Comments on New ecodesign methodology for energy-related products (MEErP)

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1 Federal Institute for Materials Research and Testing, Germany Berlin Federal Environment Agency Germany Dessau-Roßlau 13 th February 2012 Comments on New ecodesign methodology for energy-related products (MEErP) 1. General Comments We support a further development of the methodology in order to appropriately address energy related products and resource efficiency aspects. The MEErP report includes based on the lessons learned from previous preparatory studies several clarifications. This seems very helpful in order to ensure a harmonised application of the assessment methodology and to gain comparable results. We especially welcome the introduction of the optional task 0 in order to define an appropriate scope in case of very large and inhomogeneous product groups; the default values of energy prices for the life cycle cost analysis as well as the escalation rate which indicates the expected energy price raise. This secures the use of the same parameters for the life cycle cost calculations in the different preparatory studies; the societal life cycle cost calculation; the possibility of entering new materials into the calculation with the new sheet for extra materials. 2. Base cases and improvement options ErPs are often assessed and limit values set according to the performance on test stands according to standards. These may deviate to a large extend from real life performance of the same ErP. Examples: For the combustion of solid and liquid fuels emissions of CO or hydrocarbons as measured on test stand at new appliances do not reflect real life emissions but can (at best) be used to compare the emissions of different appliances. In many cases energy use and emissions depend of maintenance and local conditions. Hence the standard performance needs to be described and should be used for the design of regulations but should be separated from data used for life cycle assessment where necessary. In MEErP it should be made clear that and at which point of the ErP studies differences between standard and real life impacts should be assessed.

2 3. Break Even Point Germany submitted a paper to the commission with proposals how to advance the present product policy instruments to an EU Top Runner System. One key issue is to orient staged requirements to the most efficient technologies on the market. This means that life cycle costs can be higher than the least life cycle cost (LLCC) but shall not be higher than the base case. This is the point where there are no additional costs over the life cycle for the consumer. The MEErP-study called this case break even (BE) point (MEErP study part 1, chapter 4.1.4). In principle, for the assessment of the BE the same rules apply as for the LLCC. The Break Even Point (the case with the highest achievable efficiency without exceeding base case life cycle costs) should from now be assessed in each preparatory study. 4. Best available technology and best not yet available technology The identification and description of best available technology (BAT), which can be given as benchmarks in the ecodesign regulations has been very insufficient in some preparatory studies. It is important to assess if the identified benchmark can be achieved for the whole scope or for single applications only. A general validity of benchmarks for a product group is a prerequisite in order to define benchmarks as future target values. Otherwise the product scope should be divided into subgroups to provide a good picture of the best available technology for the entire application range. In particular, it must be clearly stated whether benchmark values are based on real products available on the market, i.e. when there are benchmarks with regard to a number of environmental aspects if products exist that comply with all of the specified values or if compliance with all benchmarks would result in a theoretical product. The guidance of the MEErP study (see part 1, p. 84) is helpful but not yet sufficient. Especially a general definition of BAT should be given. In some cases, the data provided by the preparatory study are already outdated at the time of decision in the regulatory committee. Therefore the impact assessment should always assess and if necessary update the identified benchmarks. The best not yet available technology (BNAT) should not only be described technically but as far as possible also by efficiency parameters (e.g. energy consumption or energy efficiency index) in order to get a picture of possible future levels of efficiency. This is of special importance for product groups where the energy label or an energy efficiency scale (without entire label) is revised or introduced in order to appropriately predefine future energy efficiency classes. While some preparatory studies provided such information in very good quality in others it was completely missing. As the MEErP-study is already finished, we ask the commission to establish a short guidance document on identifying and describing BAT and BNAT in the preparatory study and the impact assessment. 5. Emissions to air during the use phase Emissions to air during the use phase (e.g. exhaust gas as well as relevant indoor air emissions) are not yet appropriately reflected with the indicators. E.g. no indicator of the Eco- Report Tool would lead to a proposal to limit NOx-emission in use phase, as it is planned for the implementing measure of boilers. While it is relevant to consider emissions for the entire

