Ecodesign

Ecodesign

Policy

At the global level, the Marrakech Process aims “to support the elaboration of a 10-Year Framework of Programs (10 YFP) on sustainable consumption and production” coordinating global efforts on greener production among other efforts (United Nations, 2008).

At European Union level, multiple Directives with significant impacts on product design have been implemented, coordinated as part of the Sustainable Development Strategy (SDS). The overarching principles of the SDS are to take a life-cycle perspective on product impacts, to support eco-design to reduce these impacts, and support and stimulate demand for better performing products (Nash, 2009: 496). The Strategy focuses on targets in key areas, not just environmental, including climate change, sustainable transport, sustainable consumption and production, and conservation of natural resources, with a global as well as EU element (EurActiv, 2007). Greenhouse gas emissions are a central focus of European policy development. The requirements of policies at EU and UK level to reduce greenhouse gas emissions are likely to have increasing implications for product design.

The revised EU Waste Framework Directive (WFD) provides overarching coordination of Directives controlling waste arisings and treatment, and sets environmental objectives, a clear hierarchy for waste treatment options, beginning with minimisation, and recycling targets (leading up to recycling of 50% of household waste and 70% of C&D waste by 2020) (Council of the European Union, 2008). More information on the WFD can be found in the consultation on the National Waste Management Plan for Scotland.

The SDS principles are also enacted for product design through the Integrated Product Policy. This seeks to minimise the environmental impacts of products through integrating environmental considerations into all stages of a product’s life cycle, covering design, materials sourcing, manufacture, marketing, disposal and so on (Europa, 2008). The IPP includes a “toolbox” of policy interventions to address this goal. A mixture of Directives, regulations and voluntary agreements have been implemented:

to strengthen and expand the scope of ecolabels to cover more products with more stringent criteria to enable informed consumer choices
to directly require certain minimum product standards regarding energy and resource efficiency
to restrict and ban certain materials from use, and
to use Extended Producer Responsibility instruments to make producers responsible for the costs of waste arisings, to provide incentives to reduce these and to fund best practice waste management.

Green Public Procurement is also being encouraged, with the development of minimum GPP standards and standardised criteria and tools being developed to aid GPP. Finally, standard tools are being developed to assess product performance and market penetration to monitor progress (Nash, 2009: 497). More detail is provided in the sections below.

Ecolabelling

The EU ecolabel, or flower mark, is a voluntary labelling scheme for products that meet certain environmental standards, set for each product group. Current proposals aim to modify the labelling criteria, to make it less bureaucratic and costly to use the label, and in general to prevent its use on products which contain hazardous chemicals. The possibility of extending the label to food and drink products is also being considered ( ENDS Europe, 2009e, European Parliament, 2009). The Energy Labelling Directive meanwhile requires A-G energy efficiency indicator labels to be added to various energy-using products such as dishwashers, fridges, washing machines, and other white goods (Aichinger, 2008).

International standard ISO 14024 attempts to define standard approaches to the development of environmental criteria for the ecolabelling of products to increase harmonisation worldwide. The Global Ecolabelling Network also works to share and develop best practice ecolabelling and promote the use of ecolabels, and has governmental members across five continents (Global Ecolabelling Network, 2008).

Multiple national ecolabelling schemes also exist, such as the Scandinavian “Nordic Swan”, the German “Blue Angel” and the US “Energy Star” (Courville, 2002).

Product design EU Directives, Regulations and Initiatives

The EcoDesign Requirements for Energy Using Products (EuP) Directive, 2005/32/EC, requires industry to develop self-regulated standards for the energy efficiency of products on a product by product basis, for those with significant levels of impact or market sales. If they do not agree significant standards the EU itself regulates the market (Aichinger, 2008). Directives 92/42/EEC, 96/57/EC and 2000/55/EC also cover energy efficiency requirements for boilers, household refrigerators/freezers, and fluorescent lighting. Compliance must be certified by the manufacturer or, for products imported from outside the EU, by the importer. The requirements do not allow individual Member States to stipulate greater ecodesign requirements than those at the EU level (EurActiv, 2009b). This is intended to maintain harmony across the single market (ibid.), but also means Scottish Government cannot act unilaterally in this area.

A proposal to extend the EuP Directive suggested extending the Directive to cover products which affect energy use, comprising “windows, construction products, insulation materials, detergents, and water using products such as shower heads and taps”. This would also include increased focus on the life cycle impacts of such products, not just the energy efficiency of their operation ( ENDS Europe, 2009a). Meanwhile the energy labels are being modified to introduce new A-20% and A-40% categories for products 20% and 40% more efficient than A-rated models, replacing the current A+ and A++ categories. Leading up to 2014 a range of increasingly stringent minimum energy efficiency requirements will be introduced, in many product areas meaning that only those achieving the A-20% or higher rating will eventually be allowed to be sold across the EU ( ENDS Europe, 2009d).

