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Smart ecoDesign

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It creates a framework for the integration of various environmental aspects, such as energy EMC Pollution. Radiation Pollution. Other Product Specific

    Smart ecoDesign

    Energy Using Devices (EuP)

    Eco-design Checklist For Electronic Manufacturers, ‘Systems Integrators’, and Suppliers

    of Components and Sub-assemblies

    Issue 2 25 October 2007

Author: Graham Adams, seeba co-ordinator

    Checked and Approved by: Martin Charter, Director, CfSD

    Asia Eco-Design Electronics (AEDE) is funded by the European Union as part of the Asia-Pro Eco Programme This document has been produced with the financial assistance of European Union. The contents of this document are the sole responsibility of The Centre for Sustainable Design at the University College for the Creative Arts and can under no circumstances be regarded as reflecting the position of the European Union.

Contents

    1. INTRODUCTION......................................................................................................................... 4 OVERVIEW OF THE EUP DIRECTIVE ...................................................................................................... 5 Background ..................................................................................................................................... 5 Implementation Measures ............................................................................................................... 7 Eco-design Requirements ................................................................................................................ 9 Conformance ................................................................................................................................. 11 Initiatives for SMEs....................................................................................................................... 12 OTHER RELEVANT LEGISLATION ........................................................................................................ 13 Directive 2002/96/EEC: ................................................................................................................ 13 Directive 2002/95/EC: .................................................................................................................. 13 Directive 76/769/EEC: .................................................................................................................. 13 Directive 67/548/EEC: .................................................................................................................. 13 Directive 2002/44/EC: .................................................................................................................. 14 BASIC OVERVIEW OF ECO-DESIGN ..................................................................................................... 14 OBJECTIVES OF THIS DOCUMENT ........................................................................................................ 14 2. CHECKLIST PRINCIPLES ...................................................................................................... 16 ADVANTAGES AND LIMITATIONS OF CHECKLISTS .............................................................................. 16 CHECKLISTS IN THIS GUIDE AND THEIR APPLICATION ........................................................................ 16 Checklist 1: Management System.................................................................................................. 16 Checklist 2: Identification of key environmental aspects .............................................................. 17 Checklist 3: Material selection and use ........................................................................................ 17 Checklist 4: Manufacturing .......................................................................................................... 17 Checklist 5: Packaging, transport and distribution ...................................................................... 17 Checklist 6: Installation and maintenance .................................................................................... 17 Checklist 7: Product Use .............................................................................................................. 17 Checklist 8: End-of-life ................................................................................................................. 18 Checklist 9: Conformance Declaration ........................................................................................ 18 3. CHECKLISTS ............................................................................................................................ 19 CHECKLIST 1: MANAGEMENT SYSTEM ............................................................................................... 19 Introduction .................................................................................................................................. 19 Preparation for the EuP ................................................................................................................ 19 Internal Design Control ................................................................................................................ 22 Environmental Management System ............................................................................................. 24 CHECKLIST 2: IDENTIFYING KEY ENVIRONMENTAL ASPECTS TO BE USED IN THE ECOLOGICAL PROFILE .............................................................................................................................................. 26 CHECKLIST 3: RAW MATERIAL SELECTION AND USE ........................................................................... 28 Consumption of materials, energy, water etc. ............................................................................... 29 Anticipated emissions to air, water, or soil ................................................................................... 30 Anticipated pollution through noise, vibration, radiation, electromagnetic fields etc. ................. 31 Expected generation of waste material ......................................................................................... 31 Possibilities for reuse, recycling and material recovery. .............................................................. 32 CHECKLIST 4: MANUFACTURING ........................................................................................................ 33 Consumption of materials, energy, water etc. ............................................................................... 33 Anticipated emissions to air and water ......................................................................................... 34 Anticipated pollution through noise, vibration, radiation, electromagnetic fields etc. ................. 35 Expected generation of waste material ......................................................................................... 36 Possibilities for reuse, recycling and material recovery. .............................................................. 36 CHECKLIST 5: PACKAGING, TRANSPORT AND DISTRIBUTION .............................................................. 37 Consumption of materials, energy, water etc. ............................................................................... 37 Anticipated emissions to air, water, or soil ................................................................................... 37 Anticipated pollution through noise, vibration, radiation, electromagnetic fields etc. ................. 38 Expected generation of waste material ......................................................................................... 38 Possibilities for reuse, recycling and material recovery. .............................................................. 38

