A new focus on eco-design aims to tackle unrecyclable electrical products
The environmental impact of our love for electricals is something that has come under increasing scrutiny in recent years.
Rapid innovation in technology over the last 20 years has brought about an astonishing transformation of our society, but we now replace our products at a rate which has made e-waste the world’s fastest growing waste stream.
New waste, new rules
To address this issue, manufacturers of digital devices and electricals can expect to see new rules in the coming years to encourage them to design products that are more easily repairable, last longer and are easier to recycle at the end of life.
The climate crisis is also leading to greater scrutiny of our material consumption. Work of academics such as Professor Julian Allwood at the University of Cambridge has made clear that our current consumption of metals and minerals is incompatible with long-term carbon neutrality targets. The vision of a circular economy – one where resources are kept in use as long as possible and circulated back at the end of life – has gained traction both within the European institutions and UK government.
The right to repair
Further, a growing body of consumers are increasingly demanding that they have products that are more easily repairable. The “Right to Repair” movement, which began in the States, is garnering growing support across Europe. Here consumers maintain it is their right as owners of a product to repair and modify them.
We are already seeing some manufacturers respond to these trends. The durability of digital devices has lengthened. Second-hand marketplaces for electronics are healthy and thousands of products are being refurbished and remanufactured every year, for example by Circular Computing, HPE or Amazon Renew. Some manufacturers now flaunt the scores their products have achieved on ifixit, a wiki-based site that teaches people how to fix almost anything. It rates devices according to how easy it is to repair, see here for laptops for example. We are also seeing connected devices being used to support predicted maintenance to support others in repairing and maintaining capital equipment.
Regulators want to make this the norm. There are two key regulatory interventions that we are expecting which will mainstream eco-design in electricals.
The first is through eco-design legislation. This sets out product-specific design requirements which, if unmet, means you can no longer sell the product in Europe. Typically, eco-design in Europe has targeted the energy consumption of products but the Commission is now systematically considering resource efficiency.
On 1 October 2019, 10 new eco-design measures – covering products including servers, televisions, washing machines and fridges – were adopted and contained for the first time measures which included requirements for recyclability and repairability. Common rules included: ensuring spare parts are available for seven to ten years; conditions that repairs must be possible using commonly available tools and equipment and that repair information must be made available to professional repairers. In a few years, these will be reviewed to include more detailed requirements.
New measures were recently announced as part of the European Commission’s EU Green Deal and its updated Circular Economy Action Plan, which included a commitment to establish a new “right to repair” in EU Consumer Law.
Modulating end of life fees
The second intervention is through “end of life” fees. Electricals and electronics are already covered by producer responsibility legislation, which means that manufacturers of these products pay for their collection and recycling at the end of life. In future, these costs will be modulated from product to product to reflect how easily products can be upgraded, repaired and recycled.
Potentially, these will also reflect how much recycled content is contained in products too. While the exact details of how these regulations will be applied in practice are still being worked through, it is clear that those designing for the environment can expect to see lighter fees in future years.
The future is eco-design
In the UK, there is no sign that the Government wants to diverge from this policy direction. In its Clean Growth Strategy, Industrial Strategy and 25 Year Environment Plan, the desire to encourage producers to design “better products” has been a consistent theme. The draft Environment Bill provides Government with new powers to apply eco-design measures and to mandate the provision of information to end users regarding the performance of products.
There are commitments in the Resources and Waste Strategy to support remanufacturing and to explore extended product warranties. Eco-modulated fees have also been outlined in draft plans for packaging. We can expect similar when rules around the UK’s waste electricals are reviewed this year.
Getting it right
There are some practical issues that remain to be resolved. The Product Liability Directive holds producers liable for malfunctioning products. If third parties are to have a greater role in repairing products, who holds the liability if something goes wrong? This is complicated by a market in counterfeit spare parts, an issue raised by NGOs such as Electrical Safety First. And how would we deal with product recall if components are later discovered to be a risk? It is clear we need to do some more thinking about how we align the competing priorities of a circular economy and product safety.
We also have incredibly bad systems data. The repair market is largely unregulated. We have really no idea of the true scale of repairs in the UK. If we do not know this, how can we be sure that these policies are actually working? We can design all the repairability measures we like, but if consumers are not repairing products then it will have been in vain.
It is clear then that we still have some way still to go to become a nation that routinely upgrades, fixes and mends. However, as government, consumer and business priorities continue to move towards a more sustainable economy, it is clear that we will be encouraged to do just that in the years to come.
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