September 2006

DEFRA has published a consultation on EuP with replies invited by 29 th November 2006 .  This full consultation can be viewed on the DEFRA website www.defra.gov.uk/corporate/consult/ecodesign-energy/index.htm

The EuP directive was published in the official journal on the 11 th July 2005. The directive came into force on the 11 th August 2005 and member states have until 11 th August 2007 to implement this into national law. A pdf of the directive 2005/32 can be downloaded here.

Article 15 of the directive discusses the proposed implementing measures and confirms the criteria for selection as follows

The product should have significant volumes of sales, typically over 200,000 units p.a in the community.

1. The product should have a significant environmental impact.
2. The product should have the potential for improvement on the impacts without incurring excessive costs.

Article 16 of the directive suggests that by July 2007, a working plan is drawn up with product groups that match these criteria and that should be considered for implementing measures. In the transition period implementing measures are to be introduced for

Reducing stand by losses for groups of products.

• Product groups that show potential for cost effective reductions in green house gases such as heating & water heating equipment, electric motor systems, lighting, domestic appliances, office equipment, consumer electrics and HVAC systems.

The EUP directive is a framework directive that harmonises requirements concerning the design of end use equipment. The directive merged two initiatives, the EEE directive (impact on the environment of electrical and electronic equipment) and the EER directive (energy efficiency requirements) to make a single directive.

With regard to article 95, the new framework directive aims to ensure the free movement of end use equipment by integration of environmental aspects in the design & development of equipment and by setting eco design requirements.

The proposal defines EuP as equipment which is dependant on energy input (electricity, fossil and renewable fuels) to work as intended and equipment for the generation, transfer and measurement of such energy. In principal all such products are covered by this directive, but in practice it sets out criteria for selecting product groups to be considered. Once product groups are selected the commission will introduce what is termed an 'implementing measure' for that product group.

The commission may adopt implementing measures for defined catagories of EuP in order to set eco-design requirements and specific eco-design requirements.

The eco-design requirements expects manufacturers to consider the entire life cycle of product groups and to assess the ecological profile of the equipment. This includes a life cycle analysis of equipment looking at;

1. Raw Materials
2. Acquisition
3. Manufacturing
4. Packaging, Transport and Distribution
5. Installation and Maintenance
6. Use
7. End of Life

At each phase of this manufacturers are required to assess consumption of materials and energy, emissions to air and water, pollution, expected waste and recycling/re-use.

The specific eco-design requirements may take the form of considering the reduced consumption of a given resource in the various stages of its life cycle, such as water or electricity. This requires a technical-economical analysis to be done to identify technical options for improving the environmental performance of the equipment. This analysis should then lead to a reduction in the environmental impact of the equipment. In the case of energy consumption in use, the level of energy consumption should be set at the life cycle cost minimum to the final users (LLCC or least life cycle cost)

Internal design control and an environmental management system are the procedures available to the producer for ensuring and declaring that it's products satisfies the provisions of any applicable implementing measure.

Presumption of conformity to the directive is through a CE mark as well as established EU schemes such as the Eco-Label.