Guidelines for the verification of household appliances under energy labelling and eco design

This Technical Report provides guidance for the verification testing of household and similar electrical appliances according to the Commission Regulations implementing Ecodesign Directive 2009/125/EC and Commission Delegated Regulations supplementing Energy Labelling Directive 2010/30/EU. It is also due to be suitable for succeeding documents.
This Technical Report might also be applicable to other types of energy related product and parts of it might also be applicable for the verification of product claims in schemes outside the European Union.

Leitlinien für die Verifizierung von Geräten für den Hausgebrauch im Hinblick auf Energiekennzeichnung und Ökodesign

Lignes directrices pour la vérification des appareils domestiques dans le cadre de l'écoconception

Smernice za preverjanje gospodinjskih aparatov v okviru označevanja z energijskimi nalepkami in okoljsko primerne zasnove

To tehnično poročilo podaja smernice za overitveno preskušanje gospodinjskih aparatov in podobnih električnih naprav v skladu z uredbami Komisije o izvajanju Direktive 2009/125/ES o okoljsko primerni zasnovi in delegirano uredbo Komisije o dopolnitvi Direktive 2010/30/EU v zvezi z označevanjem z energijskimi nalepkami. Primerno naj bi bilo tudi za prihodnje dokumente.
To tehnično poročilo se lahko uporabi tudi za druge vrste proizvodov, povezanih z energijo, in deli poročila se lahko uporabijo za preverjanje navedb o proizvodih v shemah zunaj Evropske unije.

General Information

Status
Published
Publication Date
14-May-2018
Current Stage
6060 - National Implementation/Publication (Adopted Project)
Start Date
07-May-2018
Due Date
12-Jul-2018
Completion Date
15-May-2018

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Standards Content (Sample)

SLOVENSKI STANDARD
SIST-TP CLC/TR 50674:2018
01-junij-2018
6PHUQLFH]DSUHYHUMDQMHJRVSRGLQMVNLKDSDUDWRYYRNYLUXR]QDþHYDQMD]
HQHUJLMVNLPLQDOHSNDPLLQRNROMVNRSULPHUQH]DVQRYH
Guidelines for the verification of household appliances under energy labelling and eco
design
Lignes directrices pour la vérification des appareils domestiques dans le cadre de
l'écoconception
Ta slovenski standard je istoveten z: CLC/TR 50674:2018
ICS:
97.030 (OHNWULþQLDSDUDWL]DGRPQD Domestic electrical
VSORãQR appliances in general
SIST-TP CLC/TR 50674:2018 en
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

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SIST-TP CLC/TR 50674:2018

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SIST-TP CLC/TR 50674:2018

TECHNICAL REPORT CLC/TR 50674

RAPPORT TECHNIQUE

TECHNISCHER BERICHT
April 2018
ICS 97.030
English Version
Guidelines for the verification of household appliances under
energy labelling and eco design
Lignes directrices pour la vérification des appareils Richtlinien für die Verifizierung von Geräten für den
domestiques dans le cadre de l'écoconception Hausgebrauch im Hinblick auf Energiekennzeichnung und
Ökodesign


This Technical Report was approved by CENELEC on 2018-03-26.

CENELEC members are the national electrotechnical committees of Austria, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic,
Denmark, Estonia, Finland, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia,
Lithuania, Luxembourg, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden,
Switzerland, Turkey and the United Kingdom.



European Committee for Electrotechnical Standardization
Comité Européen de Normalisation Electrotechnique
Europäisches Komitee für Elektrotechnische Normung
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2018 CENELEC All rights of exploitation in any form and by any means reserved worldwide for CENELEC Members.
 Ref. No. CLC/TR 50674:2018 E

