16 02 26 CWP 08-12 UA Draft Task Report

INOGATE Country Work Plan Ukraine
Technical Assistance to SAEE in the transposition of the

EU Legal Acts on Energy Labelling and Ecodesign into
Ukrainian Legislation. Support of the VII International
Investment Business Forum on Energy Efficiency and
Renewable Energy (CWP.08/12.UA)
Task Report
INOGATE Technical Secretariat and Integrated Programme in Support of
the Baku Initiative and the Eastern Partnership Energy Goals
Contract 2011/278827
A project within the INOGATE Programme
Implemented by:
Ramboll Denmark A/S (lead partner)
EIR Global sprl.
The British Standards Institution
LDK Consultants S.A.
MVV decon GmbH
ICF International
Statistics Denmark
Energy Institute Hrvoje Poar
January 2016
Name of the
Document
Technical Assistance to SAEE in the transposition of EU Legal Acts on Energy

Labelling and Ecodesign into Ukrainian Legislation. Support of the VII
International Investment Business Forum on Energy Efficiency and Renewable
Energy (CWP.08/12/UA) Task Report
Status of the
document
Draft
Name
Date
Prepared by
W.F. Lutz, T. Lock, A. Antonenko, A.

Cherniavskyi
10/01/2016
Reviewed by
M. Allington, W.F. Lutz
15/01/2016
Approved by
P. Larsen
This report has been prepared with the support of the European Union. The content of this report is the
sole responsibility of the experts and can in no way be taken as reflecting the views of the European Union.
Content
Abbreviations ........................................................................................................................................... 5
Executive Summary.................................................................................................................................. 6
1. Introduction ....................................................................................................................................... 10
2. Background ....................................................................................................................................... 12
2.1. Energy labelling and Ecodesign in Ukraine ................................................................................ 12
2.2 The process of approving Technical Regulations ........................................................................ 13
2.3 Baseline indicators ...................................................................................................................... 16
3. Review of draft Technical Regulations for Energy Labelling of Energy-related Products.................. 16
4. Translation of EU Ecodesign Regulations and of existing Technical Regulations for Energy Labelling
of Energy-related Products ............................................................................................................... 19
4.1. Translation of EU Ecodesign Regulations................................................................................... 19
4.2. Translation of existing Technical Regulations of Energy-related Products ............................... 19
5. Transposition of the EU Ecodesign Directive into Ukrainian Legislation ........................................... 19
5.1. Scope.......................................................................................................................................... 19
5.2. Methodology.............................................................................................................................. 20
5.2.1. Meetings with SAEE and stakeholders ......................................................................... 21
5.2.2 Review of legal documents............................................................................................ 22
Strategy of development of the system of technical regulation until 2020.............. 24
5.3. Evaluation of options ................................................................................................................. 24
5.4. Conclusions and Recommendations .......................................................................................... 26
6. Prioritisation of the Introduction of Ecodesign Technical Regulations in Ukraine ............................ 31
6.1. Scope.......................................................................................................................................... 31
6.2. Methodology.............................................................................................................................. 32
6.3. Results ........................................................................................................................................ 33
6.3.1 Criterion 1 Prioritisation by Commitments within the Action Plan for the
Implementation of the Association Agreement ........................................................ 33
6.3.2 Criterion 2 Prioritisation by Complementing product groups in Ukraine which
already have an existing Energy Labelling Technical Regulation with an Ecodesign
Technical Regulation.................................................................................................. 33
6.3.3 Criterion 3 Prioritisation by Level of Technical Complexity and Contentiousness ..... 34
6.3.4 Criterion 4 Prioritisation by Projected EU Energy Savings by 2020 ............................ 35
6.3.5 Prioritisation .................................................................................................................. 39
Calculation Method ................................................................................................... 39
Prioritised Order ........................................................................................................ 39
6.4 Conclusions ................................................................................................................................. 41

7. Harmonised Standards for Products Covered by Ecodesign and Energy Labelling Regulations ....... 42
7.1 Scope........................................................................................................................................... 42
7.2 European Harmonised Measurement Standards and Transitional Methods of Measurement. 43
7.2.1 Scope ............................................................................................................................. 43
7.3 European Harmonised Measurement Standards and Transitional Methods of Measurement. 44
8. Support to the VII International Investment Business Forum on Energy Efficiency and Renewable
Energy ............................................................................................................................................... 45
8.1 Workshop "Ecodesign: the experience of the EU and first steps of Ukraine" ............................ 45
8.2 Workshop "Awareness Raising for Energy Efficiency"................................................................ 46
8.3 Experts zone................................................................................................................................ 46
8.4 Logistical support ........................................................................................................................ 46
9. Further steps ...................................................................................................................................... 46
10. Conclusions and Recommendations ................................................................................................ 47
List of Annexes and Appendices ............................................................................................................ 50
Abbreviations
CDR
Commission Delegated Regulation
CEN
European Committee for Standardisation
CENELEC
European Committee for Electrotechnical Standardisation
CMU
Cabinet of Ministers of Ukraine
DCFTA
Deep and Comprehensive Free Trade Area
DG NEAR
Directorate-General for Neighbourhood and Enlargement Negotiations
EBA
European Business Association
EC
European Commission
ErP
Energy-related product
ETSI
European Telecommunication Standards Institute
EU
European Union
ITS
INOGATE Technical Secretariat
Mtoe
Million tonnes of oil equivalent
OJEU
Official Journal of the European Union
PJ
Petajoule
SAEE
State Agency for Energy Efficiency and Energy Saving of Ukraine
SGUA
Support Group for Ukraine of the EC
ToR
Terms of Reference
TR
Technical Regulation
TWh
Terawatt-hour
Executive Summary
Ukraine has made considerable progress in the transposition of EU legislation in the field of Energy
Labelling and is undertaking first steps towards Ecodesign. In the field of Energy Labelling, the EU
Directive 2010/30/EU and four Commission Delegated Regulations (CDR) for energy-related products
have been transposed into Ukrainian legislation, with seven more product-specific regulations in
different stages of elaboration and approval. While the transposition of the Energy Labelling
Directive and of CDRs for energy-related products is an obligation under the Energy Community
Treaty, the transposition of the Ecodesign Directive 2009/125/EC is a requirement under the EU
Ukraine Association Agreement.
This assignment was carried out by the INOGATE Technical Secretariat (ITS) following a request
received from the State Agency for Energy Efficiency and Energy Saving of Ukraine (SAEE), in
accordance of the INOGATE Country Work Programme Ukraine, the "Work Plan 2015" agreed upon
between SAEE and ITS, and the Terms of Reference (ToR) for this activity approved by the European
Commission (EC), DG NEAR. The assignment covered various tasks, which refer both to Energy
Labelling and Ecodesign, and were finalised within the timeframe agreed upon with SAEE:
Translations of EU Ecodesign Regulations into Ukrainian and of existing Ukrainian Technical

