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Energy Using Products Directive (EuP) Print E-mail

Overview of Legislation
The European Union has implemented an ambitious energy program (EuP) to address the security of its energy supply, as well as energy-related health and environmental issues. On a more tactical level, the EU’s Energy Commissioner – Andris Piebalgs – introduced on October 19, 2006, his plan to achieve a 20% reduction in energy usage by 2020. This Energy Efficiency Action Plan will be phased in during the next 6 years. If successful, it will contribute to the EU’s Kyoto Protocol targets and save more than 100 billion Euros annually.

The Plan identifies more than 75 actions in 10 priority areas, including (related to EuP) new energy performance standards for different product groups such as boilers, copiers, TVs and lighting. One aspect of this energy program targets both consumer and business purchasing behavior: namely, the use of energy-related labels – like the EU’s Eco-Flower label and Energy Star label – that raise awareness of a product’s energy usage. The other aspect of the energy program targets manufacturers by requiring and/or incenting them to reduce the environmental impacts associated with all stages of the product life cycle for their energy-using products.

The EU-wide Directive driving this aspect of the energy program is titled DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a framework for the setting of Eco-design requirements for Energy-using Products and amending Council Directive 92/42/EEC.EuP targets the negative environmental impacts of energy-using products that occur throughout the product life-cycle from the extraction of raw materials out of the earth and/or the use of recyclable materials all the way through manufacture, distribution, use and disposal. The word “framework” in the title refers to the fact that EuP sets a framework for fast-tracking future implementing legislation. EuP itself, as it currently stands, does not require companies to do anything, but provides the context for implementing legislation that will set specific requirements. The phrase “setting of Eco-design requirements” speaks directly to the idea that this legislation is ultimately about impacting the important design stage of the product life-cycle. “Energy-using Products” indicates that the Energy-using Products (EuP) Directive goes beyond the EE industries in that it addresses all non-transportation products that use energy. As such, it would include products like gasoline lawn motors that are not EE products. EuP also covers all types of energy sources.

Key Dates
The following key dates apply to EuP:
 -July 2005: EuP was adopted
 -March 31, 2006: Applications for 50-member Consultation Forum to assist the European Commission closed
 -August 11, 2007: Final date for EU member states to transpose EuP into national law

Initial Focus
Historically, most EPR Directives address only (or primarily) one environmental aspect. For instance, RoHS addresses toxicity and WEEE addresses recycleability. By design, EuP will address multiple environmental aspects over time via successive implementing legislation. The first environmental aspect to be addressed by EuP is energy efficiency, because energy efficiency is the fastest and most affordable way to increase the security of the energy supply while simultaneously reducing energy-related issues like climate change. In addressing energy efficiency via EuP, the EU has decided to focus on a relatively limited portion of the EE industry – narrower than the 10 product categories covered by WEEE and the 8 categories covered by RoHS. More specifically, EuP will target approximately a dozen product groups that meet the following three criteria: 1. High-volume: >200,000 units are placed annually on the EU market;  2. High negative impact in regard to energy; 3. Significant room for improvement in energy efficiency at a reasonable cost.

Current Requirements
EuP energy efficiency requirements, which are enforceable starting January 2009, require that standby electricity consumption be cut by almost 75% by 2020. By 2010, the standby power consumption of equipment in any condition has to be less than 1 Watt if the equipment is providing a reactivation function or 2 Watts if the equipment is providing a status/information function. These values will be lowered in 2013 to 0.5 Watt and 1 Watt respectively.
Companies whose products fall within the scope of EuP will face several data collection challenges.

Companies will be required to collect and report upon various energy metrics related to the energy utilization of particular product groups.

Most importantly, EuP introduces additional requirements that are potentially far more challenging than RoHS, REACH, WEEE or any other current legislation. Companies will be required to provide ecological profiles of their products, which will require information on material and energy inputs and outputs. Ecological profiles must include information specific to the environmental aspects for each stage of the Eco Lifecycle starting with the extraction of raw materials from the earth and/or the use of recycled materials; continuing through the processing, manufacturing, distribution and use stages; ending with the disposal stage.