Household appliance manufacturers1 acknowledge that the recently published Energy Efficiency Plan (EEP) identifies the correct challenges the Union is facing, and the in-principle huge potential residing in energy efficiency policies. However, they express deep concern that the plan will most likely not succeed as the coherent, compelling driver to accelerate policy deployment, which is needed.

The Plan acknowledges that, in view of the latest legislative and practical developments, the EU will not meet its energy savings target by 2020. The expected benefits of a promising 2006 energy efficiency action plan and of the 2008 Climate and Energy Package are not expected to be reaped either.

A change of direction is needed now

The Plan calls for the Commission to propose mandatory targets in 2013 in case the assessment confirms that the overall EU target is unlikely to be achieved. In order to work in this direction, it mainly proposes to revise the Energy Service Directive.
We ask for the Energy Services Directive (ESD) to become more ambitious and common methodologies to be developed to assess the progress made. The revised ESD will not lead to any effect before 2013. We fear that it will be unable to later recover the time and emissions that will be the effect of the delayed start.

Consequently, we express doubts about the actual impacts of the approved EEP, if any, in reality.

Our industry has highlighted the following areas of concerns in the Energy Efficiency Plan:

− Leadership
Poor EU leadership coupled with unnecessary delays to take robust decisions.

− Prioritization
Lack of prioritization for energy efficiency mirroring empty legislative provisions at EU
level (no clear obligations).

− Barriers to energy efficiency
Persistence of barriers to the developments of energy efficiency markets and insufficient uptake of the most efficient products.

− Funding
Lack of funding to energy efficient solutions.

− Implementation
Risk of threatening implementation of the Ecodesign Directive for energy related products, depowering the potential of the Ecodesign Directive to achieve the 2020 targets.

− Smart grids vision
Poor understanding of the potential of the demand side management by smart grids.

− Mandatory energy management
Administrative and financial burdens combined with implementation concerns for the
proposed mandatory energy management systems.

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