Author Archives: ECD_admin

France – Reparability Index Comes into Affect

On January 1, 2021, the France Anti-waste law came into effect along with requirements for certain products to display a repairability index. Impacted product types include:

  • Clothes Washers
  • Computer Monitors
  • Desktop Computers / Personal Computers
  • Electric Lawnmowers
  • Electronic Displays [Other Names: Video display devices]
  • Laptop / Notebook Computers
  • Mobile / Cell Phones
  • Televisions
  • Washer / Dryers
  • Workstations

The text of the French regulation on repairability of EEE is available on the France official journal[1].

[1] France repairability regulation,

EU – SCIP Database is Open for Business – Who Submits?

On October 28, 2020, ECHA opened the EU SCIP database to submissions.

Various questions on sales and distribution scenarios are emerging as at who is required to submit notifications into the SCIP database, and how to best support downstream economic actors. These scenarios are discussed below.

In the ECHA SCIP FAQ on “Which suppliers of articles have the obligation to provide information to ECHA?”, ECHA states:

The following suppliers of articles need to provide information to ECHA:

– EU producers and assemblers,

– EU importers,

– EU distributors of articles and other actors who place articles on the market.

Retailers1 and other supply chain actors supplying articles directly to consumers are not covered by the obligation to provide information to ECHA.


1 Excluding retailers who are importers and/or producers.

 When the Manufacturer is the EU Importer

The obligation to submit SCIP notifications for manufacturers is clear for those who manufacture in the EU or have their own EU import subsidiaries – these organizations are able to use their own legal entity to  submit their product information into SCIP. This in-turn makes it easy for distributers to do a simplified SCIP notification (SSN) to meet their regulatory obligations.

When the Manufacturer is not the EU Importer

The business implications are less clear for foreign manufacturers who do not have direct control of import into the EU.  A downstream actor will need to do the detailed SCIP submission for the product. This will normally be the EU importer if they are an EU entity.

ECHA has already started providing guidance to distributors that they can use the simplified SCIP notification (SSN) process to meet their submission obligations (unless they are also the importer). To use the SSN process, the distributor needs to obtain the SCIP number from their upstream partner – the manufacturer or importer – and then include this number in their SSN upload into the SCIP data. They do not need to know any technical details about the product or the SVHC contents.  This is possible because the full submission will already be in SCIP by the time the product gets to them.

Note 1: if the distributor is also the importer and the product is not already in SCIP, the distributor will need to make the detailed SCIP submission.

Note 2: if the distributor is a retailer who sells directly to consumers and is not the importer, they are exempt from SCIP reporting. This assumes that an upstream EU importer has already made the SCIP submission.

Import of components and subassemblies into the EU

Another scenario with some uncertainty is when a component or subassembly is imported into the EU, especially when the integrator is the importer of record.  This scenario is not well addressed in the guidance documents.  In general, the SCIP obligation is triggered when a product is placed on the EU market. The evidence for the above position may be found in the ECHA SCIP FAQ on “Which suppliers of articles have the obligation to provide information to ECHA?”, states…

According to Article 3(33) of the REACH Regulation, the supplier of an article means ”any producer or importer of an article, any distributor or other actor in the supply chain who places an article on the market“.


Impact on EEE Manufacturers

We will need to see how this plays out in the EEE sector, including the level of awareness of importers and distributors to their SCIP legal obligations. The speed with which EU member states enforce the requirements may also be a factor.

Regardless of how this plays out, the product manufacturer is the entity with the Bill of Materials and SVHC information needed to create the SCIP dossier.  Importers and distributors will not have necessary technical information. Therefore, product manufacturers should be prepared to provide the necessary information – either as an IUCLID SCIP dossier or some other format that can then be compiled into a SCIP dossier.

EU – Sustainable Products Initiative

The European Commission has launched its “Sustainable Products Initiative” to revise the Ecodesign Directive and propose additional legislative products to make products more sustainable.  The Commission provided the following summary:

This initiative, which will revise the Ecodesign Directive and propose additional legislative measures as appropriate, aims to make products placed on the EU market more sustainable.

Consumers, the environment and the climate will benefit from products that are more durable, reusable, repairable, recyclable, and energy-efficient. The initiative will also address the presence of harmful chemicals in products such as:

  • electronics & ICT equipment
  • textiles
  • furniture
  • steel, cement & chemicals.

The initiative is also expected to consider:

  • Supply chain information requirements (possibly digital product passport)
  • Regulation of remanufacturing, recycling, and environmental footprints

An inception impact assessment with feedback from stakeholders during a public consultation is available on the europa website[1].

[1] EU sustainable product initiative,

EU – REACH Annex XIV Authorisation for Spare Parts and Repair

The European Commission has proposed an amendment to the REACH regulation to simplify and reduce the cost of authorisation requests when an Annex XIV substance is needed after the sunset date for the manufacturing of spare parts or for repair of products.

The proposed amendment and annex are available from the EU TBT notice[1].

