Managing legal compliance
ENVIRON’s web-based systems include structured checklists to capture relevant product environmental legislation and product standards at the initial planning stage of the New Product Design process. Hyperlinks to the web database provide the product design team with further details and guidance on practical compliance issues and options. View webcast demonstration
EcoDesign of Energy Using Products (EuP) Directive
Companies producing a wide range of energy using products will have to comply with forthcoming EcoDesign requirements in order to maintain their CE marking so that these products can continue to be sold in EU Member States. The EcoDesign Requirements for Energy Using Products (EuP) Directive became law in EU Member States in August 2007 and will set EcoDesign requirements for specific groups of products. The EcoDesign requirements will reduce the environmental impact of products across the life cycle, with a particular focus on energy.
The Directive takes its legal base from Article 95 of the Treaty of Rome, and so all Member States must implement the EcoDesign requirements in exactly the same way (similar to the RoHS Directive). The Directive does not apply to means of transport (planes, cars etc). But apart from this the scope is deliberately broad so that an increasingly wide range of products can be targeted over the next few years.
Lighting, IT and consumer electronics sectors are amongst the first industry sectors to be directly affected. However, cross-industry product groups will affect huge swathes of the European electronics industry. For example, group 6 addresses standby and off-mode losses of electrically powered devices, and group 7 tackles battery chargers and external power supplies.
| 1 | Boilers and combi-boilers (gas/oil/electric) | www.ecoboiler.org |
| 2 | Water heaters (gas/oil/electric) | www.ecohotwater.org |
| 3 | Personal Computers (desktops & laptops) and computer monitors | www.ecocomputer.org |
| 4 | Imaging equipment (copiers, faxes, printers, scanners, multifunctional devices) | www.ecoimaging.org |
| 5 | Consumer electronics (televisions) | www.ecotelevision.org |
| 6 | Standby and off-mode losses of all electrically powered devices | www.ecostandby.org |
| 7 | Battery chargers and external power supplies | www.ecocharger.org |
| 8 | Office lighting | www.eup4light.net |
| 9 | (Public) street lighting | www.eup4light.net |
| 10 | Residential room conditioning appliances (air conditioning and ventilation) | www.ecoaircon.eu |
| 11 | Electric motors 1-150 kW, water pumps (commercial buildings, drinking water, food, agriculture), circulators in buildings, ventilation fans (non-residential) | www.ecomotors.org |
| 12 | Commercial refrigerators and freezers, including chillers, display cabinets and vending machines | www.ecofreezercom.org |
| 13 | Domestic refrigerators and freezers | www.ecocold-domestic.org |
| 14 | Domestic dishwashers and washing machines | www.ecowet-domestic.org |
| 15 | Simple converter boxes for digital televisions | www.ecostb.com |
A further five product groups are planned for action in 2007.
| 16 | Solid fuel small combustion installations (in particular for heating) |
| 17 | Laundry dryers |
| 18 | Vacuum cleaners |
| 19 | Complex set top boxes (with conditional access and/or functions that are always on) |
| 20 | Domestic lighting |
REACH Regulations
REACH (Registration, Evaluation and Authorisation of Chemicals) regulation came into force on across the whole of the EU on 1 June 2007. REACH requires manufacturers and importers to register chemicals manufactured or marketed in Europe in quantities higher than 1 tonne per year with the new European Chemicals Agency (ECHA) in Helsinki and, in doing so, to adequately demonstrate their safe use through a comprehensive programme of data collection, testing and assessment. Failure to register means the substance cannot be manufactured in or imported to the EU. For existing substances, there is an option to pre-register and take advantage of a phase-in programme for registration, which prioritises substances of higher volume and certain substances that have irreversible health effects or may cause long-term adverse impacts to the aquatic environment. New substances need to be registered before they are placed on the market, commencing 1 June 2008. Substances of very high concern will also be subject to further rules under the authorisation regime, and their use may be phased out or subjected to further controls or restriction accordingly.
A number of chemicals and substances used in Medical Devices may become restricted under future REACH Directive requirements. This must be kept under review. In the mean time, it is advisable to avoid use of published lists of substances which are known to be of concern. Further details are available at environcorp.com/REACH
Batteries Directive
The Batteries Directive will become law in EU Member States from September 2008 and will place design and labeling requirements, including internally attached batteries.
Article 11 of the Batteries Directive requires manufacturers to design electrical and electronic equipment so that waste batteries can be readily removed. Manufacturers are also required to provide removal instructions along with details of the type of batteries. These requirements do not apply to equipment where a permanent connection with the battery is required in order to ensure continuity of power supply for safety, performance, medical, or data integrity reasons.
WEEE Directive
Producers of electrical and electronic equipment are facing strict new compliance rules for collection, recycling and recovery of waste equipment across ten broad categories, including IT and telecoms, electrical tools, medical electrical devices and control and monitoring equipment. WEEE compliance requirements are different in each EU Member State. But ENVIRON's web-based compliance systems enable manufacturers and importers of business products to have a single system for WEEE collection, recycling and reporting across Europe, see www.b2bweee.com for details.
The WEEE Directive also includes EcoDesign requirements that Member States must address through their national WEEE regulations. This includes encouraging manufacturers to design equipment which facilitates dismantling and recovery to allow reuse and recycling of components and materials. In addition, the WEEE Directive expressly prohibits the use of specific design features or manufacturing processes which prevent products from being reused (unless these design features or manufacturing processes present overriding advantages, for example, with regard to the protection of the environment and/or safety requirements.
RoHS Directive
The RoHS Directive requires that electrical and electronic equipment must not contain more than > 0.01% by weight of cadmium or > 0.1% by weight of lead, mercury, hexavalent chromium, PBB or PBDE in any single homogenous material. See b2bweee.com/legislation/rohs-obligations for further details.
Marketing and Use of Certain Dangerous Substances Directive
The following substances are banned under the Marketing and Use of Certain Dangerous Substances Directive:
- Asbestos
- Certain Azo-colourants and Azo-dyes in leather and textile products that come into contact with skin
- Chlorinated hydrocarbons for cleaning agents (e.g. trichloroethane) and chlorinated paraffins
- PCBs, PCTs and PCNs
- Tributyl Tin (TBT), Triphenyl Tin (TPT), Tributyl Tin Oxide (TBTO)
Ozone Depleting Substances
Ozone Depleting Substances (e.g. CFCs, HCFCs etc) are banned under regulation EC No. 2037/2000.
Customer pressures for EcoDesign and product stewardship
In addition to regulatory pressures, investors, shareholders and customers are putting increasing pressures on companies to demonstrate good environmental performance. At the same time, many Corporate Social Responsibility (CSR) reports have been criticised as 'green wash'—attempts to present the company in the best possible light, whilst skirting around less flattering issues.
EcoDesign addresses the fundamental environmental impacts that a manufacturer has on society—the life cycle impacts of its products. It requires design teams to address how they can reduce environmental impacts and costs in materials selection, manufacture, packaging, use, and end-of-life options. Companies that can demonstrate tangible improvements stand to gain marketing and reputational benefits with stakeholders.
For further information, please contact Dr Aidan Turnbull
Head of WEEE, RoHS & EcoDesign on +44 (0)1225 748420
