Anticss
Anti-circumvention of standards for better market surveillance

Definition of circumvention and its impacts

At the latest since the so called “diesel gate”, the topic of manipulated emission testing of cars, possible “circumvention” was exposed to highest attention of public media, also with regard to other EU legislation such as Ecodesign and Energy labelling.

"Circumvention" comes from Latin circumventus, 'to come around'. It has currently different related meanings with a general negative connotation: (1) to go around or bypass; (2) to avoid (defeat, failure, unpleasantness, etc.) by artfulness or deception; avoid by anticipating or outwitting.

Several topics might facilitate circumvention and will be addressed by the project team:

  • 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.

Therefore, specific challenge of the ANTICSS project is to clearly define circumvention and delimitate it from other effects, to identify potential circumvention habits, describe it on a technically sound basis, to make laboratory testing or engineering analysis feasible for the selected product categories and types .

Building upon the existing Ecodesign / Energy labelling regulations and applicable harmonised standards, ANTICSS will assess “if” and “how” they can be/are actually by-passed “by artfulness or deception”, with the precise will to achieve a better positioning of a specific product that instead would reach a worse (labelling) ranking, the same ranking at a lower cost, or even not be allowed to be placed on the EU market (Ecodesign). The assessment of how much higher energy consumption and/or lower functional performance could be masked by circumvention will complete the panorama of the impact on consumers and EU energy efficiency targets, and will lead to the following question on the ways to avoid it.ANTICSS team does not intend to unmask and accuse specific circumvention cases, but rather to build a scientifically justified basis for public discourses on circumvention.


Documents (Linked to project deliverables 2.2; 4.4, 4.5):

Definition of circumvention: 

Short summary: ANTICSS_Definition_circumvention_Preliminary_Short.pdf

Full document: ANTICSS_Definition_circumvention_Preliminary_Long.pdf


Deliverables under preparation:

Final definition of circumvention

Assessments of the potential circumvention impacts

Summary of identified circumvention “habits”

At the latest since the so called “diesel gate”, the topic of manipulated emission testing of cars, possible “circumvention” was exposed to highest attention of public media, also with regard to other EU legislation such as Ecodesign and Energy labelling.

"Circumvention" comes from Latin circumventus, 'to come around'. It has currently different related meanings with a general negative connotation: (1) to go around or bypass; (2) to avoid (defeat, failure, unpleasantness, etc.) by artfulness or deception; avoid by anticipating or outwitting.

Several topics might facilitate circumvention and will be addressed by the project team:

  • 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.

Therefore, specific challenge of the ANTICSS project is to clearly define circumvention and delimitate it from other effects, to identify potential circumvention habits, describe it on a technically sound basis, to make laboratory testing or engineering analysis feasible for the selected product categories and types .

Building upon the existing Ecodesign / Energy labelling regulations and applicable harmonised standards, ANTICSS will assess “if” and “how” they can be/are actually by-passed “by artfulness or deception”, with the precise will to achieve a better positioning of a specific product that instead would reach a worse (labelling) ranking, the same ranking at a lower cost, or even not be allowed to be placed on the EU market (Ecodesign). The assessment of how much higher energy consumption and/or lower functional performance could be masked by circumvention will complete the panorama of the impact on consumers and EU energy efficiency targets, and will lead to the following question on the ways to avoid it.ANTICSS team does not intend to unmask and accuse specific circumvention cases, but rather to build a scientifically justified basis for public discourses on circumvention.


Documents (Linked to project deliverables 2.2; 4.4, 4.5):

Definition of circumvention: 

Short summary: ANTICSS_Definition_circumvention_Preliminary_Short.pdf

Full document: ANTICSS_Definition_circumvention_Preliminary_Long.pdf


Deliverables under preparation:

Final definition of circumvention

Assessments of the potential circumvention impacts

Summary of identified circumvention “habits”

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.