Best products of Europe

Washing Machines & Combined Washer-driers: Policy Recommendations

June 2015, Barbara Josephy, Anette Michel, Eric Bush

1 Summary of Key Policy Recommendations..................................................................2

2 Background......................................................................................................................2

3 EU Regulations for Washing Machines .........................................................................3 3.1 Energy Label ..............................................................................................................3 3.2 Ecodesign Regulation ................................................................................................3 3.3 Regulation on Standby and Off Mode ........................................................................3

4 Test Standard for Washing Machines............................................................................4

5 Market Development of Washing machines..................................................................4 5.1 Stock: 190 Mio Units, Sales: 14 Mio Units (EU-27) ....................................................4 5.2 Rapid evolution: already 44% were A+++ or A++ after one year ...............................4

6 Best Available Technology (BAT) in Europe according to Topten.eu ........................4

7 How Washing Machines reach A+++ .............................................................................6

8 Combined Washer-Driers................................................................................................7 8.1 Low but Increasing Market Share in Europe ..............................................................7 8.2 Out-dated Energy Label and no Ecodesign requirements .........................................7 8.3 Topten.eu: Washer-driers with heat pump .................................................................7

9 Policy Recommendations ...............................................................................................9 9.1 Energy Label ..............................................................................................................9 9.2 Ecodesign Regulation ..............................................................................................10 9.3 Measurements and Calculation Methods .................................................................12 9.4 Active Promotion of Cold Wash (20°C) ....................................................................13

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1 Summary of Key Policy Recommendations Topten welcomes the Commission’s decision to carry out revision studies for washing machines and to improve Energy Label and Ecodesign requirements. Topten’s recommendations are as followed (Details see chapter 9):

• Energy Label o Reclassification of the energy efficiency classes

(BAT 2014: Best EEI is 50% better than the threshold for A+++) o Back to the classification of A – G (instead of A+++ – D) o Top-classes empty at first to account for future innovations o Hot water inlet: yes/no-declaration on the Energy Label o Combined washer-driers: 2 labels – 1 for washing, 1 for drying

• Ecodesign regulation o Washing performance: requirements also for the 20°C cotton programme o Spin-drying efficiency: Introduction of ambitious requirements: A o Rinsing efficiency: Introduction of appropriate requirements o Programme time: Cap (e.g. 4 hours) for the standard cotton programmes o Programme time: Detailed declaration for each programme in the booklet o Capacity: Declaration based on a standardised measurement method o Combined washer-driers: Inclusion into the scope of the Ecodesign regulation for

washing machines (and for driers) • Measurements and calculation methods

o Large washing machines: higher demands regarding the EEI o European average load (e.g. 3 kg) instead of half load o Wash temperatures, number of cycles, other programmes: To be left as they are

• Active Promotion of Cold Wash (20°C)

2 Background The Energy Label regulation and Ecodesign regulation for washing machines from 2011 ask for a review by the end of 2014. Both regulations were examined by a study of CLASP (2013) and an omnibus-like review study, which concluded in March 2014 after a stakeholder meeting in November 2013 («Omnibus» Review Study 2014). The Working Document on the «Omnibus Review Process of existing measures» (2014) summarizes the conclusions as follows: • For washing machines a revision of existing regulations (or introduction of new

regulations) is the preferred policy option. • Washing machines are identified as «high priority», requiring further (extensive /

comprehensive) revision studies. The energy savings potential of washing machines by more stringent Ecodesign measures is estimated at modest 3 TWh/year in 2030 through, but there is a possibility for resource efficiency requirements in particular as regards water consumption and material efficiency, and a need to better understand the interaction between washing temperature, programme time, label information, actual load behaviour by users and appropriateness of introducing rinsing and spin-drying requirements.

• The follow-up study should also include domestic washer-driers which should be aligned, or combined, with activities related to washing machines, as «washing» appears to be a more prominent product function than «drying».

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3 EU Regulations for Washing Machines 3.1 Energy Label For washing machines, the current Energy Label is mandatory since December 2011 (Commission Delegated Regulation (EU) No 1061/2010). Compared to the former Energy Label a number of modifications were introduced, in particular: • Introduction of the three extra energy efficiency classes A+,

A++ and A+++. • Inclusion of the programmes 60°C full load, 60°C half load and

40°C half load for the calculation of the Energy Efficiency Index (EEI), for the annual electricity and water consumption and for the remaining moisture content.

• The EEI is based on the annual energy consumption for 220 standard washing cycles (weighted energy consumption over the 60°C full (3x), 60°C partial (2x) and 40°C partial load (2x) cycles). It also includes low power modes («left-on» and «off»). In the former label the EEI was based on the energy consumption per cycle.

