Consultation outcome

Summary of responses and government response

Updated 29 September 2023

Introduction

Climate change and population growth are increasing pressure on our water resources. The latest regional water resource management plans state we will need an additional 4,000 million litres of water a day by 2050, almost a third (28.5%) of current public water supplied in England. As outlined in the Environment Agency review of England’s emerging regional water resources plans, over half of this will need to come from reducing demand for water – around 2,000 million litres of water per day. This is about the same amount of water needed to supply the cities of London, Cardiff, Belfast, Glasgow, and Edinburgh combined.

The UK government’s 2021 written ministerial statement on reducing demand for water included an action “to make regulations to introduce a mandatory water efficiency label to inform consumers and encourage the purchase of more water-efficient products for both domestic and business use”. We also set out ‘Action 8) Deliver the mandatory water efficiency labelling scheme by 2025’ in our Plan for Water roadmap on water efficiency in new developments and retrofits. This policy will help meet the water demand target, to reduce the use of public water supply by 20% for each person by 2038. This has been set under the Environment Act 2021 (the Act) in England and supports priorities for sustainable water use in Scotland, Wales and Northern Ireland. It will also help deliver the Welsh Government’s objectives in its Water Strategy for Wales and Strategic Priorities Statement to encourage a reduction in water consumption and the sustainable and efficient use of water resources.

This document is a joint devolved government response which summarises the responses received through the joint consultation on our policy proposals to introduce a mandatory water efficiency label. The consultation ran from 2 September to 25 November 2022. We would like to thank all those that took part. We value all responses that were gathered and have reviewed and analysed those responses which will inform our policy moving forward.

The consultation covered four main areas. These were;

1. Ambition.
2. Design.
3. Enforcement.
4. Impacts.

This summary is a high-level overview of the main themes from the consultation responses. It tries to reflect the views offered but it is not possible to describe all the responses in detail. Many respondents provided detailed comments and views. A thematic analysis was undertaken to identify the key issues raised. We have also set out our government response and next steps to each of these areas to deliver the Mandatory Water Efficiency Labelling Scheme (MWELS).

Summary

There were a total of 98 responses to the consultation. We had responses from across England, Wales, Scotland and Northern Ireland.

The majority of respondents supported the introduction of a standalone mandatory water efficiency labelling to deliver the policy, with 74% of the responses agreeing or strongly agreeing. The majority (64%) also agreed with the proposed approach to design of the label. Although there was support for including energy information on the label (for taps and non-electric showers), the majority of responses supported a standalone label focused on water efficiency information. We want to ensure that water use is the focus of the label but will consider information campaigns around the concept that reducing water use reduces energy (for example for water-efficient showers). Due to the varying range of water heating systems it would be impractical to include energy use on a label for taps and showers.

The 2021 written ministerial statement on reducing demand for water set that we will “make regulations to introduce a mandatory water efficiency label to inform consumers and encourage the purchase of more water-efficient products for both domestic and business use” following the 2019 consultation on measures to reduce personal water use. This consultation set out the detail of the mandatory water efficiency label.

In this document we set out our responses to each theme covered by the consultation and next steps for delivering the labelling scheme. We will engage with our stakeholder steering group on the next stages of design and product standards ahead of implementing the scheme in 2025.

Analysis of responses

In total there were 98 responses to the mandatory water efficiency labelling consultation, including:

• 80 responses received through Citizen Space
• 18 responses received via email

For a list of organisations that took part in the consultation see Annex 1. Respondents who asked for their contributions to be anonymous or those that did not respond to the question have been removed from this list. It should be noted that not all individuals were speaking on behalf of their organisations as some responded generally as members of the public giving their personal views.

Question: Please select from one of the following to describe your interest in mandatory water efficiency labelling?

The following figures show the number of responses by interest in the consultation. The “other” category includes those that felt they did not fit into the listed categories.

Response	Number of responses
Member of public	38
Retail industry	8
Manufacturing	9
Non-governmental organisations	15
Water suppliers	17
Government body	2
Other	11

Question: Please indicate which nation you are considering when completing this survey?

