
First, the "A plus" classes should be eliminated from the rating scale of the Energy Label. Consumers seem to be more inclined to buy more energy efficient products if the scale is closed between A-G scales rather than when it is broadened by addition of "A plus" classes. National legislators tend also to misapply these classes by awarding them to currently most energy efficient appliances in a given category, which means that they do not leave any room for technological development and improvement. Consumers tend also to believe that the whole range of classes showed on a product should be available to them, even though many labels may show empty classes, where products are not yet on the market since there is no corresponding technology.
Second, disclosure of consumer-relevant information, affecting costs and performance, should be more transparent and comprehensible. The Directive requires the unit of "kilowatt hours per annum" to be displayed on the Engery Label, while survey showed that more than 70% tested German consumers did not understand the meaning of "per annum" on the label. Some research suggests also that consumers may prefer the label to express energy consumption per usage, i.e., "per cycle". More empirical evidence is needed as to which label is more transparent to consumers.
Lastly, BEUC believes that there is a need to reassess the relationship between the energy label, the calculation formula on which it is based and the appliance size. BEUC worries that the Directive may be promoting larger appliances, sine it is easier to receive a higher rating for a larger appliance, and the calculation formula for the energy efficiency classes takes size into account. This is a consumer-unfriendly trend since consumers may prefer to buy a bigger appliance with a higher energy-efficiency class, not understanding that they would end up spending more energy (and more money) due to the larger size of the appliance.