• Washing performance is not indicated any more, its minimum performance has to be class A (>1.03) according to the former Energy Label.

3.2 Ecodesign Regulation At the present time (February 2015), following EU Ecodesign requirements apply for washing machines sold on the EU market (Commission Regulation (EU) No 1015/2010 and Corrigendum): • Energy Efficiency Index (EEI): For all washing machines ≥ 4 kg the EEI has to be < 59,

which equals the energy efficiency classes A+, A++ or A+++ on the Energy Label. In other words: only three of the seven classes remain, while the four other classes A, B, C and D are banned from the EU market.

• Water consumption (Wt): has to be ≤ 5 x c1/2 + 35, where c1⁄2 is the washing machine’s rated capacity for the standard 60°C cotton programme at partial load or for the standard 40°C cotton programme at partial load, whichever is the lower.

• Washing Efficiency Index (Iw): for washing machines > 3 kg it must be greater than 1.03, which corresponds to the class A according to the former Energy Label (Commission Directive 95/12/EC).

• Availability of a cold wash programme (max. 20°C): Washing machines shall offer to end-users a cycle at 20°C. This programme shall be clearly identifiable on the programme selection device and/or the display.

• Further requirements are related on the calculation of the energy consumption and other parameters as well as on the booklet of instructions.

3.3 Regulation on Standby and Off Mode Additionally, washing machines are covered by Commission Regulation 1275/2008 on standby and off mode power. Since January 2013, maximum power consumption allowed is 1 W for «left-on» and 0.5 W for «off-mode».

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4 Test Standard for Washing Machines The European Test Standard EN 60456 specifies methods for measuring the performance of clothes washing machines for household use. In the version of 2012-03 in particular following modifications have been made with respect to EN 60456:2005-09: • A test procedure for a combined test sequence of cotton 40°C and cotton 60°C with full

load and partial load was introduced. • A test procedure for measuring power consumption in low power modes was introduced. • A formula to calculate the energy consumption of washing machines including low power

modes was added. EN 60456 does not include a test on hygiene.

5 Market Development of Washing machines 5.1 Stock: 190 Mio Units, Sales: 14 Mio Units (EU-27) The European washing machine market is generally considered to be saturated. In the future, the washing machine market is expected to be driven primarily by the replacement of old appliances. 2011, total washing machine sales in EU-27 were approximately 13.9 million units, the stock was estimated to be around 191 million units (CLASP 2013).

5.2 Rapid evolution: already 44% were A+++ or A++ after one year The current Energy Label for washing machines entered into force by the end of 2010 and is mandatory since December 2011. The new energy efficiency classes A+, A++ and A+++ were filled up quickly. GfK-data from January to February 2013 show that 44% of the sold washing machines were already rated in the two highest energy efficiency classes only one year after the introduction of these classes (22% in A+++, 22% in A++). This share is estimated to be clearly higher by today.

6 Best Available Technology (BAT) in Europe according to Topten.eu

The platform Topten.eu presents the best washing machines on the European market online, selecting them according to the following criteria (February 2015): • Energy efficiency: A+++, according to the Energy Label • Spin-drying efficiency: A, according to the Energy Label • Water consumption: according to the Ecodesign

requirements • Availability in at least one European country • In addition, suppliers have to provide Topten with following data:

o Energy Efficiency Index (EEI) o Energy consumption per cycle in kWh (60°C full and half load, 40°C half load) o Programme time (60°C full and half load, 40°C half load) o Power consumption in left-on-mode and off-mode o Maximum spin speed

GfK 2013

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In February 2015, around 70 high efficient washing machines with a capacity of 6 kg to 11 kg of 13 different brands were listed on Topten.eu. There key data are:

Key data Range of data of the Topten-models

Energy Efficiency Index (EEI) Best EEI: 22.8, due to an integrated heat pump (threshold for A+++ is 46 BAT is 50.5% better) Other Topten-Models: 31.7 – 45.6

Annual energy consumption (according to the Energy Label)

98 – 261 kWh/year

Energy consumption 60°C full load: 0.52 – 1.35 kWh/cycle 60°C half load: 0.41 – 0.97 kWh/cycle 40°C half load: 0.36 – 0.72 kWh/cycle

Programme time 60°C full load: 2 h 20 min – 4 h/cycle 60°C half load: 1 h 35 min – 3 h 40 min/cycle 40°C half load: 1 h 30 min – 3 h 35 min/cycle

Topten.eu lists best performing washing machines of capacities from 6 kg to 11 kg. Here: excerpt of best performing washing machines with a capacity of 8 kg (February 2015).

