REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the voluntary ecodesign scheme for imaging equipment
Date: 2013-01-29
Institutions: European Commission
Subjects: electronic device, environmental standard, marketing standard, printer, product design, self-regulation, technical standard

EUROPEAN 
COMMISSION 

Brussels, 29.1.2013  
COM(2013) 23 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the voluntary ecodesign scheme for imaging equipment 

(Text with EEA relevance) 

{SWD(2013) 14 final} 
{SWD(2013) 15 final} 

EN 

   EN 

 
 
 
 
  
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the voluntary ecodesign scheme for imaging equipment 

(Text with EEA relevance) 

1. 

Introduction and the legal framework 

Directive  2009/125/EC  of  the  European  Parliament  and  of  the  Council  of  21  October  2009 
establishing  a  framework  for  the  setting  of  ecodesign  requirements  for  energy-related 
products  (the  Ecodesign  Directive)1  provides  a  legal  framework  for  laying  down  ecodesign 
requirements for selected priority product groups. 

According to Article 15(2)(a) to (c) of the Ecodesign Directive, a priority product group has 
to be covered by either a mandatory implementing measure (i.e. a Commission Regulation) or 
a self-regulation measure (e.g. a voluntary agreement concluded by industry), if it meets three 
conditions:  (i)  it  represents  significant  sales  volumes,  (ii)  it  has  a  significant  environmental 
impact and (iii) it has a significant improvement potential. 

Furthermore,  recital  18  of  the  Ecodesign  Directive  states  that  the  priority  product  groups 
should be subject to alternative courses of action such as industry self-regulation or voluntary 
agreements rather than mandatory implementing measures, if such action is likely to deliver 
the policy objectives faster or in a less costly manner than mandatory requirements. 

Voluntary  agreements  or other  self-regulation measures can be considered as alternatives to 
implementing measures in the context of the Ecodesign Directive, provided that they comply 
with the criteria laid down in Annex VIII to the Ecodesign Directive. 

2. 

Voluntary scheme proposed by the industry for imaging equipment 

Article  16(2)(a)  of  the  Ecodesign  Directive  provides  for  the  Commission  to  introduce 
implementing  measures  for  office  equipment  and  consumer  electronics  product  groups 
offering a high potential for the cost-effective reduction of greenhouse gas emissions. 

The  Commission  commissioned  preparatory  studies  for  office  equipment  and  consumer 
electronic product groups, including imaging equipment. 
The  preparatory  study  on  imaging  equipment2  confirmed  that  this  product  group  meets  the 
criteria listed in Article 15 of the Ecodesign Directive. In particular, it represents significant 
sales  volumes,  has  a  significant  environmental  impact  and  has  a  significant  improvement 
potential. Consequently, imaging equipment should be covered by an implementing measure 
or by a self-regulation measure. 

Companies  active  on  the  imaging  equipment  market  have  proposed  a  voluntary  scheme  for 
the  imaging  equipment  product  group  in  the  EU  and,  to  this  end,  concluded  a  voluntary 
agreement laying down specific ecodesign requirements for imaging equipment placed on the 
EU market. The voluntary scheme was agreed on 16 February 2011. 

1 
2 

OJ L 285, 31.10.2009, p. 10. 
EuP Preparatory study ‘Lot 4 — Imaging equipment, copiers, faxes, printers, scanners, MFD’, carried 
out  by  a  consortium  of  six  companies,  including  Fraunhofer  IZM,  Öko-Institut,  Bio  Intelligence 
Service, Deutsche Umwelthilfe, PE Europe, CODDE. Final reports were published in December 2007 
and May 2008. Documentation is available on the study website http://www.ecoimaging.org/ . 

EN 

2 

   EN 

 
                                                 
It is estimated that the commitments undertaken by the signatories to the voluntary agreement 
will  generate  savings  in  2020  of  15  TWh,  corresponding  to  4.1  Mt  CO2  emissions  and 
between 2011 and 2020 of 130 TWh, corresponding to 36 Mt CO2 emissions. 

The voluntary scheme proposed by the industry was subject to a full impact assessment by the 
Commission3  and  stakeholder  consultations  in  the  course  of  the  Ecodesign  Consultation 
Forum4 established under Article 18 of the Ecodesign Directive. 

The  impact  assessment  concluded  that  the  proposed  voluntary  scheme  would  achieve  the 
policy  objectives  more  quickly  and  at  lesser  expense  than  mandatory  requirements.  It  also 
concluded that, as required by Annex VIII to the Ecodesign Directive, the proposed scheme 
complied  with  all  provisions  of  the  Treaty  (in  particular  internal  market  and  competition 
rules), international engagements of the EU (including multilateral trade rules), the objectives 
of  the  Ecodesign  Directive,  and  the  specific  assessment  criteria,  i.e.  (i)  openness  of 
participation,  (ii)  added  value,  (iii)  representativeness,  (iv)  quantified  and  staged  objectives, 
(v)  involvement  of  civil  society,  (vi)  monitoring  and  reporting,  (vii)  cost  effectiveness  of 
administering a self-regulatory initiative, (viii) sustainability, and (ix) incentive compatibility. 