The following figures shows the distribution of which nation respondents were considering when responding to the consultation.

Response	Number of responses
All of the UK	59
England	25
Northern Ireland	2
Scotland	6
Wales	7
None	1

Summary of consultation responses and government responses

Ambition

Question 1: Does the list of products we selected set the right level of ambition? Answer yes or no. If no, please outline why not and what other products we might consider labelling in future and why?

Half of the respondents to this question agreed with the level of ambition set by the products list outlined in the consultation document. Of those that answered this question, 29% suggested electric showers should also be included. This view was also included in responses from Scotland and Northern Ireland. There was a strong response for the inclusion of sprinklers and garden watering attachments for hoses and jet washers. Water reuse devices were also mentioned in a smaller number of responses. The Bathroom Manufacturers Association (BMA) suggested electric showers account for around 50% of the market in the UK. These were not included in the ISO31600 as they are nearly exclusive to the UK and Ireland, rather than not being suitable for labelling. Other suggestions included:

• products with a frequent cleaning cycle (for example water softeners)
• retrofit and inline (plumbed into the pipe) water limiting devices such as tap aerators
• flow restrictors and water using appliances in both domestic and commercial premises

Responses to question 1

Response	Number of responses
Not answered	6
No	41
Yes	51

Question 2: To what extent do you agree or disagree that a standalone water label only is the most appropriate way to deliver mandatory water efficiency label policy?

The majority (74%) of responses strongly agreed or agreed that a standalone water label only is the most appropriate way to deliver the MWELS.

Responses to question 2

Response	Number of responses
Strongly agree	32
Agree	40
Neutral	9
Disagree	9
Strongly disagree	5
Do not know or did not answer	3

Question 3: In what ways can the impacts of dual labelling on manufacturers be minimised?

The answers to question 3 regarding ways the impacts of dual labelling on manufacturers be minimised saw varied responses. Some respondents suggested that a single combined energy and water label could be created. Others strongly agreed that the water efficiency label should be a standalone label, stating that focusing the label on water will make it easier for customers to recognise and understand what the label is telling them. It was mentioned by 6 people that a standalone water label would allow for greater control over:

• label bandings
• minimum standards
• the inclusion of additional product types

This would make it more flexible for future changes. It was also raised 4 times that we could undertake an awareness campaign including:

• clear guidance
• best practice
• explanation of the label

Others (8) stated they disagreed with the approach, mentioning that having dual labels could be confusing for customers. 3 stated that the voluntary Unified Water Label was the best route forward. It was also raised that to reduce impact on manufacturers this could be a government funded or assisted scheme.

Minimising impacts of dual labelling through design via a template was raised in 12 responses. It was also suggested that if there was one energy and water label then different colours could be used or a traffic lights system.

It was mentioned by others that they do not see dual labelling as a problem because it has been shown to work in other countries. Other responses suggested it will be confusing to customers to have a UK version and the EU having a potentially different version, resulting in unnecessary expense to manufacturers. One response mentioned wanting an international unified label. It was also raised that for energy products, which have information about water usage, these need to align with the water label.

Government response

The list of products consulted on included those prescribed by ISO’s 31600:2022 ‘Water efficiency labelling programmes – Requirements with guidance for implementation’. These products include:

• toilets
• urinals
• kitchen sink taps
• bathroom basin taps
• non-electric shower outlet devices and shower assembly solutions
• dishwashers
• washing machines
• combination washer-dryers

Using the product lists from the ISO should:

• decrease costs for UK businesses
• improve access to overseas markets for UK manufacturers
• increase compliance with the scheme in the UK

Once the proposed regulations are enacted, the Secretary of State has the power to amend or extend the list of water using products covered by the regulations following further consultation in future. However, in light of comments received to the consultation, we propose to add electric showers to the list of water using products to which the proposed regulations will apply. Some stakeholders also proposed including products for outdoor water use (for example efficient trigger spray guns for hosepipes). We do not propose to include these at this time, as they are outside the scope of the ISO standard and would lead to a delay in the scheme launching as each product will require:

• a label and associated standards
• testing and guidance

Some water use information is included on energy labels, but this is not considered clear and simple for consumers to understand (more specifically - it is a single number and not a banded approach). Water products which are not energy related do not have this label and therefore no water use information linked to them. For products that are not currently in the scope of the proposed regulations we support the use of a voluntary approach similar to the Smart Watermark as is done in Australia.

