A brave new circular world

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I don’t usually talk about regulatory requirements in this column, but today I do. Environmental regulatory requirements often need to be addressed in the product requirements document and subsequently in the design, manufacturing, and support phases of the product lifecycle.

Manufacturers often try to put these requirements in a little box and make them “someone else’s problem”. It only works for a short time and does not yield significant success. For those who take a “someone else’s problem” approach, fundamental changes in the design and marketing of electronics, driven by environmental regulatory requirements, are about to become inevitable.

The European Union has been in a spiral of circularity since 2015, when it published its first circular economy action plan (CEAP). This put the words “circular economy” on everyone’s lips and, for some, in their strategies. It has resulted in some changes to regulatory requirements that have had a direct impact on many categories of electronic products.

Changes have been made to the regulations (known as “implementing measures”) under the Ecodesign Framework Directive (EFD) because of CEAP. Their scopes have been extended beyond simple energy efficiency, targeted since 2005. For example:

  • Household dishwashers must now have an “eco program”. This mode of operation must specifically be called “eco” and must meet specified energy efficiency and functional requirements. It should be set as the default mode. Water usage as well as energy efficiency in this and other modes must be specified in the product manual, which itself must be made available on a “free” website.
  • Spare parts, including firmware and software, must be made available to “professional repairers” for a specified period of time after the final unit of the product model has been released to the market. They must also have access to “repair and maintenance information”. Most enforcement measures include this type of requirement; the details of the requirements are specific to the product type.
  • The manufacturers of enterprise class servers and data storage systems should provide information on the weight range of cobalt in batteries and neodymium in hard drives.
  • Display, Monitor and TV Enclosures and Mounts must not contain halogenated flame retardants.

Consider how each of these elements can affect the design and supply chain decisions you can make, as well as other aspects of bringing a product to market.

In 2020, the new CEAP has been adopted. A key aspect of this plan is the establishment of a “sustainable product policy framework, comprising measures in three main areas: fostering the design of sustainable products; empower consumers and public purchasers; and promoting circularity in production processes,” according to the European Commission (EC).

“Electronics and ICT” has its own short section in the latest CEAP indicating the intent to further regulate energy efficiency and ensure design for “durability, repairability, upgradability, maintainability, reuse and recycling”. Most of these topics – and many more – have been covered in this column over the past two years. Now you know why.

A proposal has now been made for revise (“recast” in European jargon) the EFD to meet these requirements and more. Indeed, recital 5 of the proposed draft regulation says:

This regulation will help make products suitable for a circular economy, resource-efficient and climate-neutral, reduce waste and ensure that pioneering performance in sustainability gradually becomes the norm. It should provide for the definition of new eco-design requirements in order to improve the durability, reusability, upgradability and repairability of products, to improve the possibilities for refurbishment and maintenance, to combat presence of hazardous chemicals in products, to increase their energy and resource efficiency, to reduce the expected generation of waste recycled materials and to increase the recycled content in products, while ensuring their performance and safety, by enabling high quality refurbishment and recycling and reducing carbon and environmental footprints.

The EC is responsible for establishing “design requirements” in these areas and more at the product category level. But they must do so without breaking the product or its manufacturer. Article 5, paragraph 5, says:

Ecodesign requirements must meet the following criteria:

(a) there must be no significant negative impact on the functionality of the product, from the user’s point of view;

(b) there will be no adverse effect on the health and safety of persons;

c) there is no significant negative impact on consumers in terms of the affordability of the products concerned, taking also into account the access to second-hand products, the durability and the life cycle cost of the products ;

(d) there is no disproportionate negative impact on the competitiveness of economic actors, at least SMEs;

(e) no proprietary technology is imposed on manufacturers or other economic actors;

(f) there is no disproportionate administrative burden for manufacturers or other economic actors.

A new aspect of this proposal is the extent of the information that must be provided throughout the supply chain to the final consumer. It’s called the “product passport” and will be accessible via a barcode, QR code, “or other device-readable automatic identification data capture medium,” according to the EC. The product passport will include:

  • information on “substances of concern” – consumers will no longer have to request information on the content of REACH SVHCs in products, as now required by Article 33(2).
  • if applicable,

(i) information on the performance of the product against the product parameters referred to in Annex I;

(ii) information for consumers and other end users on how to install, use, maintain and repair the product in order to minimize its impact on the environment and ensure optimum durability, as well as on how to return or dispose of the product at end of life;

(iii) information for processing facilities on dismantling, recycling or end-of-life disposal;

(iv) other information which may influence how the product is handled by parties other than the manufacturer in order to improve performance with respect to the product parameters referred to in Annex I.

Fortunately, the product passport will not be the only mechanism for providing information. Other “nodigital journeys” will also be available, including placing the information in a user manual or on an “open-access website or app”.

Note that the EFD redesign is not happening in a vacuum; almost any other environmentThe related regulatory instrument that affects electrical and electronic equipment is currently or will soon be revised and revised. With the EFD, note that REACH, RoHS, WEEE, Batteries and Packaging are all currently – or soon will be – in the midst of an overhaul. CEAP 2020 is about to shake up the world that we have perhaps become too accustomed to over the past decade.

To me, this is all very unfortunate. Because the electronics industry has not been visionary, proactive, or thoughtful enough to address these issues, we are now subject to the government’s environmental performance improvement methodology. I bet the EC approach is underoptimal; this will result in limited improvement mainly due to the lack of experts in the development, design and manufacture of electronic products.

On the other hand, the electronics industry – like many other industries – is not an expert when it comes to circularity and sustainability. For this reason, your participation in current stakeholder consultations as well as future public comment periods is essential.

A consultation period for EFD is now open until June 5. This is your chance to contribute to the process. Note that there are 700 pages of documentation to go through. No, they don’t make it easy; but the solution to a complex problem is never easy.


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