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Contents Page
European foreword . 4
Introduction . 5
1 Scope . 6
2 Normative references . 6
3 Terms and definitions . 6
4 Procedure for appliance verification . 6
4.1 Overview . 6
4.2 Scope definition . 7
4.3 Test laboratory selection . 7
4.4 Model selection . 8
4.5 Desk research . 8
4.6 Sample purchase . 8
4.7 Testing . 8
4.8 Feedback . 8
4.9 Further testing if necessary . 9
4.10 Publication of the project outcome . 9
5 The verification procedure stages . 9
5.1 Regulations . 9
Figure 1 — Two stage verification process .10
5.2 Preliminary check .11
5.3 Step 1: test of one single unit .11
5.4 Step 2: test of three additional units .12
6 Procedure for the selection of models for testing .12
6.1 Introduction .12
6.2 The “random” selection .12
6.3 The “maximum failure” selection .13
6.4 The semi-random selection .13
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7 Procedure for the selection of testing laboratories . 14
7.1 General . 14
7.2 Requirements for laboratories that undertake verification testing . 14
7.2.1 General . 14
7.2.2 Independence . 14
7.2.3 Competence . 14
7.2.4 Experience . 14
7.3 The selection procedure . 14
7.4 Selection criteria . 15
7.4.1 General requirements . 15
7.4.2 Laboratory experience . 15
7.4.3 Testing capacity . 15
7.4.4 Available equipment for testing . 15
7.4.5 Testing details . 15
7.4.6 Reporting and documentation . 16
7.5 The rating system for laboratories selection . 16
Annex A (informative) Example for the selection of testing laboratories . 17
A.1 Accompanying letter to the laboratories questionnaire . 17
A.2 Laboratory Recognition Questionnaire for refrigerators (example) . 18
A.3 Example for a scoring system for the Questionnaire answers . 24
Annex B (normative) Rules for supplier visits to test laboratories. 28
Bibliography . 29