3 life cycle, an assessment with regard only to the use phase and with a differentiation with regard to outdoor and indoor air emissions should be included. E.g. the consultants of ENER lot 4 imaging equipment considered different indoor air emissions in the study, while the methodology does not ask for it and other consultants would not have considered these aspects. Such possible emissions should be considered separately for the use phase at least under Miscellaneous. The task to consider outdoor and indoor air emissions in the use phase needs to be added to the MEErP-report or - as the study is already finished - should be included in the tasks described in the call for tender respectively the contract. 6. New Indicators We welcome that new indicators are introduced, like the Critical raw materials indicator and recyc max in order to better address resource efficiency aspects beside energy efficiency. While we understand that probably due to resource constraints of the MEErP-study no more detailed analysis regarding indicators could be performed, further research and amendments are necessary. The JRC-study on behalf of the European Commission Integration of resource efficiency and waste management criteria in the implementing measures under the Ecodesign Directive 1 illustrates, that more respectively other indicators are feasible and necessary. The proposed indicator recyc max focuses on the minimization of the waste masses, but can t address the environmental impacts of the materials. An additional indicator is necessary which focuses on the maximization of the potential overall environmental benefits due to recycling, like the Recyclability Benefit Ratio proposed beside others by the JRC-study. It needs especially to be investigated and illustrated in more detail, how requirements based on these indicators can be established and how their appropriateness can be assessed. Deliverable 3 of the JRC-study provides a first valuable example in this respect. The JRC-study also demonstrates how with those indicators key components can be identified, which are the most relevant in terms of environmental impact. E.g. in the example of the hard disk drive the selective recycling of the circuit board can grant a saving up to about 90 % of the impacts due to manufacturing. In order to avoid potential shifting of burden a life cycle check for requirements, like recyclability benefit ratio is necessary. As the new indicators critical raw materials indicator, recyc max and the SVHC indicator are not included in the Ecoreport-Tool, the description of the tasks in the call for tender should explicitly refer to the application of those indicators. It should be possible to integrate implementable results of the ongoing JRC-study on resource efficiency indicators at a later stage in the MEErP. Analysis of the Base Case product and possible requirements have to be clearly distinguished especially for the content of recycled material. While a minimum requirement of recycled content of priority resources (e.g. critical raw materials) could 11 Adminstrative Arrangement no G2

4 deliver a valuable contribution to a resource efficient Europe, major practical constraints need to be considered and further investigated. First of all the long-time availability of recycled material need to be taken into account in order to avoid market distortion. Furthermore especially for metals it seems to be difficult to verify a recycled content by a product test rather certificates of the supply chain would be necessary. 7. Comments on the JRC-study Integration of resource efficiency and waste management criteria in the implementing measures under the Ecodesign Directive We very much acknowledge the contribution which the study provides to amend the MEErP in order to address resource efficiency more appropriately, see also comments above with regard to MEErP. It is of high value, that more indicators are investigated than proposed in the MEErP study, e.g. the Recyclability Benefit Ratio or the recycled content (of priority resources). The following comments are given in order to support the further advancement of the method and to check the practicability of their use. Thereby it should be differentiated between the application in the preparatory studies and the application in form of requirements, where companies have to calculate the indicators for all product models placed on the market. The examples coffee machine and hard disk drive are rather simple products compared to a PC or a machine tool. A PC or laptop can consist of 600 parts and more. Therefore the method should be checked for more complex products, as it is planned in the ongoing second phase of the JRC-study. With regard to the RRR Benefit Ratio we would like to ask, if also other methods have been assessed for their usability, like Environmental Impact Index (Atlee et. al. 2006) 2 or Quotes for environmentally Weighted Recyclability and Eco-Efficiency (QWERTY/EE), (Huisman et. al. 2006) 3 We welcome, that a disassembly index has been introduced for the calculation of RRR potentials. Only such indices will allow identifying differences between products. We understand that the given disassembly indices (e.g. deliverable 2, table 5 to 7) are only illustrative. Step 2 of the project should strive for developing and verifying such indices. We propose to investigate in how far such indices can be derived for typical electronic components used in various products and in dependence of the variety of used materials and the types of connections. The indices for mechanical disassembly need to be rechecked. At least for Precious Metals an index of 95 % is far too high, may be also for copper. According to Chancerel 4 the values are for silver below 20 %, gold and palladium about 20 % and copper about 60 % Atlee, Jennifer; Kirchain, Randolf: Operational Sustainability Metrics Assessing Metric Effectiveness in the Context of Electronics-Recycling Systems. Environmental Science & Technology, Vol. 40. No. 14, 2006, p Huisman, Jaco; Stevels, Ab L. N.:Eco-Efficiency of Take-Back and Recycling, a comprehensive Approach. IEEE Transactions on Electronics Packaging Manufacturing, Vol. 29. No. 2, April 2006, p Chancerel, Perrine and Rotter, Vera Susanne: Recovery of precious metals through preprocessing of waste electrical and electronic equipment, Müll und Abfall, No. 2, 2009, p

5 In case, that a company needs to calculate indicators, the affordability for manufacturers, especially for small and medium sized companies should be assessed. E.g. in case of PCs also little companies exist which buy components and produce tailor made PCs. Furthermore it would be interesting to compare several models of one product type to see if the indicators can also differentiate within a product group, e.g. between different coffee machines, and how big the differences are. The use of indicators like reusability and recyclability also need to be assessed in correlation of the reality of electronic waste collection and treatment. Requirements on recyclability or ease of separation of certain components will only have an impact in reality, if the end of life treatment corresponds to it. In some cases the financial or regulatory drivers are not yet strong enough to separate and recycle certain materials. On the other hand, ecodesign requirements could establish such drivers. Contact: Federal Institute for Materials Research and Testing (BAM) Floris Akkerman, Department S, Working group Product Requirements Phone: floris.akkerman@bam.de Federal Environment Agency (UBA) Andreas Halatsch, Section I 2.4 Energy Efficiency Phone: / andreas.halatsch@uba.de Ines Oehme, Section III 1.3 Eco-design, Environmental Labelling, Environmentally Friendly Procurement Phone: / ines.oehme@uba.de