3. 

Elements of the voluntary agreement 

The  voluntary  agreement  concluded  by  the  industry  lays  down  specific  ecodesign 
requirements for imaging equipment placed on the EU market. The products covered by the 
agreement  are  also  subject  to  the  ENERGY  STAR  voluntary  energy  labelling  programme, 
which  lays  down  energy  labelling  requirements  for  different  office  equipment,  including 
imaging equipment. As required by the Ecodesign Directive, the signatories to this voluntary 
scheme represent a large majority of the relevant economic sector. Under the agreement , each 
signatory  undertook  that  at  least  90 %  of  all  imaging  equipment  models  it  places  on  the 
market  would  comply  with  the  minimum  efficiency  requirements  in  terms  of  TEC  (typical 
energy  consumption)  and  OM  (operational  mode).  Furthermore  all  printing  products  should 
offer  the  ‘N-up  printing’  capability5  as  a  standard  feature  and  should  comply  with  the 
requirements for cartridges (e.g. the design should not prevent the reuse/recycling and use of 
cartridges of other producers). All new products should also comply with the requirements for 
recycling (e.g. easy disassembly and marking of plastics). Finally, the signatories undertook 
to  comply  with  the  specific  information  requirements  (e.g.  information  on  resource  and 
energy efficiency).  

In  addition  to  laying  down  the  ecodesign  requirements,  the  agreement  establishes  two 
administrative bodies: 

• 

• 

3 

4 

5 

6 
7 

the  Steering  Committee,  consisting  of  representatives  of  the  signatories  to  the 
agreement and the European Commission, which manages the agreement6, and 

the  Independent  Inspector,  who  assesses  the  compliance  of  individual  signatories 
with  the  commitments  set  out  in  the  agreement  and  provides  the  Commission  with 
the compliance reports7. 

The Impact Assessment Board gave its favourable opinion on the impact assessment on 21 September 
2012. 
The voluntary scheme for imaging equipment has been discussed twice by the Ecodesign Consultation 
Forum, i.e. at its meetings of 12 October 2009 and 9 October 2012. 
Capability to print several pages of a document on one sheet of paper, when the product is managed by 
original software provided by a manufacturer. 
Representatives of the EU Member States, EFTA/EEA countries and NGOs have observer status. 
Compliance reports are made available to and discussed with stakeholders. 

EN 

3 

   EN 

 
                                                 
The agreement also defines reporting obligations, specifying that each signatory must provide 
required  information  to  the  Independent  Inspector,  otherwise  it  will  risk  forfeiting  its 
signatory status. 

Furthermore,  the  agreement  provides  for  a  procedure  allowing  the  Steering  Committee  to 
modify the provisions of the agreement, in particular to adjust the stringency of requirements 
to  the  situation  on  the  market.  Under  this  procedure,  the  requirements  laid  down  in  the 
voluntary  agreement  will  be  revised  three  months  after  publication  of  a  new  version  of  the 
ENERGY  STAR  programme  requirements  for  imaging  equipment.  A  flexible  approach  in 
terms  of  defining  the  relevant  parameters  and  establishing  applicable  requirements  is 
important in the case of imaging equipment, as its functions evolve quickly. 

To  provide  all  stakeholders,  particularly  potential  signatories,  with  correct  and  updated 
information  about  the  requirements  applying  to  imaging  equipment  in  good  time,  the  most 
recent version of the voluntary agreement will always be published together with the impact 
assessment  and  this  Report  on  the  Commission’s  Europa  website  dedicated  to  ecodesign 
policy8 and on the website dedicated to this scheme9. 

4. 

Acceptance of the voluntary scheme 

As the voluntary scheme proposed by the industry for imaging equipment will achieve policy 
objectives  more  quickly  and  at  lesser  expense  than  mandatory  requirements,  and  as  it 
complies  with  all  the  criteria  specified  in  Annex  VIII  to  the  Ecodesign  Directive,  the 
Commission  recognises  that  imaging  equipment  placed  on  the  EU  market  is  subject  to  the 
voluntary  ecodesign  scheme  established  by  the  industry  for  imaging  equipment.  The 
conditions for the scheme are set out in the voluntary agreement concluded by the industry. 

The  Commission  considers  this  voluntary  scheme  a  valid  alternative  to  an  ecodesign 
implementing  measure.  Consequently,  the  Commission  will  abstain  from  establishing 
mandatory ecodesign requirements for imaging equipment placed on the EU market as long as 
the voluntary agreement and any subsequent versions concluded under the proposed voluntary 
scheme  will,  in  the  opinion  of  the  Commission,  meet  their  objectives  and  the  general 
principles defined in the Ecodesign Directive. 

