Discussion Report: EU Ecolabel for Washing Machines Date September 2009 AEA 1 Project summary The purpose of this pilot project is to link the work of the Eco-design of Energy-using Products (EuP) Directive, with the development of EU Ecolabel criteria. The idea behind this initiative is that with both policy instruments requiring a similar information base for their operation, the EuP evidence base can be utilised to develop EU Ecolabel criteria. This would mean that resources would be used more effectively, as work will not be duplicated. In using the EuP evidence base for Washing Machines this project aims to develop streamlined Ecolabel criteria for this product group. Streamlined criteria will focus on the main environmental impacts EuP products have, and will also cover the environmental impacts not identified in EuP study, but have been highlighted elsewhere as having a significant environmental impact. This piece of work is already well underway for the product groups identified below, where the relevant EuP evidence base has been used to help inform ecolabel proposals. • Personal computers and computer monitors • Laptops • Lighting • Refrigeration A key finding to date is that whilst the EuP preparatory reports contain useful data to inform ecolabel criteria proposals, they do not contain all of the data in the necessary format to develop a complete and rounded set of ecolabel proposals. In the context of washing machines, there is EuP information on sales by appliance category, as well as information on the range of energy efficiencies, but what is not included is an overlay of market data on these ranges of energy efficiencies. It is the combination of this data that would allow an assessment of how much of a market place could meet a certain ecolabel criterion. This example applies similarly to other environmental issues. In the development of this discussion paper for Washing Machines the EuP preparatory studies Lot 14 information was used, as well as the draft Ecodesign Regulation for Washing Machines and the latest CECED data (for which we gratefully acknowledge CECED’s kind assistance). The timescales for the development of the criteria sets is as follows: • September 2009 - distribute discussion paper • 16th October 2009 - Ad Hoc Working Group meeting to discuss draft proposals Further information about the work is available from [email protected] 2 AEA Table of contents 1 2 Introduction 5 1.1 5 EuP Directive and preparatory studies Product Definition 7 2.1 EuP Preparatory Study Definitions 7 2.2 ISO Standard Definition 7 2.3 Energy Label and Ecolabel Definition 8 2.4 Proposed Definition 9 3 Test Standards 10 4 The Market for Washing Machines 12 4.1 Current Policies and Measures 12 4.2 Market Overview 13 4.3 Production and sales 14 4.4 Future technologies 16 Proposed Ecolabel Criteria 18 5.1 Energy efficiency 18 5.2 Washing performance 21 5.3 Drying efficiency 22 5.4 Water consumption 23 5.5 Noise 25 5.6 Flame Retardants and Heavy Metals 26 5.7 Prevention of excess use of detergent 27 5.8 Appliance design 28 5.9 User instructions 29 5.10 Lifetime extension 30 5.11 Information appearing on the ecolabel 30 5 AEA 3 Summary Based on the evidence in the EuP preparatory study for washing machines, the following changes to the existing ecolabel criteria are proposed. Present requirement Energy Efficiency <= 0.17 kWh/kg Proposal Retain as ≤0.17 kWh/kg Water consumption <=12 litres/kg <8.4 litres/kg Spin drying efficiency Class A or B Retain as is Washing performance Class A or B Class A only Noise (56 dB(A) during washing and 76dB(A) during spinning) Prevention of excess use of detergent Retain Appliance design Retain User Instructions Retain Eco-design (including flame retardants and heavy metals) Follow similar criterion as for TVs Life time extension – 2 year warranty and spare parts available for 12 years after production ceases Information appearing on the ecolabel Retain 4 Retain Retain Retain Rationale Based on the 2007 CECED database there has been no technical change warranting a change to the current energy consumption criterion Average consumption in 2007 is 9.8 litres/kg. The proposed limit is achievable by 41.9% of products. Percentage of products with Class A remains too small at just over 10% Nearly 95% of products achieve Class A Small survey of washing machines on the market suggests this remains valid Important design element that should be retained Not all washing machines have energy and water saving programmes and this should be encouraged Important that consumers use the product appropriately to secure good eco-performance Also covered by WEEE and RoHS Directives now For some aspects, production is important. This requirement addresses those. Essential part of ecolabel AEA 1 Introduction This discussion paper for Washing Machines is part of a pilot project to develop streamlined ecolabel criteria for six products groups, by utilising the evidence base gathered in the Eco-design of Energy Using Products (EuP) preparatory studies and the Ecodesign Regulation. The discussion paper consists of five sections: • • • • • Section 1: introduction to the product and a brief summary of the EuP Directive and EuP preparatory studies Section 2: a review of product definitions Section 3: test standards Section 4: presents a summary of economic and market analysis from the EuP preparatory study Section 5: ecolabel criteria proposals informed by the EuP study and other data sources 1.1 EuP Directive and preparatory studies The directive 2005/32/EC on the Eco-design of Energy-using Products (EuP) is a framework for setting eco-design requirements for energy using products. The aim of the Directive is to reduce the environmental impact of energy using products. Those products that are compliant with eco-design requirements will be ensured free movement in the EU. The products covered so far have been chosen based on their meeting the following requirements: • • • The product represents a significant volume of sales and trade (more than 200,000 units a year within the EC) and, The product has a significant environmental impact(s), and The product has significant potential for improvement without entailing excessive costs. For the products that are chosen a preparatory study will be produced to provide the information the Commission needs in order to determine if a EuP implementing measures are appropriate and if so, what those measures ought to be. Each preparatory study follows a common structure to ensure key issues such as markets, technical developments and environmental impacts are covered. There are several similarities between the data collected for EuP in the eight sections and the evidence base that is required to develop EU Ecolabel criteria, such as: • • • • Product definition Economic and market analysis Consumer behaviour Technical analysis of existing products Obtaining the above data is a time consuming task, firstly to collect the data and secondly to gain agreement of the work from stakeholder consultation. Consequently, developing