Ecodesign legislation

The last few years have seen a swathe of legislation published under the EU’s Ecodesign for Energy-related Products Directive.  So far this legislation has been almost entirely concerned with energy efficiency, with the EU setting timescales for phasing out the least energy efficient products from the market.  Examples include the Household Washing Machines Ecodesign Regulation and the Household Dishwashers Ecodesign Regulation, both of which require a first round of phase-outs from 1 December this year and a second round from 1 December 2013.

The legislative framework does not, however, restrict product-specific regulations to energy efficiency alone.  The recast Directive is far broader than that. It is concerned with “the integration of environmental aspects into product design with the aim of improving environmental performance of a product throughout its whole life cycle”.  Given such a wide scope the potential for additional requirements is considerable.

What next?

There is a current European Commission-backed study looking at how ecodesign should evolve and the results will inform a re-write of the Ecodesign for Energy-related Products Directive next year.

AMDEA has contributed to the study by making suggestions to see more prominence given to standards and a greater involvement of standardisation organisations earlier on in the setting of product-specific requirements.  We have also been involved in some of the discussions over likely changes, such as the scope widening to include all products and new requirements to effect resource savings which are two recurring themes under discussion.

While the exact direction of future legislation is still a matter for conjecture, it seems that there will definitely be other requirements beyond energy efficiency in future regulations.  For instance it seems likely that there will be restrictions on the use of rare earth metals, which has major implications for the electronics industry. 

More information

So far, ecodesign legislation has stipulated relatively little in the way of information provision.  Where such requirements do arise, they tend to be in terms of adding a specific sentence to a set of instructions or such like.   We expect that in the future, ecodesign will encompass a wider range of environmental aspects and manufacturers will need to supply much more information about aspects of their products.  It has already been suggested that information about how a product can be dismantled at the end of its life for recycling might be supplied with the product.  Obviously this would have to be set against the health and safety risks of encouraging consumers to take their appliances apart and it could be that such information would not be supplied with the product but would be made available elsewhere to waste processing plants, WEEE compliance schemes etc.

We are already seeing certain chemicals being listed for phasing out because they pose a threat to human health or the environment under other legislation. However, there may also be a growing list of chemicals whose current use is deemed to be unsustainable.  And this goes beyond mere global availability – the 12th most common element in the earth’s crust is manganese (used extensively in batteries and steel production) but most of it is mined in South Africa and only a tiny percentage in Europe (Ukraine).  It is not merely a question of importing expensive materials but also the environmental impact of the mining operations and transport.  How much detail will suppliers be asked to provide in relation to their use of substances; their carbon emissions; and what efforts have they made to minimise their impact on the environment?

Manufacturers will have to manage these additional information requirements but retailers will also need to be aware of them.   More information is likely to provoke more questions from customers so retailers will require a greater understanding of what the environmental impacts of products are. 

With ever more detail of a product’s lifecycle being provided, explaining its environmental impact to a customer could become a much more complex matter than just telling them than A is better than B.