COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document 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  
SWD(2013) 14 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the voluntary ecodesign scheme for imaging equipment 

{COM(2013) 23 final} 
{SWD(2013) 15 final} 

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COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the voluntary ecodesign scheme for imaging equipment 

This working document is intended for use by the staff of the European Commission and is 
for information purposes only. It does not represent the official position of the Commission 
nor does it anticipate such a position. 

Lead DG: ENER 

Associated DG: ENTR 

Other involved services: SG, LS, CLIMA, CNECT, COMP, ECFIN, EMPL, ENV, JRC, 
JUST, MARKT, SANCO, TAXUD, TRADE, RTD 

EXECUTIVE SUMMARY 

Imaging  equipment  are  energy-related  products  covered  by  the  Ecodesign  Directive 
2009/125/EC. 

The Ecodesign Directive establishes a framework for laying down ecodesign requirements for 
energy-related  products.  Ecodesign  requirements  for  products  constitute  an  important 
instrument  for  meeting  the  policy  objectives  under  the  ‘Resource-Efficient  Europe  — 
Flagship  Initiative’1,  the  ‘Energy  2020’2  strategy  paper  and  the  Commission’s  ‘Energy 
Efficiency Plan 2011’3. 

This document and the impact assessment report consider whether ecodesign requirements for 
imaging  equipment  should  be  adopted  under  the  Ecodesign  Directive  to  reduce  the 
environmental impact of imaging equipment, in particular its energy consumption.  

1. 

PROBLEM DEFINITION 

Compared to the situation with most other products considered for measures, there is no major 
ecodesign  problem  for  imaging  equipment,  as  energy  efficiency  improvements  and  paper 
savings through duplexing are advancing rapidly, driven by voluntary policy instruments. 

The fact that the full technical savings potential is not being fully exploited is mainly due to 
the  dynamics  of  the  sector,  which  has  achieved  efficiency  improvement  rates  of  over  6 % 
annually and electricity savings of as much as 87 % over the last 15 years.  

1 

2 

3 

A  Resource-Efficient  Europe  —  Flagship  initiative  under  the  Europe  2020  strategy,  EC,  26.1.2011, 
COM(2011) 21. 
Energy 2020, A strategy for competitive, sustainable and secure energy, EC, 10.11.2010, COM(2010) 
639 final. 
Energy Efficiency Plan 2011, EC, 8.3.2011, COM(2011) 109 final. 

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A  concern  is  that  there  is  no  guarantee  that  the  current  positive  trend  in  energy  efficiency 
improvements  will  continue  and  that  current  horizontal  legislation  only  covers  selected 
environmental aspects. 

OBJECTIVES 

2. 
The preparatory study4 and the 2012 research5 found that there is a cost-effective potential for 
reducing  the  energy  consumption  of  imaging  equipment,  including  paper  consumption,  and 
that the full potential is currently not being exploited. 

The objective is therefore to develop an ecodesign measure, including self-regulation, to help 
achieve current policy objectives, i.e. 20 % energy savings and a 20 % reduction in greenhouse 
gas emissions over the 1990-2020 period as well as the promotion  of (non-energy)  material 
resource  efficiency  through  e.g.  material  reduction  (e.g.  paper),  recycling  (e.g.  of  larger 
plastic parts, electronics, metals) and reuse (e.g. toner cartridges). 

The 2012 research indicated that, despite the considerable savings already achieved, the target 
levels  for  2020  could  still  be  ambitious  and  could  aim  for  60 %  energy  savings  and  a  90 % 
duplexing rate for typical office equipment over the 2012-2020 period. 

In  line  with  recitals  18  and  19  and  Article  15(6)  of  the  Ecodesign  Directive,  self-regulation 
should be explored as the preferred option. 

3. 

CRITERIA FOR ECODESIGN MEASURES 

The approach to developing the proposed measure and its impact assessment was structured in 
four steps. 