a preparatory study takes between 11 and 21 months to complete. To investigate whether greater benefit can be extracted from its investment in EuP preparatory studies, the Commission instigated this pilot study to determine the extent to which the EuP preparatory study reports can be utilised to inform the development of EU Ecolabel criteria. A key finding to date is that whilst the EuP preparatory reports contain useful data to inform ecolabel criteria proposals, they do not contain all of the data in the necessary format to develop a complete and rounded set of ecolabel proposals. In the context of washing machines, there is EuP information on sales by appliance category, as well as information on the range of energy efficiencies, but what is not included is an overlay of market data on these ranges of energy efficiencies. It is the combination of this data that would allow an AEA 5 assessment of how much of a market place could meet a certain ecolabel criterion. This example applies similarly to other environmental issues. This paper discusses whether alterations are appropriate to the ecolabel criteria for washing machines. It presents information taken from the EuP study and other sources. Readers are invited to provide comments. Such comments will be most helpful if supporting rationale and evidence is provided. 6 AEA 2 Product Definition This section presents a review of the different definitions that are currently used to define washing machines across a number of Directives, Standards and Labels, so as to inform the definition for the Ecolabel such that it is as inclusive as possible. 2.1 EuP Preparatory Study Definitions Lot 14 of the European Commission EuP preparatory studies is for domestic dishwashers and 1 washing machines , also known as “wash appliances”. The product definition used for this EuP lot is based on the Energy Labelling Directive. The definition of “washing machines” set out in Article 1(4) of the Energy Labelling Directive 92/75/EEC is shown below in Box 1: Box 1: Washing machine definition used in the Energy Labelling Directive 92/75/EEC “Washing machine” means an appliance for cleaning and rinsing of textiles using water that may also have a means of extracting excess water from the textiles. “Automatic washing machine” means a washing machine where the load is fully treated by the machine without the need for user intervention at any point during the programme prior to its completion. Examples of user intervention could include manual fill (non automatic water level), transfer of the load between a washing drum and a spin extractor drum or manual draining. 2.2 ISO Standard Definition In the ‘Scope’ section of EN 60456:2005 (European Standard EN ISO 60456:2005 “Clothes washing machines for household use – Methods for measuring the performance (IEC 60456:2003, modified)” a washing machine is defined as ‘appliance for cleaning and rinsing of textiles using water which may also have a means of extracting excess water from the textiles’. EN 60456:2005 defines the different types of washing machines as shown in Box 2 below: Box 2: Definition of different washing machine types in standard EN 60456:2005 1 http://www.ecowet-domestic.org/ AEA 7 • • • • • Agitator washing machine: washing machine in which the textiles are substantially immersed in the washing water, the mechanical action being produced by a device moving about or along its vertical axis with a reciprocating motion (an agitator). This device usually extends above the maximum water level Horizontal drum washing machine: washing machine in which the textiles are placed in a horizontal or inclined drum and partially immersed in the washing water, the mechanical action being produced by rotation of the drum about it s axis, the movement being either continuous or periodically reversed Impeller washing machine: washing machine in which the textiles are substantially immersed in the washing water, the mechanical action being produced by a device rotating about its axis continuously or which reverses after a number of revolutions (an impeller). The uppermost point of this device is substantially below the minimum water level; Nutator washing machine: washing machine in which the textiles are placed in a vertical axis basket and partially immersed in the washing water, the mechanical action being produced by a nutation plate in the bottom of the basket, the movement being either continuous or periodically with or without reversion; Washer-dryer: washing machine which includes both a water extraction (spin) function and also a means for drying the textiles, usually by heating and tumbling. It should be noted that the definition of washing machine types will likely change due to the on-going work of the IEC subcommittee 59D ‘home laundry appliances’, which will be eventually reflected in an update to EN 60456. The proposed new definitions are reported in Box 3 here for sake of completeness of information: Box 3: Proposed new definition for use in IEC 60456 • • • Vertical axis washing machine: washing machine in which the load is placed in a drum which rotates around an axis which is vertical or close to vertical. For the purposes of this international standard, vertical axis is where the angle of the axis of rotation is more than 45 degrees to horizontal. Where the drum does not rotate, the washing machine shall be classified as a vertical axis washing machine; Horizontal axis washing machine: washing machines in which the load is placed in a drum which rotates around an axis which is horizontal or close to horizontal. For the purposes of this international standard, horizontal axis is where the angle of the axis is less than or equal to 45 degrees to horizontal; Manual or automatic washing machine: automatic washing machines where the load is fully treated by the machine without the need for user intervention at any point during the programme prior to its completion. A manual washing machine is where the machine requires user intervention at one or more points during the programme to enable the machine to proceed to the next operation. Examples of user intervention could include manual fill (non automatic water level), transfer of the load between a washing drum and a spin extraction drum or manual draining. 2.3 Energy Label and Ecolabel Definition Commission Directive 95/12/EC implements council directive 92/75/EEC with regard to the energy labelling of household washing machines. Directive 96/89/EC amends Commission Directive 95/12/EC The definition for washing machines in energy labelling directive 96/89/EC is presented in Box 4 below. The same definition is adopted by the EU eco-label scheme in Commission Decision 2005/384/EC of 12 May 2005 (prolonging the criteria established in decision 2000/45/EC). 8 AEA Box 4: Washing machine definition used in the Energy Labelling Directive and 96/89/EC and the EU EcoLabel scheme Electric mains operated household washing machines, excluding machines with no spin capability, machines with separate washing and spin drying vessels (such as twin tubs), and combined washer-driers. Appliances that can also use other sources of energy are excluded. 