The Department for Environment, Food and Rural Affairs (Defra) ran a consultation about mandatory water labelling. Tom Reynolds, chief executive of the Bathroom Manufacturers Association, highlights some key industry responses.
Defra’s plans for a mandatory water efficiency label have been widely discussed, and a host of stakeholders have now submitted their reactions.
While I can’t summarise every response we and others have made, here are some of the key trends.
A number of environmental NGOs, particularly Blueprint for Water and Waterwise, have welcomed the general principle of mandatory water efficiency, but have called for greater ambition from the Government, including ‘minimum standards’ that would have banned some fittings.
The list of products Defra selected for labelling leaves room for ambiguity, especially around the status of electric showers. The BMA and Yorkshire Water both agree that they should be included, as these showers constitute around half of the UK shower market.
On dual labelling, the BMA and BEAMA shared the view that Government should identify the existing Unified Water Label (UWL) as an acceptable means to comply with any new requirement. Using the UWL would also reduce unnecessary duplication of work already undertaken. The BMF agreed and mentioned the large costs for Government to develop their own scheme.
Several organisations disagreed with the idea that energy information should feature on the label (for taps and non-electric showers). Interestingly, the British Retail Consortium said consumers could be overwhelmed by too much information at the point of sale – in effect, causing ‘poster blindness’.
Defra is planning a database of water-labelled products. While some information is helpful for consumers, trade associations pointed out that most of the proposed information has no benefit.
Defra proposes a high level of visibility for the new mandatory water label, with an onus on manufacturers and retailers to ensure it is displayed correctly. The BMA believes the label must provide consumers and specifiers with the data required to make an informed purchase. It should therefore appear where consumers do their pre-purchase research, often in a digital format for retail and trade channels. For bathroom products, purchasing routes to market are far more complex than many other consumer products; therefore, policymakers must be realistic in their labelling expectations.
Finally, Defra says an ‘enforcement authority’ will monitor compliance with the label requirement – with little detail on how it will be enforced. This is critical to have a level playing field for everyone.
The BMA are eagerly awaiting the next steps. Considering that the first draft of regulations is due to conclude in 2023, with any changes coming into force by 2025, a swift yet considered plan will be welcome.