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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.