PASOS BÁSICOS EN LA INTERVENCIÓN CON PERSONAS CON

As noted above, the washing machine EES contains five energy efficiency Tiers. If both impeller and drum washing machines are grouped together, Tier 1 and Tier 2 products

0 0.02 0.04 0.06 0.08 0.1 0.12 0.14 0.16 0.18 0.2 4 5 6 7 8 9 En er gy E ffi ci en cy / k W h/ kg Washing Capacity / L Drum Impeller 0 5 10 15 20 25 4 5 6 7 8 9 W at er E ffi ci en cy / L /k g Washing Capacity / L Drum Impeller

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account for more than 85% market share in 2012, while there are almost no Tier 4 and 5 products available as shown in Figure 86.

Figure 86: Distribution of washing machines of all product types by energy efficiency Tier (July 2012)

However, when breaking the market down by product type, as shown in Figure 87, it is clear that all drum machines are currently Tier 1 products, with almost 80% of impeller units ranking at Tier 2, and over 10% at Tier 1.

This situation presents policymakers with a problem because the current energy efficiency Tier definitions are:

• Limiting choice for consumers by not accurately reflecting the spread of product efficiencies in the market place;

• Failing to achieve the goal of only allowing the most efficient products to be ranked in Tiers 1 and 2 (and hence considered “energy efficient products”);

• Failing to motivate manufacturers to increase the efficiency of their products to differentiate from their competitors; and

• Not creating a wide distribution in efficiency of products, thus limiting the opportunities for future revisions of the EES and in particular, the MEPR.

CLASP and Top10 138 Figure 87: Distribution of washing machines of by product type across energy efficiency Tiers

(July 2012)

However, if we examine the actual distribution of declared energy and water efficiencies, we find that there is a wider range of efficiencies of products in the market than currently indicated by the EETs.

Figure 88 shows that although almost all products rank at Tiers 1 or 2, there is still a

reasonable distribution of declared energy efficiency values for drum and impeller washing machines.

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Note that for impeller units the bars include products in 0.002kWh/Kg increments. For example, the 0.01kWh/Kg bar includes products from 0.010 to 0.012 kWh/Kg.

This demonstrates that even if policymakers believe it is not practical to create a

technology-neutral test method and comparable efficiency requirements in the short term, or possible to amend the test method to more accurately reflect actual size of loads washed by consumers, it is still possible to make revisions to the EES based on the current test methodology111.

Such revisions would:

• Remove the very worst performing products of each type from the market;

• Provide consumers with more product differentiation based on comparative efficiency, allowing them to preferentially choose the more efficient units (of a particular type) at the time of purchase.

• Incentivize manufacturers whose products are currently categorized as Tier 4 or 5 to improve their product performance so as not to appear “inferior” in comparison with competitive models.

• Allow policymakers to more appropriately focus other policy support measures on only the most efficient products. For example, approximately 90% of impeller and around 50% of drum machines washing machines currently qualify for subsidy support. The proposed EES revisions would allow policymakers to grant future subsidies or similar policy support to only the most efficient products in the market. Figure 89 combines the average declared product energy efficiency values in Figure 88 with the current EET threshold values in Table 29. It shows that although almost all products rank at Tiers 1 or 2, there is still a reasonable distribution of declared energy efficiency values for drum and impeller washing machines. This demonstrates that even if policymakers believe it is not practical to create a technology-neutral test method and comparable efficiency

requirements in the short term, or possible to amend the test method to more accurately reflect actual size of loads washed by consumers, it is still possible to make revisions to the EES based on the current test methodology.

It is clear from Figure 89 that the declared energy efficiency values are only just achieving the minimum threshold requirements.

A similar story emerges when we examine the distribution of water efficiencies across the current energy efficiency Tiers, as shown in Figure 90. Once again, most products qualify for Tiers 1 or 2, but there is a reasonable distribution of efficiency values.

111 _{During the preparation of this study, proposed revised EES requirements for both water and energy} efficiency have been issued. These are available at:

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Figure 89: Average washing machine energy efficiency declarations in each Tier compared with the threshold value for that Tier (July 2012)

Figure 90: Distribution of declared water efficiency of each product type (July 2012)

Figure 91 combines the average declared water efficiency values Figure 90 with the current EET threshold values in Table 29. Again, it is clear that the vast majority of declared water efficiency values are only just achieving the minimum Tiers 1 and 2 threshold requirements.

141 CLASP and Top10 Figure 91: Average washing machine water efficiency declarations in each energy efficiency

standard Tier, compared with the threshold value for that Tier (July 2012)

* Note the declared averages for Tier 4 products are based on a relatively small number of impeller washing machines found to be in the markets and thus may not be comparable to the averages for Tiers 1 to 3.

The fact that the majority of both energy and water efficiency declarations are only just achieving the minimum Tiers 1 and 2 threshold requirements implies one or more of the following possibilities:

• Manufacturers have very accurate control of the design and production of washing machines and can deliver products that are just at the boundary conditions. If this is the case, any tolerances allowed for MEPR and labeling compliance are not required and can be eliminated, although test laboratory tolerances will still be required.

• Manufacturers are over-reporting the performance of products; for example, declaring the lowest value of the EET Tier above that for which their products qualify, either to appear more efficient on the label and/or to qualify for subsidy support. This may be a perfectly legitimate action if the tolerances of the

declarations are sufficiently high, but again this implies that the tolerances for labeling declarations should be removed.

• Manufacturers are understating the performance of products; for example, declaring the lowest value within the EET Tier for which their products qualify to ensure their products pass any verification testing undertaken by the regulator. On one level, there is no problem with this situation as manufacturers are acting cautiously and protecting their reputations, while delivering products to the consumer that perform better than stated. However this scenario is problematic from the policymaker point of view, as knowledge of the true performance of products is important when developing future EES and subsidy requirements and analyzing the potential impact of differing threshold levels.

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At present there is no evidence to suggest which of the above scenarios may be causing the performance declarations just above EET and subsidy threshold levels, and there is certainly no evidence of manufacturer malpractice. However, there is sufficient evidence to

recommend that policymakers insist that claims made on product registration and labeling mustalign with actual testing reports submitted to support the applications, and these test reports must be from a unit with performance that is representative of typical production units. Once declarations are accurate, further research can then be undertaken to establish whether tolerances (other than those required by test laboratories) may be tightened.

7.4.6 Relationships of washing machine price to technology, rated capacity and