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Comments on an Impact Assessment on a potential implementing measure (EcoDesign Directive)

Date

30 Nov 2020

Sections

Energy

Bruxelles/Overseas 30 November 2020 – The electric Handdryer Association (eHA), the official body that represents the global hand dryer industry, shares its key arguments regarding potential legislative measures resulting of the EcoDesign Directive when it comes to energy efficiency aspect and labelling. Certain measures would impose pressure on the SME structured industry leading to false developments.

In October, the ‘Eco-design and energy labelling preparatory study on hand dryers’ final report was published. This prep study recommends certain measures are taken to reach the energy efficiency targets set by the European Commission, such as replacing dryers of category one in new devices.

However, the study failed to include a number of additional factors which are crucial to effectively assess the impact on industry and consumer. These include:

  • Environmental considerations of hand dryers
  • Substitute products (notably paper towels)
  • Consumer behaviour
  • Resulting economic and environmental impact on the electric hand dryer industry
  • Actual expectable energy efficiency gains of potential measures

Reducing GHG emissions is an important goal

eHA welcomes the efforts of the EC in encouraging more products to address climate change and reduce energy usage. GHG emissions and electric warm air hand dryers contribute in several ways towards reaching these targets.

For example, electric hand dryers use significantly less energy than is needed to produce or recycle paper towels. They also avoid indirect environmental consequences, such as the spread of diseases deriving from used paper, reducing further GHG emissions, such as methane from landfills, and reducing water pollution due to the fact that reprocessing fresh water is very energy intensive.

Milagros Garde, Manager at Mediclinics and chair of the eHA Lobbying Committee, comments: “The hand dryer industry has a strong interest in ongoing product improvement and innovation. However, the real costs – especially environmental costs – need to be considered by examining and comparing two completely different systems that serve as substitute products for each other – hand dryers and paper towels.”

 

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