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Ecodesign sets requirements for energy efficiency in the form of limit values for power consumption in watts per specific function, as an energy efficiency index, efficiency or utilisation ratio, for specific pollutants in the form of emission limit values, for fitness for use, for the availability of spare parts and repair information and for product information.

Ecodesign is an EU success story. Environmental aspects are increasingly taken into account in product design and consumers can better assess energy efficiency. The move towards more sustainability in the revision of the Ecodesign Directive is also welcome. However, the main consideration of energy consumption in the use phase is outdated and distracts from other, important aspects, for example in the life cycle of a product. The products of the manufacturers in the HKI Association are all very durable and repairable. These aspects must be more strongly recognised and will also be incorporated in the sustainable product policy initiative in the EU's ecodesign regulation. 

The HKI opposes the automatism that can be observed in the regulations. They are extended and tightened without looking at where a pragmatic way could be, where exactly potential for improvement lies and how they can be lifted together with the market and not bypassing it. For in the meantime, a high standard has been created that can also be jeopardised by such unilateral state intervention. The market concentration of a few competitors is also a worrying development.