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A Brave New Circular World

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Closing the LoopI don’t usually discuss regulatory requirements in this column, but today I am. Environmental regulatory requirements often must be addressed in the Product Requirements Documen and, subsequently, in the design, manufacturing, and support phases of the product lifecycle.

Manufacturers often try to put these requirements into a little box and make them “somebody else’s problem”. That only works for a short duration of time and doesn’t yield significant success. For those that adopt a “somebody else’s problem” approach, fundamental changes to how electronics are designed and brought to market wrought by environmental regulatory requirements are about to become inescapable.

The European Union has been on a circularity bender since 2015 when it issued its first Circular Economy Action Plan (CEAP). That put the words “circular economy” in everyone’s mouth and, for some, into their strategies. It drove certain changes to regulatory requirements that directly impacted many electronic product categories.

Changes were made to regulations (called “implementing measures”) under the EcoDesign Framework Directive (EFD) because of CEAP. Their scopes were extended beyond mere energy efficiency, which had been the target since 2005. For example:

  • Household dishwashers must now have an “eco program”. This operating mode must specifically be called “eco” and must follow specified energy efficiency and functional requirements. It must be set as the default mode. Water use as well as energy efficiency in this mode and others 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 particular length of time after the final unit of the product model is placed on the market. They must also have access to “repair and maintenance information”. Most implementing measures include this type of requirement; the requirement details are specific to the product type.
  • Manufacturers of enterprise–class servers and data storage systems must provide information about the weight range of cobalt in the batteries and neodymium in the hard disk drives.
  • Display, monitor, and television enclosures and stands may not contain halogenated flame retardants.

Think about how each of these may affect design and supply chain decisions you may make, as well as other aspects of bringing a product to market.

In 2020, the new CEAP was adopted. A key aspect of this plan is its establishment of “a sustainable product policy framework, including measures in three broad areas: fostering sustainable product design; empowering consumers and public buyers; and promoting circularity in production processes,” according to the European Commission (EC).

“Electronics and ICT” got its own short section in the latest CEAP stating the intent to further regulate energy efficiency and ensure design for “durability, reparability, upgradability, maintenance, reuse and recycling.” Most of these topics — and more — have been addressed in this column over the past two years. Now you know why.

A proposal has now been made to revise (“recast” in EU–speak) the EFD to drive these requirements and more. Indeed, Recital 5 of the draft proposed regulation says:

This Regulation will contribute to making products fit for a climate–neutral, resource–efficient and circular economy, reducing waste and ensuring that the performance of frontrunners in sustainability progressively becomes the norm. It should provide for the setting of new ecodesign requirements to improve product durability, reusability, upgradability and reparability, improve possibilities for refurbishment and maintenance, address the presence of hazardous chemicals in products, increase their energy and resource efficiency, reduce their expected generation of waste materials and increase recycled content in products, while ensuring their performance and safety, enabling remanufacturing and high–quality recycling and reducing carbon and environmental footprints.

The EC is tasked with establishing “ecodesign 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 shall meet the following criteria:

(a) there shall be no significant negative impact on the functionality of the product, from the perspective of the user;

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

(c) there shall be no significant negative impact on consumers in terms of the affordability of relevant products, also taking into account access to second–hand products, durability and the life cycle cost of products;

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

(e) there shall be no proprietary technology imposed on manufacturers or other economic actors;

(f) there shall be no disproportionate administrative burden on manufacturers or other economic actors.

A new aspect of this proposal is the extent of information that must be provided throughout the supply chain to the end consumer. This is termed the “product passport” and will be accessible via a bar code, QR code, “or other automatic identification data capture medium that can be read by a device”, according to the EC. The product passport will include:

  • information on “substances of concern” – consumers will no longer have to ask for information on REACH SVHC content in products as Article 33, paragraph 2 now requires.
  • as appropriate,

(i) information on the performance of the product in relation to 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 to ensure optimum durability, as well as on how to return or dispose of the product at end–of–life;

(iii) information for treatment facilities on disassembly, recycling, or disposal at end–of–life;

(iv) other information that may influence the way the product is handled by parties other than the manufacturer in order to improve performance in relation to product parameters referred to in Annex I.

Fortunately, the product passport will not be the only mechanism for information provision. Other “nondigital” pathways will be available as well, including placing the information in a user manual or on a “free access website or application”.

Note that the recast of the EFD is not being done in a vacuum; nearly every other environmentrelated regulatory instrument that impacts electrical and electronic equipment is now being, or soon will be, revised and recast. Along with the EFD, note that REACH, RoHS, WEEE, Batteries, and Packaging are all currently — or soon will be — in the midst of a recast. The 2020 CEAP is set to upend the world we have perhaps grown too comfortable with over the past decade.

To me, this is all very unfortunate. Because the electronics industry has not been adequately visionary, proactive, or broadly thoughtful enough to address these issues means that we are now subject to a government’s methodology for environmental performance improvement. My bet is that the EC’s approach is suboptimal; it will result in limited improvement primarily due to there not being experts in the development, design, and manufacture of electronic products.

On the other hand, the electronics industry — like many other industries — is not expert at circularity and sustainability. For this reason, your participation in the current stakeholder consultations as well as future public comment periods is critical.

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

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