Columnists: Fiona Brocklehurst, Ballarat Consulting

Published on: 22 Oct 2020

UK product policy: now we can do anything, what should we do next?

BEIS issued a call for evidence on energy related products in the summer and I co-ordinated  the response for CREDS (Centre for Research into Energy Demand Solutions, a consortium of academics from UK universities who work with researchers, businesses & policy makers to support the transition to a low-carbon energy system.)

Of the many policy tools available to increase the sustainability of energy related products, in the last decade or so the UK Government has chosen to rely almost completely on the two EU-wide policies for these products: Ecodesign and Energy Labelling.  Once the UK concludes withdrawal from the EU at the end of this year, what should happen next?

This, then, is one of the multitude of policy areas upon which the UK Government needs to decide its agenda following the end of the transition period from the EU. The call for evidence was explicitly intended to feed into this process. BEIS recognised that this is an important topic for climate targets and for the sustainability agenda more generally, quoting that these “are important as energy-related products account for approximately 55% of total (non-transport) energy use in the UK”.

A colleague, Jeremy Tait and I gave our opinion on what the UK should do once we left the EU in an eceee column in 2016, shortly after the Brexit referendum result. This response to the BEIS call was an opportunity to reflect on the evidence, together with other experts, several year later.

The BEIS consultation focused on current policy, framed by the two EU regulations. Many of the questions in the call related to particular product groups. In particular, whether there is scope to set better ecodesign requirements for products that have already been regulated at an EU level (the UK Government’s stated intention is to raise ambitions for these regulations beyond those adopted in the EU), and whether to increase the coverage for ecodesign and energy labels by adding new products for the UK. CREDS colleagues contributed valuable technical information and expert opinion on some of these – as you can see in the complete response.

I, with support from Brenda Boardman, Nick Eyre, and Tina Fawcett, (all at the Environmental Change Institute, University of Oxford), concentrated on the broader topics of the call:

  • how energy labels can be made more useful for consumers,
  • how UK market surveillance activities can be made more effective in ensuring regulatory compliance; and
  • whether additional policy levers could be considered to increase the energy, carbon and resource efficiency potential of energy-related products.

We also chose to submit evidence on the bigger question which was not included in the call for evidence – what should the UK Government’s priorities be for policies on energy related products, once outside the EU?

In summary, CREDS proposed that there are three major options for the UK in order to increase energy savings from products. These are:

  1. enhanced enforcement of the existing regulations;
  2. using existing regulations as a basis for additional UK-specific policy action; and
  3. developing UK-specific regulations.

The expense, complexity and time taken to fully realise savings from these options increases markedly moving from option 1 to option 3 (Figure 1). Our response argues that there is considerable scope for energy savings even from simply improving enforcement of the existing ecodesign and energy label regulations in the UK. A particular area of concern is that the UK appears not to be checking compliance of the energy label online or in store, as this reduces the effectiveness of the energy label to change consumer behaviour. There is also room for improvement in terms of ecodesign market surveillance: so together these should increase the effectiveness of existing policies at relatively low cost.

In addition, there are considerable risks to UK consumers and manufacturers in moving away from EU standards (option 3).

We strongly recommended fully exploiting the savings potential of options 1 and 2 before considering option 3.

Option Timescale to
Cost (£) to
Actors and
skills needed
1. Enhanced
Months Tens to hundreds
of thousands
Office for Product
Safety and Standards,
Local authority
trading standards
2. Additional
supporting policy
Months-years Depends on policy,
less than option 3
Central government,
policy makers,
technical expertise
Resistance from
depending on
3. UK-specific
4 years plus Several million Central government
policy makers,
deep techn. expertise
Serious trade
issues, additional
costs to UK
additional costs
to manufacturers.

These policy options are all described in detail with supporting evidence in the full response.

The views expressed in this column are those of the columnist and do not necessarily reflect the views of eceee or any of its members.

Other columns by Fiona Brocklehurst