[1] EU TBT database,

GEC/TUV – Sustainable Network Equipment Criteria

A full draft of criteria for the Sustainability of Network Equipment has been completed.  A public review of the criteria is currently underway until December 31, 2020.

The criteria were developed by the Sustainable network equipment technical committee led by the TÜV Rheinland certification body and the U.S. based Green Electronic Council (GEC).  It will be used for assessing the sustainability of network equipment under the GEC EPEAT ecolabel program and TÜV Rheinland’s Green Product Mark.

IEC 62321-2 – Update to Material Risks

IEC Technical Committee TC111 WG3 is updating the IEC 62321-2 “Determination of certain substances in electrotechnical products – Part 2: Disassembly, disjunction and mechanical sample preparation” standard.

The update includes a refresh of Annex B on the risk of RoHS substances being present in materials and parts used in EEE products. This is the only Internationally recognized guidance on risk of RoHS substances in EEE and is used by several EEE manufacturers in their compliance programs.  The revised draft Annex B will add material risk information for the four phthalate substances, and it updates the risk levels based on changes in the EEE supply chain over the past 15 years.

EU – Preparatory Study on Ecodesign and Energy Labelling

The European Commission launched a preparatory study earlier this year to assist in preparing the Ecodesign and Energy Labelling Working Plan for 2020-2024. The list of product categories and the new horizontal measures being considered may be useful information in anticipating upcoming requirements.

The Draft report on the task 2[1] identification of product groups and horizontal measures identifies:

Remaining product groups from working plan 2016-2019:

  • Uninterruptible Power Supplies
  • Professional laundry appliances
  • Professional dishwashers
  • Window products
  • Non-tertiary coffee machines
  • Not selected product groups

New product groups

  • Interconnected home audio and video
  • Small home / office networking equipment
  • Low temperature emitters
  • Air curtains
  • Small-scale cooking products
  • Unmanned aircraft (drones)
  • Water decalcifiers / softeners
  • Base stations and subsystems
  • Industrial sensors
  • Hair dryers
  • Tertiary hot beverage equipment incl. free-standing hot beverage vending machines
  • Greenhouse covers
  • Patio heaters

New horizontal measures

  • Lightweight design
  • Durability
  • Post consumer recycled content
  • Universal External Power Supplies
  • Universal batteries for battery-driven products
  • Ecological profile
  • Horizontal innovative solutions for improved market surveillance

[1] Ecodesign working plan task 2 report,

France – Repairability Index for Electronic Products

The French Ministry of Ecology is conducting a public consultation on several draft regulations for the calculation and display of a repairability index on select electrical and electronic products. The draft regulations will be implementing legislation for the France Anti-waste and Promotion of Circular Economy Law, 2020-105.

The requirements are being implemented in a hierarchical series of legislative instruments

The first set of product categories proposed for the repairability index include:

  • television sets,
  • smartphones,
  • laptop computers,
  • household front-load washing machines,
  • electric battery lawn mower,
  • robot electric law mower and
  • corded electric lawn mower.

Draft Decree on Repairability Index

The “Repairability Index of Electrical and Electronic Equipment, Draft Decree[1] provides the over-arching requirements and obligations. Once in effect, the decree provides definitions and will impose regulatory obligations on producer, importers, distributors, and sellers with regard to calculating and displaying the repairability index for select EEE products.

The draft decree emphasizes that the requirements apply regardless of whether a product is sold in stores or through distance selling (e.g. online sales). It also does not make any mention about the location of these organizations; suggesting the obligations are applicable whether the organization is in France or foreign.

Summary of specifications:

  • The repairability index is a score out of 10 and needs to be brought to the attention of the consumers when purchasing new equipment.
  • The repairability index is established by the producer or importer according to the format provided for in the relevant Order (based on product category).
  • The repairability index must be calculated for each product ‘model’ — whereby the product model is defined as “a version of a piece of equipment, all of the units of which share the same relevant technical characteristics for the purposes of calculating the repairability index.
  • The repairability index shall be communicated through the distribution chain free of charge.
  • The repairability index must be visibly displayed near the product on store shelves or within the presentation of the equipment and near the price when distance selling.

The repairability index is calculated based on an equal weighting of the following five parameters:

  1. the period of availability of technical documentation, instructions for use and maintenance instructions to producers, repairers and consumers;
  2. how easily the equipment may be disassembled: number of disassembly steps required for individual access to the spare parts, and characteristics of the required tools and the fastenings between the spare parts;
  3. the period of availability of the spare parts on the market and to the delivery times to producers, spare parts distributors, repairers and consumers;
  4. the ratio between the price of the parts sold by the manufacturer or importer and the price of the equipment sold by the manufacturer or importer, calculated according to the methods provided for in the relevant Order;
  5. criteria specific to the category of equipment.

The proposed Decree states that it will enter into force on January 1, 2021 and that as of January 1, 2024, a durability index is expected to supplement or replace the repairability index.