In  particular,  the  voluntary  scheme  must  continue  to  comply,  throughout  the  period  of  its 
application,  with  the  general  principles  defined  in  the  Ecodesign  Directive,  including: 
contribution to the policy objectives of the Ecodesign Directive; openness to participation by 
all  companies  active  on  the  imaging  equipment  market;  coverage  of  a  large  majority  of  the 
relevant economic sector10; clarity and unambiguity of its terms and conditions; transparency; 
well-designed  monitoring  system;  and  no  disproportionate  administrative  burden. 
Furthermore,  any  specific  ecodesign  requirements  for  imaging  equipment  placed  on  the  EU 
market which are defined in the voluntary agreement and any subsequent versions concluded 
under  the  voluntary  scheme  should  deliver  added  value  in  terms  of  the  improved  overall 
environmental performance of the products covered. 
Moreover,  as  requested  by  the  Commission  and  stakeholders11,  the  signatories  to  the 
voluntary scheme are required to: 

•  continuously assess progress in the application of the scheme, 
•  cooperate with the Commission services, Member States and stakeholders to continuously 
improve  the  environmental  performance  of  imaging  equipment,  in  particular  by 

8 
9 
10 
11 

http://ec.europa.eu/energy/efficiency/labelling/agreements_en.htm. 
www.eurovaprint.eu  
At least 70% of the products placed on the market. 
Meeting of the Ecodesign Consultation Forum on 9 October 2012 

EN 

4 

   EN 

 
                                                 
continuously reducing the energy consumption targets defined in the voluntary agreement, 
and to include other relevant environmental aspects where appropriate, 

•  cooperate with the Commission services, Member States and stakeholders to improve the 

reporting mechanism and the monitoring and auditing rules , 

•  provide, by the deadlines stipulated in the voluntary agreement, relevant data to allow the 
Commission and stakeholders to monitor achievement of the objectives of the agreement, 
whereby each signatory commits to providing information on all the imaging equipment 
models it has placed on the EU market and information about the energy consumption and 
other  environmental  characteristics  addressed  by  the  voluntary  agreement  (e.g.  ease  of 
recycling and information requirements) for each imaging equipment model subject to the 
voluntary agreement, and 

•  make efforts to ensure the active involvement of potential signatories in the scheme. 

5. 

Monitoring of the voluntary scheme 

As required by point 6 of Annex VIII to the Ecodesign Directive, the Commission, assisted by 
the  Ecodesign  Consultation  Forum  and  the  Committee  referred  to  in  Article  19(1)  of  the 
Ecodesign  Directive,  will  monitor  the  application  of  the  voluntary  scheme,  in  particular  its 
compliance  with  the  general  principles,  as  well  as  the  appropriateness  of  the  ecodesign 
requirements specified in the voluntary agreement and any subsequent versions. 

The Commission will give special attention to the reporting obligations and monitoring rules 
set out in the Ecodesign Directive, in existing Commission  guidelines and in the agreement 
itself. In particular, the Commission will check whether the provisions of the agreement and 
their  application  by  the  signatories  allow  the  Commission  and  stakeholders  (including  the 
national authorities) to effectively monitor the effectiveness of the agreement and how well it 
meets its objectives. 

If  the  Commission  concludes  that  the  objectives  and  general  principles  of  the  Ecodesign 
Directive, as reflected in the voluntary scheme, will not be met and/or the signatories to the 
voluntary  scheme  will  not  continuously  reduce  over  time  the  energy  consumption  targets, 
improve  requirements  concerning  non-energy  related  aspects  as  specified  in  the  voluntary 
agreement  or  include,  where  appropriate,  new  relevant  environmental  aspects  in  subsequent 
versions,  the  Commission  will  adopt  ecodesign  requirements  for  imaging  equipment  by 
means of a mandatory implementing measure. 

6. 

Conclusions 

The  voluntary  ecodesign  scheme  proposed  by  the  industry  for  imaging  equipment  complies 
with all provisions of the Treaty, international engagements of the EU and specific assessment 
criteria, so is considered valid under the Ecodesign Directive. 

Commission  assessment  has  revealed  that  this  voluntary  ecodesign  scheme  will  achieve  the 
policy objectives more quickly and at lesser expense than mandatory requirements. 

The  Commission  recognises  that  imaging  equipment  placed  on  the  EU  market  should  be 
subject to the voluntary ecodesign scheme. The conditions for the scheme are laid down in the 
voluntary agreement concluded by the industry. 

The  Commission  considers  this  voluntary  scheme  to  be  a  valid  alternative  to  an  ecodesign 
implementing  measure,  so  will  abstain,  for  now,  from  establishing  mandatory  ecodesign 
requirements for imaging equipment placed on the EU market. 

The Commission will continuously monitor the application of the voluntary scheme. Should 
this reveal that the objectives and general principles of the Ecodesign Directive are not being 

EN 

5 

   EN 

 
met,  the  Commission  will  establish  ecodesign  requirements  for  imaging  equipment  in  a 
mandatory implementing measure.  

EN 

6 

   EN