Ceced comments about new Ecodesign proposals

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illu[1]European Ceced (The European Committee of Domestic Equipment Manufacturers ) has always been supportive of product specific regulation under the framework of the Energy Label and Ecodesign Directives which has led to an enormous increase of energy efficiency in the household appliance offer over the last 20 years.
However, Ceced has major concerns with the current developments introducing component specific regulation under the Ecodesign Framework Directive.
“The proposal for ecodesign requirements for electronic displays – a press release by the Committee explains –  is only example which is likely to impose major administrative burden on our industry without any tangible effect on the environment or benefit for the consumer.
We particularly highlight the provisions of Annex II point 6 on information requirements which relate to specific technical parameters, material use in the design phase and to material recovery in the end-of-life phase of a single component of some household appliances”.
Ceced is of the opinion that the appliances which are placed on the market by its members are already regulated for those issues by ecodesign implementing measures, material regulation such as Reach and RoHS and by the Weee Directive.
While Ceced agrees that an analysis should be made investigating the need for information requirements regarding use of hazardous substances and documentation for recycling at the end-of-life, as well as on the recycling itself.  “We consider – they say from the Committee- that imposing new requirements under another framework other than the existing material and end-of-life legislation does not reflect a coherent legislative approach. Instead, Ceced proposes to conduct a more general and overarching approach based on standardization request”
The household appliance industry has always been a strong proponent of resource and material efficiency. We have continuously provided a significant contribution through designing and manufacturing innovative products that cut resource use, especially energy and water”.
Through the implementation of the Weee Directive, many investments by industry have increased end-of-life recycling that has impacted the potential for material recovery.
The Ceced position paper about this topic can be found on www.ceced.eu.