will need to be developed and agreed.
— There is substantial additional workload for a
company in having to calculate the in-use phase emissions, which
are outside of their control and not a core competence unlike
the production cycle of their own products.
— The additional effort both initially and on an
ongoing basis that would be required from companies in order to
include in-use phase emissions could deter participation.
In the short to medium term we believe that the greatest
carbon saving will be achieved by continuing with energy saving
labelling as the main focus for consumers whilst efforts are separately
focused on businesses to reduce the embodied carbon of their products.
Currently "embodied + in-use" labels or separate consumer-facing
energy and carbon labels are more likely to confuse than engage.
The Energy Saving Trust has proven expertise and knowledge in
raising awareness and advising consumers on their energy usage/associated
carbon impact via our existing channels and infrastructure). Moving
forward, we therefore believe that the Energy Saving Trust, working
closely with Government and other key stakeholders, is best placed
to determine how to provide consumers with information on embodied
carbon and more importantly to help them to act upon it.
3. THE CASE
FOR RATIONALISING
ENVIRONMENTAL LABELS
The Sub-committee would like to assess whether concerns over
the proliferation of environmental labels are justified, and the
extent to which consumers are able to cope and engage with the
many different labels on the market. The Sub-committee would also
like to investigate whether there is a case for rationalising
the system of environmental labelling, or for calling for certain
labels to be given priority when displayed on products.
Please see our response to Q1. We believe that the proven
track record of ESR, managed by an independent and trusted organisation,
the strong linkages with Government energy and environmental policy
combined with the major support it receives from industry and
other stakeholders justifies it being given priority for both
Government support and when being displayed on products. No other
energy efficiency product label has this scope and breadth.
We agree that a proliferation of schemes can be confusing
and that in some areas rationalisation is likely to prove helpful,
for example the number of certified "organic" schemes.
There is also a major risk about making things too complicated
for consumers, especially by schemes that adopt a multi-dimensional
rating approach that require consumers to consider detailed information
as opposed to a far simpler "mark" approach that identifies
a product as being one of the most environmentally friendly in
that product category. For example, an "at-a-glance"
accreditation scheme would provide the comfort and clarity required
by consumers and be far more effective than a multi-rated green
tariff certification scheme, which would be too complicated to
engage consumers.
We would support research into exploring the benefits in
rationalising schemes. It is hard to envisage consumers during
their weekly supermarket shop looking at the label on each product
they plan to purchase then comparing it with the labels on all
other similar products whilst taking into account other attributes
such as price and brand. One option could be to develop a small
"family" of consumer-facing labels specifically for
the UK that would address the key environmental issues facing
consumers (for example energy usage, sustainability of production
method, use of natural resources etc) and signpost customers to
the most environmentally friendly products available i.e. the
top 20% through an "at a glance" label. We would envisage
ESR being a critical part of this family. It is important to start
to bring together environmental issues such as energy, waste,
water etc.
Promoting a labelling scheme, both widely and fairly, is
vital to its success and our national network of Energy Saving
Trust advice centres (ESTACs) provides a strong infrastructure
to underpin ESR. Although we have not explored the possibilities,
in principle our ESTAC infrastructure could be helpful in raising
the profile and effectiveness of other key consumer-facing labelling
schemes.
4. THE IMPACT
OF ENVIRONMENTAL
LABELLING ON
CONSUMER BEHAVIOUR
The Sub-committee would be interested in assessing how easily
consumers understand environmental labels, and whether environmental
labelling has a significant impact on human behaviour; not only
whether it can reinforce and assist existing positive environmental
behaviour, but also whether it can cause behavioural change.
The Energy Saving Trust evaluates the effectiveness of our
ESR labelling and supporting marketing/trade activities. The starting
point for consideration of the effectiveness of a label is not
whether people understand the label but whether they actually
look for it in the first place. We also note that an accredited
backed logo is far simpler to understand than a label (or different
types of labels aiming to provide the same information) providing
detailed information in small print.
