Our position papers

Environmental NGOs (ECOS, EEB, Friends of the Earth, WWF, INFORSE, CAN, etc.) are issuing regular position papers to comment the Ecodesign and Energy Labelling proposals from the European Commission.

Our position papers in response to regulatory proposals from the European Commission are available below, ranked in chronological order.
At the bottom of the page you will also find our positions on the instruments/revision of the Ecodesign & Energy Labelling directives, and our more technical contributions to preparatory studies. 
Please note that most of these position papers relate to specific Working Documents or study chapter at a specific date before a consultation phase. Reading the related documents helps following our arguments. To check where the policy process stands for the different product groups, please visit this page.

Position on the content of Ecodesign & Energy Labelling measures

September 2011 - Network standby modes
- ECOS position paper
- Latest draft from the European Commission

September 2011 - Advanced proposal for Vacuum cleaners
- ECOS position paper
- Latest drafts from the European Commission

July 2011 - Advanced proposal for Water pumps
- ECOS position paper
- Latest draft from the European Commission

July 2011 - Directional lamps and luminaires
- Environmental NGO position paper
- Latest working documents from the European Commission

May 2011 - Final drafts for boilers
- Environmental NGO position paper
- Latest working documents from the European Commission

March 2011 - Position on voluntary initiatives in Ecodesign
- Environmental NGO position paper on voluntary agreements
- Context of the endorsement of the first voluntary initiatives under Ecodesign

Sept 2010 - Tertiary lighting: luminaires (Lot 9)
- Joint position paper from ECOS and ECEEE
- Related Working document from the European Commission

Sept. 2010 - Water heaters (Lot 2)
- Position paper from Environmental NGOs
- Related finalised Working documents from the European Commission

June 2010 - Household tumble driers (Lot 16)
- Position paper from Environmental NGOs
- Related Working document from the European Commission

June 2010 - Vacuum cleaners (Lot 17)
- Position paper from Environmental NGOs
- Related Working document from the European Commission

April 2010 - Domestic air-conditioners (Lot 10)
- comments from Environmental NGOs on the revised draft Ecodesign and Energy Labelling measures for air-conditioners and comfort fans
- Related Working document from the European Commission
- Initial position paper from Environmental NGOs for this product group (June 2009)

April 2010 - Commercial refrigeration (Lot 12)
- Opinion from Environmental NGOs on the approach for setting Ecodesign rules for display cabinets and vending machines: click here.
- Related Working document from the European Commission highlighting options for this product category

March 2010 - Household washing machines & dishwashers (Lot 14)
- comments from Environmental NGOs on the revised draft measures for the Ecodesign and Energy Labelling of washing machines and dishwashers
- Related Working documents from the European Commission
- Initial position paper from Environmental NGOs for this product group (December 2008)

March 2010 - Non-residential fans (Lot 11)
- comments from ECOS on the finalised Ecodesign rules for fans (24 March)
- previous position paper from ECOS (including more details - February 2010)
- Related Working Document from the European Commission
- Initial position paper from Environmental NGOs for this product group (May 2008)

March 2010 - Energy labelling of televisions (Lot 5)
- comments from Environmental NGOs
- Related Working document from the European Commission

February 2010 - Non-residential fans (Lot 11)
- 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

2009 & 2010 - Finalisation of the methodology for boilers (Lot 1)
- First technical contribution from ECOS and INFORSE
- Second technical contribution from ECOS and INFORSE

October 2009 - Computers and monitors (Lot 3)
- additional comments from Environmental NGOs on revised versions of the working documents (from 2 Dec. 2009)
- Initial position paper from ECOS and Environmental NGOs
- Related working documents from the Commission: computers, displays

October 2009 - Complex Set top boxes (Lot 18)
- Position paper from ECOS and Environmental NGOs
- Voluntary initiative proposed by the industry to replace a mandatory regulation: Content and discussion paper

October 2009 - Imaging equipment (Lot 4)
- Position paper from ECOS and Environmental NGOs
- Voluntary initiative proposed by the industry to replace a mandatory regulation: Content and discussion paper

June 2009 - Boilers (Lot 1)
- Position paper from ECOS and Environmental NGOs
- Related Working documents from the European Commission: Ecodesign and methodology, Energy labelling.

