UK: More White Goods Come Under Ecodesign Rules

Last Updated: 22 November 2010
Article by Paul Sheridan and Valentina Keys

On the 10th November 2010 minimum levels of energy efficiency have been set for household washing machines and dishwashers pursuant to two EU Regulations under the Ecodesign Directive 2009/125/EC for energy-related products. Manufacturers, importers and retailers must factor in these eco-design requirements into their new products and communicate this information to their suppliers.


In 2005 the Ecodesign Directive (the "EuP Directive") established a framework for the setting of ecodesign requirements for energy using products. Nine implementing measures (via EU Regulations) were implemented under this Directive relating to standby and off mode power consumption, simple set top boxes, battery chargers or external power supplies, general lighting, tertiary lighting, electric motors (1-150KW), televisions, circulators and refrigerators. The minimum standards of energy efficiency for the above product groups have to be implemented in stages and different timelines apply through to 2016.

On 20th November 2009 the EuP Directive was repealed and replaced by a broader Directive establishing a framework for the setting of ecodesign requirements for energy related products. This second directive is commonly referred to as the "ERP Directive" and we have written about this in earlier LawNows. The two most recent EU Regulations (see below) are the first implementing measures under the ERP Directive.

What are implementing measures?

The ERP Directive is also a framework Directive. It does not directly introduce obligations on business. Instead it provides a legal framework for establishing minimum ecodesign requirements for energy-related products by defining conditions and criteria for the setting of such requirements and these requirements are then implemented in subsequent EU Regulations. It is the EU Regulations that are binding on business and because they are EU Regulations rather than Directives, they are binding directly on business without the need for implementing domestic legislation (although domestic legislation is often also brought in to help determine how the EU Regulations apply).

The implementing EU Regulations are targeted at individual product groups (washing machines and dishwashers in this case) or a specific function of energy related goods (e.g. standby and off mode).

New implementing measures

There are two. EU Regulation (EC) 1015/2010 (household washing machines) and EU Regulation (EC) 1016/2010 (household dishwashers). These set minimum ecodesign standards which manufacturers must meet with a view to reducing energy and water consumption during use. The ecodesign requirements are divided into "generic" and "specific" requirements (Annex I).

Note the reference to water consumption. This is an example of how ecodesign has been broadened from energy using products to energy related products. The volume of water used by such white goods has an impact on the energy consumed.

Below is a timeline of when specific obligations will come into force.

Household Washing machines - timetable

From 1 June 2011 the booklet of instructions provided by manufacturers will have to contain the following information:

(a) it must specify that the standard 60°C and 40°C cotton programmes are the most efficient programmes in terms of combined energy and water consumption;

(b) the power consumption of the "off-mode" and of the "left-on" mode;

(c) indicative information on the programme time, remaining moisture content, energy and water consumption for the main wash programmes at full or partial load, or both;

(d) recommendation on the type of detergents suitable for the various washing temperatures.

From 1 December 2012 the cycles for 60°C and 40°C cotton programmes will have to be clearly identifiable on the programme selection device of the washing machines or the washing machines' displays.

From 1 December 2013 all household washing machines placed on the EU market will have to offer to end-users a cycle at 20°C.

Household Dishwashers - timetable

From 1 December 2012 dishwashers will have to work on the basis of one single "cycle" (i.e. the complete cleaning, rinsing and drying process) which will have to be set and displayed as a 'standard programme'.

From 1 June 2012 the booklet of instructions provided by manufacturers will have to contain the following information:

(a) the standard cleaning cycle (referred to as 'standard programme') and this must specify that this is the most efficient programme in terms of energy and water consumption;

(b) the power consumption of the off-mode and left-on mode.

(c) indicative information on the programme time, energy and water consumption for the main cleaning programmes.

From 1 December 2013 and 1 December 2016 additional technical requirements will also need to be met. These are set out in Annex II which refers to Energy, Cleaning and Drying Efficiency Indexes.

Household combined washer-dryers are excluded for now but the EU Commission states that these will be addressed "as soon as possible".


Following the implementation dates it will be an offence for a person (be it a manufacturer, an importer or retailer) to place, or put into service, on the Community market products that are not compliant with the particular ecodesign requirements. This compliance must be evidenced in technical documentation files. The key obligation placed on manufacturers, importers, retailers and 'authorised representatives' i.e. persons authorised by manufacturers to comply with the relevant product requirements forms part of each of the ten relevant EU Regulations, provisions of which implement the requirements of Article 8 of the ERP Directive to carry out a "conformity assessment" of their products. The method of "conformity assessments" varies depending on the product or product group and on the specific ecodesign requirements which are prescribed by the particular implementing EU Regulation.

In the UK the competent authority for compliance is the National Measurement Office. Criminal sanctions may apply along with the new UK civil sanctions (including variable monetary penalties) which are being introduced.

This article was written for Law-Now, CMS Cameron McKenna's free online information service. To register for Law-Now, please go to

Law-Now information is for general purposes and guidance only. The information and opinions expressed in all Law-Now articles are not necessarily comprehensive and do not purport to give professional or legal advice. All Law-Now information relates to circumstances prevailing at the date of its original publication and may not have been updated to reflect subsequent developments.

The original publication date for this article was 22/11/2010.

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