    Consumption of materials, energy, water etc. ............................................................................... 39 Anticipated emissions to air, water, or soil ................................................................................... 39 Anticipated pollution through noise, vibration, radiation, electromagnetic fields etc. ................. 40 Expected generation of waste material ......................................................................................... 40 Possibilities for reuse, recycling and material recovery. .............................................................. 41 CHECKLIST 7: PRODUCT USE .............................................................................................................. 42 Consumption of materials, energy, water etc. ............................................................................... 42 Anticipated emissions to air, water, or soil ................................................................................... 43 Anticipated pollution through noise, vibration, radiation, electromagnetic fields etc. ................. 43 Expected generation of waste material ......................................................................................... 44 Possibilities for reuse, recycling and material recovery. .............................................................. 44 ; GIVE CLEAR INSTRUCTIONS WITH THE PRODUCT AND CONSUMABLES ON WHAT TO DO WITH

    PACKAGING, AND THE PRODUCTS/CONSUMABLES AT END-OF-LIFE. .................................................... 44 CHECKLIST 8: END-OF-LIFE ................................................................................................................ 45 Anticipated emissions to air, water, or soil ................................................................................... 45 Anticipated pollution through noise, vibration, radiation, electromagnetic fields etc. ................. 45 Expected generation of waste material ......................................................................................... 46 Possibilities for reuse, recycling and material recovery. .............................................................. 46 CHECKLIST 9: CONFORMANCE DECLARATION .................................................................................... 49 4. APPENDICES ............................................................................................................................. 50 APPENDIX 1 PLASTIC COMPATIBILITIES AT END-OF-LIFE ............................................ 50 APPENDIX 2 LCA AND ECO-DESIGN TOOLS .......................................................................... 51

    1. Introduction

    This document is intended to help companies prepare for the European Energy using Products Framework Directive 2005/32/EC (EuP Directive). However following the checklists does not mean that a company will be EuP compliant since it is only when the Implementation measures for different groups of products are published that the actual requirements for a particular product group will be known. It is recommended that companies keep themselves up to date with EuP developments

    (See www.europa.eu.int/comm/energy/demand/legislation/eco_design_en.htm)

    The EuP Directive will mean a huge shift for many companies on how they design and launch their products and it will take considerable time for them to prepare for it. The first Implementation measures are expected to become EU law in early 2009. The checklists in this document are designed to help companies prepare so they are capable of meeting those requirements. In particular companies should be using them to help them modify their management systems and ensure the skills and resources are developed within the company to handle it. Companies prepared for the EuP Directive will have a tremendous advantage over those not prepared.

    At the time of writing, 21 product-related studies have been commissioned by the EC. Of these 8 have been completed, and the draft working documents of the implementation measures published for 2 of them. It is recommended that companies monitor the appropriate project websites to ensure they that are kept up to date with results of studies as they are completed (See www.europa.eu.int/comm/energy/demand/legislation/eco_design_en.htm)

    The checklists in this document will evolve as the analyses of the different products on the priority list are published and the different standards start to become available.

    One of the major challenges in writing the checklists in this document has been to marry the list of items in the main EuP legislation text with the methodology used by VHK and now being used by the priority products task forces. The former takes a more of an eco-design approach which is more understandable to most companies, whilst the second takes an Lifecycle Assessment (LCA) [simplified] approach which is more in line with the way academia and corporate business operate. It should be noted that the methodology developed by VHK is meant as a tool for each product study task force so the Commission has a common baseline to compare the environmental impact of completely different types of products. However there is some discussion that because each project manager has been instructed by the EC to use the VHK approach, that aspects of the methodology will be seen in the EuP Implementation measures.

    In addition to the above, use of highly simplified standardised data as currently proposed, will also almost certainly result in some debatable results. As an example the most critical item with regards to environmental impact in

    electronics is often the printed wiring board (PWB). The impact of this can also be greatly influenced by the design. The figure below shows the analysis of a real PWB using standardised data, and it can be seen that generally the largest environmental impact is from the materials rather than the process producing the part. However when the material’s data in the figure is examined in detail, the results show that 96% of the material energy figure comes from the use of gold flash. The EuP standardised figures for gold plating are far higher than those generally used by industry, whilst there is no standardised data at all for the flame retardant TBBA which forms 8% by weight of the total board. The danger is that misleading results will result if the wrong emphasis is placed on the Implementation legislation. What is urgently needed is a comprehensive list of standardised data which industry as a whole accepts.

