Dyson-Position-Paper-Eco-Design-And-Energy-Labelling-For-Vacuum-Cleaners.Pdf
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Dyson Position PaperPaper:: Eco Design and Energy Labelling for vacuum cleaners Introduction Dyson has reviewed with interest the working documents for implementing Eco-design and Energy labelling directives for vacuum cleaners. Europe has committed to reducing its environmental impact by 30% by 2020, when compared to 1990 levels. There is an opportunity for vacuum cleaners to contribute towards this target. The majority of vacuum cleaners’ environmental impact is accounted for in the use phase. Limiting the amount of power that a vacuum cleaner can use will have a positive environmental impact. Dyson broadly agrees with and supports the Commission’s recommendations to achieve this. The working documents rightly acknowledge that the implementing measures for vacuum cleaners need to incorporate energy consumption, performance and usability. However, Dyson considers that the Commission could implement more stringent thresholds to achieve greater energy savings. Measures also need to be representative of consumer use and easily verified. Reasoning The working documents operate in tandem, therefore Dyson’s response deals with the issues relating to both eco design and energy labelling. Dyson broadly agrees with and supports the Commission’s recommendations. In particular, Dyson supports: o Power caps, reflecting annual energy consumptionconsumption:::: These are an effective way to drive energy efficient design, will lower energy consumption and can be achieved without sacrificing performance. 1 o Separation of energy and performance metricsmetrics:::: A previously discussed, combined method was based on the flawed assumption that people vacuum for less time when their vacuum cleaner achieves high dust removal.2 Furthermore, the method proved expensive to implement, enforce and impossible to reliably reproduce. o Penalties for overly high push forceforceforce:force When cleaning hard floors and carpet, suction alone is not sufficient. Cleaner head design is critical in ensuring good pick up levels. A balance between the push force applied and the dust pick up is needed to ensure machines achieves high performance whilst remaining usable. 3 4 Dyson recommends the Commission further enhance the proposals so the implementing measures are reproducible, representative of user experience, achieve energy savings and provide the consumer with relevant and accurate product information. 1 Appendix A – High dust removal can be achieved with limited power input 2 Appendix B – Dust removal performance and cleaning time 3 Appendix C – Graph of EU machines from different manufacturers showing little correlation between dust removal from carpet and push force applied 4 Appendix D – Details from a survey of 100 German women where 95% reduced the suction on the machine until a push force of 21N to use it 1 This can be achieved with the following measures: 1.1.1. Dust removal tests conducted in a realistic state Most vacuum cleaners lose suction the moment they start being used. 5 The loss of suction reduces the ability to remove dust. Testing with a clean bin or new bag produces results that are misleading and unrepresentative of the performance in the home. 6 Measurement and calculation methods should be conducted using dust loaded machines to the point when bin or bag full is reached. Dust loaded machines will give realistic results providing the consumer with accurate information. 2.2.2. Further reduced limits on annual energy consumption The annual energy consumption of vacuum cleaners can be 1100W (circa 40kWh) after 2 years from implementation, reducing to 750W (circa 28kWh) after 5 years without sacrificing performance or consumer choice 7. Research shows that in 1994, many European manufactures had cylinder machines on the market between 1200W and 1500W and uprights between 575W and 900W.8 While power use has increased in some European markets 9 most European manufacturers have machines under 1200W in their ranges. 3.3.3. Annual use of consumconsumaaaabbbblesleslesles Throw-away filters and bags impact the environment through distribution and waste as well as a significant cost to the consumer. The number of bags and filters required per annum would be an easy declaration for any manufacturer to make. Surveys of over 2400 people across Europe show that 50% of people will use over 7.5 bags a year. And with many manufacturers recommending to additionally replace filters annually, the tally of consumables over five years is significant. 10 4.4.4. Five double pass performance. Dust removal on carpets and hard floors is important to the consumer. Testing must be representative of the performance seen in the home and also be reproducible. While it is likely that consumers perform less than five double passes in the home, changing from two to five double passes produces better reproducibility as identified by CENELEC’s round robin testing. 