Setting Standards for Smart Appliances: consultation response
Energy Systems Catapult has responded to the Department for Business, Energy and Industrial Strategy consultation on the proposals regarding Setting Standards for Smart Appliances.
In this context smart appliances are pieces of domestic equipment, running off electricity, which are communications-enabled and which are able to respond to some external signal and moderate their consumption.
The consultation emerged as a result of the Smart Systems and Flexibility Plan and asked for feedback on several key areas:
- Regulation of standards for smart appliances
- The case for labelling and how that label is useful for consumers
- The financial cases for smart appliances in terms of manufacture, sale and use
- Minimum functionality for smart appliances
- Implications on consumer protection measures
- The development of industry-led standards should be encouraged, wherever possible, so that standards are able to keep pace with the speed of development and changes are made to reflect the learning from consumers and innovators.
- Smart appliances are effective when paired with commercial arrangements that allow them to be best exploited. Appropriate overall commercial frameworks need to be in place which allow for flexibility in operating models.
- The rise of connected smart appliances increases the risk of cyber-attack, so whole-system stability and security risks should be considered fully to ensure there are sufficient measures in place, should a breach takes place.
- To solve the chicken and egg problem of developing technology, commercial arrangements and regulations simultaneously, it’s advisable to promote the ability to trial business models for LCT deployment, technologies and tariff offerings in a joined-up environment, leading to commercialisation at scale.
- Predicting what consumer protection might be required is difficult, so consumer protection should be built around observations with consumer and industry groups and modified as necessary. A risk of setting a standard ahead of time is that innovation may be stifled as organisations only seek to meet a minimum bar.
- The costs of whole life affordability, with consumer requirements being paramount, is key to understanding the net benefit to the value chain.