Regulations (TR) for Energy Labelling of energy-related products into English;
The review of five draft TRs for Energy Labelling;
Advise with regard to the most appropriate legal option to transpose the EU Ecodesign
Directive into Ukrainian legislation;
Advise with regard to the prioritisation of the introduction of Ecodesign TRs for energyrelated products (ErPs) in Ukraine;
Provide a list of European harmonised measurement standards for products covered by
existing and future Ecodesign and Energy Labelling Regulations in Ukraine;
Support to the VII International Investment Business Forum on Energy Efficiency and
Renewable Energy (10-13th November 2015), in particular the organisation and
implementation of workshops on Ecodesign and Awareness Raising, and the implementation
of an Experts' Zone.
While the translations of EU Ecodesign Regulations into Ukrainian and of existing Ukrainian TRs for
Energy Labelling into English were straightforward services provided to SAEE, the review of the draft
TRs for Energy Labelling of household tumble driers, household ovens and range hoods, vacuum
cleaners, air conditioners and water heaters, were embedded in the process of approving these TRs,
which involves several stages of stakeholder consultation, review by different Ministries and other
public authorities, and finally by the Cabinet of Ministers of Ukraine (CMU). The understanding of
this process, which is described in detail in Section 2.2 of this report, as well as of relevant pieces of
Ukrainian legislation, is essential to address the comments which SAEE received in different stages of
the approval process appropriately. Both translations and reviews of draft TRs were submitted to
SAEE and are included in the appendices to this report.
Regarding Ecodesign, a critical question concerns the most appropriate legal option to transpose the
EU Ecodesign Directive. Based on meetings with SAEE and stakeholders, a review of relevant primary
and secondary legislation, and an evaluation according to relevant criteria and arguments brought
forward in favour and against, the following three options were analysed by ITS: transposition (1) as
a Law of Ukraine, (2) as a TR based on a Resolution of the Cabinet of Ministers of Ukraine, and (3) as
an Article of the new Energy Efficiency Law, which requires the transposition of the Directive as TR
by Resolution of the Cabinet of Ministers.
Among the arguments in favour and against each option, the following arguments are considered to
be most relevant:
1. Transposition as, or foundation of, the Ecodesign Directive in primary legislation is expected
to provide a more stable legal framework, more leverage to the Government for
enforcement and higher investor confidence, and should therefore be seriously considered;
2. However, the very long periods usually required by the Ukrainian Parliament for passing
laws are a major concern, and represent a strong argument for pursuing transposition of the
Directive by a TR based on a Resolution of the Cabinet of Ministers, taking also into
consideration the positive experience in transposing the Energy Labelling Directive in 2013;
3. Relevant legal documents stipulate that the transposition of the Directive must be as a legal
act (technical regulation) of the Cabinet of Ministers;
4. Based on stipulations of the Law of Technical Regulations and Compliance Assessment, the
Cabinet of Ministers may require the transposition of the Directive as a TR.
It was found that Option 3 (Transposition as Article of the new Energy Efficiency Law which requires
the transposition of the Directive as TR by Resolution of the Cabinet of Ministers) is the only option
which satisfies all criteria and is therefore recommended as the preferred option, which will
facilitate the timely implementation of the Directive, and at the same time ground it in a Law of
Ukraine, thereby giving it legal force and providing stability to inspire investor confidence.
A second important question concerns the order of priority in which to transpose and adopt the 22
Ecodesign TRs, which are due to be transposed as part of Ukraine's commitment under the EU
Ukraine Association Agreement. In order to establish an order of priority, ITS applied the following
criteria, which had been agreed upon with SAEE:
1. The Ecodesign product group commitments made within the Action Plan for the
Implementation of the Association Agreement in 2014;
2. The complementarity of introducing an Ecodesign TRs for a product group that in Ukraine
already has an existing Energy Labelling TR;
3. The anticipated level of technical complexity and contentiousness involved within the
process to develop, consult, adopt and implement the product specific TRs;
4. The expected energy savings as a result of the implementation of the individual product
specific TRs.
The application of these criteria results in four orders of priority and the ranking shown in Table 6.4.
The list starts with the product groups cited in Resolution #847, including simple set top boxes,
external power supplies, and tertiary and non-directional lighting. The second order of priority
includes those product groups which already have an Energy Labelling regulation, including
household appliances such as refrigerators and washing machines. The list concludes with the
remainder of the residential and household products and space heaters. Industrial products are at
the bottom of the list only because they are not included in Resolution #847 and they are not subject
to existing Energy Labelling regulations in Ukraine (or the EU). The energy savings possible from this
industrial group, especially from electric motors, fans and circulators, are particularly high and are
rightfully the subject of a separate industrial products initiative from SAEE.
In order to implement the CDRs for Energy Labelling and Regulations for Ecodesign of energy-related
products, it is necessary to make use of measurement standards, which allow the declaration and
verification of the technical parameters required by the respective regulations. The EC has therefore
mandated the European standardisation bodies CEN, CENELEC and ETSI to elaborate appropriate
European harmonised measurement standards for energy-related products regulated under the EU
Energy Labelling and Ecodesign Directives.
According to Ukrainian legislation, all international (including European) standards to be applied in
Ukraine must be adopted as Ukrainian National Standards. In order to facilitate SAEE's work with the
respective Standardisation Committees in Ukraine, ITS established and submitted to SAEE a list of
standards and transitional methods of measurement which apply to the 22 product groups under
consideration. Annex 5 to this report provides lists of product groups with European Harmonised
Standards, product groups with Transitional Methods of Measurement, and product groups without
either European Harmonised Standards of Transitional Methods of Measurement, indicating the
respective standards or transitional methods for measurement and/or EC mandates, and their
applicability to Ecodesign and Energy Labelling.
Further to the Technical Assistance on Energy Labelling and Ecodesign, ITS contributed to the VII
International Investment Business Forum on Energy Efficiency and Renewable Energy, which was
organised by SAEE from 10 to 13 November 2015 in Kyiv, by organising and implementing workshops
on "Ecodesign: the experience of the EU and first steps in Ukraine" and "Awareness Raising for
Energy Efficiency", as well as by providing an experts' zone and by providing logistical support to the
Forum.
The workshop Ecodesign: the experience of the EU and first steps of Ukraine, in particular,
focussed on past and current developments in Ecodesign in the EU, and on SAEE's current activities
in this field. The workshop provided an opportunity to review the past and current work of SAEE on
Energy Labelling, and to discuss first steps towards the transposition of the EU Ecodesign Directive
2009/125/EC and of specific regulations for energy-related products.
In accordance with the Terms of Reference, the overall objectives of this assignment were: (i) further
approximation of Ukraine with the EU legislation in the field of energy efficiency, and (ii) to
contribute to the improvement of energy efficiency through the transposition of further CDRs for
Energy Labelling and through preparatory activities which will facilitate the transposition of the EU
Ecodesign Directive and of Ecodesign Regulations for energy-related products.
The baseline situation is reflected by the current status of implementation of Energy Labelling
Regulations in Ukraine and by the status of preparatory steps taken by SAEE so far to transpose the
Ecodesign Directive and the product-specific Ecodesign regulations. Key tangible results are
considered to be: (i) the submission for adoption by Resolutions of the CMU of the five draft energy
labelling TRs reviewed by the ITS experts under this assignment, (ii) the elaboration of Ecodesign
TRs, based on the EU Ecodesign Regulations, translated by ITS into Ukrainian, according to the "work
plan" agreed upon, (iii) improved capacity and awareness of decision makers, experts and the
interested public on Energy Labelling and Ecodesign, due to the delivery, by ITS experts, of the
workshop "Ecodesign: the experience of the EU and first steps of Ukraine and of the experts' zone
and leaflets distributed at the VII International Investment Business Forum on Energy Efficiency and
Renewable Energy (10 to 13th November 2015), (iv) the approval by SAEE of the proposal of ITS with
regard to the most appropriate legal option to transpose the Ecodesign Directive, and further steps
taken by SAEE to its transposition, (v) the approval by SAEE of the proposal of ITS with regard to the
prioritisation of ErPs to be regulated, and further steps taken by SAEE to the adoption of Ecodesign
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TRs according to this prioritisation, and (vi) the adoption as Ukrainian national standards of the
European harmonised measurement standards required to implement the required TRs on
Ecodesign and Energy Labelling in Ukraine, in accordance with the updated and complete list
delivered by ITS. The achievement of these results will be verified according to the standard
INOGATE monitoring procedures in March 2016.
1. Introduction
The assignment was carried out in compliance with the "Work Plan for 2015" signed between SAEE
and ITS on 15th July 2015 (Annex 1), and the ToR approved by EC DG NEAR on 8th October 2015.
The "Work Plan" defines two major areas of cooperation: (a) Technical Assistance for the
Implementation of Energy Labelling and Ecodesign in Ukraine, and (b) Support of the VII
International Investment Business Forum on Energy Efficiency and Renewable Energy to be held in
Kyiv from 10 to 13 November 2015.
The scope of work according to the ToR included the following tasks:
(a) Technical Assistance for the Implementation of Energy Labelling and Ecodesign
1. Provide experts' opinion with regard to the following five drafts of Technical Regulations (TR)
for Energy Labelling of products, which were elaborated by SAEE: Draft TRs for air
conditioners, ovens and range hoods, household tumble driers, water heaters and space
heaters.
2. Provide translations of ten Ecodesign regulations for the following energy-related products:
(i) air conditioners and comfort fans, (ii) water pumps, (iii) household tumble driers, (iv)
directional lamps, LED lamps and related equipment, (v) computers and computer servers,
(vi) vacuum cleaners, (vii) space and combination heaters, (viii) water heaters and hot water
storage tanks, (ix) domestic ovens, hobs and range hoods, (x) small, medium and large
power transformers.
3. Advise SAEE with regard to the most appropriate legal option to transpose the EU Ecodesign
Directive into Ukrainian legislation, and provide experts' advice with regard to the structure
and contents of the proposed legal document, taking into consideration its compliance with
the EU Directive and with national laws and regulations in relevant areas, like consumer
protection and public procurement.
4. Provide experts' advice with regard to the transposition of EU Ecodesign regulations into
Ukrainian Technical Regulations: prioritisation of products; structure and contents of the
proposed technical regulations, taking into consideration the compliance with the respective
EU Regulations.
5. To review and complete the list of European Harmonised Standards (elaborated under the
EU Twinning Project), which have been elaborated by the European Standardisation
Institutes CEN/CENELEC and ETSI under standardisation mandates of the EC to these
institutes under Directive 2009/125/EC, for products to be regulated in Ukraine, including
the verification of the status of completion of these standards (draft, final, date of
publication in the OJEU).
6. To assist SAEE in the preparation of a report to the Energy Community Secretariat on the
progress in introducing Energy Labelling and Ecodesign regulations in Ukraine, taking into
consideration the progress and results of the tasks carried out in this activity.
(b) Support to the VII International Investment Business Forum on Energy Efficiency and Renewable
Energy
7. To prepare, organise and implement a half-day workshop Ecodesign: the experience of
the EU and first steps of Ukraine to be held within the VII International Investment
Business Forum on Energy Efficiency and Renewable Energy. ITS to define in
coordination with SAEE the agenda, prepare presentations and provide the speakers.
10
The agenda to focus on past and current developments in Ecodesign in the EU, and on
SAEE's current activities in this field. At the opportunity of this workshop, also the past
and current work of SAEE on Energy Labelling was to be presented, in order to improve
the visibility of the national labelling programme. ITS was also to provide for the
workshop related services (rent of the conference room, simultaneous interpretation,
catering, information and dissemination materials, etc.). The workshop was to be
complemented by a separate two to three hour session on "Awareness Raising for
Energy Efficiency".
8. During the VII International Investment Business Forum on Energy Efficiency and Renewable
Energy, ITS was to provide an "expert zone", where ITS experts would be available to provide
information and answer questions on EU and Ukrainian product policies, in particular Energy
Labelling and Ecodesign.
(c) Reporting and follow-up
9. Preparation of the task report.
10. Monitoring the process of legal adoption and of the implementation of the Draft Technical
Regulations for Energy Labelling, of the proposed legal act transposing the Ecodesign
Directive and of the Draft Technical Regulations for Ecodesign prepared (status in March
2016, before the termination of the ITS project).
With regard to the Technical Assistance, all tasks have been implemented and reflected in this
report, except task 6 (assistance in the preparation of a report to the Energy Community
Secretariat), which will be undertaken as soon as a specific request will be received from SAEE. Also,
by mutual agreement with SAEE, tasks 3 and 4 focused on identifying the most appropriate legal
option to transpose the EU Ecodesign Directive, and the prioritisation of product-specific Ecodesign
regulations to be adopted in Ukraine, rather than on the structure and content of the respective
documents. As regards task 1, the review of the draft TR of space heaters was substituted by the
draft TR of vacuum cleaners, by request of SAEE. As an additional task, which was not foreseen in
the "Work Plan 2015", or in the ToR, ITS agreed to provide translations into English of five existing
Technical Regulations for Energy Labelling of energy-related products. On the request of SAEE, ITS
also drafted a letter to the State Statistical Service of Ukraine, in order to facilitate obtaining market
information on the products subject to Ecodesign regulations.
With regard to the Support to the VII International Investment Business Forum on Energy Efficiency
and Renewable Energy, all tasks were fully implemented.
Regarding follow-up, task 10 (monitoring) will be implemented according to the standard INOGATE
procedures. The monitoring exercise will be conducted with respect to the baseline indicators
developed in section 2.3 of the report.
The assignment started in July 2015 with the translation of ten EU Ecodesign Regulations according
to the timetable agreed upon in the "Work Plan 2015". From 19th to 23rd October, the first mission to
Kyiv took place, which served to confirm the scope of the Technical Assistance, to understand the
process of elaboration and implementation of Technical Regulations in Ukraine, to discuss with SAEE
and with stakeholders their views, to receive relevant background information, and to respond to
queries by SAEE on topics related to the tasks agreed. The second mission of the team of experts,
from 9th to 13th November, served to confirm and critically assess some working hypotheses
developed by the team of experts, to discuss preliminary recommendations and to finalise
preparations and implement the ITS support to the VII International Investment Business Forum on
11
Energy Efficiency and Renewable Energy, in particular the implementation of the workshops
"Ecodesign: the experience of the EU and first steps of Ukraine" and "Awareness Raising for Energy
Efficiency", which were both held on 13th November 2015.
2. Background
2.1. Energy labelling and Ecodesign in Ukraine
Ukraine has made considerable progress in the transposition of EU legislation in the field of Energy
labelling and to some extent also in Ecodesign.
From 2002 2011, SAEE elaborated eight national Energy Labelling standards for household appliances,
which were in line with the requirements of the Acquis Communautaire, but were applied on a voluntary
basis only. In 2012 and 2013, with the support of the EU Twinning Project "Improvement of the Policy
Framework in the Sphere of Energy Efficiency and its Approximation to the EU Legislation, Ukraine
2012 - 2013", SAEE elaborated Technical Regulations equivalent to the EU Labelling Directive
2010/30/EU and CDRs for various energy-related products.
So far, the following EU Legislative Acts were transposed into Ukrainian legislation, as Technical
Regulations, by the following Resolutions of the Cabinet of Ministers:
Res. 702 of 7 August 2013 "On approval of technical regulations on Energy Labelling",
transposing Directive 2010/30/EU, CDR 1060/2010 for household refrigerating appliances and
CDR 1061/2010 for household washing machines. The Resolution eventually entered into force
on 1 July 2015.
Res. 340 of 27 May 2015, transposing CDR 874/2012 for electrical lamps and luminaires,
which entered into force on 5 December 2015.
Res. 514 of 17 July 2015, transposing CDR 1059/2010 for household dishwashers, which will
enter into force on 17 January 2016.
Draft Energy Labelling TRs for household tumble driers, air conditioners, televisions, vacuum
cleaners, ovens & range hoods, water heaters and space heaters are under preparation and at
different stages of elaboration, review and adoption. Market surveillance for products subject to
Energy Labelling regulation will probably start in mid 2016.
In addition to Energy Labelling regulation, Ukraine has introduced Minimum Energy Performance
Standards for household refrigerating appliances in line with Directive 96/57/EC and proposed an
amendment which would align the minimum requirements with Ecodesign regulation 643/2009.
While the transposition of the Energy Labelling Directive and CDRs for Energy Labelling are
obligations of Ukraine under the Energy Community Treaty, the transposition of the Ecodesign
Directive by November 2017 is a requirement under the Ukraine-EU Association Agreement 1.
The transposition of certain Ecodesign regulations is also a requirement under the EU Deep and
Comprehensive Free Trade Area (DCFTA).
12
The transposition of the Ecodesign Directive and of product-specific Ecodesign regulations is

therefore a priority for SAEE, and has been mandated by several Resolutions of the Cabinet of
Ministers of Ukraine, which will be discussed in detail in Section 5 of this Report.
2.2 The process of approving Technical Regulations

Figure 2.1 provides a schematic of the process for approving TRs in Ukraine. The source of the
schematic is in-depth discussions with SAEE during the first mission of the team of experts.
Figure 2.1: Schematic of the Approval Process of Technical Regulations in Ukraine
A description of each of the stages featured in Figure 2.1 is featured below:

