Towards a systems approach in Ecodesign and Energy Labelling: How to make the political ambition a reality?

It is widely recognised that there are substantial additional energy savings to be made from taking a system approach – considering how products are combined and operate together. Despite this savings potential, political ambition has not yet resulted in regulation.

During this workshop, policy makers and key stakeholders discussed implementation barriers and explored possible remedies. Fiona Brocklehurst presented the findings of a research study on the past experiences with developing system related regulations in the ecodesign and energy labelling framework. Policy makers were invited to present their views on the topic. A case study on pump systems showed what a systems approach to energy efficiency can bring in practice. During a lively debate, stakeholders shared their experiences, questions and ideas.


  • Fiona Brocklehurst, Ballarat Consulting
    A review of systems approaches in Ecodesign and Energy Labelling
  • Hans-Paul Siderius, Netherlands Enterprise Agency
    Transforming product efficiency policy into system efficiency policy
  • Ronald Piers de Raveschoot, European Commission DG ENER.B3
    Views from the EU Commission
  • Michael Könen, Europump
    Case study: Pump systems
  • Diedert Debusscher, European Copper Institute

Take-away messages

  • We need to develop the synergies between the different regulatory frameworks.
  • We should not start immediately to regulate the most complicated system. Let’s start with those systems  that are the easiest to regulate and proceed step by step.
  • Indeed, by starting with a few domains where regulation is relatively simple, such as the one on pump systems, we can learn by experience.
  • We need to improve data exchange and ensure co-ordination between the different stakeholders that are involved in the assembly of energy using systems.



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Definition of the system and its boundaries

Q1. Is the installation the right way to differentiate individual products from a system? When I am connecting loudspeakers to a screen at home, am I installing “a system”?

Answer: One possible terminology is to differentiate between “assembly” and “installation”. Connecting your loudspeakers to your screen would be an installation, but once you have to call in the help of a professional, it would be “an assembly”. Systems energy efficiency regulation would apply to a combination of products that are assembled, not just installed. But the distinction is definitely not black and white; there is a grey area in between.

Q2. How to set the boundary of the system?

Answer: System boundaries are a matter of choice. They must be defined in the scope of the regulatory measure, preferably in such a way that the required effort is balanced with the potential gain. The wider the boundaries are drawn, the greater the potential energy savings, but the systems approach also becomes more complex.

Q3. There are systems in a wide range of scale. How can we guarantee the proportionality of ecodesign requirements for suppliers and installers? Maybe we should have a sliding scale, indicating how the regulatory burden can increase with the scale of the installation? Does anything like that exist?

Answer: It is unknown whether such an approach exists, apart from ecodesign requirements being dependent on the size or capacity of the product.

Q4. Is it a necessary condition for a regulation at systems level to have product regulations in force for all of the components involved in the system?

Answer: Not always. But in some cases, verification of system efficiency may depend on testing components that are part of the system. The results of these component tests are subsequently entered into a model for calculating the system efficiency. To ensure the correctness of the input data, setting ecodesign requirements for the components can be useful. Such requirements can also simply help to improve the energy efficiency of the ‘bricks’ that constitute the system. And in some cases, design requirements at component level can ensure qualities such as inter-operability, sensor accurateness, or usability, which have an impact on the system efficiency. And even if regulation at system level alone would manage to harvest the entire energy savings potential, this does not always mean that regulation at component level becomes superfluous, because components may also be used as stand-alone or in other, non-regulated systems.

The savings potential

Q5. There seems to be no doubt that there is a big additional energy savings potential situated in a system approach compared to a product approach, but I still think that we need to obtain a better view on this. The question is: where exactly is this potential situated? I suspect that a major part of the potential lies in the sizing of devices, and this is out of reach for the Ecodesign framework.

Answer: Not necessarily. Optimizing the sizing of devices according to the load profile is one of the measures investigated in a few Ecodesign preparatory studies (cables, pumps…).

Before and after the assembly of the system

Q6. Products can be compared by the buyer before the moment of purchase, hence the usefulness of energy labels. But systems are usually bought before they are assembled… How to assign energy labels and communicate them to the consumer before the purchase of the system? For example, a PV-system label should provide the potential buyer with accurate information about the performance of the future system which is yet to be assembled…


  • A potential solution is provided by the Preparatory Study for PV systems. It proposes to communicate the energy label with any offer provided to the customer. If it is just a voluntary initiative, it may take some time before installers are fully up to date. Maybe the inclusion of labels in the offer should be made mandatory.
  • But how to assign those labels? One option is to verify ecodesign compliance of the individual components, to verify as well the local conditions (location, inclination etc), and then to assess whether the combination of components and conditions meets the system requirements. Testing the assembled system in situ after assembly becomes less crucial with such an approach. The most important point is that all the individual components are compliant, and that the system design proposed in the offer is adapted to the expected circumstances of the installation.

