|
SCOPE of Directive 2009/125/EC: |
| |
Includes products
that use, generate, transfer or measure energy (EuP) |
| |
Includes products
that impact energy consumption during use (ErP); Recital #4
lists construction materials such as windows and insulation and
water-using products such as shower heads and taps |
| |
Excludes products
that transport people or goods |
|
ErP is a "framework
directive" that establishes only the regulatory framework for
ecodesign. The actual ecodesign requirements are set forth in the
implementing measures which are issued for specific
product groups after consultation with stakeholders. |
|
Manufacturers of a
product covered by an implementing measure have these three
obligations prior to placing the product on the EU market (or in
service): |
| |
Conformity assessment that the product
meets all relevant requirements |
| |
CE mark
affixed to the product |
| |
EC
declaration of conformity issued per
Annex VI |
|
Manufacturers
located outside the EU may not fulfill these obligations directly,
but must engage either an "authorized representative" or the
importer to do so on their behalf. |
|
The manufacturer's
conformity assessment is the heart of the ecodesign process and may
use either of these two approaches: |
| |
Internal design control per Annex IV |
| |
Management system per Annex V |
|
Internal design
control (Annex IV) is centered on the maintenance of a
technical documentation file for the
product, which includes: |
| |
General description
of product and intended use |
| |
Environmental
assessment studies used by manufacturer in evaluating, documenting
and determining product design solutions |
| |
Ecological profile
(if required by implementing measure) |
| |
Product design
specifications related to the environmental design aspects specified
in the implementing measure |
| |
Harmonized
standards used |
| |
Description of
solutions used where harmonized standards were not applied (or not
available) |
| |
Information for
other parties about how the product should be handled, used or
recycled per Annex I, Part 1 |
| |
Product
measurements related to ecodesign requirements |
|
Additional
requirements for internal design control: |
| |
Manufacturer must
take all measures necessary to ensure that the product is
manufactured in compliance with design specifications |
| |
Manufacturer or
authorized representative must keep all relevant documents for 10
years |
|
The management
system (Annex V) is centered on the implementation of an
environmental product performance policy
(with written procedures and instructions) which includes: |
| |
Environmental
product performance objectives and indictors |
| |
Procedures for
establishing ecological profile of product |
| |
Consideration of
technological options and economic requirements |
| |
Design control and
verification techniques |
| |
Processes and
systematic measures used when designing product |
| |
Checks and tests
after manufacture to verify product compliance |
| |
Procedures to
investigate nonconformity and take corrective action |
| |
Organizational
structure/responsibilities/authorities and allocation of resources
to ensure implementation |
| |
Documentation
needed to demonstrate product conformity (same list as for
"technical documentation file" in Annex IV) |
| |
Procedures for
controlling all documentation and keeping it up-to-date |
|
Additional
requirements for the management system: |
| |
Manufacturer must
take all measures necessary to ensure that the product is
manufactured in compliance with design specifications |
| |
Manufacturer must
conduct full internal audit of the management system every three
years |
| |
Manufacturer or
authorized representative must keep all relevant documents for 10
years |
|
Manufacturers are
presumed to comply with the management system if they have
implemented one of the following: |
| |
EMAS registration per Regulation
(EC) 761/2001 |
| |
Harmonized
standards (such as ISO 14001) for
management systems that include the product design function |