Stage 1: According to Article 18 of the Law of Ukraine "On technical regulations and conformity
assessment procedures" SAEE, as a central executive body which is in charge of the organisation of
the development of TRs, may establish a Technical Working Group with stakeholder representatives
interested in a specific topic and/or issue that is considered under the scope of the TR. The common
goals for the working group includes 1) drafting TRs, 2) discussing the need for changing existing TRs
and 3) determining conformity of the provisions of the draft TR with the acquis communautaire. The
size and composition of the group participation will be dependent on the group's task. Each working
group is chaired by SAEE and could be comprised of representatives from the following:
Central bodies of executive power such as the Ministry of Economic Development and Trade
of Ukraine, Ministry of Regional Development, Construction and Housing and the Ministry of
Ecology and Natural Resources.
Relevant technical standardisation committees, such as TC-13 "Standardisation of household
appliances and equipment," TC- 34 "Lamps", TC-100 "Audio-visual systems and services".
Manufacturers, suppliers and distributors of the related equipment, such as the European
Business Association (EBA) and national manufacturers of the equipment.
International experts of EU funded projects.
SAEE currently has a Technical Working Group established to respond to the feedback from the
13
Cabinet of Ministers on their first review of the draft Energy Labelling TR for air conditioners.
In terms of the procedure, after SAEE has prepared the first draft of the TR, they send it to members
of the Working Group and arrange the first review meeting. After consideration of the comments of
the working group, the final version of the draft TR is forward to the Ministry of Regional
Development for approval.
Stage 2: According to the SAEEs Statute 2, its activities are directed and coordinated by the Cabinet
of Ministers of Ukraine via the Deputy Prime Minister of Ukraine the Minister of Regional
Development. The procedural issues relating to the development of the decisions by the Cabinet of
Ministers of Ukraine are defined by the Rules of the Cabinet of Ministers 3. This document establishes
the order in which draft legal texts are reviewed, and places the responsible ministry as the first
reviewer. Only after that can the draft legal act be sent to other interested bodies 4. That is why the
first draft of the TR is reviewed by the Ministry of Regional Development.
Stage 3: Once the Ministry of Regional Development approves the draft TR, SAEE sends it to the
following ministries (if the draft TR contains provisions relating to the competence of other central
authorities, the list of authorities may be expanded):
Ministry of Economy 5: The central executive body that is responsible for the development
and implementation of state policy in the sphere of TR. The Ministry of Economy examines
draft TRs to make certain they meet specific legislation in the field of TRs for example the
Law of Ukraine "On technical regulations and conformity assessment procedures", and the
Rules of preparation of draft technical regulations based on legislative acts of the European
Union 6 and other legislation in this field. The Ministry can determine that there is an urgent
need for the adoption of a TR and prepare a Conclusion for submission along with the draft
TR, directly to the Cabinet of Ministers of Ukraine 7.
Ministry of Finance 8: The central executive body that is responsible for the development and
implementation of state financing policy.
State Regulatory Service 9 : The central executive body that is responsible for the
implementation of state regulatory policy. According to the Law of Ukraine "On Principles of
Regulatory Policy in Economic Activity" 10, the State Regulatory Service conducts a regulatory
impact assessment with a recommendation either to approve or reject the regulation.
http://zakon5.rada.gov.ua/laws/show/676-2014-%D0%BF
4 o
N 37 of the Rules of CMU
5
Statute of Ministry of economy http://zakon5.rada.gov.ua/laws/show/459-2014-%D0%BF
6
7
According to article 24 of the Law of Ukraine "On technical regulations and conformity assessment
procedures"
8
Statute of Ministry of Finance http://zakon5.rada.gov.ua/laws/show/375-2014-%D0%BF
9
Statute of State regulatory service http://zakon5.rada.gov.ua/laws/show/724-2014-%D0%BF
10
http://zakon5.rada.gov.ua/laws/show/1160-15
3
14
State Inspection on Consumer Rights Protection 11: The central executive body that is
responsible for the implementation of state policy on market surveillance specifically for
Energy Labelling and Ecodesign 12.
Anti-monopoly Committee 13: The state body with a special responsibility to ensure state
protection of competition in business and in public procurement. The Anti-monopoly
committee examines the draft TRs for compliance with anti-monopoly legislation.
In practice the majority of comments are received from the Ministry of Economy. After collecting all
the comments, SAEE finalises the draft TR. If a draft TR has undergone significant changes then it
needs to be re-approved by stakeholders 14. If not, SAEE sends the draft TR to the Ministry of Justice
for legal examination.
Stage 4: All draft legislative acts are subject to legal examination by the Ministry of Justice 15. The
Ministry of Justice examines if the draft TR complies with the Constitution of Ukraine, legislative
acts, the provisions of the European Convention on Human Rights, and in the case where the draft
document refers to the priority areas Adaptation of Ukraine to the European Union on its
compliance with the acquis communautaire. The experience from approving the draft TRs on Energy
Labelling has shown that the Ministry of Justice has provided a significant number of comments.
After obtaining the opinion of the Ministry of Justice, SAEE then finalises the draft TR for submission
to the Government.
Stage 5: Once the Ministry of Economy receive the draft TR from SAEE they submit it to the
Government 16. Experience has shown from the adoption of the TRs on Energy Labelling that this
review could last from one to three months or longer, depending on the complexity of the draft TR.
Experts of the Cabinet of Ministers Secretariat prepare an Expert opinion for when the draft TR is
presented.
Stage 6: If a positive Expert opinion is returned, and if there are no other comments from the
Government, then the draft TR is adopted and published in the official publication of the Cabinet of
Ministers of Ukraine. The regulation comes into force in the time specified in the Resolution of the
Cabinet of Ministers, but not earlier than six months from the date of publication.
Experience has shown that on occasion a TR can gather significant feedback at stage 5, the review by
the Council of Ministers. This can lead to the draft TR returning to stage 1 and undergoing another
round of inter-ministerial consultation.
11
http://zakon3.rada.gov.ua/laws/show/465/2011
The list of state market surveillance authorities approved by the Government
13
http://zakon5.rada.gov.ua/laws/show/3659-12
14 o
N 40 of the Rules of CMU
15 o
N 44-47 of the Rules of CMU
16
Article 22 of the Law of Ukraine "On technical regulations and conformity assessment procedures"
12
15
2.3 Baseline indicators

The baseline situation is as follows:
Regarding Energy Labelling: The EU Energy Labelling Directive 2010/30/EU and four CDRs have been
transposed into Ukrainian legislation. Currently, the transposition of CDRs for seven products is
pending, of which five have been reviewed by ITS experts, in the framework of this assignment.
Regarding Ecodesign: So far, SAEE has taken the following preparatory legal and practical steps to
transpose the EU Ecodesign Directive 2009/125/EC and product-specific regulations: elaboration and
approval of action plans by Resolutions of the Cabinet of Ministers of Ukraine (see Section 5 for
details), and the translation into Ukrainian of the Ecodesign Directive and of product-specific
regulations.
Key tangible results of this assignment should be considered as:
Energy labelling:
Submission for adoption by Resolutions of the CMU of the five draft TRs reviewed by the ITS
experts under this assignment.
Ecodesign:
Elaboration of Ecodesign TRs, based on the EU Ecodesign Regulations, translated by ITS into
Ukrainian, according to the "work plan" agreed upon;
Improved capacity and awareness of decision makers, experts and the interested public on
Energy Labelling and Ecodesign, due to the delivery, by ITS experts, of the workshop
"Ecodesign: the experience of the EU and first steps of Ukraine and of the experts' zone and
leaflets distributed at the VII International Investment Business Forum on Energy Efficiency
and Renewable Energy;
The approval by SAEE of the proposal of ITS with regard to the most appropriate legal option
to transpose the Ecodesign Directive, and further steps taken by SAEE to its transposition;
The approval by SAEE of the proposal of ITS with regard to the prioritisation of ErPs to be
regulated, and further steps taken by SAEE to the adoption of Ecodesign TRs according to this
prioritisation;
The adoption as Ukrainian national standards of the European harmonised measurement
standards required to implement the required TRs on Ecodesign and Energy Labelling in
Ukraine, in accordance with the updated and complete list delivered by ITS.
3. Review of draft Technical Regulations for Energy Labelling of Energyrelated Products

As agreed with SAEE, the following draft TRs for Energy Labelling of Energy-related Products were
reviewed by ITS experts:
Household tumble driers;
Domestic ovens and range hoods;
Vacuum cleaners;
Air conditioners;
16
Water heaters, hot water storage tanks and packages of water heater and solar device
(without annexes).
The draft regulations reviewed are in different stages of the approval process described in Section
2.2. Table 3.1 provides an overview of the current status of all draft Technical Regulations, including
the five regulations reviewed under this assignment:
Table 3.1: Status of Energy Labelling draft Technical Regulations (December 2015)
Product
Stage 1
Stage 2
Stage 3
Stage 4
Stage 5
Tumble Dryers*
Televisions
@ 17
Ovens & Range Hoods*
Air conditioners*
@ 18
Vacuum Cleaners*
Water Heaters*
Space heaters
Stage 6
Key:
means the respective stage has been completed
@ means the regulation is currently at this stage
* indicates products which are being supported by the current assignment
The scope and activity of the reviews completed by the ITS experts were as follows:
Household tumble driers: focused on minor comments made by the Ministry of Justice, which
referred to the clarification of technical terminology, the inclusion of the EU-Ecolabel, and regulation
stamped references in product energy labels. ITS prepared a note on "International Use of
Regulation/Date stamped references in Product Energy Labels" (see Annex 2), which will be used by
SAEE as a reference.
Domestic ovens & range hoods: The draft TR was approved by the Ministry of Economy with
comments. Major issues addressed by the review were in addition to clarifications of technical
terminology the dates for entry into force of different labels as stipulated by the corresponding EC
regulation, and the inclusion of the stipulations of EC CDR 518/2014 (internet sales). Also, the draft
TR was brought in compliance with the corresponding EC CDR 65/2014, the Law of Ukraine "On
technical regulation and conformity assessment, and the "Rules of preparing technical regulations
based on EU legislation" approved by Resolution of CMU no. 708 of 12.06.2012. Necessary changes
17
This is the second time that the draft TV Energy Labelling Technical Regulation has been at stage 5. Earlier
this year the Council of Ministers rejected the draft technical regulation and it returned to stage 1 for further
development.
18
Similar to TVs, the draft Air-conditioner Energy Labelling Technical Regulation was previously at stage 5, but
returned to stage 1 after receiving feedback from the Council of Ministers on developmental points.
17
concerned: some calculation rules, taking into consideration the corrigendum to CDR 65/2014, the
table on "verification tolerances" in Annex 8, and adjustment to specific stipulations of the Law On
Technical Regulation and conformity assessment and the Rules of preparing technical regulations
based on EU legislation (including stipulations on normative provisions see below).
Vacuum cleaners: This draft TR is still under preparation by SAEE (stage 1). Major issues addressed
by the review referred to technical terminology. Also, the draft TR was brought in compliance with
the corresponding EC CDR 665/2013 (e.g. including the stipulations of EC CDR 518/2014 regarding
internet sales), as well as with regard to specific stipulations of the Law of Ukraine "On technical
regulation and conformity assessment, and the "Rules of preparing technical regulations based on
EU legislation" (including stipulations on normative provisions).
Water heaters, hot water storage tanks and packages of water heater and solar device: Also this
draft TR is still under preparation by SAEE (stage 1). ITS was asked to review the draft TR without the
annexes, which had not been finalise by SAEE at this moment. The draft TR (without annexes) was
brought in compliance with CDR (EU) # 812/2013 and article 10 of CDR (EU) #518/2014 (including
redrafting of part of the draft Technical Regulation, taking into account the structure and content of
articles 3-6 of CDR (EU) # 812/2013 (with amendments), as well as with specific stipulations of the
Law of Ukraine "On technical regulation and conformity assessment, and the "Rules of preparing
technical regulations based on EU legislation" (with regard to normative provisions).
Air conditioners: the draft TR for air conditioners had already reached stage 5 of the approval
process, but were returned by the Cabinet of Ministers to SAEE with several comments:
Apart from technical errors in translation, the CMU's comments referred to the following issues:
There was not a complete set of references to implementing regulations that would enable
compliance of Ukrainian product suppliers such as the EC regulation 842/2006 on Global
Warming Potential values of fluorinated greenhouse gases. This regulation is not replicated
in Ukrainian Law and so there are no grounds for direct regulatory references without
changes being made to the draft technical regulation;
There was a lack of conformity of the draft technical regulation with the requirements in the
Resolution of the Council of Minsters #708, dated 18 June 2012 on Normative References,
which stipulates that normative references be excluded from definitions within technical
regulations.
Specifically, Resolution #708 stipulates that normative provisions (such as calculations) contained
within definitions in EU acts must be included in the text of appropriate parts of the TR instead of
the definitions of the TR.
Within the draft TR for the Energy Labelling of air conditioners a significant number of the technical
definitions, contained within an annex to the regulation, included not only the identification of the
term, but also an equation, written in text format. This is also the case within the original EU
delegated act for the Energy Labelling of air conditioners No 626/2011, but it is not an issue for the
EU. So, by faithfully delivering a direct translation of the EU regulation, it also conflicted with the
rules for development of TRs in Ukraine (i.e. Resolution #708).
In order to respond to this issue, the team of experts undertook an exercise to identify the
conflicting definitions within the draft TR for the Energy Labelling of air conditioners, distil the
equations from the text based definitions, create the formulas and re-insert them into the draft TR.
18
Please refer to Annex 3 which was used as guidance for the review of the draft TR for air
conditioners.
The reviews of the five draft TRs were submitted to SAEE and are included in Appendix I.
4. Translation of EU Ecodesign Regulations and of existing Technical

Regulations for Energy Labelling of Energy-related Products
4.1. Translation of EU Ecodesign Regulations
In accordance with the "Work Plan 2015" signed between SAEE and ITS, the current EC Ecodesign
Regulations were translated by ITS into Ukrainian and submitted to SAEE in accordance with the
time schedule agreed upon, for the following energy-related products: (i) air conditioners and
comfort fans, (ii) water pumps, (iii) household tumble driers, (iv) directional lamps, LED lamps and
related equipment, (v) computers and computer servers, (vi) vacuum cleaners, (vii) space and
combination heaters, (viii) water heaters and hot water storage tanks, (ix) domestic ovens, hobs and
range hoods, (x) small, medium and large power transformers.
The translations of the ten Ecodesign Regulations were submitted to SAEE and are included in
Appendix II.
4.2. Translation of existing Technical Regulations of Energy-related Products