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European foreword
This document (CLC/TR 50674:2018) has been prepared by WG16 "Uncertainty" of CLC/TC 59X
"Performance of household and similar electrical appliances".
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. CENELEC shall not be held responsible for identifying any or all such patent rights.
This document is primarily for information. However, the reader should note that this Technical Report
also includes some statements based directly on European eco-design and energy labelling regulations
which are applicable for certain types of product at the time of writing.
This Technical Report has been developed from early experience of energy label and eco-design
verification projects. It also draws on the experience of pilot projects such as the ATLETE (Appliance
Testing for Energy Label and Evaluation) which were co-funded by the Intelligence Energy Europe
Programme of the European Union. Two projects were carried out under this scheme: refrigerators
(2009 to 2011) and washing machines (2012 to 2014). The projects were used to: check compliance
with energy labelling and ecodesign regulations for these appliance types across the EU; improve the
capacity of testing laboratories; and support cooperation among national Market Surveillance
Authorities (MSAs) by demonstrating how verification projects could be undertaken.
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Introduction
The European energy labelling scheme (and associated eco-design requirements) relies on
performance declarations being made accurately by the suppliers of the labelled products. To ensure
the integrity of the labelling scheme and to prevent abuse through overstated claims, it is a requirement
of the regulations that the scheme is policed by the member states. Policing is conducted by MSAs.
One of the more significant tools of the MSAs is the verification of energy label and eco-design claims.
Energy labelling and eco-design regulations identify the specific claims that can be verified and the
verification tolerances that should be applied. This Technical Report describes how a typical verification
project can be carried out and gives specific detail on the subjects of model selection, laboratory
selection and carrying out the testing procedure in two steps.
The objective of verification testing is to come to a clear and legally sound decision as to whether a
product complies with the requirements given in a Regulation or if the declarations made by the supplier
are incorrect.
This Technical Report is intended to be a supporting tool valid at EU/EEA level and Country level for
MSAs dealing with compliance and verification issues. It aims to help optimize the available resources
and increase the effectiveness of MSAs engaging in the verification process.
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1 Scope
This Technical Report provides guidance for the verification testing of household and similar electrical
appliances according to the Commission Regulations implementing Ecodesign Directive 2009/125/EC
and Commission Delegated Regulations supplementing Energy Labelling Directive 2010/30/EU. It is
also due to be suitable for succeeding documents.
This Technical Report might also be applicable to other types of energy related product and parts of it
might also be applicable for the verification of product claims in schemes outside the European Union.
2 Normative references
The following documents are referred to in the text in such a way that some or all of their content
constitutes requirements of this document. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any amendments) applies.
CLC/TR 50619, Guidance on how to conduct Round Robin Tests
3 Terms and definitions
For the purposes of this document, the following terms and definitions apply.
ISO and IEC maintain terminological databases for use in standardization at the following addresses:
— IEC Electropedia: available at http://www.electropedia.org/
— ISO Online browsing platform: available at http://www.iso.org/obp
3.1
supplier
manufacturer or its authorised representative in the EU or the importer who places or puts into service
the product on the EU market
3.2
compliant
meets a requirement or number of requirements specified in energy labelling or eco design regulations
having taken into account the applicable verification tolerances
Note 1 to entry: Verification tolerances are only applicable when values determined in tests conducted by an
MSA are compared to values declared by the supplier.
3.3
non-compliant
fails to meets a requirement or number of requirements specified in energy labelling or eco design
regulations, having taken into account the applicable verification tolerances
Note 1 to entry: Verification tolerances are only applicable when values determined in tests conducted by an
MSA are compared to values declared by the supplier.
4 Procedure for appliance verification
4.1 Overview
When conducting a verification project it is important to consider all the tasks and carry them out in a
logical and methodical order. A typical verification project should comprise of the following tasks:
• scope definition;
• test laboratory selection;
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• model selection;
• desk research;
• sample purchase;
• testing;
• feedback;
• further testing if necessary;
• publication of the project outcome.
These tasks are described in more detail in the following subclauses.
4.2 Scope definition
Time and money will inevitably limit the number of models that can be verified, so it is important to
focus on the achievable targets. Considerations at this stage could include limiting the extent of the
project in one or more of the following ways:
• geographical area to be covered;
• types of retail outlet for example, high street or internet;
• type of appliance for example, vented or condenser tumble dryer;
• appliance price range;
• appliance size for example, rated capacity;
• appliance claimed energy efficiency for example, only A+ and above;
• which claims are to be verified.
Regulations normally include an annex which specifies which parameters should be tested for
verification. These annexes were substantially revised in 2017 [10] [11]. A verification project may
include any single parameter or a selection of parameters or all of them. The verification itself should
include the following:
