As other European countries have announced their plans to introduce similar measures, APPLiA Energy and Environment Policy Manager Giulia Zilla discussed how fragmented implementation of product regulations at national level would impact the ongoing work at the EU level and the functioning of the Single Market.
Since January 1st 2021, France is the first country in Europe to have implemented a repairability index on 5 categories of electronic devices. The objective of the index is to encourage consumers to choose more repairable products, and manufacturers to improve the repairability of their products.
At its core, the repairability index is a score ranging from 0 to 10 informing consumers about how repairable a product is at the point of purchase.
While there is currently no European wide repairability index, one does exist in France, where it applies to a range of products including washing machines, dishwashers, vacuum cleaners, smartphones, TVs, high-pressure cleaners, and lawn mowers.
Concretely, what does it mean for manufacturers?
Manufacturers are responsible for calculating and communicating the repairability index of the products in scope to retailers prior to being placed on the market. They are required to provide retailers with the reparability index logo and its corresponding parameters, electronically and at no cost, for each model.“A logo is then placed either on the package or next to it, so that consumers can consult before purchasing,” explained Zilla.
While there is currently no European repairability index, there are provisions at the design stage to improve repairability on a range of products. The Joint Research Centre has carried out a study on the repairability scoring system, while the European Commission is currently assessing its applicability on a product-by-product basis.France was the first country to introduce the repairability index at the national level in 2021, but it is already looking to introduce a durability index that would integrate the current repairability index and come into effect in 2024. “Other member states, such as Belgium, are also preparing draft laws based on the French model, set to come into force by the end of 2024,” pointed Zilla on the current state of play.
The implementation of these measures at the national level without an EU-wide regulation places a burden on both manufacturers and consumers.
If we take the case of France, the upcoming addition of a durability index would make the introduction of a repairability index at European level “obsolete and misleading” for consumers who would be faced at the point of sale with two different indexes.
To ensure a functioning single market and to avoid confusion among consumers, “European industry needs Member States to work hand in hand with the European Commission to implement product regulation,” concluded Zilla.
New requirements should always be based on detailed impact assessments that take into account the whole lifecycle of the product, considering interdependencies between all different aspects that constitute it, from safety to energy efficiency among others.
A European common ground should be established for the repairability scoring system that is based on the JRC methodology and the relevant standards, as applied on a product-by-product basis.