Upon request of SAEE, ITS provided translations into English of the following existing Technical
Regulations for Energy Labelling:
Res. 702 of 7 August 2013 "On approval of technical regulations on Energy Labelling",
transposing Directive 2010/30/EU, CDR 1060/2010 for household refrigerating appliances and
CDR 1061/2010 for household washing machines;
Res. 340 of 27 May 2015, transposing CDR 874/2012 for electrical lamps and luminaires;
Res. 514 of 17 July 2015, transposing CDR 1059/2010 for household dishwashers.
Before submission to SAEE, the translations underwent a rigorous quality assurance check. In the
case of the four product-specific TRs, small inconsistencies with the corresponding EU CDRs were
detected and communicated to SAEE.
The translations of the five TRs were submitted to SAEE and are included in Appendix III.
5. Transposition of the EU Ecodesign Directive into Ukrainian Legislation

5.1. Scope
19
The transposition of the EU Ecodesign Directive 2009/125/EC into Ukrainian legislation by November
2017 is a requirement under the EU-Ukraine Association Agreement and is expected to become also
a requirement under the Energy Community Treaty. SAEE is therefore actively pursuing the
transposition of the Directive.
In principle, two different ways exist to transpose the Directive into Ukrainian legislation: either as a
Law or as a Technical Regulation by Resolution of the Cabinet of Ministers. An important precedent
is the EU Energy Labelling Directive 2010/30/EU which was transposed in August 2013 by Resolution
no. 702 of the Cabinet of Ministers, as a Technical Regulation. Since then, four product-specific
Energy Labelling regulations were enacted and seven more are under preparation, five of them with
the assistance of the current assignment (see Section 3 of this report).
While the transposition of the Ecodesign Directive as a Technical Regulation by Resolution of the
Cabinet of Ministers would allow a rather swift legal procedure, which would not involve Parliament,
there are also arguments in favour of the transposition of the Directive as a Law of Ukraine. The
main argument is the major weight of the Law, which may also be more immune against attempts to
amend the legislation, and may provide more leverage to the Government to enforce its
implementation. Implementing the Ecodesign Directive as a Law and specific product-specific
regulations with legal force may also give investors more certainty when considering long-payback
investments in upgrades to production facilities. The expectation is that the Ecodesign Directive may
become part of the required structural reform measures for macro-financial assistance in 2017,
which will provide a strong incentive to Parliament for a timely transposition of the Directive.
On the other hand, according to various pieces of Ukrainian legislation 19, both the Directive
2009/125/EU and product-specific Ecodesign regulations have to be enacted by Regulatory Acts of
the Cabinet of Ministers of Ukraine.
5.2. Methodology
In order to assess the most appropriate legal option to transpose the EU Ecodesign Directive into
Ukrainian legislation, discussions were held with SAEE, consultations with stakeholders were
conducted and relevant legal documents have been reviewed. Presentations and discussions during
the workshop "Ecodesign: the experience of the EU and first steps of Ukraine" in Kyiv, on November
13, 2015, provided additional input for this assessment. Based on a brief account of the meetings
19
Action Plan on implementation of the Association Agreement between Ukraine and the European Union,
European Atomic Community and their member states for 2014-2017, approved by Resolution of the Cabinet
of Ministers of Ukraine 847- of 17 September 2014; Plan for implementation of Directive 2009/125/EC,
Commission Regulation (EC) 278/2009, Commission Regulation (EC) 245/2009, Commission Regulation
(EC) 244/2009, Commission Regulation (EC) 107/2009 Commission Regulation (EC) 1275/2008,
establishing the framework and requirements for the eco-design of energy products, approved by Resolution
of the Cabinet of Ministers of Ukraine 475/2015; Strategy of development of the system of technical
regulation until 2020, approved by Resolution of the Cabinet of Ministers of Ukraine 844- of August 19,
2015.
20
with SAEE and stakeholders, and the reviews of legal documents, three options are presented, which
are analysed in accordance to relevant criteria.
5.2.1. Meetings with SAEE and stakeholders
During two missions of the team of experts to Ukraine (week of 1923 October and week of 913
November 2015), meetings and consultations were held with: 20
Senior staff of SAEE, including the Head of Department for Technical Regulation in Energy
Efficiency, the Head of the Standards, Regulations and Labelling Divisions, the Head of the
Legislative Support Division, and technical specialists.
The Support Group for Ukraine (SGUA) of DG NEAR, the Deputy Head of the European
Integration Department of the Ministry of Energy and Coal Industry, the Head of the
Technical Regulation Division of the Ministry of Economy of Ukraine, a Senior Specialist of
the Division for European Integration, Adaptation of Legislation and Supporting of
International Agreements of the Ministry of Ecology and Natural Resources, the Coordinator
of Communications of Household Electrical Appliances of EBA, as well as representatives of
product suppliers.
In these meetings, the basic options for transposition of the Directive (as Law of Ukraine or as
Technical Regulation enacted by Resolution of the Cabinet of Ministers) were presented and
discussed.
The views expressed by the interlocutors varied from strong advocacy to transpose the Directive
within the system of TRs, by Resolution of the Cabinet of Ministers (Ministry of Economy) to a clear
preference to implement it as a Law of Ukraine (SGUA). While the preference to transpose the
Directive as a law was shared by the representative of the Ministry of Ecology and Natural
Resources, the representative of EBA advocated its transposition as Technical Regulation by
Resolution of CMU.
A concern articulated by various interlocutors were the very long periods needed by the Ukrainian
Parliament to pass laws 21, and the associated uncertainty regarding the date of implementation of a
Law transposing the Directive.
Arguments in favour of a Law were related to its superior legal status, compared to regulatory acts,
which would be more adequate, given the market restrictions imposed by Ecodesign. A law may also
provide a more stable legal framework, facilitating compliance by market actors, although this
argument was not shared by all interlocutors. 22 Transposition as a Law will also reflect the legal
character of the Ecodesign Directive, which provides "the framework for the setting of Ecodesign
requirements for energy-related products" and for the implementing measures for each ErP.
An third option brought forward by SAEE was to include in the forthcoming new Energy Efficiency
Law which is currently drafted by the Agency an article which confirms Ukraine's obligation to
20
See Annex 4 for a list of interlocutors.

E.g. the new Energy Efficiency Law is debated already since seven years in Parliament.
22
In the opinion of the advocates of transposition as Technical Regulation, the implementation of a technical
regulation would be easier to control and monitor.
21
21
transpose Directive 2009/125/EC and to implement it as Technical Regulation by Resolution of the

Cabinet of Ministers.
5.2.2 Review of legal documents
Association Agreement European Union Ukraine 23 and Action Plan
The Association Agreement between the European Union and Ukraine requires Ukraine to transpose
Directive 2005/32/EC and various implementing directives and regulations 24, within three years after
entry into force of the agreement. 25 It also stipulates that "New daughter directives/regulations shall
be implemented in accordance with the timetables established in these directives/regulations after
changes to this Annex in line with the institutional provisions as set out in Title VII 26 of this
Agreement and as notified to the Ukrainian side."
The Action Plan on implementation of the Association Agreement between Ukraine and the
European Union of September 2014 27 confirms these commitments, specifying that the Directive
2005/32/EC (substituting Directive 2009/125/EU) 28 has to be transposed by August 2017, together
with the Commission Regulations mentioned in the Association Agreement. It specifies the following
Ukrainian entities as responsible for the implementation: the Ministry of Nature, SAEE, the Ministry
of Energy, and the Ministry of Economic Development. 29 Both the Directive and the Commission
Regulations are supposed to be transposed by regulatory acts to be submitted to the Cabinet of
Ministers of Ukraine (CMU). 30
Plan for the implementation of Directive 2009/125/EC and Commission Regulations
23
Association Agreement between the European Union and its Member States, of the one part, and Ukraine,
of the other part, Official Journal of the European Union, 29.5.2014. The Agreement was ratified by the
Ukrainian Parliament in September 2014.
24
Commission Regulations (EC) No 278/2009 (No-load condition electric power consumption and average
active efficiency of external power supplies), 245/2009 (Fluorescent lamps without integrated ballast, high
intensity discharge lamps, and ballast and luminaires able to operate such lamps), 244/2009 (Non-directional
household lamps), 107/2009 (Simple set-top boxes) and 1275/2008 (Standby and off mode power
consumption of electrical and electronic household and office equipment), as well as Directives 92/42/EEC
(New hot water boilers fired with liquid and gaseous fuels), 96/57/EC (Household electric refrigerators,
freezers and combinations) and Directive 2000/55/EC (Ballasts for fluorescent lighting).
25
Annex XXVII to Chapter 1 of the Association Agreement.
26
"Institutional, General and Final Provisions".
27
Action Plan on implementation of the Association Agreement between Ukraine and the European Union,
European Atomic Community and their member states for 2014-2017, approved by Resolution of the Cabinet
of Ministers of Ukraine 847- of 17 September 2014
28
This is apparently the result of a misinterpretation by the authors of the Action Plan.
29
Government entities as quoted in accordance to their denomination in the legal documents reviewed.
30
The text of the Action Plan regarding the transposition of the Directive: "Development and submission of
draft regulatory acts to the Cabinet of Ministers with a view of implementation of Directive 2005/32/C of the
European Parliament and of the Council of 6 July 2005 determining the structure of setting the Ecodesign
requirements for energy-related appliances (substitution of Directive 2009/125/EU of 21 October 2009
establishing a framework for the setting of Ecodesign requirements for energy-related products)"
22
Based on the provisions of the Association Agreement and of the Action Plan for its implementation,
the Cabinet of Ministers, by Resolution No 475 of 14 May 2015, approved the "Plan for
implementation of Directive 2009/125/EC, Commission Regulation (EC) 278/2009, Commission
Regulation (EC) 245/2009, Commission Regulation (EC) 244/2009, Commission Regulation (EC)
107/2009 Commission Regulation (EC) 1275/2008, establishing the framework and
requirements for the eco-design of energy products".
The plan assigns SAEE as the main implementing agency for the following activities: 31
Assessment of Ukrainian legislation regulating energy saving and energy efficiency to detect
the need for amendments in connection with the Ecodesign Framework Directive;
Definition and legislative consolidation of the basic energy efficiency requirements of
products subject to Ecodesign;
Development of national standards harmonised with European standards.
Co-executors are the Ministry of Natural Resources, the Ministry of Regional Development, the
Ministry of Economic Development and the Ministry of Health.
The implementation plan foresees several activities, among these "Standard setting activities" and
the "Development of regulation activities". Among the "standard setting activities", the plan
foresees "The development of a legal act (technical regulation) to consolidate the basic
requirements to energy efficiency products that will apply under the Ecodesign Framework
Directive", by August 2017. Under the headline "development of regulation activities", the Plan
stipulates the development of Technical Regulations in accordance with the Commission
Regulations for the products included in the Action Plan on implementation of the Association
Agreement.
Law on Technical Regulations and Compliance Assessment
The Law of Ukraine on Technical Regulations and Compliance Assessment (Law No 124 of 15 January
2015), which will enter into force on 10 February 2016, "defines the legal and organisational
framework for development, adoption and application of the technical regulations and foreseen
procedures for compliance assessment".
The Law defines a TR as a regulatory act relating to the identification and fulfilment of mandatory
requirements to the parameters of products or production processes and associated methods,
including the relevant procedure provisions, like compliance assessment. The "provision of energy
efficiency" is explicitly mentioned as a possible objective of a TR. 32 According to Article 9 of the Law,
TRs are approved by laws, acts of the Cabinet of Ministers and central executive bodies, and "a
regulatory act having signs of a technical regulation specified by this Law, are regarded as a
technical regulation regardless of use of such words as "a technical regulation" in the title".
31
SAEE has recently been assigned Central Executive Body for Ecodesign by Resolution of CMU #1057 of
16/12/2015
32
Article 9 of the Law on Technical Regulations and Compliance Assessment.
23
Strategy of development of the system of technical regulation until 202033

