AEG 8209 D- User Manual

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Dyson Position

Dyson Position

Dyson Position

Dyson Position Paper

Paper

Paper

Paper: Eco Design and Energy Labelling

: Eco Design and Energy Labelling

: Eco Design and Energy Labelling

: Eco Design and Energy Labelling for vacuum cleaners

for vacuum cleaners

for vacuum cleaners

for vacuum cleaners

Introduction

Introduction

Introduction

Introduction

Dyson has reviewed with interest the working documents for implementing Eco-design and Energy labelling directives
for vacuum cleaners.

Europe has committed to reducing its environmental impact by 30% by 2020, when compared to 1990 levels. There
is an opportunity for vacuum cleaners to contribute towards this target. The majority of vacuum cleaners’
environmental impact is accounted for in the use phase. Limiting the amount of power that a vacuum cleaner can
use will have a positive environmental impact.

Dyson broadly agrees with and supports the Commission’s recommendations to achieve this. The working
documents rightly acknowledge that the implementing measures for vacuum cleaners need to incorporate energy
consumption, performance and usability. However, Dyson considers that the Commission could implement more
stringent thresholds to achieve greater energy savings. Measures also need to be representative of consumer use
and easily verified.

Reasoning

Reasoning

Reasoning

Reasoning

The working documents operate in tandem, therefore Dyson’s response deals with the issues relating to both eco
design and energy labelling.

Dyson broadly agrees with and supports the Commission’s recommendations. In particular, Dyson supports:

o

Power caps,

Power caps,

Power caps,

Power caps, reflecting

reflecting

reflecting

reflecting annual energy consumption

annual energy consumption

annual energy consumption

annual energy consumption:::: These are an effective way to drive energy efficient

design, will lower energy consumption and can be achieved without sacrificing performance.

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o

Separation of energy and performance metrics

Separation of energy and performance metrics

Separation of energy and performance metrics

Separation of energy and performance metrics:::: A previously discussed, combined method was based on the
flawed assumption that people vacuum for less time when their vacuum cleaner achieves high dust
removal.

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Furthermore, the method proved expensive to implement, enforce and impossible to reliably

reproduce.

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Penalties

Penalties

Penalties

Penalties for

for

for

for overly

overly

overly

overly high

high

high

high push

push

push

push force

force

force

force: When cleaning hard floors and carpet, suction alone is not sufficient.

Cleaner head design is critical in ensuring good pick up levels. A balance between the push force applied
and the dust pick up is needed to ensure machines achieves high performance whilst remaining usable.

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Dyson recommends the Commission further enhance the proposals so the implementing measures are reproducible,
representative of user experience, achieve energy savings and provide the consumer with relevant and accurate
product information.

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Appendix A – High dust removal can be achieved with limited power input

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Appendix B – Dust removal performance and cleaning time

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Appendix C – Graph of EU machines from different manufacturers showing little correlation between dust removal from carpet and push force

applied

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Appendix D – Details from a survey of 100 German women where 95% reduced the suction on the machine until a push force of 21N to use it