Joint industry paper on material efficiency requirements display regulation

EXECUTIVE SUMMARY

Following detailed analysis of the Commission’s proposal for a display energy labelling regulation as well as the Commission’s revised approach presented during the Consultation Forum, the above signatories have identified the following key concerns as potentially affecting manufacturers and consumers.

We welcome the Commission’s revised scope proposal, which now covers the full range of stand-alone displays and excludes displays integrated in other types of products. We reiterate that the original scope proposal lacked an impact assessment with a view to technical feasibility, costs, benefits and innovation, as required under the Ecodesign Directive. Moreover, we encourage a thorough assessment of the design aspects of integrated displays for the setting of resource/material efficiency requirements in the appropriate vertical regulations. While we encourage the introduction of such requirements to facilitate the transition to a Circular Economy, we support that better regulation principles must be respected at all times, together with an appropriate implementation process.

Additionally, our industries support the introduction of the requirements to facilitate End-ofLife dismantling. We also applaud the announced shift of focus from the initial gluing and welding restrictions to a technology-neutral requirement concentrating on the removability of components for selective treatment irrespective of the employed joining, fastening or sealing techniques. We believe that the revised wording emphasizes the original intention behind the requirement, i.e. to restrict joining techniques that prevent removability. While seconding the Commission’s new approach, we propose a further adjustment of the wording of the requirement to also cater for products that must rely on non-removable joining techniques to ensure proper safety and functionality, durability and privacy.

Finally, we remain concerned that a requirement to disclose detailed information on dismantling operations could hamper the industry’s competitiveness and reveal IPR-sensitive information. We are apprehensive of the liability issues, security and potential brand damage that may arise for manufacturers. Consequently, our industries advise against any obligation making product diagrams and repair/disassembly information available to third parties. We insist on ensuring a safe dismantling process of components and advocate that information should only be shared upon request from recyclers and market surveillance authorities. Lastly, on the identification and tracking of material/chemical presence in hardware products, we are concerned about the significant financial and administrative burden that would dominate any usefulness aspired by the Commission’s proposal.