Download Submission to 2016 RDC Consultation_Staycold

From: Edward Jonas [mailto:[email protected]]
Sent: Thursday, 11 August 2016 12:38 a.m.
To: Lisa Sinclair
Subject: Consultation response
Hi Lisa,
Thank you for asking Staycold to participate in your consultation. Our perspective mainly relates to
the UK market and also the Australian market. I am pleased to offer the following comments relating
to the questions in the consultation document:
1. Yes, it is the regulations that drive the efficiency gains. In the UK, the Energy Technology List
is voluntary and it is not generally well understood. Staycold offers two ranges. One is “high”
efficiency and the other is “normal” efficiency. We find that some of the biggest end users
have professional buyers who receive their incentives based on capital cost reduction.
Therefore, even though their employer would make substantial savings by adopting the high
efficiency range, they may ignore it and go for the normal efficiency models to reduce the
initial purchase price. By comparison, individual bar owners often buy the superficially more
expensive, high efficiency version and they find it an easy and obvious choice to make. There
are exceptions to this such as Heineken who always go for the high efficiency versions, even
though they themselves do not pay the electricity bill. However, another global brand, who
shall remain nameless told us “we talk the talk, but do not walk the walk”. Therefore I agree
that regulation is the way forward.
2. Option 4 so as to align the labelling and testing methods.
3. The footprint of the cabinet is affected by its longevity in use. Many Chinese components are
of low quality and short lifetime. Such components generate wasteful activity in terms of
service visits. The high efficiency components such as EC fans have much longer lifetimes
and therefore a lower footprint. If there is a focus upon energy consumption, it should also
help to push users towards longer product lifetime as a positive side effect.
4. The smaller buyers (owner users) are easier to persuade to spend more for lower lifetime
costs. The larger buyers (barring a few exemplary beacons of responsibility) are more
focused upon initial purchase price. Corporate incentive systems that may favour lowest
initial cost may be to blame. For example, this happens where the savings on electricity and
service costs are won by another department over which the product buyer has no
responsibility. Also global procurement systems where the vendor is not allowed to meet or
speak to the buyer are not conducive to making detailed arguments about lifetime and
efficiency. E- Auctions being the worst example. We did gain one major contract, never
having met the buyer nor even spoken to them on the phone.
5. Yes I agree and the lack of credible comparison data is to blame.
6. It would be a positive impact that would help drive efficiency…as long as the data is credible.
How do you stop the vendors who simply invent the data or tell the customer what they
want to hear?
7. I have not measured it, but possibly only 10% of large brand buyers. Smaller owner users I
would say the % is closer to 30%.
8. 100% of owner users would benefit. Brand buyers may not pay the electricity bill for the
running cost of the product and therefore they may not be so interested.
9. Price, aesthetics, performance, efficiency. First three hard to rank, but efficiency is usually at
the bottom of the list.
10. I think it tends to push prices up, if the threshold levels are hard to meet.
11. I do not agree. We market “GreenSense” and “Greensense Plus” versions of the same
model. Different components leading to different efficiency levels and therefore different
price points. You can see the details at www.staycold.co.uk/product-ranges/back-barcoolers.html
12. Yes, see answer to Q11.
13. Unintended positive side effect is to extend length of product lifetime. Eg Led lasts longer
than old style tubes. EC fans last longer than shaded pole.
14. Yes
15. It will assist the consumer to make a better choice. But only if the source data is credible.
16. Expense and timescale for testing.
17. N/A
18. N/A
19. If the label thresholds are sufficiently different to differentiate the high and low efficiency
cabinets then it will be positive. If the bands are so broad that all models are encompassed
within one rating, then it will be detrimental.
20. See Q19
21. I do not know.
22. No
23. No
24. Yes because our products get used in commercial premises and in households. Which
standard to apply? Also AS1731 is based on the old EN441 which is replaced in EU by
EN23953. Therefore there is an additional layer of expensive testing to be done.
25.
26. Yes I fully agree.
27. No
28. No problem if harmonised with EU introduction dates
Kind regards,
Edward Jonas
Managing Director
Staycold Export Ltd.