The impact on the sector
The outbreak of COVID-19 has created an unprecedented situation for the EU society and for the whole economy.
The home appliance sector has witnessed a dramatic reduction in demand and almost a complete shutdown of activities, including manufacturing, supply, after sales services, logistics, laboratories and research in innovation, in most EU Member States. Furthermore, the closure of shops in all European countries is impacting severely the whole economy.
Our recommendations
To preserve the continuation and the future of the home appliance industry in Europe, key legal requirements need to be alleviated now. We are fully committed to the Union decarbonisation goals and we are not asking for legislation to be recalled. We are requesting that the weight of some upcoming legal obligations is alleviated to instead allow us to concentrate on overcoming this unprecedented societal challenge.
Concretely, we call on the European Commission to:
- delay by four months the 1 November 2020 date set in the current Energy Labelling delegated Regulations to 1 March 2021 to enable placing on the market products bearing only the current label until 28 February 2021; delay by four months the 1 March 2021 date in the current Energy Labelling Regulations to 1 July 2021 to postpone the mandatory provision of the new energy label. However, manufacturers should be able to place products on the market bearing only the new label as of 1 March 2021, as originally required, and point of sales (online and offline) must display the new label starting from 1 March 2021 as soon as the new label is available with the product;
- delay by two years the application date of the second tier of Ecodesign requirements from 2024 to 2026. These targets require massive industrial investments, which companies simply cannot achieve due to the current situation;
- delay the current 65% WEEE collection target for a two-year period. These targets would be impossible to reach in today’s context;
- delay the 5 January 2021 deadline to deliver extensive chemical data for parts of appliances into the SCIP database developed by ECHA by one year. Required testing is on hold due to laboratory closures. In addition, the requested data and evidence cannot be properly collected due to the many affected partners involved in the supply chain of materials;
- delay the implementation of the EU-MDR ANNEX XVI Common Specifications foreseen for 26 May 2020. Clinical testing, which is critical for this law, is delayed as people cannot be currently recruited due to the high contamination risk;
- allow one more year for the transposition of both the Digital Content and the Sale of Goods Directives into national legal frameworks. We understand that some Member States are already putting this process on hold;
- allow one more year for the transposition of the Waste Directive (EU) 2018/851 into national legal frameworks;
- delay for 6 months the preparation of the delegated acts on “privacy and fraud” and on “reconfigurable radio systems” under the Radio Equipment Directive;
- define a longer transition period for the definition of cybersecurity schemes and their introduction under the Cybersecurity Act.