Conformity Magazine - February 2009 - (Page 48)

• Availability of technology • Development cycle and time to market Often, conflicts will arise when integrating a combination of these drivers into a design specification. For example, changing materials to improve recyclability may increase cost, while optimizing a product for weight reduction might negatively affect its manufacturability or recyclability. A choice of new technology may not meet energy efficiency targets. Making a product more robust may increase its lifetime and, as a result, reduce long-term resources use and waste generated, but it may also increase initial costs which may have social as well as economic effects. Most importantly, changing materials or structural aspects may jeopardize compliance with other legal requirements for safety or EMC performance. In resolving these conflicts, compromises will need to be made, but as a minimum any applicable legislation must be complied with, with product safety as a priority. After that, the best balance of environmental performance should be sought without jeopardizing marketability. Regarding compliance, as mentioned earlier, the EuP Directive is a CE marking directive, and will require an EC Declaration of Conformity and the affixing of the CE Mark. Of course, all the products will already be carrying the CE marking demonstrating compliance with the EMC and Low Voltage Directives or, perhaps in future, the R&TTE Directive or the Directive on Machinery Safety. Manufacturers will now have to sign off that they have properly complied with all the environmental requirements, and have evidence to prove it. In this way, eco-design requirements will take their place alongside EMC and product safety. Like all CE marking directives the EuP Directive requires that compliance be demonstrated through prescribed conformity assessment procedures. In this case, there are two options. The first option, the Internal Design Control procedure, requires the setting up of a technical file containing the evidence of compliance in the form of the assessments, design solutions and measurements employed to comply with the requirements specified in the implementing measures. For the second option, those companies having an environmental management system (EMS) based on ISO 14001, or registered under the EMAS and covering product design, can follow Annex V, the EMS procedure. The process is one of self-certification with products subject to post-market surveillance as with other CE Marking directives, but the door has been left open for the Commission to prescribe third party intervention in the implementing measures, when thought justified and proportionate to the risk. Other design issues arise when considering the impact of the supply chain on managing compliance. Many of the requirements we see arising are dependent on improvements 8 Conformity february 2009 and changes to components and technologies (e.g., power supply efficiency and use of LEDs). With the widespread use of sub-contract manufacturing and design, influence and control of materials, components and technologies used can be distributed through complex supply chains. This is largely outside of the control of the final equipment designer, and end equipment manufacturers will have to cope with managing eco-design in the supply chain and across wide geographical areas in order to preserve the environmental performance of their products. In addition to the growing legislative requirement needed to address environmental impacts of products, changing external market conditions are increasingly driving eco-design to the forefront of business planning. Expectations are growing among consumers and customers that the environmental impacts of products be reduced consistent with the increasing concerns over global warming and pollution. Consumers may be increasingly influenced in their buying decisions by the degree to which they believe the product is environmentally friendly. In line with this trend, many companies are beginning to see eco-design as a way to achieve or maintain market advantage. Business goals are tied inexorably to the marketability of the company’s products, and eco-design will significantly affect this marketability. We can see eco-design moving from being a legal compliance issue that can be tackled with a oneoff initiative by the design department, to a strategic issue affecting the longer term sustainability of the business. As well as legal compliance and marketability, manufacturers carrying out eco-design can realize benefits in cost reduction, improved stakeholder and supply chain relationships, improved image, employee motivation and innovation. However, the potential benefits relate to critical operational and planning activities, and can only be realized if they are anticipated, recognized and recorded as part of the overall business goals, objectives and targets. This clearly illustrates why the implementation of eco-design processes and the production of more environmentallyfriendly products should be firmly embedded in the strategic planning processes of the business, as well as into the product design and development activities. In that way, they can make a valuable contribution to the goals and objectives of the business, as well as benefiting the environment. Vic Clements is an environmental specialist and freelance consultant, and can be reached at vclements@waitrose.com. 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Conformity Magazine - February 2009 Contents Editor's Note FCC Clarifies Closed Captioning Requirements for DTV Receivers Commission Cracks Down (For the Fifth Time!) On Junk Fax Marketer FDA Requests Comments on Global Harmonization Documents Australia Now Requires Solar Panel Testing and Certification EU Drafting New Directive on Toy Safety EU Commission Revises Standards List for EMC, R&TTE Directives Additional Standards Published For the EU's Medical Devices Directive EU Commission Publishes Additional Standards for Directives on Active Implantable, In Vitro Medical Devices EMC For the Functional Safety of Automobiles ESD Open Forum The ILAC Arrangement: Facilitating Trade Efficient Methodology for the EMI Analysis of Optical Transceivers Including PCBs and/or Flex Circuits The EuP Directive - Implementation, Design Requirements and Issues Chambers, Shielding, and Accessories Buyer's Guide CPSIA Lead Requirements Apply to Existing Inventory, Says CPSC CPSC Clarifies Certifcation Requirements Other CPSC Actions in the News IEC Standards Update Product Reviews UL standards Update Telcordia Standards Update From Our "You Can't Make This Stuff Up" Department Looking Back: Items from Past Issues of Conformity Advertisers

Conformity Magazine - February 2009

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