Stakeholders supported dual labelling (energy and a separate water label) in pre-consultation workshops. However, some expressed concern around the increased regulatory burden on manufacturers from the MWELS for products requiring a UK Energy Label which already includes some water efficiency information (for example, washing machines dishwashers and washer-dryers). Dual labelling is common in other countries with water labelling schemes. We will ensure that the design of the mandatory water efficiency label and information provided is clear so as to limit any confusion that could be caused by dual labelling, and we will not seek more than the existing water usage information collected for the energy label.

Design

Question 4: To what extent do you agree or disagree that the example label designs appropriately deliver water efficiency information to a consumer?

The majority (64%) strongly agreed or agreed that the example label designs would deliver water efficiency information appropriately to a consumer.

Responses to question 4

Response	Number of responses
Strongly agree	29
Agree	33
Neutral	13
Disagree	4
Strongly disagree	5
Do not know or did not answer	14

Question 5: Are there any additional elements required in the labelling specification?

Several responses raised the idea of QR codes (quick response code – a type of matrix barcode) for further information, specifically on performance information and best practice for a product (in this case when using an eco-wash cycle). More generally respondents wanted:

• more technical information
• how to identify leaks
• correct use of dual flush toilet buttons
• how to use products most efficiently
• how retrofitting would affect a system

Several responses suggest that flow rates should be added to the label. Across the board, respondents wanted a simple, easy to understand label maybe using a red, amber, green colour scheme and a user-friendly metric. It was also suggested that the label could be made to match the energy label.

Question 6: To what extent do you agree or disagree that including energy information on the label (for taps and non-electric showers) would be beneficial?

The majority of respondents (60%) agreed that including energy information on the label for taps and non-electric showers would be beneficial.

Responses to question 6

Response	Number of responses
Strongly agree	35
Agree	24
Neutral	10
Disagree	14
Strongly disagree	8
Do not know or did not answer	7

Question 7: What would be the most effective way for energy information to be included in the label?

Some respondents believe that the labels should be joint (as in only one label) or water labels should have some energy information included, such as highlighting costs and how much energy can be saved using water-efficient devices. Of those that answered this question 26% believed the labels should be kept separate. It was raised that if energy information was added to the label this would be confusing for customers. There were several reasons cited, such as consumers not understanding energy use factors (such as kilowatt hours) and the main objective of choosing water-efficient devices may be lost.

Question 8: To what extent do you agree or disagree that the display requirements are suitable to ensure water label visibility to the consumer? Please include any additional comments on the above proposals.

The majority of respondents (66%) agreed that the display requirements set out in the consultation are suitable to ensure water label visibility for the consumer. Many of the additional comments included ideas for the display of the label, with the majority suggesting an online platform that could be linked to a QR code. They suggested this could include cost analysis as well as efficiency information. This could alleviate concerns that were raised over label visibility and compliance. There was a desire for clear guidance around online labelling, given many purchases are made online rather than in-store. Research presented as a response to the consultation question by the BMA suggested “40% of product sourcing is through the installer and, therefore, the merchant network”. It also highlighted the need to engage beyond labelling to meet the policy objective of reducing demand for water. An issue was raised around potential confusion between the new mandatory label and existing voluntary labels, where present.

Responses to question 8

Response	Number of responses
Strongly agree	26
Agree	38
Neutral	13
Disagree	6
Strongly disagree	3
Do not know or did not answer	12

Government response

We will work with our expert stakeholder group to finalise the design based on the design proposed in the consultation document and supported by the majority of responses. We will explore the option of including a QR code and additional information linked to the labelling database. Although there was support for including energy information on the label (for taps and non-electric showers), the majority of responses supported a standalone label focused on water efficiency information (Question 2). We want to ensure that water use is the focus of the label but will consider information campaigns around the concept of reducing water use reduces energy (for example for water-efficient showers). This could be embedded in the QR code information. Due to the varying range of water heating systems, it is impractical to include energy use for taps and showers. This will also address calls to simplify the design of the label.

