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What is
EuP?
EuP is short for
Energy-using
Products
Directive
2005/32/EC - EuP
On July 6, 2005, the
European
Parliament issued a directive "establishing a framework
for the setting of ecodesign requirements for energy-using
products."
The initial focus will be
on electric motor systems, HVAC equipment, water
heaters, domestic appliances, consumer electronics, office equipment, and
lighting because these products have been identified as having
high potential for a cost-effective reduction in greenhouse gasses. Over
time, implementation will expand to include all energy-using products,
defined as any product that is dependent on energy input (electricity,
fossil fuels, and renewable energy sources) to work as intended. However,
all means of transportation are specifically excluded from the scope of the
directive.
Ecodesign
reflects the philosophy that the most cost-effective way to reduce a
product's negative impact on the environment is to consider such issues
up-front during the design phase. This is because the amount of pollution caused over a product's
life is largely set by decisions made at design.
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Evaluation must include the entire
product life cycle: from raw material selection and manufacturing
process to packaging, transport, and distribution to installation,
maintenance and use, and finally to end-of-life which includes recycling,
reuse, and final disposal. |
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Ecodesign must balance
environmental considerations with technical, functional and economic considerations.
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Relevant
environmental
considerations are defined to include use of materials hazardous
to health or the environment; consumption of materials,
energy and water; potential for recovery of
materials and energy; use of recycled materials and used components; waste materials produced; emissions to air, water or
soil; consumables needed for proper use and
maintenance; pollution from noise, vibration, radiation
and electromagnetic fields; extension of product lifetime; ease of reuse and recycling at
end-of-life, including complexity and time
needed for disassembly.
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An EuP's
ecological profile consists of the measurable physical inputs and outputs
(such as materials, emissions and waste) over the product's entire life
cycle.
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The EuP directive provides
the legislative criteria and framework for the move to life cycle ecodesign.
The implementing measures that will
determine the specific requirements for each type of EuP are yet to be
developed.
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Per the directive,
implementing measures may not result in a
significant negative impact on the functionality, affordability or life
cycle of the product; on the industry's competitiveness; or on health,
safety and the environment. Proprietary technology and excessive
administrative burden may not be imposed on manufacturers. Requirements may
be phased-in, when necessary, to accommodate product development life
cycles. |
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Implementing measures are
to be developed through consultation with
stakeholders. Representatives from member states; manufacturers,
including small and medium-sized enterprises (SMEs) and craft industries;
trade unions, traders, retailers and importers; environmental
protection groups and consumer organizations are to be included. |
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Self-regulation
measures should be considered
and given priority when voluntary measures by the industry would provide
faster progress by allowing manufacturers to implement ecodesign standards
more quickly and cost-effectively than if mandatory measures were
imposed. Self-regulation also provides flexibility to respond to
technological options and market developments. Should market forces
fail to develop as anticipated, implementing measures would then be
imposed. |
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Self-regulation is
contingent upon harmonized standards
being developed by a recognized standards body and published in the Official
Journal of the European Union. Harmonized standards are voluntary
industry standards that provide technical specifications, measuring and
testing methods, ecological profiles, etc. for conformity with the EuP
directive. |
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There is a
presumption
of conformity for products
which have been developed according to published harmonized standards. |
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There is a
presumption
of conformity for products
which have received the Community eco-label (EC Regulation No 1980/2000). |
Conforming EuP products
must have:
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Declaration
of conformity which includes the name and address of the
manufacturer; an unambiguous description of the product such as the model
number; the applicable implementing measure; the harmonized standards or
other technical specifications met; and the identification and signature of
the person empowered to bind the manufacturer. Declarations may be issued
for individual products or for part families and must be kept on file by the
manufacturer. |
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CE
marking (at least 5 mm high) on the product or, if that is not
possible, affixed to packaging and accompanying documents.
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Information about the
manufacturing
process -- on the product itself if possible. |
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Information
about environmental characteristics and performance
that would allow consumers to compare products
-- on the product itself if possible.
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Consumer information about the
product's installation, use and maintenance
-- on the product itself if possible.
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End-of-life
information for treatment facilities concerning disassembly, recycling, or
disposal --
on the product itself if possible. |
Manufacturers may choose
one of two types of conformity assessment used
to demonstrate compliance with an implementing measure. The documentation
required for either assessment must be kept for 10 years after the last
manufacture of a product.
Internal
design control:
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A
technical
documentation file which includes the description and intended
use of the EuP; its ecological profile; environmental assessment studies by
the manufacturer or published in the literature; the solutions adopted to
meet the required standards; and quantifiable measurements that prove the
EuP meets all applicable standards. |
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Production
measures to ensure that the manufactured product does in fact
meet its design specifications. |
Management
system:
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A
program of systematic procedures for improving the overall environmental
performance of an EuP including: environmental performance objectives and
indicators; design control and verification techniques; methods for
establishing the ecological profile; management organizational structure and
resources; employee responsibilities and authorities; control of all
required documents and declarations; post-manufacture tests and checks to
verify product compliance; procedures to investigate and respond to
non-conformity; verification that the management system is working as
planned; and a full internal audit of the management system at least every
three years. |
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Written
procedures and instructions that thoroughly document the
management system. |
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A
technical documentation file which includes the description and intended
use of the EuP; its ecological profile; environmental assessment studies by
the manufacturer or published in the literature; the solutions adopted to
meet the required standards; and quantifiable measurements that prove the
EuP meets all applicable standards. |
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Presumption
of compliance
for manufacturers registered with EMAS
(EC
Regulation No 761/2001) provided that the design function is included in the
registration. |
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Presumption
of compliance for manufacturers with management systems
(including product design) implemented in accordance with published
harmonized standards. |
This summary is intended to give you an easy-to-understand overview and does
not constitute legal advice. The actual standard in the original language
should be reviewed and used for all business, legal, and product compliance
purposes.
Should
you need assistance in preparing your company for the EU's Ecodesign
Directives, we stand ready
to help you. Just
email
us or give us a call at 972-679-8996 for a rapid and personalized response.
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2006 -- All Rights Reserved
RSJ
Technical Consulting
PO Box 867705, Plano, Texas 75086
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