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7 How Washing Machines reach A+++ The calculation of the Energy Efficiency Index (EEI) is determined in accordance with Annex VII of Commission Delegated Regulation (EU) No 1061/2010. Parameters flowing into its calculation are: (weighted) energy consumption at 60°C full load and half load and at 40°C half load, programme time, capacity and (weighted) power in left-on mode and off-mode. A low EEI, which means high energy efficiency, can be achieved in different ways or its combination: • Advanced technology: Inverter driven motors and permanent magnet motors reduce

the energy consumption. A highly effective technology is the integration of a heat (see www.topten.eu: Adora SLQ-WP by V-Zug, EEI: 22.8). The heat pump technology is already successfully applied for tumble driers. To apply it also for washing machines is a promising novelty on the market (first introduction in 2014) with high energy savings potential.

• Effective load sensors: The overall energy consumption and EEI respectively are also positively influenced by effective load sensing devices and controls capable of estimating the weight of the laundry load and automatically adjusting the energy and water consumption. An effective load sensor is in so far of relevance as it is a known problem that washing machines often are only partially filled. In particular this consumer behaviour becomes meaningful for larger-sized washing machines, which are rarely fully loaded.

• High capacity: Since capacity is part of the EEI’ equation, a higher capacity with the same energy consumption lowers it, which has a positive influence on the reached energy efficiency class on the Energy Label. Even if larger machines wash more efficiently per kg, more and more part load washing will occur, and the relative savings per kg nominal load then are lost. Theoretically, half load (e.g. at 60°C) should lead to a reduction of electricity consumption by 50% compared to a full load (e.g. at 60°C). However, in practice the reduction ranges from 0% to 35.6% (see Topten.eu). In fact this leads to an increase of the energy consumption per kg laundry! Thus, capacity can be more important regarding the energy consumption than the decaled energy efficiency class. Or in other words: washing machines classified in the best energy class do not automatically consume little energy.

• Elongation of programme times: The increase of energy efficiency often goes along with longer programme times. However, high energy efficiency and relatively short programme times do not have to exclude each other. This is demonstrated by Topten-machines with short times of the «standard» programmes: 2 h 20 min (60°C full), 1 h 35 min (60°C half) and 1 h 30 min (40°C half) respectively (Schulthess Spirit eMotion 7040i and Merker Bianca 735, both with a capacity of 7 kg and an EEI of 43, which equals A+++ -6.5%). A new Miele-model presented at IFA 2014 reaches A+++ -40% with programme times below 3 hours. Its market introduction is planned for 2015. However, the risk of the longer cycle time is that consumers might not use the energy efficient «standard» programmes and switch to shorter, but more energy consuming programmes.

• Lower temperature than declared: Apparently not all washing machines wash at the required temperature of 60°C as shown by tests of the consumer organization Stiftung Warentest. To wash at lower temperatures leads to a better EEI and better classification because then less water has to be heated. However it has to be noted, that obviously the required washing performance (>1.03) was also guaranteed by these lowered temperatures.

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8 Combined Washer-Driers Washer-driers combine the functions of a washing machine and a tumble drier, in one drum. The appliance therefore can combine both processes «washing» and «drying» in one non-stop cycle (no interaction by the user is needed in between). In the non-stop cycle the load capacity is the one of «only drying», which normally is smaller than the one for «only washing». However, if it is washed at full load, the user then has to take out a part of the wet load after spinning, and run two drying cycles one after another in order to dry the complete load (e.g.: washing / drying in the non-stop cycle: 6 kg; washing separately: 9 kg, drying separately: 6 kg). The advantage of washer-driers over a separate washing machine and separate drier is not so much comfort, but space (only one appliance instead of two appliances) and the lower purchase price. However, running costs for electricity and water can be much higher.

8.1 Low but Increasing Market Share in Europe Washer-driers account for approximately 2.5% of total washing machines sales in Europe (CLASP 2013). However, according to market observations by Topten there are more and more manufacturers offering and promoting them. It therefore has to be counted with an increasing demand in the near future.

