The European Public Health Alliance (EPHA) welcomes the opportunity to provide comments on the Working Documents for Ecodesign and Energy Labelling measures for domestic cooking appliances and supports the European Commission’s endeavours to protect the health of Europeans through the draft Ecodesign Regulation. We stress the importance of ensuring that the ongoing revision of the Ecodesign Regulation for domestic cooking appliances addresses the pollution stemming from gas hobs by setting NO2 emission limits, and enhances the energy efficiency criteria for these products.
EPHA has consistently advocated for the Health in All Policies (HiAP) approach, emphasising the need to address health concerns and regulate harmful pollutants from gas cooking in the ongoing review of the Ecodesign measures for domestic cooking appliances. To address this issue, EPHA suggests the following actions:
- Setting a NO2 emission limits of 6ng/J, as a crucial step towards phasing out harmful products from the market and enhancing indoor air quality, particularly benefiting vulnerable groups such as children and individuals with pre-existing respiratory conditions who are most susceptible to the adverse health effects of NO2 pollution.
- Progressively facilitating the accurate comparison of energy efficiency between gas and electric hobs, using the existing gas test method with aligned pot sizes and the same metrics until further information has been collected to develop a more representative test method.
- Introducing additional energy efficiency product information requirements for gas and electric hobs in online and print instruction manuals by 2025, informing consumers of the real efficiency of their cooking appliances in the absence of an energy label, and enabling the European Commission to gather data for the next policy review.