EuP-Directive Status quo and critical observations

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1 EuP-Directive Status quo and critical observations Dirk Jepsen & Norbert Reintjes Presentation given at the Electronics Goes Green conference Berlin 9 th of September

2 Expertise Ökopol GmbH (Institute for Environmental Strategies) Independed European Consulting Company, based in Hamburg since 1989 Clients from Authorities (EU-COM, Ministries in MS and local authorities) Industries and Trade NGOs (Environmental and consumer NGOs, citizens groups) Working Areas Industry plants (IPPC, BAT) Politics on chemicals (REACH, GHS) Politics on Waste (WEEE, ElektroG) Integratred Product Policy (EuP, Ecolabel, etc.)

3 Expertise EuP related work Expert input to the regulatory process on 2005/32/EC (EuP directive) Concept and promotion of a German stakeholder network shadow group for the EU processes; EuP-Netzwerk Deutschland Information services and background support EU COM - DG Env. Member states authorities European Env. NGO network (lot E) Industry and trade (associations & single companies) Internet sites: Newsletter service

4 Content of presentation Content Major Characteristics EuP-directive and implementation proces Status Quo Challenges & Observations Conclusions

5 EuP DC & implementation process Major characteristics of the EuP-Directive Life-cycle thinking adressing all (relevant) env. issues with special focus on energy consumption Framework directive General rules (aims, scope, procedure, etc.) in directive itself Binding (minimum) requirements on Product group specific or cross cutting aspects elaborated in subsequent processes (vertical/horizontal) implementing measures (IM) Stakeholder involvement at several stages Tool box (labeling, minimum requirements, harmonised standards,..) DIRECTIVE 2005/32/EC establishing a framework for the setting of ecodesign requirements for energy-using products and amending Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC of the European Parliament and of the Council

EuP processes: Participants, Elements and Tools NGOs Industry participates participates Consultation forum consult Commission DG Energy, Transport DG Industry agreement Regulatory committee

6 EuP processes: Participants, Elements and Tools NGOs Industry participates participates Consultation forum consult Commission DG Energy, Transport DG Industry agreement Regulatory committee conskitute Suggests & develops Selfregulation Annex VIII verification Commission & reg committee defines Implementing measures Gives mandates Harmonised Standards CENELEC TC 111 X (DKE K 191) Consultation forum participate participate Member state Organizes Verification tools for Conformity Assessment Checks conformity with self selected Tool Checks exemplarily conformity Market surveillance Manufacturer Importer Placing on the market CE marking Declaration of conformity

7 EuP DC & implementation process EuP process to Implementing Measures Time Study Workplan Prep-study Imp. Ass. Agreement Adoption European Commission EU-Parl. Draft Workplan Workplan Working Doc Draft IM Final IM Cons. Forum Cons. Forum Reg. Com. Interservice

8 EuP DC & implementation process Standard Prep. Study Approach vhk-method 1. Product definition, standards & legislation 2. Economics & Markets 3. Consumer analysis & local infrastructure 4. Technical analysis existing products 5. Definition of base case Universal Environmental Impact Assessment Methodology and BaseData 7. Improvement potential 6. Technical analysis best available technology 8. Policy, impact and sensitivity analyses MEEuP Methodology Report, page 18

9 EuP DC & implementation process Status Quo: Product groups in Prep-studies (3) 1 2 Boilers Water heaters Electric motors, pumps, fans, circulators Commercial refrigeration, freezers 3 PC and PC-monitors 13 Domestic refrigeration, freezers 4 Imaging equipment 14 Washing mashines, dishwashers 5 TV 15 Solid fuel small combustion installations 6 Stand by- off-modeloss 16 Laundry dryers 7 Battery charger and EPS 17 Vacuum cleaners 8 Office lighting 18 Complex set-top boxes 9 Public street lighting 19 Domestic lighting 10 Room air conditioning -- Simple set top boxes

10 EuP DC & implementation process Status Quo: decisions taken (2) Implementing Measure (IM) adopted Standby and off mode (Lot 6) IM submitted to Regulatory Committee Simple set top boxes (no Lot number) Tertiary sector lighting products (Lot 8 & 9) Product groups covered in ongoing preparatory studies will follow 2008 & 2009

