New EU Vacuum Cleaner Regulations likely promoted with false claims

Summary

On September 1st, the EU Commission launched new regulations limiting the maximum power of vacuum cleaners to 900 watts.  A news item claimed

The updated rules will result in vacuum cleaners that use less energy for a better cleaning performance. This will help consumers to save money, as switching to a more efficient product can save €70 over its lifetime.

Elsewhere the is a claim that “with more efficient vacuum cleaners, Europe as a whole can save up to 20 TWh of electricity per year by 2020.

There is no reference to the source of the claims. Pulling in data from various sources I have calculated how the figures may have been derived. Based on these figures it would appear

  • The assumed savings are 200 kWh per vacuum cleaner, based on switching from a 1600 watts to a 900 watts, and 290 hours of use over the average lifetime.
  • This ignores that many vacuum cleaners are below 1600 watts due competition, not rules in place.
  • Cost savings are based on the average electricity costs in the EU, when in reality electricity costs in the most expensive country are 2.6 times that of the cheapest.
  •  Cost savings are not net of cost increases, such as more time spent cleaning and increase costs of the appliance.
  • Claims of reduction in electricity consumption are based on the requirement that all 350 million vacuum cleaners of 1600 watts are replaced by 900 watt cleaners by the start of 2020.

If any business made bald unsubstantiated claims about a new product, it would be required to back up the claims or withdraw them. Morally, I believe the EU Commission should aspire to emulate the standards that it imposes on others in marketing its own products. A law making Authority cannot be regulated and brought to account for the harms it causes. But I feel that it owes its citizens a moral duty of care to serve them, by minimizing the harms that it can cause and maximising the benefits.

The Launch of the New Regulations

BBC had an article on September 1st Sales of inefficient vacuum cleaners banned

They state

The EU’s own website says: “With more efficient vacuum cleaners, Europe as a whole can save up to 20 TWh of electricity per year by 2020.

“This is equivalent to the annual household electricity consumption of Belgium.

“It also means over 6 million tonnes of CO2 will not be emitted – about the annual emissions of eight medium-sized power plants.”

Although the BBC do not link to the webpage among millions. A search on the phrase reveals the following link.

http://ec.europa.eu/energy/en/topics/energy-efficiency/energy-efficient-products/vacuum-cleaners

Vacuum cleaners are subject to EU energy labelling and ecodesign requirements. By switching to one of the most energy efficient vacuum cleaners, you can save €70 over the lifetime of the product.  With more efficient vacuum cleaners, Europe as a whole can save up to 20 TWh of electricity per year by 2020. This is equivalent to the annual household electricity consumption of Belgium. It also means over 6 million tonnes of CO2 will not be emitted – about the annual emissions of eight medium-sized power plants.

There are no references to where the figures come from.

Another source is much nearer in the menu tree to the EU homepage and is on a news page.

http://ec.europa.eu/energy/en/news/updated-energy-efficiency-rules-vacuum-cleaners-will-save-consumers-money

Updated energy efficiency rules for vacuum cleaners will save consumers money

Friday, 01 September 2017

From today, vacuum cleaners sold in Europe will be more cost- and energy-efficient. The European Commission is making use of the latest state-of-the-art technologies to ensure that European consumers have the most energy efficient products available. The updated ecodesign requirements will lower appliances’ maximum power, annual energy consumption and noise levels. They will also increase their minimum ability to pick up dust.

The updated rules will result in vacuum cleaners that use less energy for a better cleaning performance. This will help consumers to save money, as switching to a more efficient product can save €70 over its lifetime. With more efficient vacuum cleaners, Europe as a whole will be in a position to save up to 20 TWh of electricity per year by 2020.

Like with the first EU source (which this press release links backed to) there is no reference to the source of the claims.