11 This is also in line with IEC test standards which manufacturers already test to, such limiting complexity and cost for manufacturers. 5 Appendix E – Dust loading results for a typical bagged vacuum cleaner 6 Appendix F – Clean and dust loaded dust removal for European cylinder vacuum cleaners (IEC 60312) 7 AEA, Work on Preparatory Studies for Eco Design, Requirements of EuPs (II). Lot 17 vacuum cleaners. TREN/D3/390-2006 Final Report, P31 8 Appendix G – Table showing machines available for sale in Argos catalogue in 1994 9 Appendix H – Power trends in Germany, France and UK 10 Appendix I – Summary of survey showing Median bag replacement across Europe 11 Appendix J – Results showing the less variability at two double passes compared to five 2 Appendix A High dust removal can be achieved with limited power input The following graphs (IEC 60312 dust removal from hard floors with crevices, and carpet tests) show no direct correlation between dust removal performance and motor power. Machines with both high and low rated motor power can achieve the same IEC performance as shown with the highlighted boxes. IEC 60312 Hard Floor with Crevice Pickup Vs Rated Motor Power 120 (%). 100 80 60 40 20 IEC 60312 Dust60312 Hard IECfrom from Floor removal Crevices 0 0 500 1000 1500 2000 2500 3000 Rated Motor Power(W) IEC 60312 Dust removal from carpet Vs Rated Motor Power 100 90 80 70 60 50 40 30 IEC 60312IEC Dustremoval fromcarpet (%) 20 10 0 0 500 1000 1500 2000 2500 3000 Rated Motor Power(W) 3 Appendix B Dust removal performance and cleaning time The results below are the raw results for the first four weeks of a blind trial with 30 trialists, where each trialist has used both a high performing (80% Wilton and 100% on crevice) and lower performing machine (70% Wilton and 5% crevice) for two weeks each. These differences are highly significant using the IEC 60312 tests. There is little change in cleaning time. At first glance it even seems people spent on average less time cleaning with the lower performing machine than the high performing machine; although when a statistical test was performed it showed no significant difference between the two datasets. Figure 1: Time taken (minutes) cleaning over a two week period with high performing vacuum cleaner. Figure 2: Time taken (minutes) cleaning over a two week period with the same model modified to give low performance. 4 Appendix C Graph of EU machines from different manufacturers showing little correlation between dust removal from carpet and push force applied 100 90 80 70 60 50 Pickup (%) Pickup 40 30 20 Push average 10 0 0 10 20 30 40 50 60 IEC Motion resitance Av. (N) 5 Appendix D Details from a survey of 100 German women where 95% reduced the suction on the machine until a pushpush force of 21N to use it Results from push force survey of 100 German women where they were asked to use a vacuum cleaner for 5 minutes in the maximum mode on carpet. Before being asked to use the vacuum cleaner again they were then shown the instruction manual and told about the various settings. 95% turned the machine down to 21Newtons or less. Favourite VC setting after being told about settings and allowed to change Equivalent pushforce of setting participants machine (N) Base 100 Lower VC setting (1) 11% 10.6 Middle VC setting (2) 59% 13.6 High VC setting (3) 26% 21.2 Turbo VC setting (4) 3% 28.1 Did not change the VC at all (Turbo = 4) 2% 28.1 6 Appendix EEE Dust loading results for a typical bagged vacuum cleaner Dust loading graph for a typical bagged vacuum cleaner showing the loss in airflow as the bag is loaded with dust until the bag full is indicated. As the airflow of the machine drops, the machine performance drops as the cleaner head is tuned for the clean airflow characteristics. Testing is based on IEC 60312 clause 2.9 Air flow & air watts vs dust loading 40 350 32 280 24 210 16 140 Air (l/sec) FlowAir Output (Air (Air Watts) Output 8 70 0 0 0 50 100 150 200 250 300 350 400 450 500 Dust Load (g) 7 Appendix FFF Clean and dust loaded dust removal for European cylinder vacuum cleaners (IEC 60312) Some machines retain their dust removal through use, most machines’ dust removal declines quickly. The following two graphs show the effect of dust removal on the IEC carpet and IEC crevice test when the machines have been loaded with test dust. The IEC 60312 standard takes this into account with a section on performance of vacuum cleaners with dust loaded receptacles. The majority of machines show a significant drop in dust removal performance. IEC Wilton Pick-up UK EU Cylinders 100 Clean 90 Loaded 80 70 60 50 40 Dust removal onIEC carpet (%) Dust removal 30 20 10 0 IEC Crevice Pick-up UK EU Cylinders 120 Clean Loaded 100 80 60 40 Dustremoval (%) onIECcrevice 20 0 8 Appendix GGG Table showing representative selection of machines available for sale in Argos catalogue in 11994.994.