COMMISSION STAFF WORKING DOCUMENT Impact Assesment 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) 15 final 

COMMISSION STAFF WORKING DOCUMENT 

Impact Assesment 

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) 14 final} 

EN 

   EN 

 
 
 
 
  
 
 
 
Table of contents 

1.  Procedural issues and consultation of interested parties..................................................... 4 

1.1  Organisation and timing .............................................................................................. 3 

1.2 

1.3 

Impact Assessment Board ........................................................................................... 5 

Transparency of the consultation process.................................................................... 6 

1.4  Outcome of the consultation process........................................................................... 6 

2.  Problem definition .............................................................................................................. 7 

2.1  Baseline scenario ......................................................................................................... 8 

2.1.1 

Scope of appliances covered ................................................................................ 9 

2.1.2  

Sales and stock ................................................................................................... 10 

2.1.3   Environmental impact ........................................................................................ 10 

2.1.4  Market structure ................................................................................................. 14 

2.1.5   Expenditure ........................................................................................................ 16 

2.1.6 

Improvement potential ....................................................................................... 16 

2.2  Relevant legislation ................................................................................................... 17 

2.2.1 

2.2.2 

2.2.3 

EU mandatory legislative measures ................................................................... 17 

EU voluntary measures ...................................................................................... 21 

Third country mandatory measures.................................................................... 23 

2.2.4  National and regional voluntary initiatives in the EU and third countries......... 23 

2.3  Market and regulatory failures .................................................................................. 24 

2.4 

2.5 

Subsidiarity................................................................................................................ 24 

Legal basis for EU action .......................................................................................... 24 

3.  Defining Objectives .......................................................................................................... 25 

4. 

Identifying policy options ................................................................................................. 26 

4.1  Option 1: No EU action ............................................................................................. 26 

4.2  Option 2: Self-regulation ........................................................................................... 26 

4.2.1   Main elements of the voluntary agreement proposed by the industry ............... 29 

4.2.2   Assessment of the voluntary agreement proposed by the industry against the 
criteria of Annex VIII to the Directive ............................................................................. 31 

4.3  Option 3: Mandatory energy labelling Regulation .................................................... 31 

4.4  Option 4: Mandatory ecodesign Regulation.............................................................. 32 

4.5  Option 5: Combined mandatory ecodesign and energy labelling Regulations ......... 33 

4.6 

Policy options proposed............................................................................................. 33 

5.  Analysis of impacts........................................................................................................... 34 

5.1 

Energy saving and security of supply........................................................................ 35 

5.2  Greenhouse gas emission reduction .......................................................................... 36 

5.3  Customer economics and affordability...................................................................... 39 

 
 
 
5.4  Business economics and competitiveness proofing................................................... 39 

5.5 

5.6 

5.7 

Territorial impact....................................................................................................... 40 

Employment............................................................................................................... 40 

Technology, functionality and innovation................................................................. 41 

5.8  Health and safety ....................................................................................................... 41 

5.9  Administrative burden ............................................................................................... 41 

5.10 

Impact on trade .......................................................................................................... 40 

5.11  Summary.................................................................................................................... 41 

6.  Comparing the options...................................................................................................... 42 

7.  Monitoring and evaluation................................................................................................ 43 

Annex 1 Steering committee meetings..................................................................................... 46 

Annex 2 Recycling and reuse of paper and ink........................................................................ 58 

Annex 3 Manufacturers in ENERGY STAR database............................................................. 59 

Annex 4 EPA............................................................................................................................ 62 

Annex 5 Ecolabels.................................................................................................................... 63 

Annex 6 ENERGY STAR analysis.......................................................................................... 64 

Annex 7 Research 2012............................................................................................................ 75 

Annex 8 ENERGY STAR countries ........................................................................................ 83 

Annex 9 Voluntary agreement ................................................................................................. 85 

Annex 10 Scenario data.......................................................................................................... 105 

Annex 11 Compliance with Criteria VA (Art. 17) ………………………………………… 113 

 
 
 
 
1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1. 

Organisation and timing 

This is an impact assessment study on possible policy measures, including self-regulation, for 
imaging  equipment  (copiers,  printers,  multi-functional  devices,  fax  machines)  under  the 
Ecodesign Directive 2009/125/EC1, possibly in combination with measures under the Energy 
Labelling Directive2. 

Legal basis of the Ecodesign Directive is Art. 114 TFEU (internal market)3 and the Energy 
Labelling Directive is based on Art. 194 TFEU  on  energy  policy,  aiming  amongst  others  at 
ensuring security of energy supply in the Union and promoting energy efficiency and energy 
saving.  

Ecodesign and energy labelling requirements for products constitute an important instrument 
for meeting the policy objectives under the ‘Resource-efficient Europe - Flagship Initiative’4, 
the ‘Energy 2020’5 strategy paper and the Commission’s ‘Energy Efficiency Plan 2011’6. The 
Ecodesign Directive references the objectives of the EAP6 7 and ECCP8.    

At an operational level the ’20-20-20’ target is relevant, which aims amongst others at a 20% 
reduction of energy consumption and carbon emissions in 2020 with respect of the reference 
year  1990  (or1995).9  For  (non-energy)  resources  efficiency  it  is  important  that  measures 
address materials reduction, recycling and re-use.  

Horizontal legislation covers aspects as chemicals10 and waste11. Imaging equipment is part of 
the  holistic  energy  accounting  in  the  Energy  Performance  of  Buildings  Directive  (EPBD)12 

1 Directive 2009/125/EC of 21 October 2009 establishing a framework for the setting of ecodesign requirements 
for energy-related products (recast). OJ L 285, 31.10.2009, pp. 10-35.  
2  Directive  2010/30/EU  of  the  European  Parliament  and  of  the  Council  of  19  May  2010  on  the  indication  by 
labelling and standard product information of the consumption of energy and other resources by energy-related 
products (recast). OJ L 153, 10.6.2009, pp. 1-12.  
3 Treaty on the European Communities (TEC) was replaced by the Treaty on the functioning of the European 
Union  (TFEU)  which  entered  into  force  on  1st  of  December  2009,  following  the  Treaty  of  Lisbon  13  Dec. 
2007. The content of article 95 TEC was moved to article 114 TFEU.  
4  A  resource-efficient  Europe  –  Flagship  initiative  under  the  Europe  2020  strategy,  EC,  26.1.2011,  COM 
(2011)21. 
5 Energy 2020, A strategy for competitive, sustainable and secure energy, EC, 10.11.2010, COM(2010) 639 final 
6 Energy Efficiency Plan 2011, EC, 8.3.2011, COM (2011) 109 final. 
7 Decision No 1600/2002/EC of the European Parliament and of the Council of 22 July laying down the Sixth 
Community Environment Action Programme OJ L242/1 10.9.2002. 
8 European Climate Change Programme. http://ec.europa.eu/clima/policies/eccp/index_en.htm 
9 Formulated in ‘Energy Policy for Europe’, Presidency conclusions, European Council, March 2007 
10 RoHS Directive 2011/65/EC (recast) 
11 WEEE Directive 2012/96/EC (recast) 
12 EPBD Directive 2010/31/EC (recast) 

 
 
                                                 
and  the  upcoming  Energy  Efficiency  Directive  (EED)13.  It  is  also  included  in  the  carbon 
accounting of the EU Emission Trading Scheme (ETS)14.  

Core  of  the  product-specific  EU  policy  measures  on  energy  efficiency  and  paper  saving 
features  of  imaging  equipment  is  the  voluntary  EU  ENERGY  STAR  programme15,  with 
upcoming support from the voluntary Green Public Procurement (GPP)16 and  EU  Ecolabel 
which largely duplicate energy and paper saving requirements. More details are provided in 
par. 2.2. 

Imaging  equipment  (‘Lot  4’)  is  a  product  group  in  the  first  tender  for  a series  of  ecodesign 
preparatory  studies,  issued  by  the  Commission  late  200517.  The  preparatory  study  was 
performed  by  Fraunhofer  IZM  in  collaboration  with  Öko-Institut  between  early  2006  and 
concluded May 2008.18 The study concluded that the product group was eligible for ecodesign 
measures and proceeded accordingly (see par. 2.5, Legal basis).  

Subsequently, in preparing a draft implementing measure and in accordance with recital 18, 
19 and Art. 15(3) of the Ecodesign Directive, the Commission investigated the possibility of 
’self-regulation, such as voluntary agreements, which, following an assessment in accordance 
with  Article  17,  are  expected  to  achieve  the  policy  objectives  more  quickly  or  at  lesser 
expense than mandatory requirements.’19 

In  the  Ecodesign  Consultation  Forum  of  12  Oct.  2009,  the  imaging  equipment  industry 
presented a first draft proposal for a voluntary agreement (hereafter ‘VA’). Initial reactions to 
the  VA  are  listed  in  par.  1.4.  This  led  to  a  series  of  negotiations  in  the  VA  Steering 
Committee meetings, open to all stakeholders, resulting in better compliance with the generic 
requirements  for  a  voluntary  agreement  in  Article  17  and  Annex  VIII  of  the  Ecodesign 
Directive (see par. 2.5, 4.2, Annex 11 of this IA). The last VA Steering Committee meeting 
was held in Dec. 2011 (see Annex 1), which prompted the Commission services to proceed 
with preparations for a policy decision, including an Impact Assessment (‘IA’).  

As part of the IA, the Commission services with technical assistance of external consultants20 
updated  certain  aspects  treated  in  the  preparatory  study.  Analysis  of  the  most  recent  energy 

13  Draft  directive  on  energy  efficiency  and  repealing  Directives  2004/8/EC  and  2006/32/EC  [COM(2011)370, 
22/06/2011]. Political consensus on EED reached in July 2012. Signature and publication in the OJ expected 
Oct. 2012 (see http://ec.europa.eu/energy/efficiency/eed/eed_en.htm) 
14  Directive  2003/87/EC  of  the  European  Parliament  and  of  the  Council  of  13  October  2003  establishing  a 
scheme for greenhouse gas emission allowance trading within the Community and amending Council Directive 
96/61/EC (OJ 25.10.2003, L 275, p.32-46) with amendments. 
15 The EU ENERGY STAR programme entails an US-EU agreement, regulation with public procurement clause, 
product-label/logo, international co-ordination of test & calculation methods, equipment database at www.eu-
energystar.org.  Key  reference:  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.  

16 Directives 2004/17/EC and 2004/18/EC. see also 

http://ec.europa.eu/internal_market/publicprocurement/other_aspects/index_en.htm  

17 Tender No. TREN/D1/40 lot 4-2005 
18 Stobbe, L. (Fraunhofer Institute IZM, contractor), Preparatory Study “Imaging Equipment”(Lot 4), Report for 
Tender  No.  TREN/D1/40  lot  4-2005  (Öekoinstitut  and  Fraunhofer),  Task  reports  1  (Nov.  2007)  to  8  (May 
2008).  

19 cit. Art. 15(3) of Directive 2009/125/EC 
20 Van Holsteijn en Kemna (VHK) 

 
 
                                                 
efficiency data in the EU ENERGY STAR database21 was performed (status Feb. 2012) and 
additional  literature  search  revealed  recent  sources  that  allowed  to  fill  in  the  blanks  on  the 
year 1995, a reference year for policy objectives such as the ’20-20-20’ target. (see par. 4.2 
and Annex 7 of this IA).  

The underlying report gives the outcomes of the IA. 

1.2. 

Impact Assessment Board 

The  Impact  Assessment  Board  gave  its  favourable  opinion  in  the  meeting  of  19  September 
2012 under the condition that report should be improved in a number of respects, in particular 
regarding clarification and expansion of certain elements. In response, the underlying report 
has  addressed  the  issues  mentioned.  Paragraph  1.1  has  been  expanded  regarding  policy 
context  and  targets.  The  content  of  other  paragraphs  in  Chapter  1  has  been  clarified.  The 
introduction at the outset of Chapter 2 on the problem definition has been rewritten. In par. 
2.1.4 the absence of independent EU-based manufacturing has been brought into better focus. 
The  background  to  the  definition  of  the  baseline  as  well  as  the  use  of  this  baseline  in  the 
evaluation  of  options,  have  been  clarified  (par.  2.1,  par.  5.10  and  chapter  6).  In  par.  2.2,  in 
particular the  existing voluntary  measures in the EU –with a leading role for EU ENERGY 
STAR programme—have been described more extensively and also the targets and ambition 
levels of current and future requirements have been highlighted. The explanation of the scope 
(par.  2.1.1)  has  been  expanded  regarding  the  exemptions.  Chapter  3,  in  line  with  Impact 
Assessment Guidelines for comitology-decisions and self-regulation22, has been kept compact 
on  policy  context  already  given  in  Chapter  1  but  does  expand  on  exact  operational  targets. 
Chapter 4 was expanded particularly in its description of the mandatory options. The impact 
analysis  in  chapter  5  now  clarifies  aspects  of  consumer  impacts,  administrative  burden  and 
industry competitiveness. In Chapter 6, the relative importance of the baseline has been better 
explained;  improvements  and  targets  have  been  put  into  perspective  vis-à-vis  the  policy 
objectives. 

Before the Impact Assessment Board meeting, the impact assessment report was subject to the 
consultations  of  the  Ecodesign  Inter-service  Impact  Assessment  Group  (2  August  2012). 
During  the  consultations,  the  impact  assessment  was  amended  according  to  the  comments 
received from DG MARKT (clarification in Chapter 2.2.4 that GPP apply to the best products 
in terms of environmental performance) and from DG COMP (correction of the numbering in 
Annex 9 and in a footnote on page 22). Furthermore, DG COMP provided three comments on 
the text of the voluntary agreements that will be considered during its next review.  

None of the members of the Group accepted an invitation to a meeting to discuss the impact 
assessment report. 

Moreover,  on  18  June,  the  draft  impact  assessment  report  was  sent  for  consultations  to  DG 
ENTR (Unit B4) to obtain its preliminary comments on the report and in particular from the 
'competitiveness proofing' angle. This version of the report includes comments received from 
DG ENTR. 

21 www.eu-energystar.org 
22 European Commission, IMPACT ASSESSMENT  GUIDELINES, 15 January 2009, SEC(2009) 92 

 
 
                                                 
1.3. 

Transparency of the consultation process  

Consultation of the representatives of EU Member States and stakeholders (industry and 
NGOs) constituted an important part of the process of establishing ecodesign requirements for 
imaging equipment and of analysing impacts of possible measures. 

Expertise was gathered in particular through: 

(cid:131) 

(cid:131) 

(cid:131) 

The  preparatory  study23,  where  stakeholders  were  actively  participating  including 
through  multiple  stakeholder  meetings24.  The  preparatory  study  hosted  a  dedicated 
website25  where  the  interim  results  and  further  relevant  materials  were  published 
regularly for timely stakeholder consultation and input. The preparatory study provided 
the  European  Commission  with  the  technical  and  market  data  supporting  the 
establishment of eco-design requirements for imaging equipment in accordance with the 
methodology defined in Annexes I and II to the Ecodesign Directive; 

Opinions  of  stakeholders  gathered  consistently  throughout  the  whole  process  of 
establishing ecodesign requirements for imaging equipment and specifically through the 
Ecodesign Consultation Forum of 12 October 2009, in accordance with the stipulations 
of  Article  18  of  the  Ecodesign  Directive,  as  well  as  through  bi  and  multilateral 
meetings,  amongst  others  in  the  VA  Steering  Committee  meetings,  open  to  all 
stakeholders. Minutes of these meetings can be found in Annex 1. 

Additional  analysis  (hereafter  ‘Research  2012’)  based  on  a  public  database  of  EU 
registered models that are compliant with ENERGY STAR requirements, accessible to 
and with results verifiable by all stakeholders and other interested parties.  

Thus the Commission's standards on public consultation have been met.  

1.4. 

Outcome of the consultation process 

Positions of the main stakeholders on the key features of the proposal for the VA presented at 
the meeting of the Consultation Forum of 12 October 2012, can be summarised as follows: 

(cid:131) 

(cid:131) 

(cid:131) 

The Member States supported in principle the industry proposal but would welcome a 
further improvement of the level of ambition. The industry was asked to provide further 
information/evidence  on  the  level  of  market  coverage  of  the  agreement  and  further 
clarification on the governance of the VA. 

NGOs would prefer a Regulation over a self-regulation. NGOs acknowledged that the 
industry  proposal  on  imaging  equipment  had  certain  merits  however  it  needed  to  be 
improved in terms of the representativeness and targets.  

The industry pointed out the advantages of the presented self-regulation, i.e. fast entry 
into force of the requirements, greater flexibility, availability of data, and possibility of 
all  market  actors  to  work  together  towards  greater  energy  efficiency  of  imaging 

23 ibid 15. 
24  Stakeholder  meetings  were  organised  during  the  study  and  at  the  start  of  the  project,  two  industry  contact 
meetings were organised in Berlin on 7-8 March and 20-21 March 2006. 
25 http://www.ecoimaging.org/  

 
 
                                                 
equipment.  The  industry  committed  to  providing  the  Consultation  Forum  with  an 
independent assessment of the market coverage of the VA.26  

In the context of the VA, two meetings of the Steering Committee established under this VA 
were  held.  At  both  meetings,  representatives  of  the  Commission,  EU  Member  States  and 
stakeholders have discussed the application of the VA27 (see Annex 1). 

As mentioned in par. 1.1, the negotiations prompted the industry to formulate a more stringent 
compliance rate, larger market coverage as well as –anticipating ENERGY STAR version 2.0 
requirements likely to be introduced in 2013– addressing other environmental issues, such as 
design for recycling and re-use of cartridges.  

The full text of the final VA is given in Annex 9. 

Following  the  revision  clause  in  the  VA,  already  at  the  last  meeting  of  the  Steering 
Committee  it  was  agreed  that  the  signatories  of  the  VA  (hereafter  ‘Signatories’)  would 
establish a working group in 2012 that would prepare a new proposal for the next version of 
the VA that will be discussed with the Commission and other stakeholders in 2013.  

2. 

PROBLEM DEFINITION 

If it is accepted that a limited level of market imperfection is unavoidable (see par. 2.3), there 
are  no  major  ecodesign  problems  for  the  imaging  equipment  sector  in  comparison  to  other 
product groups subject to ecodesign regulations.  

It should be stressed that the improvement in the IE sector has been realised in recent years 
by the industry on a voluntary basis. The preparatory study identified electricity consumption 
and indirect energy in the form of paper use as the most important environmental impacts.  

• 

• 

The  latest  2012  research  by  the  Commission  estimates  that  over  the  last  15  years  a 
direct electricity saving of 87% has been realized, i.e. from 27 TWh in 1995 to 3.5 TWh 
in 2010 (see table 4, p. 29 ‘Voluntary’ scenario), despite the fact that market penetration 
of  equipment  has  continuously  grown.  Different  from  other  sectors  where  voluntary 
agreements are proposed, this product sector has shown a long term proven track record 
of  over  5-6%  compound  average  annual  efficiency  improvement,  which  constitutes  a 
significant  achievement  compared  even  to  other  sectors  that  have  been  extensively 
approached through mandatory policies such as the so-called ‘white-goods’.  

