Anticss
Anti-circumvention of standards for better market surveillance

FAQ

What are your main questions about products, energy efficiency, market surveillance, Ecodesign, energy labels and circumvention? Find out answers to these questions below.

Do contact the project organisers if you want to know more!

What are the ANTICSS project key objectives?

ANTICSS objectives are to assess what "circumvention" actually is and how the EU Ecodesign and Energy labelling legislation and relevant harmonised standards can be circumvented in order to achieve a better product positioning. Its objectives are also to understand 'if' and 'how much' energy consumption and/or functional performance modifications could be ascribed to circumvention; and 'how' circumvention attempts could be unmasked via the definition of new specific procedures or check lists, modified test conditions, "sentinel" parameters to be screened, etc.

What scope of activities ANTICSS project organises?

ANTICSS firstly aims to define what circumvention is in relation to EU Ecodesign and Energy labelling legislation and relevant harmonised standards. It then investigates how they can be circumvented in order to achieve a better product positioning.  The project team collects and discusses evidence on potential circumvention cases, following up with a limited number of laboratory testing of selected product models along with engineering analysis to confirm the circumvention and assess its impact on products’ energy efficiency and functional performance.

What product categories are being investigated?

The project generally focuses on all products regulated by the EU Ecodesign and Energy label legislation: household appliances, information and communication technologies, lighting and others. The final selection of categories to be investigated in depth will be done on the basis of information gathered within the first stages of project research.

What kind of possible circumvention means will be analysed by the project?

The ANTICSS methodology is simple but effective: Elaboration of a detailed definition of what "circumvention" is, to distinguish it from other effects and thus to facilitate unambiguous public communication. 

The non-exhaustive list below includes topics that are addressed in order to assess the meaning of "circumvention":

  • hidden software (defeat devices)
  • (hidden) specific cycle/setting/configuration used only for testing for legislation compliance
  • products specifically designed to be excluded from legislation
  • ambiguities (such as unclear definitions, boundaries) and loopholes in legislation
  • deviations in testing condition(s), allowed or due to possible different interpretation of standard clauses
  • exploiting a weakness in the test procedure’s method for addressing measurement uncertainties
  • actual performances (energy consumption/functional performances) vs. standard cycles/duty cycles
  • decouple measurement of energy consumption and functional performances
  • smart appliances embedded software: the challenge is how to identify "useful" energy saving automatic functions/sensors and connectivity from "circumvention-targeted" sensors/functions/software.

What are expected overall project results?

ANTICSS project team will draw recommendations for policy makers and standardisation bodies on how to identify circumvention habits through laboratory testing and to prevent circumvention risks, thus allowing preparing better circumvention-proof standards and legislation before adoption. In this respect guidelines on "How to detect and avoid circumvention of Ecodesign and Energy labelling legislation and standards", will be prepared targeted to all market economic and non-economic actors and MSAs for a more effective EU legislation enforcement.

The project will support in many ways the increase of confidence among purchasers, manufacturers and retailers :

  • By setting a clear definition of circumvention delimitating it from other effects, thus facilitating unambiguous public communication
  • By providing methodologies for detecting cases of circumvention, and providing Market Surveillance Authorities with tools for its identification during market surveillance actions  
  • By supporting the optimization of standards and legislation in order to prevent circumvention
  • By supporting communication and collaboration platforms between major stakeholders
  • By providing reliability to manufacturers through specifying potentially vague legislation and standards which might be interpreted differently by various market actors and some of them taking unfair advantages so far.

What are your main questions about products, energy efficiency, market surveillance, Ecodesign, energy labels and circumvention? Find out answers to these questions below.

Do contact the project organisers if you want to know more!

What are the ANTICSS project key objectives?

ANTICSS objectives are to assess what "circumvention" actually is and how the EU Ecodesign and Energy labelling legislation and relevant harmonised standards can be circumvented in order to achieve a better product positioning. Its objectives are also to understand 'if' and 'how much' energy consumption and/or functional performance modifications could be ascribed to circumvention; and 'how' circumvention attempts could be unmasked via the definition of new specific procedures or check lists, modified test conditions, "sentinel" parameters to be screened, etc.

What scope of activities ANTICSS project organises?

ANTICSS firstly aims to define what circumvention is in relation to EU Ecodesign and Energy labelling legislation and relevant harmonised standards. It then investigates how they can be circumvented in order to achieve a better product positioning.  The project team collects and discusses evidence on potential circumvention cases, following up with a limited number of laboratory testing of selected product models along with engineering analysis to confirm the circumvention and assess its impact on products’ energy efficiency and functional performance.

What product categories are being investigated?

The project generally focuses on all products regulated by the EU Ecodesign and Energy label legislation: household appliances, information and communication technologies, lighting and others. The final selection of categories to be investigated in depth will be done on the basis of information gathered within the first stages of project research.

What kind of possible circumvention means will be analysed by the project?

The ANTICSS methodology is simple but effective: Elaboration of a detailed definition of what "circumvention" is, to distinguish it from other effects and thus to facilitate unambiguous public communication. 

The non-exhaustive list below includes topics that are addressed in order to assess the meaning of "circumvention":

  • hidden software (defeat devices)
  • (hidden) specific cycle/setting/configuration used only for testing for legislation compliance
  • products specifically designed to be excluded from legislation
  • ambiguities (such as unclear definitions, boundaries) and loopholes in legislation
  • deviations in testing condition(s), allowed or due to possible different interpretation of standard clauses
  • exploiting a weakness in the test procedure’s method for addressing measurement uncertainties
  • actual performances (energy consumption/functional performances) vs. standard cycles/duty cycles
  • decouple measurement of energy consumption and functional performances
  • smart appliances embedded software: the challenge is how to identify "useful" energy saving automatic functions/sensors and connectivity from "circumvention-targeted" sensors/functions/software.

What are expected overall project results?

ANTICSS project team will draw recommendations for policy makers and standardisation bodies on how to identify circumvention habits through laboratory testing and to prevent circumvention risks, thus allowing preparing better circumvention-proof standards and legislation before adoption. In this respect guidelines on "How to detect and avoid circumvention of Ecodesign and Energy labelling legislation and standards", will be prepared targeted to all market economic and non-economic actors and MSAs for a more effective EU legislation enforcement.

The project will support in many ways the increase of confidence among purchasers, manufacturers and retailers :

  • By setting a clear definition of circumvention delimitating it from other effects, thus facilitating unambiguous public communication
  • By providing methodologies for detecting cases of circumvention, and providing Market Surveillance Authorities with tools for its identification during market surveillance actions  
  • By supporting the optimization of standards and legislation in order to prevent circumvention
  • By supporting communication and collaboration platforms between major stakeholders
  • By providing reliability to manufacturers through specifying potentially vague legislation and standards which might be interpreted differently by various market actors and some of them taking unfair advantages so far.
Project news
December 14th, 2018

Advisory Board meeting

Project meeting with the Advisory Board members in Wien

December 06th, 2018

Project leaflet in Portuguese

Project leaflet in Portuguese language now available.