Our 2005-06[20]
evaluation survey of a sample of the general public revealed that
19% of those purchasing an appliance during the financial year
2005-06 claim to have looked for the ESR logo. Invariably numbers
of people taking account of a label will be lower than those who
recognise a label. For instance 2006-07[21]
market research shows that 39% of people recognise the ESR label
when prompted. This compares to 18% (Energy Star), 59% (European
Energy label) and just 4% (vehicle label), although of course
some labels are on a greater number of products and therefore
visibility would be higher.
Our research also shows that in 13% of cases, appliance purchasers
bought an ESR appliance and claim they would not have purchased
that particular ESR appliance if it had not had the ESR logo on
it. This provides strong evidence that for these purchasers energy
efficiency is a "must have" buying criterion alongside
other better known key requirements such as price and size. It
also shows that the ESR logo provides a simple, clear signal to
allow buyers to identify the most energy efficient products and
to meet this buying criterion.
The findings also illustrate the importance of promoting
the ESR label through more than one route, not just directly to
the consumer but also through retailers and manufacturers. Purchasers
are more likely to look out for the logo themselves (19% of buyers)
than have a member of retail staff point it out to them (reported
by 10% of buyers). For many, their own awareness of the logo through
our consumer advertising and PR activities and the information
available through EST advice centres and our website is enough
to encourage them to look for the logo and buy ESR goods. However,
the retail environment and retail sales staff can also play an
important role in persuading the public to buy ESR goods as our
research shows that the impact of ESR on purchasing decisions
is increased if the retailer points out the logo to the buyer.
For example, in 2005-06, overall 13% of washing machine sales
were ESR and would not have been bought had they not been ESR,
rising to 19% when the retailer pointed out the logo.
Research with our retail partners undertaken in 2004-05 also
reflects these findings. Retailers noted the value of the Energy
Saving Trust marketing of ESR to consumers and the extent to which
it was easier to sell an ESR product to a customer that was already
aware of the logo. They also noted their customers proactively
request ESR products. Key success factors for ESR include the
simplicity an "at-a-glance" label provides, that it
is backed by an independent and trusted organisation with national
marketing and promotion and involves the leading manufacturers
and retailers. It is worth noting that retailers would like to
see greater effort behind information, education and awareness
promotion of ESR to consumers.
5. THE REGULATION
OF ENVIRONMENTAL
LABELLING
The Sub-committee would like to examine the ways in which environmental
labels are calculated, assessed and awarded, and would also like
to investigate the current regulation to which these labels are
subjected. The Sub-committee would welcome assessments of whether
current levels of regulation are adequate, or whether further
regulation, be it wider in scope or stricter in demand, is required.
The underpinning process for labelling schemes will vary
considerably and some will inevitably be more robust than others
depending most notably on the type of label, the level of independence
of the certifying body and the degree of compliance testing. The
process for ESR can be summarised as follows:
Calculation
— The standard-setting process is supported by a
detailed procedure for justifying the endorsement of the product
category. The procedure involves: specifying the energy savings
endorsement would deliver; forecasting future sales with and without
endorsement; explaining how product endorsement complements the
wider national and international product policy agenda; stating
the marketing commitments to support the product endorsement;
summarising the product testing that can support the endorsement;
and specifying details of stakeholder support (eg manufacturers,
suppliers, associations, NGOs).
— The ESR scheme benefits greatly from working through
the Energy Efficiency Partnership for Homes, which is a network
of approximately 400 UK organisations involved in the energy efficiency
sector. The Partnership's 17 sector working groups, including
one for each of the industrial sectors (eg appliances, lighting)
meet on a quarterly basis and provide an ideal basis in which
to communicate with the industry and receive feedback on new product
endorsement and the review of existing endorsement criteria. The
Market Transformation Programme (MTP) provides sector specific
technical expertise and a linkage with the Government's sustainable
products evidence base, its wider policy network and its modelling
capacity.
— Independent peer review of the calculations is
provided by the Endorsement Panel. The Endorsement Panel is a
body of independent experts from a variety of fields including
regulatory, policy, consumer support, certification and environment.
