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Closing the ‘Reality Gap’ – Ensuring a Fair Energy Label for Consumers

In June 2017, the European Parliament voted a revised Energy Labelling Regulation reinforcing its consumer empowerment role. Following that parliamentary decision, a group of environmental NGOs published a report focusing on 18 months of research into the test standards of three popular consumer products covered by the energy label scheme – dishwashers, refrigerators and televisions. The study found that the test standards, when used for the declaration of energy-performance of these products, do not always reflect typical consumer usage and technological developments.

Appliances regulated by the EU energy label are responsible for most home energy use. Together with other efficiency policies, experts estimate these policies are set to reduce energy bills of an average EU household by nearly €500 by 2020 [1].

Environmental groups are calling for more accurate, fair and consumer-relevant standards in support of the provision laid out in the newly revised EU Energy Labelling legislation stating “Harmonised standards shall aim to simulate real-life usage as far as possible while maintaining a standard test method.” [2]. These standards are the foundation on which robust policies are built, and they require staying up-to-date with technological and behavioural evolution and new features entering the market.

The investigation

A group of NGOs collaborated to study test standards of three popular consumer products: dishwashers, fridge-freezers and televisions. Following European harmonised test standards and implementing deviations from those, the NGOs explored product performance under both standardised test conditions and under conditions that are closer to real life. Only one unit of each model was tested, so the results and process followed do not constitute market surveillance testing and consequently not a compliance check. For this reason, the names of the models tested are not published in the report.


The investigation’s key finding is the need to improve test methodologies overall and establish a solid foundation for more representative, more reliable measurements, and better policy measures that depend on those measurements.

Four principal concerns were identified through this research and testing which may be undermining the representativeness and transparency of the energy label:

Solutions proposed

The NGOs recommend that the standardisation community, policy-makers, and other stakeholders work together to make improvements in standards for the three product groups investigated (and learn lessons beyond), including;

Complementing these recommendations, the NGOs developed a new video test loop for measuring average television power use that is much closer to what is broadcasted today to replace the standardised video which is more than ten years old. We also suggest a test method for measuring automatic brightness control, a feature that adapts the brightness of the screen to the ambient light and allowing energy. These are offered to help strengthen television testing and improve the real-life representativeness of the test.

Senior consultant for Topten, Francisco Zuloaga, said: “People trust the energy label and our work is intended to underpin that, to ensure that ‘what you buy is what you get’. Our study found gaps where things could be strengthened. Policymakers and the standardisation community should quickly adopt our recommendations to help ensure a level playing field for all.”



 [1] See: https://ec.europa.eu/energy/si...

 [2] See: https://www.coolproducts.eu/ne...

 [3] See: http://www.web4948.vs.speednam...

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