Indirect  energy  saving,  in  the  form  of  using  less  paper  due  to  duplexing28  and  N-
printing29,  has  been  put  on  the  agenda  a  few  years  ago  and  the  use  of  N-printing  and 
to  92% 
is  progressing  satisfactorily.  Approximately  80%  (colour) 
duplexing 
(monochrome)  of  typical  office  printers,  i.e.  with  speeds  above  19  images  per  minute 
ipm (colour) or 25 ppm (monochrome), now feature duplexing as a standard.  

26 The independent assessment is obtained by an Independent Inspector (ERA Technology ltd.) according to the 
specifications set out in the VA (chapter 6 and Annex C of voluntary agreement version 3.5).  
27 For minutes of the two Steering Committee meetings please see Annex I to this impact assessment. 
28 ‘duplexing’ or double-sided printing is printing on both sides of the paper (F. ‘retro-verso’)  
29 ‘N-printing’ is printing multiple down-sized document pages (typically 1:2) on one sheet of paper. This is only 
possible if font-size allows downsizing whilst maintaining good readability. 

 
 
                                                 
These  developments  have  been  made  possible  through  R&D  spending  –as  a  percentage  of 
turnover– well above general industry average and a portion of R&D spending on resources 
and  environmental  issues  is  estimated  to  be  large  (see  p.  31  and  Annex  3).  Voluntary 
measures  around  the  globe  like  ENERGY  STAR,  Japanese  Top  Runner,  procurement,  etc. 
have  been  measure  drivers,  not  only  for  the  achievements  but  also  for  globally  harmonized 
test & calculation methods, revising them at a pace of once every 3-4 years, whereby these 
revisions  increasingly  also  tackle  new  concerns  like  cartridge  re-use.  This  level  of 
harmonisation and the pace of revision is rarely achieved in mandatory measures. 

The EU plays an important part in this global effort of voluntary measures, through the EU-
US agreement on ENERGY STAR (see p. 15), confirmed in regulations and governed by the 
EU ENERGY STAR Board (EUESB) with representation of all Member States, through the 
Green Public Procurement GPP, the EU Ecolabel, etc. A recent Commission communication 
COM(2011) 337 has once again stipulated and quantified the  success  of these measures for 
the office equipment sector as a whole.  

The  only  significant  concern  in  the  case  of  imaging  equipment  is  that  the  above  mentioned 
could significantly slow down or stop.  

The VA provides a guarantee to maintain a similar pace of improvement. The VA fulfils all 
requirements  for  this  type  of  agreement  and  the  monitoring  mechanisms  are  deemed 
satisfactory.  The  construction  of  the  VA  is  similar  to  other  ecodesign VAs  that  had  already 
been subject to the impact assessment. 

Nevertheless, stakeholders from Member States and NGOs have been debating the acceptance 
and content of the VA. Three important reasons can be mentioned:  

1. 

2. 

3. 

The  nature  of  the  voluntary  instrument  inherently  provides  less  ex-ante  certainty  than 
mandatory instruments. Stakeholders have thus sought assurances as much as possible. 

The  initial  VA  proposals  by  the  industry  were  not  very  ambitious  in  providing  the 
minimum  degree  of  certainty  that  stakeholders  were  after.  Throughout  the  negotiation 
process of the last three years the ambition level of the VA has been raised.  

The poor data availability and incomplete analysis at the time of the preparatory study 
led  to  some  incorrect  messages,  e.g.  that  improvements  would  stop  at  2005  level  and 
savings  could  only  achieved  with  mandatory  measures,  which  only  in  the  underlying 
report could be corrected through additional analysis. 

The key question of the underlying report is whether the current trends of energy efficiency 
improvements for this sector, with an extensive set of voluntary instruments –backed up by 
the  VA  as  a  guarantee–  should  continue  ‘as  is’  or  whether  there  is  a  merit  in  introducing 
mandatory ecodesign and energy labelling measures.  

2.1. 

Baseline scenario 

The following sections describe in a greater detail the inputs used to define the baseline ( 
hereafter ‘BAU’30) scenario for calculating economic and environmental impacts. 

The BAU scenario is linked to the ‘no EU action’ option (see Chapter 4) and means that no 
new measures will be implemented. With most product-groups being investigated under the 
Ecodesign Directive, this  means that an on-going  – negative or at least suboptimal – trend 

30 ‘Business-as-Usual’ 

 
 
                                                 
continues. However, in the case of imaging equipment, where the on-going trend is very 
positive and the industry is proposing a VA as an extra guarantee for continuity instead of 
mandatory measures, the ‘no EU action’ scenario actually means a rupture in current EU 
policy relying on voluntary policy measures and a considerable risk of the on-going trend 
slowing down, stopping or reverse.  

The  implications  of  prolonged  uncertainty  over  mandatory  measures  can  of  course  not  be 
fully  predicted.  Uncertainty  provokes  cautious  behaviour,  i.e.  postponing  investments, 
avoiding  risks  at  all  levels,  keeping  up  with  a  minimum  compliance  with  known  voluntary 
efficiency levels but nothing more, preparing for reaction instead of taking action, focussing 
on areas –geographically or otherwise—where there are less risks. This is exactly the type of 
behaviour that has been assumed in the preparatory study concluded in May 2008. Therefore, 
and also because it provides the comprehensive set of data that has been used all through the 
consultation process, the IA report takes their ‘average case’ with reference year 2005, with 
some minor corrections, as the baseline.  

2.1.1. 

Scope of appliances covered 

The  scope  of  the  future  measure  was  decided  on  the  basis  of  Articles  15  and  16  of  the 
Ecodesign  Directive  and  was  later  refined  during  the  preparatory  study  in  search  for  a 
functional approach31.  

The  scope  of  the  future  measure  (defined  in  the  preparatory  study)  covers  monochrome  or 
colour  output  imaging  equipment  that  uses  Ink  Jet  (hereinafter  'IJ'),  Electro  photographic 
(hereinafter  'EP'  or  ‘laser’)  and  Solid  ink  (hereinafter  'SI';  SI  will  be  included  in  the  EP 
category marking technologies. Moreover, EP equipment is split between copiers, printers and 
facsimile machines and IJ is expressed in multi- and single function devices.  

It  is  estimated  that  the  products  covered  constitute  more  than  90%  of  imaging  equipment 
sales. Products that are exempted include printers for special applications such as large size 
printers (e.g. for technical drawings) and printers with legacy marking technology such as DT 
(dot  matrix),  TT  (thermal  transfer)  and  DS  (dye  sublimation).  The  latter  have  survived,  for 
reasons  of  compactness,  robustness  or  other  features,  in  retail  (cash-receipts,  price  labels), 
outdoor applications (e.g. ATM receipts, parking tickets) and official document printing (e.g. 
passports  and  ID  cards).  Setting  up  test  &  calculation  methods  for  these  specialty  printers 
would be time-consuming without any noticeable environmental gain.  

Also exempted are high speed printers with speeds >66 images per minute ipm (monochrome) 
and >51 ipm (colour). They are used in professional print-shops,  where the purchaser  has a 
high-interest  in  keeping  running  costs  low.  Consequently  they  are  the  most  energy  efficient 
around and all have duplexing capabilities. It is believed that the economic interest of market 
forces will continue to regulate these models and it is not necessary to include them explicitly 
in the scope. 

2.1.2. 

Sales and stock 

The  sector  is  economically  significant.  In  2010  the  unit  sales  of  imaging  equipment  in  the 
EU27  amounted  to  approximately  31  million  units32  of  which  25.5  million  IJ  units  and  5.5 
million  EP  units.  In  2020,  estimated  sales  (based  on  the  preparatory  study)  will  reach 

31 Ecodesign Directive Article 15, Point 2(ii).  
32 Apparent sales value: production + import - export, production value fax machines is estimate. 

 
 
                                                 
approximately  37  million  units  of  which  30.5  million  IJ  and  6.5  million  EP  units.  Sales 
projections for 2030 have some degree of uncertainty33; a linear projection would suggest that 
in 2030 the EU27 unit sales would reach around 41 million units, of which 34 million IJ units 
and 7 million EP units. 

This proves that imaging equipment meets the first criterion of Article 15(2) of the Ecodesign 
Directive,  i.e.  that  the  product  group  represents  a  significant  sales  volume  (sales  over  200 
thousand units/a). 

Furthermore, the sales data results in a combined annual turnover of the imaging equipment 
industry (manufacturers, wholesale and retail) in the EU25 of 5 billion Euro (2004 data34).  

EU-27 unit sales of Imaging equipment

s
t
i
n
u
n
o

i
l
l
i

M

40,0

35,0

30,0

25,0

20,0

15,0

10,0

5,0

0,0

25,5

5,5

EP

IJ

1995

2000

2005

2010

2015

2020

2025

2030

Year

Figure 1: EU-27 sales for imaging equipment 

2.1.3.  Environmental impact 

The  preparatory  study  and  the  research  2012  identified  the  main  environmental  impacts  of 
imaging  equipment  over  their  life  cycles.  The  corresponding  environmental  parameters  of 
imaging equipment are: 

•  electricity consumption during use phase; 

•  paper consumption during use phase; 

• 

toner/ ink consumption during use phase. 

Electricity consumption and related greenhouse gas emissions 

On  the  basis  of  the  preparatory  study  data  and  the  research  2012  data,  the  total  electricity 
consumption in the period 2005-2022 of the stock is calculated. For the period 1995-2005, the 

33 For many years the rise of the ‘paperless office’ and widespread introduction of E-paper (re-usable electronic 
sheets) has  been  predicted  to  revolutionize  the  imaging  equipment  market.  So far  this  has  not  happened,  but 
especially  in  very  long  term  projections  the  impact  of  these  possible  market  and  technology  shifts  cannot be 
excluded.  
34 EU sales value equipment in 2004: production value €1 billion, import value €7.8 billion, export value €3.8 
billion euro and apparent sales €5 billion (All in MSP excl. VAT) 

 
 
 
 
 
                                                 
preparatory  study  supplies  no  data  and  this  was  derived  from  the  Top  Runner  trend  (see 
Chapter 2.2.3) using 2005 as a stationary point. In 2022 there has been a full stock change of 
products  subject  to  measures  proposed  here.  For  2022-2030  there  is  some  degree  of 
uncertainty of the technological trends and no new measures are calculated. 

The total electricity consumption of the stock of imaging equipment amounts to 9 TWh/a in 
2010. This corresponds to a total of around 3.4 Mt CO2 eq. emissions (0.07% of the total CO2 
emissions in the EU2735). The electricity consumption in 2020 will be around 9.5 TWh/a, and 
in 2030 it is estimated to be 10.4 TWh/a. Electricity projections between 2020 and 2030 have 
some degree of uncertainty, as already mentioned in Chapter 2.1.2. 

EU-27 Electricity consumption 
TWh/year

27,01

30,0

25,0

20,0

15,0

10,0

5,0

0,0

8,67

9,13

10,40

1990

2000

2010

2020

2030

2040

Year

h
W
T
n
o
i
t
p
m
u
n
s
o
c

y
t
i
c
i
r
t
c
e
l
E

Figure 2: Electricity consumption EU-27 (baseline) 

Table 1: Electricity consumption, Greenhouse gas emissions (in CO2 equivalent), EU-27, 2010 

Avg. Installed 
2010 
(kWh/year. 
unit) 
67 
21 
286 

Avg. Sold 
2010 
(kWh/year. 
unit) 
70 
21 
289 

Total electricity 
consumption in 
2010 (stock) 
TWh/year 
9 
2.3 
6.7 

Total GHG 
emissions in 
2010 (Mt CO2 
eq.)36 
3.4 
0.9 
2.5 

Electricity avg./total 
of which ink jet  
of which EP (‘laser’ ) 

Paper consumption 

Indirectly,  paper  is  the  most  energy  consuming  component  of  the  imaging  equipment  unit. 
The equipment is not responsible for the volume of document pages (‘images’) that the user 
wants to print or copy, but it is at least half responsible for the physical amount of paper that 
is required, i.e. if it does not provide the possibility of double-sided printing (‘duplexing’) or 
‘N-printing’ (2 or more reduced-size document pages per paper page). For reasons of clarity 
and because the important issue is the marginal improvement and not the absolute figure, it 
was  decided  not  make  a  partitioning  between  the  paper  use  that  is  the  responsibility  of  the 

35According the 2010 Statistical Pocketbook "EU Energy & Transport" the EU-27 emissions in 2005 are 4 521 
Mton CO2. 9 Mton are 0.2% of that. 
36 Electricity 384 kg CO2/ MWh, Paper 0.6 kg CO2/kg, Toner/ ink 2.0 kg CO2/kg  

 
 
 
 
 
 
 
                                                 
user  and  the  paper  use  due  to  limitations  of  the  equipment,  but  instead  report  on  the  total 
paper  use  of  imaging  equipment  as  it  becomes  apparent  from  e.g.  ENERGY  STAR  duty 
cycles.    

Single print 
According  to  the  preparatory  study,  an  average  unit  is  producing  24 400  images  per  year 
(122kg/  unit  at  80  g/m2)  single  page  print  only.  On  the  basis  of  a  single  page  printing,  the 
stock would consume 16 100 million kg (16.1 Mt) of paper per year of which 1 700 million 
kg (1.7 Mt) in the IJ equipment and 14 400 million kg (14.4 Mt) in the EP equipment. Energy 
consumption to produce this paper would be 645 PJ primary energy37 and GHG emissions 9.6 
Mt CO2 eq. per year. 

Duplexing 
In the real life duplexing will be used. Assuming 65% duplexing rate and 15% N-printing38 in 
2005, this results in the paper consumption of around 15 000 pages (approximately 75 kg/unit 
at 80g/m2). Thus, it is estimated that imaging equipment in the EU27 consumes almost 10 000 
million kg (10 Mt) of paper annually, of which 1 700 million kg (1.7 Mt) in IJ equipment and 
8 300 million kg (8.3 Mt) in EP equipment. Energy consumption to produce this paper is 400 
PJ  in  primary  energy  (equivalent  to  around  40  TWh  electricity)  and  the  related  greenhouse 
gas emissions amount to 6 Mt CO2 equivalent per year.  

The  indirect  energy  consumption  (in  electricity  equivalent)  in  2020  will  be  around  42.75 
TWh/a and in 2030 it is estimated to be 47 TWh/a, as can be seen in the figure below. The 
projections between 2020 and 2030 have some degree of uncertainty, as already mentioned in 
Chapter 2.1.2. 

EU-27 indirect energy consumption 
TWh/year

38,77

42,75

46,99

50,0

40,0

30,0

20,0

10,0

0,0

23,42

l

t
n
e
a
v
i
u
q
e
y
t
c
i
r
t
c
e
e
h
W
T

l

1990

1995

2000

2005

2010

2015

2020

2025

2030

2035

Year

Figure 3: Indirect paper energy consumption EU-27 (in electricity equivalent TWh) 

Ink consumption 

37 According to MEErP Office paper 40 MJ/kg 
38  90%  of  images  are  produced  by  EP  equipment,  of  which  74%  has  duplex  capabilities  (according  to  EU-
ENERGY STAR database) that are used in 90% of all prints. 10% of images are produced by IJ equipment, of 
which  21%  has  duplex  capabilities  (according  to  Energystar  database)  that  are  used  in  90%  of  all  prints.  N-
printing  (2  images  per  page)  is  assumed  relevant  for  medium  volume  equipment  (20-40  ppm,  workgroup 
printing) and for legal documents or similar (large font, large line space, few graphs).     

 
 
 
 
 
                                                 
The average unit consumes 662 g toner/ ink per year. In total 87 million kg toner (ink)/yr is 
consumed,  of  which  23.1  million  kg  ink  for  IJ  equipment  and  63.9  million  kg  toner  for  EP 
equipment. The total energy consumption to produce this toner/ink is 3.5 PJ39 primary energy 
(equivalent to around 0,35 TWh electricity) and the related greenhouse gas emissions amount 
to 0.17 Mt CO2 equivalent per year. 

Figure 4 clearly shows that paper consumption is the biggest energy consumer compared to 
electricity use and ink.  

Primary energy consumption 485 PJ 
(equivalent to 48,5 TWh electric)

1%

17%

82%

Electricity

Paper

Ink

Figure 4: Primary energy consumption of environmental parameters of imaging equipment in 2010 

Total energy consumption 

The table below presents the total energy consumption for imaging equipment over the period 
1995-2030.  The  indirect  energy  (energy  consumption  to  produce  paper)  is  calculated  in 
electricity  equivalent  so  that  the  direct  and  indirect  energy  can  be  compared.  This  is  the 
business  as  usual  scenario  that  will  be  used  in  the  evaluation  of  different  policy  options  in 
Chapter 5.  

Table 2: Total energy consumption imaging equipment in EU-27 (TWh) 

Direct energy (Electricity in TWh) 
Indirect energy (Paper in electricity 
equivalent TWh)  
Total energy consumption (TWh) 

1995 

2000 

2005 

2010 

2015 

2020 

2025 

2030 

27.01 
23.42 

22.33 
27.74 

11.97 
33.14 

8.67 
38.77 

8.69 
40.89 

9.13 
42.75 

9.74 
44.43 

10.40 
46.99 

50.43 

50.07 

45.11 

47.44 

49.58 

51.88 

54.18 

57.39 

39 According to MEErP toner 50 MJ/kg 

 
 
 
 
 
                                                 
EU-27 Total energy consumption IE 
TWh/year 

70,0

60,0

50,0

40,0

30,0

20,0

10,0

0,0

23,42

27,01

Indirect energy (Paper)

Direct energy (Electricity)

42,75

46,99

9,13

10,40

38,77

8,67

1995

2000

2005

2010

2015

2020

2025

2030

l

t
n
e
a
v
i
u
q
e
y
t
i
c
i
r
t
c
e
e
h
W
T

l

Figure 5: Total energy consumption imaging equipment in EU-27 (direct + indirect energy consumption) 

This  proves  that  imaging  equipment  meets  the  second  criterion  of  Article  15(2)  of  the 
Ecodesign Directive, i.e. significant environmental impact (see Chapter 2).  

2.1.4.  Market structure  

There  are  no  independent  EU-manufacturers  of  the  products  in  the  scope  that  have  a  full 
manufacturing  line  for  these  products.  And  there  are  certainly  no  SMEs  competing  in  this 
market  of  large  multinationals.  The  15-25  000  EU  industry  jobs  are  all  with  subsidiaries  of 
Asian (mainly Japanese) and North-American companies.  

Furthermore (see par. 2.1.4 and par. 5.4) none of these subsidiaries has a full production line, 
so there are also no local SME part suppliers. At best the European subsidiaries make spare 
parts  but  above  all  they  are  engaged  in  logistics  and  support  activities  (distribution  centres, 
sales offices, service engineers, administrative regional headquarters, etc.).  

The only independent EU-manufacturers of imaging equipment produce specialty-printers for 
cash-registers, passports, etc. (Olivetti, Compuprint, cab GmbH) that are not in the scope of 
the VA. Furthermore there are resellers with their own brand name or manufacturers that do 
not  produce  imaging  equipment  anymore  in  the  EU  (e.g.  Philips).  The  preparatory  study 
(Task 2, Table 6, p. 9) mentions that there were still a  few independent German and Dutch 
producers  in  2007,  but  in  the  meanwhile  they  are  no  longer  independent:  In  2008  Kyocera 
Mito (JP) has taken a majority share in UTAX (D) and TA Triumph-Adler(D). In 2009 Océ 
(NL) was taken over by Canon (JP).  