The Panel meets on a quarterly basis to advise on the management
of the Scheme and in particular considers and issues recommendations
on the endorsement criteria proposals presented to them.
Assessment
— The Table contained in Appendix 1 identifies the
method of verification. On average across all 28 product groups,
a majority of our standards require independent third party verification.
Our working presumption for new products is that we require independent
verification.
— We also have an internal review process, which
ensures that different personnel are involved with evaluations
of the applications and with taking certification decisions (for
both company and product applications). This is standard certification
practice. In addition an internal peer review is carried out by
colleagues not already involved in the evaluation process.
Monitoring
— The validity and integrity of the data presented
to the public is maintained through a six-weekly review of the
certified products. This process involves making contact with
each member every six weeks and seeking confirmation that the
certified products are still in production and available for purchase
in the UK.
— Once established, the Scheme has an objective
to review the product endorsement criteria on an annual basis.
The endorsement criteria review procedure involves addressing
similar areas to those answered in the original justification
for the standards. This ensures that the argument for continuing
ESR endorsement remains valid. The Scheme has an objective—where
product groups can be differentiated by their energy efficiency
properties—to endorse the top 20% of the market. The objectives
set for the programme and the procedures established for their
delivery help to ensure objectives continue to be met.
Compliance Testing
— The Energy Saving Trust undertakes compliance
testing on Energy Saving Recommended products in order to assess
whether they continue to meet the criteria to which they were
originally certified. The Scheme has an objective to compliance
test around 5% of certified products every year. If a product
fails a compliance test, manufacturers are given the opportunity
to comment on the test results, which could lead to a challenge.
If a manufacturer does not contest the result, or if the challenge
is unsuccessful, the product will be deregistered. Non-attributable
results are circulated to stakeholders.
Regulation
— The Energy Saving Trust is not aware of any regulations
specifically for voluntary environmental product labels.
We believe that consideration for greater regulation of less
robust labels, particularly Type II schemes is justified. In particular,
it is important to prevent the use of labels/marks that make a
product look good when it isn't relevant to others in the same
product category. Whilst we support the increased engagement of
business on environmental issues, we believe there are justifiable
concerns about "greenwash" and some ecobrands that are
not independently certified. Ideally all labelling schemes should
be underpinned by robust evidence.
6. EXPORTS FROM
DEVELOPING COUNTRIES
The Sub-committee would also like to investigate the impact
of environmental labelling on exports from developing countries,
and in particular whether labelling of this kind could have a
detrimental impact on the trade opportunities available to these
countries.
As this is not an area of our core expertise, we have no
comments or evidence to submit.
7. INTERNATIONAL LABELLING
Finally, the Sub-committee would be interested in assessing
the feasibility of an international environmental labelling system,
and the extent to which this would be compatible with the rules
on trade set out by the WTO.
Agreement at a European or International scale will inevitably
mean compromise, often at the lowest common denominator ie a requirement
that every one can agree on. In practice, in the any labelling
scheme that has this much coverage would rely on a manufacturer's
self declaration of conformance with the standards, not an independent
third party assessment. The implementation of detailed procedures
for calculation, effective monitoring and robust compliance testing
through an independent organisation, as in the case of ESR, would
be required to ensure the credibility of this type of label. Examples
of European or International labelling Schemes include the EU
Energy Label and the EU Energy Star for office equipment where
both rely on a manufacturer's self-declaration for conformance.
We are not best placed to comment on WTO rules, although
we note that ISO 14024 principle 2 above states:
Procedures and requirements for environmental labels and
declarations shall not be prepared, adopted, or applied with a
view to, or with the effect of, creating unnecessary obstacles
to international trade.
5 October 2007
APPENDIX 1
ENERGY SAVING
RECOMMENDED (ESR)
The Energy Saving Recommended scheme was established at the
request of Government and launched by the Energy Saving Trust
in July 2000. ESR is a voluntary product labelling scheme for
domestic energy saving products with the broad aim to signpost
consumers to the most energy saving products in the market. It
is a key driver in changing consumer's purchasing behaviour. Through
Government funding, the Energy Saving Trust is using ESR as a
tool to deliver energy and carbon savings via its interaction
with the various energy efficiency stakeholders in the UK across
the supply chain.
