1. AMDEA represents the manufacturers of large appliances like washing machines and cookers; small kitchen appliances; heating and water heating products; ventilation equipment; and vacuum cleaners and floor cleaning equipment. The Association makes an active contribution to efforts to achieve energy efficiency in the home. It is represented on a number of groups, including the Energy Saving Trust and the British Energy Efficiency Forum. This paper looks at some of the issues in the Sub-Committee's inquiry from the manufacturers' point of view.

  2. Many domestic appliances have been the subject of non-integrated environmental regulation in recent years. AMDEA has from time to time commented on the burdens imposed on manufacturers by different regulatory authorities in an unco-ordinated fashion, and welcomes the realisation that the industry and consumers alike can benefit from a more rational approach to environmental regulation. Perhaps the most outstanding example of the lack of synchronisation in this field has been the drive to remove CFCs and then HCFCs from refrigerators, whilst at the same time subjecting them first to Energy Labelling and then removing the highest energy consumers from the market through the Energy Efficiency Standards directive. Some important UK manufacturing has not survived this onslaught.

  3. Of itself, Integrated Product Policy will not prevent a recurrence of this damage to UK manufacturing unless full account is taken of the overall commercial impact of all the proposed environmental measures. Necessarily well-signposted prohibitions and restrictions which impede the achievement of a reasonable rate of return on manufacturing investment give opportunities to precisely targeted foreign imports.

  4. The UK Eco-labelling Board consulted AMDEA carefully about the scheme proposed for Washing Machines and Dishwashers at an early stage in 1993. They were precisely guided that requiring third party certification of compliance with the necessary criteria [rather than manufacturer self-declaration procedures which have long been in place for safety regulations] would, coupled with fees based on sales, act as a cost deterrent to manufacturers. The advice was ignored and the Ecolabel was only applied for by one manufacturer.

  5. A relatively small number of consumers is influenced by environmental considerations in its choice of domestic appliances. A larger number—perhaps around 15 per cent today—is influenced by the energy consumption ratings on the Energy Label, whilst even more are interested in the performance rating on the Energy Label. The European Commission's approaches to directives on Eco-labelling and energy labelling are not fully integrated, and the developments in the energy efficiency standards field have probably had more effect than market transformation activities. The first step was taken with refrigeration products, with a mandatory directive. The second development, applying to washing machines, was achieved more speedily through a voluntary agreement with the European manufacturers' association, CECED. European regulations on such matters as the recovery and recycling of end of life products and prohibitions on use of certain materials are likely to have more impact than new approaches to product labelling.

  6. It has been suggested that a new Ecolabel, in our sector, could mimic in some fashion the Energy Label design. Certainly the Washing Machine label presents far more information than the Ecolabel—and would prove a very difficult act to follow. To have any additional meaning, the Ecolabel would need to require lower energy and water consumption than an "A" rated machine together, presumably, with very demanding requirements in the field of materials and detergent use. In a market largely driven by price [and with Ecolabels an additional manufacturers' cost] it is difficult to see high take-up of such a label. The best advice AMDEA can offer on the role of the new advisory panel at DETR is that it should examine other sectors.

  7. It seems that some reliance will be placed on Market Transformation activities to achieve the UK-only target of 20 per cent emissions reductions by 2010. There are discussions about possible Energy Saving Trust [EST] endorsements of the most energy efficient domestic products, although criteria would have to be carefully calculated and consulted upon. But budgets for this kind of activity are fairly limited, and the most effective promotion can be achieved by manufacturers and retailers. Recent weeks have shown signs of increased activity in this area, but more might be done if manufacturers felt they were not battling against an official antipathy to electricity as a fuel [after all, unlike gas appliances, their products are responsible for no emissions at all!]. An interesting example is storage heating, currently frowned upon. Yet there are several million radiators currently in use with a technology up to 15 per cent less efficient than the latest models. A positive promotion by EST of these new systems, as replacements, among consumers who clearly prefer electrical whole-house heating could make a significant contribution to the 2010 target.

Peter Carver
Director General