New energy labels to impact on retail refrigeration

The EU Ecodesign Directive (Directive 2009/125/EC) is a framework directive that obliges manufacturers of energy consuming products to reduce the energy consumption and sometimes also other negative environmental impacts occurring throughout the product life cycle. The Directive is complemented by the Energy Labelling Directive (Directive 2010/30/EU).

Most end users are familiar with energy labelling of domestic products such as refrigerators, washing machines and clothes driers. Traditionally energy labelling has been focused on domestic appliances, where labels have been ubiquitous since the early 1990s. Energy labelling is a European initiative where minimum energy performance standards (MEPS) are applied (through the Ecodesign Directive). This means that a product must perform better than the MEPS to be able to be sold in Europe. In addition to MEPS, labelling levels are often applied which indicate levels of performance from low to high (Energy Labelling Directive).

When implementing energy labelling, the aim is that consumers should not be disadvantaged by Ecodesign regulations in terms of affordability of products, or the life cycle cost of the product. The Directive also stipulates that regulations should have as a target that products placed on the market have an energy efficiency of at least that of the lowest life cycle cost (LLCC) for the product (i.e. they should include all available energy savings that pay off during the product lifetime). Although the focus is on energy use, the label can also cover the consumption of other resources and impacts (for example water consumption or noise levels during use). Generally with most refrigeration equipment, the use phase has the greatest environmental impact and so tends to be the focus of regulations.

More recently the European Commission has been evaluating the use of energy labels outside of the domestic environment. This has led to labels for professional (catering) cabinets which were introduced in 2016. It is now illegal to sell most professional cabinets without a label in Europe. As the regulation has been in place for several years, the MEPS are now being tightened and energy levels made more stringent (from 1 July 2019 only products that are energy label of E or better can be sold in Europe). Regulations for refrigeration with a direct sales function (retail cabinets) are now in a draft form and due to be implemented on 1 March 2021. These include all supermarket refrigerator cabinets (both horizontal and vertical), beverage coolers, ice-cream freezers, gelato-scooping cabinets and refrigerated vending machines. The method to assess performance is via test standards that enable measurement of temperature and energy performance. Although test standards, such as EN ISO 23953 (Refrigerated display cabinets) have been available for many years, several new test standards specifically to measure performance of beverage coolers, ice-cream freezers, gelato-scooping cabinets and refrigerated vending machines have recently been generated to enable these products to be tested and their performance compared.

The energy label is generated from a test carried out according to a specific test standard for the product. The products are tested in an environmental test room where the ambient conditions (temperature, humidity and air flow) are controlled. A test is then applied which measures temperature within the cabinet and the energy used by the cabinet. To enable the cabinet to be labelled, the measured test room energy is converted into energy used per year and compared to a standard annual energy (SAE) to provide an energy efficiency index (EEI) which then relates to the label level. The SAE is calculated using an equation which takes into account differences between cabinet types, temperature levels, sizes of cabinets and operation types (plug in or remotely operated). This theoretically enables cabinets to be directly compared and the energy efficiency of for example an open fronted chilled multi-deck cabinet to be compared to a frozen cabinet with doors.

The impact of selecting different efficiency cabinets is quite dramatic. The EEI for an A rated cabinet needs to be better than 10, whereas the lowest energy category (G) has an EEI of between 80 and 100. Even with today’s best technology, for a typical vertical chilled 2.5 m long cabinet the energy used per year could range from 2865 kWh/year for a B rated cabinet (typical best current technology) to 17,192 kWh/year for a G rated cabinet (lowest energy label allowed to be sold). It should be noted that to make this saving you may need to change technology, for example the G rated cabinet might be an open fronted multi-deck whereas the B rated cabinet might be a well-insulated cabinet with doors.

The graph below shows the AEC for 6 different cabinet types with various temperature classifications (temperature achieved in the cabinet). The energy used for a middle of label band A, B, D and G is shown. G is the highest energy label that will be legally allowed, D is middle ranking label, B is a realistic best performance scenario for current cabinets and A relates to a best performing future cabinet (the Commission have stated that no cabinets will be labelled A initially). Savings (based on a tariff of £0.14/kWh) are shown when comparing an A and a G cabinet. For all but the smaller ice cream freezer and beverage cooler the savings achieved by selecting the best versus the worst cabinet in each scenario exceed £2k per year. Over an estate consisting of hundreds of cabinets this equates to a substantial monetary (and carbon) saving. It does however, need to be borne in mind that energy used in a test scenario does not necessarily translate into savings in a retail environment. Real life savings could be greater or smaller depending on the environment in which the cabinet is placed and the way the cabinet is used and maintained.

The Ecodesign and labelling regulations for refrigeration products with a direct sales function are slightly different from previous regulations. Previous regulations for other products have been far less prescriptive and have not included a specified need for technical evidence and reports on the performance of products. The reason for this new requirement is that products must be listed on a European product database for energy labelling. The European product database for energy labelling (EPREL) is a database that relates to the energy label, technical documentation and compliance information. The EPREL is divided in two parts:

  1. A compliance site. This is a secure website or portal hosted by the EC. It is an access point for publishing and accessing public and compliance data by Suppliers, Market Surveillance Authorities (MSA) and EC officials.
  2. A public site. Again a secure website or portal. The site enables citizens, resellers and researchers to have access to product information. It is stated on the portal that ‘consumers will be able to search the EPREL database for energy labels and product information sheets as of the second quarter 2019’.

Due to the requirements within the EPREL, suppliers must now provide justification for the energy label they claim. Within the draft regulation for refrigerating appliances with a direct sales function, it is stated that products must be tested and must be accompanied by a certificate or test report. This means that the product must comply with the following requirements:

  1. it has been specifically designed and tested for the mentioned operating condition or application, according to the European legislation mentioned or related acts, relevant Member State legislation, and/or relevant European or international standards;
  2. it is accompanied by evidence, to be included in the technical documentation in the form of a certificate, a type approval mark or a test report, that the product has been specifically approved for the mentioned operating condition or application;
  3. it is placed on the market specifically for the mentioned operating condition or application, as evidenced at least by the technical documentation provided for the product and any advertising or marketing materials;

Such evidence can be obtained by independent testing. Alternatively manufacturers can self-certify products and in this case witness testing (where self-certified test data is independently checked and validated) can be a useful means to ensure that standards are correctly applied and information is reliably interpreted.

One question you may be asking is; how will Brexit affect these regulations? In terms of the standards used for the testing it is clear that there will be little change. British Standards have clearly stated in a position statement that ‘BSI should remain a full member of the European Standards Organizations’. Therefore the standards used in the UK will not change, as BSI will continue to work with other European standardisation organisations. In terms of the Ecodesign and labelling regulations themselves, it seems unlikely that the UK will not apply labelling after Brexit. Companies who manufacture in Europe and companies who import into Europe will need to comply with these regulations. UK companies selling products into Europe must comply and so it seems unlikely that manufacturers would not need to label products in the future. End users who are aware of labelling are generally positive and see it as a means to compare products and buy the most energy efficient option. Therefore there is likely to be pressure from end users to label products. In addition, energy labelling is considered positively by the UK Government as a means to reduce the UK’s carbon emissions. Domestic energy labelling (where energy used by products has approximately halved since inception) is seen as a success by legislators and something to be replicated in other areas.

For further information contact Judith Evans (j.a.evans@rdandt.co.uk) or visit the web site at www.rdandt.co.uk.