- The Consumer Council ("CC") supports the Electrical and Mechanical Services Department's proposal to review and upgrade the grading requirements for refrigerating appliances, washing machines and storage type electric water heaters under the Mandatory Energy Efficiency Labelling Scheme (MEELS). CC considers that the upgraded standards would be able to help consumers to better differentiate products with different levels of energy efficiency performance and incentivize product suppliers to develop more energy efficient products.
- As mentioned in CC's last submission in June 2023 on the same subject matter, CC believes that raising the bar and upgrading the criteria of energy efficiency grading would help to promote products of higher efficiency, consequently leading to greater reduction in overall energy consumption without compromising the quality of living in the long term.
- CC suggests that the grading criteria, especially those for Grade 1, should be as stringent as those currently adopted in other advanced economies such as the European Union (EU) wherever applicable.
- It is expected that some of the models currently registered under MEELS would be downgraded upon implementation of the proposed grading criteria. Meticulous care should be taken to ensure these changes should not confuse consumers when they are comparing the energy efficiency between products. CC is of the view that it is important to widely publicise the relevant information about changes to be made in MEELS, so as to avoid causing confusion to the public.
- Consumers nowadays are very used to searching for information on electrical appliances via the Internet or even placing their orders directly online. Therefore, CC suggests that once the proposed grading criteria is implemented, apart from ensuring that the new gradings are shown on the energy labels affixed to the products, relevant information should also be updated on the websites of the product suppliers and retailers wherever the energy efficiency grading is mentioned, in order to prevent any misunderstanding. For example, a consumer orders a model of Grade 1 (the old grading), but the energy label on the delivered product shows a lower grading (the new grading), creating the perception of maltrade practices to consumers.
- In addition to refrigerating appliances, washing machines and storage type electric water heaters covered in the proposal, CC suggests that the grading criteria of the other prescribed products under MEELS should also be reviewed and upgraded in due course. For instance, for split-type room air conditioners, CC observed that as of mid-September, there were around 73% of all registered models rated as Grade 1 for cooling performance (excluding models that are no longer being supplied on the market). Moreover, in one of CC's test reports on the 14 models of "I horsepower" split-type room air conditioners published in 2022, it was found that despite all tested models having met the Grade 1 requirement for cooling performance, their Cooling Seasonal Performance Factor (CSPF) values ranged from 5.28 to 7.72, equivalent to a considerable variance of up to 31.6%, meaning that the tested Grade 1 model with the highest CSPF could save more than 30% energy when compared with the tested Grade 1 model with the lowest CSPF. CC considers that it is time to tighten the grading criteria for split-type room air conditioners as well so as to enhance the effectiveness of the scheme to help consumers to choose models with higher energy efficiency.
- Regarding the 8 prescribed products under MEELS, CC recommends that the scope of covered products should be reviewed from time to time through market research, study of production trends and applicability of relevant test standards, to keep pace with technology advancements and ever-changing market demand.
- In addition to those prescribed products currently covered under MEELS, CC considers that other product types of relatively high energy consumption or that are commonly used by consumers, e.g. instantaneous electric water heaters, electric fans, electric room heaters etc., should also be explored for inclusion in MEELS in due course.
- Network-connected electrical appliances (e.g. room air conditioners, washing machines, etc.) have gained popularity in recent years. CC suggests exploring the feasibility to include the energy consumption of network connection functions of products as one of the requirements in MEELS.
- Apart from domestic products, high energy-consuming appliances commonly used in the commercial sector, such as large capacity industrial washing machines used in laundry shops, should also be explored to be covered.
- Besides the above-mentioned views, some further comments in relation to the revision of the Code of Practice on Energy Labelling of Products (CoP) for refrigerating appliances, washing machines and storage type electric water heaters are specifically outlined below.
Refrigerating Appliances
- CC supports the proposal of adopting the latest edition of the IEC 62552 series standards where testing would be conducted at 2 diverted ambient temperatures of 16°C and 32°C, rather than at a single ambient temperature of 25°C, and this would enable evaluation of seasonal energy performances of refrigerating appliances.
- CC supports the introduction of load processing energy efficiency test which would take the incremental energy impact of user-related factors into account, such as opening doors by the users and cooling of warm food and drinks, to reflect the actual usage in a more realistic manner. However, in clause 8.4 of the proposed revision of the CoP, it is noted that among the three types of refrigerating appliances covered under MEELS (i.e. refrigerator, refrigerator-freezer, and food freezer), the load processing energy efficiency test is required to be performed for refrigerator-freezer only. According to the IEC 62552 series standards, the load processing energy efficiency test is applicable to all types of refrigerating appliances. Therefore, CC suggests that the requirements of load processing energy efficiency test as well as the associated total annual energy consumption and total energy consumption index should be extended to all types of refrigerating appliances rather than confined to a single type of refrigerating appliances, in order to more comprehensively evaluate their energy efficiency performance.
- In clause 8.5.2 of the proposed revision of the CoP, CC observed that the proposed assumption of annual operation days of 196 and 169 days at ambient temperatures of 16°C and 32°C respectively for calculating the annual energy consumption is not quite aligned to the corresponding values set by the authorities of some other economies (for example, Mainland China and the EU). In consideration of the difference with other markets and the higher average temperature in Hong Kong especially in view of the fluctuating weather during summer, a more scientific study on the ambient temperatures in local households should be considered when determining the relevant annual operation days in order to more realistically reflect the local situation.
- The total annual energy consumption, according to Annex F of IEC 62552-3 standard and the calculation methods adopted by some other economies, often includes the energy consumptions of auxiliary components such as anti-condensation heater or automatic icemaker (if any). CC recommends including the energy consumption of such component(s) as well in calculating the total annual energy consumption in MEELS.
