Our position papers
ECOS, EEB, Friends of the Earth, WWF, INFORSE-Europe, CAN-E and Greenpeace are issuing regular position papers to comment the draft Ecodesign and Energy Labelling proposals from the European Commission.
You can download our position papers below. Please note that most of these position papers relate to specific Working Documents issued by the European Commission at a specific date before a Consultation Forum discussion. Reading the related Working Document helps following our arguments. However, these Working Documents are then outdated when the European Commission publishes a further draft. To check where the policy process stands for a specific product group, please visit this section.
(Lot 16) Household tumble driers (June 2010)
- Position paper from Environmental NGOs
- Working document from the European Commission
(Lot 17) Vacuum cleaners (June 2010)
- Position paper from Environmental NGOs
- Working document from the European Commission
(Lot 10) Domestic air-conditioners (April 2010)
- comments from Environmental NGOs on the revised draft Ecodesign and Energy Labelling measures for air-conditioners and comfort fans
- Latest Working document from the European Commission
- Initial position paper from Environmental NGOs for this product group (June 2009)
(Lot 12) Commercial refrigeration (April 2010)
- Opinion from Environmental NGOs on the approach for setting Ecodesign rules for display cabinets and vending machines: click here.
- Working document from the European Commission highlighting options for this product category
(Lot 14) Household washing machines and dishwashers (March 2010)
- comments from Environmental NGOs on the revised draft measures for the Ecodesign and Energy Labelling of washing machines and dishwashers
- Latest Working documents from the European Commission
- Initial position paper from Environmental NGOs for this product group (December 2008)
(Lot 10) Industrial and ventilation fans (March 2010)
- comments from ECOS on the finalised Ecodesign rules for fans (24 March)
- previous position paper from ECOS (including more details - February 2010)
- Latest Working Document from the European Commission
- Initial position paper from Environmental NGOs for this product group (May 2008)
(Lot 5) Energy labelling of televisions (March 2010)
- comments from Environmental NGOs on the revised version of the proposed Energy Label for TVs
- Working document from the European Commission
(Lot 10) Industrial and ventilation fans (February 2010)
- additional comments from Environmental NGOs on revised version of the proposed Ecodesign measure for fans (from Dec. 2009)
- Initial position paper from ECOS and Environmental NGOs
(Lot 1) Boilers - Finalisation of the methodology (Dec 2009/Jan 2010)
- First technical contribution from ECOS and INFORSE on the methodology
- Second technical contribution from ECOS and INFORSE on the methodology
(Lot 3) Computers and monitors (discussion in October 2009)
- additional comments from Environmental NGOs on revised versions of the working documents (from 2 Dec. 2009)
- Initial position paper from ECOS and Environmental NGOs
- Updated working documents from the European Commission: computers, displays
(Lot 18) Complex Set top boxes (discussion in October 2009)
- Position paper from ECOS and Environmental NGOs
- Voluntary initiative proposed by the industry to replace a mandatory regulation: Content and discussion paper
(Lot 4) Imaging equipment (printers, copiers, faxes...) (discussion in October 2009)
- Position paper from ECOS and Environmental NGOs
- Voluntary initiative proposed by the industry to replace a mandatory regulation: Content and discussion paper
(Lot 1) Boilers (2nd discussion in June 2009)
- Position paper from ECOS and Environmental NGOs
- Working documents from the European Commission: Ecodesign and methodology, Energy labelling.
(Lot 11) Air-conditioners, ventilation and fans (discussed in June 2009)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: air-conditioners, air-coolers & comfort fans
Positions of Environmental NGOs on the revision of the EU Energy Labelling (updating the A-G energy scale) - on-going discussion in 2008 and 2009
- Most recent position after the rejection by the European Parliament of new energy labels proposed by the European Commission (June 2009)
- Statement of Environmental NGOs on the layout of the EU Energy Label (February 2009)
- Background powerpoint presentation on this topic
- First position of Environmental NGOs on the revision of the Energy Labelling policy (February 2008)
Additional comments to policy-makers on TVs, fridges, washing machines, dishwashers, motors, circulators (for the votes in March 2009)
- Position paper from ECOS before votes by Member States
(Lot 13 & 14) Fridges, washing machines and dishwashers (discussed in December 2008)
- Position paper from ECOS and Environmental NGOs
- Working documents from the European Commission: fridges, washing machines, dishwashers
(Lot 5) Televisions (discussed in October 2008)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: televisions
(Lot 2) 2nd consultation on water heaters (July 2008)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: 3rd version
(Lot 11) Motors, circulators and pumps (discussed in May 2008)
- Position paper from ECOS and Environmental NGOs
- Working documents from the European Commission: motors, pumps, circulators
(Lot 19) Domestic lightbulbs (discussed in March 2008)
- Position paper from ECOS and Environmental NGOs
- Working documents from the European Commission: introduction, requirements, labelling
(Lot 1&2) Boilers and water heaters (discussed in February 2008)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: 1st version
(Lot 7) Power supplies (discussed in February 2008)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: power supplies
(Lot 0) Simple set top boxes (TV decoders) (discussed in February 2008)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: set top boxes; summary of the preparatory study by ECOS
(Lot 8) Office lighting (discussed in December 2007)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: office lamps, ballasts and luminaires
(Lot 6) Standby losses (discussed in October 2007)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: simple standby modes
(Lot 9) Street lighting (discussed in May 2007)
- Position paper from ECOS and Environmental NGOs
- Working document from the European Commission: street lamps
ECOS has also reacted to the "EuP Working Plan" and the preparatory study for this plan; this document sets the next product categories to be covered by the Ecodesign policy process in the next 3 years. You can download here the comments from ECOS on the preparatory study (Feb. 08), and download here the comments on the Working Plan (May 2008).
Finally, ECOS also sometimes comments draft chapters of the preparatory studies. For each of the studies, ECOS recruits technical experts to monitor the work from the consultants and suggest input. We are currently involved in a dozen of lots. Our call for experts are published in the News section. If you are interested in the Environmental NGOs' views on a specific on-going study, please contact ECOS.