28 Apr 2015

Industry answer to Commission paper on products integrated into other energy related products

Industry answer to Commission paper on products integrated into other energy related products

Promote innovation instead of double regulation

The issue of setting ecodesign requirements on components integrated in products that are already themselves covered by ecodesign measures is a priority concern for our industry. This recent practice, is endangering freedom to innovate without any benefit for either consumers or the environment.

We believe that this approach is flawed for the following reasons:

1. Manufacturers should be able to choose the best combination of components whilst ensuring the ecodesign requirements for the final equipment are met

2. Regulating components does not necessarily lead to a more energy-efficient products from a least life cycle cost perspective

3. The proposal’s effect on spare parts will endanger their availability, thereby hampering reparability and lifetime of the final product

4. A “one size fits all” approach, when setting requirements for components used in a number of different applications, will not deliver the expected results in terms of energy savings

Back to Sustainability
View the complete Policy Paper
Our resources on Sustainability
Policy Paper 23 Jul 2020
DIGITALEUROPE’s vision for sustainable consumers: consumer information, repair and product lifetimes
Policy Paper 11 Jun 2020
JBCE – DIGITALEUROPE joint position paper on the NFRD review
Policy Paper 27 Apr 2020
DIGITALEUROPE’s Initial Views on the Revision of Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical & electronic equipment (RoHS)
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