Energy Efficiency

Evidence required from importers for each registered appliance

If I am a retailer, how can I register with the Malta Resources Authority?

Those retailers who wish to participate in the scheme should register their interest with the Malta Resources Authority and they will be granted approval by the Authority if they meet established criteria and conditions. Amongst other requirements, retailers are required to submit details on all the appliances they have for sale and are obliged to agree that all these appliance may be subject to physical verification by the Authority or its representatives.   Registered retailers are obliged to ensure that the appliances' energy efficiency labels are clearly attached to the appliances.

Appliance models that are eligible for the rebate can be identified through a sticker shown below. Retailers are authorised to display these stickers, similarly to the energy efficiency label, on appliances on display in showrooms that are eligible for the rebate. These stickers may only be placed on the appliance models listed as eligible (denoted by YES or PROVISIONAL in the appropriate column) for the rebate in the table available on our website www.mra.org.mt. Stickers should also be immediately removed from any appliances that no longer qualify for the rebate. They may not be fixed to appliance models that are listed as pending, or to appliance models that are not listed on our website.

Evidence required from importers for each registered appliance

Suppliers of household domestic appliances selling their appliances in the Community market are required, by virtue of Article 2(3) of Directive 1992/75/EC on the labelling of household appliances, to establish the following documentation:

"3. Technical documentation shall be established which shall be sufficient to enable the accuracy of the information contained in the label and the fiche to be assessed. It shall include:

- a general description of the product,
- the results of design calculations carried out, where these are relevant,
- test reports, where available, including those carried out by relevant notified organizations as defined under other Community legislation,
- where values are derived from those obtained for similar models, the same information for these models."

The directive also specifies that this documentation must establish the manufacturer or his authorized representative in the Community or the person who places the product on the Community market and that it must be available for a period of five years.

The implementing directives (e.g. 94/2/EC for refrigerators) specify the standards to be used for testing and more details concerning the technical documentation for each appliance type.

As far as Government's scheme is concerned, what is being requested is evidence from the supplier confirming the accuracy of this information, prior to the appliances being considered eligible for a rebate.

What sort of evidence is being expected?

Briefly, one would expect to see what one would typically include in a normal lab report - i.e. date, test objective, details of appliance, methods or materials; experimental procedure (standard); test results, conclusions (energy class) and name of lab and responsible person.

Regrettably, a website listing, a statement by the manufacturer or a product catalogue is not considered sufficient evidence.

This documentation will not be required where the seller did not import the appliances directly, provided that the wholesaler supplied the relevant documentation to the MRA. This documentation will also not be required where the appliance is registered either with the Energy Savings Trust of the UK or similar governmental EU bodies (subject to prior MRA approval and indication by seller) or with Eurovent (for AC's)

This scheme has nothing to do with the Low Voltage Directive and certificates of conformity required by that directive. Information about any other test not related to energy efficiency is not necessary. The document submitted should be certified by the manufacturer or retailer or laboratory.

This scheme does not restrict or prohibit appliances from being placed on the market. It must be emphasised that this information is not being requested because there is any evidence that any particular label is incorrect. Participation in the scheme is completely voluntary and retailers or importers are free to participate or otherwise.

The verification referred to above is used to enable purchases of eligible appliances to qualify for refund in order that -
(1) it is ensured that purchasers are not cheated;
(2) rebates are not given on unmerited appliances; and
(3) genuine products whose suppliers have followed the proper procedures are not put at a disadvantage.

All along, it is thus ascertained that public funds are given to whoever may prove eligibility, in the spirit of public accountability and a non-discretionary policy.