2.4 Proposed Definition We propose to retain the current eco-label definition of washing machines, presented in the Box 4 above, as it is the most comprehensive of the existing definitions. Electric mains operated household washing machines, including machines with separate washing and spin drying vessels (such as twin tubs), and combined washer-driers. Machines with no spin capability and those that also use other sources of energy are excluded. AEA 9 3 Test Standards The current test standards used for testing the performance of washing machines are shown below in Table 1: 2 Table 1: Test standards for Washing Machine Test Standard name Date in force Description Comments BS EN 60456 Clothes washing machines for household use Methods for measuring the performance 2005 The test standard contains a number of methods for measuring the various performance characteristics of washing machines. The tests that are relevant to Government Standards are: cleaning performance, energy consumption, water consumption, spin extraction performance and spin speed. BS EN 50229 Electric clothes washer-dryers for household use – Methods for measuring performance 2001 The test standard contains a number of methods for measuring the various performance characteristics of washer driers. The tests that are relevant to Government Standards are: cleaning performance, energy consumption, water consumption, spin extraction performance and spin speed. The tests form the basis of the EU Energy Label – see BNW14 EU Energy Labelling of washing machines http://www.mtprog.com/s pm/download/document/i d/587 The EU Ecolabel also uses this test method. EuP will require a revised version of the test standard that includes methods for half loads. The tests form the basis of the EU Energy Label – see BNW14 EU Energy Labelling of washing machines http://www.mtprog.com/s pm/download/document/i d/587 The new edition of EN ISO 60456:2005 ‘Clothes washing machines for household use – Methods for measuring performance’ was published in 2005 and is an updated version of the method currently adopted by the Ecolabel (EN ISO 60456:1999). This revision included several significant updates: • Those resulting in improved reproducibility and repeatability in test results. • Improvements to the load specification in terms of the textile materials, procedures for their handling and pre-conditioning, • Better control of the reference machine water flow, • Improved definition of ambient temperature as being 23C+/- 2C, • Changes to the reference detergent’s composition. In light of the update, it would be sensible for the ecolabel to adopt the revised edition. Since the ecolabel criteria were released, a new test method has been published for noise measurements in July 2001 – IEC 60704-2-4, edition 2 ‘Household and similar electrical appliances – Test code for the determination of airborne acoustical noise Part 2-4: Particular requirements for washing machines’. The method covers single unit electrically driven machines, the washing and spinning function of combined appliances for household and similar uses and spin driers. 2 Market Transformation Programme. BNWO3: Combined laundry Government Standards Evidence Base 2009: Policy Scenario 10 AEA For the test, the same standard test load is used as in IEC 60456 (the standard as EN 60456). Revised ecolabel criteria ought to take account of this method. The Implementing Measures for Stand by/off mode were adopted in December 2008 by the European Commission and came into force on January 7th, 2009 (Commission Regulation (EC) No. 1275/2008). It sets the following limits: • • • • By January 7, 2010: Off Mode not to exceed 1.00W consumption By January 7, 2010: Stand by Mode not to exceed 1.00W; or 2.00W if providing information or status display By January 7, 2013: Off Mode not to exceed 0.50W consumption By January 7, 2013: Stand by Mode not to exceed 0.50W; or 1.00W if providing information or status display If we assume an average of 5 washes per week with an A-rated washing machine (energy consumption 0.95 kWh per wash), this will give us 4.75 kWh of energy used weekly for washing. Each washing cycle is assumed to be 2 hours. For the rest of the week - 158 hours – the washing machine will be in a stand by mode. As energy consumption in the stand by mode should not exceed 1.00W from January 2010, this gives us an energy consumption of 158 W, i.e. 0.158 kWh a week from the stand by mode. Weekly use of energy in the On mode 4.75 kWh Weekly use of energy in the Stand by mode 0.158 kWh Thus, we believe, that with the advent of the EuP standby measures, the ecolabel only need concern itself with the on-mode power consumption. This accounts for the majority of energy consumed and is therefore the area where the ecolabel ought to focus. Therefore, we propose to follow the same stand by mode requirements as specified in the Implementing Measures for Stand by/off mode. AEA 11 4 4.1 The Market for Washing Machines Current Policies and Measures Table 2 below describes the environmental performance policies and measures that have been legally adopted along with an explanation of how the market will change over time. 3 Table 2: Current policies and measures Policy name Period in force EU Energy Label 1996 2010 EC Ecolabel 1999 ongoing The Energy Efficiency Commitment (EEC) 20052008 Energy Saving Recommended 2005 2008 Industry voluntary commitments 1996 – 2002 and 2002 – 2010 Early replacement 2007 ongoing EU Energy Label 1997 2010 Industry 1996 - 3 2001 onwards Description Impact Washing machines Defines A to G classes All new washing machines are required to for energy efficiency, be labelled. Consumer information wash performance and encourages people to buy more efficient spin performance. Gives and better performing products. maximum spin speed Manufacturers also compete on the basis information and water of energy label information. consumption. Voluntary declaration for The ecolabel enables consumers to resource efficiency. For identify the best performing products. the standard 60°C cotton Typically, the ecolabel is set at a high level programme: energy such that only 10 to 20% of products in a consumption equal to or category can attain the award level. lower than 0.17 kWh/kg (Class A+), water consumption equal to or lower than 12 litres/kg. Energy supplier subsidy Not quantified at this level – Ofgem claims or purchasing incentive that over 8 million cold and wet appliances for more efficient were subsidised under the scheme. products Washing machines with EU energy label class A or better could be subsidised. Point of sale promotion to Not quantified. Criteria for 2006 onwards identify the most efficient are EU Energy Label A class for energy, models. wash performance and spin performance. From 2009 standby energy consumption is included in the criteria. Removes least efficient Removed EU Energy Label energy machines, sets ‘soft’ fleet classes E, F and G by 1999. Removed average targets class D by 2003, set target for sales of average of 0.2 kWh/kg by 2008, promotes models with 0.17 kWh/kg and A rated wash performance. Industry promotion to To encourage consumers to replace older consumers appliances with more efficient new ones. Washer driers Defines A to G classes All new washer dryers are required to be for energy efficiency of labelled. Consumer information washing and drying encourages people to buy more efficient cycle, wash performance and better performing products. and spin performance. Manufacturers also compete on the basis Gives maximum spin of energy label information. speed information and water consumption. Removes least efficient The washing machine commitment Market Transformation Programme. BNWO2: Combined laundry Government Standards Evidence Base 2009: Reference Scenario 12 AEA Policy name Description Impact voluntary commitments Period in force 2002 and 2002 2010 machines, sets ‘soft’ fleet average targets. Early replacement 2007 ongoing Industry promotion to consumers. impacted on the development of the washer drier market. For washing machines it removed EU Energy Label energy classes E, F and G by 1999. Removed class D by 2003, set target for sales of average of 0.2 kWh/kg by 2008, promotes models with 0.17 kWh/kg and A rated wash performance. Improvements in energy consumption have also been seen in washer dryers. To encourage consumers to replace older appliances with more efficient new ones. 4.2 Market Overview The information below is mostly based on the data extracted from Lot 14 of EuP ‘Preparatory studies for domestic dishwashers and washing machines’ and was last updated in 2005. In some cases where there is more recent data on the energy and water consumption (such as the CECED database), the data is presented. The take up of washing machines as noted in the EuP study has reached a point where the market is almost saturated in the EU-15 (Figure 1 below). The situation in the newer member states is slightly different (at least as far as the 2005 EuP study was concerned) in that consumers are more often buying a washing machine for the first time and that take-up is increasing rapidly (source: Lot 14 Task 2 report). 4 Figure 1: Washing machine ownership (EU15) Washing Machines EU 15 ownership rate 1.00 0.90 0.80 0.70 % 0.60 0.50 0.40 0.30 0.20 0.10 20 04 20 01 19 98 19 95 19 92 19 89 19 86 19 83 19 80 19 77 19 74 19 71 19 68 19 65 19 62 19 59 19 56 19 53 19 50 0.00 Considering the market’s development, the EuP study authors observe that the development in 1996 of the EU Energy Label for washing machines drove product development to achieve improved energy efficiency. Because the focus was on energy, technical developments in this area moved ahead rapidly such that a 37% reduction in energy consumption could be achieved compared to a 1992 product without sacrificing wash performance. Consumers embraced the changes and as the authors 4 Lot 14, Task 2: Economic and Market Analysis. Rev. 1.0. Final draft. November 2007. AEA 13 state, expect continued improvement in part they say, because consumer magazines include many other performance parameters in their comparative tests. 4.3 Production and sales Table 3 below shows the production of washing machines in EU25 countries, and the total production in EU27. The majority of data is for the year 2005. As can be seen from the table, the majority of washing machines in Europe are produced in Italy – 8.5 million machines out of 18.1million produced in EU27 in total. Italy is followed by Germany where 3.1million washing machines were produced in 2005. Table 3: Production of washing machines (2005 – units 000s) Country AT BE BG CY CZ DE DK (2004) EE (2003) EL ES FI FR IE IT LV LT LU HU MT NL PL PT (2006) RO SI (2003) SK SE UK EU 27 Washing machines n.a. -75 3 150 -240 100 1 907 1 285 8 527 n.a. ---1 240 180 600 n.a. 110 710 18 124 Table 4 and Table 5 below compare the 2002 sales with those of 2004 using data obtained from GfK databases. The tables show a clear penetration of the A class, the take up of the A+ class, the decreasing share of the B and C classes and the disappearance of the other low efficiency classes. Noting the trend, the EuP study authors remark that class B may eventually disappear given that the category has lost over 30% of its market share in just two years. 14 AEA Table 4: Washing machines sales for the years 2002 – 2004 (units) _ By Energy Efficiency Class TOTAL WEST Energy Efficiency Class <Grand Total> TOTAL East (Cz Hu Pl Sk) January 2002 - January 2004 January 2002 December - December December 2002 2004 2002 TOTAL East January 2004 December 2004 January 2004 December 2004 11,198,889 12,166,433 1,253,348 1,579,762 1,621,560 0 2 0 0 0 9,699 929,225 30 24,816 19,060 A 6,749,547 8,549,715 556,986 1,243,710 1,265,422 B 2,235,786 1,441,018 365,304 184,230 200,284 C 1,412,140 909,048 214,610 55,020 54,044 D 150,126 88,656 16,280 6,327 11,326 E 25,926 15,649 2,347 296 361 F 52,447 56,923 79 13 0 G 5,744 1,438 8 0 0 557,472 174,759 97,704 65,350 71,065 A ++ A+ UNKNOWN There are a couple of anomalies in the EuP data above but nonetheless it provides a helpful indication of the market situation. Tables 4 & 5 show the washing machines sales by energy efficiency classes for the years 2002 and 2004. Table 5 provides the percentage variation of the 2004 sales with respect those of the year 2002 by EU western and eastern countries and by EE classes. The first four columns of Tables 4&5 compare the 2002 sales with those of 2004. For the Eastern countries, only the four nations taken into account in the 2002 data are compared (Czech Republic, Hungary, Poland, Slovakia). The fifth columns of Table 4 carries out the 2004 sales data of all the 8 countries considered by GfK. Overall the 2004 western plus eastern sales (8 countries) exceed 13 millions. The increment of the 2004 sales with respect those of 2002 (4 countries) is around the 10,4 %, of which the 8,6 % is attributable to the western countries and at least 26 % to the eastern ones. This remarkable increment shows, if confirmed for these last years and in the future, that this market is very rapidly renewing. Table 5: Percentage sales of washing machines (2002 and 2004 %) – Energy Efficiency Class West EU East EU 2002 East EU (5 countries) 2004 * A ++ 0.00 0.00 0.00 0.00 0.00 A+ 0.09 0.00 7.64 1.57 1.18 A 60.27 44.44 70.27 78.73 78.04 B 19.96 29.15 11.84 11.66 12.35 C 12.61 17.12 7.47 3.48 3.33 D 1.34 1.30 0.73 0.40 0.70 UNKNOWN 5.73 7.99 2.04 4.16 4.40 100.00 100.00 100.00 100.00 100.00 Total AEA East EU (4 countries) 2004 West EU 15 The market for washing machines showed growth in the last 10 years, having risen by two thirds from 1995 levels. Percentage ownership rose by 2% over the same period and households have increased by 2.5 million (9.6%) over the same period. The market is mature, and is a replacement market with machines typically being replaced when they breakdown and are considered un-repairable. Product trends include a move towards larger load capacities, higher spin speeds, longer main wash times and shorter quick washes, and more programmes to cope with different fabric types. 