8.2 Out-dated Energy Label and no Ecodesign requirements

Combined washer-driers are still labelled with the Energy Label from 1996. Its energy efficiency classes range from class A to G according to Commission Directive 96/60/EC. On the Energy Label are specified energy consumption for washing, spinning and drying at the full capacity of the wash cycle. The data are based on the 60°C programme for normally soiled cotton and the drying programme «dry cotton». Because capacity for drying usually is lower than the one for washing, the full cycle energy consumption includes two drying cycles. For better comparison additionally the electricity consumption only for washing is listed. There are no Ecodesign requirements established for washer-driers so far. They are neither covered by the regulation for washing machines nor by the one for tumble driers. Combined washer-driers have their own performance test standard EN 50229. It is independent from those for washing machines (EN 60456) and tumble driers (EN 61121). In the draft version EN 50229:2014 adjustments were made to the latest versions of EN 60456 for washing machines und EN 61121 for tumble driers.

8.3 Topten.eu: Washer-driers with heat pump In order to qualify for Topten.eu, washer-driers must meet the following criteria: • Energy efficiency: max. 0.5 kWh per kg laundry (full wash and

dry cycle / washing capacity) • Water consumption: max. 12 litres per kg laundry (full wash and dry cycle / washing

capacity)

These Topten-criteria only are reached when the appliance is equipped with an integrated heat pump. Due to this technology these BAT-models consume 40% less energy. The

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energy consumption for washing and drying of the Topten-models accounts for 3.67 to 3.8 kWh, while inefficient washer-driers without heat pump use > 6 kWh for this process. Due to the integrated heat pump furthermore no cooling water is needed anymore for drying. Therefore water only is needed for washing, which saves 30% of water compared to conventional washer-driers without heat pump. The Topten-models use 69 litres / cycle, while inefficient models use around 100 litres and more. It has to be noted, that efficient combined washer-driers still use around 50% more energy than efficient washing machines and efficient tumble driers (calculations of Topten).

Best performing washer-driers according to Topten.eu (February 2014)

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9 Policy Recommendations The current Energy Label and Ecodesign regulations for washing machines ask for a review by the end of 2014. Next to the verification tolerances, the review shall in particular assess the opportunity of setting requirements on rinsing and spin-drying efficiency and the potential for hot water inlet. Topten welcomes the Commission’s decision to carry out revision studies for washing machines and to improve the Energy Label and Ecodesign requirements. The recommendations of Topten are as followed:

9.1 Energy Label Reclassification of the energy efficiency classes (BAT 2014: EEI is 50% better than threshold for A+++) The revised Energy Label for washing machines from 2010/2011 and the introduction of the energy efficiency classes A+, A++ and A+++ obviously stimulated industry to develop more efficient products at the beginning. However, innovation force of the manufacturers has been underestimated and the new classes not been designed ambitiously enough: due to technological progress (e. g. integrated heat pump, inverter motors etc.), but also low-tech optimization to the Label and measurement standard (e.g. larger capacity thanks to larger drum in an otherwise un-changed machine, lower wash temperatures at longer programme times, ...), the current Energy Labelling scheme quickly lost its ability to differentiate between high efficient machines. In early 2013, one year after the new Energy Label classes became compulsory, already 44% of the sold washing machines on the European market occupied the two highest energy efficiency classes A+++ and A++. Today, the best Energy Efficiency Index (EEI) found on Topten.eu already is 22.8, which equals A+++ -50.5%. Manufacturers have no possibility to communicate these innovations with the existing Energy Label, it therefore provides no longer an incentive for further developments. Topten recommends a reclassification of the Energy Label with ambitious thresholds regarding the energy efficiency classes, in order to keep driving the market development towards higher energy efficiency.

Back to the classification of A - G (instead of A+++ – D) It is well-known that consumers do not understand the logic behind the different scaling A+++ to D and A to G. They often do not know for which best class they shall opt, when buying appliances (e g.: energy efficiency classes for washing machines reach from A+++ to D, while the classes for its spin-drying efficiency range from A to G.) Topten recommends to go back «to the roots» and to scale again from A to G instead of A+++ to D. The reversion should be subject of Directive 2010/30/EU, which currently is also under review.

Top-classes empty at first to account for future innovations There is still further potential for technological improvement of washing machines in several areas e.g. integrated heat pumps, efficient motors, time and temperature trade-off, mechanical action and controls. Therefore, the revision of the Energy Label shall define a longer-lasting labelling scheme holding the top-classes empty at the time of its introduction to allow future technical developments.

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Hot water inlet: yes/no-declaration on the Energy Label The higher the washing temperature, the higher are the potential savings from hot water supply (up to 70% less electricity consumption by the washing machine). On the European market there are several washing machines available offering the option for «hot fill» (see Topten.eu). As in many countries more and more households use solar energy, it is recommended to declare on the Energy Label whether the washing machine accepts «hot fill» or not.

