Understanding values
Different documents like product information sheets, energy labels, technical documentation and test reports partly require the same parameters to be stated. However, the presented values for parameters in these documents may not always be the same.
As a supplier, you have to differentiate between:
- Measured values
- Declared values
- Published values
- Determined values
Measured values to be provided in test reports
The basis for setting up a product documentation are various test reports. For each product model to be tested for compliance with a specific regulation, one or more test reports have to be issued. These reports must cover all obligations in all EU regulations applicable to the specific product. Ideally, the products are tested by an accredited test lab, however also in house testing is possible. Values stated in the test reports are called “measured values”.
Declared values to be provided in the technical documentation
Based on the test reports containing the measured values, the supplier generates the technical documentation. The values provided in the technical documentation are “declared values”.
The supplier is free to decide, whether to declare exactly the measured values from the test report or less favourable values. I.e., if the efficiency of a product according to the test report is 90%, the supplier can declare 90%, or e.g., 89%. Declaring more favourable values than measured (e.g., 91% in this case) would lead to a formal non-compliance of the documentation. The technical documentation with declared values is only accessible for market surveillance authorities, but not for other market actors.
Published values on the label and the product information sheet
Consumers only see values provided on the product information sheet and the label. These values are called “published values”. Again, the supplier can decide to publish values, which are equal to the declared values or less favourable.
Determined values in tests arranged by MSA's
A “determined value” is a value measured within a test of a test laboratory, carrying out tests on behalf of an MSA or an in-house test of the MSA. From the technical perspective, a determined value is the same as a measured value described above. However, determined values serve specifically for the compliance verification by MSA's.
In the verification procedure used by MSA's, certain tolerances, specified in the specific product regulation, are applied (see Annex “Verification procedure for market surveillance purposes” in the product-specific regulations). The specified tolerances are for use by market surveillance only but must not be applied for the declaration of values by suppliers.
In market surveillance inspections, MSA's will compare the determined values with the declared values from the supplier. If in this comparison the tolerance specified in the ecodesign or energy labelling regulation is exceeded, this is a formal non-compliance.
If the minimum requirement is still met, the MSA might ask the supplier to re-declare the value, i.e. the product can stay on the market. If the new “declared value” is less favourable than the “published value”, also the published value needs to be changed.
If a “determined value” measured by market surveillance is outside the tolerance level and at the same time does not meet the minimum requirement specified in the ecodesign regulation, the product is technically non-compliant. The responsible MSA can require the supplier to technically revise the product or else remove it from the EU market.
If a declared value meets the ecodesign minimum requirement, but the determined value does not, but the difference between the two values is within the tolerance, the product is compliant.
MSA's communicate with each other via a system called ICSMS. Into this system, MSA's insert the results of their inspection campaigns. The entries are visible to all MSA's in the EU. This makes sure that especially results of non-compliant products detected in one member state can be enforced in the entire EU.