• checking the values declared in the technical documentation against the values measured in tests
conducted by the supplier;
• checking the declared values against the energy labelling and eco design requirements;
• checking that any required product information published by the supplier is not more favourable
than the declared values;
• checking the declared values against values determined by testing a sample of the model.
Decisions on the scope of the project may be guided by various forms of market intelligence including
the reports and activities of other MSAs and commercial market data agencies.
4.3 Test laboratory selection
A laboratory must be selected which has the capability to make the required tests on the appliance. It is
important that the laboratory can demonstrate an acceptable level of quality and competence. The
process of selecting a laboratory can be lengthy so it is worth starting early to ensure the verification
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project is not delayed at the testing stage. A detailed procedure for recruiting a test laboratory is given
in Clause 7.
4.4 Model selection
Having scoped the project, the models to be tested need to be selected. Three methods of model
selection are described in Clause 6. Each selection method has its own merits according to the
particular circumstances of the market sector being investigated.
It is important to be aware that suppliers often have a number of models with different model identifiers
that are in fact equivalent in terms of performance and energy label claims. Such models can usually be
identified in the technical file. See 4.5. It should also be noted that equivalent models may be sold
under a variety of different brand names.
4.5 Desk research
Appliance suppliers are legally obliged to maintain a technical file containing all the evidence they have
compiled to support the energy label and eco-design claims on their products. Suppliers are also legally
obliged to provide copies of the technical file to MSAs on request.
Examination of the technical file can reveal non-compliant products in some cases without the need to
conduct any laboratory tests. As an example, the supplier may be found to be using an energy label
that claims a better energy class than the results of its test data can support. This would indicate a
failure without any further work being necessary. (See also 4.2.)
The technical files can also be used to confirm which models are claimed to be equivalent in terms of
energy label claims.
4.6 Sample purchase
Having selected the models to be tested, samples of those models need to be acquired for testing. It is
important that samples are not obtained directly from the supplier so as to avoid the possibility of a
‘golden’ sample being tested.
Samples should be obtained in the same way as the consumer would purchase them. It is helpful to
record the details of any energy label or ecodesign information displayed at the point of sale - this
includes online trading.
A decision has to be made as to whether one sample or four samples should be purchased. Where the
verification procedure involves testing one sample and then testing three more samples if the first
sample fails, (known as the two step procedure - see Clause 5) it can be useful to purchase all four
samples at the outset. This avoids the possibility that the verification process is stalled after the first test
because further samples of the model are no longer available. This advantage must be weighed against
the cost of buying samples which turn out not to be needed.
Every sample purchased may potentially become the subject of a legal case. For this reason it is
essential that all samples are marked with a unique identifier as soon as they are acquired. They must
also always be stored in secure locations and a documented chain of custody must be kept. For
example, if a sample is passed to a laboratory for testing, documentation must show who passed the
sample to whom and at what time and on what day. This can be used to prove that all data generated
by the verification project can be ascribed to the particular sample in question.
4.7 Testing
The purchased samples are tested in the appointed laboratory according to the test procedure called up
by the relevant regulation. Verification testing is normally performed in a two-step process, the details of
which are described in Clause 5.
4.8 Feedback
It is recommended that the MSA maintains good communications with the supplier throughout the
verification process. For example it can save time and money if the supplier can confirm that a sample
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is not faulty prior to testing. Also, if the model is clearly failing after Step 1 of the testing process, the
supplier may agree to take action at that stage, avoiding the need for Step 2 testing.
On completion of Step 2, if the model has failed, the results of the testing are sent to the supplier in the
form of a full test report. If the supplier accepts the results then remedial actions need to be considered
which may include one or more of the following: withdrawal of the model from the market, modification
of the model, the award of compensation to consumers who have bought the model, compensation for
the impact on the environment by contribution to a carbon reduction programme. If the supplier does
not accept the test results, legal action may be necessary.
4.9 Further testing if necessary
If the supplier of a failed model agrees to carry out modifications to improve the performance of the
model, it is recommended that the MSA purchases a sample of the modified model and carries out
testing to determine the effectiveness of the modification. The supplier may agree to pay the cost of the
additional tests.
4.10 Publication of the project outcome
It is important that the results of verification projects are disseminated as quickly and widely as
possible. For example, results could be forwarded to the Information and Communication System for
pan-European Market Surveillance (ICSMS) at https://webgate.ec.europa.eu/icsms . Publicity is a
valuable tool for enforcement. It is also helpful for other MSAs running parallel verification programmes.
Publication will help them to avoid unnecessary duplication of effort and help them to target those
models / sectors having the worst track record.
5 The verification procedure stages
5.1 Regulations