June 2009 - Air-conditioners & ventilation (Lot 10)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: air-conditioners, air-coolers & comfort fans

March 2009 - Additional comments to policy-makers on TVs, fridges, washing machines, dishwashers, motors, circulators
- Position paper from ECOS before votes by Member States

December 2008 - Fridges, washing machines & dishwashers (Lot 13-14) consultation meeting of December 2008
- Position paper from ECOS and Environmental NGOs
- Related Working documents from the European Commission: fridges, washing machines, dishwashers

October 2008 - Televisions (Lot 5)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: televisions

July 2008 - Water heaters (Lot 2)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: 3rd version

May 2008 - Motors, circulators & pumps (Lot 11)
- Position paper from ECOS and Environmental NGOs
- Related Working documents from the European Commission: motors, pumps, circulators

March 2008 - Domestic lightbulbs (Lot 19)
- Position paper from ECOS and Environmental NGOs
- Related Working documents from the European Commission: introduction, requirements, labelling 

February 2008 - Boilers & water heaters (Lot 1-2)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: 1st version

February 2008 - Power supplies (Lot 7)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: power supplies

February 2008 - Simple set top boxes (TV decoders)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: set top boxes; summary of the preparatory study by ECOS

December 2007 - Office lighting (Lot 8)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: office lamps, ballasts and luminaires

October 2007 - Standby & off-mode losses (Lot 6)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: simple standby modes

May 2007 - Street lighting (Lot 9)
- Position paper from ECOS and Environmental NGOs
- Related Working document from the European Commission: street lamps

Position on the policy instruments and their revision

September 2011 - Study to prepare the 2nd Ecodesign Working Plan (2012-2014)
- ECOS final comments on the study (Sept. 2011)
- ECOS comments on the draft Tasks 1-2-3 of the study

October 2011 - Study on the evaluation of the Ecodesign directive
- ECOS comments on the draft study (October 2011)
- ECOS response to the 1st evaluation questionnaire

March 2011 - Study for the revision of the MEEuP methodology
- ECOS answer to the 1st questionnaire on the methodology

2008 & 2009 - Debate on the revision of the Energy Labelling directive
- Position of NGOs 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)

2008- Preparation of the 1st Ecodesign Working Plan (2009-2011) and preparatory study for this plan (this document sets the product categories to be covered by the Ecodesign policy).
-  download here the comments from ECOS on the preparatory study (Feb. 08),
- download here the comments on the Working Plan itself (May 2008).

Latest contributions to technical Preparatory studies

Preparatory studies on cooking appliances: ovens (22)
- ECOS input on tasks 6&7
- ECOS input on first tasks

Preparatory studies on cooking appliances: hobs, grills (23)
- ECOS input on tasks 6&7
- ECOS input on first tasks

Preparatory study on coffee machines (25)
- comments from Topten Europe (supported by ECOS)
- ECOS input (on the first tasks)

Preparatory study on networked standby (26)
- ECOS initial input
- ECOS final comments (on task 8)

Preparatory study on commercial refrigeration (ENTR 01)
- ECOS input

Preparatory study on transformers (ENTR 02)
- CLASP input (supported by ECOS)

Preparatory study on sound & image equipment (ENTR 03)
- summary of ECOS input
- final ECOS input

Preparatory study on Machine tools (ENTR 05)
- ECOS input on tasks 1,2,3
- ECOS input on tasks 4,5

Prep. study on solid fuel small combustion (15)
- several ECOS-INFORSE contributions available (upon request)

Prep. study on directional lighting (19)
- Final ECOS input
- First ECOS input

Prep. study on air-conditioners (10)
- ECOS final input