A Look at Key Standards That Could Influence Future EU Legislative Proposals

Among the 44 recitals in the EU’s Ecodesign Framework Directive [1] is an assertion that the consideration of the environmental impact of an energy-related product [2] throughout its whole life cycle “has a high potential to facilitate improved environmental performance in a cost-effective way, including in terms of resource and material efficiency.”

However, the Framework Directive does not define what it means by “resource and material efficiency,” nor is this discussed in the European Commission’s Frequently Asked Questions (FAQ) on the Ecodesign Directive and its Implementing Regulations. [3]

Nevertheless, resource efficiency requirements are now getting written into EU ecodesign implementing measures. [4] For instance, the 2019 Refrigerating Appliance Ecodesign Regulation [5] specifies several resource efficiency requirements. Among these requirements are provisions for refrigerating appliance manufacturers, their authorized representatives, or importers to ensure the availability of spare parts as well as to offer access to repair and maintenance information.

Meanwhile, the European Commission has driven the creation of European material efficiency standards through a request made to the European Standardization Organizations (i.e., CEN, CENELEC, and ETSI). International, European, and national standard setters also appear to have been giving attention to resource efficiency – and product circularity more generally – in their respective work programs.

This article discusses the recent drafting of a European circular product standard, the publication of EN4555X material efficiency standards, and some specific international and national standards. This standardization activity is spearheading thinking on resource efficiency, and it could be that the requirements of these standards find their way into EU ecodesign implementing measures in the years ahead.

Circular Product Draft Standard – CD 45560

CEN and CENELEC’s Joint Committee 10 has drafted a standard with the title of “Method to achieve circular designs of products.” The Committee’s intention is to produce a standard that will present a method to help achieve “circular-ready” product designs. This standard is poised to:

• Specify requirements and guidance for integrating circularity into the design and development process of products developed by an organization (e.g., the manufacturer of one or more energy-related products);
• Support organizations in developing product design rules to fulfill their chosen circular categories (e.g., the circular business models chosen by the organization, the legislative requirements);
• Focus on material efficiency; and
• Provide guidance on how to reduce environmental impacts.

European Material Efficiency Standards – EN4555X Series Standards

Several generic material efficiency standards have been adopted as European Standards. The list that follows identifies these standards and summarizes what they address:

• EN 45552:2020, General Method for the Assessment of the Durability of Energy-related Products

As energy-related products often cannot be completely recycled, each product disposed of as waste incurs losses in energy and materials. Increasing the durability of energy-related products could therefore contribute to a reduction in the quantity of raw materials used, as well as the energy required for the production/disposal of such products. In turn, reductions in adverse environmental impacts become possible.

When considering durability, the trade-off between longer lifetimes (reducing impacts related to the manufacturing and disposal of the energy-related product) and reduced environmental impacts of new products (compared to worse/decreasing energy efficiency of older products) needs to be considered. In addition, consumer behavior and advances in technology have to be taken into account.

EN 45552:2020 specifies a general method for the assessment of the reliability and durability of energy-related products. In the standard, it is noted that durability can be expressed in different units (e.g., elapsed time, the number of operating cycles, distance, etc.). Meanwhile, reliability can be expressed as a particular unit combined with a probability. EN 45552:2020 describes a general assessment method that is intended to be adapted for application, at a product or product-group level, in order to assess the reliability/the durability of energy-related products.

• EN 45553:2020, General Method for the Assessment of the Ability to Remanufacture Energy‑related Products

This standard provides a general method for assessing the ability of an energy-related product to be remanufactured. Remanufacturing is identified as an industrial process where at least one change is applied that influences the safety, original performance, purpose, or type of the energy-related product.

• EN 45554:2020, General Methods for the Assessment of the Ability to Repair, Reuse and Upgrade Energy-related Products

In this standard, common elements allowing an energy-related product to be repaired, reused, or upgraded are addressed at both the component and product levels. For instance, the standard details how to evaluate the ability of certain parts for disassembly.

• EN 45555:2019, General Methods for Assessing the Recyclability and Recoverability of Energy-related Products

EN 45555:2019 notes that recovering materials and energy can reduce environmental impacts over the product life cycle, including through reduced extraction of natural resources and associated emissions of primary material production.