The revised Integrated Pollution Prevention and Control Directive, 2008/1/EC, aims to control emissions to air, water and soil of various pollutants from major industrial installations (Europa, 2008b).

Directive 2003/87/EC on greenhouse gas emissions trading affects large greenhouse gas emitting installations. These are likely to be supplying business rather than the public, but the Directive still has implications for the design of their products and manufacturing processes.

A Regulation on CO 2 emissions from cars sets targets for the EU fleet average emissions levels to be 130 grams per kilometre by 2015, with interim targets leading up to that and fines on manufacturers failing to achieve their contribution to the target. The longer-term target is 95 g/km by 2020.

In the area of construction, proposals for a revision of the 2002 Energy Performance of Buildings Directive include seven instruments for promoting energy efficiency, including VAT reductions on green goods and services, of which Member States are expected to implement at least two ( ENDS Europe, 2009c).

There is also European-level funding available to support business development and commercialisation of innovative green products. The “Eco-innovation” funding scheme seeks to allocate €200 million of funds between 2008 and 2013 to “support innovative products, services and technologies that can make a better use of our natural resources and reduce Europe’s ecological footprint”. This is part of the wider European Environmental Technology Action Plan ( ETAP) (Europa, 2009).

Hazardous materials Directives and Regulations

These comprise the Restriction of Hazardous Substances ( RoHS) Directive, REACH (Registration, Evaluation and Authorisation of Chemicals) Regulation, and the Marketing and Use of Certain Dangerous Substances ( MUCDS) Directive.

The RoHS Directive effectively bans certain hazardous substances from use, while REACH imposes requirements to report use of a range of chemicals used in quantities of more than 1 tonne per year to the new European Chemicals Agency, and to demonstrate that they are being used safely. Chemicals of particular concern are likely to be further restricted and eventually banned from use or import. The MUCDS Directive bans certain other materials from use. Regulation No. 2037/2000 also bans ozone-depleting substances (Environ UK, 2009a). The Directives and Regulations impose significant extra bureaucracy and costs on the use of these materials, providing strong incentives to business to avoid their use.

End-of-life Directives

The End-of-Life Vehicles Directive sets targets for the recycling of cars of 85%, rising to 95% by 2015, for each Member State, with 5% of this permissible as energy recovery. Individuals should also be able to return vehicles free of charge for recycling (OECD, 2006a: 35).

The Waste Electrical and Electronic Equipment (WEEE) Directive requires producers of such products (or for certain business users, the final user) to pay for the collection and recycling of the products on disposal. Additionally, they must also fund such collection and recycling of WEEE that was produced before the Directive came into force, regardless of the manufacturer of it – either the producer if the product they sell replaces the old one, or else the end business user, must fund this (Environ UK, 2009b).

The Batteries Directive includes design and labelling requirements for batteries, such that they can be easily removed from products, and are accompanied by instructions for doing this, and information on the type of battery. There is an exclusion for products where “a permanent connection with the battery is required in order to ensure continuity of power supply for safety, performance, medical, or data integrity reasons.” (Environ UK, 2009a).
The Product Warranty Directive, 1999/44/EC, implemented in the UK by The Sale and Supply of Goods to Consumers Regulations 2002, provides consumers with a legal minimum product warrantee of 2 years for new products, or 1 year for used products (unless sold by a private individual), introducing an incentive to design and sell products with a minimum level of robustness and reliability.

Demand-side action

Green Public Procurement

The European Union strongly encourages the use of Green Public Procurement ( GPP) to realise direct environmental benefits and to drive green markets, and has a substantial online resource to aid public sector procurers with this, including simple tools and information to use to develop and stipulate green criteria.

Several EU countries, including the UK, already achieve substantial percentages of GPP. A report by PricewaterhouseCoopers, Significant and Ecofys (2009) indicates that the UK procures 75% green products by percentage of total procurement value, and 59% by proportion of total contracts awarded (ibid: 35) 11. This has led to an overall 38% reduction in lifetime CO 2 emissions compared to non-green public procurement of the same product categories, primarily arising from construction and electricity procurement, with a concurrent 5.7% reduction in total costs (considering Life Cycle Costing). In most product categories, there were negligible cost differences, while there were savings of 7.11% in construction, 3.44% in cleaning services, and increased costs of 12.88% for paper (ibid: 58, 67). There remains substantial scope to increase GPP, and to increase the proportion of GPP that are assessed by more stringent criteria.

Legally, GPP is allowable under EU procurement Directives, but must follow certain guidelines. Requirements for energy performance, materials sourcing and production methods of the goods and services purchased are all allowable, while wider stipulations about the operating practices of the tenderers are not ( e.g. requiring the use of recycled paper in the tenderer’s offices). Fuller details are available in the European Commission guidelines “Buying Green!” (European Commission, 2004)

European Union countries and regions have developed tools to enable public bodies to implement GPP more easily, such as that developed by Value Wales (Procurement) or the Belgian waste agency OVAM’s internet tool ( HLSTC, 2008: 64).

