On 12 October 2009, a Consultation Forum was held in the framework of Directive 2005/32/EC on ecodesign requirements for energy-using products (the EuP Directive). At the 12 October meeting, the Commission, Member States and industry discussed the future of ecodesign of imaging equipment, and whether a voluntary agreement in relation to such equipment, proposed by the industry, was acceptable or not.

Hong Kong sellers will be familiar with the “big names” that comprise, in large part, the major manufacturer-suppliers of this kind of equipment, and who have collectively drafted the voluntary agreement. The names include Canon, Dell, HP, Brother, Toshiba, Panasonic, Xerox, Samsung, Sharp, Fujitsu and Kodak. The products that would fall within the voluntary agreement’s scope are standard size format products from the following product categories: copiers, multifunction devices, printers and faxes.

The draft as presented to the Forum spelt out that signatories would commit to ensuring that, as of 1 January 2011, 50% of their imaging equipment would comply with the requirements and efficiencies set out in the proposed agreement’s text. These include energy savings (Energy Star V1.1 requirements), and various resource efficiencies, including the encouragement of environmentally friendly paper (such as eco-labelled paper, recycled paper, etc.). On other aspects, the draft stated that toner and ink modules/containers must be so designed as to ensure their channeling to reuse or recycling. Information requirements included informing customers about the environmental performance of the products concerned.

According to the Commission, the proposed voluntary agreement as presented was not acceptable, as several stakeholders had reservations over its key elements. Perhaps as a planned response to such opposition, which was probably expected, industry representatives made clear that the draft was not a final proposal for a voluntary agreement, but more of a discussion paper.

With regard to the eco-efficiency compliance standard, the industry was informed that it had to come back by the end of this year with a finalised proposal that would have more ambitious targets. While the draft proposed a compliance rate of 50% of a signatory’s equipment that is placed on the market as of 1 January 2011, the Commission felt  that this was “more or less business as usual – not enough and not credible”, reflecting concerns raised by environmentalists.

The Commission declared that it could accept compliance by a later date, but wished to see a much higher level of compliance. One possibility would be that 90% of products meet the standards by 2012.

Other environmental requirements on ink cartridge recycling and reduced paper consumption must, it was declared, be further elaborated, with more details being needed on resource efficiency.

Hong Kong’s businesses should be aware that, at this stage of the procedure, if the finalised proposal from industry is not ambitious enough, the Commission will work according to the legislative process, and propose a binding implementing measure for all imaging equipment. As the framework EuP Directive works on the basis that acceptable voluntary agreements from industry may be preferable to binding legislation, Commission officials – and no doubt the industry itself – are hopeful that a tightened up and workable draft can be presented for approval by the end of this year.