Display methods, signage and general parameters

The proposed “Order regarding the display methods, markings and general parameters for calculating the repairability index” (notification number 2020/0469/F – H00) specifies the display of the repairability index and provides general rules for the calculation of the index.

The repairability mark (on products or retail displays) includes a score out of 10 and a color-coded repair symbol (red (low) through green (high)) (Figure 1).  The draft order describes the details of the mark and its presentation.

Figure 1: graphical ‘repairability index’ mark







The proposed Order describes the parameters (criteria and sub-criteria) for calculating the repairability and provides a template .

The draft Order also provides a list of ‘common tools’ for the purpose of scoring sub-criteria 2.2 on ‘tools required’.

Two lists of spare parts have been defined and are used in criteria 2, 3, and 4.  The specific parts included on each list are specified in the product category specific order:

  • List 2 includes a maximum of three to five spare parts that most frequently break or break down.
  • List 1 includes other spare parts (max. of 10) that the equipment needs to be in good working order to function.

Product Category Specific criteria and rating systems

Specifications of criteria and sub-criteria for calculating the repairability index are provided in the product category specific orders. A sampling of the requirements for computer laptops and smartphones are provided below as indicative examples.

Computer laptops — proposed “Order of XXXX on the criteria, sub-criteria and scoring system for calculating and displaying the repairability index for laptop computers” specifies the details of each sub-criteria for laptop computers.

For the purpose of defining the scope of products that will need to display the repairability index, France is leveraging the scope of the EU regulation Commission Regulation (EU) No 617/2013 with regard to ecodesign requirements for computers and computer servers[1] and the associated definition of laptop computers.

  • Technical documentation, instructions for use and maintenance instructions, if available for five or more years, contribute points to the repairability index
  • List 2 spare parts that are mostly likely to fail and should be readily available to repairers and consumers are: mass storage devices (HDD, SDD), display, battery, power connectors and charger.
  • List 1: Other spare parts that should be made available are: Motherboard, RAM, fans, keyboard, and connector ports
  • The Criterion 5 (product specific criterion) requirements are focused on software and firmware updates, remote assistance and resetting software.

Smart Phones — Draft “Order of XXXX on the criteria, sub-criteria and scoring system for calculating and displaying the repairability index for smartphones”

Criterion No1 – Documentation

1.1 Producer’s commitment on the duration (technical documents and instructions): Disassembly diagram, Wiring and connection diagram, Error and diagnostic codes, etc.

(producer, repairers, consumers)


Spare parts for criteria 2, 3, and 4:

  • List 2 parts: Battery, display device, front camera, back camera, charger
  • List 1 parts: Charging connector, Connectors, motherboard, buttons, microphone, speaker

Criterion No2 – Disassembly and access, tools and fasteners

*ND/NA = not removable or not individually accessible

2.1 Ease of disassembling the parts (number of steps to access): 16 and more, 11-15, 6-10, 1-5

2.2 Tools required to disassemble parts: ND/NA, Proprietary tools, Specific tools, Tool-free, common tools

2.3 Characteristics of the fasteners: Neither removable nor reusable, Removable, non-reusable, Removable and reusable

Criterion No3 – Availability of spare parts

Based on years of availability and column (producer, spare parts distributor, repairers, consumers)

3.1 and 3.2 Producer’s commitment on the period of availability (list 1 and list 2 parts)

3.3 and 3.4 Delivery time for parts (list 2 and list 1)

Criterion No4 – Price of spare parts

4.1 Ratio of the price of list 2 parts compared with the price of the new product

Criterion No5 – Specific criterion

5.1 Information on type of update: Corrective, Evolving or Mixed (consumers)

5.2 Free remote assistance: Up-to-date information on website, Remote diagnostic assistance and Remote repair assistance (repairers and consumers)

5.3 Possibility of resetting software: Operating system reset and Firmware reset (producer, repairers, consumers)

Impact on EEE Manufacturers

The product categories that will need to display a repairability index focused on a limited set of high volume products, but this may be expanded to a broader set of products.  It’s also likely that the requirements will spread across the EU in light of the European Circular Economy Action Plan.

A limitation in the current repairability index is that it does not take into account the durability of products – durability of the components and the system can mitigate some of the need for repairability (as noted in the European standard EN 45552 “General method for the assessment of the durability of energy-related products”. Based on the draft decree, France is considering a future modification in the requirements to address this aspect.


 [1] EU Regulation on computers and servers,

[1] France Draft Decree,

[2] France notification 2020/0469/F – H00, H00,

IPC-1752B – Materials Declaration Standard Published

The revised IPC-1752B: Materials Declaration Management Standard was published by IPC in early July 2020. The standard is a major revision to IPC-1752A which was in effect from 2010 until 2020. IPC-1752B includes technical changes that are not backward compatible to earlier versions of the standard. It supports SCIP data by using a combination of Class C and Class D declarations. The IPC-1752B standard is available on the IPC website[1].

[1] IPC-1752B standard,