While recycling of energy-related products aims to close a circular economy loop, trade-offs might arise between different material efficiency-related topics. For instance, the mass of an energy-related product, as well as its durability, repairability, reusability, and energy efficiency, need to be balanced to improve the environmental benefit.

Once an energy-related product has reached the end of its life and is deemed waste, the product can either be prepared for reuse or recycled/recovered. EN 45555:2019 elaborates on the product characteristics that are relevant for the recyclability and recoverability of an entire energy-related product. The focus is, therefore, on the recyclability/recoverability of the product itself rather than the recycling or recovery processes. The general method presented in EN 45555:2019 considers the availability and efficiency of state-of-the-art recycling and recovery processes to determine the recyclability/recoverability rate of an energy-related product.

• EN 45556:2019, General Method for Assessing the Proportion of Reused Components in Energy‑related Products

EN 45556:2019 provides general methods for assessing the proportion of reused components in an energy-related product. The standard presents four calculation methods based on the mass of reused components and the number of reused components.

• EN 45557:2020, General Method for Assessing the Proportion of Recycled Material Content in Energy-related Products

This standard facilitates the provision of substantiated claims concerning the recycled material content of energy-related products. Of particular importance is the tracing of recycled materials from different sources.

The recycled material content of a new product is a characteristic of the product and its parts. This contributes to material efficiency, in addition to the potential for reusability, recyclability, and recoverability.

With a focus on the efficient and effective use of natural resources, primary materials are often able to be substituted with recycled materials, reducing the demand for primary materials with related potential environmental, social, and economic implications. These could include reduced mining and consumption of natural resources, reduced landfills, reduced emissions, and energy savings. The overall environmental impact will depend on the difference in the impacts of making materials from primary sources (e.g., oil, ore, etc.) versus reprocessing waste into secondary materials, which would directly substitute primary materials.

The benefit of increasing recycled material content in products is, in many cases, the incentivization of recycling end-of-life waste material through the stimulation of demand for recycled materials. In other cases, where there is already a high demand for recycled materials compared to the available supply, the link between the specification of material with a higher amount of recycled content and the incentivization of recycling is weaker. Overall, the rationale for specifying recycled material content needs to be considered for each material individually, depending on the specific supply/demand situation. EN45557:2020 provides for such considerations.

• EN 45558:2019, General Method to Declare the Use of Critical Raw Materials in Energy-related Products

Critical raw materials (CRMs) are economically important materials that exhibit high supply risks. The European Commission (and certain national governments) have identified and listed CRMs. The availability of information on the use of CRMs in energy-related products is intended to improve the exchange of information.

As information on the use of CRMs in energy-related products is fairly limited at present, determining usage is important. The objective of EN 45558:2019 is to provide a general methodology for the declaration of the use of CRMs in energy-related products in support of EU ecodesign implementing measures. 

EN 45558:2019 specifies a method for the declaration of CRMs, based on IEC 62474, Material Declaration for Products of and for the Electrotechnical Industry. The standard seeks to support efforts by energy-related product manufacturers to obtain information and report on the use of certain CRMs.

• EN 45559:2019, Methods for Providing Information Relating to Material Efficiency Aspects of Energy-related Products

This standard describes a general method for the communication of material efficiency aspects of energy-related products. It is intended to be used when developing a communication strategy in horizontal, generic, product-specific, or product-group publications. The standard relates to EN 45552 to 45558.

However, none of these standards have been adopted as harmonized standards under EU ecodesign legislation. As general methods, the standards provide a starting point for energy-related product manufacturers to begin assessing their products. But they are not necessarily going to capture every nuance and provide the reasoning that would justify trade-offs and substantiate the “best” material efficiency options. Nevertheless, the standards put European-level material efficiency thinking in a larger context.

Notable International and National Standards

In addition to the adoption of EN 4555x series standards, certain international and national standards are worth noting. Among these are:

• ISO 11469, Plastics – Generic Identification and Marking of Plastics Products

This international standard specifies a system of uniform marking of products that have been fabricated from plastics. The marking system is intended to help identify plastic products for subsequent decisions concerning handling, waste recovery, and/or disposal. Generic identification of the plastics is provided by the symbols and abbreviated terms given in ISO 1043, Parts 1 to 4.

The standard includes requirements on the marking system and the method of marking. The marking system is subdivided into marking of products, marking of single-constituent products, marking of polymer blends or alloys, and marking of compositions with special additives (fillers or reinforcing agents, plasticizers, flame retardants, and products with two or more components that are difficult to separate).