Q7. How about the necessary post-installation fine-tuning of a system’s energy performance? The use of BACS (building automation and control systems) could be key in facilitating this.

Answer: If such fine-tuning is relevant, it should be incorporated in the scope of the regulation.

Compliance and market surveillance

Q8. Could a commissioning report provided by the installer be used by Member State Authorities (MSAs) to verify compliance?

Answer: Yes, a commissioning report written according to well-defined criteria could have the same value as a test report from a product manufacturer: it is a piece of evidence the MSA will take into account during the verification process. The MSA may either decide it is sufficient, or require further investigation, such as a laboratory test for a product, or an inspection in-situ for a system. The decision to make such an inspection can be made either randomly, or based on the findings of the initial evaluation.

Q9. Concerning the legal issues with in situ market surveillance in certain member states: what about health and safety regulations and inspections, how did they overcome these issues?

Answer: I don’t know the details, but health and safety still has higher priority than energy efficiency for certain Market Surveillance Authorities (MSAs).

Ecodesign and EPBD

Q10. Concerning energy using products and systems installed in buildings, a long-term co-operation between Ecodesign and EPBD – both at directive and at regulatory level – is probably the only way to completely capture the energy savings potential. Shouldn’t the Ecodesign and EPBD align their regulations with each other in a better way, to clearly define which process will do what, and to avoid missing out on significant savings potential?


  • Absolutely. There is certainly an awareness about that. The BACS preparatory study – on how BACS could improve the performance of buildings – tackles this as well. The Consultation Forum meeting on this study will be held in October. An electronic energy label is one of the elements that could help with aligning Ecodesign and EPBD (see further).
  • The Energy Performance of Buildings (EPB) standards are the missing link between products (regulated by Ecodesign), functional systems (whether or not regulated by Ecodesign), and the building as an overall system. In a new revision of these standards, experts are currently focussing on how to link product data with data of functional systems and of the entire building, in light of energy performance requirements.

Digital solutions (digital product passport, digital energy label, digital building logbook, European product database…)

Q11. Could a digital energy label be solution?

Answer: If we can make the energy label electronic, it becomes easier to vary the outcome depending on the location. For example, it can be linked to an application in which you can enter product characteristics and local conditions, to receive the resulting energy label in return. Such an electronic energy label could also help to align Ecodesign regulation with EPBD.

Q12. Energy Performance of Buildings (EPB) calculations need product input data, and so do ecodesign requirements for functional systems in buildings. It would be of great help if these data (e.g. thermal conductivity of insulation materials) could be made available in a pan-European database (e.g. an extension of EPREL).

Answer: Indeed, but we should be careful not to go for the creation of a monster before we can even start to regulate.

Energy consuming systems, smart systems and demand side management (DSM)

Q13. Would you consider the electricity distribution network and the transmission network as part of the system as well? If not, Demand Response would be excluded.

Answer: It all depends on what is meant by “the system”. Every product (or system) operates in an environment that is made up of other products and systems. If for a certain aspect of a product/system, the distribution or transmission network is a relevant “surrounding” system, then it should be taken into account.

Q14. Future buildings will be complex systems in which energy use will have to be balanced with the ability to offer grid flexibility, for example through space and water heating buffer capacity, energy storage, and smart EV battery charging. Shouldn’t product regulations focus more on connectivity, intelligence and interoperability of devices rather than just energy efficiency, to prepare for this future?


  • Indeed, we should think about the link between product regulation and the broader perspective in which the product will be functioning.
  • Regulation that enables a system approach can serve this goal. Think about measures such as mandatory information about the load profile, or the inclusion of sensors and communication technology.

Pump systems

Q15. A lot of investigations seem to have been done already on the potential regulation of pump systems. Is there a high additional savings potential in this domain?

Answer: The preparatory study showed that there is a substantial savings potential from a combination of an extended product approach with differentiation according to the local conditions (load profile). That said, market surveillance issues pose a serious barrier for regulation.

Ecodesign and codes of conduct

Q16. How could ecodesign address codes of conduct for design and installation? There must be precedents for this with building related systems. What can be learnt?

Answer: Codes of conduct are voluntary, which means that they cannot be used within Ecodesign regulation. But they can certainly be used as an inspiration for regulation at system’s level.

Systems and standards

Q17. A question to Hans-Paul Siderius: what do you mean by “the regulatory standardisation of the system”?

Answer: With “regulatory standardisation” I mean the rules that standardize the assembly of a system.

The view of the European Commission

Q18. Can you give a better view on the actual postion of the European Commission on the topic?

Answer: Our main focus today is the Sustainable Product Initiative (SPI). It aims at extending Ecodesign from energy related products to any kind of products, incorporating various kind of sustainability requirements. In any case, we want to give more tools to Ecodesign to tackle material efficiency and circularity. A systems approach is currently not investigated by the SPI. The major challenge for a systems approach lies outside the jurisdiction of the Ecodesign regulatory framework, more precisely with the market surveillance authorities.

Additional information