Combined Washer-Driers: 2 labels – 1 for washing, 1 for drying The update of the Energy Label for washing machines offers a good opportunity to also revise the out-dated label for combined washer-driers Commission Directive 96/60/EC. As was discussed among participants during the Omnibus stakeholder meeting in November 2013, it is recommended to label washer-driers with 2 labels: 1 for washing, 1 for drying. The integration into the scope of the energy labelling for washing machines and tumble driers would be a new and unconventional measure for labelling, but would allow consumers a direct comparison with washing machines and tumble driers respectively regarding their energy efficiency, energy and water consumption, spin-drying efficiency etc. It is recommended to take the non-stop-cycle of the revised measurement standard for combined washer-driers as basis for the two labels as this is the appliance’s main function. However, it has still to be defined at which point washing ends.

9.2 Ecodesign Regulation Washing Performance: requirements also for the 20°C cotton programme Heating-up cold tap water to 30°C, 40°C, 60°C or even 90°/95°C uses the lion’s share of washing machines’ electricity consumption. The 20°C programme saves in average 60% electrical energy compared to the 40°C programme (according to tests carried out by Topten in collaboration with the VDE Testing and Certification Institute and the consumer organisation Stiftung Warentest in December 2014). Thus, «cold wash» holds a tremendous energy saving potential, which cannot be reached as easily by any other measure in the whole washing process. The tests also showed that washing at 20°C gives good results when using good detergent and machines with a good washing performance. The results at 20°C comply with the requirements on the washing performance of the EU Ecodesign Regulation 1015/2010 (>1.03). It has to be guaranteed that the 20°C cotton programmes as required by the Ecodesign Regulation lead to good washing results. Therefore the introduction of requirements on the washing performance of these 20°C cotton programmes is recommended, analogue to the requirements on the Washing Efficiency Index (e.g. own requirements for 20°C or inclusion in the calculation formula that so far is only applied for 60°C and 40°C).

Spin-drying efficiency: Introduction of ambitious requirements: A The better the laundry is spun, the less energy is needed to dry it. Therefore the spin-drying efficiency is a relevant parameter when assessing the overall energy consumption of the laundry process, as drying laundry by a tumble drier consumes far more energy than the washing process itself and spinning is much more efficient than tumble drying. A strong trend towards drying by tumble driers can be observed, while hanging up laundry outdoor is decreasing. Therefore, Topten recommends to introduce ambitious requirements on the spin-drying efficiency: minimum requirement shall be class A. As the washing machines presented on Topten.eu demonstrate well, it is feasible to reach best energy efficiency class plus best spin-drying efficiency class.

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To the point of view of Topten class B would be to weak as this already is met already by the majority of the models on the European market (72%, see «Omnibus» Review Study 2014).

The «Omnibus» Review Study 2014 argues that better spinning (A) might lead to more wrinkles and thus to more ironing and to a higher overall electricity consumption. Topten is of the opinion that the impact of ironing is overestimated as the trend clearly goes towards tumble drying which supersedes ironing in most cases. It is therefore justified to announce the stringent requirement «A» on the spinning performance, which would bring high energy savings.

Rinsing efficiency: Introduction of appropriate requirements It could be observed that water consumption has continuously decreased over the past few years, which brought high water savings. However, the value of the given information on the Energy Label (L/annum for 220 «standard» cycles) is limited as long as sufficient rinsing is not ensured. Rinsing only to the point where it is sufficient is challenging, but saves water during the whole laundering processes and leads for more environmentally sustainable laundering practice. The existing method for assessing rinsing efficiency (based on alkalinity) specified in EN 60456 is known to have some deficiencies. Working groups on European and International levels are working on developing a sufficiently reliable method that may finally be used for Ecodesign and Energy labelling requirement. Topten recommends to introduce stringent requirements on the rinsing efficiency based on the new measuring method. As done for the washing performance (requirement A), also sufficient rinsing performance should be part of a washing machine’s primary function and therefore should be guaranteed. The introduction of minimum requirements on the rinsing performance would also be a help for persons with allergies.

Programme time: Cap (e.g. 4 hours) for the standard programmes The prolongation of the programme time opens the possibility to wash at lower temperatures with the same washing result and can therefore increase the energy efficiency. The risk of the longer programme time is that consumers might not use the energy efficient «standard» programmes and will think of this option as «inconvenient» and therefore switch to shorter, but more energy consuming programmes.

Topten recommends to set a cap of e.g. 4 hours regarding the cycle times for the standard programmes 60°C full, 60° half and 40°C half load and 20°C. This measure would guarantee a minimum user-friendliness and also avoid extra-long programme times just for the optimization of the machines’ energy efficiency.