Establishing the calculations behind the claims

However, there the claims that together with other data and some assumptions have enabled me to piece together the numbers behind the claims. These are:-

  1. The maximum of 20 TWh of electricity that could be saved by 2020. There are one billion kilowatt hours in a terawatt hour.
  2. According to Eurostat’s Household Composition Statistics, there are 495.6 million EU citizens living in households, with an average 2.3 persons per household. That is around 215 million or maybe 210 million households.
  3. There is more than one vacuum cleaner in the average household.
  4. All vacuum cleaners are operated at maximum power all the time.
  5. All current vacuum cleaners are 1600 watts. By 2020 they will all be at 900 watts.
  6. Life of the average vacuum cleaner is five years. This I worked out from slotting in other variables.

 

To understand how many kilowatt hours in the maximum cost saving of €70, one needs to know the cost of a unit of electricity. In a recent post on electricity prices in South Australia, Joanne Nova provided a graphic based on data from MARKINTELL, US Energy Information Administration. Based on this I have produced a graphic showing that if Denmark, where electricity is most expensive, a person saved €70 on their electricity bill, the savings in most of the other EU countries.

If the Danes will save €70 from buying a vacuum cleaner under the new regulations, in the UK the saving will be about €49, France €39 and in Hungary and Estonia just €27. This is because of the huge difference in electricity costs, with Danish electricity being 2.6 times that in Hungary and Estonia. It is a simple step to work out the number of kilowatt hours of electricity saved for a spend of €70.  Assuming $1.00 = €0.85, the next graph shows how many units of electricity will be saved in each country.

If the EU Commission had properly checked its figures, when quoting the maximum saving, will base it on the highest electricity rates in the EU, and not the average rates. They will, therefore, assume that the maximum savings for the EU will be around 133 kilowatt hours and not 200 kilowatt hours. Otherwise, the maximum savings in Denmark, Germany, Italy and Portugal could be greater than the claimed maximum, whilst people in some other countries with lower than average electricity costs will be misled as to the extent of the possible savings.

I have put together a table that fits the assumptions and known variables based on €70 of savings in both Denmark and the fictional EU average.

The 200 kWh saving over a five-year vacuum cleaner life seems more reasonable than 133 kWh. The 350 million vacuum cleaners in the EU or two for every three people, seems more reasonable than 538 million, which is both less of a rounded estimate and would mean around 35 million more vacuum cleaners than people. The assumption that the average household spends 1 hour and 50 minutes per week vacuuming might be a bit high, but there again I know of people who regularly exceed this amount by quite a margin.

Based on how the numbers fit the maximum saving of €70 per vacuum cleaner to have been based on the average cost of electricity in the EU. As such it is an incorrect statement. There are other issues that arise.

Evaluating the claims

There are other issues that arise from consideration of these figures, though are not necessarily solely reliant upon those figures.

First, the 26TW of savings is if all the current vacuum cleaners (assumed to be at 1600W rating) will be replaced by the start of 2020. That is in just 2.33 years. If vacuum cleaners have an average five-year life, many people will be scrapping their existing vacuum cleaners before the end of their useful life. Even with a maximum marginal cost saving of €14 a year, this would mean incurring unnecessary additional costs and throwing out perfectly serviceable vacuum cleaners. However, if they replace a 2000 watt or higher vacuum cleaner purchased prior to September 2014, then the savings will be much higher. In which case the EU Commission News item should have noted that some savings were from regulations already in place.

Second is that many households have an old vacuum cleaner in reserve. They may have it for a number of reasons, such as having upgraded in the past, or purchased it prior to the regulations came into force in 2014. So when their main vacuum cleaner finally keels over, they will not purchase a low powered one. It will be therefore very many years before anything approaching 100% of existing vacuum cleaners have been replaced, especially if the perception is that the newer products are inferior.

Third, is an assumption that every vacuum cleaner is on the limit of the regulations. Greater efficiency (saving money) is something people are willing to pay for, so the market provides this anyway without the need for regulation, just as people pay for more fuel efficient cars. It is only the people who max out on the power permitted that will be affected to the full extent. As greater power is a cheap way of increasing performance, this will most affect the cheapest cleaners. The poor and those setting up a home for the first time (with severe budget constraints) are likely to be those most disadvantaged, whilst those who are willing and able to upgrade to the latest gadgets will make the lowest savings.