• BS 8887, Design for Manufacture, Assembly, Disassembly and End-of-Life Processing (“MADE”)

The UK national standards body, the British Standards Institution (BSI), developed and published a series of standards dedicated to design for manufacture. The series consists of:

• • BS 8887-1, Design for Manufacture, Assembly, Disassembly and End-of-Life Processing (MADE) – Part 1: General concepts, process and requirements;
  • BS 8887-2, Design for Manufacture, Assembly, Disassembly and End-of-Life Processing (MADE) – Part 2: Terms and definitions;
  • BS 8887-220, Design for Manufacture, Assembly, Disassembly and End-of-Life Processing (MADE) – Part 220: The process of remanufacture – specification. This outlines the steps required to change a used product into an “as-new” product, with at least equivalent performance and warranty of a comparable new replacement product; and
  • BS 8887-240, Design for Manufacture, Assembly, Disassembly and End-of-Life Processing (MADE) – Part 240: Reconditioning.

The international standard BS ISO 8887-1, Design for Manufacture, Assembly, Disassembly and End-of-Life Processing (MADE) Part 1: General concepts, process and requirements, is currently under development by the BSI committee TDW/4 “Technical Product Realization.”

• British PAS 141 re-use standard

Publicly Available Specification (PAS) 141 was developed to increase the reuse of electrical and electronic equipment and to ensure that these items are tested and repaired to a minimum level. In the UK, the Waste and Resources Action Programme (WRAP) has developed a set of protocols based on industry experience highlighting tests and procedures to be carried out. The product protocols form a baseline for electrical product assessment and repair for reuse and can be used as a guideline for product assessment and testing.

• Austrian standard ONR 192102:2014 on durable, repair-friendly designed electrical and electronic appliances

This standard describes a label for repair-friendly designed appliances. Energy-related product manufacturers, their authorized representatives, or importers who intend to label their products must test their products according to the requirements of ONR 192102 verifying compliance with a test report. The standard outlines a labeling system with three levels of achievement (good, very good, excellent). This is mostly based on repairability criteria. The standard includes around 40 criteria for white goods and 53 criteria for small electronics (brown goods). The aim is to consider repairability to ensure energy-related products are not discarded sooner than is necessary as a result of a fault or an inability to repair a fault.

The criteria include accessibility of components, ease of disassembly, use of standard components, achievable service life (e.g., at least ten years for white goods), availability of spare parts (at least ten years after the last production batch), facilitation of regular maintenance, and further service information. No specific testing procedures or methods are detailed though.

Concluding Thoughts

It will be interesting to see what now becomes of the standards outlined – and standardization activities mentioned – with respect to EU ecodesign implementing measures.

For EU legislators, significant gains could be achieved by drawing upon the published standards to identify and determine new requirements for inclusion in proposals for new or amended laws. For instance, requirements for CRM listings and product durability assessments could be incorporated into proposed revisions of EU ecodesign laws for domestic ovens, hobs and range hoods, as well as water pumps. This is possible, as is the drafting of product-specific European material efficiency standards to help give effect to these requirements for applicable energy-related products.

Upon adoption, such product-specific European material efficiency standards would likely get published in the EU Official Journal as harmonized standards under relevant ecodesign laws. This is, for instance, already the case for many product-specific performance standards. As is always the way with these things, future European Commission proposals for new or amended ecodesign laws will likely prove very telling.

Endnotes

1. EU Directive 2009/125/EC.
2. These are any goods or systems “with an impact on energy consumption during use which is placed on the market or put into service, including parts with an impact on energy consumption during use which are placed on the market or put into service for customers and that are intended to be incorporated into products.”
3. See https://commission.europa.eu/system/files/2023-01/EC_FAQ_ED%20-%20JAN%202023.pdf
4. As defined in the Ecodesign Framework Directive, implementing measures are “measures adopted pursuant to this Directive laying down ecodesign requirements for defined products or for environmental aspects thereof”. Implementing measures include ecodesign regulations (e.g., the Refrigerating Appliance Ecodesign Regulation) and self-regulatory initiatives (e.g., the Games Consoles Ecodesign Voluntary Agreement).
5. This is Regulation (EU) 2019/2019.