The EU - Ukraine Association Agreement envisages the creation of a deep and comprehensive free
trade area (DCFTA), which requires reforming the system of TRs in Ukraine, in order to remove
technical barriers to trade.
The "Strategy of development of the system of technical regulation until 2012", which was approved
by Resolution of the Cabinet of Ministers of Ukraine 844- of August 19, 2015, includes an Action
Plan, which specifies the activities to be implemented, including a list of "New technical regulations
that meet EU legislative acts". Among these activities are:
A system to determine the Ecodesign requirements for energy-related products (Directive
2009/125/EC of the EP and Council of October 21, 2009 on setting the system of determining the
Ecodesign requirements to the energy consuming products), as well as the list of 22 EC Ecodesign
regulations referred to in Section 6 of this report. The responsible entities for the implementation of
these activities are the Ministry of Regions, SAEE and the Ministry of Nature. The deadline of these
activities is 2015 2017, and the progress indicator is an "Act by the Cabinet of Ministers".
Conclusions from the review of legal documents
The Action Plan on implementation of the Association Agreement, the Plan for the Implementation
of the Ecodesign Directive and various product-specific regulations, and the Strategy of the system
of TRs stipulate that Directive 2009/125/EC should be implemented in Ukraine by "regulatory acts to
be submitted to the Cabinet of Ministers of Ukraine", "a legal act (technical regulation)" or by an "Act
by the Cabinet of Ministers", respectively. "Acts by the CMU" are usually Resolutions of the CMU,
which typically enact Technical Regulations. The fact that the same legal instruments are stipulated
for the transposition of Commission Regulations for specific products (implementing measures),
suggest that the Government intends to transpose the Ecodesign Directive as a Technical Regulation,
by Resolution of the Cabinet of Ministers.
Furthermore, the Law on Technical Regulations and Compliance Assessment includes stipulations
which could be interpreted in favour of transposing the Ecodesign Directive as a Technical
Regulation, e.g. the definition of a Technical Regulation in Article 1 and the stipulations in Article 9 of
the Law, mentioned above. 34 Therefore, in the case of transposition of the Ecodesign Directive by
law, an important question is whether the draft law (bill) would be presented in Parliament or
submitted by the Cabinet of Ministers to Parliament. In the latter case, the Cabinet of Ministers
could conclude that certain stipulations in the draft legal act would characterise it as a Technical
Regulation and thus prevent it to qualify to be presented as draft law.
5.3. Evaluation of options
33
Strategy of development of the system of technical regulation until 2020, approved by Resolution of the
Cabinet of Ministers of Ukraine 844- of August 19, 2015
34
According to the interpretation by the Ministry of Economy (communication by the Head of the Technical
Regulation Division), due to these stipulations the Ecodesign Directive would qualify as a technical regulation,
taking into consideration e.g. article 3(1.) and article 5(1.) of Directive 2009/125/EC.
24
As follows from the above, in principle three options for the transposition of the Ecodesign Directive
into Ukrainian legislation exist:
1. As a Law of Ukraine;
2. As a Technical Regulation based on a Resolution of the Cabinet of Ministers of Ukraine;
3. As an Article of the new Energy Efficiency Law, which requires the transposition of the
Directive as Technical Regulation by Resolution of the Cabinet of Ministers.
Both the meetings with SAEE and stakeholders, and the review of the legal documents, revealed
arguments in favour and against each of these options, in particular Options 1 and 2, which are in
the centre of (controversial) debate among stakeholders. In this context, Option 3, which was
brought forward by SAEE could be a "third way" in order to overcome this dichotomy, as will be
argued below.
Arguments for and against each of these options are presented in Table 5.1, referring to relevant
criteria, mentioning the related evidence. The table also includes comments by the independent ITS
experts on the evidence gathered for and against the arguments.
While the transposition of the Ecodesign Directive according to Options 1 or 2 would be rather
straightforward, transposition in accordance with Option 3 would require a more detailed analysis of
how to include the requirement of transposition in the new Energy Efficiency Law and the reference
to the respective Technical Regulation issued by Resolution of the Cabinet of Ministers.
Taking into consideration that Directive 2009/125/EC is an integral legal document which
"establishes a framework for the setting of Community ecodesign requirements for energy-related
products", it is recommended to transcribe its integral text into the respective Technical Regulation,
with the necessary adjustments due to the different legal contexts in the EU and in Ukraine. 35
This means that an Article in the new Energy Efficiency Law, which requires the transposition of the
Directive as Technical Regulation by Resolution of the Cabinet of Ministers should be concise,
without going into details with regard to specific stipulations of the Directive.
Therefore, the Article in the new Energy Efficiency Law should stipulate: (i) that energy-related
products placed on the market in Ukraine will be subject to ecodesign requirements, in accordance
with EU Directive 2009/125/EC and related implementing measures; (ii) that the Directive and the
implementing measures will be fully transposed into Ukrainian legislation as Technical Regulations,
by Resolutions of the Cabinet of Ministers, in accordance with a timetable to be established for that
purpose; (iii) that future recasts of Directive 2009/125/EC will be reflected in amendments of the
corresponding Ukrainian legal documents; (iv) the central executive bodies which will be in charge of
implementing the respective Technical Regulations. 36
35
This procedure was applied in the transposition of the Energy Labelling Directive 2010/30/EU into Ukrainian
legislation as Technical Regulation on Energy Labelling of Energy-related Products, approved by Resolution of
the Cabinet of Ministers of Ukraine No. 702 of August 7, 2013.
36
The exact content and wording of this Article should be subject of advice by legal experts.
25
5.4. Conclusions and Recommendations

Among the arguments in favour and against each options, the following arguments are considered
to be most relevant:
1. Transposition as, or foundation of, the Ecodesign Directive in primary legislation is expected
to provide a more stable legal framework, more leverage to the Government for
enforcement and higher investor confidence, and should therefore be seriously considered.
2. However, the very long periods usually required by the Ukrainian Parliament for passing
laws are a major concern, and represent a strong argument for pursuing transposing the
Directive by a Technical Regulation based on a Resolution of the Cabinet of Ministers, taking
also into consideration the positive experience in transposing the Energy Labelling Directive
in 2013.
3. Relevant legal documents stipulate that the transposition of the Directive must be as a legal
act (technical regulation) of the Cabinet of Ministers.
4. Based on stipulations of the Law of Technical Regulations and Compliance Assessment, the
Cabinet of Ministers may require the transposition of the Directive as a Technical Regulation.
Hence, even when considering only these four key arguments, the dichotomy remains between the
two main options (transposition as Law or Technical Regulation enacted by Resolution of CMU).
However, as can be seen in Table 5.1, Option 3 (transposition as Article of the new Energy Efficiency
Law which requires the transposition of the Directive as Technical Regulation by Resolution of the
Cabinet of Ministers) satisfies all criteria and should therefore be considered as the preferred option.
Pursuing Option 3 will facilitate the timely implementation of the Directive (even in the case of
delays in the implementation of the Energy Efficiency Law), and at the same time ground it in a Law
of Ukraine, thereby giving it legal force and providing stability to inspire investor confidence.
This recommendation should be subject to a rigorous legal examination and should be verified
with the relevant EU institutions.
26
Table 5.1: Options for the transposition of the Ecodesign Directive into Ukrainian legislation
Criteria
Option 1:
As Law of Ukraine
Adequate level of
legislation
Stable legal framework
Major weight of a Law

(primary legislation), as
compared to a
(secondary legislation)
More stable legal
framework, which
makes it more difficult
to amend the
legislation
Arguments
Option 2:
As Technical Regulation
by Resolution of the
Cabinet of Ministers
Option 3:
As Article of the new
Energy Efficiency Law
which requires the
transposition of the
Directive as Technical
Regulation by
Resolution of the
Minor weight of a
(secondary legislation)
Provides foundation in
primary legislation
Might be more
susceptible to attempts
to amend the regulation
Stable legal framework,

due to foundation in
primary legislation
Evidence
Option 1 is supported by:
SGUA
The Ministry of Ecology and
Natural Resources
Option 2 is supported by:
Ministry of Economy
European Business
Association
Option 3 was mentioned by
SAEE as a viable alternative
General assumption based
on international best
practice
General assumption based
on international best
practice
Ministry of Economy and
SAEE consider TR as less
susceptible to attempts to
amendments
Comments by ITS
The preferences articulated
by these organisations were
based on several of the
arguments mentioned in
this table
Transposition as, or
foundation in, primary
legislation should be
considered as the preferred
option
Notwithstanding the
arguments by the Ministry
of Economy and SAEE,
foundation of the
transposed Ecodesign
Directive in primary
legislation should provide a
more stable legal
framework
___________________________________________________________________________27
Criteria
Leverage to Government
to enforce
implementation
Certainty for investors
Compliance with EU legal

framework
Provides more leverage

to the Government to
enforce its
implementation
More certainty for

investors when
considering longpayback investments in
upgrades of production
facilities
Transposition as a Law
reflects the legal
character of the
Ecodesign Directive,
which provides "the
framework for the
setting of Ecodesign
requirements for
energy-related
products" and for the
implementing
measures for each ErP
Arguments
Provides less leverage to
the Government to
enforce its
implementation
Provides leverage to
Government to enforce
the implementation of
the Directive
transposed as Technical
Regulation
Evidence
General assumption,
although the Ministry of
Economy and SAEE argued
that the transposition as TR
would be easier to control
and monitor
May provide less

certainty for investors,
increasing risk-weighted
cost of capital
Provides certainty for

investors
Investors may consider a

legal framework based on a
Law as more stable
Placing the framework

Directive on the same
level as product-specific
regulations contradicts
EU practice
Not fully in line with EU

practice
EU legislation on Ecodesign:
Directive and productspecific implementing
measures (regulations)
Comments by ITS
Notwithstanding the
arguments by the Ministry
of Economy and SAEE,
foundation of the
transposed Ecodesign
Directive in primary
legislation should provide
more leverage to the
Government for
enforcement
Foundation of the
Ecodesign Directive in
primary legislation will
increase investor
confidence
Although transposition as a
Law will be most compliant
with the EU legal
framework for Ecodesign,
other options do not
contradict the obligations
of Ukraine under the
Association Agreement
___________________________________________________________________________28
Criteria
Swiftness of
implementation
Potential impact on
macro-financial assistance
Existing legislation
Very long periods are

needed by the
Ukrainian Parliament
to pass laws, leading to
uncertainty regarding
the date of
implementation of a
Law transposing the
Directive.
Ecodesign Directive
may become part of
the required structural
reform measures for
macro-financial
assistance in 2017,
which will provide a
strong incentive to
Parliament for a timely
transposition
Does not comply with
relevant legal
documents
Arguments
Allows a rather swift
legal procedure, which
would not involve
Parliament
Allows a rather swift

implementation of the
Ecodesign Directive as
Technical Regulation,
probably even ahead of
the promulgation of
the new Energy
Efficiency Law
Transposition as
Technical Regulation will
meet the deadline 2017
Transposition as
will meet the deadline
2017
Relevant legal
documents stipulate the
transposition of the
Directive as:
By regulatory acts of the
(technical regulation)
Complies with relevant

documents, as the
Directive would be
implemented as
Technical Regulation,
under the umbrella of
the New Energy
Efficiency Law
Evidence
The draft new Energy
Efficiency Law has already
been debated in Parliament
for the last seven years.
Precedent is the EU Energy
Labelling Directive
2010/30/EU which was
transposed in August 2013
by Resolution no. 702 of the
Cabinet of Ministers, as a
Technical Regulation, within
a period of less than 15
months.
Communication by SGUA
Comments by ITS
The usually long periods
required by the Ukrainian
Parliament for passing laws
are a major concern and a
strong argument for
pursuing Option 2 or 3.
This argument is
strengthened by the
positive experience in
transposing the Energy
Labelling Directive in 2013
Action Plan on
implementation of the
Association Agreement
between Ukraine and the
European Union
Plan for the
implementation of Directive
2009/125/EC and
Commission Regulations
Strategy of development of
the system of TR until 2020
Option 1 obviously
contradicts the stipulation
of various relevant legal
documents, whereas
Option 2 is in full
compliance and Option 3
does not contradict it.
An important argument in
favour of Option 1, as far as
this possibility is confirmed.
___________________________________________________________________________29
Criteria
Compliance with
Ukrainian legal framework
In the case that the

Law would be initiated
by a Government
entity to be submitted
by the Cabinet of
Ministers to
Parliament, the
could conclude that
certain stipulations in
the draft legal act
would characterise it
as a Technical
Regulation and thus
prevent it to qualify to
be presented as draft
law.
Arguments
Law on Technical
Regulations and
Compliance Assessment
includes stipulations
which could be
interpreted in favour of
transposing the
Ecodesign Directive as a
Would not be in
contradiction to the
Law on Technical
Regulations and
Compliance
Assessment
Evidence
The definition of a
Technical Regulation in
Article 1 and the
stipulations in Article 9 of
the Law, the Ecodesign
Directive would qualify as a
technical regulation, taking
into consideration e.g.
article 3(1.) and article 5(1.)
of Directive 2009/125/EC.
Communicated by Ministry
of Economy.
Comments by ITS
Although the interpretation
of the stipulations of the
Law of Technical
Regulations and
Compliance Assessment by
the Ministry of Economy
are debatable, it may not
be taken for granted that
CMU would pronounce
again submission to the
Parliament of a law
transposing the Ecodesign
Directive. This would not be
the case if the respective
bill would be presented in
Parliament.
___________________________________________________________________________30
6. Prioritisation of the Introduction of Ecodesign Technical Regulations in

