In a nutshell:

• DG Energy has drafted the Ecodesign and Energy Labelling Regulations for refrigerated commercial display cabinets (aka ENER Lot 12)
• The proposed drafts submitted on 17 September 2015 do not consider the very wide variety of products, in particular of supermarket display cabinets
• The level of ambition of the proposed two tiers is too stringent
• The 28 September sets of plotted data points support the view that a more detailed product segmentation makes sense
• These graphs also show that the stringency of the EEI requirements would require a revision

The industry would wish that the Commission integrates the more detailed supermarket cabinet segmentation in its drafts and that the EEI requirements are considered anew.