The Institute for Impact Assessment and Scientific Evaluation of Policy and Legislation
Ecodesign policy prejudges Impact Assessment
May 16th 2018
The policy option selected for EU Ecodesign legislation for domestic appliances, lighting and computers prejudges the ongoing consultation and Impact Assessment process. The European Commission's Impact Assessment presents four options but immediately selects a preferred option, before completing the necessary analysis.
The Impact Assessment Institute has scrutinised the European Commission Inception Impact Assessments (IIAs) on computers, lighting products, washing machines, dishwashers and refrigerators. The IIAs do not quote adequate references to background data and analysis for its assertions on objectives and preliminary assessment of impacts, despite the availability of relevant consultants’ studies.
Of particular concern is the premature selection of the preferred policy option, to update the current Ecodesign regulation and Energy Labelling. The function of the planned full Impact Assessment is to provide the necessary evidence to determine whether this or another option has the most beneficial impacts. Selecting the preferred option at this early stage undermines the public consultation and the Impact Assessment process.
Selection of policy options should be decided after completion of the full Impact Assessment, taking into account all available evidence, including submissions to the public consultation.