    It is not suggested that the design checklists in this report are fully married up successfully with the EuP methodology but it is believed a good `start has been made.

Any feedback or comments on the checklist are welcomed.

Overview of the EuP Directive

    Background

    The EuP Directive was published in the European Union official journal on the 22nd July 2005. Member States are supposed to transpose it into national law by the 11th August 2007. It is based on article 95 so the requirements should

    be identical for all member countries. It creates a framework for the integration of various environmental aspects, such as energy efficiency, hazardous substances, water consumption or noise emissions, into the design of energy using products.

Initially there were 2 pieces of legislation in preparation:

    ; Framework directive on impact on the environment of electrical and

    electronic equipment" (EEE), which was based on Life Cycle

    Thinking, allowing the manufacturer to find the optimal balance

    between economic, social, technical and environmental

    requirements when designing his products.

    ; Framework directive on energy efficiency for end use equipment

    (EER), aimed to help commitments under the Kyoto protocol on

    combating climate change. The aim of this proposal was to set

    specific requirements for energy consumption of products targeted

    in so-called "implementing measures".

    On the 1st August 2003, the two draft directives were combined to become the EuP directive. It tries to combine the original principle of life cycle thinking with the setting of more specific requirements in the EER.

    The EuP directive came about because it was estimated over 80% of all product-related environmental impacts are determined during the product design phase. The EuP directive states in the introduction:

    Action should be taken during the design phase of EuPs since it appears that the pollution caused during a product’s life cycle is determined at that stage, and most of the costs involved are committed then.’

    Energy using products account for a large proportion of the consumption of natural resources and energy used within the EU.

    The directive applies to products that use electricity, fossil fuels or renewable energy sources during its use stage of the life cycle. It also applies to products used for generation, transfer or measurement of energy, and parts dependent on energy input supplied to end-users as individual parts if they can be assessed for environmental performance. Component and sub-assembly manufacturers may under the implementing legislation have to supply material composition and energy/material consumption data to the EuP producer. There are some exemptions. They are:

    ; Transportation vehicles for people or goods. E.g. cars, trucks, ships,

    aeroplanes and rail.

    ; It is not clear whether the above includes agricultural and construction

    equipment that can move.

    The EuP is a framework directive. The framework sets a template for legislation on specific product groups. The specific product groups will follow the parts of the template that are applicable to those groups. The framework will then allow the rapid implementation of legislation on products under the scope of the EuP in a standardised manner. It should be noted the EuP Directive will not directly create legal obligations and requirements for

    manufacturers. This will happen only when the implementing measures are adopted.

Implementation Measures

    Implementation measures can be either self regulation by an industry, or legislation. If self regulation is used it will have to demonstrate it is effective and satisfy the following:

    ; Open to all countries for participation in preparation and

    implementation.

    ; Provide positive improvements to the eco performance of EuPs.

    ; Represent a large majority of the industry for the relevant sector.

    ; Have clear measurable objectives, including time span and use of

    scientific data to develop the indicators.

     Be transparent. Stakeholders including EU states, NGOs, industry, and ;

    consumer associations must have access to interim and final reports.

    ; Have good monitoring system with independent inspectors.

    ; Cost effective, especially with regards to monitoring.

    ; Consistent with economic/social dimensions of sustainable

    development

    ; Compatible with external factors e.g. market pressures, taxes etc.

    There will be 2 types of implementing measure requirements called specific and generic requirements. Specific requirements will have specific measurable targets set which companies will have to meet. This could be for example a value for maximum energy consumption on standby mode, or a maximum threshold set for a hazardous substance.

    Generic requirements have no targets but a company is expected to demonstrate they have addressed it in their product launch process. These requirements will be taken from the complete list of generic requirements in the EuP.