A list of the current 17 Signatories of the VA (par. 4.2.2, p. 22) is believed to cover more than 
90%  of  industrial  market  actors  for  the  products  in  the  scope  (p.  23,  96%  according  to 
industry, see p.44). 

The  EU27  printer  market  is  dominated  by  five  producers,  namely  Hewlett-  Packard  (US), 
Canon  (JP),  Epson  (JP),  Lexmark  (US)  and  Brother  (JP)  representing  by  up  to  86  %  of  the 

 
 
 
 
 
 
market  (Figure  6).40  These  five  manufacturers  also  control  the  total  imaging  equipment 
market in the EU 27, where they have a market share up to 70%.41 

Geographically,  the  industrial  employment  is  concentrated  in  the  Netherlands  (many 
European  HQs,  Océ  R&D,  total  ca.  6  000  jobs)  and  Western  European  Member  States  like 
Germany,  UK,  France  and  Italy  with  each  1  000  –  3  000  jobs  partitioned  to  imaging 
equipment industry. In other Member States the industrial employment is held at the level of 
100-500 jobs. 

40%

14%

6%

10%

13%

17%

Hewlett-Packard

Canon

Epson

Lexmark

Brother

Other

Figure 6: Companies with high market shares in printers unit sales in 2006 for the geographic region of 
Europe, the Middle East and Africa (source: Gartner market research 2006) 

Retail activities include ink cartridge shops and office supplies dealers. Equipment retail takes 
place through specialist shops, supermarkets and internet.  

40 Development of European Ecolabel and Green Public Procurement Criteria for Imaging Equipment JRC IPTS 
Draft Preliminary Study. Draft Task 2: Economic and Market Analysis; Jiannis Kougoulis, Oliver Wolf February 
2011 
41  The  printer  market  sales  share  for  the  geographic  region  of  Europe,  the  Middle  East  and  Africa  (EMEA) 
measured in sold units 

 
 
 
 
                                                 
2.1.5.  Expenditure 

The expenditure related to the use of imaging equipment is presented in Table 3 and Figure 7. 

Table 3: Expenditure (billion euros) of the main environmental parameters of imaging equipment in 2010 

Purchase 
costs42 

Maintenance 
costs 

Electricity 
costs 

Paper 
costs43 

Expenditure total 
of which Ink Jet 
of which EP 
(‘laser’ ) 

14.8 
5.1 
9.7 

14.0 
0 
14.0 

1.6 
1.2 
0.4 

64.4 
6.7 
57.7 

Toner/ 
ink 
costs44 
161.1 
16.8 
144.3 

Total  consumer 
expenditure EU-
27 

255.9 
56.2 
199.7 

Figure 7: Total consumer expenditure of the main environmental parameters of imaging equipment 

2.1.6. 

Improvement potential  

The  preparatory  study  states  that  for  the  reference  year  2005  the  existing  cost  effective 
technical  solutions  allow  for  improvement  of  the  energy  efficiency  of  imaging  equipment. 
The total energy consumption of imaging equipment can be reduced up to 30% according to 
the best case scenario presented in the preparatory study. This statement will be moderated in 
the updated analysis described in Chapter 4.2, but it indicates that a significant improvement 
potential  exists.  The  preparatory  study  concludes  that  savings  can  be  achieved  without 
excessive costs. 

This  indicates  that  imaging  equipment  meets  the  third  criterion  of  Article  15(2)  of  the 
Ecodesign Directive, i.e. significant improvement potential without excessive costs.  

42 Consumer price incl. VAT 
43 Paper costs per page €0.02 
44 Toner/ ink costs per page €0.05 

 
 
 
 
                                                 
 
2.2. 

Relevant legislation  

2.2.1.  EU mandatory legislative measures 

Currently there  is  no  mandatory EU legislation  on  energy  efficiency  of  imaging  equipment. 
However,  certain  aspects  of  imaging  equipment  are  partially  regulated  in  the  following  EU 
laws: 

• 

• 

• 

Regulation  1275/200845  lays  down  requirements  for  standby  and  off  mode  electric 
power  consumption  of  electrical  and  electronic  household  and  office  equipment.  The 
impact of this Regulation can remain limited as imaging equipment are rarely in the 'off' 
or  'standby'  modes  as  they  need  to  be  constantly  in  on  mode  or  ‘networked  standby’ 
mode to be able to operate. 

Directive  2012/19/EU  on  Waste  Electrical  and  Electronic  Equipment  (hereinafter 
'WEEE')46 that applies to office imaging equipment under category 3 of Annex IA, IT 
and telecommunications equipment, stating that: 

(cid:131) 

(cid:131) 

the rate of recovery shall be increased to a minimum of 75% by an average weight 
per appliances;  

component,  material  and  substance  reuse  and  recycling  shall  be  increased  to  a 
minimum of 65 % by an average weight per appliance.  

Annex  II  to  the  WEEE  Directive  provides  selective  treatment  for  materials  and 
components  of  waste  electrical  and  electronic  equipment  in  accordance  with  Article 
6(1) of the Directive. In case of office imaging equipment, the provisions apply to toner 
cartridges, liquid and pasty, as well as colour toner.  

The Directive 2011/65/EU on restriction of the use of certain hazardous substances in 
electrical and electronic equipment (hereinafter 'RoHS')47 applies to the use of the heavy 
metals, such as lead, mercury, cadmium, hexavalent chromium, and brominated flame 
retardants  (poly-brominated  diphenyl  ethers  and  poly-brominated  biphenyls)  in  new 
electrical and electronic equipment placed on the market after 1 July 2006. 

In  part,  also  the  voluntary  ENERGY  STAR  programme  discussed  hereafter  contains  some 
mandatory  clauses,  in  as  much  as  Article  16  of  Regulation  106/2008/EC  enforces  public 
procurement of office equipment to use the ENERGY STAR criteria.  

2.2.2.  EU voluntary measures 

EU ENERGY STAR programme 

On  19  December  2000  the  Agreement  between  the  Government  of  the  United  States  of 
America  and  the  European  Community  on  the  coordination  of  energy-efficient  labelling 

45 Commission Regulation (EC) No 1275/2008 of 17 December 2008 implementing Directive 2005/32/EC of the 
European Parliament and of the Council with regard to ecodesign requirements for standby and off mode electric 
power consumption of electrical and electronic household and office equipment; OJ L 339/45 18.12.2008 
46 Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and 
electronic equipment (WEEE) OJ L 197/38-71, 24.7.2012 
47 Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the   
use of certain hazardous substances in electrical and electronic equipment OJ L174/88 1.7.2011 

 
 
 
                                                 
programs for office equipment was signed between parties. It was confirmed in the EU law in 
2001.  The  objective  is  to  set  up  a  common  labelling  programme  for  energy-efficient  office 
equipment, the ENERGY STAR. 

The nature of the Agreement can be summarised as follows: 

• 

• 

• 

• 

• 

• 

ENERGY  STAR  is  the  name  and  the  logo  of  the  joint  programme  and  is  a  US-
registered service mark owned by the United States Environmental Protection Agency 
(EPA).  

Participation  in  the  programme  is  voluntary,  and  the  Agreement  makes  provision  for 
manufacturers,  vendors  or  resale  agents  of  the  products  in  question  to  register  as 
participants in the programme and to be authorised to use the ENERGY STAR logo to 
identify their products, provided that these meet the requirements set out in Annex C to 
the  Agreement  (e.g.  low-power  ‘sleep’  mode  option  for  monitors).  The  Agreement 
basically covers the office equipment listed in the Annex thereto (monitors, computers 
and operating systems, but also fax machines, scanners, copiers and printers).  

The  products  identified  by  the  ENERGY  STAR  logo  are  tested  at  the  participants' 
installations  or  by  an  independent  testing  laboratory.  The  management  bodies 
designated by the two signatories may also test or examine products in order to verify 
whether they comply with the specifications set out in the Agreement.  

Each party designates a management body to be responsible for the management of the 
ENERGY STAR programme: on the one hand, EPA and, on the other, the Commission. 
The EC has assigned the task of setting and reviewing the technical specifications and 
of  monitoring  the  application  of  the  programme  within  the  Community  to  an 
appropriate body, viz. the European Union ENERGY STAR Board. This body, which is 
made up, in part, of national representatives, will advise and assist the Commission in 
the management of the programme.  

The  Agreement  sets  out  guidelines  on  the  proper  use  of  the  ENERGY  STAR  name. 
These  guidelines  cover  not  only  the  use  of  the  logo  as  a  label  but  also  the  use  of  the 
ENERGY STAR name in educational documents, advertisements, etc.  

The parties are free to amend the Agreement (e.g. addition of a new item of equipment) 
by  mutual  agreement  of  the  two  management  bodies.  They  may  also  terminate  the 
Agreement  at  any  time  by  giving  three  months'  notice,  in  which  case  the  European 
Community  will  no  longer  be  able  to  use  the  ENERGY  STAR  mark,  since  it  is  the 
property of the EPA.  

• 

The Agreement is concluded for five years. 

The EU participation in the ENERGY STAR programme was confirmed in Council Decision 
2001/469/EC of 14 May 200148 and implemented through Regulation (EC) No 2422/2001 of 
6 November 200149. The Agreement has been renewed in 200650 and 201151. In that context, 

48  Council  Decision  2001/469/EC  of  14  May  2001  concerning  the  conclusion  on  behalf  of  the  European 
Community  of  the  Agreement  between  the  Government  of  the  United  States  of  America  and  the  European 
Community  on  the  coordination  of  energy-efficient  labelling  programs  for  office  equipment;  OJ  L172  of 
26/06/2001, p.1 
49 Regulation (EC) No 2422/2001 of the European Parliament and of the Council of 6 November 2001 on a 
Community energy efficiency labelling programme for office equipment. OJ L 332, 15.12.2001, p. 1. 
50 OJ, 28.12.2006, L381 p.26-30 

 
 
                                                 
Commission Communication COM(2011)337 on the implementation of the ENERGY STAR 
programme  in  the  EU  in  the  period  2006-201052  proposed  certain  adjustments  for  the 
prolongation of the Agreement, specifically on the requirements of third part testing.  

Regulation (EC) No 2422/2001 has been recast in Regulation (EC) No 106/200853. Article 6 
of the latter regulation stipulates that Commission, other Community institutions and central 
government  authorities  of  Member  States  shall  specify  energy-efficiency  requirements  not 
less  demanding  than  the  Common  Specifications  [i.e.  ENERGY  STAR  specifications]  for 
public  supply  contracts.  Around  mid-2012  a  new  EU  ENERGY  STAR  Regulation  is 
expected, dealing with the adjustments (or similar) suggested in COM(2011)337.  

Since  2008  the  ENERGY  STAR  equipment  specifications  have  been  incorporated  in 
European law. Council Regulation 1275/2008/EC54 has been issued on stand-by energy use. 
ENERGY STAR specifications for imaging equipment are described in Commission Decision 
2009/347/EC  of  20  April.55  Commission  Decision  2009/486/EC  has  been  issued  on  the 
revision of computer specifications56. Commission Decision 2009/789/EC sets out ENERGY 
STAR specifications of displays.57  

In its dealing with the EU ENERGY STAR the Commission, and the designated Management 
Entity, is assisted by the ENERGY STAR Board with full representation of the EU Member 
States.  Commission  Decision  2003/168/EC  of  11  March  2003  establishes  the  European 
Community ENERGY STAR Board (ECESB).58 Commission Decision 2003/367/EC sets the 
internal rules of procedure of the European Community ENERGY STAR Board.59  

The  official  EU  ENERGY  STAR  database  of  ENERGY  STAR  compliant  office  equipment 
can  be  found  on  www.eu-energystar.org.  News,  rules  for  registration  and  other  ENERGY 
STAR  related  information  are  also  published  on  this  website.  At  the  moment  (Sept.  2012) 
around 5100 models of EU ENERGY STAR compliant imaging equipment are registered. 

COM(2011)337  concludes  that  the  ENERGY  STAR  programme  in  the  European  Union  is 
successful.  Furthermore,  it  specifies  that  ‘The  dynamism  and  voluntary  nature  of  ENERGY 

51 On 29th November 2011, the EU and the US initialled a new ENERGY STAR EU-US Agreement on the 
coordination of energy-efficient labelling programs for office equipment. 
(http://ec.europa.eu/energy/international/bilateral_cooperation/usa_en.htm) 
52  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. 
53 Ibid 12. 
54 Ibid 46. 

55 Commission Decision of 20 April 2009 determining the Community position for a decision of the 
management entities under the Agreement between the Government of the United States of America and the 
European Community on the coordination of energy-efficiency labelling programmes for office equipment on 
the revision of the imaging equipment specifications in Annex C, part VII, to the Agreement  

56 Commission Decision of 16 June 2009 on the revision of the computer specifications (2009/489/EC). OJ 
29.6.2009, L161, p.16-36 

57 Commission Decision of 26 October 2009 on the revision of the computer monitor specifications 
(2009/789/EC). OJ  29.10.2009, L 282, p. 23-40 

58 Commission Decision of 11 March 2003 establishing the European Community ENERGY STAR Board 
(2003/168/EC), OJ L67 12.3.2003, p. 22-24. 

59 Commission Decision of 15 May 2003 establishing the Rules of Procedure of the European Community 
ENERGY STAR Board (2003/367/EC). OJ 21.5.2003, L125, p.9-11 

 
 
                                                                                                                                                         
STAR  make  it  a  policy  tool  particularly  well  suited  for  ICT  products’.  It  illustrates  this  by 
showing the expected impact of ENERGY STAR on the electricity consumption of computers 
and  displays  by  2020,  where  ENERGY  STAR  is  expected  to  save  35%  versus  a  baseline 
without policy. In the underlying report it will be shown that for imaging equipment similar 
the  number  of 
savings  can  be  expected.  Furthermore,  COM(2011)337  notes 
manufacturers participating in the programme has increased significantly from 16 companies 
in 2006 to 74 in 2010 with public procurement (since 2008) as a main driver. 

that 

The focus of the current ENERGY STAR version 1.1 criteria for imaging equipment is on (1) 
duplexing and N-printing, (2) the typical electricity consumption (TEC)60, (3) the operational 
mode (OM)61 and (4) the digital front end (DFE) requirements62. 

In  the  ENERGY  STAR  version  2.0  more  stringent  ambition  levels  on  the  above  mentioned 
issues as well as additional requirements on (5) design for recycling and (6) cartridge re-use 
can be expected.   

Draft 1 of ENERGY STAR requirements version 2 63 shows TEC and OM requirements that 
are,  depending  on  the  print  speed,  30-45%  lower  than  in  ENERGY  STAR  version  1.1  (see 
Annex 6). Stand-by values are 50% below version 1.1 level.  

The aim is, verified with draft requirements and models currently on the market64, to set the 
energy efficiency limits that would allow 25-35% of the models –depending on print speed– 
to  pass  (compare:  today  90%  of  models  in  the  scope  passes  ENERGY  STAR  v.  1.1 
requirements).   

Green Public Procurement 

In  2004,  the  Council  and  the  European  Parliament  adopted  Directives  2004/18/EC  and 
2004/17/EC  aimed  at  clarifying,  simplifying  and  modernising  existing  European  legislation 
on public procurement.  Directive 2004/18/EC  65 is the most relevant for procuring imaging 
equipment  and  it  contains  specific  reference  to  the  possibility  of  including  environmental 
considerations in the contract award process. The preamble to Directive 2004/18/EC identifies 
the objective of clarifying how contracting authorities ‘...may contribute to the protection of 
the environment and the promotion of sustainable development, whilst ensuring the possibility 
of obtaining the best value for money for their contracts.’ 

60  TEC  is  a  method  of  testing  and  comparing  the  energy  performance  of  imaging  equipment  products,  which 
focuses on the typical electricity consumed by a product while in normal operation during a representative period 
of  time.  The key  criteria  of  the  TEC  approach for  imaging  equipment  is  a value for  typical  weekly  electricity 
consumption, measured in kilowatt-hours (kWh). The maximum TEC is calculated for each individual product 
and takes into account the product's size format, marking technology, and monochrome product speed. 
61 OM (Operational Mode) is a method of testing and comparing the energy performance of imaging equipment 
products, which focuses on product energy consumption in various low-power modes.  The key criteria used by 
the OM approach are values for low-power modes, measured in watts (W). 
62  Relates  to  network  connectivity,  mailbox  functionality,  job  queue  management,  machine  management, 
advanced graphic user-interface, ability to initiate communication with other host servers and client computers, 
ability to post-process pages. 
63https://www.energystar.gov/ia/partners/prod_development/revisions/downloads/img_equip/Draft_2_Version_2
_Imaging_Equipment_Specification.pdf?edd1-6b94 
64https://www.energystar.gov/ia/partners/prod_development/revisions/downloads/img_equip/Draft_2_TEC_Qual
ification_Rates.pdf?edd1-6b94 
65 Directive 2004/18/EC of the European Parliament and of the Council of 31 March 2004 on the coordination of 
procedures for the award of public works contracts, public supply contracts and public service contracts. OJ, 
L134, 30.4.2004, p. 114-235 

 
 
                                                 
More  detailed  provisions  permit  the  inclusion  of  environmental  requirements  in  technical 
specifications  (Article  23(3)b), the  use of eco-labels (Article 23(6)),  applying award criteria 
based on environmental characteristics (Article 53), etc.. The Directives thus offer a number 
of opportunities for GPP to be implemented, throughout the contract award process.  

Currently  GPP  criteria  for  imaging  equipment  are  being  drafted  and  published  for 
consultation.  The  criteria  relate  to  energy  efficiency  and  duplexing  as  well  as  design  for 
recycling and cartridge re-use, in line with ENERGY STAR requirements.66 

EU Ecolabel  

The EU Ecolabel67 is a voluntary label that helps identifying products and services that have a 
reduced  impact  on  the  environment  throughout  their  life  cycle,  from  the  extraction  of  raw 
materials to production, use and disposal.  

The draft Ecolabel criteria include requirements for energy, duplexing, N-printing, recycling 
and  re-use,  hazardous  substances,  indoor  air  pollution,  noise,  and  criteria  on  ink  and  toner 
consumables. The requirements on energy anticipate upcoming ENERGY STAR version 2.0. 
68   

2.2.3.  Third country mandatory/ voluntary legislative measures 

Japanese Top Runner 

The Top Runner approach identifies the most efficient product on the market and on the basis 
of its specifications, establishes energy efficiency requirements that all similar products must 
meet by a specified date.  

Copying machines became designated products for the Top Runner standard in 1999 with a 
target  year  2006.  During  this  period,  many  energy  saving  technologies  were  developed.  In 
2006 an improvement of 72.5% with respect of 1999 was reached (far beyond the originally 
anticipated improvement of 31.0%).69 No new targets have been set for dedicated copiers due 
to  the  fact  that  multifunctional  devices  took  over  the  market  while  the  number  of  shipped 
copiers was significantly reduced. 

Multifunctional devices and printers came in the scope of the Top Runner program in 2007. In 
that year, a calculation formula for target standard values was developed on the basis of the 
actual measurements of annual energy  consumption of these appliances.  The target year for 
the multifunctional devices and printers is 2017. 