Fourth, the cost savings appear to be only on electricity costs. The extra costs of upgrading to a more technologically advanced machine that compensates for the loss of power, does not appear to have been taken into account in the calculations. If it had, then the electricity savings would have to be much greater, to include the additional costs. In which case, the fictional European average household would have to be saving far more on their electricity than €70. Let us say people upgrade from a €100 to €300 machine, both with a five year average life. To make €70 of savings over five years a Danish household would have to be running their vacuum cleaner for nearly three hours a week, a British or Dutch household over four hours per week, and the Hungarian and Estonian households over seven hours a week. But this defies other assumptions and would also shorten the average life of a vacuum cleaner. No allowance appears to have been made for more expensive vacuum cleaners.

Fifth, there are other, simpler ways of replacing the loss of suction from lack of power than technological wizardry that pushes up costs. The simplest is to reduce the area in contact with the floor. This means that people spend more time using the machines, offsetting some of the energy savings. Alternatively, there could be some loss of suction, which again means people spend more time cleaning, and getting frustrated due to the lack of performance. Some of this could be by more frequent swapping of cleaning heads. If you value people’s leisure time at just €5.00 an hour, then over the short five year life of a cleaner (about 290 hours based on 65 minutes a week of use), the average household will “lose” the €70 of electricity savings if they have to spend more than 5% more time cleaning. In reality it will be much more, and many people will feel aggrieved at having a less efficient machine.

Sixth is that the extra power can be used for simpler, proven and more robust technologies. Efficiency savings come about through complex optimisation strategies, reducing the life of cleaners.

So the claim by the EU that people will save money from the new regulations seems to be false for any one of a number of reasons. More likely than not people will be made net worse off by the regulations. Further the alleged benefits from the new regulations in terms of savings in electricity (and hence CO2 emissions) seems to have been grossly exaggerated.

But won’t there be a massive saving in CO2 emissions?  Even if the 6 million tonnes of emissions saved is in the more distant future, it is still a far large number. In terms of a small country like Belgium, it is a large amount. But considered in the context of EU’s INDC submission to the Paris climate talks it is quite small.

The EU and its Member States are committed to a binding target of an at least 40% domestic reduction in greenhouse gases emissions by 2030 compared to 1990,

From the accompanying country brief, the 1990 emissions were 5368 mtCO2e, so a 40% cut is 2147 mtCO2e. In 2012 emissions were 4241 mtCO2e (mostly for non-policy reasons) so there is just 1020 million tonnes to cut. 6 million is just 0.6% of that target.

On a global perspective, even with all the vague policy proposals fully enacted, global emissions by 2030 will be nearly 60,000 MtCO2e and will still be rising. There seems no prospect of additional policies being proposed that would start reducing global emissions. A policy that makes around 0.01% of the difference to the larger picture is inconsequential. To achieve the policy goals a few thousand similar-sized schemes are required. Nothing like that is going to happen. Countries in the developing world, with over half the global population, will see emissions will grow for decades, dwarfing any reductions made in the EU.

Concluding comments

The new vacuum cleaner regulations appear to be justified on the basis of grossly exaggerated and untenable claims of the benefits in terms of cost savings and reductions in GHG emissions, whilst ignoring the costs that they impose.

If any business made bald unsubstantiated claims about a new product, it would be required to back up the claims or withdraw them. If such sweeping claims were made about a new product such as anti-aging creams or vitamin pills, that could be attributed to other factors, then it would be prosecuted. Morally, I believe the EU Commission should aspire to emulate the standards that it imposes on others in marketing its own products. A law making Authority cannot be regulated and brought to account for the harms it causes. But I feel that it owes its citizens a moral duty of care to serve them, by minimizing the harms that it can cause and maximising the benefits.

Kevin Marshall