A shift towards a sustainable society requires policymaking that achieves overall environmental improvement while continuously promoting innovation and enhancing the competitiveness of industry. A so-called “top runner” approach, as implemented in Japan for the improvement of energy effi ciency for product groups, has gained interest in the EU, e.g. in the discussion of the Environmental Technologies Action Plan (ETAP).This study critically examines the environmental effectiveness and the policy implications of the top runner approach in Japan, in order to better understand the potential for applying the top runner approach in Europe.