We will develop our labelling scheme based on the display requirements outlined in the consultation document, which is supported by responses and consider how we can best enforce the inclusion of the label for online sales. We will also work with the expert stakeholder group to discuss marketing, promotion and education about the label to ensure installers are able to confidently recommend water-efficient devices. We recommend that only the UK mandatory water efficiency label is displayed to reduce potential confusion for consumers.

Enforcement

Question 9: To what extent do you agree or disagree with the information we propose for the database in annex E?

The majority of responses (53%) strongly agreed or agreed with our proposals in respect of the information to be included in a water label database. Around 19% did not know or had no answer to this question. Overall, responses were in support of a database however, 20% believe there is no reason to add cost information and some furthered this with no need for noise levels. Only one commented on images and not to use them and only one mentioned including the manufacturers names. Two responses stated the label should not apply to marine devices. The focus for many responses was who the responsibility to enforce/update the database would fall to.

Responses to question 9

Response	Number of responses
Strongly agree	18
Agree	34
Neutral	12
Disagree	9
Strongly disagree	6
Do not know or did not answer	19

Question 10: Should any additional information to that set out in annex E be included in a database?

A small majority of responses to this question (51 responses) did not think there was a need for additional information to be included in a database. It was repeatedly raised that products need to be compliant with water fittings regulations and should been tested against leaks and that this could come with certification that can be published online with the product. Another suggestion was that a product’s rating should be displayed alongside the product online. Several responses also asked that flow rate be included within the scheme.

Responses to question 10

Response	Number of responses
Do not know or did not answer	8
No	51
Yes	39

Question 11: Are there any existing standards or regulations beyond those listed from pages 99 - 104 of the Energy Saving Trust (EST) technical report, which you consider may have implications for the delivery of mandatory water efficiency labelling?

The majority of the 22 responses for this question were from:

• water suppliers (7)
• manufacturers (5)
• non-government organisations (3)

Many (9) recommended the need to include the Water Supply (Water Fittings) Regulations 1999. There was also mention of including a review mechanism, such as the Australian Water Efficiency Labelling Scheme has on its costs and benefits every five years with recommendations being made for improvements to the scheme given in a report.

Question 12: Please outline the criteria which you consider the enforcement authority should fulfil, and explain your reasons?

Of the 57 responses, 20 mentioned specifically that the authority should audit labels displayed and address sub-standards. The need for the authority to check the testing that has occurred to make sure that there is no false reporting was included in 11 responses. It was mentioned that there should also be a reviewing and reporting process every 5 years that would provide information on any enforcement actions taken. Some of the response mentioned the need for the enforcement authority to have the ability to give fines to ensure compliance. There was also mention that the enforcement authority should have some capacity to promote the label.

Question 13: To what extent to you agree or disagree with proposed mandatory water efficiency labelling enforcement plan?

The majority of respondents (62%) strongly agreed or agreed with the proposed enforcement plan.

Responses to question 13

Response	Number of responses
Strongly agree	28
Agree	32
Neutral	16
Disagree	2
Strongly disagree	6
Do not know or did not answer	14

Question 14: Do you have any further comments on the enforcement plan?

It was raised that the enforcement regime needs to be adequately funded to ensure it is effective. It was raised as a concern that the cost will be passed on to consumers. It was mentioned it should also be made simpler for the manufacturers to test so it is not confusing to them. Reliability of testing and a strengthened role of product testing was mentioned in several responses as something should be a key aspect of enforcement. Responses also suggested sharing any performance metrics with the public.

Government response

Once the regulations are created, we will begin developing a database to enable consumers to access information about the water efficiency of water using products in the scope of the MWELS. This will help them to make informed purchasing decisions. The database will be administered by Defra and the costs have been accounted for in the impact assessment. Products will need to be compliant with the Water Supply (Water Fittings) Regulations 1999 and evidence of testing by an accredited provider in order to be labelled and this will be made clear in the database.

