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FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
1 Material efficiency in EU Ecodesign: new
challenges for policy and standardisation
20 October 2016
Bram Soenen
Federal Public Service Health, Food chain Safety and Environment
Directorate-general for Environment
Department of Product Policy and Chemical Substances
Product policy
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
A
B
C
D
E
F
G
Ecodesign:
Mandatory exclusion
1
2
3
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9
10
Ecodesign:
Compulsory CE mark
Voluntary benchmarks for
EED 2012/27/EU
EU GPP:
Stimulate
market for better
products
EU GPP:
Prohibition to
procure
Incentives
Environmental
product ranking
Eco-label:
Voluntary
« Label of excellence »
2
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Continuous improvement of products3
Ecodesign
Energy label
Ecolabel
Benchmark:
Market pullMinimum
requirements:
Market push
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
4Ecodesign Framework Directive
2009/125/EC Energy related products (except transport):
•Improving energy and environmental performance
•Allow free circulation of goods on Internal Markt
•New Approach
Requirements by product group in Implementing
Measures
•Evaluation of lifecycle environmental impacts
•Correspond to Least Life Cycle Cost (LLCC)
Decision procedure & Transparancy
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Ecodesign Implementing Measures
Regulation: directly applicable no transposition in national Law required full harmonisation
•Definitions and scope
•Minimum performance standards & consumer information
Staged to design cycle/market: every 2-3 year new requirements
•Review study after 5-7 years
•Measuring method and conformity assessment
•Verification procedure for market surveillance
•Benchmarks
5
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
6 Ecodesign - implementation
• Harmonised standards are essential for presumption of conformity
• Publication references in OJEU
• Sometimes transitory measures
• EC mandates to CEN/CENELEC/ETSI to proactively develop standards.
Standards missing verifiable requirements impossible
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Manufacturers’ obligations
• Design and construct in compliance with Eco-design
requirements
• Use harmonized standards referenced in the OJEU
for presumption of conformity
• Carry out conformity assessment (self-assessment is
the general rule)
• Affix the CE marking
• Draft and sign Declaration of Conformity
7
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Anecdotal non-energy requirements
•Efficiency bonus for low GWP
refrigerants
•ELVs on NOX, CO and PM for
boilers
•Limit on Mercury in lamps
•Lead declaration in TVs
•Water use in washing
machines
•Durability of lamps (number
of switching cycles; operating
time)
•Durability of vacuum cleaners
(motor operating time)
•Warning non-replaceable
battery notebooks
•Noise ventilation units,
vacuum cleaners
•Default duplex printing,
remanufacture of cartridges
… (Imaging equipment)
•Consumer information on
maintenance
• Information for recyclers
8
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Problems for ‘non-energy related issues’ in
Ecodesign ?•Till now attention for energy consumption in the use phase
energy security and climate change
•MEErP only looks at CRM not ‘Abiotic Depletion’
•Assumptions on WEEE probably incorrect (Coherency WEEE and
Ecodesign?)
•No direct benefit for manufacturer or consumer for better
recyclability (differentiated Recupel fee ?)
•Life time testing very impractical
•Standards lacking Difficult or impossible to set obligations if
they are not verifiable
•SVHC in plastics ‘non-toxic recycling’
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FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Possibilities for ‘non-energy related issues’
in Ecodesign ? (1/2)
All environmental aspects for ErP covered by
Ecodesign!
• Review IM (Electronic displays/lamps 2017 ?)
• New IM EuP (Commercial Refrigeration 2018 ?)
• New IM ErP (taps and showers 2019 ?)
• ‘horizontal measure’ (cfr. standby 2020 ?)
Orientation debate in the college 25/10
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FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Possibilities for ‘non-energy related issues’
in Ecodesign ? (2/2)Phased introduction:
• Start with information requirement,
• add minimum requirement later.
‘Voluntary Agreements’ (VA) requirements and verification are
different more room for ‘non-energy related issues’;
Life time testing very impractical link with 1999/44/EC on
consumer guarantees ?
Product Environmental Footprint initiative will provide
methodology and experience for generic requirements ?
11
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
‘Non-energy related issues’:Information to the consumer
• spare parts
• repair instructions, …
Functionality requirements
• Early failures
• Reduced performance on aging, …
Information to recyclers
• plastics marking including additives and flame retardants
• time for manual disassembly, …
Minimum requirements
• Life time, reparability, recycled content,…
• polymer composition, recyclability of plastics, …
12
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
BE Federal Road map circulaire EconomieRoad map FPS Economie & FPS Volksgezondheid (2014)
• Preparatory study VITO-ICEDD-TNO (2014)
Ministers working on new Road Map
• Potential circulaire Economie in Belgium PWC (2016)
• Technical study ‘recycled content’ (2016)
• Benelux study in on reparability (2017)
• Pilot studies to promote circular economy through product
design (2017)
• Go4Circle will monitor waste sector to identify product related
issues a.o. (2017-19)
• ‘Planned obsolescence study’ (FPS Economy)
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FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
M/543 - Broad objectives
Considers the following material efficiency aspects:
a) Extending product lifetime.
b) Ability to re-use components or recycle materials
from products at end-of-life.
c) Use of re-used components and/or recycled
materials in products.