Step 1: Legal basis: compliance with the Ecodesign Directive, Article 15 

In  accordance  with  Article  15(4a)  and  Annexes  I  and  II  to  the  Ecodesign  Directive,  the 
Commission  has  carried  out  a  technical,  environmental  and  economic  preparatory  study  to 
assess the criteria for ecodesign implementing measures for imaging equipment6. 

The study has shown that these criteria are met, as (1) imaging equipment is placed on the EU 
market  in  large  quantities,  (2)  the  environmental  impact  of  the  life-cycle  electricity 
consumption of imaging equipment is significant, (3) there is a considerable disparity in the 
environmental  impacts  of  imaging  equipment  currently  on  the  market.  Cost-effective 
technical solutions exist that could lead to significant improvements. 

Table  1:  Criteria  of  Article  15(2)  of  the  Ecodesign  Directive  applied  to  imaging 
equipment 

Art. 15(2a) 

Annual EU sales volume (units)  

Art. 15(2b) 

Environmental impact: direct 
electricity consumption of imaging 
equipment, in TWh electricity and Mt 
CO2 equivalent per year [1] 

31 million 
37 million 
41 million  

2010 
2020 
2030 
direct (electricity) 
2010 
2020 
2030 

8.7 TWh (3.6 Mt CO2) 
9.1 TWh (3.5 Mt CO2) 
10.4 TWh (3.6 Mt CO2)  

4 
5 

6 

EuP Preparatory study on Imaging Equipment compiled by Fraunhofer IZM. 
Research  of  the  EU-ENERGY  STAR  database  performed  by  consultants  (van  Holsteijn  en  Kemna 
VHK) in 2012 (‘2012 research’). 
http://www.ecoimaging.org/. 

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Environmental impact: indirect energy 
for production of paper consumed by 
imaging equipment, in TWh 
electricity equivalent and Mt CO2 
equivalent per year [2] 

indirect (paper) 
2010 
2020 
2030 

38.8 TWh (5.8 Mt CO2) 
42.8 TWh (6.4 Mt CO2) 
47.0 TWh (7.0 Mt CO2) 

Art. 15(2c) 

Improvement potential versus BAU in 
the same year (applying existing cost-
effective technology, Voluntary sub-
option ), expressed in units as above. 

direct energy (efficiency improvement) 
7.9 TWh (4.1 Mt CO2) 
2020 
9.1 TWh (4.3 Mt CO2) 
2030 

indirect energy (duplexing and N-printing) 
2020 
2030 

7.1 TWh (1.1 Mt CO2) 
7.8 TWh (1.1 Mt CO2) 

[1] Conversion from TWh electricity to Mt CO2 equivalent takes into account improvements in CO2 emissions of 
power plants over the 2010-2030 period (source MEErP 2011) 
[2] Office paper production: primary energy 40 MJ/kg paper, conversion to electricity equivalent using primary 
energy  factor  2.5  (40  MJ  primary=  16  MJ  electric  =  4.44  kWh  electric),  greenhouse  gas  emissions  0.6  kg/kg 
paper (source MEErP 2011). Paper consumption has been calculated according to ENERGY STAR duty cycles. 

The  criteria  are  fully  met  by  monochrome  or  colour  output  imaging  equipment  with  ink-jet 
(IJ), electro-photographic (EP/‘laser’) and solid-ink (SI, included in the EP category) marking 
technologies. EP equipment comprises copiers, printers, multifunctional devices (MFDs) and 
facsimile machines and IJ equipment is categorised into multi- and single-function devices. 

Legacy  marking  technology  such  as  thermal  transfer  (TT),  direct  thermal  (DT)  and  dye 
sublimation (DT) is excluded as it is sold in small numbers and predominantly used in special 
applications such as the printing of receipts, labels and textiles. For the same reasons, large-
size  printers,  e.g.  for  technical  drawings,  are  also  excluded.  Finally,  high-speed  printers  for 
e.g. professional print shops are excluded because cost considerations in this market segment 
drive buyers to purchase only the most energy-efficient models. 