4.4 Future technologies Producers have worked hard to improve the performance of washing machines. As the EuP Task 6 study report observes (page 133), further improvement is unlikely unless a step change in product or washing process can be devised. Whilst new products are being researched, it is unlikely that these will come to market for some years meaning the ecolabel revision should be based on existing technology. Two areas of research noted in Task 6 are: • Washing with steam • Washing with air and negative ions Whether these or other technologies become a market reality for the next ecolabel revision remains to be seen. Researchers at the University of Leeds, UK, have developed a new way of cleaning clothes using less 5 than 2% of the water and energy of a conventional washing machine . The revolutionary technology will provide alternatives to both domestic washing and dry cleaning, heralding the world’s first “virtually waterless” washing system. The picture below represents a pilot example of a waterless washing machine. Xeros, a University of Leeds organisation, is looking to commercialise the technology with some of the biggest names in the washing and dry-cleaning industries. It is likely to find application first as commercial washing machine types rather than domestic types. The process is based on the use of plastic granules (or chips), which are tumbled with the clothes to remove stains. A range of tests, carried out according to worldwide industry protocols to prove the technology performs to the high standards expected in the cleaning industry, show the process can remove virtually all types of everyday stains as effectively as existing processes whilst leaving clothes as fresh as normal washing. In addition, the clothes emerge from the process almost dry, reducing the need for tumble-dryers. The technology uses as little as a cup of water in each wash cycle. 5 http://www.leeds.ac.uk/media/press_releases/current/washing_machine.htm 16 AEA According to Waterwise, a UK NGO focused on reducing water wastage in the UK, washing machine use has risen by 23% in the past 15 years, up from 3 times a week in 1990 to an average of 4 times a week per household today. The average UK household uses almost 21 litres of water each day on clothes washing - 13% of daily household water consumption. This accounts for approximately 455 million litres of water daily in the UK, enough water to fill 145 Olympic size swimming pools. There are more than two million washing machines sold in the UK annually, valuing the UK market alone at around £1bn. The Xeros technology is a fundamental step-change in the textile lifecycle by replacing water in washing with plastic/polymer chips. The technology could be used in domestic washing machines, in which the amount of water and energy used for washing would be dramatically reduced. The technology has been tested in controlled lab experiments in the Company’s laboratories in Leeds. The Xeros technology, among some others, is identified in a draft report on reducing the environmental impacts of clothes cleaning completed for Defra. The table below represents future developments in the washing technologies together with their environmental benefits and possible 6 impacts . It should be noted that these novel technologies were investigated in a preliminary fashion but not investigated further or subject of more detailed analysis as they were considered to have less potential for environmental benefits in the short to medium term. 6 BIO Intelligence service in collaboration with Giraffe and Intertek. July 2009. Reducing the Environmental Impacts of Clothes Cleaning. A research report completed for the Department of Environment, Food and Rural Affairs. Draft Final Version. AEA 17 5 5.1 5.1.1 Proposed Ecolabel Criteria Energy efficiency Energy Label The energy efficiency levels of the difference Energy Label classes are shown below in Table 6. Table 6: EU Energy Label energy efficiency classes Energy efficiency class A+ A B C D E F G 5.1.2 Energy consumption ‘C’ in kWh per kg 0 washed for standard 60 C cotton cycles using test procedures of the harmonized standards referred to in Article 1 (2) C≤0.17 C≤0.19 0.19<C≤0.23 0.23<C≤0.27 0.27<C≤0.31 0.31<C≤0.35 0.35<C≤0.39 0.39<C The EuP preparatory study data The EuP study authors report a notable improvement in energy efficiency performance over the period 1997-2005, as shown in Figure 2 and Figure 3 below. Figure 2: Average specific energy consumption per load (1997 – 2005) 18 AEA Figure 3: Washing machine specific energy consumption (1997 and 2005) Figure 3 shows that of the sample, nearly 90% of washing machines fall within the range 0.166 to 0.190 kWh/kg. It should also be noted that nearly 40% of machines in the 2005 sample have energy efficiency performance better than the ecolabel limit of 0.17 kWh/kg (according to the Commission Decision of 17 December 1999). This compares to the 1999 situation where there were no products meeting the 0.17 kWh/kg requirement. The study authors note that in Germany and the Netherlands evidence suggests even the sales of Class A machines is reducing and that in Italy they note two unofficial Class A++ machines on sale (Task 2 report, page 10). Converting Figure 3 values into Energy Label classifications results in the data as shown in Figure 4 below. What this clearly shows is how quickly Class A have been adopted (from less than 5% in 1997 to nearly 80% in 2003). The rapid take up of unofficial A+ machines is also clearly shown whereby these make up over 35% of the market in 2005. Class A+ (0.17 kWh/kg) is a half energy class improvement i.e. 10% (AEAT final report to the Commission, washing machine ecolabel, 1999, page 6). Figure 4: Energy efficiency class (1997 –2005) AEA 19 The most recent, 2007 CECED database shows the energy consumption of more than 6000 washing machines, based on their energy efficiency class. According to the database, 96.93% of all washing machines are A-rated based on their energy efficiency. 