14
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
M/543 - Deliverables shall be general in
nature
i) upgrade‐ability;
ii) ability to extract key
components for reuse,
repair, recycling and
treatment;
iii) calculation of recycled
and re‐used content in
products;
iv) methods to identify
components by e.g. their
environmental impact;
v) reporting formats;
vi) reusability,
recyclability and
recoverability indices
15
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
M/543 - Things to specify where possible
1) Selection of parameters to be evaluated;
2) Calculation methods;
3) Test methods;
4) Definition of reference tables (or guidance on how to
build representative and quality-assured tables);
5) Definition of reporting formats;
6) Description of the means for communicating
information regarding products.
16
EN …
EN …
EN …
EN …
EN …
EN …
How the standardisation request fits in the Ecodesign architecture
EcodesignRegulation C
Annex I –RequirementsEcodesign
Regulation B
Annex I –Requirements
EcodesignRegulation A
Annex I –Requirements
EN StandardProduct A
Durability aspects
EN StandardProduct Y
End-of-life treatment
EN (generic) standardisation deliverables on end-of-life treatment under EC/2009/125
EN (generic) standardisation deliverables on durability under EC/2009/125
EN (generic) standardisation deliverables on RRR indexes under EC/2009/125
Standardisation request M XYZ
December 2015
EN StandardProduct B
R index
Review Regulation Z
Annex I –Requirements
Review Regulation Y
Annex I –Requirements
Review Regulation X
Annex I –Requirements
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
M/543- Deadline for adoption 31-03-201918
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
M/543 - Timing
11/11 written input nomination of national experts for PTs,
comments on Terms of Reference and Rules of procedure.
21, 22 and 24/11 back-to-back kick-off meetings for PTs in
CCMC (Brussels). Propose planning and nominate Leaders
06/12 JWG10 Convenors Advisory Group (CAG) web meeting
(PT Leaders + JWG10 secretariat) Resolve issues ?
18/01/2017 2nd JWG10 meeting (CCMC, Brussels; max3
delegates per MS). Decide on PTs.
9 and 10/05/2017 3th JWG10 meeting.
23
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
JWG10 Get involved!
• Contact [email protected] and/or
• NBN activity ?
• JWG10 requires 1 delegation per Member State
composed of CEN and CENELEC mirror committees
24
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Wild takeaway ideas
On EU Ecodesign
25
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Extraction of key components (1/2)
From [DATE], manufacturers shall declare the total extraction time
of the following components or materials from a product unit:
(a) printed circuit boards (larger than 10 cm2);
…
(h) any other materials or components referred to in Article
8(2) of Directive 2012/19/EU of the European Parliament and of the
Council of 4 July 2012 on waste electrical and electronic equipment
and listed in Annex VII
26
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Extraction of key components (2/2) Upon request, manufacturers and importers shall provide within 10
days to Member State authorities and recyclers detailed
instructions for the manual extraction from the [PRODUCT] of any
materials and components covered by the point a) to h) of this
paragraph, including:
i. a numbered list of the key components present
ii. one or more graphical representations of the model showing the
location of any materials and components covered by the
point a) to h)
iii. a list of the required tools
iv. the sequence of extraction steps and how to perform these each
step
v. a graphical representation of each tear down step
27
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Marking of plastic parts
From [DATE] manufacturers shall, if sufficient space is available
after inclusion of the safety-related information, mark plastic parts
with a mass larger than 100g by specifying the typology of plastic
polymer or blend set between the punctuation marks “>” and “<”.
Plastic parts with a mass larger than 100g may include in the
specified typology information related to:
(i) the presence of fillers.
(ii) the presence of fire retardant in plastic parts
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FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Polymer compostion requirements (1/2)
From [DATE] manufacturers shall ensure that
plastic parts with a mass greater than 100 grams consist of one
single polymer or polymer blend.
all plastic parts with a mass greater than 100 grams consist of no
more than four separable polymers or polymer blends, as indicated
in table x in Annex XX.
The following shall be excluded :
- packaging, tape, plastic protective and stretch wraps, labels;
- Printed Circuit Boards (PCB), wiring and cables, electronic
components, optical components, electrostatic discharge (ESD)
components, electromagnetic interference (EMI) components;
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FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Polymer compostion requirements (2/2)
From [DATE] the recyclability rate index of plastic parts in
[PRODUCT] shall be higher than 80% .
