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.

Several topics might facilitate circumvention and for example the following ones are being addressed by the project team:

  • hidden software solely reacting to test situations
  • specific cycle/setting/configuration used only for testing for legislation compliance
  • ambiguities (such as unclear definitions, boundaries), weaknesses and loopholes in legislation and harmonised standards
  • energy saving software or technology specifically applicable to test situations; specific analysis of the role of smart appliances 
  • specific factory settings not reverting after changing setings in the menu
  • decouple measurement of energy consumption and functional performances
  • products specifically designed to be excluded from legislation
  • missing representativeness (energy consumption/functional performances) vs. standard cycles/duty cycles

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:

Basis report summarizing in anonymous form the identified circumvention ‘habits’ (May 2021)

Impact Assessment of circumvention under EU Ecodesign and Energy labelling (May 2021)

Definition of ‘circumvention’ and ‘jeopardy effects’ in relation to EU Ecodesign and Energy labelling legislation (June 2019)

Analysis of the relation between "smart" products and circumvention (June 2019)


Preliminary definition of circumvention (9/2018 - Outdated)

Short summary: ANTICSS_Definition_circumvention_Preliminary_Short.pdf

Full document: ANTICSS_Definition_circumvention_Preliminary_Long.pdf



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.

Several topics might facilitate circumvention and for example the following ones are being addressed by the project team:

  • hidden software solely reacting to test situations
  • specific cycle/setting/configuration used only for testing for legislation compliance
  • ambiguities (such as unclear definitions, boundaries), weaknesses and loopholes in legislation and harmonised standards
  • energy saving software or technology specifically applicable to test situations; specific analysis of the role of smart appliances 
  • specific factory settings not reverting after changing setings in the menu
  • decouple measurement of energy consumption and functional performances
  • products specifically designed to be excluded from legislation
  • missing representativeness (energy consumption/functional performances) vs. standard cycles/duty cycles

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:

Basis report summarizing in anonymous form the identified circumvention ‘habits’ (May 2021)

Impact Assessment of circumvention under EU Ecodesign and Energy labelling (May 2021)

Definition of ‘circumvention’ and ‘jeopardy effects’ in relation to EU Ecodesign and Energy labelling legislation (June 2019)

Analysis of the relation between "smart" products and circumvention (June 2019)


Preliminary definition of circumvention (9/2018 - Outdated)

Short summary: ANTICSS_Definition_circumvention_Preliminary_Short.pdf

Full document: ANTICSS_Definition_circumvention_Preliminary_Long.pdf



Project news

September 29th, 2021

FINAL REPORT

Project final report now available

September 29th, 2021

NEWSLETTER n.5

AntiCSS final newsletter available