Greenhouse and Energy Minimum Standards (Rotary Clothes Dryers) Determination 2022: exposure draft

To:-

Department of Industry, Science, Energy and Resources
Australian Government

Fisher & Paykel Appliances response to draft determinations under the Greenhouse
and Energy Minimum Standards Act 2012 (GEMS Act)

Fisher & Paykel thanks the Department of Industry, Science, Energy and Resources (the
department) for the opportunity to comment on the following 3 exposure draft determinations
under the Greenhouse and Energy Minimum Standards Act 2012 (GEMS Act):

 Dishwashers
 Clothes washing machines
 Rotary clothes dryers

COMMENTS

“12 Registrations affected by this Determination” – Fisher & Paykel supports this clause
that allows for continued supply of already registered products, and without the need to do
any grandfathering. This provision is welcomed as it removes a significant cost burden.

“2 Commencement, revocation and replacement”
Fisher & Paykel does not support a 6-month period for the commencement of the
Determination. This is inadequate and we strongly recommend that the Government
consider a minimum 18-month plus period.

While these changes have been flagged by the Government, business like ours including our
sister company Haier, does not make decisions to implement solutions on draft
legislation. Funding and justification for changes can only be approved when there is
confirmed legislation in place.

Six months is simply not long enough, given the lead times that are in place for the
procurement and supply of labels. At a minimum we order and hold 12 months’ worth of
label stock across a various product categories to maximise scales of economy and get the
cheapest price for our labels.

While the grandfathering provision does assist here in allowing currently registered products
to be sold through, it becomes much more complicated when a product that is currently
registered to the 2015 GEMs Determination must be reregistered to the new 20XX
Determination once this comes into force. (due to 5 year registration expiring)
The new determination calls up new standards and in the case of clothes washer products a
detergent has been removed from the latest standard. (“removal of “other than Drum
detergent”)
To make that product compliant with the new detergent, significant development work will be
required to be able to comply with the standard. Again, 6 months is not long enough. This
type of change would require a minimum of 18 months to develop and implement a
standards compliant solution.

So in summary, the 6 month commencement timing will remove products from the market,
depending on the products registration expiry date and there will be insufficient time
available to develop and implement alternate solutions. While we appreciate the
grandfathering conditions in the draft determination, we would have expected to have seen
the commencement timing being closer to 2 years as has been the case in previously
implemented determinations, to allow manufacturers time to make necessary changes.

Thank you for your consideration.

Fisher & Paykel Appliances Ltd
Level 1, Wall Street Mall, 211 George Street
Dunedin 9016
New Zealand

Instagram | Facebook | LinkedIn