The “top runners”, i.e. firms with the most energy-efficient products at the start of a target cycle, do not need to invest further (OECD, 2009b). Moreover, since compliance is assessed by comparing performance in the base and target years, target setting does not take account of potential technological improvements that would occur in the absence of the programme, or of developments already available but commercially untapped (Nordqvist, 2006). Comparing performance in the target year with baseline projections would be more appropriate (IEA, 2008).