Ukraine
6.1. Scope
The scope of products featured under the assignment is detailed in Table 6.1. The source of the
scope is the "Strategy for Development of the System of Technical Regulations until 2012", published
as Resolution 844 of the Cabinet of Ministers on 19 August 2015, which identified 22 Ecodesign
product groups. Table 6.1 also indicates which product groups SAEE either has or intends to
introduce an Energy Labelling technical regulation.
Table 6.1: Product scope and the associated regulatory intention
No Product Group
Ecodesign
Implementing
Measure
Intention
for Energy
Labelling
Regulation
1 Household refrigerating appliances
(EC) No 643/2009
2 Household washing machines
(EU) No 1015/2010
3 Household dishwashers
(EU) No 1016/2010
4 Non-directional household lamps
(EC) No 244/2009
(EC) No 859/2009
(EU) No 2015/1428
5 Directional lighting: luminaires, reflector lamps and (EC) No 1194/2012

LEDs
(EU) No 2015/1428
6 Tertiary lighting
(EC) No 245/2009
(EU) No 347/2010
(EU) No 2015/1428
7 Standby and network standby
(EC) No 1275/2008
(EU) No 801/2013
N/A
8 Simple set-top boxes
(EC) No 107/2009
N/A
9 External power supplies
(EC) No 278/2009
N/A
10 Electric motors
(EC) No 640/2009
(EU) No 4/2014
N/A
11 Televisions
(EC) No 642/2009
Draft
12 Industrial Fans (125W-500kW)
(EU) No 327/2011
N/A
13 Air conditioners and comfort fans
(EU) No 206/2012
Draft
14 Water pumps
(EU) No 547/2012
N/A
15 Glandless standalone circulators and glandless

circulators
(EC) No 641/2009
(EU) No 622/2012
N/A
16 Household tumble driers
(EU) No 932/2012
Draft
17 Computers and computer servers
(EU) No 617/2013
N/A
18 Vacuum cleaners
(EU) No 666/2013
Draft
19 Space and combination heaters
(EU) No 813/2013
Draft
___________________________________________________________________________
31
20 Water heaters and hot water storage tanks
(EU) No 814/2013
Draft
21 Domestic ovens, hobs and range hoods
(EU) No 66/2014
Draft
22 Small, medium and large power transformers
(EU) No 548/2014
N/A
SAEE is seeking a prioritised order in which to transpose and adopt the 22 Ecodesign TRs in Table 6.1.
This section presents the criteria used to assess the product groups, and the resulting recommended
prioritised order for the transposition and adoption of the Ecodesign TRs.
6.2. Methodology
In discussion and agreement with SAEE, four criteria have been proposed and selected in which to
assess and prioritise the 22 Ecodesign product groups featured in Table 6.1. The criteria are
presented below in priority order:
1. The Ecodesign product group commitments made within the Action Plan for the
Implementation of the Association Agreement 37 in 2014;
2. The complementarity of introducing an Ecodesign TR for a product group that in Ukraine
already has an existing Energy Labelling TR;
3. The anticipated level of technical complexity and contentiousness involved within the
process to develop, consult, adopt and implement the product specific TRs;
4. The expected energy savings as a result of the implementation of the individual product
specific TRs.
The first criterion reflects the Ecodesign product groups specifically identified within the Action Plan
for the Implementation of the Association Agreement.
The second criterion reflects the desire from SAEE to complement the product groups in Ukraine
which already have an existing Energy Labelling TR with the associated Ecodesign TR.
The third criterion is a more subjective assessment of the Ecodesign product groups based upon the
level of technical complexity and contentiousness involved in introducing the proposed Ecodesign
TRs. The concept of utilising parameters such as technical complexity and contentiousness in the
context of preparing and adopting Ecodesign product regulations was proposed by Hans-Paul
Siderius a respected Standards and Labels International expert, based at the Netherlands Enterprise
Agency 38. Technical complexity is defined as a product with a large variation of product types, user
options, operating modes, features, interdependent subsystems, for which it is complicated to set an
efficiency metric or for which it is not easy to measure performance. Contentiousness refers to the
political sensitivity of addressing the efficiency of the product, including the likelihood of industry,
consumer and social objections to banning certain product variants, or the measure having a
significant effect on certain performance parameters or influence on energy infrastructure. The
resulting assessment is based upon ICF Internationals first-hand experience of witnessing the
progress over the last 10 years of the EU Ecodesign preparatory and adoption process from
delivering Ecodesign technical support services to the UK Governments Energy using Products
37
38
Approved by Resolution of the Cabinet of Ministers of Ukraine #847, 17 September 2014

Speeding up adoption of Ecodesign and Energy Label Measures, ECEEE 2013 (Hans-Paul Siderius)
___________________________________________________________________________
32
Programme. This has for example included considerable difficulty and delay (primarily because of
technical complexity) related to the development of the space and combination heaters regulation,
along with legal challenge from industry, and considerable adverse media coverage related to the
vacuum cleaners regulation.
The fourth criterion considers the amount of energy projected to be saved as a result of introducing
the regulatory measure. The figures are sourced directly from the ECs Impact Assessments, which
are conducted as part of the regulatory adoption process. The outputs are therefore based on
potential energy savings in the EU-28. However this method could be used as a proxy indicator of the
relative contribution that each product specific TR could make to energy savings in Ukraine. This
method provides some guidance in the absence of a detailed national picture of the stock of ErPs in
residential and non-residential buildings, of the ownership rates, the annual sales figures, the
product lifetime, their energy consumption and how the products are used in real-world settings (i.e.
user behaviour). Clearly there exists a risk in taking the projected energy savings for the EU-28 and
utilising them within a discussion on how much energy could be saved in Ukraine, because the
context (especially on energy and product pricing) and available technologies are different. This risk
should be remembered when considering the projected energy savings as a proxy indicator for
Ukraine.
6.3. Results
6.3.1 Criterion 1 Prioritisation by Commitments within the Action Plan for the Implementation of
the Association Agreement
The Association Agreement between Ukraine and the EU was ratified by the Parliament of Ukraine in
September 2014, which includes the creation of a DCFTA 39. As part of the Association Agreement, a
number of commitments were made with respect to the Ecodesign Framework Directive and its
Implementing Measures for transposing into Ukrainian law. These commitments were detailed
within the proceeding Action Plan on the Implementation of the Association Agreement which
specified that the Framework Directive (2009/125/EC) and the following implementing measures be
adopted into Ukrainian Law by August 2017:
Standby/off-mode horizontal measure, EC Regulation No 1275/2008;

Simple set top boxes, EC Regulation No 107/2009;
Non-directional household lamps, EC Regulation No 244/2009;
Tertiary lighting, EC Regulation No 245/2009; and
External power supplies, EC Regulation No 278/2009.
Therefore, in order for SAEE to fulfil and comply with the Resolution of the Cabinet of Ministers,
these five product groups will each carry the number 1 priority for introducing the corresponding
Ecodesign TR in Ukraine.
6.3.2 Criterion 2 Prioritisation by Complementing product groups in Ukraine which already have
an existing Energy Labelling Technical Regulation with an Ecodesign Technical Regulation
Table 6.1 listed the six product groups which already have a corresponding Energy Labelling TR
39
http://ec.europa.eu/trade/policy/countries-and-regions/countries/ukraine/
___________________________________________________________________________
33
adopted in Ukraine. These are:
Household refrigerating appliances

Household washing machines
Household dishwashers
Non-directional household lamps
Directional lighting: luminaires, reflector lamps and LEDs
Tertiary lighting
In addition, there are a further seven product groups which have a draft Energy Labelling TR either in
development or going through the inter-ministerial approval process for TRs these are listed below:
Televisions
Air conditioners and comfort fans
Household tumble driers
Vacuum cleaners
Space and combination heaters
Water heaters and hot water storage tanks
Domestic ovens and range hoods
The six product groups with an existing adopted Energy Labelling TR will be attributed a value of 1 in
the proceeding prioritisation assessment. The further seven product groups which are currently
going through the process of preparing and adopting an Energy Labelling TR will be attributed a value
of 0.5. The remaining product groups will be attributed a value of 0.
6.3.3 Criterion 3 Prioritisation by Level of Technical Complexity and Contentiousness
Table 6.2 presents the outputs of the exercise to assess each of the 22 Ecodesign product groups
against the parameters of technical complexity and contentiousness, based upon experience of
involvement in the EU Ecodesign regulatory process. A scale of 1-5 is used for assessing against each
parameter, with 1 being the lowest and 5 being the highest. The two values are then added together
creating one total score for each product group.
___________________________________________________________________________
34
Table 6.2: Ecodesign Product group assessment according to the technical complexity and contentiousness
scale
Measure
Technical
Complexity
Contentiousness
Total
10
Vacuum cleaners
Computers and computer servers
Standby and network standby
Tertiary lighting
Electric motors
Directional lighting
Domestic ovens, hobs and range hoods
Televisions
Industrial Fans (125W-500kW)
Water pumps
Circulators
Small, medium and large power transformers
Simple set-top boxes
External power supplies
6.3.4 Criterion 4 Prioritisation by Projected EU Energy Savings by 2020

Table 6.3 presents the outputs from the ECs projections from the amount of energy saved from the
introduction of Ecodesign and Energy Labelling TRs for each of the 22 product groups. The Ukrainian
___________________________________________________________________________
35
regulatory intention for each product group (i.e. whether or not to introduce both Ecodesign and
Energy Labelling TRs) is directly linked to the regulations in existence within the EU. No data were
available to the authors on the relative penetration and energy performance of the listed product
groups in Ukraine. In the absence (at time of writing) of such data, the value of the energy savings
listed in the Commissions Impact Assessments was chosen as a proxy for the situation in Ukraine. It
is likely that there are differences in penetration levels (e.g. for dishwashers and tumble driers),
pricing and usage of some product groups in Ukrainian conditions, and so the proposed ranking
should be re-considered when suitable Ukrainian data become available to allow local impact
assessment. The 22 product groups are ranked in Table 6.3 according to the projected energy savings
with the product group delivering the most energy savings ranked first.
Table 6.3: Ranked energy savings in TWh for the 22 Ecodesign product groups
Measure
Space and
combination
heaters
Reduction in
Annual EU
Electricity
Consumption
by 2020 40
Ukrainian Comment on EU Impact

Regulatory Assessment
Intention
523.35 TWh Ecodesign

45 Mtoe and Energy
Labelling
Rank 41
The Impact Assessment did not

separate out Ecodesign but SAEE
plans to implement both measures
in the long term. The savings were
not expressed by the EC in TWh but
using an online conversion 42, a
figure for converting Million tonnes
of oil equivalent into TWh is
presented.
Electric motors
139 TWh
Ecodesign
The Impact Assessment focused on

Ecodesign, which is in line with the
plans from SAEE.
Industrial Fans
(125W-500kW)
54 TWh
Ecodesign

plans from SAEE. This regulation is
currently under review in the EU.
Simple set-top
boxes
47 TWh
Ecodesign

plans from SAEE.
Televisions
43 TWh
Ecodesign and The Impact Assessment focused on

Energy
Ecodesign and Energy Labelling,
Labelling
which is in line with the plans from
SAEE. This regulation is currently
under review in the EU.
Non-directional
39 TWh
Ecodesign and Note that the implementation of
40
As taken from the product specific Impact Assessments http://ec.europa.eu/smartregulation/impact/index_en.htm

41
10 = highest; 1 = lowest
42
http://www.conversion-website.com/energy/ton-of-oil-equivalent-to-terawatt-hour.html
___________________________________________________________________________
36
household lamps
Energy
Labelling
stage 6 of EC Regulation No
244/2009 has been delayed by 2
years to 2018, thus ensuring these
savings are not fully realised by
2020 as originally intended. The
Impact Assessment did not separate
out Ecodesign from labelling. SAEE
also plans to introduce the
Ecodesign TR alongside the existing
Energy Labelling TR. This regulation
is currently under review in the EU.
A more comprehensive light
sources regulation is anticipated in
late 2016.
Tertiary lighting
38 TWh
Ecodesign and The Impact Assessment did not

Energy
separate out Ecodesign from
Labelling
labelling. SAEE also plans to
introduce the Ecodesign TR
alongside the existing Energy
Labelling TR. This regulation is
currently under review in the EU. A
more comprehensive light sources
regulation is anticipated in late
2016.
Standby and
network standby
35 TWh
Ecodesign

plans from SAEE. This regulation is
Glandless
standalone
circulators and
glandless
circulators
26.6 TWh
Ecodesign

plans from SAEE.
Directional Lamps,
LED Lamps and
related equipment
24.7 TWh

Energy
Labelling
implement the Ecodesign measure
currently under review in the EU. A
more comprehensive light sources
regulation is anticipated in late
2016.
10
Water heaters and

hot water storage
tanks
19 TWh

Energy
Labelling
labelling, but SAEE plans to
implement both measures.
11
Vacuum cleaners
18.8 TWh

Energy
Labelling
12
Computers and
computer servers
16.3 TWh
Ecodesign
13

Ecodesign as there is no
___________________________________________________________________________
37
corresponding Energy Labelling

regulation, which is in line with the
plans from SAEE.
43
16.2 TWh*
Ecodesign
Household Tumble
Dryers
12.9 TWh

Energy
Labelling
15
Air conditioners
and Comfort Fans
11 TWh

Energy
Labelling
16
External power
supplies
9 TWh
Ecodesign
17
Domestic ovens,
hobs and range
hoods
7.5 TWh
Water Pumps
4.6 TWh
Household
refrigerating
appliances
4 TWh
27 PJ
*Note that this saving is calculated

to 2025 given tier II requirements
only enter into force in 2021 (to
allow time for development of
amorphous core technology). The
Impact Assessment focused on
Ecodesign as there is no
corresponding Energy Labelling
regulation, which is in line with the
plans from SAEE.
14
Small, medium
and large power
transformers

plans from SAEE. Note this
regulation is currently being
reviewed in the EU to consider
alignment with US regulations.