Figures  8  and  9  show  that  the  Japanese  Top  Runner  targets  for  monochrome  and  colour 
imaging  equipment  for  2017  are  almost  in  line  with  what  is  expected  for  ENERGY  STAR 

66http://susproc.jrc.ec.europa.eu/imaging-equipment/docs/GPP%20Imaging  20Equipment%20IPTS%202nd%20 
revision_Clean.pdf 
67 Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on the EU 
Ecolabel. OJ L27, 30.1.2010, p. 1-19 
68http://susproc.jrc.ec.europa.eu/imaging-
equipment/docs/EU%20Ecolabel%20Criteria%20for%20Imaging%20Equipment%20legal%20text.pdf  
69  Final  report  by  Copying  Machine,  etc.  Evaluation  Standards  Subcommittee,  Energy  Efficiency  standards 
Subcommittee  of 
for  Natural  Resources  and  Energy.  Dec  2011. 
http://www.eccj.or.jp/top_runner/pdf/tr_copying_machines_etc_dec2011.pdf  

the  Advisory  Committee 

 
 
                                                 
version  2.0.  This  confirms  the  role  of  ENERGY  STAR  as  the  de  facto  standard  for  energy 
efficiency of imaging equipment. 

Figure 8: Target standard lines for monochrome imaging equipment (ENERGY STAR vs. Top Runner. 
source VHK70) 

Figure 9: Target standard lines for colour imaging equipment (ENERGY STAR vs. Top Runner. Source 
VHK) 

US ENERGY STAR programme 

The  U.S.  Environmental  Protection  Agency  (EPA)  introduced  the  ENERGY  STAR  label in 
1992  to  recognize  energy-efficient  computers.  Since  then,  the  label  has  grown  to  identify 

70 Source: Data analysis VHK, technical IA assistance to the Commission, 2012. 

 
 
 
 
 
 
                                                 
efficient products across more than 40 product categories and in more than 35 countries71. For 
office  equipment  (category  ‘Computers’)  a  distinction  is  made  between  computers,  displays 
and imaging equipment.  

The ENERGY STAR programme is a voluntary partnership between government, businesses, 
and purchasers designed to encourage the manufacture, purchase, and use of energy efficient 
products.  The  primary  objective  of  the  ENERGY  STAR  programme  is  to  make  it  easy  for 
buyers  to  identify  the  most  energy-efficient  products  in  the  marketplace  by  differentiating 
them with the ENERGY STAR mark. When the EPA and U.S. Department of Energy (DOE) 
set specifications for the specific products, they strive to recognize the top energy performers 
in the market  72 (Annex 4 gives more detailed information about when the specifications are 
set or changed). 

The main driver for industry participation in ENERGY STAR in the US is that meeting the 
ENERGY  STAR  requirements  is  a  mandatory  condition  for  procurement  by  the  US 
government and governmental institutions.  

2.2.4.  National voluntary initiatives in the EU Member States and third countries  

The  most  important  national  and  regional  voluntary  initiatives  regarding  the  labelling  and 
subsequent procurement incentives for imaging equipment are: 

Australian Voluntary Environmental Labelling Standard GECA: The primary purpose of this 
standard is to define environmental performance criteria for the most harmful environmental 
and human hazards of printers and fax machines placed on the Australian market and to use 
these criteria as indicators of general environmental performance of this product group. 73 

Nordic Swan: The Scandinavian Nordic Swan Ecolabel product definition and criteria refer to 
the  current  ENERGY  STAR  criteria  for  energy  consumption.  Other  criteria  relate  to  the 
design for reuse/disassembly/recycling and presence of hazardous/toxic substances.74 

Blue  Angel:  The  German  Blue  Angel  ecolabel  employs,  just  like  the  ENERGY  STAR 
programme,  limit  values  for  power  consumption  and  default  times  for  transition  between 
various power modes, but uses a more elaborate approach.75 

Umweltzeichen  of  Austria:  The  Austrian  Umweltzeichen,  ‘UZ  16’  Office  appliances  with 
print function, sets out criteria for energy consumption, emissions, paper and toner use. 76  

A more complete overview of national and regional voluntary initiatives in the EU and third 
countries is given in Annex 5. 

71 EU-27, Iceland, Norway, Liechtenstein, USA, Canada, Japan, Taiwan, Australia and New Zealand 
72http://www.energystar.gov/ia/partners/prod_development/new_specs/downloads/EPA_Oven_Announcement_
Memo.pdf?cd2b-9cc9 
73  Good  Environmental  Choice  Australia  (GECA)  May  2006:  Australian  Voluntary  Environmental  Labelling 
Standard for Printers, Faxes, and Multifunction Devices. 
74 For more information please see: Nordic Ecolabelling of Imaging equipment Version 5.3 14 June 2007 – 30 
June 2013 http://www.nordic-ecolabel.org/criteria/product-groups/  
75 For more information please see: Office Equipment with Printing Function (Printers, Copiers, Multifunction 
Devices), RAL-UZ 122  http://www.blauer-
engel.de/en/products_brands/search_products/produkttyp.php?id=333  
76 For more information please see: http://www.umweltzeichen.at/  

 
 
                                                 
2.3.  Market and regulatory failures 

As  mentioned  in  Chapter  2,  if  it  is  accepted  that  a  limited  level  of  market  imperfection  is 
unavoidable  there  are  no  major  ecodesign  problems  for  the  imaging  equipment  sector  in 
comparison to other product groups subject to ecodesign Regulations.  

In as much as market and/or regulatory failures for imaging equipment exist, according to the 
preparatory study they pertain mainly to the low-volume equipment in the consumer market 
and  less  to  the  professional  office  market,.  They  can  be  caused  by  the  fact  that  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  with  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).  

2.4. 

Subsidiarity 

The principle of subsidiarity as defined in Article 5 of the Treaty on European Union ensures 
that  decisions  are  taken  as  closely  as  possible  to  European  citizens.  Consequently,  EU 
Institutions  should  take  action  only  in  areas  which  fall  within  its  exclusive  competence  and 
which lead to a more effective action if the latter was taken at national, regional or local level. 
The production of imaging equipment is a global business with no EU players and Member 
States  are  fully  aware  that  requirements  regarding  the  placing  on  the  market  can  only 
effectively be realised at EU, if not at a global level. 

Legal basis for EU action 

2.5. 
The  Directive  2009/125/EC  (hereinafter  ‘Ecodesign  Directive’)77  establishes  a  legal 
framework for laying down ecodesign requirements for selected priority product groups.  

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

In accordance with Art. 15(6) and Annex II of the Ecodesign Directive a technical-economic 
analysis  shall  be  performed,  amongst  others  proposing  target  levels  based  on  the  available 
data at the time. 

Article 16 of the Ecodesign Directive provides the legal basis for the Commission to adopt an 
ecodesign Regulation for a chosen product group, while Article 19 provides for a regulatory 
procedure with scrutiny for the adoption of such a measure.  

77 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 OJ L 285/10, 31.10.2009   

 
 
                                                 
Recitals 18, 19 and Art. 15(3) of the Ecodesign Directive encourage the Commission to give 
priority  to  a  self-regulation  over  a  mandatory  measure,  if  the  former  is  likely  to  deliver  the 
policy objectives faster or in a less costly manner then the latter. 

According to Article 17 of the Ecodesign Directive, a valid voluntary agreement proposed by 
the  industry  must  comply  with  the  criteria  laid  down  in  Annex  VIII  to  the  Ecodesign 
Directive. 

An  ecodesign  self-regulation  meeting  the  conditions  stipulated  in  Annex  VIII  to  the 
Ecodesign  Directive  can  be  considered  a  valid  alternative  to  an  ecodesign  mandatory 
implementing  measure.  Consequently,  as  long  as  the  voluntary  agreement  meets  its 
objectives, the Commission may refrain from adopting an ecodesign implementing measure. 

If the monitoring and reporting performed under the voluntary agreement, or Member States 
or  stakeholders  indicate  distortions  in  the  functioning  of  the  voluntary  agreement,  the 
Commission  should  consider  proposing  ecodesign  mandatory  Regulation.  The  Commission 
may recognise valid VA in the form of a Commission Report to the European Parliament and 
the Council. (i.e. non-legislative act). 

3. 

DEFINING OBJECTIVES 

The  strategic  policy  context  has  been  addressed  in  par.  1.1.  Operational  objectives  that  are 
relevant for measures on imaging equipment in the context of ecodesign are: 

• 

• 

• 

a 20% energy saving in 2020 versus 1990, 

a 20% carbon emission abatement in 2020 versus 1990, 

promotion  of  non-energy  materials  resources  efficiency  through  amongst  others 
materials  reduction  (e.g.  paper),  recycling  (e.g.  of  larger  plastics  parts,  electronics, 
metals) and re-use (of toner cartridges). 

The  preparatory  study  stated  that  with  respect  of  the  2005  level  a  30%  electric  efficiency 
improvement  in  2020  was  cost-effective,  to  be  reached  through  mandatory  measures.  This 
conclusion is in line with what usually can be expected from mandatory ecodesign measures 
also  for  other  product  groups.  It  would  mean  that  in  a  ‘best  case  scenario’  and  a  continued 
increase in market penetration of the equipment, the absolute EU energy consumption in 2020 
would remain at the 2005 level. The preparatory study did not provide energy efficiency data 
for 1995.  

The additional 2012 research by the Commission based on new data that came available after 
the conclusion of the preparatory study filled in the 1995 data  and showed that the ambition 
level  can  be  significantly  higher.  More  specifically,  new  information  indicated  that  if  the 
positive trend –based on voluntary measures– continues, a 60% energy saving over the 2012-
2020 period is realistic. This means a 2020 target value of 1.5-2 TWh electricity consumption, 
i.e. an electricity saving of 90-95% over the policy reference period 1990-2020 is realistic.  

For automatic duplexing and N-printing a realistic target is that in a few years over 90% of 
typical office printers (speed >19 ipm for colour; >25 ipm for monochrome) will have both 
features. A further penetration of duplexing in the consumer market (below the given speeds) 
may be expected, but –given the low printing volume—add relatively little in terms of savings 
for 2020.  

 
 
4. 

IDENTIFYING POLICY OPTIONS  

This Chapter describes five policy options that will be considered in this impact assessment. 

Option 1: No EU action 

Option 2: Self-regulation 

Option 3: Mandatory energy labelling Regulation 

Option 4: Mandatory ecodesign Regulation 

Option 5: Combined ecodesign Regulation and energy labelling Regulation 

4.1. 

Option 1: No EU action 

This option means that the EU will not engage in any new measures.  

Furthermore,  ‘No  EU  action’  also  means  that  the  Commission  does  not  accept  the  VA 
concluded by the imaging equipment industry and thus still considers the option of mandatory 
action beyond (ambitious) criteria proposed in the VA. As has been argued in the introduction 
of the ‘baseline scenario’ (par. 2.1) this creates a high level of uncertainty and a considerable 
risk that the on-going positive trend of energy efficiency improvements will slow down, stop 
or  may  well  be  reversed.  Specifically,  there  is  a  possibility  that  R&D  spending  on  energy 
efficiency,  as  part  of  the  total  R&D  budget,  can  be  reduced,  e.g.  in  favour  of  aesthetics, 
gadgets or minor performance features. Manufacturers, which are all extra-EU multinationals, 
can  decide  not  to  introduce  on  the  EU  market  their  most  energy  efficient  models78. 
Furthermore, in a worst-case scenario, the EU-US co-operation could fall apart with negative 
repercussions on the current global harmonisation in test procedures and requirements. 

To calculate the effect  of  this scenario the baseline  scenario from the preparatory study has 
been assumed.  

4.2. 

Option 2: Self-regulation 

This option means that the Commission will continue relying on the self-regulation and will 
accept  the  VA  as  a  guarantee  for  continuation  of  the  current  trend  and  will  refrain  from 
mandatory  actions  under  Directives  2009/125/EC  and  2010/31/EU  as  long  as  the  policy 
targets are met. The terms of the final VA are given in Annex 9. 

In  short:  the  energy  efficiency  and  duplexing  requirements  relate  to  the  current  ENERGY 
STAR requirements version 1.1 and commitments that by 1 January 2012, 90% of models of 
Signatories will meet those requirements. Signatories cover over 90% of the EU market. 

Design for recycling and re-use of cartridges are new items in the VA, i.e. they are not part of 
ENERGY STAR v. 1.1 but anticipate requirements of the new v. 2.0.  

Section  11  of  the  VA  states  that  a  revision  of  the  VA  will  take  place  3  months  after  the 
publication  of  a  new  version  of  the  ENERGY  STAR  programme  requirements.  The 

78 This has happened before and often for reasons that seem far less important. For instance, the COM (2011)337 
mentioned  that  as  much  as  60%  of  manufacturers  are  expected  to  drop  out  of  the  EU  ENERGY  STAR 
programme if third-party certification would become mandatory. 

 
 
 
                                                 
Commission, assisted by a Regulatory Committee will decide whether the ambition level and 
others terms and conditions of the revised VA are acceptable, following consultations with all 
stakeholders (including NGOs and industry) in the Consultation Forum framework79.  

It was understood between parties that a revised VA would adhere to the continuation of the 
progress in recent years. Chapter 3 explains the target values that pertain to this policy option. 

These ambitious targets that go far beyond what was considered possible in the preparatory 
study, can be found in achievements seen in previous years: 

• 

• 

Over  the  1995-2005  period,  industry  reached  an  electricity  saving  of  at  least  60-65%, 
i.e. for the EU the electricity consumption for imaging equipment was reduced from 27 
TWh/a in 2005 to around 9-10 TWh/a in 2020 (see also par. 2.2.3.Top Runner). 

Over the 2005-2012 period, strictly following voluntary measures, a further reduction of 
electricity consumption was reached of 60-65% with a drop to 3.5 TWh in 2012. This 
was  achieved  not  only  through  90%  of  models  complying  with  ENERGY  STAR 
version 1.1 (as assessed in the context of the VA) but also by the fact, as shown by the 
2012 additional analysis,  that the average compliant model outperformed the minimum 
ENERGY  STAR  energy  efficiency  requirements  by  43%.    (see  Annex  7)  Over  the 
2005-2012  period,  the  share  of  typical  office  models  with  automatic  duplexing  rate 
increased from an estimated 65% in 2005 to 80-90% in 2020. Duplexing rates for 1990-
1995 are not available (see Annex 7). 

• 

Overall, over the period 1995-2012 an energy saving of 87% was reached, which results 
in an average efficiency improvement of over 6% annually.  

Hereafter the second and third points are illustrated with some main outcomes of the analysis 
of the ENERGY STAR database in February 2012. A full explanation is given in Annex 7.  

Typical Energy Consumption (TEC) 

The  ENERGY  STAR  methodology  for  the  efficiency  of  mainly  EP  imaging  equipment 
distinguishes  four  TEC  classes:  TEC  3  and  4  cover  monochrome  and  colour  MFDs 
respectively;  TEC  1  and  2  cover  other  imaging  equipment  (copiers,  printers,  fax  machines 
etc.)  with  monochrome  and  colour  output  respectively.  All  TEC  classes  use  a  standard  size 
paper format and the energy performance is determined through a duty cycle. 

Figure 10 shows how the registered EP models in the EU ENERGY STAR database (n=2612) 
score against the minimum requirements of ENERGY STAR version 1.1 for the various TEC 
classes. The minimum requirement is set at 100% and efficiency classes with a bandwidth of 
10% were distinguished. For example an efficiency class ’10-20%’ means that these models 
consume  80  to  90%  less  energy  than  the  ENERGY  STAR  limit.  The  models  in  the  class 
‘>100%’ were not in the database; they constitute 10% of the total (ca. n=290).   

Under the terms of the VA, over 90% of products comply with the ENERGY STAR version 
1.1  means  that  still,  10%  of  products  is  not  included  in  the  database  and  thus  an  additional 
column was added to the graph below representing the percentage of products that are outside 
the  VA  and  assumed  to  be  above  the  maximum  TEC  value.  With  a  sample  size  of  2 612 

79 Article 18 of the Ecodesign Directive. 

 
 
                                                 
products  representing  90%  of  the  market,  the  10%  outside  the  scope  represent  around  290 
products. 

Number of products per efficiency class 

s
t
c
u
d
o
r
P
f
o
r
e
b
m
u
N

450

400

350

300

250

200

150

100

50

0

Outside Energy Star

TEC 1

TEC 2

TEC 3

TEC 4

0-10% 10-20% 20-30% 30-40% 40-50% 50-60% 60-70% 70-80% 80-90% 90-100% >100%

Percentage of max. TEC

Figure 10: Number of product per energy efficiency class  

The results in figure 10 are not weighted for the specific energy consumption. For example it 
might  well  be  that  the  best  models  pertain  to  low-volume/low  speed  imaging  equipment, 
whereas most high volume equipment that has the highest environmental impact is very close 
to  the  limit.  To  take  that  into  account,  an  analysis  was  made  of  the  print-speeds  (which 
determine the print volume in the ENERGY STAR metric) within each TEC class. The results 
are shown in figure 11 below.  

Electricity use distribution
Based on EU Energy Star database (Feb 2012), number of models (n=2612) weighted by specific TEC 
energy value, subdivided by product speed in ipm

25%

20%

15%

10%

5%

0%

0-10%

10-20%

20-30%

30-40%

40-50%

50-60%

60-70%

70-80%

80-90%

90-100%

TEC 1

TEC 2

TEC 3

TEC 4

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

2%

1%

0%

0%

4%

2%

2%

2%

3%

2%

2%

2%

3%

3%

6%

5%

5%

4%

5%

2%

2%

4%

12%

2%

0%

3%

15%

0%

0%

6%

Figure 11: Overall electricity use distribution 

The  results  from  figure  11  are  slightly  less  favourable  than  those  in  figure  10,  However,  as 
mentioned above, this indicates that the average energy efficiency of the models is over 40% 
better than the ENERGY STAR limit. This is not exactly a sales weighted outcome but it is as 
close as data allows and given the large number of models it is estimated to be accurate.  

Duplexing and OM (operational mode) 

Similar  to  the  TEC  improvement,  the  OM  and  duplexing  rate  also  show  potential  for 
significant savings. More detailed information on the ENERGY STAR requirements is given 
in Annex 6. 

 
 
 
 
 
 
For  OM  products  the  ENERGY  STAR  v.1.1  requirements  sets  maximum  power  values  for 
standby-mode  (1  Watt),  sleep-mode  (between  1.4  -  30  W  depending  on  OM  class)  and 
‘functional  adders’80  like  interface  (e.g.  wired,  wireless,  infrared)  and  storage  (e.g.  CCFL 
lamps,  memory,  cordless  handset).  On  average  the  EU-registered  products  are  also  35% 
below the levels. The best products perform 85% better than the maximum requirement. 

4.2.1.  Main elements of the VA proposed by the industry 

At the Consultation Forum meeting (of 12 October 2009), the imaging equipment industry has 
presented a proposal for a VA (self-regulation) aiming at limiting the power consumption of 
imaging  equipment  placed  on  the  EU  market.  The  proposal  for  the  agreement  has  been 
amended  on  the  basis  of  comments  received  from  the  Commission  and  stakeholders.81  The 
VA version 3.5, of 15 February 2011 has already been signed and has entered into force and 
thus it already generates savings. 