Step 2: Existing initiatives and capacity of market forces to address the issue 

Articles  15(2)  and  15(4c)  of  the  Ecodesign  Directive  require  relevant  EU  and  national 
environmental  legislation  to  be  considered.  Imaging  equipment  has  not  been  subject  to  any 
product-specific mandatory measures, but certain aspects have been addressed by horizontal 
legislation on standby and off-mode electricity use7, chemicals8, and waste9. The energy use 
of  imaging  equipment  in  the  non-residential  sector  is  part  of  energy  accounting  under  the 
Energy  Performance  of  Buildings  Directive10  and  the  upcoming  Energy  Efficiency 
Directive11. It is also included indirectly in carbon accounting under the EU Emission Trading 
Scheme. 

The  energy  efficiency  and  core  environmental  impacts  of  imaging  equipment  are  addressed 
mainly  by  the  voluntary  EU  ENERGY  STAR  programme,  following  EU-US  Agreements 
since the year 2001. Further support via Green Public Procurement criteria (GPP) and the EU 
Ecolabel, which largely use ENERGY STAR requirements and formats, is planned for 2012. 

7 

8 
9 
10 
11 

Regulation 1275/2008 on standby and off-mode electric power consumption of electrical and electronic 
household and office equipment. 
RoHS Directive 2011/65/EC (recast). 
WEEE Directive 2012/19/EU (recast). 
EPBD Directive 2010/31/EC (recast). 
Draft  directive  on  energy  efficiency  and  repealing  Directives  2004/8/EC  and  2006/32/EC 
[COM(2011) 370, 22/06/2011]. 

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Since  2008,  meeting  the  ENERGY  STAR  criteria,  which  are  updated  every  three  to  four 
years,  has  been  mandatory  for  equipment  procurement  by  EU  institutions  and  central 
governments  of  Member  States12.  The  response  of  the  imaging  equipment  industry  to  the 
measures  has  been  positive,  with  a  high  participation  rate  (>90 %  market  coverage),  a  large 
share  of  compliant  products  (>90 %  of  models  under  current  requirements)  and  self-
declaration at a satisfactory level of reliability13. 

Where market and/or regulatory failures for imaging equipment exist, they concern mainly the 
low-volume  equipment  in  the  consumer  market  and  less  the  professional  office  market, 
according  to  the  preparatory  study.  They  can  arise  because  current  electricity  prices  do  not 
reflect  environmental  costs  for  society  and  thus  play  an  insufficient  role  in  the  purchase 
decision (negative externality). Furthermore, most consumers base their choice of equipment 
on purchase price and other factors like availability, service and ‘trusted’ brand names, rather 
than energy costs, because of lack of adequate information (asymmetric information). In this 
context,  it  is  relevant  that  the  ENERGY  STAR  logo  is  well  known  in  the  office  sector  but 
much less among private consumers. Finally, cases of market failure occur where investment 
costs and running costs are borne by different parties, e.g. a company purchasing department 
may have a different financial perspective than the business unit actually using the equipment 
and paying for its running costs (split incentives). 

Step 3: Policy objectives and levels of ambition 

The general objective is to address the market failures and externalities by taking appropriate 
ecodesign measures. The options considered for detailed impact analysis were: no EU action 
(business  as  usual,  BAU),  self-regulation  (‘Voluntary’  option),  and  ecodesign  requirements 
(‘Ecodesign’  option).  The  industry  has  expressed  its  preference  for  a  voluntary  agreement 
(‘self-regulation’) over a regulatory measure. 

Annex II to the  Ecodesign Directive provides  that energy consumption  requirements should 
normally be set at a level so as to minimise life-cycle costs (unless other factors make this too 
strict). 

The starting point of the analysis was the preparatory study, which provided the basis for the 
BAU  (Business-as-Usual)  scenario.  Sales  data  from  the  preparatory  study  are  used  in  the 
stock  model  to  calculate  stock,  electricity  consumption  and  paper  consumption  for  all  the 
options. 