Programme time: Detailed declaration for each programme in the booklet It is of great importance that consumers are fully informed by the booklet of instructions on each programme (main and additional ones) regarding its maximum capacity, energy and water consumption, programme time, maximum spin speed and remaining moister content (%). This allows consumers a direct comparison with the energy friendly «standard» programmes (60°C full and half load, 40°C half load), and they can make an informed choice between the standard programmes and other – shorter, but maybe more energy consuming – programmes.

Capacity: Declaration based on a standardised measurement method Currently the capacity of a washing machine is defined and declared by the manufacturer – this is what is stipulated by the Ecodesign regulation. There exist no direct normative demands.

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Topten noticed that identical washing machines sometimes get different capacities depending in which country they are sold.

It has to be noted that capacity has a direct influence on the Energy efficiency Index EEI. Thus, a high capacity helps to get a better classification on the EU Energy label. To avoid misuse, it is recommended to require the measurement of the volume as described in the existing standard IEC 60456 and to define a clear formula with a conversion factor from volume into capacity (load in kg).

Combined Washer-Driers: Inclusion into the scope of the Ecodesign regulation for washing machines (and for driers) So far, there exist no Ecodesign requirements for combined washer-driers. From an energy and water saving point of view it is worthwhile to set also Ecodesign requirements on combined washer-driers, especially also behind the background that the energy and water consumption between high efficient models and non-efficient models varies widely. The revision of the Ecodesign regulation for washing machines offers a good opportunity to also cover the washing function of combined washer-driers in it. The best washer-driers consume 50% more energy than the best washing machines, one reason more to include them in the Ecodesign regulation for washing machines. The requirements for washing machines should be identically valid for washer-driers. Likewise, the Ecodesign regulation for tumble driers should also cover the drying function of washer-driers.

9.3 Measurements and Calculation Methods Large washing machines: higher demands regarding the EEI It is a clear trend towards large washing machines with a capacity up to 13 kg. However, the problem of filling washing machines often only partially is a well-known fact. Even if larger machines would wash more efficiently per kg, the relative savings per kg nominal load are lost in case more and more inefficient part load washing occurs. In other words: large washing machines are only fine as long as they have a low energy and water consumption when they are only little filled. It is a fact, that it is easier for large washing machines to reach a good Energy Efficiency Index (EEI) than for smaller ones, since capacity is part of the equation. A higher capacity with the same energy consumption thus positively influences the EEI. It therefore is recommended to adjust the SAEc in a way that large machines have to afford more in terms of energy efficiency than smaller ones in order to reach a certain energy class (e.g. curved line, natural logarithm based on capacity).

European average load (e.g. 3 kg) instead of half load The current measurement and calculation methods focus on half load. For a 10 kg machine this means 5 kg and for a 13 kg machine this means 6.5 kg. These half load-capacities resemble more to a fully loaded «normal» washing machine and stay in a strong contrast with the European average load to be around 3 to 3.5 kg. Topten therefore recommends to focus on the European average load instead of half load.

Wash temperatures, number of cycles, other programmes: To be left as they are Measurement and calculations methods should represent reality as good as possible. However, changes will always make a continuous tracking of market developments impossible and should be well justified. Concerning the number of cycles (220), wash temperatures (60°C/40°C) and other programmes, Topten recommends to leave them as they are. The motivations are: Wash temperatures: The average washing temperature in Europe is around 40°C. Topten agrees with the «Omnibus» Review Study (2014) that the usage of 60°C-cycles probably is

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overestimated. However, the energy consumption for heating up cold tap water up to 60°C is energetically more impacting than for cold wash (15°/20°C). Therefore it is preferable to also have in the future data on the 60°C-programme.

Besides, there are no «true» wash temperatures, as the households habits on the selection of wash temperatures vary widely, not only within households but also within Europe (e.g. in northern countries often higher wash temperature are selected than in southern ones).

Number of cycles: The «Omnibus» Review Study suggests a reduction from 220 cycles to 200 or less. From the point of view of Topten, a change in the number of cycles is not necessary because the comparability of the energy efficiency of different washing machines is ensured. There anyway is no «true» number since usages vary widely and cannot be grasped with one formula (e.g. washing machine in a single household, where only rarely is washed, versus a family with daily washings). The assumed number of cycles will always be an approximation, which is only true for some households.