We propose to report on the labelling scheme as part of our annual reports on the English Water Demand Target and the Environmental Improvement Plan set under the Environment Act 2021. We will review the labelling scheme in line with the review dates for the Water Demand Target for England set out in the Environmental Act 2021.

Given the majority of responses agreed with our proposed approach to the enforcement regime we will further develop this policy and are in discussion with partners for delivery. We propose that the MWELS regulations and ISO on labelling are listed on the designated standards list, which would also mandate the testing requirements.

Impacts

Question 15: To what extent do you agree or disagree that these figures are accurate?

The consultation responses are varied in their views, with:

• 28% agreeing
• 14% disagreeing
• 24% being neutral

There were a number of responses that indicated concern or frustration that the data supporting the figures outlined in the consultation document was not readily available for challenge. A small number of respondents suggested that there was an underestimation of benefits, since it did not include external equipment such as hose pipes.

Responses to question 15

Response	Number of responses
Strongly agree	7
Agree	21
Neutral	24
Disagree	9
Strongly disagree	5
Do not know or did not answer	32

Question 16: To what extent do you agree or disagree that the costs and benefits are accurate?

The majority of responses were neutral or did not know or answer the question. Around 33% of responses agreed with the costs and benefits and 19% disagreed. Many responses have cited recent inflation and costs of energy as a reason that they think the costs and benefits are inaccurate. However, cases were made both for costs being greater, and in addition to that, potential savings also being greater. There was also representation from a small number of stakeholders over the voluntary unified water label having lower running costs than the proposed mandatory label.

Responses to question 16

Response	Number of responses
Strongly agree	5
Agree	27
Neutral	16
Disagree	10
Strongly disagree	9
Do not know or did not answer	31

Question 17: To what extent do you agree or disagree that there is limited impact on smaller companies?

Around 31% disagreed that there is limited impact on smaller companies, 24% agreed and 16% were neutral. Comments were mainly focused on the issues that a small business would face regarding areas such as compliance costs, printing of labels and additional costs in showrooms.

Responses to question 17

Response	Number of responses
Strongly agree	8
Agree	16
Neutral	16
Disagree	19
Strongly disagree	12
Do not know or did not answer	27

Question 18: To what extent do you agree or disagree with our assessment of equality impacts? Please provide any information to support your view.

There were 31 responses to the question. Around half (47%) agreed with our assessment of equality impacts followed by 28% who did not know or did not answer. Of these, 5 respondents outlined their surprise that there are no minimum standards and the need to include minimum standards in the final policy. Several mentioned that there should be some exemptions from the label particularly when there is a health and safety aspect involved, for example in the medical field. It was also mentioned by one respondent that marine products should be exempt due to the lack of water they use. It was suggested that labelling exemptions should be limited to instances where higher flow rates are required due to local environmental conditions and the intended use of the product, for example medical and safety use.

Responses to question 18

Response	Number of responses
Strongly agree	20
Agree	26
Neutral	8
Disagree	10
Strongly disagree	7
Do not know or did not answer	27

Question 19: In addition to the previous questions, is there any other information you would like to share regarding the proposed UK mandatory water efficiency labelling?

Responses to this question mainly outlined the overall stance of the consultee’s outlining both support and reinforcing points made throughout their consultation responses. For example, raising the need for having minimum standards and to expand our ambition on the range of products covered such as hose pipes. There was also mention of the voluntary unified water label already being present in the UK market.

Government response

The independent research undertaken by the Energy Saving Trust reviewing the costs and benefits of the various options for a water efficiency label is publicly available (Water Labelling Phase 1 Technical Report). This report was peer reviewed and updated in further phases to provide more specific information on impacts of the labelling programme.

We will update figures where appropriate to address inflation impact in costs as well as benefits in water and energy bill savings. This will be reflected in the Impact Assessment that will accompany the statutory instrument to deliver the labelling scheme. We will consider equality impacts for marine as well as health and safety in any future development of the label including minimum product standards.