2.28% of washing machines are B-rated, 0.78% are C-rated, and only 0.01% are D-rated. The database classifies washing machines into 4 energy efficiency classes – A, B, C and D. However, as identified above, currently there is a new A+ energy efficiency class, with the energy efficiency level set at ≤0.17 kWh/kg. Taking this into account, 59.05% of all the washing machines in the database will be A+-rated (with the majority of them having energy efficiency =<0.17), and 37.88% of the washing machines will be A-rated. Figure 5 below shows the CECED data for specific energy consumption of washing machines on the EU market corresponding to different loads. As can be seen from the graph the most common load for domestic washing machines is 5kg. This corresponds to the energy consumption between 0.13 and 0.35 kWh/kg cycle. Figure 5: Specific energy consumption as function of the load for the washing machine models in the 2007 CECED technical database 0.4 0.35 Energy Efficiency 0.3 0.25 0.2 0.15 0.1 0.05 0 0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 Load (kg) The 1999 ecolabel criteria for washing machines states that a washing machine shall use less than or equal to 0.17 kWh of electrical energy per kg of washload measured according to EN 60456:1999, using the same standard 60 °C cotton cycle as chosen for Commission Directive 95/12/EC (1). From analysing CECED’s data and Figure 5 above, we propose that the requirement should remain at less than or equal to 0.17 kWh per kg. Although from analysing the CECED 2007 database it would be possible to reduce this criterion down to <0.17 kWh per kg, this would significant reduce the percentage of washing machines that could comply from 58.9% to 8.6%. As can be seen from the Table 8 below, 58.9% of all washing machines have energy efficiency of 0.17kWh/kg and below. However, the majority of them (about 95%) fall within the energy efficiency range of 16≤C≤17 kWh/kg. Percentage compliance of 58.9%at a level of 0.17kWh per kg is very high for an Ecolabel criterion, however a combination of this with the water consumption and drying efficiency criterion greater reduces the percentage compliance. This is explained further in the water consumption chapter. 20 AEA Table 8: Breakdown of A+ rated washing machines based on their energy consumption (%) Energy consumption (A+ rated washing machine) 5.2 % of total A+ rated washing machines % of total washing machines ≤0.17 86.0% 58.9% ≤0.16 ≤0.15 3.0% 3.0% 3.1% 1.1% ≤0.14 2.0% 0.3% ≤0.13 2.0% 0.2% Washing performance The ecolabel’s present requirement established in 1999 is for washing performance of Class A or B. Since then notable market developments have ensued such that whilst in 1999 just 23% of machines achieved Class A, by 2007 more than 95% of machines achieve Class A (CECED 2007 database). Washing performance Class A, as shown in Figure 6 taken from the EuP study, now dominates the market. Figure 6: Washing performance class (1997 –2005) Washing performance is the rating, which is given to a washing machine to determine how well it o cleans during a cycle. Washing performance is tested at 60 C cotton cycle. However, this wash programme is not necessarily the one that most consumers will use particularly with the widespread availability of low temperature detergents. 0 Some commentators have suggested that the ecolabel ought to consider wash performance at 40 C 0 but as other stakeholders have remarked, the currently available test methods only cater for a 60 C wash. We therefore propose to retain wash performance as a requirement but to set a stricter limit requiring Class A performance. o o The availability of detergents showing good washing performance at 40 C and even 30 C coupled with the desire to make electricity and financial savings provides a further incentive for a consumer to use a o 40 C cotton cycle. Low temperature detergents perform well across a range of environmental AEA 21 o indicators. Wash at 30 C should be encouraged as there is an existing trend and further adoption o would reduce environmental impacts significantly. Whilst it is impractical to set a 30 or 40 C requirement for the ecolabel presently, efforts should be made via the present work to revise the laundry detergent criteria to gauge the issues associated with reviewing the wash performance test and what would be required to develop an updated method. 5.3 Drying efficiency Figure 7 below, extracted from the Lot 14 EuP study, shows the improvement over time in washing machine drying efficiency. Considering the 1999 ecolabel requirement for Class A or B, we see that when the requirement was established less than 20% of products met the standard. By 2005 this had increased to over 50% but it should be noted that just over 10% of these products are Class A. Figure 7: Drying efficiency (1997 – 2005) The drying efficiency of washing machines has further improved since 2005, as can be seen from Figure 8 below, which is based on CECED 2007 data. It can be seen that 13% are now class A and 47% achieve B class. 22 AEA Figure 8: Drying efficiency based on CECED data 2007 50% 45% Percentage in class 40% 35% 30% 25% 20% 15% 10% 5% 0% A B C D E F G Drying efficiency The question is whether: • the ecolabel should set a drying requirement? • If so, what the level ought to be? From a life cycle perspective, a washing machine achieving good drying performance may mean that the textiles are more likely to be air dried than via a tumble drier. The EuP Task 6 report discusses this issue (page 156 onwards) but in doing so says that it is remarkably complicated with several influencing factors: not only by seasonal variations (summer and winter) but also geographic location (warm or cold climate), consumer behaviour, textile residual moisture content and performance characteristics of the tumble dryer amongst others. It could be argued that the ecolabel ought not be overly selective on this one issue as other design characteristics warrant more attention. With this in mind, we suggest the current requirement for Class A or B is retained. 5.4 Water consumption Figure 9 taken from the Lot 14 EuP Task 2 report, shows changes in average water consumption over the period 1997 to 2005. AEA 23 Figure 9: Washing machine average water consumption, 1997 - 2005 The trend in Figure 9 is not surprising: a significant fraction of the energy consumed by a washing machine is used to heat the water it consumes, so it follows that to secure the improvements noted earlier in average energy efficiency that the average amount of water used would decrease too. The ecolabel’s 1999 requirement is 12 litres of water per kg of washload very near the average value of 12.9 litres in 1999. Considering the EuP study report and its data we suggest that the ecolabel requirement could be reduced. This is supported by the information presented in the Figure 10 below that shows a correlation between the load of the washing machines and specific water consumption from the CECED 2007 database. Figure 10 shows that since 2005 the trend for reduced water consumption by washing machines has continued. Figure 10: Water consumption per kg according to CECED 2007 data 18 Water consumption litres/kg 16 14 12 10 8 6 4 2 0 0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 Load (kg) 24 AEA It can be seen from the figure that the most commonly used load of 5kg has an average water consumption of 7.0 to 15.2 litres/kg. From looking at the whole CECED database, which includes a total of 6835 washing machines, we propose a water consumption criterion of <8.4 litres/kg. Summary The summary below provides an indication of available washing machines with respect to energy, washing performance, drying performance and water consumption. The difference between the two tables below is that the first table is looking at the individual criteria only and not the combination of criteria, which is why the