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
PDF
Our resources on Sustainability
Policy Paper 26 Jul 2019
Joint industry comments on modulating producers’ financial contributions for Waste Electrical and Electronic Equipment
Publication & Brochure 12 Jun 2019
Digitalisation as key for a sustainable Europe - our Call to Action for the EU's Strategic Agenda 2019-2024
Policy Paper 24 May 2019
Key recommendations for the development of the SVHC database by ECHA
Hit enter to search or ESC to close