    Energy using products (EuPs) will be targeted if they meet the following criteria:

    ; Sales in the EU greater than 200,000/year

    ; Have a significant environmental impact as set out in EU decision

    1600/2002/EC

    ; Have significant potential for improvement

    Products in most of the WEEE categories are likely to be targeted as nearly all of them meet the above requirements.

    A range of products have already been identified for priority action on introducing implementation measures. These are:

    ; Heating and water heating equipment

    ; Electric motor systems

    ; Lighting (Public and office)

    ; Computers

    ; Imaging equipment

    ; Televisions

    ; Standby and off mode energy use

    ; Battery chargers and power supplies

    ; Room *air conditioning system

    ; Domestic and commercial refrigerators and freezers

    ; Washing machines and dishwashers

    ; Domestic lighting

    In addition to the above a fast track simple set top box study has been launched plus the following studies are planned to start during 2008:

    ; Complex set top boxes (with conditional access and/or functions that

    are always on)

    ; Vacuum cleaners

    ; Laundry driers

    ; Domestic lighting phase II

    ; Solid fuel small combustion installations (in particular for heating)

    Draft Implementation measures on public street lighting and standby and off mode losses were produced in September 2007

    In parallel to the above a 3 year working plan will be produced. A study group for preparing this has been set up. It will propose products to be included in the working plan. A short list of the 25 highest priority products from all the products examined will be produced.

Eco-design Requirements

    Specific eco-design requirements are set target values that must be met by the EuP as set out by the implementation measure. The commission will carry out technical, environmental and economic analysis on representative EuPs and identify technical options for improving the environmental performance. From this the specific requirements will be formulated. The date of entry will take into account the time normally required to redesign an EuP.

    As mentioned previously generic eco-design requirements look at the whole ecological profile with no specific limit values on a particular environmental aspect. The minimum scope is set by the implementing measures with priority given to what can be most influenced by product design. These measures will be decided by a committee still to be formed by the Commission. It will where appropriate decide:

    ; Relevant eco-design parameters from the full list.

    ; The information supply requirements from the full list

    ; The requirements for the manufacturer from the full list.

    An environmental assessment of a representative model looking at inputs/outputs as measurable quantities that occur throughout the life cycle will need to be done. Manufacturers use this assessment to improve environmental performance during product design against benchmarks set by the EU commission. The design should be a balance between different environmental aspects and other requirements in safety, health, quality,

    performance, manufacturability, marketability and costs, whilst complying with relevant legislation.

    The following lifecycle phases, where they relate to design will be required to look at:

    ; Raw material selection and use

    ; Manufacturing

    ; Packaging, transport and distribution

     Installation and maintenance ;

    ; Use

    ; End of life (e.g. end of its first use reuse- recycling - until final

    disposal.)

    The following environmental aspects of each phase will be assessed where relevant for:

    ; Consumption of materials, energy, water etc.

    ; Anticipated emissions to air, water, or soil

    ; Anticipated pollution through noise, vibration, radiation,

    electromagnetic fields etc.

    ; Expected generation of waste material

    ; Possibilities for reuse, recycling and material recovery taking into

    account 2002/96/EC (WEEE directive)

    Where appropriate the following should be used to evaluate the environmental aspects for potential eco-design improvements that can be made:

    ; Product weight and volume

    ; Recycled material content and incorporation of used components

    ; Consumption of energy, water etc through the lifecycle

    ; Use of hazardous substances (As per directives 67/548/EEC,

    2002/95/EC, and 76/769/EEC)

    ; Quantity and nature of consumables needed for use and maintenance

    ; Ease of reuse and recycling (number of materials/components,

    disassembly time, complexity of tools, component standardisation etc)

    ; Incorporation of used components

    ; Avoidance of technical solutions detrimental to reuse or recycling

    ; Extension of lifetime (modularity, upgradeability, guarantees etc)

    ; Amount of hazardous and non-hazardous waste generated.

    ; Emissions to air, water and soil of hazardous substances, gasses etc.

    The following information will need to be supplied by the manufacturer if specified under the implementation measures because they influence the way the EuP is handled, used or recycled by parties other than the manufacturer:

    ; Design information relating to the manufacturing process.

    ; Information to be given together with the EuP to consumers on

    significant environmental characteristics and performance of product so

    they can make comparisons.

    ; Information to consumers on how to install the product in order to

    minimise environmental impact and ensure optimal life-expectancy.

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