numbers are different in some cases. From doing some statistical analysis on the CECED 2007 database we can see that from the 6835 washing machines in the database 58.9% would be compliant based on an energy efficiency level of ≤0.17 and a drying performance of A or B. When taking waste consumption at <8.4 l/kg into account as well the overall percentage is 41.8%. This percentage will be further reduced due to the requirements of other criteria such as noise, appliance design and lifetime extension. Percentage of washing machines passing individual criteria Energy Washing performance Drying performance ≤0.17 - 58.9% <0.16 – 3.1% <0.15 – 1.1% Class A - 95.8% Class A – 13.3% Class B – 46.6% Combined A&B – 59.9% Water consumption (<8.4 l/kg) 44.8% Percentage of washing machines passing combined criteria and the overall pass rate Energy Washing performance Drying performance Water consumption (<8.4 l/kg) ≤0.17 - 58.9% Class A - 58.9% Class A – 13.3% Class B – 45.6% Combined A&B – 58.9% 41.8% Overall pass rate (% of total number of washing machines) 41.8% <0.16 – 3.1% Class A - 3.1% Class A – 3.1% 3.1% 3.1% <0.15 – 1.1% Class A - 1.1% Class A – 1.1% 1.1% 1.1% 5.5 Noise There is very little data in the EuP report regarding noise in either the washing or spinning modes. The study authors adopted 53 dB(A) and 70 dB(A) for washing and spinning respectively (Task 5, page 38) commenting that noise reduction is something that ideally ought to be achieved given the irritation caused by machines operating at night. Note that the authors identified a ‘top of the range’ 2006 product (from the perspective of energy efficiency) and its noise characteristics were 53 and 72 dB(A). AEA 25 The 1999 ecolabel criteria states that noise shall not exceed LWAd 56 dB(A) during washing or LWAd 76 dB(A) during spinning, measured according to EN 60456:1999, using the same standard 60 °C cotton cycle as chosen for Directive 95/12/EC. There are conflicts between the desire to improve drying performance whilst achieving noise reduction. Basically in trying to secure enhanced drying performance (via faster spin speeds) more noise is generated (Task 6 report, page 86). There is no information on noise in the 2007 CECED database. Therefore, not to over restrict the washing machines that can comply with the Ecolabel criteria (considering the energy efficiency, water and drying efficiency proposals), we propose to keep the same levels as in the 1999 criterion. The noise proposal is shown below in Box 5. Box 5: Noise Ecolabel proposal Airborne acoustical noise from the appliance, counted as sound power, shall not exceed LWAd 56 dB(A) during washing or LWAd 76 dB(A) during spinning, measured according to EN 60456:1999, using the same standard 60 °C cotton cycle as chosen for Directive 95/12/EC. Information about the noise level of the machine shall be provided in a way clearly visible to the consumer. This shall be done by the incorporation of this information in the energy label for washing machines. 5.6 Flame Retardants and Heavy Metals For the flame retardant (FR) and heavy metal criterion we propose to use the same requirements as agreed for the Television Ecolabel outlined in Commission Decision 2009/300/EC of 12 March 2009 and shown in Box 6. This is a common issue across many of the different ecolabel product groups and using a recently agreed approach is most appropriate at this time. There is varying opinions regarding FRs a number of which have been communicated to us previously as part of this work and revisions for other product groups. Although we are currently proposing to use the same criterion as in the Television Ecolabel, it is our understanding that FRs will be discussed in a separate meeting to be arranged by the Commission possibly later in 2009. This may result in the proposal being changed to reflect the outcome of this Commission meeting. 26 AEA Box 6: Proposed EU Ecolabel criteria for heavy metals and flame retardants (a) Cadmium, lead, mercury, chromium 6 + or poly-brominated biphenyl (PBB) or poly-brominated diphenyl ether (PBDE) flame retardants, as listed in Article 4(1) of Directive 2002/95/EC of the European Parliament and of the Council (2), shall not be used unless the applications of those substances are listed in the Annex to that Directive as exempted from the requirements of Article 4(1) of that Directive or unless their maximum concentration value is equal to or lower than the threshold specified in that same Annex. Regarding the Annex, for PBBs and PBDEs, the maximum concentration value shall be < 0,1 %. (b) Plastic parts shall not contain flame retardant substances, or preparations containing substances, that are assigned or may be assigned, at the time of application, any of the following risk phrases or combinations thereof: — R40 (possible risk of cancer), — R45 (may cause cancer), — R46 (may cause heritable genetic damage), — R50 (very toxic to aquatic organisms), — R51 (toxic to aquatic organisms), — R52 (harmful to aquatic organisms), — R53 (may cause long term adverse effects in the aquatic environment), — R60 (may impair fertility), — R61 (may cause harm to the unborn child), — R62 (possible risk of impaired fertility), — R63 (possible risk of harm to the unborn child as defined in Directive 2006/121/EC. This requirement shall not apply to reactive flame retardants i.e. those which upon use change their properties (i.e. are actually not contained in the final product in a concentration > 0,1 %) such that the identified R-phrases above no longer apply. Assessment and verification: A certificate signed by the manufacturer declaring compliance with these requirements shall be submitted to the awarding competent body. A declaration of compliance signed by the plastic and flame retardant suppliers and copies of relevant safety data sheets about materials and substances shall also be provided to the awarding competent body. All flame retardants used shall be clearly indicated. 5.7 Prevention of excess use of detergent The 1999 ecolabel criteria has a requirement for prevention of excess use of detergent and this is shown below in Box 7: Box 7: 1999 Ecolabel criterion for prevention of excess use of detergent The appliance shall have clear volumetric and/or weight-related markings on the detergent dispenser allowing the user to adjust the detergent quantity used according to the type and amount of load and its degree of soiling. Although the ecolabel criteria for the laundry detergents include requirements on dosage recommendations for normally and heavily soiled textiles and for the ranges of water hardness, it is felt that the above criteria in washing machines is an important deign element to assist the correct use of detergents. Therefore we propose that this criterion is kept in as above. AEA 27 5.8 Appliance design The 1999 ecolabel criteria has a requirement for appliance design and this is shown below in Box 8: Box 8: 1999 Ecolabel criterion for appliance design The machine shall have clear markings on it identifying the appropriate settings