APPLiA’s recommendations for Energy Efficiency Product Legislation

APPLiA submitted recommendations to the European Commission on the energy rules framework, highlighting the need for workable milestones ahead of the Energy Efficiency Products Omnibus.

This position paper outlines APPLiA’s strategic recommendations to optimise the EU’s energy labeling and ecodesign framework. As the home appliance industry navigates a complex regulatory landscape, APPLiA advocates for a transition toward digital-first solutions, the elimination of regulatory overlaps, and the restoration of procedural transparency to ensure legal certainty and industrial competitiveness.

Key Recommendations

• Transition to Digital Energy Efficiency Labels: APPLiA proposes amending Article 3(1) to include digital labels alongside printed ones. The label should remain a tool to promote energy efficient products, i.e. products that combine a high performance and a low energy consumption.
• Legal Certainty and Timelines: Manufacturers require stable timelines when drafting regulations, in addition to reasonable timelines for implementation (minimum 24–36 months) to manage factory retooling and investment cycles.
• Elimination of Double Regulation: APPLiA urges the Commission to exempt components (e.g. motors, fans, light sources) that are already part of a compliant final appliance from their own vertical legislations. Regulating components within a compliant system adds administrative burden without increasing efficiency.
• Support for the Circular Economy: To promote product longevity, legislation must ensure that spare parts remain available and compliant as "originally built," preventing the forced scrapping of functional components due to evolving vertical regulations.
• Avoid a one-size-fits-all for ESPR labels: A common label layout for all products under the scope of the ESPR is unfeasible. Due to product specificities, the decisions on the layout and content of any potential future ESPR label shall be left to product-specific regulation.
• Operational Transparency: The industry calls for the reinstatement of the practice of distributing draft Commission proposals well in advance of Consultation Forum or Ecodesign Forum meetings. Early access is vital for informed stakeholder feedback, error prevention, and a democratic legislative process.