The verification procedure described in this Technical Report follows the two-step process established
in the energy labelling implementing Directives supplementing Directive 92/75/EEC. Similar procedures
are described in the current Commission delegated regulations supplementing Directive 2010/30/EU on
energy labelling and Commission regulation implementing directive 2009/125/EC on ecodesign. The
procedure is presented in Figure 1.
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NOTE 1 The verification tolerances set out in the regulations relate only to the verification of the measured
parameters by Member State authorities and shall not be used by the supplier as an allowed tolerance to establish
the values in the technical documentation.
NOTE 2 Determined values are the values of relevant parameters as measured in testing by the MSA and the
values calculated from these measurements.
NOTE 3 Average means arithmetical mean.
NOTE 4 Some products covered by the energy labelling and / or eco design regulations have a verification
procedure that is different to the one described here.
Figure 1 — Two stage verification process
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The procedure includes:
‒ a preliminary check;
‒ Step 1: tests on one single unit of the model;
‒ Step 2: tests on three additional units of the same model.
For the eco design verification, the requirements valid at the time of the placing on the market of the
samples shall be considered.
5.2 Preliminary check
Before undertaking any technical tests, the supplier’s technical file should be checked. In the absence
of a technical file, data given in the appliance instruction book can be compared with the eco design
requirements and the performance classes claimed on the energy label. Any inconsistencies should be
checked with the supplier before proceeding further with the process. For the ecodesign verification the
requirements valid at the time of the placing on the market of the sample(s) under test shall be
considered.
5.3 Step 1: test of one single unit
The laboratory should check each unit to be tested, to ensure that it has no obvious operating defects
or damage, for example: deformation of the external casing, fault indicators active on the appliance or
parts missing.
One unit of the selected model is tested according to the applicable harmonized standard(s) published
in the Official Journal of the EU. If there is not yet a harmonized standard present, transitional methods
published in the Official Journal of the EU are to be used. If no published method exists, state of the art
method(s) agreed with the suppliers should be used.
The supplier should be invited to attend some of the testing so that they can see that the work is being
carried out correctly and that the sample on test is installed and working correctly. It is important to
establish a set of rules for such meetings to ensure the supplier is not able to influence the outcome of
the testing in an inappropriate way. A list of suggested rules is given in Annex B.
The testing laboratory reports the results of the verification test to the MSA only.
If the MSA is satisfied that the outcome of the test complies with all the labelling declarations and eco
design requirements for the unit on test (including the relevant verification tolerance specified in the
respective Regulation) then the model is deemed to have passed the verification and the testing
procedure ends.
If the unit fails one or more of the labelling declarations or eco design requirements, or is not able to
complete a test, the MSA may decide to proceed to Step 2.
Prior to embarking on Step 2, the MSA should check if the supplier agrees with the findings of Step 1.
The supplier of the model under test should have the opportunity to check in situ under supervision of
the test laboratory or MSA if the tested unit is defective or damaged. A supplier who believes that the
tested unit is defective should report this to the MSA. The onus is on the supplier to provide evidence
that damage or a defect capable of affecting the test results does exist; and that the “defect” is peculiar
to the test unit alone and not common to other samples of the stock of the appliance.
If the MSA accepts that the evidence provided by the supplier demonstrates that the tested unit was
defective or damaged, the original Step 1 test will be considered void and a new test can be undertaken
on a replacement sample of the same model purchased from the market.
If the supplier accepts that the model is non-compliant, the supplier and MSA then have to come to an
agreement about what remedial actions need to be carried out by the supplier (see 4.8).
If the MSA does not accept claims from the supplier that the unit tested was faulty and the supplier
does not accept that the model is non-compliant then the MSA should proceed to Step 2 to complete
the verification process.
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5.4 Step 2: test of three additional units
Three additional units of the same model are tested according to the same measurement methods as
described in 5.3.
The tests should whenever possible be performed in the same laboratory that ran Step 1, in order to
ensure highest coherence between the steps.
It is recommended that all relevant parameters are tested, even if some of them were found compliant
in the first phase of testing. The following two examples illustrate the advantages and disadvantages of
testing all parameters at Step 2.
Example 1 Step 1 for a washing machine model indicates it fails in terms of spin speed and remaining
moisture content but it narrowly passes all other test parameters. Spin speed and remaining moisture content
measurements are somewhat vulnerable to the random movement of the load in the washing machine which can
cause the machine to be unbalanced and therefore spin at a lower speed. During Step 2, there are no unbalanced
load situations and the model passes the spin speed and remaining moisture tests. However, the model fails in
terms of energy consumption. This could happen because the verification tolerance permitted for energy
consumption in Step 1 is 10 % whereas in Step 2 the verification tolerance permitted for the average of the three
models is only 6 %. In this case, repeating all parameters detected a failure that would otherwise have gone
unnoticed.
Example 2 Step 1 for a tumble
...

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