Additional  analysis  was  performed  of  the  models  registered  in  the  EU  ENERGY  STAR 
database  at  www.eu-energystar.org.  It  found  the  electricity  consumption  and  duplexing 
characteristics of all imaging equipment models placed on the EU market that were registered 
in  the  EU  ENERGY  STAR  database  in  2012  but  also  in  preceding  reference  years  back  to 
2009.  This  assessment  showed  not  only  the  number  of  models  compliant  with  ENERGY 
STAR  requirements  version  1.0,  1.1  (on  which  the  current  Voluntary  Agreement  (VA)  is 
based) and the draft version 2.0 (to enter in force in 2013 and on which the next version of the 
VA will be based), but also revealed how much better these models scored with respect to the 
ENERGY  STAR  minimum  requirements.  The  results  of  this  assessment  are  shown  for  the 
Voluntary  option.  It  was  assumed  under  this  option  that  a  voluntary  agreement  would 

12 

13 

See Article 16 of Regulation (EC) No 106/2008 of the European Parliament and of the Council of 15 
January  2008  on  a  Community  energy-efficiency  labelling  programme  for  office  equipment  (recast 
version), OJ 13.2.2008, L39, p. 1-7. 
Commission  Communication  COM(2011) 337  final  on  the  implementation  of  the  ENERGY  STAR 
programme in the EU in the period 2006-2010. Brussels, 9.6.2011. 

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maintain the pace of improvements at levels above the ENERGY STAR requirements (as in 
previous years). 

The  Ecodesign  option  lays  down  minimum  mandatory  efficiency  requirements  for  imaging 
equipment  placed  on  the  market.  The  disadvantage  of  a  Regulation  requiring  100 % 
compliance  by  definition  vis-à-vis  an  effective  voluntary  agreement  aimed  at  90 % 
compliance  is  its  lack  of  flexibility,  so  the  ambition  is  usually  considerably  lower.  At  first 
sight,  this  may  seem  contradictory,  but  essentially,  under  Article  15(5)  of  the  Ecodesign 
Directive (‘no negative impact’ on functionality and industry competitiveness), the ambition 
level  for  requirements  under  a  Regulation is  mainly  determined  by  the  weakest  10 %  of  the 
market, consisting of special products or products made by financially weaker companies. In 
contrast,  the  ambition  level  of  a  voluntary  agreement  can  focus  on  the  90 %  ‘normal’ 
products, produced by innovative, financially healthy manufacturers. 

The  Ecodesign  option  takes  this  into  account:  the  first  tier  was  set  for  2014,  assuming  an 
efficiency target of 40 % under the BAU level and the second tier was set for 2016 assuming a 
target  60 %  below  BAU.  For  duplexing,  it  was  assumed  —  optimistically  —  that,  after 
formulation  of  a  list  of  exemptions,  requirements  could  be  set  at  the  same  level  as  for  the 
Voluntary option, i.e. for typical office printers a 75 % (2014) and 85 % (2016) duplexing rate 
would apply. 

Step 4: Environmental, economic and social impact assessment 

The analysis of sub-options found the savings shown in Table 2. The table and figure below 
show  the  direct  electricity  consumption  of  imaging  equipment,  the  indirect  energy 
consumption  (calculated  as  electricity  equivalent)  needed  to  produce  paper  and  the  total 
energy consumption (direct + indirect) under BAU and the savings of the two other options 
compared to BAU. 

Table 2: Summary of the savings generated by imaging equipment in the EU-27 under different 
options  compared  to  the  baseline  BAU  for  2020  and  2030  (monetary  savings  are  expressed  in 
constant 2010 euros) 

Total savings (direct and indirect paper energy excl. toner) 2020 

BAU (levels) 
2020 

2030 

Voluntary 

Ecodesign 

2020 

2030 

2020 

2030 

Versus Baseline BAU 

Energy consumption (TWh) 

Direct  
Indirect 

Total 

CO2 emissions (Mt) 

