G/TBT/N/FRA/219  
3 February  2022 
(22-0814) Page: 1/2 
Committee on Technical Barriers to Trade  Original:  French  
 
  
NOTIFICATION  
The following notification is being circulated in accordance with Article 10.6.  
 
1. Notifying Member : FRANCE  
If applicable, name of local government involved (Articles 3.2 and 7.2):  
2. Agency responsible:  
Ministère de la transition écologique  (Ministry for Ecological Transition)  
Commissariat général au développement durable  (General Commission for Sustainable 
Development)  
Service de l'économie verte et solidaire  (Solidarity and Green Economy Service)  
Tour Séquoïa  
92055 Par is-La Défense Cedex  
Name and address (including telephone and fax numbers, email and website 
addresses, if available) of agency or authority designated to handle comments 
regarding the notification shall be indicated if different from above:  
3. Notified under Article 2.9.2 [X], 2.10.1 [ ], 5.6.2 [ ], 5.7.1 [ ], other:  
4. Products covered (HS or CCCN where applicable, otherwise national tariff 
heading . ICS numbers may be provided in addition, where applicable) : Robot and 
household vacuum cleaners  
5. Title, number of pages and language(s) of the notified document : Arrêté relatif 
aux critères, aux sous critères et au système de notation pour le calcul et l'affichage de 
l'indice de réparabilité des aspirateurs robots (Order relating to the c riteria, sub -criteria 
and scoring system for the calculation and display of the repairability index of robot 
vacuum cleaners) (12 pages, in French)  
6. Description of content : The repairability index consists of a score out of 10 intended to 
be displayed a t the time of purchase to inform consumers of the categories of electrical 
and electronic products . This score is obtained by dividing an overall score of 100 points 
by 10 according to five criteria, each scored out of 20 and of equal weight, making it 
possible to assess the repairability of the products concerned . These criteria are as 
follows : documentation provided by the manufacturer, ease of disassembly of the 
product, availability of spare parts, relationship between the price of the most expensive 
spare part and the price of the original product, usage counter (optional) or other criteria 
specific to the category of products concerned . This Order applies to robot and household 
vacuum cleaners as defined in Article 2(8) and (16) respectively of the ame nded 
Commission Regulation (EU) 666/2013 of 8 July 2 013 laying down ecodesign 
requirements for vacuum cleaners . 
It specifies the criteria, sub -criteria and scoring system applicable to robot vacuum 
cleaners to calculate the repairability index by model . 
Producers, importers, or other parties placing electrical and electronic equipment on the 
market, including robot vacuum cleaners, shall be required to calculate the index for the 
categories of products concerned, and to make this information available.  G/TBT/N/FRA/219  
- 2 - 
  7. Objective and rationale, including the nature of urgent problems where 
applicable : Directive (EU) 2018/851 on waste encourages Member States to take 
appropriate measures to prevent waste generation . In addition, one of the objectives of 
the European action  plan for the circular economy (COM (2020) 98) is to improve the 
durability and repairability of products . The stakeholder consultation held in the context 
of the Roadmap for the circular economy, which was presented by the Government on 2 3 
April 2 018, res ulted in measure No. 10, which provides for mandatory information on the 
repairability of electrical and electronic products . The measure aims to promote 
responsible consumption by improving consumer information through the establishment 
and mandatory display of a simple repairability index for some of these products . This 
index aims to inform the consumer regarding how easy it is to repair the product 
concerned . This measure thus aims on the one hand to compensate for the asymmetry 
of informa tion between consumers and manufacturers or distributors concerning the 
repairability of products and, on the other hand, to encourage manufacturers to integrate 
repairability criteria into the design of their products, thus tending towards products that 
are more durable because they are more robust because they are 'eco-designed '. With 
this measure, a reasonable ambition is to reduce breakdowns of electrical and electronic 
products giving rise to repair in the network of French repairers to 60%, within fiv e years, 
as compared to around 40% today . From an environmental standpoint, this measure will 
allow France to pursue its national objective of reducing the resource consumption linked 
to French consumption : to reduce resource consumption relative to GDP by  30% 
compared to 2010, by 2030 (Law No. 2015-992). More repairable and therefore more 
durable products will effectively lead to a reduction in resource consumption (reduction 
in the need for new products), a reduction in the quantity of waste electrical an d electronic 
products and an associated reduction in greenhouse gas emissions . The category  of 
cordless vacuum cleaners  was selected for implementation of the repairability index 
because these appliances are in general use in France,  and because of  the imp act of this 
use on household budgets and the environmental impacts generated by this product ; 
Protection of the environment . 
8. Relevant documents:  
Decree No. 2020-1757 of 2 9 December 2 020 relating to the repairability index of electrical 
and electronic equipment  
9. Proposed date of adoption : 2 May 2 022 
Proposed date of entry into force : 31 October 2 022 
10. Final date for comments : 60 days from the date of notification  
11. Texts available from : National enquiry point [ ] or address, telephone and fax 
numbers and email and website addresses, if available, of other body:  
https://ec.europa.eu/growth/tools -
databases/tris/fr/search/?trisaction=search.detail&year=2022&num=32  
https://members.wto.org/crnattachments/2022/TBT/FRA/22_1306_00_f.pdf