Ecodesign Directive: An Essential Guide

The EcodesThe Ecodesign Directive establishes a framework for general requirements and specific implementing measures for various energy-related products, such as vacuum cleaners, computers, and refrigerators.

In this guide, we explain the directive’s product scope and provide information concerning conformity assessment, documentation, labelling, and other requirements.

Product Scope

This directive covers the following energy-related product categories:

• Lighting products
• Heaters, boilers, and cooling products
• Refrigeration products
• Vacuum cleaners
• Washing machines and tumble driers
• Air conditioning products
• Televisions and computer monitors
• Kitchen appliances
• Dishwashers
• Water pumps and circulators
• Power adaptors
• Computers and data storage products
• Phones and tablets
• Imaging equipment
• Game consoles
• Electric motors
• Products with standby and off mode
• Welding equipment

Implementing Measures

The Ecodesign Directive acts as a framework for energy-related products. It sets the product scope, conformity assessment procedures, documentation requirements (e.g., Declaration of Conformity, technical documentation), and other general requirements for covered products.

Product-specific regulations – called “implementing measures”, such as those covering dishwashers, lighting products, and power supplies – outline product-specific requirements.(e.g., energy efficiency, sound power level).

Several of these regulations also set harmonised standards and additional requirements concerning technical documentation, labelling, conformity assessment, and more.

Below, we list the general requirements for several categories of products covered by the Ecodesign Directive.

Air conditioners

Regulation (EU) 206/2012 sets out ecodesign requirements for mains-operated air conditioners with a rated capacity of ≤ 12kW for cooling, and comfort fans with power input ≤ 125W.

This includes requirements concerning:

• Minimum energy efficiency
• Maximum power consumption
• Maximum sound power level

EN Standards

Here are some listed harmonised EN standards relevant to this category of products:

a. EN 12102 – Air conditioners measurement of airborne noise

b. EN 12900 – Refrigerant compressors

c. EN 15218 – Test methods and requirements for air conditioners and liquid chilling package

d. EN 12900 – Manufacturer’s performance data refrigerant compressors

Refrigerators

Regulation (EU) 2019/2019 establishes ecodesign requirements for electric mains-operated refrigerating appliances that have a total volume of between 10 and 1,500 litres.

This included requirements concerning:

• Energy efficiency index limits
• Energy consumption
• Storage conditions

EN Standards

We could only find the following harmonised standard:

EN 62552 – Household refrigerating appliances characteristics and test methods

Lighting products

Regulation (EU) 2019/2020 sets ecodesign requirements for light sources that use any of the following lighting technology:

• Incandescence
• Fluorescence
• High-intensity discharge
• Inorganic light emitting diodes (LED)
• Organic light emitting diodes (OLED)

The regulation also covers light sources used for signalling (e.g. traffic lights) or used for film projection and similar purposes.

The regulation includes requirements concerning:

• Energy efficiency
• Functionality
• Provision of information

EN Standards

We could not find any harmonised standard under this regulation.

Dishwashers

Regulation (EU) 2019/2022 sets ecodesign requirements for household dishwashers, which include those that are built-in, as well as battery-powered ones.

The requirements concern elements such as the following:

• Energy efficiency
• Functionality
• Low power modes
• Resource efficiency

EN Standards

Here is the only harmonised standard that is listed for dishwashers:

EN 60436 – Electric dishwashers for household use – Methods for measuring the performance

Tumble driers

Regulation (EU) 932/2012 sets ecodesign requirements for household, as well as non-household, tumble driers that are either electric-mains operated or gas-fired.

The requirements concern elements including:

• Energy consumption
• Provision of information
• Power consumption
• Energy efficiency index
• Condensation efficiency

EN Standards

There is a harmonised standard under this regulation:

EN 61121 – Tumble dryers for household use – Methods for measuring the performance

Electric motors

Regulation (EU) 2019/1781 establishes ecodesign requirements for induction electric motors that have specific characteristics, such as:

• Do not have brushes, commutators, slip rings
• Are not electrically connected to the rotor
• Are rated for operating on a 50 Hz, 60 Hz or 50/60 Hz sinusoidal voltage
• Have either 2, 4, 6, or 8 poles
• Have a rated voltage between 50 V and 1,000 V
• Have a rated power output between 0.12 kW and 1,000 kW

The regulation includes requirements regarding:

• Energy efficiency
• Provision of product information

EN Standards

We could not find any harmonised standards for this regulation.

Power supplies

Regulation (EU) 2019/1782 sets ecodesign requirements for external power supplies that:

• Are designed to convert AC power input into DC or AC outputs
• Are used with one or more unconnected devices making up the primary load
• Are physically enclosed from those devices
• Connected to those devices with removable or hard-wired electrical wirings
• Have a maximum nameplate output power of 250 W.
• Are used with electrical and electronic devices such as clocks and radio sets

This includes requirements concerning:

• Energy efficiency
• Provision of information
• Calculations and measurements

EN Standards

We could only find one harmonised standard under this regulation:

EN 50563 — External a.c. – d.c. and a.c. – a.c. power supplies – Determination of no-load power and average efficiency of active modes

Conformity Assessment

The Ecodesign Directive sets two separate conformity assessment procedures, that is the internal design control procedure in Annex IV and the management system procedure in Annex V. Some implementing measures also set additional requirements concerning these procedures.

According to Article 8, the manufacturer can choose which procedure to adhere to. Both procedures require manufacturers to declare that their products fulfil the relevant requirements, including the criteria of the applicable implementing measures.

Internal design control

This procedure requires the manufacturer to compile a technical documentation file. This file should permit an assessment of the product’s conformity to the relevant implementing measure’s requirements.

It requires the documentation to contain the information set in Annex IV.

