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The European Commission DG GROW (Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs) had entered a contract with Viegand Maagøe, VHK and Oeko-Institut to conduct a preparatory study to inform and assist the Commission in preparing the Ecodesign and Energy Labelling Working Plan 2020-2024 as part of the implementation of the Ecodesign Directive 2009/125/EC and Energy Labelling Regulation (EU) 2017/1369.

The study started in March 2020 and finished by mid-May 2021.

Formally, this is the first combined Ecodesign and Energy Labelling Working Plan to be undertaken, following the changes contained in the Energy Labelling Regulation (EU) 2017/1369 (Article 15). However, it should be noted that previous Ecodesign Working Plans informally always kept in mind the possibility of combining Ecodesign and Energy Labelling, where judged appropriate on a product-by-product basis. 

The Working Plan study was the first step in a process aiming at publishing implementing measures and acts in the Official Journal. See below a brief overview of the process.

Overview of the ecodesign and the energy labelling regulatory processes

Sustainable development, resource efficiency, circular economy and competitiveness comprise very important policy priorities for the long-term EU strategy “Clean Planet for All in 2050” and mid-term 2030 Energy Strategy. In this respect, one of the primary objectives of the European Commission is to promote the greater integration of product-related policies to attain enhanced long-term sustainability and competitiveness in the EU.

This is especially the case, given that many of the products potentially under consideration will be designed and manufactured from 2030 onwards, following new or revised Ecodesign and Energy Labelling requirements possibly to be made during the period 2020-2024, or thereafter. These products will be used, maintained, repaired and possibly upgraded during the period running up to 2050, and thus will make a key contribution to the above-mentioned 2050 strategy.  

The Ecodesign Directive 2009/125/EC, together with the Energy Labelling Regulation (EU) 2017/1369, are fundamental building blocks in moving towards an optimal use of energy resources and circular economy models. Moving towards a more circular economy implies achieving even better environmental performance, higher energy and material efficiency and lower environmental externalities of products in the internal market. Together, the transparent future-oriented framework of EU-wide ecodesign minimum requirements and energy labelling for energy-related products ensures the free movement of those better-performing products within the internal market. 

The above framework reinforces the EU’s competitiveness, since many companies involved in the supply and value chains of product and services in the EU – especially from a numerical and EU GDP contribution perspective – comprise Small and Medium-sized Enterprises (SMEs), as well as larger companies. These SMEs utilise the very same Energy-related Products (ErP), which are regulated via Ecodesign and Energy Labelling regulations, and are able to make savings on their utilities (primarily energy, water and IT infrastructure) bills via the use of such improved products. 

The above SMEs – together with larger enterprises – are also often involved in the value chains of producing the same regulated ErP goods, resulting in commercial and innovation benefits at regional, Member State and EU-wide levels, as well as in enhanced exports revenues derived from enhanced international sales of cutting edge products, engendered by ecodesign and energy labelling measures.



  1. Develop the approach for identification and prioritisation of products for the working plan with a view to better take into account environmental impacts in all life-cycle stages and circular economy aspects such as products durability, reparability, recyclability and/or recycled content. Product groups assessed are:

    • Products in previous Ecodesign Working Plans and related studies indicated as potential targets for Ecodesign and/or Energy Labelling measures, but for which no measures have resulted to date​.

    • Regulated products with potential for increased circular economy related requirements

    • Complex products i.e. combined products in one product

    • Products with interactive and interoperable IT solutions such as interconnected products with interactions or automations resulting in an environmental improvement 

    • Horizontal innovative solutions for improved market surveillance for existing products releasing a further potential

    • Energy-related products i.e. products not consuming energy but influencing the energy consumption of the system it is related to

    • New product groups not yet studied including the ICT products and systems.

  2. Analyse the product groups and initiatives regarding sales, stock, resource consumption, improvement potential, environmental impacts, regulatory coverage and feasibilty, market surveillance impact and industrial competitiveness.

  3. Inform and assist the European Commission in its decision-making process to compile the Ecodesign and Energy Labelling Working Plan 2020-2024 with a strong and transparent evidence base derived from scrutinising regulations and available studies, together with a thorough consultation process of relevant stakeholders.


The study was performed through the following four tasks.


The task establishes the background and the methodology through assessment of relevant sources and policies and launches the stakeholder contact and consultations, which includes establishment of the study website.


The task provides lists of potential product groups and horizontal initiatives through screening and assessment techniques. The lists will be the basis for the analysis work in the following tasks.


The task performs the first analysis of the product groups and initiatives identified in Task 2 in terms of sales, trade and stock, resource consumption, the technical-economic improvement potential and a check of whether the results indicate that the product or initiative is within the scope of the Ecodesign Directive and the Energy Labelling Regulation and if not, the product or initiative will not be analysed in Task 4.  

Based on the results in Task 3, Task 4 will perform complementary analyses of the product groups to provide a more holistic picture of the products when including other environmental impacts; a view on existing regulations for same products; market surveillance impact; and industrial competitiveness. 