80  A  functional  adder  is  a  standard  product  feature  that  adds  functionality  to  the  base  marking  engine  of  an 
imaging  equipment  product.  The  Operational  Mode  portion  of  this  specification  contains  additional  power 
allowances for certain functional adders. Examples of functional adders include wireless interfaces and scanning 
capability. 
81 The most recent version of the voluntary agreement is v3.5 from 15 February 2011 

 
 
                                                 
Scope 

The VA applies to imaging equipment defined as in ENERGY STAR v.1.1. ENERGY STAR 
distinguishes  the  Typical  Electricity  Consumption  (TEC)  products  and  Operational  Mode 
(OM) products. TEC products are standard-size copiers, Multifunction Devices (MFDs), and 
printers that use Electrophotography (EP), Solid Ink (SI), and High Performance Ink Jet (IJ) 
marking  technologies,  OM  products  cover  the  remainder  of  mainly  non  high-performance 
inkjet products (see par. 2.1 for exemptions). 

Signatories 

Currently  there  are  seventeen  Signatories82  to  the  VA,  including:  Brother  International 
Europe,  Canon,  Dell,  Epson,  HP,  Kodak  Limited  (UK),  Konica  Minolta  Business  Solutions 
Europe,  KYOCERA  Document  Solutions  Europe  B.V.,  Lexmark  International,  Murata 
Machinery  Europe,  OKI  (UK)  Ltd.,  Panasonic  Europe  Ltd.,  Ricoh  Europe  PLC,  Samsung 
Electronics  Europe,  Sharp  Electronics  (Europe)  GmbH,  Toshiba  TEC  Germany  Imaging 
Systems and Xerox. The current Signatories to the VA account for more than 90% of the total 
EU market for imaging equipment, which exceeds the agreed limit83. 

As required by Annex VIII to the Ecodesign Directive, the voluntary agreement remains open 
to the participation of other companies.  

Requirements 

The  requirements  laid  down  in  the  VA  are  based  on  the  ENERGY  STAR  programme 
requirements  (v.1.1).  The  VA  will  be  revised  in  2013  to  be  brought  in  line  with  the  new 
ENERGY STAR programme requirements (v.2) to enter into force in 2013. 

Each signatory to the agreement committed itself that at least 90% of its products placed on 
the  EU  market  (regardless  of  their  origin)  will  comply  with  the  minimum  efficiency 
requirements formulated in TEC and OM84. Furthermore, all products should comply with to 
the requirements on duplexing rates, recycling and use of cartridges.  

Administrative bodies 

The VA establishes two administrative bodies:  
o 

The  Steering  Committee  consists  of  the  representatives  of  the  Signatories  to  the 
agreement  and  the  European  Commission.  The  representatives  of  the  EU  Member 

82 www.eurovaprint.eu   
83  The  Directive  requires  that  signatories  to  the  agreement  must  'represent  a  large  majority  of  the  relevant 
economic  sector'.  In  its  explanatory  document  on  voluntary  agreements  concluded  under  the  Ecodesign 
Directive (EDWB 2010 Doc03), the Commission specified that to consider an agreement as valid, the proven 
market share must be at least 70%. 
84  Signatories  shall  submit  to  an  Independent  Inspector  reports  based  on  compliance  with  the  Voluntary 
Agreement  (the  ‘Reports’)  according  to  the  guidelines  in  Section  6  of  the  VA  (see  also  Annex  9).  Individual 
companies  will  work  towards  the  fulfilment  of  the  compliance  rate set  out  in  section 4.1  of the  VA.  In  case  a 
Signatory  fails  to  meet  the  compliance  rate, actions will  be  taken,  depending  on  the  level  of  non-compliance: 
underachieving<=5%  Signatory  has  6  months  to  achieve  the  targets  and  status  will  be  set  to  Defaulting 
Signatory,  underachieving  >5%  discussion  Signatory  and  the  steering  committee  to  develop  a  suitable  way 
forward and status will be set to Defaulting Signatory. If the Signatory does not comply within the set deadline 
as agreed with the Steering Committee, the Signatory shall be deemed not to take part any more in the Voluntary 
Agreement and shall be deleted from the list of Signatories.   

 
 
                                                 
States,  EFTA/EEA  countries  and  NGOs  have  a  status  of  observers.  The  Committee 
manages  the  agreement.  The  Committee  is  to  meet  at  least  twice  per  year  and  its 
meetings  are  open  to  any  person  who  represents  a  legitimate  stakeholder.  The 
Committee is to seek to achieve agreement by consensus at all times. 
The  Independent  Inspector  plays  a  crucial  role  in  the  process  of  monitoring  the 
application  of  the  agreement.  'ERA  Technology  Ltd'  has  been  chosen  to  act  as  the 
Inspector85. 

o 

4.2.2.  Assessment of the VA proposed by the industry against the criteria of Annex VIII to 

the Directive 

According  to  Article  17  of  the  Ecodesign  Directive,  voluntary  agreements  and  other  self-
regulation presented as alternatives to ecodesign mandatory Regulations shall be assessed on 
the basis of nine criteria laid down in Annex VIII to the Directive:  

1. 

2. 

3. 

4. 

5. 

openness of participation,  

added value,  

representativeness (market coverage),  

quantified and staged objectives,  

involvement of civil society (transparency and dissemination of information),  

6.  monitoring  and  reporting,  cost-effectiveness  (no  disproportionate  administrative 

burden),  

7. 

8. 

sustainability (meet policy objectives in this respect),  

incentive compatibility (consistency with other policy measures).  

Therefore,  before  proceeding  to  the  comparison of  the  expected  impacts  of  this  option  with 
the impacts of other viable options, an analysis of these criteria has been performed. This is 
reported in Annex 11. The VA fulfils the criteria for a valid voluntary agreement laid down in 
Annex VIII.  

4.3. 

Option 3: Mandatory energy labelling Regulation 

This  option  would  include  the  mandatory  energy  efficiency  labelling  of  imaging  equipment 
consisting of seven efficiency classes established under the Energy Labelling Directive86. 

This option would imply the following benefits of the labelling: 

• 

it  could  allow  comparison  on  gradual  scale  and  would  help  consumers  to  make  cost 
effective purchasing decision by addressing running costs,  

85 The independent third party designated by the Steering Committee (on behalf of all Signatories) and who is 
tasked with, and responsible for, the collection and processing of information supplied by Signatories pursuant to 
Section  6  and  Annex  B,  and  determining  a  Signatory’s  compliance  with  the  Agreement  in  accordance  the 
Commitments. The Steering Committee shall engage the services of the Independent Inspector upon terms and 
conditions that shall require undertakings of confidentiality from the Independent Inspector, and which shall also 
set out any requirements or applicable mechanisms for a process of appeal, in case this is ever be necessary 

86 Directive 2010/30/EU of the European Parliament and of the Council of 19 May 2010 on the indication by 
labelling and standard product information of the consumption of energy and other resources by energy-related 
products  OJ L 153/1 18.6.2010 

 
 
                                                 
• 

it  could  increase  the  compliance  rate.  However,  given  that  the  latest  tests  of  office 
equipment  showed  a  95%  compliance  rate  with  self-certification,  the  additional  gains 
are expected to be minimal87.  

Drawbacks for energy labelling: 

• 

A difference between the seven energy scales would be very close, what – coupled with 
the measurement tolerances — might have a negative effect on the credibility of such a 
scheme.  

•  Mandatory  Regulations  might  affect  agreements  between  the  US  Environmental 
Protection  Agency  and  the  European  Commission  about  the  use  of  ENERGY  STAR 
programme,  because  it  is  necessary  that  the  ENERGY  STAR  programme  and  the 
ecodesign scheme are consistent and coordinated.  

• 

• 

New  testing  requirements  in  the  energy  labelling  Regulation  would  add  at  least  one 
month to the process of product registration. 

The cost of product registration would increase, in a way that would unevenly impact 
different market operators.88  

It is therefore concluded that a policy option that relies only on energy labelling will not be 
optimal.  This  is  in  line  with  conclusion  of  COM  (2011)337.  Energy  labelling  besides  the 
agreement  will  be  time  consuming  and  will  increase  the  administrative  burden  for  the 
manufactures. Therefore, this option is discarded from further analysis. 

4.4. 

Option 4: Mandatory ecodesign Regulation  

This  option  aims  at  improving  the  environmental  performance  of  imaging  equipment  by 
laying down mandatory minimum efficiency requirements for their power consumption. 

Article 15(5) of the Ecodesign Directive requires that an ecodesign Regulation must meet the 
following criteria: 

a) 

b) 

c) 

d) 

e) 

there shall be no significant negative impacts on the functionality of the product, from 
the perspective of the user, 

health, safety and the environment shall not be adversely affected, 

there  shall  be  no  significant  negative  impact  on  consumers  in  particular  as  regards 
affordability and life cycle cost of the product, 

there shall be no significant negative impacts on industry’s competitiveness, 

in principle, the setting of an ecodesign requirement shall not have the consequence of 
imposing proprietary technology on manufacturers, 

f) 

no excessive administrative burden shall be imposed on manufacturers. 

87 COM(2011) 337 final Communication from the Commission on the implementation of the ENERGY STAR 
programme in the European Union in the period 2006 – 2010 
88 For this market segment, feedback received from two major manufacturers indicates a 30% increase in the cost 
of product registration. COM(2011)337 final 

 
 
                                                 
In  general  an  ecodesign  Regulation  could  be  an  effective  measure  because  it  is  largely 
independent  on  consumers  and  market  behaviour  and  takes  the  worst  performing  products 
from the market.  

The  biggest  disadvantage  of  a  mandatory  Regulation  vis-à-vis  an  effective  voluntary 
agreement is that its ambition level is typically very much lower. By definition, a Regulation 
requires  not  90%  compliance,  like  a  VA,  but  100%  compliance.  This  may  seem  more 
ambitious, but in practice this is highly questionable. The ‘missing’ 10% difference between a 
VA  and  a  Regulation  usually  concerns  the  special  products  with  specific  functionality  that 
will have trouble in meeting stringent requirements and/or it concerns products marketed by a 
few financially weak companies for which even modest investments might be problematic. In 
other words, in order not to come into conflict with Article 15(5) regarding the requirement of 
‘no negative effect’ on e.g. functionality or industry competitiveness, this 10% will drag down 
the ambition level for the whole product group considerable, i.e. by much more than 10%.  

It  is  concluded  that  this  policy  option  is  valid  and  thus  it  will  be  further  analysed  and 
compared with other valid options in Chapter 5. 

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

4.5. 

Option 5: Combined mandatory ecodesign and energy labelling Regulations 

This option foresees the adoption of the ecodesign and energy labelling Regulations. 

As stated above, an ecodesign Regulation could be an effective measure, because it is largely 
independent  on  consumers  and  market  behaviour  and  could  take  the  worst  performing 
products off the market.  

However, as concluded above, the energy labelling will be time consuming and will increase 
the administrative burden for manufacturers.  

It is therefore concluded that this option is discarded from further analysis. 

4.6. 

Policy options proposed 

Given the previous paragraphs the options considered in the impact analysis are as follows: 

• 

• 

'Baseline' (Business As Usual, hereinafter 'BAU') that follows the preparatory study;  

'Voluntary', assuming that the combination of the current measures (ENERGY STAR, 
GPP, etc.) and mainly the voluntary agreement proposed by the industry will allow for 
maintaining the pace of improvements at a level above ENERGY STAR requirements89; 

• 

'Mandatory'  (ecodesign)  assuming  the  adoption  of  a  mandatory  ecodesign  Regulation.

89 For details see Annex 6 

 
 
   
                                                 
The  technical  and  market  data  on  the  ENERGY  STAR  programme  and  the  voluntary 
agreement that supports the analysis of the proposed options is provided in Annex 6.  

5. 

ANALYSIS OF IMPACTS  

The  aim  is  to  describe  for  each  option  the  associated  environmental,  economic  and  social 
impacts  related  to  achieving  compliance  with  the  applicable  requirements,  while  avoiding 
negative  impacts  on  industry’s  competitiveness  and  product  functionality.  This  assessment 
includes impacts on manufacturers, including SMEs. 

This chapter compares impacts of the options per aspect, including: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

energy saving and security of supply, 

paper consumption (duplexing), 

greenhouse gas emission reduction, 

customer economics and affordability, 

business economics and competitiveness, 

employment, 

health, safety and other environmental aspects, 

technology, functionality and innovation, and 

administrative burden (including monitoring and reporting). 

Starting point of the analysis was the preparatory study, which was the basis for the ‘BAU’ 
scenario. Sales data of the preparatory study is used in the stock model to calculate the stock, 
electricity consumption and paper consumption for all the options.  

Additional  analysis  was  performed  on  the  models  registered  in  the  EU  ENERGY  STAR 
database  at  www.eu-energystar.org.  It  showed  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 (see Annex 6). This assessment showed not only the number of models compliant with 
ENERGY  STAR  requirements  version  1.0,  1.1  (on  which  the  current  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  it  revealed  also  how  much  better  these  models  scored  with  respect  of  the 
ENERGY STAR minimum requirements.  

The results of this assessment are shown in the Voluntary scenario. It is assumed under this 
scenario that a voluntary agreement will allow for maintaining the pace of improvements at 
the levels above the ENERGY STAR requirements (as in previous years). More details of this 
option are provided in par. 4.2 and in Annex 10.  

The  third  option  is  ‘Ecodesign’  that  lays  down  minimum  mandatory  efficiency  requirement 
for  imaging  equipment  placed  on  the  market.  More  details  of  this  option  are  given  par.  4.5 
and in Annex 10.  

 
 
5.1. 

Energy saving and security of supply 

The  table  and  figure  below  shows  the  direct  electricity  consumption  of  the  imaging 
equipment, the indirect energy consumption (calculated as electricity equivalent) to produce 
paper and total energy consumption (direct + indirect) of the BAU and two other options. 

Table 4: Energy consumption of IE for BAU, Voluntary and Ecodesign scenario in TWh (electricity 
equivalent) for EU-27 

BAU (preparatory study) 
Direct (TWh) 

Indirect (TWh) 

Total (TWh) 

Voluntary 
Direct (TWh) 

Indirect (TWh) 

Total TWh) 

Ecodesign 
Direct (TWh) 

Indirect (TWh) 

Total (TWh) 

1995 

2000 

2005 

2010 

2015 

2020 

2025 

2030 

27.01 

23.42 

50.43 

27.01 

23.42 

50.43 

1995 

27.01 

22.33 

27.74 

50.07 

22.33 

27.74 

50.07 

2000 

22.33 

11.97 

33.14 

45.11 

9.04 

33.14 

42.18 

2005 

11.97 

8.67 

38.77 

47.44 

3.54 

36.67 

40.21 

2010 

8.67 

8.69 

40.89 

49.58 

1.56 

34.67 

36.23 

2015 

6.98 

9.13 

42.75 

51.88 

1.22 

35.62 

36.84 

2020 

3.57 

9.74 

44.43 

54.18 

1.27 

37.03 

38.29 

2025 

3.83 

10.40 

46.99 

57.39 

1.33 

39.16 

40.49 

2030 

4.08 

23.42 

27.74 

33.14 

38.77 

39.69 

36.21 

37.03 

39.16 

50.43 

50.07 

45.11 

47.44 

46.68 

39.78 

40.85 

43.24 

Direct energy consumption 

Option Ecodesign saves approximately 5.6 TWh in 2020 and 6.3 TWh/a in 2030 compared to 
BAU (61% savings). Option Voluntary saves some 7.9 TWh/a in 2020 compared to BAU and 
9.0 TWh/a in 2030 compared to BAU (87% savings).  

The most remarkable outcome of research 2012 is that the electricity consumption of imaging 
equipment  covered  by  the  voluntary  agreement  is  around  40%  better  than  the  minimum 
requirement according to ENERGY STAR v. 1.1. 

Indirect energy consumption 

This  product  group  consumes  also  a  lot  of  indirect  energy  as  can  be  seen  in  the  paper 
consumption.  

The  table  above  shows  the  paper  consumption  of  imaging  equipment  products  per  unit  per 
year,  according  to  the  different  duplexing  rates  and  the  electricity  equivalent  of  the  energy 
that  is  required  to  produce  that  paper  for  all  imaging  equipment  in  the  EU.  The  number  of 
prints  is  assumed  the  same  for  each  year  and  the  only  change  is  in  the  duplexing  rate, 
following ENERGY STAR requirements90.  

90 ENERGY STAR v.1.0 in 2005 (baseline see also Chapter 2.1.4), ENERGY STAR 1.1. in 2009 and ENERGY 
STAR 2.0 in 2013 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
For  the  BAU  a  duplexing  rate  of  65%  is  used  as  already  explained  in  Chapter  2  and  an  N-
printing possibilities of 15% is used for all the options. The Voluntary scenario is linked with 
the  ENERGY  STAR  requirements  concerning  duplexing.  The  analysis  of  the  research  2012 
(Annex 6) has been used to calculate the duplex rates. This resulted in 78% duplexing in 2009 
and 85% in 2013. The Ecodesign scenario follows the BAU till 2014 where besides energy 
efficiency  requirements  also  requirements  for  duplexing  are  set.  In  2014,  75%  of  imaging 
equipment products has to have duplexing capabilities and in 2016 this has to be 85%. 

The table above shows paper savings in 2020 of 17% in the case of the Voluntary scenario 
compared to the baseline what results in an energy saving for paper production equivalent to 
around 7.1 TWh/year in electricity.91The above estimate should be treated with caution. The 
calculation  is  based,  as  was  the  baseline  calculation,  on  the  paper  output  for  an  average 
product. Differentiation and weighting by print speed (images per minute ipm) and the related 
non-linear increase of paper output would result in a higher share of duplexing. On the other 
hand, an unknown share of images printed by a duplex printer may still be single-sided and 
this would have a more unfavourable effect on the duplexing figures presented above.  

EU-27 Energy consumption total TWh/year

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

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

 -

1990

1995

2000

2005

2010

2015

2020

2025

2030

2035

Year

Figure 12: Total energy consumption IE per scenario for EU-27 in TWh per year 

5.2. 

Greenhouse gas emission reduction 

Table 5: CO2 emissions of imaging equipment per scenarios in Mt (eq.) for EU-27 

1995 

2000 

2005 

2010 

2015 

2020 

2025 

2030 

12.56 
3.51 
16.07 

9.60
4.16
13.76

5.03
4.97
10.00

3.56
5.82
9.37

3.43
6.13
9.57

3.47 
6.41 
9.88 

3.51 
6.66 
10.17 

3.54
7.05
10.58

BAU (preparatory study) 
Direct (Mt) 
Indirect (Mt) 
Total (Mt) 

Voluntary 

91 Note that the actual production energy for paper is made up for the most part by fuels (fossil and biomass), but 
the  electricity  equivalent  is  used  to  make  the  indirect  energy  savings  from  paper  savings  comparable  to  the 
direct electricity savings from the unit  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Direct (Mt) 
Indirect (Mt) 
Total (Mt) 

Ecodesign 
Direct (Mt) 
Indirect (Mt) 
Total (Mt) 

12.56 
3.51 
16.07 

9.60
4.16
13.76

3.80
4.97
8.77

12.56 
3.51 
16.07 

9.60
4.16
13.76

5.03
4.97
10.00

1.45
5.50
6.95

3.56
5.82
9.37

0.62
5.20
5.82

2.76
5.95
8.71

0.46 
5.34 
5.81 

1.36 
5.43 
6.79 

0.46 
5.55 
6.01 

1.38 
5.55 
6.93 

0.45
5.87
6.33

1.39
5.87
7.26

The picture for greenhouse gas emissions is similar to that of the electricity consumption. The 
estimated  CO2  emissions  savings  in  2020  for  the  Voluntary  scenario  is  4.07  Mt  CO2 
equivalent  compared  to  the  BAU  and  are  higher  than  savings  to  be  achieved  under  the 
ecodesign option. 

