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:
- the period of availability of technical documentation, instructions for use and maintenance instructions to producers, repairers and consumers;
- 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;
- the period of availability of the spare parts on the market and to the delivery times to producers, spare parts distributors, repairers and consumers;
- 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;
- 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, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013R0617
[1] France Draft Decree, https://ec.europa.eu/growth/tools-databases/tris/en/index.cfm/search/?trisaction=search.detail&year=2020&num=468&mLang=en&CFID=5701851&CFTOKEN=7c34eb62578d4a6e-DFA2D618-9D36-76EE-856C43CF20CCA460
[2] France notification 2020/0469/F – H00, H00, https://ec.europa.eu/growth/tools-databases/tris/en/index.cfm/search/?trisaction=search.detail&year=2020&num=469&mLang=EN