The recyclability rate index of plastic parts in [PRODUCTS] shall be
determined in accordance with the following equation:
Where:
Rplastic = recyclability rate index of plastic parts [%]
mi = mass of the ith plastic part heavier than 100g
mtot = total mass of plastic parts heavier than 100g
RCRi = recycling rate of the material used in the ith plastic part
heavier than 100g [%] as specified in the table :
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FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Lifetime extention requirement (1/2)
From [DATE] the manufacturer or importer shall declare what the
available spare parts of a [PRODUCT] are.
If spare parts are available, the manufacturer or importer or their
authorised representative(s) shall declare:
(a)contact details including a free access website to obtain ordering
and shipping information, including at least his own customer
service or repair shop;
(b)contact details of professional repair and servicing centers that
are able to repair and service the product, including at least his
own customer service or one servicing center that is recognized
by him to provide repair and maintenance services for their
products.
31
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Lifetime extention requirement (2/2)
For any spare parts available from the manufacturer or importer
himself, they shall declare:
(a)the first date they are available and the price at that date.
(b)the length of time that they are planned to be available after
the end of production;
Or if disassembly and replacement instructions or spare parts are
not available, they shall provide on the external packaging of the
[PRODUCT], the following information ‘The manufacture does
not provide spare parts and replacement instructions for this
product’.
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FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
33Documentation• Working documents and reports of the CF, voted IM and impact
assessments:
ec.europa.eu/energy/efficiency/ecodesign/eco_design_en.htm
ec.europa.eu/enterprise/policies/sustainable-business/ecodesign/
• Final drafts:
ec.europa.eu/enterprise/tbt/
• Voted drafts:
ec.europa.eu/transparency/regcomitology/index.cfm
• Published IM:
eur-lex.europa.eu/
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
34Additional info
National initiative EuP-Network-Germany:
http://www.eup-network.de
The european council for an energy efficient economy:
http://www.eceee.org/Eco_design/products/
Views of environmental NGOs on the EuP policy:
http://env-ngo.eup-network.de/
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
35 Thank you for your attention !
Bram Soenen
Scientific Advisor
Federal Public Service Health, Food chain Safety and Environment
Directorate-general for Environment
Product policy
Victor Hortaplein 40 bus 10,
1060 Brussel
tel +32 (0) 2 524 96 92
fax +32 (0) 2 524 96 01
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
ADDITIONAL SLIDES36
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
37 Integrated Product Policy
Minimise environmental impacts of products
along their life cycle
direct and indirect impacts
avoid burden shifting
identify trade-offs and synergies
take action where most cost efficient
Combination of policy instruments
minimum requirements, labelling, fiscal measures,…
Communication of the Commission : “Integrated Product Policy - Building onEnvironmental Life-Cycle Thinking” COM(2003) 302 final
EU IPP : http://ec.europa.eu/environment/ipp/index_en.htm
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
38 Directive
2009/125/EC
‘Horizontal’
Implementing
Measures
‘Vertical’
Implementing
Measures
Standby
off mode
network
standby
… Boilers TransformersWashing
machines…
Generic
requirements
(Ecoprofile)
Specific
requirements
(MEPS)*
……… …
Voluntary
Agreements
Information
(Declaration)
*Minimum Efficiency Performance Standard
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Ecodesign process39
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Preparatory study
Stakeholder consultation40
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
41Process (1/2)• Working plan with priority products
• Preparatory study and stakeholder meetings based on a fixed procedure Life cycle based methodology “MEErP”
• Consultation Forum (Member States, industry, traders,
NGOs) :
• defining and reviewing implementing measures
• examining effectiveness market surveillance
• assessing voluntary agreements
• Impact assessment – Inter-service consultation - WTO
notification
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
42Process (2/2)• Finale vote by MS in Regulatory Committee
• parallel adoption of a Delegated Act on Energy Label
by the Commission (‘twin’ Directive 2010/30/EU, optional)
• Publication of the implementing measure:
• adopted by the Commission under the regulatory
procedure with scrutiny
• ecodesign instrument: regulation (no transposition,
fully harmonised)
• Market surveillance by Member States in ADCO group
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
Impact Ecodesign
• Quick market transformation, little impact on market
structure
• No negative effects on availability of products and prices
• 19% more energy efficient products
• Half of the 20% energy efficiency goal for 2020
• >2000 MWh/year primary energy reduction (15% EL - 85%
ED)
• Reduction of imports for gas and coal of 23% and 37%
• 100 bilion €/year savings in 2020 (4-500€ per household)
43
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
44 State of Play
•25 Regulations
•3 Voluntary Agreements - www.eurovaprint.eu
•Working plan 2015-2017 ?
•First 9 Regulations being reviewed
•Evaluation Energy Labelling Directive
http://www.energylabelevaluation.eu/
•Energy label generator: http://eepf-
energylabelgenerator.eu/
•Ecodesign plays an important role in the Circular
Economy Package
FPS HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT
45 Belgian co-ordination
Labelling competence of FPS Economy - DG Energie
Ecodesign competence of FPS Public Health - DG
Environment
Bram Soenen