EU-27 CO2 emissions in Mt-year

16,07 

13,76 

BAU (preperatory study)

Voluntary

Ecodesign

10,00 

9,37 

8,77 

6,95 

9,57 

8,71 

5,82 

10,00

6,80

5,81  5,89 

10,58

7,26
6,33

t

M

s
n
o
i
s
s
i

m
e
2
O
C

 18,0

 16,0

 14,0

 12,0

 10,0

 8,0

 6,0

 4,0

 2,0

 -

1990

1995

2000

2005

2010

2015

2020

2025

2030

2035

Year

Figure 13: Total CO2 emissions of imaging equipment per scenarios in Mt (eq.) for EU-27 

5.3. 

Customer economics and affordability 

The VA is an extra guarantee for a continuation of the on-going trend; hence no impacts of 
measures on the consumer prices are expected as a consequence of the VA in the ‘Voluntary’ 
scenario.  In  the  Ecodesign  scenario,  the  progress  in  energy  efficiency  and  other  features  is 
less significant than in the ‘Voluntary’ scenario and thus no higher production-costs, and also 
no higher purchase prices, could be expected from the measures. 

5.4. 

Business economics and competitiveness proofing 

The impact of the two options on the turnover and investment costs of stakeholders is small. 
There are no significant investments needed and the price level can be maintained.  

The main difference between the baseline scenario and policy scenarios such as the voluntary 
agreement  is  not  in  an  absolute  investment  level,  but  in  the  way  the  customary  R&D 
investments – typically 3.6 to 8.7%92 of turnover in this sector — are spent. The agreement 
indirectly  ensures  that  the  industry  remains  committed  to  R&D-spending  on  energy  saving 
and  environmentally  friendly  features.  Without  the  agreement  the  industry  might  decide  to 
invest  more  in  aesthetics  or  other  commercial  gadgets  appealing  to  customers.  Likewise, 

92 Annual report Xerox in 2010, R&D investment 3.6% of turnover, Annual report 2011 Canon R&D investment 
8.7%, Annual report Ricoh 2011 R&D investment 5.7%   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
invest  continuously 

improving 
companies 
rationalisation,  automation  and/or  employing  low-cost  labour.  The  agreement  indirectly 
ensures that the gain from this activity – for example 2% per year is spent in paying for the 
extra energy features while keeping consumer prices more or less constant.  

lowering  production  costs 

through 

in 

5.5. 

Competitiveness proofing (CP)  

CP  is  a  possible  element  of  the  Impact  Assessment.  Commission  Staff  Working  document 
SEC (2012) 009193 describes ‘Competitiveness proofing’ as ‘a complementary instrument to 
reinforce the overall assessment of economic impacts of a new proposal with a better account 
of impacts on enterprise competitiveness at sector and aggregate level by identifying, and – 
where  proportionate  –  by  quantifying  the  likely  impacts  of  the  new  proposal  in  three 
dimensions  of  enterprise  competitiveness,  i.e.  costs,  capacity  to  innovate  and  international 
competitiveness [of the European industries].’  

However,  the  same  source  also  states  that  ‘In  the  case  of  policy  interventions  of  a  self-
regulatory nature (such as codes of conduct, or voluntary standards), the case for an in-depth 
analysis of impacts on sectorial competitiveness is likely to be limited since the sector itself 
plays a key role in determining the content of the initiative’.  

For the products in the scope of the agreement or other considered options, the need for an in-
depth competiveness proofing is further weakened by the fact that there are neither EU owned 
manufacturers nor any mainstream product manufacturing activities on EU27-soil by non-EU 
companies.  The  EU27  hosts  the  administrative  headquarters,  physical  distribution  facilities, 
sales offices and other commercial activities of non-EU companies as well as some of their 
research  and  development  (R&D)  activities,  technical  support,  manufacturing  of  spare  parts 
and auxiliaries.  

It is concluded that a more in-depth competitiveness proofing in this case is not necessary. 

5.6. 

Territorial impact 

Territorial impact assessment (TIA) is one of the possible elements of the impact assessments. 
As  stated  in  a  recent  presentation  of  the  Commission  services94,  TIA  is  only  required  when 
the policy explicitly targets a (type) of a region and/or the policy targets some regions or areas 
more than others. In the case of the ecodesign policy for imaging equipment, these conditions 
do not apply and thus the TIA is not appropriate.  

5.7. 

Employment 

Actual  manufacturing  of  mainstream  imaging  equipment,  part  production  and  assembly  of 
imaging equipment could not be identified according to the preparatory study and the research 
2012.  Therefore  any  negative  impact  of  product-oriented  measures  can  be  excluded. 
Geographically the industrial employment is concentrated in the Netherlands (many European 
HQs, Océ R&D, total ca. 6 000 jobs) and other EU Member States like Germany, UK, France 
and  Italy  with  each  1  000-3  000  jobs  partitioned  to  imaging  equipment.  In  the  remaining 

93 http://ec.europa.eu/governance/impact/key_docs/docs/sec_2012_0091_en.pdf  
94 Dijkstra, Lewis (European Commission, DG Regio), “Assessing territorial impacts as part of the general 
impact assessment guidelines, presentation ESPON Workshop, 6 June 2012. 
http://www.espon.eu/export/sites/default/Documents/Events/Workshops/TerritorialImpactAssessment062012/Le
wis_Dijkstra_DG_REGIO_Presentation.pdf   

 
 
                                                 
Member States the employment rate is at the level of 100-500 jobs, mainly depending on the 
size  of  the  national  markets  and  -  to  a  lesser  degree  -  the  geographical  focus  of  individual 
manufacturers.95  

5.8. 

Technology, functionality and innovation 

The implementation of the Ecodesign and particularly Voluntary scenario would not have a 
negative  impact  on  the  functionality  of  the  equipment.  Linking  the  agreement  with  the 
ENERGY  STAR  programme  reduces  the  electricity  consumption  of  imaging  equipment 
without a need for additional changes to the technology or functionality.  

Health and safety  

5.9. 
The  preparatory  study  addresses  the  health  issues  briefly.  Studies  published  by  BGfA96  and 
BfR97  prove  that  emission  levels  are  below  the  maximum  amounts  of  indoor  emission 
levels98. Modern printer designs, especially the smaller devices produce little or no ozone.99 
No  impacts  of  the  considered  options  on  health  or  safety  have  been  identified  during  the 
impact assessment. 

5.10.  Administrative burden 

Voluntary scenario 

In the case of the Voluntary scenario, the monitoring will be performed by the Commission 
assisted  by  the  Committee  referred  to  in  Article  19  of  the  Ecodesign  Directive  and 
stakeholders. This monitoring will be performed on the basis of the reports submitted by the 
Independent  Inspector  who  will  be  assessing  the  compliance  of  the  Signatories  with  the 
agreement.  For  that  reason,  the  Inspector  will  collect  and  aggregate  the  data  from  the 
individual  Signatories  in  accordance  with  Annex  G  to  the  agreement.  Member  States 
authorities will not be obliged to perform market surveillance actions. Furthermore, Member 
State market surveillance authorities will have access upon request to the background data in 
order to verify the compliance. Per Member State, the cost of extra hours of workload for the 
Ecodesign  Regulatory  Committee  (and  possibly  the  EU  ENERGY  STAR  Board)  in 
evaluating the annual monitoring reports and propositions for new VA target levels may be in 
the same order of magnitude, including market surveillance. 

The administrative burden per individual manufacturer to participate in the VA is estimated in 
the order of € 5000- 10 000 as a contribution in the costs for e.g. the Independent Inspector 
and attending meetings of the Steering Committee.  

95 In this context it should be considered that all manufacturers are non-EU companies and basically all go where 
the market is. There may be some peak local interests because of local companies that have been taken over in 
the more recent past, but on the long run these historical local interests tend to disappear  
96 German Research Institute for Occupational Medicine of the Institutions for Statutory Accident Insurance and 
Preven 
97 German Federal Institute for Risk Assessment 
98 All studies show that copiers and printers mainly emit VOCs to the ambient air during operation. However, the 
measured  indoor  air  concentrations  are below  the  currently  valid  occupational  limit  values  for  the  respective 
single substances approximately by the factor 100 to 1,000. Thus, almost all of the measured concentrations lie 
within the background exposure of the average population. 
99  Criteria  and  emission  levels  are  discussed  more  extensively  in  the  Green  Public  Procurement  (GPP)  and 
Ecolabel  studies  by  DG  JRC  and  IPTS.  Development  of  European  Ecolabel  and  Green  Public  Procurement 
Criteria for Imaging Equipment; Jiannis Kougoulis, Renata Kaps, Oliver Wolf 

 
 
                                                 
As  a  conclusion,  the  Voluntary  scenario  will  not  significantly  increase  the  administrative 
burden  of  the  actors  involved.  For  more  information  on  monitoring  and  reporting  under  the 
agreement, see Chapters 4.2.3 and 7. 

Ecodesign scenario 

In the case of the Ecodesign option, the administrative burden will be higher than in the case 
of the Voluntary scenario as the verification of the compliance of imaging equipment with the 
applicable  requirements  will  wholly  relay  on  the  national  authorities.  The  administrative 
burden of Member States for mandatory measures would probably be similar to that of other 
ecodesign  measures,  i.e.  in  the  order  of  €  0.5  million  initial  costs  for  setting  up  the  legal 
framework  plus  –per  Member  State–  the  costs  of  continuous  market  surveillance,  including 
spot  checks.  The  costs  of  the  latter  will  depend  on  the  overall  budget  that  each  individual 
Member  State  is  willing  to  spend  on  surveillance.  Assuming  e.g.  testing  of  50-100 
models/year in total by the Member States, the testing and reporting costs will be in the area 
of € 0.25 – 0.5 million annually. 

The  costs  of  mandatory  measures  for  industry  will  depend  on  the  exact  modality  of  the 
requirements.  If  it  involves  mandatory  third-party  certification,  it  can  be  expected  that 
manufacturers will diminish their EU catalogue to save costs100. At the moment (Sept. 2012) 
there  are  5111  different  imaging  equipment  models  registered  in  the  EU  ENERGY  STAR 
database. These represent more than 90% of the market and thus 10% should be added. On 
the other hand, probably also 10% of the registered models are out of scope. So this means 
that around 5000 models should undergo third-party testing.  

As a rough estimate, assuming that for bulk-testing it will be possible to find test-houses that 
will  charge  €  2000,-/model  an  initial  market  transformation  would  require  €  10  million. 
Subsequently, assuming that a model stays in the catalogue for 4-5 years, the costs would be € 
2 to € 2.5 million/year. Compared to the estimated turnover of the industry (say 50% of the 
market size of € 5 billion, see p. 7) this is 0.1%.  

Note that the € 2000,- is estimated on the basis of the costs for other products that undergo 
simple duty cycle testing (e.g. ‘white goods’).  

5.11. 

Impact on trade 

The  requirements  proposed  in  this  report  are  based  on  a  technical,  environmental  and 
economic analysis. The process for establishing requirements for imaging equipment has been 
transparent.  Competitive  disadvantages  for  EU  manufacturers  exporting  imaging  equipment 
to third countries are not expected. The ENERGY STAR programme on which the agreement 
is based, is also applicable in many non-EU economies101 and thus in all these countries the 
same criteria apply (see Annex 8). 

5.12. 

Summary  

The  following  table  summarizes  the  findings  of  the  savings  in  2020  and  2030  and  the 
accumulative  savings  2011-2020  and  2011-2030.  The  projections  between  2020  and  2030 

100 As an illustration: COM (2011)337 predicts that 60% of manufacturers will drop out of the EU ENERGY 
STAR program if third-party testing becomes mandatory.  

101 Norway, Iceland, Liechtenstein, US, Japan, Canada, Taiwan, Australia and New Zealand 

 
 
                                                 
 
have  some  degree  of  uncertainty,  as  already  mentioned  in  the  sales  and  stock  paragraph  in 
Chapter  2,  and  for  this  a  simple  extrapolation  of  the  sales,  electricity  consumption,  CO2 
emissions and electricity costs savings have been used. 

Table 6: Summary of the savings generated by imaging equipment under different options compared to 
the baseline BAU for 2020 and 2030. (The monetary savings are expressed in constant 2010 Euro.) 

Total savings (Direct and Indirect paper energy excl. toner) 2020  
Versus Baseline 

Voluntary 

Ecodesign 

2020 

2011-2020 

2020 

2011-2020 

Energy consumption (TWh) 
Direct  
Indirect 
Total 

CO2 emissions (Mt) 
Direct  
Indirect 
Total 

Costs saving excl. toner (in bln. Euro) 102 
Direct  
Indirect 
Total 

7.9 
7.1 
15.0 

3.0 
1.1 
4.1 

2.11 
7.12 
9.24 

71.2 
59.2 
130.4 

27.0 
8.9 
35.9 

16.2 
59.2 
75.4 

5.6 
6.5 
12.1 

2.1 
1.0 
3.1 

1.5 
6.5 
8.0 

26.0 
24.9 
50.9 

7.9 
3.7 
11.6 

6.4 
24.9 
31.3 

Total savings (Direct and Indirect paper energy excl. toner) 2030  
Versus Baseline 

Voluntary 

Ecodesign 

2030 

2011-2030 

2030 

2011-2030 

Energy consumption (TWh) 
Direct  
Indirect 
Total 

CO2 emissions (Mt) 
Direct  
Indirect 
Total 

Costs saving excl. toner (in bln. Euro) 75 
Direct  
Indirect 
Total 

9.1 
7.8 
16.9 

3.1 
1.2 
4.3 

3.6 
7.8 
11.4 

156.7 
134.0 
290.7 

57.5 
20.1 
77.6 

44.7 
134.0 
178.7 

6.3 
7.8 
14.1 

2.1 
1.2 
3.3 

2.5 
7.8 
10.3 

85.66 
99.70 
185.36 

29.2 
15.0 
44.2 

26.3 
99.7 
126.0 

Note  that  in  the  table  above,  the  baseline  is  a  reference  point  to  compare  the  two  policy 
options, but may have some limitations as mentioned in paragraph 2.1. For the assessment of 
the contribution of options to the policy objectives, notably the ‘20-20-20’ target in 2020 with 
respect to 1990, the options have to be compared not to a baseline, but to the status quo in the 

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

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
 
reference  years  1990-1995.  Also  the  restrictions  in  data  reliability  should  be  taken  into 
account.  

Still, the conclusions on electric efficiency improvements are robust: The voluntary scenario 
can be expected to make a contribution of at least 25 TWh direct electricity saving (0.9 % of 
EU27  end-use  electricity  consumption  in  2007)  and  thus  9.5  Mt  CO2  of  greenhouse  gas 
emissions  (0.2%  of  EU27  total  in  2007).  The  Ecodesign  scenario,  i.e.  mandatory  measures, 
will deliver an estimated 2.5 TWh less, i.e. around 22.5 TWh and 8.6 Mt CO2. 

For  the  savings  on  paper  consumption,  it  has  to  be  taken  into  account  that  the  scenario 
calculations  –both  in  the  preparatory  study  and  in  the  baseline  presented  in  Chapter  2—are 
based  on  the  ENERGY  STAR  duty  cycle,  which  is  typical  of  the  US  practice.  In  the  EU, 
however, the average paper use per capita is significantly (30-40%) lower than in the US. It is 
not known with certainty that this also applies to the office paper market and thus ENERGY 
STAR  duty  cycle  was  chosen  as  at  least  a  robust  reference  point.  But  anecdotal  evidence 
based  on  CEPI  industry  statistics  also  seem  to  suggest  that  consumption  of  office  paper 
(mostly UWF cut-size grade) in the EU is some 40% lower than in the US. As a result, also 
the absolute savings will probably be 40% lower.  

As a result, it is cautiously estimated that duplexing and N-printing will contribute to savings 
of  around  1  million  tonnes  (1  Mt)  of  office  paper.  This  is  an  estimated  15-17%  of  the 
(lowered) estimated total EU office paper consumption and 1,25% of the total EU paper and 
cardboard consumption.  The mandatory  Ecodesign scenario is expected to score worse than 
the Voluntary scenario in this respect, but the inaccuracy of available data does not allow a 
quantitative differentiation. A saving of 1 Mt paper causes an indirect primary energy saving 
equivalent to 4 TWh electricity and 0.6 Mt CO2. 

6. 

COMPARING THE OPTIONS  

Following the principle of proportionality in the analysis effort, the policy options: 'No new 
EU  action',  'Mandatory  energy  labelling  Regulation'  and  'Combination  of  mandatory 
ecodesign Regulation and energy label Regulation' were discarded at an earlier phase of the 
analysis.  

The analysis of option 'Voluntary' shows that this option optimally fulfils the objectives laid 
down in Chapter 3. As described in Chapter 4.2.3 it also meets the criteria of Annex VIII to 
the Ecodesign Directive. Recital 18, 19 and Article 15(3) of the Ecodesign Directive state that 
the priority shall be given to a self-regulation over a mandatory Regulation, if the former is 
likely  to  deliver  the  policy  objectives  faster  or  in  a  less  costly  manner  then  the  latter.  The 
analysis shows that this is the case in the imaging equipment sector.  

The main reasons for which the Ecodesign option is not preferable over the Voluntary option 
are:  

• 

• 

It generates lower savings than the Voluntary option (see Chapter 5); 

It  does  not  provide  flexibility  in  introducing  new,  more  stringent  requirements.  In 
particular, a review and revision of the Ecodesign Regulation every three years, like in 
the case of the ENERGY STAR criteria (see Annex 6) is highly unlikely.  

 
 
• 

Costs  of  monitoring  the  compliance  of  imaging  equipment  with  the  applicable 
requirements  (mainly  costs  of  the  market  surveillance  performed  by  national 
authorities) will be significantly higher than under the Voluntary option. 

•  Mandatory  Regulation  might  affect  agreements  between  the  US  Environmental 
Protection  Agency  and  the  European  Commission  about  the  use  of  ENERGY  STAR 
programme (see Chapter 4.3). 

• 

As  is  also  explained  in  COM  (2011)337,  the  dynamics  of  this  product  sector  is  much 
larger than the dynamics that can reasonably be expected for mandatory measures and 
the  flaws  in  the  preparatory  study,  which  was  certainly  not  worse  than  many  other 
studies of its kind, are an ulterior proof.  