according to fabric type and laundry code. The machine shall have clear markings on it identifying energy and water saving programmes and options. Broadly washing machines are designed with clear markings identifying the appropriate settings according to fabric type and laundry code with some also having markings identifying energy and water saving programmes and options. It is felt that these are important design elements for the end user and we therefore propose to retain this criterion as above. In addition, the 1999 ecolabel criteria included criterion relating to take back and recycling. The take back element is now addressed through the WEEE Directive and it is proposed to amend the information provided in the user instructions to reflect this, see Section 5.9 below. However it is important that the appliance design still allows for ease of recycling and repairs. It is therefore proposed to retain elements of the 1999 criteria together with criteria consistent with that included in the recent revision to the ecolabel for televisions with regard to design for disassembly Box 9: Design for Disassembly Criterion The manufacturer shall demonstrate that the appliance can be easily dismantled by professionally trained recyclers using tools available to them, for the purpose of: • undertaking repairs and replacement of worn-out parts, • upgrading older or obsolete parts, and • separating parts and materials, ultimately for recycling To facilitate the dismantling: • Fixtures within the appliance shall allow for its disassembly e.g. screws, snap fixes, especially for parts containing hazardous substances. • Plastic parts shall be of one polymer or be of compatible polymers for recycling and have relevant ISO11469 marking if greater than 25 g in mass • Metal inlays that cannot be separated shall not be used. • Data on the nature and amount of hazardous substances in the appliance shall be gathered in accordance with Council Directive 2006/121/EC and the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). Assessment and verification: A test report shall be submitted with the application detailing the dismantling of the appliance. It shall include an exploded diagram of the appliance labelling the main components as well as identifying any hazardous substances in components. It can be written or audiovisual format. Information regarding hazardous substances shall be provided to the awarding competent body in the form of a list of materials identifying material type, quantity used and location. 28 AEA 5.9 User instructions The current ecolabel criterion is: Box 10: 1999 Ecolabel criterion for user instructions The appliance shall be sold with an instruction manual which, amongst others, shall provide advice on the correct environmental use and, in particular recommendations for optimal use of energy, water and detergent in the operation of the appliance. This manual shall include: (a) on the cover page or first page the following text: ‘Information on how to minimise environmental impacts is given in this manual’; (b) if the machine has hot-fill, advice that the use of the hot-fill can save primary energy and related emissions if the water is heated by solar energy, community heating, modern natural gas or oil heating systems or natural gas continuous flow heater. The user shall be informed that the conduit between the warm water source and the washing machine should be short and well insulated; (c) advice to use a full load whenever possible; (d) advice on the availability of ecological friendly modern detergents, such as compact detergents; (e) advice on varying the detergent dose according to water hardness, the type and amount of the load and its degree of soiling (for example: a half load requires less detergent); reference shall be made to the markings in the detergent dispenser; (f) advice on sorting fabrics appropriately, the corresponding wash temperature according to the fabric type, also stating that in most cases washing at higher temperatures is no longer necessary when using modern detergents, such as compact detergents, and modern washing machines; (g) information about the energy and water consumption of the washing machine for the different temperature settings and for different load settings, allowing the consumer to identify an appropriate programme to make the least use of energy and water; (h) advice that the washing machine should be switched off when it has completed its cycle, because of possible energy losses; the instruction manual shall state the time needed to complete the programmes available; (i) information on power requirements during the following modes: off mode, timer mode (programming), programme ended mode; (j) advice to avoid pre-washing in the machine whenever possible; (k) advice on appropriate maintenance of the washing machine, including the regular cleaning of filters and pumps, and removal of deposits; (l) advice on how to install the machine so as to minimise the noise emitted; (m) information that ignoring the issues mentioned above can lead to higher consumption of energy, water and/or detergent and thus can increase the running costs and lead to poor washing performance; (n) advice on how the consumer can take advantage of the manufacturer's take-back offer. There are extensive user manuals available for modern washing machines that include all the above points. However, as it is very important that consumers use the product appropriately to secure good eco-performance, so we propose to retain this criterion as above with the exception of point (n), which we propose to amend as follows: (n) End of life instructions for the proper disposal of the appliance at civic amenity sites or through retailer take back schemes as applicable, which shall comply with Directive 2002/96/EC of the European parliament and of the Council This is consistent with the recent ecolabel revision for televisions and reflects the requirements of the WEEE Directive (2002/96/EC). AEA 29 5.10 Lifetime extension We propose to retain the criterion on lifetime extension from the 1999 ecolabel criteria, as shown below in Box 11. Box 11: 1999 Ecolabel criterion for lifetime extension The manufacturer shall offer a commercial guarantee to ensure that the washing machine will function for at least two years. This guarantee shall be valid from the date of delivery to the customer. The availability of compatible replacement parts shall be guaranteed for 12 years from the time that production ceases. 5.11 Information appearing on the ecolabel We propose to retain the 1999 ecolabel criterion as follows: Box 12: 1999 Ecolabel criterion for information appearing on the ecolabel ‘This product qualifies for the European Union eco-label because in particular it is economical with energy and water and is designed to increase durability, to facilitate recycling, reparability and environmentally sound disposal.’) 30 AEA AEA group 329 Harwell Didcot Oxfordshire OX11 0QJ Tel: 0870 190 8206 AEA 31
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