Preparing for the Energy-Using Products (EuP) Ecodesign Directive
October 2007 (07B-155)
With the objective of increasing energy efficiency and protecting the environment, the EuP Directive is new European CE Marking legislation that will affect the entire life cycle of electrical and electronic products from design and production to end-life disposal. As such, this Directive will have more of an impact on the way companies launch their products than any other piece of EU legislation.
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The EuP Directive: An Overview
The EuP Directive will require manufacturers and importers to assess the environmental aspects of their products throughout their life cycle, and then based on this assessment to evaluate alternative design solutions, with the aim of improving the environmental performance of their products. For many companies, this will fundamentally change the design process and necessitate major changes to company management systems. As a CE Marking Directive, the requirements of the EuP Directive will have to be factored in alongside EMC, safety, radio and other requirements. The first products affected (as highlighted in the image below) will also have to comply within a matter of months so if you have not already started, work on preparing for compliance needs to start now.
| OBJECTIVE: |
The Directive aims to encourage manufacturers and/or importers to produce products which are designed to minimize their overall environmental impact, including the resources consumed in their production and disposal. |
| SCOPE: |
The EuP Directive applies to energy-using products being sold on the EU market in large quantities and posing a significant threat to the environment; some of the priority products affected as of 2008 are highlighted below. |
| RESPONSIBILITY: |
Under the Directive, manufacturers and importers are responsible for compliance. Manufacturers must ensure that their energy-using products comply with the applicable requirements, issue a declaration of conformity and mark the product with the CE Mark. If the manufacturer is established outside the EU and has no authorized representative in the EU, the importer will be required to ensure compliance. |
Complying with the EuP Directive
As a New Approach Directive, manufacturers or those responsible for compliance, such as importers/retailers, can demonstrate compliance using one of the two following options:
 Internal Design Control: A technical documentation file process that contains the evidence of compliance (ecodesign requirements contained within the implementing measure, design processes and measures taken, measurements and assessment of improvements made in environmental impact, etc…). Compliance with specific ecodesign Harmonized Standards (to be published) will also demonstrate compliance.
Full Quality Assurance: An alternative option is to manage your products under a “Full Quality Assurance” approach embracing process and quality controls. This can be used by companies who have a management system along the lines of EMAS or ISO 14001.
In both cases, manufacturers must perform an assessment of the EuP model throughout its life cycle, based upon realistic assumptions about normal conditions and purposes of use and then establish the EuP's ecological profile.
Preparing for the EuP Directive
The EuP Directive promises to bring sweeping changes to the industry. However, as the requirements are not yet established, a good place to start addressing compliance is by assessing your current status/product scope.
1) Gather information relevant to your product: Review information from the priority working group’s recommendations affecting your product(s). Is there any advice forthcoming from your trade association? What are your competitors and others in your industry doing and saying?
2) Review your product: Perform an ecological assessment of your product throughout its lifecycle (i.e., make an ecological footprint report).
3) Speak with your customers and suppliers: What are your customers asking for? What are your suppliers saying?
4) Develop a plan for compliance: Involve all appropriate areas within your organization.
5) Contact Bureau Veritas for assistance: We will gladly assist you starting from Step 1! Contact us directly for details.
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EuP AND IMPLEMENTING MEASURES
The EuP Directive does not introduce directly binding requirements for specific products. Instead, it defines conditions and criteria for establishing environmentally relevant requirements through subsequent implementing measures, which will vary by product. Under the measures, manufacturers and importers will be required to assess the environmental aspects of their products throughout the product’s life cycle.
Manufacturers also will be obliged to provide consumer information on the sustainable use of the product, the ecological profile of the product and the benefits of ecodesign as well as dismantling instructions. |
Contact Information
Bureau Veritas provides a range of training, consultancy, testing and certification services to help you prepare for and comply with this Directive. We can also provide you with an EuP Ecological Footprint Report.
Please visit our website at www.electrical.bureauveritas.com or email us at ecodesign-eup@bureauveritas.com for further information/assistance
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Bureau Veritas Consumer Products Services, Inc. (“BVCPS”) provides the information in this client bulletin as a resource of general information. It does not replace any applicable legal or regulatory requirements and is provided “as is.” BVCPS will not be liable for any indirect, special, punitive, consequential or other damages (including without limitation lost profits) of any kind in connection with this client bulletin. BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THIS CLIENT BULLETIN.
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