Furthermore, the Voluntary option implies: 

• 

• 

• 

• 

• 

• 

• 

• 

a  contribution  to  the  ‘20-20-20’  target  over  the  1990-2020  period  of  25  TWh/a  direct 
electricity saving through efficiency improvement and the equivalent of approximately 
4 TWh/a electricity saving through indirect paper resources saving, making a total of 29 
TWh/a (compare: 1,1 % of the EU’s total electricity consumption in 2007); 

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

a contribution to non-energy resources efficiency policy of over 1 million tonnes (1 Mt) 
reduced  office  paper  consumption  over  the  1990-2020  period  and  a  contribution  to 
recycling and re-use.  

that the requirements of the Ecodesign Directive 2009/125/EC, and in particular Recital 
18 and Annex VIII are met, 

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

that there is no significant administrative burden for stakeholders, 

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

no significant impacts  on  the  competitiveness of the industry and employment, and in 
particular in the SMEs sector due to the small absolute costs related to product re-design 
and re-assessment. 

7. 

MONITORING AND EVALUATION 

The procedure for monitoring and reporting under the voluntary agreement is as follows: 

• 

• 

The  Steering  Committee  will  continuously  follow  progress  and  results  of  the  VA  and 
agree on practicalities, such as the collecting of the data from the individual Signatories 
by  ERA.  The  Steering  Committee  will  include  the  Signatories  of  the  VA  and  will  be 
opened to outside stakeholders (as observers).  

Signatories  will  annually  submit  to  the  Commission  a  report  through  the  independent 
third-party.  For  quantified  objectives  the  report  will  include  detailed  figures  based  on 
agreed  measurement  methods.  The  first  reporting  period  started  in  January  2011  and 
ends  in  June  2011.  In  line  with  the  provisions  of  the  draft  VA,  by  the  latest  30  June 
2011 each signatory shall provide the applicable information to the independent third-

 
 
party. The independent third-party will then have 3 months to aggregate the results and 
present them to the Commission and stakeholders. 

The members of the Consultation Forum will be consulted to take stock and monitor the 
results  of  the  VA.  Member  States  wishing  to  verify  the  reported  information  will  be 
granted access on demand to the background data and on that basis will be able perform 
products checks/tests. 

The  Commission,  assisted  by  the  Ecodesign  Regulatory  Committee  (in  its  advisory 
capacity),  will,  in  the  light  of  the  received  reports  and  input  from  the  Consultation 
Forum, consider whether the objectives of the VA are met. The Commission will give 
special attention to the reporting and monitoring obligations laid down in the Ecodesign 
Directive, existing Commission guidelines and in the agreement itself. In particular, the 
Commission  will  regularly  assess  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 
meeting by the latter its objectives. 

If the Commission considers that the VA failed to achieve its objectives it will consider 
proposing a mandatory Regulation instead.103. 

No significant impacts on the competitiveness of industry, and in particular SMEs. 

No  market  surveillance  is  needed  due  to  the  annual  reports  produced  by  Independent 
Inspector and the possibility to do annual analysis of the EU-ENERGY STAR database. 

• 

• 

• 

• 

• 

103 The environmental ‘cost’ of regulating later, at a failure of the VA, instead of now are believed to be limited. 
The  underlying  impact  assessment  shows  that  current  voluntary  progress  in  the  field  of  energy  saving  is 
significant,  promises  to  continue  and  exceeds  what  is  expected  to  be  reached  through  mandatory  minimum 
requirements. Should such progress come to an un-anticipated stop, the monitoring mechanisms in place should 
signal this trend. Given the fact that the parameters to be regulated as well as the relevant test and calculation 
methods  are  in  place,  the  design  of  a  mandatory  ecodesign  measure  should  be  possible  within  a  limited 
timeframe of 1.5 to 2 years.        

 
 
                                                 
Annex Table of contents 

Annex 1 Steering committee meetings....................................................................................................48 

Annex 2 Recycling and reuse of paper and ink.......................................................................................58 

Annex 3 Manufacturers in ENERGY STAR database............................................................................59 

Annex 4 EPA...........................................................................................................................................62 

Annex 5 Ecolabels...................................................................................................................................63 

Annex 6 ENERGY STAR analysis.........................................................................................................64 

Annex 7 Research 2012...........................................................................................................................75 

Annex 8 ENERGY STAR countries .......................................................................................................84 

Annex 9  Voluntary agreement ...............................................................................................................83 

Annex 10 Scenario data.........................................................................................................................106 

Annex 11 Compliance VA criteria (art. 17)..........................................................................................105 

 
 
ANNEX 1  

STEERING COMMITTEE MEETINGS 

1st Steering Committee Meeting 

16 June 2011 

Meeting Minutes  

Voluntary  Industry  Agreement  to  Improve  the  Energy  Consumption  of  Imaging 
Equipment under the EuP Directive  

Table of Contents 

Meeting Details………………………………………………………………………………  3 

Agenda…………..……………………………………………………………………………  3 

Date and Venue………………………………………………………………………………  3 

Agreement of the Agenda…………………………………………………………………   

Status and next steps towards official endorsement…………………………………   

4 

4 

Formal Commitments……………………………………………………………………… 

4  

Legal Entity and Management…………………………………………………………… 

Invitation to Tender………………………………………………………………………… 

Publication of an FAQ……………………………………………………………………… 

5 

5 

5 

Q&A Session………………………………………………………………………………....  6 

Next Steps………………………………………………………………………………….....  7  
List of Participants of the 1st lot 4 VA Steering Committee…… 

7  

Meeting Details 

Agenda 

1.  Introduction 

2.  Status and next steps towards official endorsement 

a.  Status of industry signatures 

3.  Electing of a Chair and Secretary of the Steering Committee 

4.  Organization of VA operations 

5.  Legal entity 

a.  Selection of an Independent Inspector 

6.  Publication of an FAQ for clarifications on VA commitments and operations 

7.  Next Steps – Steering Committee Meeting  

 
 
 
 
 
 
 
 
 
 
8.  Q&A session  

9.  Conclusions  

Date and Venue 
June 16, 2011  
DIGITALEUROPE 
Rue Joseph II, 20 
B-1000, Brussels 
Belgium 

Agreement of the Agenda 
The agenda was agreed. 

Status and next steps towards official endorsement  

A background on how the VA was created and developed was given by Pierre Sicsic (HP). 
On the basis of the Commission’s final report published in May 2009, the Consultation Forum 
decided  in  October  2009  that  a  VA  would  be  the  appropriate  tool  to  address  this  product 
category  already  covered  by  ENERGY  STAR.  It  was  felt  that  the  new  VA  would  provide 
more visibility to the ENERGY STAR in Europe and reduce free riding. It was estimated that 
this VA would reduce the annual energy consumption of imaging equipment in the EU from 
ca. 11 TWh to between 5 and 6 TWh in 2020. 

Following intense consultation with stakeholders, a final version of the VA was presented in 
the 
February  2011  after  which 
implementation.  

the  Commission  recommended 

to  start 

industry 

Overall, the 17 companies signing up to this  VA represent more than 96% of the European 
market.  

Mr.  Truszczynski  reported  that  the  European  Commission  is  fully  supportive  of  industry’s 
proposed VA as it represents a valid alternative to regulation, having a quasi-legal status. To 
this  end,  a  message  from  DG  ENER  Head  of  Unit  was  sent  to  the  members  of  the 
Consultation  Forum  in  March  2011,  informing  that  the  Commission  would  refrain  from 
regulating this specific product group and inviting industry to implement the VA.  

Mr.  Truszczynski  informed  that  the  impact  assessment  is  due  to  be  finalized  in  the  coming 
months  and  that  the  inter-service  consultation  would  follow  in  autumn  2011.  On  this  basis, 
Mr. Truszczynski further added that the Commission’s formal endorsement could be expected 
by the end of the year. The VA Signatories expressed their hope that the VA would have the 
same legal ground of a regulation in the framework of the Ecodesign Directive.  

Mr.  Arditi  from  EEB  expressed  satisfaction  with  industry’s  proposed  VA  as  it  integrates 
recommendations from NGOs and Member States, and ensures good market coverage.  

Formal Commitment  

Participants were made aware that implementation has  already  started, with  signatures  from 
the different companies being collected.  

 
 
 
 
 
An  overview  of  industry’s  commitments  in  sales  unit  in  the  EU27  between  01/10/2011  and 
31/03/2012 was provided. Regarding requirements for cartridges, a question was raised as to 
whether it would be possible to clarify these in a FAQ.  

Legal Entity and Management  

Mr. Sicsic provided an overview of the operational structure of the VA.  

As regards the Steering Committee, it was clarified that each signatory to the Agreement, as 
well as the European Commission, shall have the right to nominate one person to represent it 
at the Steering Committee. Also, the Steering Committee shall elect, amongst its members, a 
Chair. Meetings of the Steering Committee shall be open to:  

-  Any person representing a Signatory or potential signatory to agreement,  

-  Any  representatives  of  the  European  Commission  or  Member  States,  as  well  as 

member states of the EEA or EFTA, and 

-  Organizations that have a permanent seat on the Consultation Forum 

It was pointed out that companies not able to attend the meetings could be represented with a 
proxy.  

A legal entity (Newco) would be established as a not-for-profit association under the Belgian 
Law. Newco would represent the VA Signatories and have a seat at the Steering Committee. 
Possible names for Newco are currently being evaluated. A launch event is planned after the 
summer. 

Invitation to Tender  

Participants  were  informed  that  an  invitation  to  tender  was  sent  on  18  May  2011  with  a 
request for proposals to be submitted by 10 June. It was noted that so far three proposals have 
been  received  (Fraunhofer  IZM,  ERA  and  BIO  Intelligence  Service).  Mr.  Sicsic  further 
informed  that  tenders’  evaluation  would  be  finalized  by  end  of  June  and  followed  by  a 
recommendation to the Signatories.  

Among the tasks of the Independent Inspector would be to aggregate the information from the 
Signatories, make it anonymous and report about companies’ compliance rate to the Steering 
Committee.  Additionally,  the  Independent  Inspector  would  issue  a  report  in  October  2011 
which  would  represent  the  reference  baseline  for  the  Signatories.  The  report  will  cover 
aggregated sales figures of the first six months of 2011. 

Publication of an FAQ 

A guideline document would cover the following subjects and questions: 

-  Legal basis of the VA 

-  Market context 

-  Product scope, definitions 

-  Objectives, targets, timeline 

 
 
-  Automatic duplex implementation 

-  Environmental information 

-  Demonstration of compliance 

It  was  pointed  out  that  the  FAQ  guideline  would  be  a  living  document  to  be  published  on 
DIGITALEUROPE’s website until the launch of a dedicated website. 

Q&A session 

A question as to whether a dedicated email reflector for the Lot 4 VA would be created was 
raised. Mr. Sicsic replied that the main documents would be uploaded to the CIRCA website.  

Regarding non-compliant models, it was asked whether they would be communicated so as to 
orient consumers’ choice. Mr. Sicsic replied that ENERGY STAR requirements already allow 
distinguishing among products and that EPEAT would be implemented as well.  

Regarding section 9, it was asked whether the only obligations to refer to are those mentioned 
in section 4.1.  

Clarification was provided with regard to non-compliant companies and the reasoning behind 
the fact that, in case of non-compliance, these companies would be given the chance to first 
achieve  the  basic  requirements  and  then  to  step  up.  Mr.  Arditi  mentioned  that  this  scenario 
should not become an industry strategy.  

It  was  mentioned  that  new  versions  of  the  ENERGY  STAR  should  not  be  disregarded. 
However, it was pointed out that there will be a delay between ENERGY STAR and the up-
grade of the VA. The aim of ENERGY STAR is to trigger innovation to improve products. 
This  frontrunner  approach  is  to  be  respected,  thus  the  upgraded  ENERGY  STAR  versions 
cannot be applied to all products immediately. 

It was further mentioned that it would be appreciated if clear requirements for dismantling the 
equipment would be provided.  

Regarding the use of recycled parts, the wish was expressed that the next version of product 
declaration might contain the percentage of recycled parts in order to show the dynamic of the 
VA. 

The  chair  drew  the  attention  to  the  fact  that  there  have  been  and  there  will  be  direct  and 
indirect discussion with all stakeholders about their expectations. Mr. Sicsic mentioned that so 
far a standard for the recycled contents does not yet exist. Should there be one, industry would 
be ready for discussion.  

The  role  of  the  Independent  Inspector  was  questioned  with  regard  to  the  data  verification 
process. It was clarified that information is provided by default in annex C, and that for the 
purpose of clarification and upon request, industry is prepared to provide information as per 
annex B. It was requested by some stakeholders that the Independent Inspector should have 
the  power  to  undertake  random  audits.  It  was  clarified  that  the  Independent  Inspector  only 
performs an audit when there is obvious non-compliance. The chair pointed out that there is a 
good  basis  for  market  surveillance  since  there  are  verified  ENERGY  STAR  products  being 
certified by third parties. There was one claim that third party certification may not always be 
reliable. Signatories underlined that the US verification requirements are very strict and that 
laboratories are all accredited.  

 
 
Next steps 

It was agreed that the next Steering Committee meeting would be convened on 7 December 
2011 (at 14.30 – 17.00 CET).  

List of participants  

Stephane Arditi / EEB 
Valentina Bolognesi / DIGITALEUROPE 
Wolfram Buchroth / Konica Minolta Europe 
Tracey Rawling Church / Kyocera Mita 
William Dazy / Canon 
Marie-Hélène Dubray / Panasonic 
Sylvie Feindt / DIGITALEUROPE 
Maxime Furkel / Lexmark 
Detlef Hagemann / German Machine Tool Builders’ Association  
Wolfgang Hahn / DIGITALEUROPE 
Hiromitsu Hatano / Ricoh Europe PLC 
Yasuhiro Jingu / Toshiba Tec 
Nicole Kearney / Defra 
Stephen Kimber / Brother 
Karsten Lindloff / German Energy Agency 
Sara Rodriguez Martinez / HP 
Peter McGregor / OKI 
Pascale Moreau / Epson 
Tom Moriarty / Dell 
Jonathan Murray / DIGITALEUROPE 
Milena Presutto / ENEA 
Claire Schonbach / Xerox 
Pierre Sicsic / HP 
Bram Soenen / Belgian Federal Government  
Laura Spengler / Okopol 
Jacek Truszczynski / European Commission  
Dierk Ulken / Toshiba Tec 
Frank Weyler / Muratec 

 
 
 
ErP Lot 4 VA – Second Steering Committee meeting  

Brussels, 7 December 2011, 10h00  

Meeting minutes  

Participants  

Name   Company  
Stephane Arditi   EEB  
Boncho Bonchev Republic of Bulgaria   
Wolfram Buchroth Konica Minolta  
William Dazy Canon   
Marie-Helene Dubray Panasonic   
Maxime Furkel Lexmark   
Emilien Gasc   ANEC/BEUC   
Hiro Hatano Ricoh Europe  
Sharon Heyman Sharp   
Yasuhiro Jingu Toshiba TEC   
Remy H. Kadirbaks Kyocera Mita   
Nicole Kearny    UK Department for Environment, Food and Rural Affairs  
Declan Keegan   Epson   
Stephen Kimber Brother  
Christoph Mordziol  Rationelle Energienutzung bei Elektrogeräten und  Beleuchtung  
Karsten Lindloff   German Energy Agency  
Boris Manev Epson   
Peter McGregor Oki  
Christoph Mordziol German Federal Environment Agency   
Chris Robertson  ERA  
Sara Rodriguez Martinez  HP  
Adam Romanowski  EC  
Feriel Saouli  EuroVAprint ASBL  
Claire Schonbach   Xerox  
Pierre Sicsic  HP  
Andy Skarstein   ERA  
Bron Soenen   Belgium Federal Government  
Frank Weyler   Murata Machinery Europe  

Apologies   
Greg Batts   Kodak   
Milena Presutto   Enea  
Bill Skeates Samsung  
Mark Sweeney Environment and Green Technologies Dept. Enterprise Ireland   

 
 
 
  
  
  
    
 
 
 
1.   Update from EuroVAprint (Sara Rodriguez Martinez)  

• Explain the process to date.  

An association (EuroVAprint ASBL) has been created in October 2011 to serve as a legal and 
administrative framework for the Signatories to abide by the requirements of the VA.   

The founding members are Canon, Epson, Hewlett Packard, Lexmark, OKI and Xerox.  

The  Board  members  are:  Canon,  Epson,  Hewlett  Packard,  Lexmark  and  Xerox  (the 
association is not allowed to have the same number of Directors and members).  

The President is Sara Rodriguez-Martinez (Hewlett Packard)  

The Secretary is William Dazy (Canon)  

The Treasurer is Maxime Furkel (Lexmark)  

All 17 Signatories are in the process of acquiring membership in EuroVAprint. Their market 
coverage is around 96%.  

The Board launched a call for tender to select an association management company.  

Cambre  Associates  SPRL  (www.cambre  -associates.com)  was  awarded  the  contract  in 
November 2011.  

 • Choice of ERA as Independent Inspector  

A call for tender was issued in May and three proposals were received. ERA Technology Ltd 
(www.era.co.uk) was awarded the contract in November 2011.  

 2.  Update from the European Commission (Adam Romanowski)  

•  After  the  October  2009  Consultation  Forum  (CF),  industry  took  on  board  a  lot  of 
stakeholders’ comments. The VA was deemed to be acceptable under the requirements of the 
Ecodesign  Directive.  The  VA  also  had  relevance  in  terms  of  market  coverage  –  one  of  the 
requirements of the Directive (art. 8).  

• The impact assessment will start in January 2012 by external consultants – The process to 
assess the technical, economic and social impact of the VA) should take about 2-3 months. If 
the outcome is positive, the College of Commissioners will formally approve it in the form of 
a Commission Recommendation (mid 2012 draft, possibly adopted, published in Series C of 
OJEU in summer).  

• The VA will therefore be considered as a viable alternative to implementing measures under 
the  Ecodesign  Directive.  In  other  words  the  European  Commission  will  not  regulate  this 
particular product group.  

•  A  Regulatory  Committee  will  assist  the  European  Commission  in  monitoring  the 
implementation of the VA – if the VA fails to meet its set objectives, then an implementing 
measure (IM) will have to be adopted.  

 
 
 
• This VA (and the cSTB104 VA) is not meant to cover every aspect of the industry.  

Flexibility  is  expected  from  the  European  Commission  as  well  as  from  other  stakeholders. 
There is a need to ensure smooth implementation and transparency on both sides. Industry has 
to prove that it can self -regulate responsibly.  

•  A  revision  of  the  imaging  equipment  VA  may  be  initiated  sometime  mid-2012  at  the 
earliest.  

 Q&A  

• Flemish environmental agency: is there a Regulatory Committee set up under the Ecodesign 
Directive for this VA? The European Commission: the EC will be assisted by the Regulatory 
Committee will decide whether the VA meets its objectives. Once the  

Commission  has  data  from  the  Independent  Inspector,  Member  States  will  be  invited  to 
decide, together with the Commission, whether implementation is on track or not. A meeting 
(possibly joint with the cSTB VA) will look at the first reporting period (timing: April/May 
2012).  

•  The  Impact  assessment  and  the  Commission  Recommendation  will  be  published  on  the 
same day in the OJEU.  

• UK (DEFRA) asked about the timing of version 2.0 ENERGY STAR specifications?   

• BEUC/ANEC requested an email distribution list be set up for non -industry stakeholders, as 
is  the  case  with  the  cSTB  VA.  EuroVAprint  indicated  its  intention  to  create  a  website  (see 
actions below).  

• EEB asked how Commission and Member States’ recommendations could be integrated in 
further discussions.  