Other programmes than the «standard programmes for cotton»: Detailed declarations on each programme: «Omnibus» Review Study (2014) states that the programmes on which the «standard» and the Ecodesign regulation are based are probably not the most used programmes. The real improvement potential therefore would depend on the improvement of other programmes as well. However, these programmes are not considered in the regulation and improving other programmes is not stimulated with the current legislation. A review should analyse the possibly to set incentives on other programmes as the «standard» programme (e.g. 20°C). Topten agrees that the programmes taken as «standard» shall be as close to reality as possible. On the other side, it is known that manufacturers optimize the «standard» programmes to get good classifications on the Energy Label. To take other programmes as «standard» than the ones taken currently would only displace but not solve the problem. It is of great importance that consumers are fully informed on each programme in the booklet of instructions concerning maximum capacity, energy and water consumption, programme time etc.

9.4 Active Promotion of Cold Wash (20°C) Heating-up cold tap water to 30°C, 40°C, 60°C or even 90°/95°C uses the lion’s share of washing machines’ electricity consumption. Washing machines offering a cycle at 20°C – as required by the EU Ecodesign Regulation 1015/2010 – and a variety of detergents designed for the temperature range from 15°/20°C up to 60°/90°C are both available on the European market. Nevertheless, most consumers still do not switch washing temperatures down to 15°/20°C in their everyday lives mainly because of prejudices, but also traditions and habits, that hinder them from taking this step (Josephy et al. 2013). Discussions on «cold wash» – especially on the washing performance – are often controversial and emotional. To contribute to the debate with impartial and scientific facts, Topten carried out 18 tests in collaboration with the VDE Testing and Certification Institute and the consumer organisation Stiftung Warentest in December 2014. The main test results were: • Washing at 20°C gives good washing results, when using good machines and good

detergents. The results comply with the requirements of the EU Ecodesign Regulation 1015/2010.

• The washing result depends on detergent, pre-treatment of stains, washing machine, load size and programme time. Good results were achieved by the combination of a good detergent (with / without additionally soil remover) and a good washing machine.

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The potential is not yet exploited (machines with an even better washing performance than the tested one are available on the market, etc.).

• In case of stubborn stains the pre-treatment may improve the washing result, especially when washing at 20°C.

• Washing at 20°C saved around 60% electrical energy compared to the tested 40°C-programmes. Thus, «cold wash» holds a tremendous energy saving potential, which cannot be reached as easily by any other measure in the whole washing process.

Topten is pursuing the strategy to reduce the wash temperature at best right down to 15°C/20°C, while A.I.S.E. follows the approach to downshift the washing temperature gradually (see «I prefer 30»-campaign, www.Iprefer30.eu) From the point of view of Topten it is important to take up the issue of «cold wash» EU-wide and to push its implementation. To promote the topic of «cold wash», the following measures are recommended: • EU policies: Including of requirements on the Washing Efficiency at 20°C into the

revision of EU Ecodesign Regulation 1015/2010.

• Washing machine manufacturers, detergent manufacturers and retailers: active and continued advertisement of «cold wash» for slightly and normally soiled laundry, ongoing optimization of the 15°/20°C cycles, of the detergents (especially regarding sebum) and of the purchasing of detergents.

• Environmental organizations, consumer organizations, energy agencies: active and continued information and education of the consumers regarding washing performance of detergents at 20°C, dosage, chemicals, hygiene, biofilm. (e.g. with flyers such as the Topten-documentation «Washing at 20°C is Cool»).

• Science, test institutes: Publication of studies (consumer and technical), continuing tests on «cold wash» not only on heavily soiled but especially also on normal soiled laundry.

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References

Bush, Eric & Jürg Nipkow (2005): Energie- und Kostenoptimierungen bei Waschmaschinen und Geschirrspülern: Kriterien für Warmwasseranschluss. Im Auftrag des Amts für Hochbauten der Stadt Zürich. URL: http://www.topten.ch/uploads/images/download-files/warmwasseranschluss.pdf

CLASP (2013): Estimating potential additional energy savings from upcoming revisions to existing regulations under the ecodesign and energy labelling directives. A contribution to the evidence base. 18 February 2013. URL: http://www.clasponline.org/en/Resources/Resources/PublicationLibrary/2013/ CLASP-and-eceee-Point-To-Additional-Savings-from-Ecodesign-and-Energy-Labelling.aspx

Commission Delegated Regulation (EU) No 1061/2010 of 28 September 2010 supplementing Directive 2010/30/EU of the European Parliament and of the Council with regard to energy labelling of household washing machines. URL: http://www.topten.eu/uploads/Upload/Labelling_Regulation_WM_EN_OJL_30-11-2010.pdf

