Introduction
1. The Consumer Council welcomes the Government's proposal to introduce mandatory energy efficiency labelling schemes (EELS), so as to provide consumers with information on the energy efficiency of products and to encourage product suppliers to market more energy-efficient products. Considering that refrigerators, room coolers and compact fluorescent lamps account for a substantial percentage of the electricity consumption in the residential sector, the Council supports including these products in the initial phase of the mandatory EELS.
2. The Council believes the mandatory EELS should help to reduce energy consumption and contribute to sustainable development in the long term.
3. The Council considers that more stringent grading thresholds should be applied under the mandatory EELS if the schemes are intended to help consumers differentiate between products of different energy efficiency and make the best choice.
Council Response
Updating and reviewing the scheme criteria and specifications
4. It is observed that under the existing voluntary EELS, of all the room coolers registered (which account for some 80% of room coolers on the market), most of them bear the Grade 1 energy labels. The Council is of the view that largely homogeneous performance as a result of lax grading criteria offers very little assistance to consumers in making purchase decisions. Since technology has been improving, the Council believes that regular updating and reviewing of the standards adopted for the schemes should be conducted to reflect advances and to induce improvement.
5. It is proposed that product models already registered under the voluntary EELS will not need to be re-tested before transferring to the mandatory scheme. The Council is concerned that the criteria of some of the existing schemes might need reviewing and any such reviews should be conducted before the launching of the mandatory EELSs.
6. Other reviews, such as tightening / harmonizing the tolerance of the testing conditions of the schemes and converting from the voluntary "Recognition Type" label to the mandatory "Grading Type" (such as for compact fluorescent lamps), should also be conducted before the launching of the mandatory schemes.
7. The Council agrees that the mandatory EELS will accept testing standards recognized under the voluntary EELS. The Council however suggests that the version of test standards adopted in the scheme should be reviewed periodically to ensure that they are up-to-date.
Updating product information on EMSD's registry
8. The Council supports the proposal that importers or local manufacturers of the registered products will be required to provide the Electrical & Mechanical Services Department (EMSD) with a set of up-to-date product information to ensure that the information at the EMSD's registry is up-to-date. However, updating once every five-year may not be appropriate to reflect the rapidly changing markets, since many products are regularly modified to cope with changed market situation and consumer demand. After five years, a registered model could well have been discontinued and the required updating of information after a long lapse would not provide much benefit. The Council suggests to shorten the update interval to once every three-year.
Surveillance check tests
9. Since the test reports accepted by EMSD for registration purpose will be based on performance of test samples provided or selected by the manufacturers, the Council is concerned whether the products being sold in the market will have similar energy efficiency performance as the test samples. It is suggested that the government should conduct regular check tests to ensure the actual energy performances match their claims.
Publicity
10. The Council suggests the government should publicize the mandatory EELS scheme to make it widely known to the public, using activities such as roadshows or TV announcements, so as to encourage consumers to make use of the EELS energy labels as a guide to choose environmental friendly products.
