The directorate rushed out a first draft of the so-called "triple E" proposal this spring, stealing thunder from its sister environment directorate, which was then finalising a proposal on management of waste EEE - or WEEE (ENDS Daily 2 May). At its core, the EEE initiative demands that manufacturers ensure their products comply with a set of "basic requirements" of better eco-design by means of an "internal design control" or by adopting environmental management systems - now renamed "environmental assurance systems".
Few changes have been made since the first draft. Though the scope has been cut from EEE design and manufacture to just design, sources say this amounts to a linguistic rather than substantive change. On the other hand, the proposal's general objective is now to "secure a high level of environmental protection" rather than to "minimise" the environmental impact of EEE, a distinction that industry maintains is crucial (ENDS Daily 14 September).
In other changes, subsidiary provisions governing selection and design of components and materials plus equipment use become "general principles" that manufacturers should "take into account," rather than mandatory requirements. Products that have been awarded the EU ecolabel will be automatically considered in compliance with the directive.
Industry has responded with disappointment to the new draft, which was circulated on Friday. "We were expecting more changes," said one source. "Some of the basic requirements [still] need to be worked on." These oblige producers to avoid the use of materials which "present a threat to the environment" and to minimise energy consumption and pollution generation.
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