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Implications of Eco design Requirements for Energy Related Products (ErP) on Electrical & Electronic Equipments (EEE) Business. Dr. Rashmi Naidu REACH Support, Nagpur. REACH and ErP Sensitization workshop 9 th Sept’10 (Bangalore) & 10 th Sept’10 (Chennai). Contents. What is ErP Directive?
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Implications of Eco design Requirements for Energy Related Products (ErP) on Electrical & Electronic Equipments (EEE) Business Dr. Rashmi Naidu REACH Support, Nagpur REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Contents • What is ErP Directive? • Aims of ErP • Products/Components affected by ErP? • Exemptions within ErP • Key features of ErP • Present Status of Implementing Measures • Authorized Representative (AR)? • Role of an Authorized Representative • Relevance of ErP for Non-EU Manufacturers • SSS Authorized Representative Services REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
What is ErP Directive? • ErP Directive (2009/125/EC): A Framework for setting eco-design requirements for energy-related products; • The old EuP Directive only covered products that were using energy such as a microwave, washing machine or a television. • The new ErP-Directive covers products under the old EuP Directive as well as products that are energy-related and do not directly use energy such as double glazing windows, taps and showerheads. • EuP legislation shall be consistent in all EU States, i.e., it is a single market directive. contd.. REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
What is ErP Directive (Contd…..) • As the first directive it covers a product’s total life cycle, starting from Raw Material selection to Manufacturing, then trade, Use/ Maintenance, Reuse/ Recycling/ End of Life Treatment. This is known as ‘cradle to grave approach.’ • Before an ErP compliant product is placed on the market and/or put into service, • a CE marking have to be affixed and • an EC declaration of conformity have to be issued. • The manufacturer or its authorized representative must ensure and declare that the product complies with all relevant provisions of the applicable implementing measure. REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Aims of ErP Directive • Promotion of sustainable development by increasing: • energy efficiency and the level of protection of the environment, • the security of the energy supply • Providing framework for eco-design requirements in order to ensure free movement of ErP compliant products within the European Union REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
What Products/components will ErP affect? • Products that use electricity, fossil fuels or renewable energy sources during its use stage of the life cycle. • Product used for generation, transfer or measurement of energy. • Parts dependent on energy input supplied to end-users as individual parts • Component and sub-assembly manufacturers may, under the implementing measures, have to supply material composition and energy/material consumption data to the ErP producer. • certain energy-related products such as windows, insulation materials, or some water-using products such as shower heads or taps REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Presumption of Conformity • If the product is already compliant with existing EU harmonized standards published in the Official Journal of EU. Or; • Product having Community Eco Label pursuant to EC No. 1980/2000 or; • Any other Eco Label fulfilling equivalent conditions to Community Eco Label REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Key Features of ErP • Eco design requirements • Implementing measures • CE Marking REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Eco Design Requirements Any requirement in relation to a product, or the design of a product, intended to improve its environmental performance, or any requirement for the supply of information with regard to the environmental aspects of a product. ‘Generic eco-design requirement’ means any eco-design requirement based on the ecological profile as a whole of a product. ‘Specific eco-design requirement’ means a quantified and measurable eco-design requirement relating to a particular environmental aspect of a product, such as energy consumption during use. REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Implementing Measures • Implementing Measures (IMs) are the specific product related pieces of legislation (e.g. regulations) that set out the legislative requirements that products sold in the EU will be required to meet from specific dates. • the European Commission, assisted by a committee of Member States, adopt implementing measures relating to individual product types. REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Present Status of Implementing Measures • Implementation Measures already in place for following product categories: • Standby mode of electrical and electronic equipment • Simple set top boxes • Lighting equipment (lamps, ballasts, lighting fittings) • No-load condition electric power consumption and average active efficiency of external power supplies • Domestic refrigeration • Televisions • Domestic lighting • Electric Motors • Circulators REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Present Status of Implementing Measures • Following products will be covered by individual implementing measures: • Tertiary sector lighting (street & office) • External power supplies • Boilers and combi-boilers (gas/oil/electric) • Water heaters • Personal computers (desktops and laptops) & computer monitors • Imaging equipment (copiers, faxes, printers, scanners, multifunctional devices) • Air-conditioning and ventilation systems (residential) • Commercial Refrigeration (display cabinets and vending machines) REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Present Status of Implementing Measures (Contd….) Domestic dishwashers and washing machines Solid fuel small combustion installation Laundry driers Vacuum cleaners Complex set top boxes Domestic lighting II (reflector lamps and luminaries) Electric Pumps Fans REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
CE Marking The letters "CE" are the abbreviation of French phrase "Conformité Européene" which literally means "European Conformity" The CE marking must have a height of at least 5 mm. If the CE marking is reduced or enlarged the proportions given in the above graduated drawing must be respected. The CE marking must be affixed to the EuP. Where this is not possible, it must be affixed to the packaging and to the accompanying documents. REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Authorized Representative? ‘Authorized representative’ means any natural or legal person established in the Community who has received a written mandate from the manufacturer to perform on his behalf all or part of the obligations and formalities connected with this Directive REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
What is the Role of Authorized Representative? • To maintain relevant technical and legal documentation on the product / components. • To report and be answerable to the Enforcement agency in various EU member states. • To develop and maintain the Technical dossier on the product/ component. • To Issue declaration of conformity. • To maintain documentation for 10 years after the product/ component is last placed on the market. REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Why ErP is Relevant for Non-EU exporters • To ensure the continuity of the current business activities & provide new horizons for expanding the business. • To reduce the risk associated with the non-compliance and improve the company’s reputation in the international markets. • For Non-EU manufacturers/exporters, it is the responsibility of the person putting the ErP into the EU market to ensure ErP compliance REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Important Timelines within ErP REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Non-EU exporters Obligations? • Identify and appoint an Authorized Representative (AR) to be able to fulfill the requirements of ErP regulation on their behalf. • Non-EU exporter needs to develop a technical documentation file on the products/ components that would be maintained by the Authorized Representative (AR). • In addition, the non-EU exporter would be required to provide through the AR a “declaration of Conformity” of products with the ErP implementation procedures as are laid out within the law. • The component exporters would also need to communicate with their importer to seek clarity on who shall be fulfilling the ErP Directive obligation. REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
SSS Authorized Representative Services • SSS (Sweden) with a core team of 25 professionals specialize in EU regulations • SSS will act as your Authorized Representative and will provide advice on the compliance with product specific legal and technical requirements. • SSS will develop the technical dossier as is required to be maintained within respective ErP implementation measures. • SSS will also guide you for the certification procedures. • SSS will issue the declaration of conformity with ErP regulation on your behalf to your buyers and relevant Competent Authorities. • SSS will acts as the contact person for market surveillance authorities and end users when conformity issues are concerned. • SSS stores and updates the technical files of the products/ components sold in Europe, and make them available to the appropriate authorities upon request. • SSS monitors and reports on new developments in European product legislation relevant to clients. REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
For more information Please visit the web site www.reach-support.com www.reach-onlyrep.eu www.erp-compliance.com For seeking responses to queries, please write to rashmi@reach-support.com Thank you REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)