Direct  

Indirect 

Total 

9.13 
42.75 

51.88 

3.47 

6.41 

9.88 

10.40 
49.99 

57.39 

3.54 

7.05 

10.59 

7.92 
7.12 

9.07 
7.83 

15.04 

16.91 

5.56 
6.54 

12.10 

6.31 
7.83 

14.15

2.99 

1.07 

4.06 

3.09 

1.17 

4.26 

3.58 
7.83 

2.10 

0.98 

3.08 

1.48 
6.54 

2.15 

1.17 

3.32 

2.49 
7.83 

Costs saving excl. toner (in bn euros) 
14
Direct  
Indirect 

2.43 
42.75 

4.10 
46.99 

2.11 
7.12 

14 

Paper cost savings are calculated by multiplying the number of pages saved by €
 0.02 (price for 1 page, 
also calculated in chapter 2). Electricity rates are per kWh primary energy. For electricity, residential 
electricity rates in 2010 excluding taxes are used, i.e. €
 0.18/kWh, assuming an annual (long-term 2011-
2030 average) electricity price rate increase of 4 %. 

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Total 

45.18 

51.09 

9.24 

11.41 

8.02 

10.32

Figure  1  shows  that  electricity  consumption  will  grow  if  no  measures  are  taken.  The  two 
options,  Voluntary  and  Ecodesign,  will  substantially  reduce  the  growth  of  electricity 
consumption. 

EU-27 Energy consumption total TWh/year

h
W
T
n
o
i
t
p
m
u
s
n
o
c
y
g
r
e
n
E

 70,0

 60,0

 50,0

 40,0

 30,0

 20,0

 10,0

 -

50,43 

50,07 

45,11 

47,44 

42,18 

40,21 

49,58 

51,88

46,68 

39,78

36,23 

36,84

57,39

43,25

40,49

BAU (preperatory study)

Voluntary

Ecodesign

1990

1995

2000

2005

2010

2015

2020

2025

2030

2035

Year

Figure 1: EU-27 Energy consumption total TWh/year 

4. 

CONCLUSIONS 

The Voluntary option is the preferred choice. It contributes to solving the continuity problem 
with the current positive trend towards energy efficiency and paper saving (duplexing and N-
printing)  and  addresses  other  resource-efficiency  issues  like  recycling  and  reuse.  In  this 
dynamic  product  sector,  it  generates  considerably  higher  savings  than  the  alternative  of 
mandatory  ecodesign  requirements,  provides  flexibility,  enables  quicker  updating  of  target 
levels, and has a lower administrative burden. Unlike mandatory measures, it poses no risk of 
a  negative  impact  on  the  effectiveness  of  current  successful  policy  measures  such  as  EU 
ENERGY STAR. 

Specifically, the Voluntary option entails: 

• 

• 

• 

• 

• 

a  contribution  to  the  ‘20-20-20’  target  (1990-2020  period)  of  25  TWh/a  in  direct 
the  equivalent  of 
electricity  savings 
approximately  4  TWh/a  electricity  savings  through  indirect  paper  resource  savings, 
making  a  total  of  29  TWh/a  (equivalent  to  1.1 %  of  the  EU’s  total  electricity 
consumption in 2007); 

improvements  and 

through  efficiency 

a  contribution  to  the  ‘20-20-20’  target  (1990-2020  period)  in  the  form  of  direct 
reductions  of  9.6  Mt  CO2  eq/a  (electricity)  and  0.6  Mt  CO2  eq/a  (paper)  in 
greenhouse  gases,  making  a  total  of  10.2  Mt  CO2/a  (0.2 %  of  EU  greenhouse  gas 
emissions); 

a contribution to non-energy resource efficiency of over 1 million tonnes (1 Mt) in 
reduced  office  paper  consumption  over  the  1990-2020  period  and  a  contribution  to 
recycling and reuse; 

that the requirements of the Ecodesign Directive 2009/125/EC, in particular recitals 
18 and 19, Article 15(6) and Annex VIII, are met, 

that the requirements will already have entered into force and are less costly than in 
the case of a Regulation, 

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• 

• 

• 

• 

that there is compatibility and complementarity with the existing policy instruments, 

that there is no significant administrative burden for manufacturers or retailers, 

insignificant,  if  any,  increase  in  purchasing  cost,  which  would  be  largely  offset  by 
savings during the use-phase of the product, 

no  significant  impact  on  the  competitiveness  of  industry  and  on  employment,  in 
particular in SMEs. 

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