Requirements on material efficiency within the Ecodesign Directive

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The Ecodesign Directive and the EU energy labelling have proven to be effective policy instruments to reduce energy consumption and thereby CO2 emissions. It is estimated that the Ecodesign Directive and the EU energy labelling have resulted in savings in 2020 of approximately 9% of the current energy consumption and 7% of the carbon emissions (European Commission 2019). In the new circular economy action plan from the European Commission, the Ecodesign Directive is assigned a key role in the transition towards a circular economy; indeed, it is a policy tool which can ensure circular design of products entering the European Market. However, studies have shown that around 10%–20% of the products on the European Market are non-compliant with the ecodesign requirements (Petersson and Nielsen 2013); consequently, 10% of the total energy savings are lost (Baton et al. 2017). It is therefore key to ensure that existing and future material efficiency requirements, in support of a circular economy, can be verified in relation to market surveillance. This has precisely been the theme of this project.
This project has analysed existing and future material efficiency requirements under the Ecodesign Directive and the EU energy labelling and how these are verified. The point of departure for the analysis of the future material efficiency requirements is the work conducted under the standardisation mandate M/543 from the European Commission targeting material efficiency aspects under the Ecodesign Directive.
The document review of the adopted implementing measures under the Ecodesign Directive, covering 28 energy-related product groups, showed that 22 implementing measures include information requirements targeting material efficiency, while only nine include specific requirements. The specific requirements cover aspects such as durability (or reliability using the definition from EN 45552), availability of firmware, easy disassembly, spare parts availability, access to repair and maintenance information for professional repairers, data deletion options, disassembly for recyclability and guidelines for marking plastic and hazardous substances.
The standards developed under M/543 targeting material efficiency aspects are horizontal standards, which cannot be directly applied to energy-related products or product groups. The only exceptions are the standard on critical raw materials (EN 45558) and the standard on methods for providing information (EN 45559), which can be applied directly to products or product groups. The horizontal standards are intended to provide the framework for developing product or product group–specific standards. The horizontal standards focus on durability, remanufacture, repair, recyclability, reused components, recycled content and critical raw materials. The maturity level of the different methods in the horizontal standards varies, a factor that could also have an impact on the time horizon for their implementation. Only the standards on critical raw materials and providing information are considered directly applicable.
The concepts are also at different levels of maturity. It is more likely that specific criteria will be set for the reliability than for the durability of products because more standards already exist regarding reliability. The analysis of the future material efficiency requirements revealed that there is a considerable overlap between the durability standard (EN 45552); the standard on remanufacturing (EN 45553); and the standard on repair, reuse and upgrade (EN 45554), as they cover overlapping and similar aspects. This is an obvious consequence of the fact that a product’s ability to be repaired or upgraded affects the product’s durability and its ability to be remanufactured.
The study revealed two aspects not covered in detail by the standardisation mandate M/543, namely considerations regarding reduced resource or material consumption and chemicals and restrictions hereof. Both aspects are important in a transition to a circular economy.
The existing experience with control measurements of the adopted material efficiency requirements are still limited in Denmark. Denmark and the other Nordic countries, in particular Sweden, are considered to be some of the countries dedicating the most resources to market surveillance in Europe. It is therefore likely that the existing experience with control measurements through product testing in the EU member states is still limited. An exception is Sweden, which is further elaborated in chapter 8. The limited experience entails that there might be undiscovered difficulties in the verification and test of these requirements, which will not be uncovered before more experience with control measurements have been gained. A recommendation is therefore to make use of a future European project such as Eco-design Compliance Projects (EEPLIANT) to gain more experience with market surveillance of the material efficiency requirements across the EU member states.
Due to the horizontal nature of the standards, it is still difficult to evaluate how easy it will be to verify these types of aspects. The standards suggest different types of assessment methods and a few general remarks can be made on their verification.
• For the durability standard 45552, it will be potentially more complex to verify future durability requirements (covering both repair and remanufacturing steps) compared with future reliability requirements, as the reliability concept is further developed in the standardisation context.
• For the standard EN 45553 on remanufacturing, the assessment methods have not been well developed yet, as it primarily identifies important product attributes and criteria that are vital for remanufacturing processes.
• For the EN 45554 standard on repair, reuse and upgrade only, one of the assessment methods is based on a calculation, while the remaining criteria are evaluated based on a classification of the different aspects according to a scale ranging from A to E. This classification of the different criteria can embed a qualitative interpretation if the requirements for the different classifications are not well defined. Further study is therefore needed to examine the verification of these types of requirements.
• The EN 45556 standard on the proportion of reused component and the EN 45557 standard on recycled content can only be determined indirectly, as no methods exist to measure this directly. The verification is, therefore, by means of documented evidence from manufacturers and suppliers.
• The EN 45558 standard on critical raw materials and the EN 45559 standard on information can to some extent can be used directly on specific products and verified through document review.
To ensure verifiability of the future material efficiency requirements, it is essential that standards are developed and harmonised; they can then be used to check product compliance with the ecodesign requirements. Furthermore, accredited test laboratories should be available to perform the compliance check. The contracts with the accredited test laboratories should also have a dynamic structure to ensure that all ecodesign requirements can be tested at the same laboratory and to utilise synergies among the different policy areas.
Original languageEnglish
Number of pages54
Commissioning bodyEnergistyrelsen
Publication statusPublished - Mar 2021

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