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March 14, 2018

Lifts and the Eco-design Directive

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In order to reach the objectives of its environmental policy, the EU adopted a series of legislative acts with the goal of improving energy efficiency and reducing the environmental impact of buildings and industrial products. Among these acts, we mention the Regulation (EU) 2017/1369 on energy labelling and the Directives 2012/27/EU on energy efficiency, 2010/31/EU on the energy performance of buildings (EPBD) and 2009/125/EC on the eco-design requirements for energy-related products, more commonly known as the Eco-design Directive.

For the time being, lifts are not included in the scope of the legislations mentioned above[1]. Indeed, they are explicitly excluded from the scope of the Regulation 2017/1369 on energy labelling – whereas n°4 recites: “[..] As the energy consumption of means of transport for persons or goods is directly and indirectly regulated by other Union law and policies, it is appropriate to continue to exempt them from the scope of this Regulation, including means of transport with a motor that stays in the same location during operation, such as elevators, escalators and conveyor belts”. However, lifts have been included in the product list of the Working Plan 2016-2019 of the Eco-design Directive. This list consists of products for which it has been estimated a relevant potential in terms of energy saving and environmental impact. The inclusion of a product in the list of the Working Plan leads to the launch by the European Commission of a preparatory study aimed at the verification of the concrete possibility to reach an improvement in the environmental impact of the product, including the relevant aspects of the circular economy (reparability, life cycle duration, reuse and recycle, etc.).

The EC awarded the preparatory study for lifts to a consortium led by the Fraunhofer ISI, a German research institute for energy technologies. The study needs to provide an analysis of the relevant technical, environmental and economic aspects related to the lift sector; consequently, the EC will be able to execute an impact assessment that will allow deciding, after the consultations with the stakeholders, whether to widen the scope of the Eco-Design Directive to lifts. In case the scope will be widened, the EC can decide to approve either an implementing measure, in which it fixes the specifications for the eco-design for lifts (in line with the Annexes I and/or II of the Directive), or a self-regulation measure proposed by the industry and elaborated in accordance with the Annex VIII of the Directive.

The preparatory study on lifts has started in the second half of 2017 and will last two years, according to a pre-established scheme. During this two-year period, the consortium foresees three stakeholder meetings, one of which took place on February 21st, 2018, in Brussels at the EC DG GROW venues. The study consists of seven tasks: the tasks one, two and three, whose draft reports have been presented and discussed during the meeting, focuses respectively on the scope of the study, the market and the users.

According to the report presented during the meeting, the scope would coincide with the one of the Lifts Directive 2014/33/EU; as a consequence, lifting platforms and homelifts would be excluded. In this regard, EFESME raised the attention on the fact that it has to be carefully considered whether to include in the study and, therefore, in the possible, future implementing or self-regulation measures, the homelifts. Their exclusion could probably alter competition in the market of low-rise buildings (up to three or four stops). EFESME and the other stakeholders raised further points also during the discussions of the tasks “Market” and “Users”. All documentation, including the minutes of the meeting, is available on the webpage of the study.

As a principle, from the lift SME point of view, it would be preferable that lifts would not be subject to any European energy or environmental legislation. The extension of the scope of the Eco-desing Directive to lifts would inevitably lead to a supplementary economic burden to be added to those ones necessary to comply with the already existing legislative obligations deriving from the Lifts, Machineries and Electromagnetic Compatibility Directives. However, the common and widespread need to reduce the energy consumptions and the environmental impact also in our sector pushes inevitably towards a sort of regulation on the mid-long term also for lifts, which have a relevant impact, especially in some particular cases, in terms of energy consumption. SBS commits, with the support of EFESME, to supervise that the obligations for the lift sector will not be too onerous, but proportionate to the energy savings that can be achieved with a reasonable value for money. Moreover, the two organisations will verify that the all measures foresee a reduced impact on SMEs, as established in the EU legislation.

[1] Some Member States, in particular Portugal, Denmark and Italy, voluntarily included in their national implementation of the EPBD Directive some requirements related to the energy consumption of lifts.

 

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