Response to the Draft Revision of Code of Practice on Energy Labelling of Products
1. The Consumer Council supports extending the scope of the Mandatory Energy Efficiency Labelling Scheme (MEELS) to include televisions, storage type electric water heaters and induction cookers, as well as the heating performance of reverse cycle type room air conditioners and washing machines with higher rated washing capacity. The Council considers that expanding the coverage of the MEELS to make information on the energy efficiency of a wider range of products available to consumers will enable them to make purchase decisions with energy conservation in mind. This in turn will encourage product suppliers to develop and market more energy-efficient products for local consumers. It will also help promote the concept of sustainable consumption and steer consumer behaviour towards sustainability in the long run.
2. Televisions, storage type electric water heaters and induction cookers are currently covered in the Voluntary Energy Efficiency Labelling Scheme (VEELS) using a "recognition type" energy label. The Council supports the proposed change from a "recognition type" energy label to a "grading type" energy label when these 3 product types are included in the MEELS, since a "grading type" energy labelling is more informative and can facilitate comparison.
3. The Council suggests that more stringent grading thresholds be adopted so as to provide useful differentiation between products of different levels of energy efficiency performance, and motivate product suppliers to develop and market more energy-efficient products. Moreover, considering future advances in energy-saving technology, the adoption in the current revision of more stringent grading thresholds can reduce the need for or frequency of upgrading the thresholds. The Council suggests that the grading thresholds, especially those for the top Grade 1, be at least comparable with those currently adopted in other advanced economies such as the European Union whenever applicable.
4. Besides addition of the above-mentioned product types to the draft revision of CoP, other product types of relatively high energy consumption should also be considered for inclusion in the MEELS in further phases.
5. The Council has further comments specifically in relation to washing machines, storage type electric water heaters, induction cookers and televisions which are given below.
6. As household washing machines with rated washing capacity over 10 kg are already on the market, proposed extension of MEELS to washing machines with capacity not exceeding 10 kg is not in line with market trend. The Council suggests that the scope of coverage be further extended to washing machines of washing capacity beyond 10 kg. Besides, testing of rinsing performance pursuant to IEC 60456 standard and of noise performance pursuant to IEC 60704 series standards should be considered for inclusion so as to provide more useful information to consumers.
Storage Type Electric Water Heaters
7. In the draft revision of CoP, storage type electric water heaters of rated storage capacity not exceeding 50 litres have been included. The Council notes that in the current VEELS, products of a wider range up to 300 litres are covered. The Council is of the view that the scope of coverage in MEELS should be extended to cover products of capacity up to 300 litres to eliminate a gap between the MEELS and current VEELS criteria.
8. The Council supports the proposal of calculating the Energy Efficiency Index with reference to IEC 60379 standard for the determination of energy efficiency performance of storage type electric water heaters.
9. The Council supports the proposal of including induction cookers of higher total rated power (up to 7000W) than that in the current VEELS (up to 2800W). However, considering that household multi hob/zone models of total rated power exceeding 7000W (e.g. 7400W) are already on the local market, the Council suggests that the scope of coverage be further extended beyond 7000 W if possible.
10. The Council also supports the proposal that any induction cooker with standby power consumption exceeding a set maximum limit can only obtain Grade 5. Many multi hob/zone models are of countertop built-in type and they are always connected to the power source. Users tend to simply switch off soft-touch power button only for all types of induction cookers and considerable energy will be wasted on standby mode so this aspect should be made a decisive factor in the choice among products.
11. Ceramic and hybrid (with both induction hob and ceramic hob) cookers can be considered for inclusion in the scope of coverage and made subject to identical tests and grading criteria, so that consumers can compare the energy efficiency of these types of cookers directly as well.
12. The Council supports the proposal of using the default picture settings of televisions for the measurements of their on-mode power consumptions, since many users tend not to adjust the picture settings.
13. The Council also supports the proposal that any television with its standby power consumption exceeding a set maximum limit can only obtain Grade 5, for reasons same as for induction cookers.