Frequently Asked Questions - and answers!
RoHS is about material bans and toxicity, WEEE is about waste management, and EuP now is about energy consumption?
Energy consumption is one of several aspects of the EuP directive. Although it is named "Energy-using Products" directive it should not be misinterpreted to cover only the energy use of products. The EuP - in the context of the Integrated Product Policy - follows a much more holistic approaching, aiming at an overall environmental improvement of electrical and electronic products. The energy efficiency is, for sure, one major environmental issues, but there are many more, such as resource consumption (materials, water, and energy), recyclability, emissions, consumption of auxiliaries, life time etc. etc.
Which products are in the scope of the EuP?
The Energy-using Products directive is a framework directive, meaning product specific requirements will be given more in detail in coming implementing measures. For which product groups will there be implementing measures? The EuP directive itself states the following criteria for drafting implementing measures:
- the EuP [energy-using product] shall represent a significant volume of sales and trade, indicatively more than 200.000 units a year within the Community;
- the EuP shall, considering the quantities placed on the market and/or put into service, have a significant environmental impact ...
- the EuP shall present significant potential for improvement in terms of its environmental impact without entailing excessive costs;
It has to be analysed by the European Commission, which products will fall under this definition. "Candidates" for implementing measures are:
- Water heaters
- Personal Computers and monitors
- Office / imaging equipment
- TV sets
- Battery chargers and external power supply units
- Air conditioning appliances
- Electric motors
- Refrigerators and freezers
- Dishwashers and washing machines
- and standby and off-mode losses in general.
What are the economic incentives of eco-design?
Eco-design can lead to significant economic benefits through saving of materials, reduced number of components, use of recycled materials etc. For example the reduction of hazardous chemicals in production processes usually leads to less efforts needed for safety (hazardous substances logistics, documentation), meaning also cost reduction.
Another very simple example is as follows: Under WEEE the producer has to pay for the recycling according to the equation "product weight x units sold = market share (in kg)". The larger the market share, the higher the recycling costs. In case a company can reduce the product weight through eco-design the calculated market share decreases without selling less products. By now it is not clear, how much recycling will cost under WEEE conditions, but in European countries, where already similar systems exist, the recycling costs per kg are usually roughly in the range of 50 Euro-Cents. Recycling costs would drop accordingly, if product weight is reduced.
For more "advanced" eco-design approaches than just reducing the product weight Envirowise in UK undertakes "design tracks" individually with companies. Within this process several companies saved already more than 100,000 Euro per year each. See the Case Studies section for details.
Besides these quantifiable economic figures eco-design can have significant indirect economic effects: Better brand image, acquiring new customers, advantages within public procurement etc.
In many cases eco-design can lead to increased energy-efficiency, meaning cost savings for the customer. This has to be communicated properly, especially in case the more energy efficient device is more expensive and a cost break-even-point will only be reached after a certain use time.
What is an "Ecological Profile"?
The EuP directive defines the term ecological profile as follows:
"Ecological profile" means a description, in accordance with the implementing measure applicable to the EuP, of the inputs and outputs (such as materials, emissions and waste) associated with an EuP throughout its life cycle which are significant from the point of view of its environmental impact and are expressed in physical quantities that can be measured.
Do our competitors from Asia also have to comply with RoHS, WEEE, EuP?
In case your competitors serve also the EU market they also have to comply with the EU legislation. For these three directives it does not matter where a product is manufactured but if it is sold in the EU. Non-compliant products or if the producers are not registered according to the WEEE schemes means, these product are not allowed to enter the EU market. Be aware of non-compliant supplied parts, because then you are responsible as a producer. By the way: Also e.g. China is preparing a similar RoHS and WEEE legislation, meaning this legislation is not a regional "phenomenon" but compliance becomes an essential factor for global business success in general.
Does the consumer pay for "green" products?
Some do, others don't! Being asked, a large majority says that they care for environmental features. A remarkable number of consumers is even willing to pay more, in case the eco-product is more expensive. However, green products still serve a certain market niche. On the other hand, all major electronics brand name companies have implemented some kind of green initiatives - because it is of importance to them to be visible as an environmentally conscious company. In Japan, "leadfree" became a huge market success, long before RoHS came into force.
We want to initiate a project to improve the environmental performance of our products.
Who can help us?
There are a lot of consultants and research institutes all over Europe specialised on green product design. Some of them even have a profound technological background. See the list of eco-design contacts and especially of the partners in the EcoDesignARC network to find a national contact. There also might be an appropriate funding programme on national or European level to support your project and to finance external advice.
How can I be sure a Life Cycle Assessment (LCA) tells me the environmental "truth" about a product?
As LCA is a very complex methodology, it is difficult to assess the correctness of an LCA study. There are a couple of ISO standards of the 14.040 series, standardizing the LCA process and guaranteeing a certain level of science behind such a study. Transparency is the key: Databases and calculations should be documented well. Check especially the basic assumptions made and the boundary conditions. Is the scenario described representative? The International Stainless Steel Forum (ISSF) published a short checklist to evaluate the quality of an LCA study, see worldstainless.