Additionally, the manufacturer must enact all necessary measures to ensure the product complies with design specifications and relevant requirements.

Management system

A manufacturer that chooses the management system procedure should:

a. Declare that their product’s compliance with relevant requirements

b. Implement the environmental elements outlined in Annex V:

• Environmental product performance policy
• Planning
• Implementation and documentation
• Checking and corrective action

Note that, although it provides general guidelines, the Ecodesign Directive does not indicate a specific management system for manufacturers to follow. Instead, it states that a management system can be used as long as it covers the above-mentioned elements.

Here is an example of a management system:

ISO 14006 — Environmental management systems – Guidelines for incorporating ecodesign

Documentation

The Ecodesign Directive requires importers and manufacturers to prove their product’s conformity to relevant requirements. They should do this by retaining and providing, upon request, documentation, including the Declaration of Conformity (DoC), technical documentation, and other necessary information.

Declaration of Conformity (DoC)

Importers or manufacturers must draw up, retain, and, when requested, provide a Declaration of Conformity. As specified in Annex VI, the Declaration of Conformity should the following information:

• Manufacturer’s name and address
• Sufficiently descriptive identification of the product’s model
• References to applied harmonised standards (where appropriate)
• Other specifications and technical standards used (where appropriate)
• Reference to other CE-mark legislation applied (where appropriate); and
• The identification and signature of the individual authorised to bind the manufacturer

Technical Documentation

The Ecodesign Directive requires compiling, keeping, and making available a technical documentation file.

Internal design control conformity assessment

If the internal design control is used, it should include the information listed in Annex IV:

a. Product description and intended use

b. Outcomes of applicable environmental assessment studies

c. References to case studies or literature about environmental assessments

d. The ecological profile, if the relevant implementing measure requires it

e. Product design specification components relevant to its environmental design features

f. A list of relevant standards used

g. Explanation of solutions adopted to adhere to the requirements

h. A copy of the information regarding the product’s environmental design features, in accordance with the ecodesign requirements set in Annex I

i. Outcomes and details of conformity of ecodesign measurements requirements

Management system conformity assessment

Point 3.3.2 of Annex V lists the documentation that is required to perform the management system conformity assessment. Overall, the items are similar to the ones listed above.

Implementing measures

Some implementing measures set additional measures concerning the technical documentation.

Additional Information

Manufacturers must, per Article 14, provide consumers with:

a. Necessary information regarding how they can sustainably use the product; and

b. The product’s ecological profile and ecodesign benefits.

Depending on the implementing measures, manufacturers may have to provide different information. Here are some examples:

a. Information regarding the manufacturing process.

b. Details regarding a product’s performance and environmental characteristics.

c. Instructions for consumers on the product’s installation, usage, and maintenance.

d. Information for treatment facilities regarding the product’s end-of-life disassembly, disposal, or recycling.

Example: External power supplies

Regulation (EU) 2019/1782 establishes ecodesign requirements for external power supplies. Per Annex II of that regulation, manufacturers must include on their websites and the product’s instruction manuals the following information:

• Manufacturer information
• Model identifier
• Input voltage and frequency
• Output voltage, current and power
• Average active efficiency
• Efficiency at low load
• No-load power consumption

Labelling Requirements

The Ecodesign Directive requires importers and manufacturers to affix the CE marking to their product and packaging and provide other necessary information such as an external power supply’s output power, voltage, and current.

CE Marking

Importers and manufacturers must affix a CE marking, which must:

• Have a height of at least 5 mm
• Be affixed to the product

If affixation of the CE marking onto the product is not possible, then the product’s packaging and accompanying documents must carry it instead.

Additional information

As explained earlier, implementing measures may require manufacturers to provide information that aids distributors and consumers in handling, using, or recycling the product.

This information could include:

• The designer’s information on the manufacturing process
• Information for consumers about the product’s environmental characteristics
• The product’s installation, usage, and maintenance instructions
• The product’s disassembly, recycling, or disposal information for treatment facilities

Example: External power supplies

Regulation (EU) 2019/1782 sets ecodesign requirements for external power supplies. According to Part 2(a) of Annex II, the power supply’s nameplate must include the following information:

• Output power, in watts (W)
• Output voltage, in volts (V)
• Output current, in amps (A)

Lab Testing

Importers and manufacturers often must ensure that they have tests performed to prove their product’s compliance with the Ecodesign Directive’s requirements. When their products pass lab testing, they receive a test report that proves their product complies with the relevant requirements and implementing measures.

Test methods

Here we list several examples of harmonised standards that contain test methods (or methods for measuring performance):

a. EN 60436 – Electric dishwashers for household use – Methods for measuring the performance

b. EN 62552 – Household refrigerating appliances – Characteristics and test methods

c. EN 61121 – Tumble dryers for household use – Methods for measuring the performance

Testing labs

Here are several companies that offer to test products against the Ecodesign Directive:

• Intertek
• SGS
• Bureau Veritas
• Eurofins
• Hong Kong Standards and Testing Centre

Compliance Risks

Home appliances, displays, LED lighting, and other electronic products are not by default designed to comply with the Ecodesign Directive. Electronics products manufactured for other markets, such as the United States or China, may not be compliant with the more stringent EU energy efficiency requirements. Further, there are plenty of non-compliant products being sold online.

This is partly because manufacturers consider it unnecessary to design products for other markets, according to stricter EU rules. That said, there are also plenty of manufacturers that don’t understand or are unaware of the Ecodesign Directive and relevant EN standards.

As an EU importer or manufacturer, it’s always up to you to verify that the product or component is designed for Ecodesign compliance – and provide the required label files. Luckily, that’s made simple thanks to the energy label creation tool.