Energy
Labelling
implement both measures. The
savings were not expressed by the
EC in TWh but using an online
conversion 43, a figure for converting
PJ into TWh is presented.
18
Ecodesign

plans from SAEE.
19

Energy
Labelling
Labelling TR. Note that because of
the long lifetime of refrigerating
appliances, there is an inertia in the
20
http://www.conversion-website.com/energy/gigajoule-to-terawatt-hour.html
___________________________________________________________________________
38
realisation of the savings. The

savings increase to 12 TWh by 2025.
This regulation is currently under
review in the EU.
1.7 to 2 TWh Ecodesign and The Impact Assessment did not
Energy
Labelling
21
Household
1.2 to 1.5 TWh Ecodesign and The Impact Assessment did not
washing machines
Energy
Labelling
labelling, SAEE also plans to
22
Household
dishwashers
6.3.5 Prioritisation
Calculation Method
The method for combining the individual criteria is summarised in Figure 6.1 below:
Figure 6.1: Method for integrating the 4 criteria to produce the prioritised list
Prioritised Order
The summation of the outputs from the four criteria and the resulting prioritised order are presented
in Table 6.4 below.
___________________________________________________________________________
39
Table 6.4: Prioritisation order for the preparation and adoption of the 22 Ecodesign technical regulations in Ukraine
___________________________________________________________________________40
6.4 Conclusions
The final prioritised order (Table 6.5) represents a rationally derived basis upon which SAEE can
approach the introduction of Ecodesign TRs in Ukraine.
Table 6.5: Final prioritised order for the Ecodesign technical regulations in Ukraine
No
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Product Group
Simple Set Top Boxes
External Power Supplies
Tertiary Lighting 44
Non-directional Household Lamps8
Standby/Off-mode
Directional lighting: luminaires, reflector lamps and LEDs8
Televisions
Vacuum cleaners
'Industrial' products
Circulators
Transformers
Water pumps
Electric motors
It can be seen that the space and water heaters product group ranks highest for energy savings, but
also ranks highest for technical complexity and contentiousness. Negotiating the EU regulation for
this product group took seven years much longer than other regulations. So, whilst it might seem
attractive to target the introduction of Ecodesign regulations for space and water heaters to receive
significant energy savings, it might well take a long time and consume a lot of resources to approve
the regulation it could also create a negative perception within government, industry and civil
society for Ecodesign. It is therefore suggested to begin in Ukraine with the introduction of product
groups, with more modest energy saving potential, that are considerably less complex and
contentious, in order to prove the process and gain a positive stakeholder perception for the
regulations.
The list starts with the product groups cited in Resolution #847, these include Simple Set Top Boxes
and External Power Supplies, which should be relatively easy to deliver and will serve to prove the
process within Ukraine. Then SAEE can progress onto tertiary and non-directional lighting which are
more contentious, but with greater energy savings. In doing so the current EU review of the lighting
regulations (also including directional lighting) should be considered, which is expected to simplify
these three regulations into a single one by the end of 2016. Once the obligations under Resolution
44
Note that the three lighting regulations (which are also listed in the Action Plan for the Association
Agreement) are currently being reviewed in the EU with the intention of superseding them with a combined,
single light sources Ecodesign regulation, accompanied by a single light sources Labelling regulation. The first
draft working document for this combined regulation is available. The earliest anticipated date that such a
regulation could come into force would be December 2016.
___________________________________________________________________________
41
#847 are delivered, SAEE can progress to complement those product groups in Ukraine which already
have an Energy Labelling regulation. These product groups begin with household appliances such as
refrigerators and washing machines. It should be noted that the projected energy savings for
household appliances could be larger for Ukraine, in relative terms, compared with the EU
projections, given that energy using product policy has been in existence for these product groups in
the EU for approximately 20 years and so the resulting energy savings from further regulatory
strengthening are diminishing: this is not the case for Ukraine. The list concludes with the remainder
of the residential and household products and space heaters which is expected to be the most
difficult.
Please note that the industrial products listed from circulators through to computers and computer
servers 45 are at the bottom of the list only because they are not included in Resolution 847 and they
are not subject to existing labelling regulations in Ukraine (or the EU). The lack of labelling for these
products is because industrial consumers do not use packaging labels to the same extent as mass
market consumers, i.e. purchasing an industrial motor from a wholesaler is a different experience
than purchasing a TV in a retail outlet. This is because industrial consumers have professional
procurement staff used to reviewing technical specifications of products, including energy savings
levels. The energy savings possible from this industrial group, especially from motors, fans and
circulators, are particularly high and are rightfully the subject of a separate industrial products
initiative from SAEE. It is right to treat industrial products differently and so that initiative should
take precedence over this proposed prioritisation.
7. Harmonised Standards for Products Covered by Ecodesign and Energy

Labelling Regulations
7.1 Scope
The scope of products featured under this assignment together with the Ukrainian Governments
intention for regulation for each product category is detailed in Table 7.1 below. For the first six
product groups listed 46, Energy Labelling TRs are already adopted in Ukraine.
Table 7.1: Product scope and the associated regulatory intention
Measure
Ecodesign
Energy Labelling
Household refrigerating
appliances*
(EC) No 643/2009
(EC) No 1060/2010
Household washing machines*
(EU) No 1015/2010
(EU) No 1061/2010
Household dishwashers*
(EU) No 1016/2010
(EU) No 1059/2010
45
The computers regulation 617/2013 refers to PCs, notebooks and small servers. These are not subject to
labelling in Europe because of an agreement between the EU and the US government to adopt the ENERGY
STAR label for such equipment. Use of the ENERGY STAR label is widespread for such equipment and it is
recommended that SAEE consider its use in Ukraine. A preparatory study covering the use of more powerful
but less ubiquitous enterprise servers and associated networking equipment (used for example in data
centres) has been recently completed and a related Ecodesign regulation is under development.
46
An asterisk* indicates this product group has a technical regulation for Energy Labelling approved in Ukraine.
___________________________________________________________________________
42
Measure
Ecodesign
Energy Labelling
Non-directional household lamps*
(EC) No 244/2009
(EC) No 859/2009
(EU) No 2015/1428
(EU) No 874/2012
Directional lamps, LED lamps and

related equipment*
(EC) No 1194/2012
(EU) No 2015/1428
(EU) No 874/2012
Tertiary lighting*
(EC) No 245/2009
(EU) No 347/2010
(EU) No 2015/1428
(EU) No 874/2012
Domestic ovens, hobs and range

hoods
(EU) No 66/2014
(EU) No 65/2014
Air conditioner and comfort fans
(EU) No 206/2012
(EU) No 626/2011
Household tumble dryers
(EU) No 932/2012
(EU) No 392/2012
(EU) No 813/2013
(EU) No 811/2013
Water heaters and hot water

storage
(EU) No 814/2013
(EU) No 812/2013
Vacuum Cleaners
EU) No 666/2013
(EU) No 665/2013
Televisions
(EC) No 642/2009
(EU) No 1062/2010
Water pumps
(EU) No 547/2012
N/A
(EU) No 617/2013
N/A
Transformers
(EU) No 548/2014
N/A
(EC) No 1275/2008
(EU) No 801/2013
N/A
(EC) No 107/2009
N/A
(EC) No 278/2009
N/A
Electric motors
(EC) No 640/2009
(EU) No 4/2014
N/A
(EU) No 327/2011
N/A
Glandless standalone circulators

and glandless circulators
(EC) No 641/2009
(EU) No 622/2012
N/A
7.2 European Harmonised Measurement Standards and Transitional Methods of

Measurement
7.2.1 Scope
Not all of the product groups covered by this assignment have European harmonised standards 47
(see Table 7.2).
47
http://ec.europa.eu/growth/single-market/european-standards/harmonisedstandards/ecodesign/index_en.htm
___________________________________________________________________________
43
Table 7.2: Product Groups with and without associated European Harmonised Standards
Measure
European
Transitional Methods
Harmonised Standard of Measurement
Air conditioner and comfort fans
Household tumble dryers
Vacuum Cleaners
Transformers
Electric motors
Glandless standalone circulators and glandless circulators
Water heaters and hot water storage
Water pumps
Directional lamps, LED lamps and related equipment
Tertiary lighting
Televisions
N/A
N/A
The majority of the product groups that do not have European harmonised standards, have instead a
set of transitional methods of measurement: that is a set of measurement methods issued by the EC
intended to cover the intervening period from when a regulation is adopted in the EU to when a
European harmonised standard can be published. Simple set top boxes and industrial fans have
neither European harmonised standards nor transitional methods of measurement.
Annex 5 provides lists of product groups with European Harmonised Standards, product groups with
Transitional Methods of Measurement, and product groups without either European Harmonised
Standards of Transitional Methods of Measurement, indicating the respective standards or
transitional methods for measurement and/or EC mandates, and their applicability to Ecodesign and
Energy Labelling.
7.3 European Harmonised Measurement Standards and Transitional Methods of

Measurement
There are ten product groups under this assignment without European harmonised standards. They
are currently subject to the development process whereby the European Standards Organisations
(ESOs) act upon the mandate issued to them by the EC inviting them to create European harmonised
___________________________________________________________________________
44
standards. The status of each product group is summarised in Table 4.1 of Annex 5. Where otherwise
not referenced, the source of information for Table 4.1 of Annex 5 was ECOS: the European
Environmental Citizens Organisation for Standardisation 48.
The workload directed to the ESOs in recent years has increased considerably, and as can be seen
from table 4.1 in Annex 5 significant delays are now materialising. In order to better facilitate the
response for developing European harmonised standards, CEN and CENELEC have created the
Ecodesign Coordination Group 49. All mandates go through this group, which has stakeholders from
the various standardisation technical committees, industry associations, civil society groups and the
EC. This is a forum where EC officers can answer questions from stakeholders and explain their
expectations for the harmonised standards.
The CEN & CENELEC Ecodesign Support Group has set up a number of Task Forces to deal with
horizontal Ecodesign issues related to standardisation. These are: terms and definitions (task force
1), tolerances and measurement uncertainties (task force 2), Ecodesign Energy Performance of
Buildings Coordination (task force 3) and material efficiency (task force 4).
8. Support to the VII International Investment Business Forum on Energy

Efficiency and Renewable Energy
From 10 to 13 November 2015, SAEE organised the VII International Investment Business Forum on
Energy Efficiency and Renewable Energy in Kyiv.
ITS contributed to the Forum by organising and implementing workshops on "Ecodesign: the
experience of the EU and first steps in Ukraine" and "Awareness Raising for Energy Efficiency", by
providing an experts' zone and by providing logistical support to the Forum.
Both workshops were attended by almost 100 participants.
The workshop agendas, presentations, list of participants, and other pertinent documents are
available at:
http://www.inogate.org/activities/627?lang=en&order=date_issue_desc&section=documents
ITS received letters of recognition signed by Mr Sergey Savchuk, Chairman of SAEE, acknowledging
the contributions to the Forum and the Workshops on Ecodesign and Awareness Raising (see Annex
6).
8.1 Workshop "Ecodesign: the experience of the EU and first steps of Ukraine"
The workshop Ecodesign: the experience of the EU and first steps of Ukraine focussed on past and
current developments in Ecodesign in the EU, and on SAEE's current activities in this field. The
workshop provided an opportunity to review the past and current work of SAEE on Energy Labelling,
and to discuss first steps towards the transposition of the EU Ecodesign Directive and of specific
regulations for ErPs.
48
49
http://ecostandard.org/
http://www.cencenelec.eu/standards/Sectors/SustainableEnergy/Ecodesign/Pages/default.aspx
___________________________________________________________________________
45
Following an opening address by Mr Krzysztof Gierulski, Member of the Support Group for Ukraine of
the EC, and welcome words on behalf of Mr Sergey Savchuk, Chairman of SAEE, the following topics
were addressed by speakers of ITS, SAEE and the Ministry of Economy of Ukraine:
An introduction to Energy Labelling and Ecodesign, which have been cornerstones of the EU
Energy Policy, since 1992 and 2005 respectively;
An overview on the EU Ecodesign Directive 2009/125/EC, requirements under the Directive
and the energy savings achieved;
The Ecodesign process - from preparatory study to implementation;
Verification procedures and market surveillance for regulated ErPs;
An overview on SAEE's achievements in Energy Labelling, in particular the transposition of
the EU Energy Labelling Directive 2010/30/EU and of regulations for specific products, as well
as the current work programme to introduce labelling for more products;
The transposition of Energy Labelling and Ecodesign requirements according to the EU
Ukraine Association Agreement;
The current assistance by ITS towards the transposition of the EU Ecodesign Directive and of
regulations for energy related products in Ukraine.
8.2 Workshop "Awareness Raising for Energy Efficiency"