Car scrapping

Across the EU, many countries now have incentives to retire old cars and purchase newer models with higher fuel efficiency, although this is partly to combat falling sales during the current recession. Acea, the car industry association, supports this approach for the purposes of boosting car sales, while the UKCBI supports it for carbon reduction purposes ( ENDS Europe, 2009f, CBI, 2009). The UK scheme, introduced in the previous Budget, provides a £2,000 incentive to buy a new car if a vehicle over 10 years old is traded in. However, the environmental value of such schemes is entirely dependent on the relative environmental performance of the old and new cars.

Voluntary agreements

The European Commission ( ENDS Europe, 2009b) and the HLSTC (2008: 55-56) both support and encourage voluntary agreements with the retail sector to “choice edit”. In essence, such agreements phase out selling of poorly performing products even in the absence of regulations. Removing poorly performing products reduces the potential confusion arising from a mass of competing eco-labels, or missing information, and delivers environmental benefits without the need for consumers to consciously select green products. Explicit visible support for green products by retailers also sends a signal both to households and to producers, raising awareness of the importance of green criteria in product selection and development, of the availability of such products, and through facilitating access to them, sending a signal that they are mainstream and contributing to development of a new social norm.

Product design policy in some countries

Some countries are engaged in policy initiatives to promote ecodesign and the market for greener products, including those reducing waste over the life cycle.

In Belgium, OVAM, the public waste agency, provides free expert audits of SMEs to assess their waste costs and use benchmarking techniques to compare against best practice ( HLSTC, 2008: 64). OVAM’s Inspiration database provides a best practice resource, with information on over 250 companies and their waste minimisation practices (ibid).

Schemes exist in various places to encourage households to purchase newer energy efficient models of energy using products to replace their older inefficient models. In certain situations this leads to substantial carbon savings that more than compensate for the impacts of retiring a product before it has ceased to work. The car scrapping scheme described above could in principle achieve this for cars. The Los Angeles Department for Water and Power meanwhile will give low-income households a new energy efficient fridge for free when they hand in their old inefficient one for recycling, or partially pay for one for higher income households (Los Angeles Times, 22/11/07).

“The program hopes to remove 50,000 old, inefficient refrigerators off the market and save the City $12 million a year in fuel costs and reduce CO 2 greenhouse gas emissions, equivalent of removing 40,000 cars off of the road.” ( LADWP, 2009).

The programme will also provide rebates for an “air conditioner, washing machine, windows, central heat pumps, or pool pumps and motors”.
An alternative scheme in Germany provides a website that allows users to check the energy and money savings of upgrading their old fridge to a new one, comparing between thousands of different products ( kuehlcheck.sec2-server.de). The service also covers home heating and central heating pumps (klima-sucht-schutz.de/english.html).

Policy problems

HLSTC (2008: 48-50) notes the problem that the requirements of multiple product policies can conflict with one another, noting examples of hazardous materials removal from electronics increasing energy use, and car safety requirements increasing weight. For waste specifically, they suggest that a focus purely on weight-based landfill-diversion targets can be limiting, and should perhaps include volume and toxicity measures. While this issue should be considered, it is inevitable that multiple disparate environmental and other goals will at times conflict. And many of the EU targets on waste, which Scotland and the UK must meet, are weight-based.

Indicating on the price label the cost of end-of-life processing at the point of sale can also incentivise design changes to reduce this element ( OECD, 2006a, EPEPF, 2008).

Identifying the impacts of a particular policy on product design can be difficult ( OECD, 2006a). It can be problematic both to obtain information about product design changes that have taken place, and to then attribute these changes as resulting from specific policies (ibid). This is however a general issue with evaluating the outcomes of policy changes.

More fundamentally, policies which realise waste reductions for business and individual products may have little or no effect on overall waste arisings and total environmental impacts. Where waste minimisation also saves business money, and this is passed on to the consumer through reduced unit prices, the so-called “rebound effect” could well see any environmental gains lost through increased consumption, as the consumer uses the money saved to buy more goods. In this way, resource efficiency does not necessarily translate into reductions in total resource use or waste arisings from the economy.

Ecodesign policy levers also have to be designed with consideration of other factors beyond environmental benefits. Barriers to policy include:

  • Legal restrictions e.g.EU common market and competition rules.
  • Limits to ecodesign knowledge e.g. life cycle assessment tools, materials information, techniques and technologies for implementing better ecodesign.
  • Intellectual property such as patents and copyright – these can restrict knowledge transfer and the spread of best practice.
  • Path dependency – business and industries have invested in certain capital and approaches which limit the ability to make changes, or increase the costs of doing so.
  • Company culture, habit and lack of awareness may introduce resistance to change even in the absence of significant costs.

Policy should also be aware of the potential impacts of interventions on, for example job creation and job security, and the competitiveness policy. The latter could push product design elsewhere, or set an European region up as a world leader.
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