Given that the industry is hoping for a two-year extension to align itself with the requirements of minimum energy performance standards planned for commercial refrigeration cabinets in 2014, it could seem slightly speculative to be talking about how the market might be regulated.
However, even at this early stage, there is no escaping the fact that market surveillance is going to be an important element of any standards framework that is introduced.
It is one thing establishing criteria that manufacturers need to comply with, but how do you prevent products that don’t meet the necessary standards from entering the market? The ability of the authorities to police the situation and ensure that non-compliant equipment doesn’t enter the supply chain is something that all conforming manufacturers will have a keen eye on for obvious commercial reasons.
Some commentators have already noted that there will be ample opportunity for suppliers to bring in sub-standard refrigeration equipment post-Ecodesign Directive due to the highly fragmented nature of the UK market. And by the time inferior kit has found its way into kitchens, it’s too late.
In the domestic sector, where energy labelling has been implemented for a number of years, the market is self-regulating. However, suppliers agree that it is difficult to see the commercial sector working in quite the same way.
“The commercial refrigeration market is more diversified and less transparent so self-surveillance may work less well,” suggests Stephen Ongley, national account manager at Liebherr. “On the other hand, because of the lower unit volumes, transgressions by smaller players are neither likely to seriously upset the market or compromise the intention of the directive.”
According to Chris Playford, market and development director at Foster, the current plan is for independent testing by policing authorities to be conducted at a national level, with each country making its own arrangements to enforce compliance.
He says: “Given the number of brands and products in the market place it would be sensible to be able to coordinate the evaluation of products across member states to be able to cover a greater number of products and ensure that a product failing in one member state is effectively prohibited throughout Europe.
“The scheme does follow the domestic schemes in that it is entirely self-certification without independent scrutiny of test data and the compliance of test chambers will not be assessed, which one can foresee will introduce variance in results between suppliers and policing authorities.
“While there are the issues listed above, this directive does at least provide a common basis for the provision of test data and ranking, which is at least a starting point that provides some level of transparency to customers and distributors and can be built on moving forward.”
Gram’s managing director, Glenn Roberts, says that ideally there will be “stringent” checks conducted on the performance of products either entering the UK or being manufactured within its borders.
He suggests responsibility for this will have to rest with both the relevant governmental authorities and industry itself. “Clearly this will also be driven by end-users and their desire to reduce their energy bills and enjoy the additional durability and longevity of usage that will come from the application of the directive,” he adds.
It goes without saying that all manufacturers involved in setting the new regulations expect the authorities to put the necessary measures in place to enforce any breach of the regulations when the time comes. Enforcement is seen as the key factor in creating an even playing field for all manufactures which comply with the new directive.
Roberts says that while he expects European partner countries committed to the directive to do their best to police non-compliance through the agencies at their disposal, he does not envisage a situation where the industry will see a newly-formed ‘fridge police’ at any of Europe’s borders.
“Therefore it is critical that some form of checks and balances are applied,” he says. “CE approval will certainly filter out non-compliant products, as will the interested parties within the industry lobbying hard to ensure that the directive is followed.”
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Foster’s Playford admits that it will be almost impossible to stop unscrupulous traders from bringing in non-compliant products if they are absolutely determined to do so.
“It will depend to a large extent on the resources provided to the policing authority to evaluate products that are positioned throughout the range of energy levels from A-G and not focus on those that are positioned in the upper quartile of the energy scale,” he suggests. “It is plausible to see non-conforming product ‘hiding’ in the mist of the energy labels out of the eye of the enforcement authorities.”
Steve Goldsmith, chief refrigeration engineer at Precision Refrigeration, believes that end-users will have a vital role to play in keeping non-compliant refrigeration cabinets off the market.
“The importing of low cost, illegal equipment will always be the biggest issue but hopefully end-users armed with the right information will eventually force the non-compliant equipment from the market place,” he says.
Ultimately, says Goldsmith, enforcement must be the responsibility of government agencies, a view shared by Malcolm Harling, sales and marketing director of Williams Refrigeration.
“At this stage we assume the authorities will draw on their previous experience of products that are already the subject of energy labelling regulations,” comments Harling. “This type of regulation isn’t new to the UK — it’s just new to our industry.”
MEP standards: Progress report
At a recent event hosted by CESA in London, DEFRA presented an update on Ecodesign requirements for non-household refrigeration following an Impact Assessment study into the category. In its summary it reported:
• Proposals for the combined minimum requirements and energy labels have met with “widespread support from industry”.
• New harmonised test methodology is being developed by CEN TC44 Working Group 2 with target date to publish standard by end of 2013.
• Impact Assessment study recommends to retain the timing of mandatory minimum requirements as proposed in consultation document, which are:
– Tier 1 requirements from January 2015
– Tier 2 requirements from January 2016
– Tier 3 requirements from January 2018
• Requirements will increase prices by potentially up to 20% after Tier 3, but move market towards more value-added products.