- CC suggests that the grading criteria should be based on the statistical studies on some population of refrigerating appliances and should be able to differentiate products with different levels of energy efficiency performance on the market. As the design and energy-saving technology of refrigerating appliances are advancing, the tightened grading criteria should take that into consideration so as to be representative and to remain relevant without the need of frequent updates.
- Regarding the scope of refrigerating appliances covered under MEELS, CC considers that the limit of rated total storage volume of 500 litres should be extended to cover larger refrigerating appliances as models of rated total storage volume exceeding 500 litres are quite common in the local market.
- In consideration of the updates on test methodology in the proposed revision of the CoP, CC suggests that Appendix 2B of the CoP which is about the information to be contained on the energy labels should also be updated accordingly, so as to avoid causing confusion to the public. For instance, in the revised methodology, the annual energy consumption is no longer simply calculated by multiplying the measured energy consumption by 365.
- A few editorial errors in the proposed revision of the CoP are observed and outlined below:
- In clause 8.9.2(a) (page 17 of the consultation document), the phrase of "Subject to clause 10.8.2(c)" should be corrected to "Subject to clause 8.9.2(c)".
- In clause 8.10.1(b) (page 18 of the consultation document) which is about the requirements of storage volumes in the compliance monitoring testing, it states that "Where the volumes of the pantry and/or cellar compartment and fresh food storage compartment are adjustable relative to one another by the user, this requirement applies when the pantry and/or collar compartment is adjusted to its minimum volume". However, in clause 8.6.1(b) (page 16 of the consultation document) which is about the requirements of storage volumes when applying for energy labels (i.e. such requirements should tally with above-mentioned clause 8.10.1(b)), the phrase of “pantry and/or" is missing in this clause.
- In Appendix 2A (page 20 of the consultation document), the heading of “Example of Calculating the Energy Efficiency Grade for Washing Machine” should be corrected to “Example of Calculating the Energy Efficiency Grade for Refrigerating Appliance”.
- In Appendix 2A (page 21 of the consultation document), the equation of “468.802 x 0.777 + 303" should be corrected to "468.202 x 0.777 + 303”.
Washing Machines
- CC supports the proposal of adopting the same international standard IEC 60456 for testing both horizontal axis type and vertical axis type washing machines rather than applying different test standards for the 2 types as was the case previously. CC considers that could facilitate the comparison between the performance of the 2 types of washing machines under MEELS.
- At present, the scope of MEELS for washing machines covers both washers and washer-dryers. However, for washer-dryers, the energy performance of clothes drying is not evaluated. In CC’s test report on 10 models of washer-dryers published this year, it was found that the energy consumption of drying per kg of clothing could be even higher than that of washing per kg of clothing. Furthermore, the results showed a huge difference in energy consumption of drying per kg of clothing amongst the test models, with a maximum difference of approximately 62%. Thus, CC is of the view that clothes drying function should be explored for inclusion in the evaluation of MEELS.
- The current scope of MEELS for washing machines only covers models of rated washing capacity not exceeding 10 kg. However, it is observed that household washing machines (including both washers and washer-dryers) of rated washing capacity higher than 10 kg can be widely found. Although the current rated washing capacities of washing machines are mostly below 10 kg, the rapid development of manufacturing designs and technology would contribute to the continuous increase in the rated capacities in the foreseeable future. In view that the scope of the relevant test standard IEC 60456 has no limit in terms of rated washing capacity, CC suggests that the coverage of MEELS could be extended to those of rated washing capacity above 10 kg.
- CC is of the view that rinsing performance as per IEC 60456 standard and noise performance as per IEC 60704 series standards should be considered for inclusion so as to provide more comprehensive product information to consumers.
Storage Type Electric Water Heaters
- CC has observed that some new models of storage type electric water heaters from some popular brands are of double-tank design rather than single-tank design. However, double-tank models are not currently covered under MEELS nor in the proposal. Excluding double-tank models from MEELS is not beneficial to consumers as they may not be able to compare the energy efficiency between different double-tank models in order to make an informed choice. Moreover, CC has observed that some double-tank models on the market are of a slim design which might be disadvantageous to the thermal insulation performance and thus might lead to higher energy consumption. Therefore, CC suggests extending the scope of MEELS to cover double-tank models in addition to single-tank models.
- CC also suggests adopting the latest edition of IEC 60379 standard (published in February 2023) to evaluate the performance of storage type electric water heaters, rather than continue using the previous edition of this standard (published in 1987) as proposed in the proposal. CC considers that although the latest edition of this standard is very new, the energy consumption test method for the measurement of standing loss per 24 hours (which is a parameter for determining the energy efficiency grading) for single-tank models remains unchanged compared to the previous edition of this standard, thus adopting the latest edition of this standard in MEELS should be feasible. More importantly, the latest edition of this standard had specified the energy consumption test method for multi-tank models, thus adopting the latest edition of this standard and extending the scope of MEELS to cover double-tank models would enable the comparison between the performance of single-tank models and double-tank models on the market.
- The duration of hot water supply of storage type electric water heaters is very important to the users during winter. The maximum possible volume of water delivered at 40°C (IEC 60379:2023 Clause 9.7) is a vital information for consumers and should be included in MEELS.
- CC suggests widening the scope of MEELS so that models of rated water storage capacity exceeding 50 litres would be covered.
- An editorial error is observed in Appendix 7A of the proposed revision of the CoP (page 44 of the consultation document). The phrase of "which is between 55% and 60%" should be corrected to "which is between 55% and 65%".
Consumer Council
September 2023
