Published name
Upload a submission
11 April 2022
GEMS Product Review Team
Department of Industry, Science, Energy and Resources
GPO Box 2013
Canberra ACT 2601
Via email: screens@industry.gov.au
ARA RESPONSE TO THE EQUIPMENT ENERGY EFFICIENCY
PROGRAM ISSUES PAPER
The Australian Retailers Association (ARA) appreciates the opportunity to contribute to the joint
consultation between the Australian, State and Territory and New Zealand Governments into Equipment
Energy Efficiency: Televisions, Computer Monitors and Digital Signage Displays. We welcome the intent
of the Commonwealth Department of Industry, Science, Energy and Resources (DISER) to release a
regulation impact statement (RIS) on the minimum energy performance standards (MEPS) and energy
rating requirements in Australia and New Zealand.
The ARA is Australia’s oldest, largest and most diverse industry retail body representing two-thirds of a
$360 billion sector that employs 1.3 million Australians. We are proud to represent the full spectrum of
Australian retail, from our largest national and international retailers, to our small and medium sized
members - who make up 95% of our membership. Our members operate more than 100,000 shopfronts
and online stores across the country with offerings across all categories - from food to fashion,
hairdressing to hardware, and cosmetics to computers.
From the discussion paper, we note the Equipment Energy Efficiency (E3) Program is considering
whether to update Australia and New Zealand’s television and computer monitor MEPS and labelling
requirements; and harmonise the requirements with prevailing international standards. E3 is also
considering whether to extend energy efficiency labelling to include digital signage displays to align with
the new European requirements for electronic displays.
We understand that the new EU Ecodesign regulations include MEPS for televisions and computer
monitors, and mandatory labelling for electronic displays including televisions, computer monitors and
signage displays. Europe included all 3 types of display, because of the increasing overlap in functions
between different display types.
Mandatory energy labelling and MEPS for televisions was introduced in Australia in 2009 and in New
Zealand in 2012; the stringency of both was increased in 2013.
Television technologies and features have changed and advanced significantly since 2013. This means
the current regulatory framework is out of date and unable to deal adequately with some of the new
products on the market. In particular, the test method used in Australia and New Zealand was published
in 2010 and is based on a superseded international standard.
We note that this international test method is under revision and a new standard is expected to be
published in April 2023, meaning that the Australian and New Zealand test method standard will become
even more out of date.
Australian Retailers Association Level 1, 112 Wellington Parade
ABN 99 064 713 718 East Melbourne VIC 3002
In Australia, the current determination for television MEPS and labelling does not include computer
monitors or digital signage displays, although computer monitors are regulated through a separate
determination. In New Zealand, televisions and computer monitors are included in the Energy Efficiency
(Energy Using Products) Regulations 2002 as separate product classes.
The Issues Paper, due to the convergence of these technologies and international trends to regulate
these products together, considers whether it makes sense for Australia and New Zealand to apply the
same energy efficiency requirements to these products as applied overseas.
The ARA has consulted with subject matter experts from our Sustainability Advisory Committee on
elements relating to this issues paper. This submission has been informed by that engagement.
These members play a variety of roles in the value chain. Some are brand owners that engage overseas
suppliers to produce and import private label products; others are importers of branded products; and
others source from wholesalers once products have been imported. All will likely play a key role in the
transition of Equipment Energy Efficiency standards given their relationship with the end consumer.
While other stakeholders will be better placed to respond to the technical nature of the 25 questions
raised in the issues paper, the ARA supports the adoption of trusted, internationally recognised
standards used in Australia’s comparable markets across Europe and North America, alongside robust
voluntary standards that are well defined and have high levels of consumer trust.
The ARA also makes the following principles-based recommendations that we consider to be critical in
the design, implementation and management of future Energy Efficiency policies.
One scheme
There should be one equipment energy efficiency scheme for all electrical and electronic products. We
believe this will simplify engagement with consumers, minimise impacts on retailers and optimise
efficiencies of scale for consumer education programs.
Consumer first
Any future standard must minimise complexity and barriers to consumer adoption. While retailers
recognise their obligation in terms of consumer education and awareness, any international energy
efficiency policy aligned, should be clear and consistent across electronic products to assist with
consumer understanding.
Product agnostic
The ARA believes this product-agnostic approach should include all categories, with the benefits
derived from including all electrical and electronic products, including televisions, computer monitors
and digital signage displays, potentially assisting in the costs of manufacturing each item.
National consistency
While the scheme should be national, it must be designed in consultation with state, territory and local
governments to ensure a consistent approach across the country. The ARA also believes that a national
compliance framework would be required to provide transparency over management of the policies,
with adjustments to the current processes for reviewing and updating mandatory standards focused
upon providing clarity and consistency to retailers, while also ensuring clear, concise and timely
communication of any updates.
International alignment
The Australian scheme should align with existing labelling standards used in overseas jurisdictions,
particularly those in the European Union or the United States’ Energy Star program. This will increase
Australian Retailers Association Level 1, 112 Wellington Parade
ABN 99 064 713 718 East Melbourne VIC 3002
the ability of all stakeholders along the supply chain to ensure that appropriate product labelling
requirements are met, without having to impose additional labelling and compliance requirements for
products to be sold in Australia.
Data-driven decisions
Any future policy would need to improve data capture and improve visibility of material flows, to inform
data-driven decisions about issues, risks and opportunities.
On behalf of our membership and the retail community, thank you for the opportunity to contribute to
this discussion about Australia’s approach to equipment energy efficiency for electrical and electronic
products. As this process continues, the ARA welcomes the opportunity to participate as an industry
stakeholder to ensure the needs of our members are understood and incorporated into any future
legislation.
Please do not hesitate to contact Jason Robertson, ARA Director of Policy, Sustainability and Impact, via
email at jason.robertson@retail.org.au should you wish to discuss our submission further.
Yours sincerely,
Paul Zahra
Chief Executive Officer
Australian Retailers Association Level 1, 112 Wellington Parade
ABN 99 064 713 718 East Melbourne VIC 3002