Commission Delegated Regulation (EU) No 392/2012 of 1 March 2012 supplementing Directive 2010/30/EU of the European Parliament and of the Council with regard to energy labelling of household tumble driers. URL: http://www.topten.eu/uploads/File/Energy%20Label%20Driers% 20March%202012.pdf

Commission Directive 95/12/EC of 23 May 1995 implementing Council Directive 92/75/EEC with regard to energy labelling of household washing machines. URL: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:1995L0012: 19970117:EN:PDF

Commission Directive 96/60/EC of 19 September 1996 implementing Council Directive 92/75/EEC with regard to energy labelling of household combined washer-driers. URL: http://www.topten.eu/uploads/File/Washer-Driers_Label_1996_EN.pdf

Commission Regulation (EC) No 1275/2008 of 17 December 2008 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for standby and off mode electric power consumption of electrical and electronic household and office equipment. URL: http://www.topten.eu/uploads/File/Ecodesign%20Regulation_Standby_1208.pdf

Commission Regulation (EU) No 1015/2010 of 10 November 2010 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for household washing machines. URL: http://www.topten.eu/uploads/Upload/REG_1015_2010.pdf

Commission Regulation (EU) No 932/2012 of 3 October 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for household tumble driers. URL: http://www.topten.eu/uploads/File/Ecodesign_regu_932_2012_driers.pdf

Corrigendum to Commission Regulation (EU) No 1015/2010 of 10 November 2010 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for household washing machines. URL: http://www.topten.eu/uploads/Upload/Corrigendum_REG_1015_2010.pdf

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Directive 2010/30/EU of the European Parliament and of the Council of 19 May 2010 on the indication by labelling and standard product information of the consumption of energy and other resources by energy-related products. URL: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010: 153:0001:0012:en:PDF

EN 50229: Electric clothes washer-dryers for household use – Methods of measuring the performance. URL: http://www.beuth.de/en/standard/din-en-50229/106859366

EN 60456: Clothes washing machines for household use – Methods for measuring the performance. URL: http://www.beuth.de/en/standard/din-en-60456-vde-0705-456-2012-03/148501897

EN 61121: Tumble dryers for household use – Methods for measuring the performance. URL: http://www.beuth.de/en/standard/din-en-61121-vde-0705-1121-2013-12/193326307

GfK 2013: Home Appliances. IFA Press Conference 2013. Friedemann Stöckle, Global Director MDA. 2013-04-19. URL: http://gpc.ifa-berlin.com/media/ifagpc/ifagpc_media/ifagpc_pdf/2013_13/ presentations/GfK-HA-Presentation.pdf

Josephy, Barbara, Eric Bush, Jürg Nipkow & Sophie Attali (2011): Washing machines: Key criteria for best available technology. EEDAL 2011. URL: http://www.topten.eu/uploads/File/039_Barbara_Josephy_final_Washing.pdf

Josephy, Barbara, Eric Bush, Jürg Nipkow, Karin Kleeli & Sandro Glanzmann (2013): Cold wash – Do prejudices impede high energy saving potentials? EEDAL 2013. URL: http://www.topten.eu/uploads/File/EEDAL13_Barbara_Josephy_Cold_Wash.pdf

Nipkow, Jürg, Eric Bush, Barbara Josephy (2007): Schlussbericht 2007: Warmwasseranschluss. URL: http://www.topten.ch/uploads/images/download-files/Schlussbericht%202007%20Warmwasseranschluss.pdf

«Omnibus» review study on Cold Appliances, Washing Machines, Dishwashers, Washer-Driers, Lighting, Set-top Boxes and Pumps. Final report. By Van Holsteijn en Kemna B.V., laamse Instelling voor Technologisch Onderzoek NV, Viegand Maagøe A/S and Wuppertal Institut für Klima, Umwelt, Energie GmbH. 12 March 2014. URL: http://www.energimyndigheten.se/Global/Företag/Ekodesign/Produktgrupper/ Omnibus%20Study%20-%20Final%20Report%20-%2012-03-2014.pdf

Topten.eu – Best Products of Europe. www.topten.eu

Washing at 20°C is cool. Topten-documentation. URL: http://www.topten.eu/uploads/File/Professional/Other%20Pro%20Guidelines/ Flyer_Coldwash_2014.pdf

Working Document On the Omnibus Review Process Of existing measures. European Commission, DG Energy, Brussels, 4 April 2014. URL: https://www.energimyndigheten.se/Global/Företag/Ekodesign/Produktgrupper/ Note%20to%20CF%20Omnibus%20Review%20Process%204-4-2014.pdf