ESR is designed as a "good to best practice" label,
aiming to endorse a maximum of the top 20% of the market in any
product category. Consequently it is both dynamic and flexible
and can respond to market developments and innovation far more
quickly than other labels in the same arena (eg EU Energy Star,
EU Energy Label).
At the end of September 2007, ESR covered seven sectors and
28 individual product groups with standards that are regularly
reviewed and revised to help drive the market for energy efficient
products. In 2005-06 nine sets of product standards were reviewed
and revised, a further 13 reviews/revisions were delivered in
2006-07 and seven new ones have been completed in 2007-08 so far
with more expected. ESR now covers in excess of 2,500 certified
products with 201 registered companies (117 manufacturers, 18
suppliers and 66 retailers). ESR therefore has the widest scope
of any energy efficiency product label in the UK. No other energy
efficiency product labelling scheme in the UK has the level of
product compliance testing and ongoing monitoring to assess whether
certified products continue to meet the scheme standards. On a
European scale the Energy Saving Trust is one of the most prolific
independent product testers.
Sector and Product Coverage of ESR
| Sector | Product Group
| V[22]
|
Appliances | Cold Appliances (Refrigerators, Freezers, Fridge Freezers, Chest Freezers)
| M |
| Washing Machines | M
|
| Dishwashers | M
|
| Electric Tumble Dryers |
M |
| Gas Tumble Dryers | M
|
| Kettles and Instantaneous Water Heaters
| I |
| Consumer | Integrated Digital Televisions
| M |
| Electronics | Simple Set Top Boxes
| M |
| (CE) | Digital Television Recorders
| I |
| Energy Saving Mains Controllers (CE equipment)
| I |
| Information and | Desktop Computers
| M |
| Communication | Laptop Computers
| M |
Technology
(ICT) | Imaging Equipment (inkjet printers, inkjet multi-functional devices,
photo printers)
| M |
| Computer Monitors | M
|
| Energy Saving Mains Controllers (ICT equipment)
| I |
| Heating | Natural Gas and LPG Boilers
| I |
| Oil Boilers | I
|
| Gas Central Heating Controls
| M |
| Hot Water Cylinders |
I |
| Insulation | Cavity Wall Insulation
| I |
| Loft Insulation | I
|
| External Wall Insulation
| I |
| Dry Lining Insulation |
I |
| Lighting | Compact Fluorescent Light bulbs (CFLs)
| I |
| Candle Effect CFLs | I
|
| Halogen Bulbs | I
|
| Dedicated Low Energy Luminaires
| I |
| Glazing | Windows | I
|
| |
|
Energy Saving Trust's planned expansion of ESR to include
household consumer electronics, homes and cars will build upon
Government's announcement of the phase-out of energy-guzzling
light bulbs and efforts to strengthen European product standards.
The development of ESR is essential to not only encourage manufacturers
to improve the performance of their products but also to increase
engagement and help consumers purchase the lowest carbon products.
Where appropriate, we are expanding beyond just energy efficiency
for instance in the case of dishwashers we now set water consumption
performance requirements and aim to do likewise for washing machines
too (as energy and hot water usage is intrinsically linked). Our
proposed new build and existing homes standards could also go
beyond energy efficiency too.
19
Further information on these and other logos and labels commonly
found on UK products can be found in the Defra guide at http://www.defra.gov.uk/environment/consumerprod/pdf/shoppers-guide.pdf Back
20
Note: The evaluation results from 2004-05 were better than
in 2005-06 as ESR was re-branded with related visual changes in
the logo leading to a drop in consumer recognition. Back
21
Our 2006-07 evaluation survey will not be available until later
this year. The quoted evaluation survey and market research results
are not directly comparable and can only be used to provide an
indication of the relativity between awareness and action. Back
22
"V"-verification, "M"-manufacturers self-declaration,
"I"-independent third party testing. Back
| 
