- The Consumer Council (CC) supports in principle the Electrical and Mechanical Services Department’s revision of the Code of Practice on Energy Labelling of Products (CoP) for inclusion of three additional product types, namely light emitting diode (LED) lamps, gas cookers and gas instantaneous water heaters, into the fourth phase of the Mandatory Energy Efficiency Labelling Scheme (MEELS). CC considers that expanding the coverage of the MEELS to a wider range of products available to consumers will enable them to make energy-efficient choice in buying these products. Furthermore, the mandatory scheme in turn will encourage product suppliers to design and supply better products for local consumers. It will also help to promote the concept of sustainable consumption and steer sustainable consumption behaviour in the long run.
- As mentioned in CC’s last submission in May 2021 regarding the fourth phase of the MEELS, CC suggests that more stringent grading thresholds be adopted whenever feasible so as to provide meaningful differentiation between products of different levels of energy efficiency performance, and promote innovation of traders. Moreover, considering future advances in energy-saving technology, the adoption of more stringent grading thresholds at the commencement can reduce the frequency of upgrading the thresholds in the future. CC suggests that the grading thresholds, especially those for the top Grade 1, as well as other relevant performance requirements be at least comparable with those currently adopted in other advanced economies such as that in the Mainland and the European Union whenever applicable. Besides, any plan of upgrading of thresholds in other advanced economies should be closely monitored, so as to ensure the standards of Hong Kong are on par with other advanced economies when the fourth phase of the MEELS takes effect (targeted to be commenced in Q2 2023).
- In addition to those three product types to be included in the fourth phase of the MEELS, CC considers that other product types of relatively high energy consumption or commonly used by consumers, e.g. electric fans, electric room heaters, electric rice cookers, microwave ovens etc., should also be explored to be included in the MEELS in future. Moreover, to build Hong Kong as a smart city, apart from household products, high energy-consuming products such as passenger cars (in particular electric cars) should be seriously visited and have a clear inclusion roadmap in the coming years.
- Besides the above-mentioned views, some further comments specifically in relation to the revision of the CoP for LED lamps, gas cookers and gas instantaneous water heaters are outlined below.
LED Lamps
- Referring to clause 15.4.2(a) (page 11) of the consultation document, CC agrees that the tests should be conducted at the voltage and frequency of mains electricity in Hong Kong (i.e. 220V, 50Hz), no matter the model’s rated voltage is 220V or 220-240V etc., as CC suggested in the last submission.
- With regard to the test requirements, in Table 15.3 (page 17) of the consultation document, it is stated that for LED lamps whose rated power is less than or equal to 2W, there is no requirement on their displacement factor. However, in the example illustrated on page 23, the requirement on displacement factor being not less than 0.4 is imposed on the LED lamp whose rated power is 2W. To avoid any confusion, assuming that the requirement in Table 15.3 is correctly stated, it is suggested to fine-tune the example with coherent requirement.
- In Table 15.3 of the consultation document, the requirement on lumen maintenance at the end of 6,000 hours being not less than 80% is proposed, irrespective of the model’s rated lamp life. However, CC noted that in the Chinese Standard GB/T 24908 and the US Energy Star programme, more stringent lumen maintenance requirement is adopted, and the lumen maintenance requirement depends on the model’s rated lamp life. For instance, in GB/T 24908 standard, if the model’s rated lamp life is 25,000 hours, the lumen maintenance at the end of 6,000 hours should not be less than 91.8%. If the model’s rated lamp life is 50,000 hours, the corresponding requirement would be raised to being not less than 95.8%. CC is of the view that the lumen maintenance requirement in the MEELS should be at least comparable with GB/T 24908 standard or the US Energy Star programme.
- Regarding the information to be displayed on the energy label, CC suggests that in addition to efficacy (lm/W), other parameters including luminous flux (lm) and lamp life (hours) of the model should also be included on the energy label. The luminous flux represents the brightness of LED lamps, and consumers can compare the luminous flux instead of the rated power (W) when choosing the brightness of LED lamps. The lamp life is another major factor in purchasing LED lamps. Thus, it is essential to mandate the display of all these information in the product label. It will also be of extra benefit to consumers if the said information can be found in EMSD’s MEELS webpage under “record of listed models” for public reference.
Gas Cookers and Gas Instantaneous Water Heaters
- CC supports the proposal of showing the thermal efficiency (in %) on the energy labels for both types of gas appliances, so that consumers would be able to compare the energy efficiency performances among different models of the same product type, even when their energy efficiency grades are the same. Meanwhile, for gas cookers with two or more burners, the thermal efficiencies of the burners could be different from one burner to another. It is not clearly mentioned in the consultation document whether the thermal efficiency value of each burner or only one burner would be shown on the energy label. CC opines that the thermal efficiency value of all burners should be shown on the energy label. However, if only one can be displayed due to whatever reason, the lowest thermal efficiency value among all burners (i.e. the thermal efficiency value used to determine the energy efficiency grade of the model) should be shown in order to avoid the risk of misleading consumers. Moreover, such requirement (i.e. showing the lowest thermal efficiency value) should be clearly stated in the CoP for the trade to follow. Furthermore, the thermal efficiency value of each burner as well as other important parameters (e.g. heat input of each burner) should be published in EMSD’s MEELS webpage of “record of listed models” for consumers’ reference.
- When it comes to gas instantaneous water heaters, hot water production capacity (or called hot water supply), which is commonly expressed in the unit of litre/min at 25°C water temperature rise, is a key parameter for consumers to choose a suitable model. Therefore, CC suggests adding the rated hot water production capacity on the energy label for gas instantaneous water heaters. It is also suggested to disclose the same information in EMSD’s MEELS webpage of “record of listed models” for consumers’ reference.
- CC agrees that the gas type should be shown on the energy labels for both types of gas appliances, as CC suggested in the last submission.
- Clause 17.2 (page 40) of the consultation document specifies the definitions of terms relevant to gas instantaneous water heaters to be used in the CoP. However, it is noted that the paragraph about “rated heat input” in this clause wrongly specifies the definition of rated heat input of gas cookers rather than gas instantaneous water heaters. Correct definition should be specified in the CoP to avoid confusion.
Consumer Council
August 2022