A separate half-day workshop on Awareness Raising for Energy Efficiency was held later on the
same day to present the EU experience in raising public awareness on energy efficiency, recent
initiatives of ITS in Eastern Partnership countries as well as the corresponding initiatives of SAEE in
Ukraine. Among the speakers were representatives of SAEE and ITS.
8.3 Experts zone

In cooperation with SAEE, ITS provided an experts' zone, where ITS experts provided information and
answered questions of visitors of the Forum on EU and Ukrainian product policies, and particularly on
Energy Labelling and Ecodesign.
For this purpose, ITS elaborated two leaflets: "What is Ecodesign and why do we need it in Ukraine"
(in Ukrainian and English) and "What is Energy Labelling" (in Ukrainian), which were available for
visitors of the experts zone, with the objective to raise awareness among the interested public (see
http://www.inogate.org/activities/627?lang=en&order=date_issue_desc&section=documents).
8.4 Logistical support

ITS provided logistical support to the Forum, which included all services required for the workshops
mentioned under Sections 8.1. and 8.2 and the experts zone (Section 8.3), as well as general support
services to the four-day Forum.
9. Further steps
Further to the tasks and deliverables documented in this report, ITS will assist SAEE in the
preparation of a report to the Energy Community Secretariat (ECS) on the progress in introducing
___________________________________________________________________________
46
Energy Labelling and Ecodesign regulations in Ukraine, taking into consideration the progress and
results of the tasks carried out in this activity.
Part of the communication with the ECS will be a consultation with regard to the required structural
changes to Ukrainian TRs compared to the corresponding EU Regulations, which stem from current
Ukrainian legislation, including the Resolution of the Council of Minsters #708/2012 on Normative
References.
10. Conclusions and Recommendations

This assignment included various activities, which can be grouped under the following headlines:
Translations of EU Ecodesign Regulations into Ukrainian and of existing Ukrainian TRs for
Energy Labelling of ErPs in English;
The review of five draft TRs for Energy Labelling;
Advise with regard to the most appropriate legal option to transpose the EU Ecodesign
Directive into Ukrainian legislation;
Advise with regard to the prioritisation of the introduction of Ecodesign TRs for ErPs in
Ukraine;
Provide a list of European harmonised measurement standards for products covered by
existing and future Ecodesign and Energy Labelling Regulations in Ukraine;
Support to the VII International Investment Business Forum on Energy Efficiency and
Renewable Energy (10-13th November 2015), in particular the organisation and
implementation of workshops on Ecodesign and Awareness Raising, and the implementation
of an Experts' Zone.
While the conclusions and recommendations on each topic have been provided in the respective
sections of this report, they are briefly summarised below.
Translations of EU Ecodesign Regulations into Ukrainian and of existing Ukrainian Technical
Regulations for Energy Labelling of ErPs into English
All translations were submitted in accordance to the time schedule agreed upon. In the process for
translation of the existing TRs for Energy Labelling minor inconsistencies with the corresponding EU
CDRs were detected and communicated to SAEE.
Review of five draft Technical Regulations for Energy Labelling
In the reviews of the draft TRs for household tumble driers, household ovens & range hoods, vacuum
cleaners, air conditioners and water heaters (without annexes) comments received in the process of
the inter-ministerial approval process were addressed, together with inconsistencies with the
corresponding EU CDRs and Ukrainian legal acts, in particular the Law of Ukraine "On technical
regulation and conformity assessment" and Rules of preparing technical regulations based on EU
legislation (Resolution of CMU of 12.06.2012 #708). The reviews were submitted for SAEE's
consideration and comments.
Advise with regard to the most appropriate legal option to transpose the EU Ecodesign Directive
into Ukrainian legislation
Based on meetings with SAEE and stakeholders, and the review of pertinent legal documents, ITS
evaluated three options for the transposition of the Ecodesign Directive into Ukrainian legislation: (1)
___________________________________________________________________________
47
as a Law of Ukraine, (2) as a Technical Regulation based on a Resolution of the Cabinet of Ministers,
and (3) as an Article of the new Energy Efficiency Law which requires the transposition of the
Directive as Technical Resolution by Resolution of the Cabinet of Ministers. ITS analysed arguments
for and against each of these options, referring to relevant criteria, mentioning the related evidence.
While there are strong arguments in favour of transposition as a Law, the legal documents reviewed
stipulate that the transposition of the Directive must be as a legal act (technical regulation) of the
Cabinet of Ministers. On the other hand, transposition as an Article of the new Energy Efficiency Law
which requires the transposition for the Directive as TR by Resolution of the Cabinet of Ministers,
satisfies all criteria of the analysis applied and is recommended as the most viable option, which will
facilitate timely implementation of the Directive, and at the same time ground it in a Law of Ukraine,
thereby giving it legal force and providing stability to inspire investor confidence.
Advise with regard to the prioritisation of the introduction of Ecodesign Technical Regulations for
energy-related products in Ukraine
SAEE is seeking a prioritised order in which to transpose and adopt the 22 Ecodesign TRs which are
due to be transposed as part of Ukraine's commitment under the EU Ukraine Association
Agreement. Following consultation with SAEE, ITS proposed an order of priority based on the
following criteria: (i) the Ecodesign product group commitments made within the Action Plan for the
Implementation of the Association Agreement in 2014, (ii) the complementarity of introducing an
Ecodesign TR for a product group that in Ukraine already has an existing Energy Labelling TR, (iii) the
anticipated level of technical complexity and contentiousness involved within the process to develop,
consult, adopt and implement the product specific TRs, and (iv) the expected energy savings as a
result of the implementation of the individual product specific TRs.
The application of these criteria results in four orders of priority and the ranking shown in Table 6.4.
The list starts with the product groups cited in Resolution #847, include simple set top boxes,
external power supplies, and tertiary and non-directional lighting. Once the obligations under
Resolution #847 are delivered, SAEE can progress to complement those product groups in Ukraine
which already have an Energy Labelling regulation, including household appliances such as
refrigerators and washing machines. The list concludes with the remainder of the residential and
household products and space heaters. Industrial products are in a separate list only because they
are not included in Resolution 847 and they are not subject to existing labelling regulations in
Ukraine (or the EU). The energy savings possible from this industrial group, especially from motors,
fans and circulators, are particularly high and are rightfully the subject of a separate industrial
products initiative from SAEE.
Provide a list of European harmonised measurement standards for Products covered by existing
and future Ecodesign and Energy Labelling Regulations in Ukraine
20 of the 22 product groups under consideration are either covered by European harmonised
standards or by transitional methods of measurement issued by the EC, while simple set top boxes
and industrial fans have neither European harmonised standards nor transitional methods of
measurement. Annex 5 provides lists of product groups with European harmonised standards,
product groups with transitional methods of measurement, and product groups without either
European harmonised standards or transitional methods of measurement, indicating the respective
standards or transitional methods for measurement and/or EC mandates, and their applicability to
Ecodesign and Energy Labelling.
Support to the VII International Investment Business Forum on Energy Efficiency and Renewable
Energy (10-13th November 2015), in particular the organisation and implementation of workshops
on Ecodesign and Awareness Raising, and the implementation of an Experts' Zone
___________________________________________________________________________
48
The workshops on Ecodesign and on Awareness Raising, as well as the Experts' Zone, served to
inform stakeholders and the interested public about the experience in the EU in Energy Labelling,
Ecodesign and awareness raising for energy efficiency, and on current and planned activities of SAEE
in these fields. In particular the workshop on Ecodesign provided an opportunity to review the past
and current work of SAEE on Energy Labelling, and to discuss first steps towards the transposition of
the EU Ecodesign Directive 2009/125/EC and of specific regulations for ErPs.
___________________________________________________________________________
49
List of Annexes and Appendices

Annex 1
WORK PLAN FOR 2015 to implement activities within the Protocol of

Intent between the State Agency For Energy Efficiency and Energy Saving
of Ukraine and the technical assistance project under the INOGATE
Programme INOGATE Technical Secretariat and Integrated Programme in
support of the Baku Initiative and Eastern Partnership energy objectives
Annex 2
International Use of Regulation/Date stamped references in Products

Energy Labels
Annex 3
Guidance on the Calculations and Production of Equations from within EU

Regulation 626/2011 Energy Labelling of Air Conditioners
Annex 4
Meeting attendees First and Second Mission of Team of Experts to Ukraine
Annex 5
Harmonised Standards for Products covered by Ecodesign and Energy

Labelling Regulations
Annex 6
Letters of Recognition
Appendix I
Reviews of Draft Technical Regulations for Energy Labelling of (i)

household tumble driers, (ii) domestic ovens and range hoods, (iii) vacuum
cleaners, (iv) air conditioners, (v) water heaters, hot water storage tanks
and packages of water heater and solar device (without annexes).
Appendix II
Translations into Ukrainian of EC Ecodesign Regulations for the following

energy-related products: (i) air conditioners and comfort fans, (ii) water
pumps, (iii) household tumble driers, (iv) directional lamps, LED lamps and
related equipment, (v) computers and computer servers, (vi) vacuum
cleaners, (vii) space and combination heaters, (viii) water heaters and hot
water storage tanks, (ix) domestic ovens, hobs and range hoods, (x) small,
medium and large power transformers.
Appendix III
Translations into English of the existing Technical Regulations transposing

Directive 2010/30/EU, CDR 1060/2010 for household refrigerating appliances
and CDR 1061/2010 for household washing machines (Res. 702 of 7 August
2013 "On approval of technical regulations on Energy Labelling"); CDR
874/2012 for electrical lamps and luminaires (Res. 340 of 27 May 2015);
CDR 1059/2010 for household dishwashers (Res. 514 of 17 July 2015).
___________________________________________________________________________
50

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INOGATE Country Work Plan Ukraine

Technical Assistance to SAEE in the transposition of the

Technical Assistance to SAEE in the transposition of EU Legal Acts on Energy

W.F. Lutz, T. Lock, A. Antonenko, A.

M. Allington, W.F. Lutz

6.4 Conclusions ................................................................................................................................. 41

Commission Delegated Regulation

European Committee for Standardisation

European Committee for Electrotechnical Standardisation

Cabinet of Ministers of Ukraine

Deep and Comprehensive Free Trade Area

Directorate-General for Neighbourhood and Enlargement Negotiations

European Business Association

European Telecommunication Standards Institute

INOGATE Technical Secretariat

Million tonnes of oil equivalent

Official Journal of the European Union

State Agency for Energy Efficiency and Energy Saving of Ukraine

Support Group for Ukraine of the EC

Translations of EU Ecodesign Regulations into Ukrainian and of existing Ukrainian Technical

The transposition of the Ecodesign Directive and of product-specific Ecodesign regulations is

2.2 The process of approving Technical Regulations

A description of each of the stages featured in Figure 2.1 is featured below:

2.3 Baseline indicators

3. Review of draft Technical Regulations for Energy Labelling of Energyrelated Products

Household tumble driers;

Domestic ovens and range hoods;

Ovens & Range Hoods*

4. Translation of EU Ecodesign Regulations and of existing Technical

4.2. Translation of existing Technical Regulations of Energy-related Products

5. Transposition of the EU Ecodesign Directive into Ukrainian Legislation

See Annex 4 for a list of interlocutors.

transpose Directive 2009/125/EC and to implement it as Technical Regulation by Resolution of the

Strategy of development of the system of technical regulation until 202033

5.3. Evaluation of options

5.4. Conclusions and Recommendations

Stable legal framework

Major weight of a Law

Stable legal framework,

Certainty for investors

Compliance with EU legal

Provides more leverage

More certainty for

May provide less

Provides certainty for

Investors may consider a

Placing the framework

Not fully in line with EU

Very long periods are

Allows a rather swift

Complies with relevant

In the case that the

6. Prioritisation of the Introduction of Ecodesign Technical Regulations in

1 Household refrigerating appliances

2 Household washing machines

4 Non-directional household lamps

5 Directional lighting: luminaires, reflector lamps and (EC) No 1194/2012

7 Standby and network standby

8 Simple set-top boxes

9 External power supplies

12 Industrial Fans (125W-500kW)

13 Air conditioners and comfort fans

15 Glandless standalone circulators and glandless

16 Household tumble driers