Ofwat the water company economic regulator’s response stated:

We are pleased to see that the proposals for the standalone label cover the whole of the UK and include a comprehensive range of water using products and appliances. We are particularly supportive of proposals to make the label simple and prominently displayed on products at the point of sale” and “given the ongoing focus on the resilience of water supplies, sustainability and affordability, we would very much like to see a swift progress in linking the proposed water efficiency labelling with building regulations and minimum standards.

We highlight this as labelling is a key enabling policy for water companies to support achieving our statutory Water Demand Target for England.

Next steps

Based on 2019 prices, the label could save:

• £125 million on water bills over 10 years
• £147 million on energy bills over 10 years
• 1,200 million litres of water a day (the equivalent of 480 Olympic swimming pools)

Implementing the proposed mandatory water efficiency label is an enabling policy for water companies and the building and construction sectors to help us achieve England’s statutory Water Demand Target and the non-statutory interim targets set under the Environment Act 2021. Providing clear water efficiency information on products will enable consumers to make informed decisions. These decisions can then be supported with communications and incentives.

We will use the responses to the consultation to inform delivery of the mandatory water efficiency label to be introduced using powers under section 52 and schedule 6 of the Environment Act 2021. Water efficiency is a policy area where responsibility is devolved and as such we will invite to take this forward jointly with:

• the Scottish Government
• the Welsh Government
• the Department of Agriculture, Environment and Rural Affairs in Northern Ireland

We will work with the organisations involved in our pre-consultation workshops and steering group to finalise the label design and standards for each product. We will also finalise our enforcement policy and approach. We aim to lay the secondary legislation in 2024 and will develop:

• the product database
• general label approach
• registration system
• website
• approach to promotion and marketing of the label

We aim to launch all of this in 2025.

The UK government has set out in its Plan for Water: our integrated plan for delivering clean and plentiful water that we will consult on, and develop, minimum product water efficiency standards including for showers, taps, toilets to follow-on from the launch of the MWELS.

We propose this to be phased in following the launch of the label following further consultation. We will also link the label development with actions set out in the environmental improvement plan roadmap on water efficiency in new developments and retrofits. We will also undertake a review of the effectiveness of the label after 5 years. As part of this we consider the inclusion of other products covered.

Annex 1

List of Organisations that took part in the consultation.

• Affinity Water
• Association of Manufacturers of Domestic Appliances (AMDEA)
• Anglian Water
• B&Q
• Bathroom Manufacturers Association
• BEAMA
• Berkeley Group
• BLANCO GmbH + Co. KG
• Blueprint for Water
• British Marine
• British Retail Consortium
• Builders Merchants’ Federation
• Caerphilly County Borough Council
• Caravan and Motorhome Club
• Consumer Council for Water (CCW)
• Chiltern Society
• Confindustria Ceramica
• Consultancy
• Consumer Council for Northern Ireland
• Consumer Scotland
• Croydex Ltd
• Energy Saving Trust
• Essex and Suffok Water
• Financial Services
• Grundfos Pumps Ltd
• Hafren Dyfrdwy
• Hampshire Council
• IKEA
• Independent consultant
• Independent Water Networks Limited (IWNL)
• Jacobs
• Janet Manning Consulting
• JPJN Partners Ltd
• Kiwa Watertec
• Llandudno Political Awareness Network
• Mace
• Natural Resources Wales
• Neoperl
• NH65 Consultancy
• Northern Ireland Water
• Northumbrian Water Limited
• Owl Cottage Accessible Holidays
• PJH
• Portsmouth Water
• Raison Home UK LTD
• Recoup Energy Solutions Ltd
• Scottish Water
• Severn Trent Water
• South Staffs Water & Cambridge Water
• South West Water Ltd
• StH Westco
• Thames Water
• The British Institute of Kitchen, Bedroom & Bathroom Installation
• The Rivers Trust
• UKGBC
• Unified Water Label Association (UWLA)
• Water Regs UK
• Water Resources West
• Water2050
• Waterwise
• Welsh Water
• Worshipful Company of Water Conservators
• Water Regulations Approval Scheme (WRAS)
• Water Research Centre (WRc)
• Water Resources East
• Yorkshire Water