11 EuP DC & implementation process New prep. studies under tender procedure (4) New prep-studies tendered by DG ENTERPRISE Sound and imaging equipment DVD/video players and recorders, video projectors and video game consoles Refrigerating and freezing equipment not already covered service cabinets, walk-in cold rooms, chillers, ice makers, ice cream and milk-shake machines, minibars Distribution and power transformers

12 EuP DC & implementation process New prep. studies under tender procedure (4) New prep-studies tendered by DG TRANSPORT & ENERGY Local room heating products Central heating products using hot air to distribute heat (other than CHP) Domestic and commercial ovens (electric, gas, microwave) Domestic and commercial hobs and grills, including when incoporated in cookers Profesionnal washing machines, dryers and dishwashers Non-tertiary coffee machines Networked standby losses of EuPs Domestic uninterruptible power supplies (UPS)

13 EuP DC & implementation process Stakeholder participation Time Study Workplan Prep-study Imp. Ass. Agreement Adoption European Commission EU-Parl. Draft Workplan Workplan Working Doc Draft IM Final IM Cons. Forum Cons. Forum Reg. Com. Interservice Interested Parties (Industry, NGOs, etc.) Member States

14 Critical observations - overall Challenges & observations Stakeholder participation Time-consuming and complex, still no satisfying (balanced) participation (in all groups) Transparence of information flow Up-to date information Scope / targeted issue Technical components or systems Status of env. issues beside energy consumption during use Patchwork / Interlink with other IPP instruments Clarification and harmonization needed Status of necessary supporting instruments Market surveillance Conformity assessment Harmonized standards

15 Critical observations stakeholder involvement Stakeholder involvment Member states Nearly no participation in Prep. Studies Only few active comments on WDs Late and not too well prepared input to draft IMs Industry Active participation in Prep.Studies (but limited to big (multinational companies) Importers, Trade, SME more or less missing Other NGOs Only few groups actively involved Example MS input to WDs (03/08) Austria Belgium Denmark Germany Finland Italy Netherlands Sweden UK Lot 9 Lot 6 Lot 8

16 Critical observations information access Transparent access to information implementation of EuP directive is based on stakeholder dialogue Transparent and efficient information flow is needed Overview over processes Technical documents Schedules, deadlines Existing information tools not sufficient Difficult to read for non-experts Not (always) up-to-date Technical hurdles of access Problems EuP-process is complex and fast progressing with short deadlines Documents are highly technical, in English and voluminous

17 Critical observations scope & target issues Scope Ongoing debate about the right scope in many product groups (namly lighting, pumps, heating,..) Technical product (Technology A) Service area Component I Component II Component III Technical product (Technology B) Component I Component II Component III

18 Critical observations IPP Instrument Mix Mix of IPP Instruments Not harmonized yet Revision cycles Issues addressed Level of ambition Mandatory Energy Labelling Voluntary Labelling Energy using products Pull Green Public Procurement MS Ivestment Progr. Push Mandatory Miniumum requirements Restrictions requirements IMs under EuP DC WEE & RoHS

19 Critical observations IPP Instrument Mix Mix of IPP Instruments (2) Harmonization attempts from SCP action plan (July 2008) EuP IM s Widening scope => energy related products Defined categories used as bases Green public procurment Minimum requirement Incentive programms of MS

20 Critical observations supporting instruments Major supporting Instruments still missing Market surveillance Still lack of concepts and knowledge on MS level for the upcoming needs of sufficient market surveillance Conformity assessment Requirements regarding conformity assessment still vague (like EMAS link) Harmonized standards Harmonized standards (e.g. for valide measurment of power consumption) missing in many product areas Fast track procedures for standardisation needed without losing reliability

21 Conclusions Conclusions The EuP implementation is a challenging process, providing lots of valuable technical expertise about eco-design already The process has reached first level of steady state But further efforts necessary EU Commission, Industry and MS should make further efforts in getting all market actors and other interested parties informed and involved Further action needed on MS level information for the upcoming enforcement needs Hight priority should be given of all involved parties regarding the development of missing instruments and links

22 Thank you for listening! For further information For contact

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