APPLiA’s response to call for evidence on simplification of energy-efficient products legislation

APPLiA appreciates the efforts of the European Commission to simplify the ecodesign and energy label framework. We trust that the energy product omnibus legislation will make it easier to market energy efficient appliances and reduce any red tape creating unnecessary burdens. 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. This position paper outlines APPLiA’s strategic recommendations.

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.
• QR code on the energy-labelled product: It would allow consumers to get access to EPREL to obtain energy label-related information after the product has been purchased.
• Legal certainty and timelines: From the Commission, 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 advocates for greater transparency in the legislative process, specifically requesting the timely distribution of draft Commission proposals. Providing early access to these drafts, particularly well in advance of Consultation Forum or Ecodesign Forum meetings, is crucial. This is essential to facilitate informed stakeholder feedback, prevent errors, and ensure a democratic legislative process.