The results of Task 4 will be fiches and matrices with data and information covering the products assessed in the study facilitating the Commission’s decision-making process for the final Ecodesign and Energy Labelling Working Plan 2020-2024.



The table shows the overall timeline for the activities. 

Policy background

Below we present the policy background for the Ecodesign and Energy Labelling Regulation in the form of the Ecodesign Directive and the Energy Labelling Regulation. Further below we present briefly the Circular Economy Action Plan because circular economy aspects are emphasized in the study objectives. 

The Ecodesign Directive of 21 October 2009 is a framework directive, which establishes EU-wide implementing measures for improving the environmental performance of products, such as household appliances, ICT products (Information and Communication Technologies) and electric motors, when they are placed or put into service on the EU market. Being a framework directive, it provides for the setting of requirements, which the energy-related products covered by implementing measures – adopted separately – must fulfil in order to be placed on the market or put into service. An alternative is a self-regulation measure most often in the form of an industry voluntary agreement e.g. for imaging equipment (copy, print and scanner equipment). 

The directive is a recast of the previous directive, Directive 2005/32/EC, where one important amendment was the change of overall scope from energy using to energy-related products. 

Implementing measures and self-regulation are drafted on the basis of a preparatory study and revised on the basis of a review study following the Methodology for the Ecodesign of Energy-related Products (MEErP). MEErP is expected to be reviewed and updated in the near future. 

Article 16 of the Ecodesign Directive lays down the requirement that the Commission establishes a working plan that shall be amended periodically by the Commission after consultation with the Consultation Forum. Three working plans have been communicated to date (2009-2011, 2012-2014, 2016-2019). The current working plan preparatory study is launched to provide the basis for the fourth working plan.
The Energy Labelling Regulation of 4 July 2017 is a framework regulation in line with the Ecodesign Directive establishing the general framework for implementing EU energy labelling in EU. It replaces the former Energy Labelling Directive 2010/30/EU. The energy labelling regulation has maintained the same scope as the previous directive, but some of the provisions are modified and enhanced in order to improve the effectiveness of the scheme. 

One of the new elements in the framework energy labelling regulation is that it lays down an obligation on the Commission to establish and make periodically updates of a long-term working plan (Article 15). The working plan must in line with the ecodesign working plan set out an indicative list of product groups which are considered priorities for the adaption of delegated acts. The working plan shall also set out plans for the revision and rescaling of labels for product groups with the exception of the rescaling of labels, which were in force at 1 August 2017, for which the rescaling is provided for in Article 11 of the Regulation. 

The working plan should be reviewed every three years and the Commission may choose to combine the working plan with the working plan that should be established in accordance with Article 16 of the Ecodesign Directive. This is why the Commission has launched a combined study for ecodesign and energy labelling. 

There is to large extent synergy between the ecodesign and energy labelling frameworks. While the ecodesign addresses the supply side and pushes the market towards higher energy and resource efficiency, the energy labelling addresses the demand side and pulls the market to even higher levels of efficiencies. The combined effects ensure dynamic improvements of the market. In this respect it also makes sense to elaborate a common working plan for both ecodesign and energy labelling.   

Other important improvements in the energy labelling framework regulation are:

  • the provisions for rescaling of the label to the A-G scale at the same time taking into account the speed of the technological progress and ensuring that the top class(es) is empty in newly rescaled labels 

  • establishment of the product registration database, which is a useful tool for consumers, dealers, market surveillance authorities, and for the regulatory process on revision of labels


A new Circular Economy Action Plan was announced by the Commission in March 2020, which is one of the main building blocks of the European Green Deal. It builds on the work done since 2015 following the First Circular Economy Action Plan. A website has been established by the Commission containing relevant information and links related to the new Action Plan. The information below summarises briefly the main areas of the action plan relevant for the working plan study though not all of the areas are in scope of the study.

The new plan focuses on the design and production for a circular economy, with the aim to ensure that the resources used are kept in the EU economy for as long as possible. The new Circular Economy Action Plan presents measures to:

  • Make sustainable products the norm in the EU;

  • Empower consumers and public buyers;

  • Focus on the sectors that use most resources and where the potential for circularity is high such as: electronics and ICT; batteries and vehicles; packaging; plastics; textiles; construction and buildings; food; water and nutrients;

  • Ensure less waste;

  • Make circularity work for people, regions and cities,

  • Lead global efforts on circular economy.

As part of the action plan the Commission will increase the effectiveness of the current ecodesign framework for energy-related products, including by swiftly adopting and implementing a new Ecodesign and Energy Labelling Working Plan 2020-2024 for individual product groups, i.e. based on the current Working Plan study. 

For electronics and IT, the Commission will present a ‘Circular Electronics Initiative’, which will promote longer product lifetimes and include, among others, regulatory measures for electronics and ICT including mobile phones, tablets and laptops under the Ecodesign Directive so that devices are designed for energy efficiency and durability, reparability, upgradability, maintenance, reuse and recycling. The plan states that the Ecodesign Working Plan 2020-2024 will set out further details on this and emphases that printers and consumables such as cartridges will also be covered unless the sector reaches an ambitious voluntary agreement by September 2020.

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