Summary of the EuP directive by RSJ Technical Consulting

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What is EuP?

EuP is short for Energy-using Products

Directive 2005/32/EC - EuP

On July 6, 2005, the European Parliament issued a directive "establishing a framework for the setting of ecodesign requirements for energy-using products."

The initial focus will be on electric motor systems, HVAC equipment, water heaters, domestic appliances, consumer electronics, office equipment, and lighting because these products have been identified as having high potential for a cost-effective reduction in greenhouse gasses. Over time, implementation will expand to include all energy-using products, defined as any product that is dependent on energy input (electricity, fossil fuels, and renewable energy sources) to work as intended. However, all means of transportation are specifically excluded from the scope of the directive.

Ecodesign reflects the philosophy that the most cost-effective way to reduce a product's negative impact on the environment is to consider such issues up-front during the design phase. This is because the amount of pollution caused over a product's life is largely set by decisions made at design.
	Evaluation must include the entire product life cycle: from raw material selection and manufacturing process to packaging, transport, and distribution to installation, maintenance and use, and finally to end-of-life which includes recycling, reuse, and final disposal.
	Ecodesign must balance environmental considerations with technical, functional and economic considerations.
	Relevant environmental considerations are defined to include use of materials hazardous to health or the environment; consumption of materials, energy and water; potential for recovery of materials and energy; use of recycled materials and used components; waste materials produced; emissions to air, water or soil; consumables needed for proper use and maintenance; pollution from noise, vibration, radiation and electromagnetic fields; extension of product lifetime; ease of reuse and recycling at end-of-life, including complexity and time needed for disassembly.
	An EuP's ecological profile consists of the measurable physical inputs and outputs (such as materials, emissions and waste) over the product's entire life cycle.

The EuP directive provides the legislative criteria and framework for the move to life cycle ecodesign. The implementing measures that will determine the specific requirements for each type of EuP are yet to be developed.
	Per the directive, implementing measures may not result in a significant negative impact on the functionality, affordability or life cycle of the product; on the industry's competitiveness; or on health, safety and the environment. Proprietary technology and excessive administrative burden may not be imposed on manufacturers. Requirements may be phased-in, when necessary, to accommodate product development life cycles.
	Implementing measures are to be developed through consultation with stakeholders. Representatives from member states; manufacturers, including small and medium-sized enterprises (SMEs) and craft industries; trade unions, traders, retailers and importers; environmental protection groups and consumer organizations are to be included.
	Self-regulation measures should be considered and given priority when voluntary measures by the industry would provide faster progress by allowing manufacturers to implement ecodesign standards more quickly and cost-effectively than if mandatory measures were imposed. Self-regulation also provides flexibility to respond to technological options and market developments. Should market forces fail to develop as anticipated, implementing measures would then be imposed.
	Self-regulation is contingent upon harmonized standards being developed by a recognized standards body and published in the Official Journal of the European Union. Harmonized standards are voluntary industry standards that provide technical specifications, measuring and testing methods, ecological profiles, etc. for conformity with the EuP directive.
	There is a presumption of conformity for products which have been developed according to published harmonized standards.
	There is a presumption of conformity for products which have received the Community eco-label (EC Regulation No 1980/2000).

Conforming EuP products must have:
	Declaration of conformity which includes the name and address of the manufacturer; an unambiguous description of the product such as the model number; the applicable implementing measure; the harmonized standards or other technical specifications met; and the identification and signature of the person empowered to bind the manufacturer. Declarations may be issued for individual products or for part families and must be kept on file by the manufacturer.
	CE marking (at least 5 mm high) on the product or, if that is not possible, affixed to packaging and accompanying documents.
	Information about the manufacturing process -- on the product itself if possible.
	Information about environmental characteristics and performance that would allow consumers to compare products -- on the product itself if possible.
	Consumer information about the product's installation, use and maintenance -- on the product itself if possible.
	End-of-life information for treatment facilities concerning disassembly, recycling, or disposal -- on the product itself if possible.

Manufacturers may choose one of two types of conformity assessment used to demonstrate compliance with an implementing measure. The documentation required for either assessment must be kept for 10 years after the last manufacture of a product.

Internal Design Control:
	A technical documentation file which includes the description and intended use of the EuP; its ecological profile; environmental assessment studies by the manufacturer or published in the literature; the solutions adopted to meet the required standards; and quantifiable measurements that prove the EuP meets all applicable standards.
	Production measures to ensure that the manufactured product does in fact meet its design specifications.

Management System:
	A program of systematic procedures for improving the overall environmental performance of an EuP including: environmental performance objectives and indicators; design control and verification techniques; methods for establishing the ecological profile; management organizational structure and resources; employee responsibilities and authorities; control of all required documents and declarations; post-manufacture tests and checks to verify product compliance; procedures to investigate and respond to non-conformity; verification that the management system is working as planned; and a full internal audit of the management system at least every three years.
	Written procedures and instructions that thoroughly document the management system.
	A technical documentation file which includes the description and intended use of the EuP; its ecological profile; environmental assessment studies by the manufacturer or published in the literature; the solutions adopted to meet the required standards; and quantifiable measurements that prove the EuP meets all applicable standards.
	Presumption of compliance for manufacturers registered with EMAS (EC Regulation No 761/2001) provided that the design function is included in the registration.
	Presumption of compliance for manufacturers with management systems (including product design) implemented in accordance with published harmonized standards.

This summary of the EuP Directive is designed to provide you with an accurate, easy-to-understand overview of the topic. However:
ê	We have not attempted to cover the implementation issues that need to be addressed at your company or in your supply chain. For this type of assistance, please email or call us at 972-679-8996 to inquire about our services.
ê	This summary does not constitute legal advice. The actual standard in the original language should be reviewed and used for all business, legal, and product compliance purposes.

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