 Actions  

• EuroVAprint President to send copies of the signatures (Annex G of the VA) to European 
Commission.  

• EuroVAprint Secretary General to set -up e-mail reflector for the SC members  and a  

section on the website where people can ask to be contacted to receive more information.  

3.  Update from ERA (Chris Robertson and Andy Skarstein)  

• Please refer to attached presentation.  

• The role of ERA is to provide impartial technical advice.  

• Examples of recent ERA work – some RoHS compliance for the UK government (guidance 
& enforcement), European Commission (RoHS 2 medical devices in categories 8-9).  

• Also help industry with compliance issues.  

104 Impact assessment already drafted – bottleneck: signatures. More advanced than the imaging equipment VA. 

 
 
                                                 
Baseline report process  

• The terms & conditions were signed and came into force on 22 November 2011.  

• 13 NDAs have been returned to ERA, 4 to go. Delays were due to compressed timescale.  

•  ERA  suggested  each  company  makes  sure  the  signatory  of  the  compliance  report  has  the 
authority to sign/commit on behalf of the company  (compliance manager/director at least?).  

Data collection (Andy Skarstein)  

• Annex C– the form was sent to all 17 Signatories. Some companies have not been able to 
return data so quickly.  

• Confidentiality: only Chris Robertson and Andy Skarstein will have access to the data. Andy 
Skarstein will generate the report, which he will send to EuroVAprint in an anonymized and 
aggregated report.  

• Within 3 months, VA Signatories to submit data.  

• Within 4 months, annual progress report to be issued by ERA.  

• ERA will use a random numbering system (Company A, etc.) that will change over time to 
make it impossible to identify companies.  

Q&A  

•  Flemish  EPA:  should  Annex  C  not  be  adapted?  No,  as  some  answers  are  Y/N,  not 
compliance rates.  

• Annex C should be cleaned up to reflect that section 3 only applies to requirements after 1 
January  2012  (although  clarified  later  in  section  5).  Consider  drafting  a  style  change  for 
further clarification.  

• Failure to comply with Part II means failure to comply with the entire VA, which applies to 
all products sold from 1 January 2012.  

 Actions  

• EuroVAprint to discuss clarification to Annex C, section 3 and report conclusions at the next 
Steering Committee  

• Claire Schonbach to add a definition of ‘new model’ as a style change  

 Timing & next steps  

•  The  first  baseline  report  will  be  sent  to  the  Steering  Committee  by  20  December  2011, 
pending all the data are sent by Signatories by then.  

• According to the European Commission, similar discussions  are taking place in the context 
of the cSTB VA, highlighting the need to find a balanced solution to sometimes conflicting 
interests  of  the  industry,  Member  States,  and  other  stakeholders,  without  breaching 
confidentiality agreements. The report should be submitted by ERA to EuroVAprint who will 
then forward it to the Steering Committee within 5 working days.  

 
 
• It is in the interest of all parties that a consistent approach is worked out for all Vas under 
the  Ecodesign  Directive.  The  suggestion  was  made  to  link  this  to  the  ENERGY  STAR 
database. EuroVAprint indicated that no decision had been made yet. NGOs argued that some 
alignment was necessary between cSTB and Imaging equipment VAs.  

Action:  

• This will be further discussed with the European Commission.    

• BEUC/ANEC suggested the setting up of a database of compliant products under this VA, 
which would go further than the ENERGY STAR database. EuroVAprint noted that products 
carrying the ENERGY STAR logo can be presumed to be compliant with the VA.   

Action  

•  EuroVAprint  to  add  text  in  the  FAQ  about  how  consumers  can  tell  whether  a  product  is 
compliant.  

• The European Commission suggested that the Independent Inspector could take the initiative 
to prepare a table with data they need for the purposes of data verification/auditing, and how 
such reporting should be presented. It was established that data verification is currently out of 
ERA’s remit.  

• On which basis cans ERA objectively run audits? No answer other than random checks was 
proposed.  

• Transparency means credibility – without full transparency, the sector will need regulating. 
It  is  in  industry’s  best  interest  to  minimize  unclear  sections/leave  less  room  for 
interpretation/doubt.  

• The Commission has drafted a document on how it understands the VAs (dated 12 March 
2010): the paper includes informal guidance on monitoring, reporting, procedure etc.   

Action  

• European Commission to share this document with ERA (as it has already been shared with 
the CF)  

•  BEUC/ANEC  raised  the  issue  that  the  VA  does  not  foresee  automatic  auditing.  There 
ensued a discussion about how audits were run in the US for Energy Star products.  

ANEC/BEUC insisted that they had requested this  clause  in  the  months  before  the  VA  was 
signed. In their view this calls for a change in the text of the VA.  

o  The  European  Commission  acknowledged  that  no  automatic  auditing  clause  was  to  be 
found  in  VA  3.5.  However,  Adam  Romanowski  proposed  that  for the  sake of  transparency, 
one audit per reporting period would make sense. Companies would be chosen randomly.   

o Budget should be earmarked to provide for such audits – even though not “automatic” under 
the VA. The SC can mandate an audit, but the Independent Inspector first needs to have funds 
available to run that audit upon request.  

Action  

 
 
• Adam Romanowski to send VA guidance note to the SC  

4.  Discussion on introducing a procedure to add ‘style changes’ into the VA  

• At the suggestion of the European Commission, and after a discussion within the SC, it was 
agreed  that  EuroVAprint  will  collect  all  style  changes  suggested  by  the  SC  members  and 
circulate a  comprehensive  version in advance of  the  last  SC  meeting  of  the  year,  where  the 
changes will be discussed and approved.  

• This will only apply to style-related changes that do not affect the content of the VA.  

Q&A  

•  There  was  a  discussion  about  the  relevant  market  share  (80%  at  least,  otherwise  VA 
terminates under art 12)  

• The question was raised of the consequence of a VA Signatory being taken over by another 
VAS.  

Action  

• EuroVAprint Secretary General  to enquire about style changes requests during week 12  

December 2011.   

5.  Update on ENERGY STAR v.2 (Claire Schonbach)  

The US EPA draft has been delayed and might not be available before January 2012. Industry 
will need time to adapt its products to the new specifications  

6.  Update on the FAQ document: When and where will these be published, how should 
they be interpreted?  

Pierre Sicsic indicated that the Signatories had prepared an FAQ document, which was meant 
for  publication  on  the  forthcoming  EuroVAprint  website  (see  below).  ERA  volunteered  to 
check the FAQ before their publication.  

7.  Website: when and where will VA information be made available, discussion about 
contents (Feriel Saouli )  

• Online mid -January.  

• Sections:  

o About EuroVAprint, why it was set up etc.  

o Contacts  

o  Useful  links  (Commission  Recommendation  when  available,    ENERGY  STAR    EU-US, 
Eco Declarations, etc.)  

o Sign up section  

o Members only – SC and all non-public documents (password protected)  

 
 
•  ANEC  suggested  that  the  signature  page  of  the  VA  of  each  member  be  posted  on  the 
website.  The  purpose  was  unclear.  The  EuroVAprint  Secretary  highlighted  that  this  might 
come in violation of data protection rules. After discussing it, the SC objected to publishing 
signing forms of the VAs.  

8.  Any Other Business  

• EEB mentioned a report on reusability/recyclability of plastic parts, which it will share with 
the SC. The industry said it would look at this document. Possibility to set requirements on all 
products horizontal) under the Ecodesign Directive.  

• No more AOB.  

Actions  

• Stéphane Arditi to share report on reusability/recyclability.  

9.  Date of next SC meeting  

Thursday 13 September 2012, 10.00 am (to 18.00 hrs.) Brussels time.  

10. Closing of meeting  

Meeting closed at 13.00 hrs. 

 
 
ANNEX 2   RECYCLING AND REUSE OF PAPER, INK AND CARTRIDGES 

Recycling paper 

The recycling content of office paper lies between 10-15%.105 Assumption of 12.5% recycling 
content will result in a paper consumption of around 1 800 pages (approximately 9 kg/unit at 
80g/m2). 

70% recycled mass, 10% recyclable content, recyclability 50% (closed loop 100%) reference 
to MEErP gives 10% van recycled mass. 

Ink cartridges 

Resources  consumption  for  ink  and  toner  cartridges  varies  widely  between  practically  zero 
(solid ink) and ink jet cartridges that use - relative to the weight of the ink - 1.5 times more 
plastic and 2.5 times more cardboard. For toner cartridges the share of cardboard is smaller. 

Assuming a factor 1.5 for both plastic and cardboard, an average unit would consume 1 kg of 
plastic  (usually  PET)  and  1  kg  cardboard  annually  for  ink/toner  cartridges.  At  a  current 
cartridge-recycling rate of 25%106 this will result in 100 million kg plastics and 100 million kg 
cardboard being discarded. At a recycled content of 40%107 for the plastics and 90% for the 
cardboard,  as  well  as  an  80%  thermal  energy  recovery  of  plastics  ending  up  in  incineration 
plants, the net energy required for cartridge and packaging production is similar at around 28-
35 MJ/kg.  This  amounts to  approximately 6 PJ per year (equivalent to 0.6 TWh electricity) 
with related emissions of 0.26 Mt CO2 equivalent. 

Reuse/ Remanufacturing/ Recycling  

There are over 1 400 remanufacturers in Europe, with a job estimate of 10 - 15 000 employees 
according to the European Toner and Inkjet Remanufacturing Association (ETIRA). 108 

105 www.wrap.org.uk/downloads/Secondary_fibre_study.0401cfdb.295.pdf  
106 20-30% of all cartridges sold worldwide are now remanufactured according to ETIRA  
107  JRC's  recent  study  assessed  the  relevance  of  the  use  of  recycled  plastics  for  the  manufacturing  of  imaging 
equipment and in particular, the benefits associated to a range of recycled content of plastic parts. Moreover, 
the  JRC  study  demonstrated  the  need  of  standardized  procedures  for  the  measurements  and  verification  of 
recycled content based on existing standards (e.g. the EN 15343. “Plastics. Recycled plastics. Plastics recycling 
traceability and assessment of conformity and recycled content”). For more information please see “Application 
of  the  project’s  methods  to  three  product  groups.  JRC  Technical  Report  n°  2  of  the  project:  Integration  of 
resource  efficiency  and  waste  management  criteria  in  European product  policies  - Second phase,  September 
2012”, http://lct.jrc.ec.europa.eu/assessment/projects#d). 

108 There are over 10 000 remanufacturers worldwide, employing over 65 000 people. 

 
 
 
 
 
                                                 
 
ANNEX 3   MANUFACTURERS IN ENERGY STAR DATABASE 

Manufacturer 

Advent 
Argox Information Co., Ltd. (imaging equipment) 
Avery Dennison 
Bixolon 
BOCA 
Brother International Europe, Ltd. (imaging equipment) 
cab 
Canon Europa N.V. (imaging equipment) 
Citizen 
Colortrac Ltd. (imaging equipment) 
Compuprint S.r.l. (imaging equipment) 
CTS electronics S.p.A. (imaging equipment) 
Datacard 
Dell 
Develop GmbH (imaging equipment) 
Epson 
EVOLIS CARD PRINTER (imaging equipment) 
HID 
HP 
Infoprint 
Inforprint solutions 
InoTec GmbH Organisationssysteme (imaging equipment) 
Intermee 
KIP 
Kodak 
Konica Minolta Business Solutions Europe GmbH 
(imaging equipment) 
Konica Minolta Business Technologies, Inc. (imaging 
equipment) 
Konica Minolta Printing Solutions Europe B.V. (imaging 
equipment) 
Kyocera Mita Europe B.V. (imaging equipment) 
Lexmark 
NANTIAN 
Nica S.r.l. (imaging equipment) 
Océ Technologies B.V. (imaging equipment) 
Oki Europe Ltd. (imaging equipment) 
Olivetti S.p.A. (imaging equipment) 
Panafax 
Panasonic Europe Ltd. (imaging equipment) 

Energystar 
registered
Copier 

Printer  MFD 

Fax 

3 

88 

195 

2 

24 
45 
106 

331 
2 
48 
50 

3 
22 

1 
1 
7 
19 
27 
12 
125 
8 

1 

2 
26 
4 
136 
2 
3 
238 

38 
6 
6 
5 
1 

17 

51 

21 
74 
2 

214 
15 

64 
139 

50 
62 
63 

19 

3 
3 
1 
17 

15 

5 

10 

5 

6 

3 

4 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Pansonic 
Philips 
Printronix 
Recognition Equipment Italy S.p.A. (imaging equipment) 
Ricoh Europe PLC (imaging equipment) 
RISO Kagaku Corporation (imaging equipment) 
Roland 
Roth+Weber GmbH (imaging equipment) 
Rowe 
Sagem 
Sagemcom Austria GmbH (imaging equipment) 
Samsung 
Savin 
Sharp Electronics (Europe) GmbH (displays / imaging 
equipment) 
Sindfonia Technology 
SNBC or Beiyang 
Star micronics 
SZ Catic Info. Tech. Ind. Co. Ltd. 
TA/Utax 
TA triumph adler 
Tally 
Tally DASCOM 
Tally Genicom 
Toshiba TEC Corporation (imaging equipment) 
UTAX GmbH (imaging equipment) 
Veenman B.V. (imaging equipment) 
Wincor Nixdorf International GmbH (imaging equipment) 
Xerox 
Zebra 

120 

3 

13 

2 

5 

5 
2 

1 
2 

302 

4 
2 
4 
120 

120 

7 
19 

51 
46 

132 

2 

12 

176 
6 
1 

4 

133 
2 

3 
1 
26 
8 
1 

13 
27 
7 
56 
7 
18 

2 
57 
19 

 Total registered products 

184 

1590 

2175 

42 

Source: http://www.eu-energystar.org/en/index.html (accessed 12-3-2012, Database update of 
9-3-2012). 

The 17 Signatories of the voluntary agreement are109: 

Brother International Europe,  
Canon Europe Ltd.,  
Dell, 
Epson America Inc.,  
Hewlett-Packard Company,  
Kodak,  
Konica Minolta Business Solutions Europe GmbH,  

109 Identified according to own research, not based on official signatory documents 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
                                                 
Kyocera Mita Europe B.V.,  
Lexmark International Inc.,  
Océ Technologies BV,  
OKI Europe Ltd.,  
Panasonic Europe Ltd.,  
Samsung Electronics Co. Ltd.,  
Sharp Electronics (Europe) GmbH.,  
Toshiba TEC,  
Xerox Corporation 
Ricoh Europe PLC 

 
 
 
ANNEX 4   US EPA 

How Does EPA Choose which Products Earn the Label? 

Products can earn the ENERGY STAR label by meeting the energy efficiency requirements 
set  forth  in  ENERGY  STAR  product  specifications.  EPA  establishes  these  specifications 
based on the following set of key guiding principles: 

•  Product categories must contribute significant energy savings nationwide. 

•  Qualified  products  must  deliver  the  features  and  performance  demanded  by 

consumers, in addition to increased energy efficiency. 

• 

If  the  qualified  product  costs  more  than  a  conventional,  less-efficient  counterpart, 
purchasers will recover their investment in increased energy efficiency through utility 
bill savings, within a reasonable period of time. 

•  Energy  efficiency  can  be  achieved  through  broadly  available,  non-proprietary 

technologies offered by more than one manufacturer. 

•  Product  energy  consumption  and  performance  can  be  measured  and  verified  with 

testing. 

•  Labelling would effectively differentiate products and be visible for purchasers. 

How Does EPA decide when to Revise Specifications? 

Generally, a market share of ENERGY STAR qualified products in a particular category of 
50 per cent or higher will prompt consideration for a specification revision. However,  there 
are other factors that weight into the decision, such as: 

•  A change in the Federal minimum efficiency standards. 

•  Technological  changes  with  advances  in  energy  efficiency  which  allow  a  revised 

ENERGY STAR specification to capture additional savings. 

•  Product availability 

•  Significant issues with consumers realizing expected energy savings 

•  Performance or quality issues 

• 

Issues with Test Procedures 

Source: http://www.energystar.gov/index.cfm?c=products.pr_how_earn  

 
 
 
ANNEX 5   ECOLABELS 

European ecolabels 

Non-European Ecolabels 

Products 

Blue 
Angel 

Nordic 
Swan 

Umwelt-
zeichen 

Copiers 

Printers 

√ 

√ 

√ 

√ 

√ 

√ 

GP
P/ 
Ecol
abel 

√ 

√ 

√ 

√ 

Multi 
Funtional 
Devices 
(MFD) 

√ 

√ 

√ 

√ 

√ 

Fax 

√ 

√ 

√ 

Source: clasponline.org 

EcoLogo 
Canada 

Env. 
Choice 
Australia

Env. 
Choice 
New 
Zealand 

Eco 
Mark 
Japan 

Eco-
label 
Korea 

Green 
Mark 
Taiwan 

Singapore 
Green 
label 

Green 
label 
Thailand

China 
label 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 6   ENERGY STAR ANALYSIS 

ENERGY STAR measure 

ENERGY  STAR  v.1.0  was  introduced  in  2006  and  was  the  first  version  in  which  TEC 
calculation  was  applied.  ENERGY  STAR  v.1.1  followed  in  2009  and  v.2.0  will  be 
implemented in 2013.  

TEC  is  a  method  of  testing  and  comparing  the  energy  performance  of  imaging  equipment 
products,  which  focuses  on  the  typical  electricity  consumed  by  a  product  while  in  normal 
operation  during  a  representative  period  of  time.  The  key  criteria  of  the  TEC  approach  for 
imaging  equipment  is  a  value  for  typical  weekly  electricity  consumption,  measured  in 
kilowatt-hours (kWh). The maximum TEC is calculated for each individual product and takes 
into account the product's size format, marking technology, and monochrome product speed. 

OM  is  a  method  of  testing  and  comparing  the  energy  performance  of  imaging  equipment 
products,  which  focuses  on  product  energy  consumption  in  various  low-power  modes.  The 
key  criteria  used  by  the  OM  approach  are  values  for  low-power  modes,  measured  in  watts 
(W). An overview of the formula’s and criteria: 

The maximum requirement for the TEC value depends on the type of product (MFD or not, 
colour or not) and the monochrome speed in ipm. The formula is as follows:  

max. TEC = A * X + B  

ENERGY STAR version 1.0 

TEC 1 

A 

B 

X (ipm) 

(kWh/ipm) 

(kWh) 

<= 12 

12<x<=50 

>50 

TEC 2 

0.2 

0.80 

A 

1.5 

-1 

-31 

B 

X (ipm) 

(kWh/ipm) 

(kWh) 

<= 50 

>50 

0.20 

0.80 

2.0 

-28 

ENERGY STAR version 1.1 

TEC 1 

A 

B 

X (ipm) 

(kWh/ipm) 

(kWh) 

<= 15 

15<x<=40 

40<x<=82 

>82 

TEC 2 

0.10 

0.35 

0.70 

A 

1 

-0.5 

-10.3 

-39.0 

B 

TEC 3 

X (ipm) 

<= 20 

20<x<=69 

>69 

TEC 4 

X (ipm) 

<= 32 

32<x<=61 

>61 

TEC 3 

X (ipm) 

<= 10 

10<x<=26 

26<x<=68 

>68 

TEC 4 

A 

B 

(kWh/ipm) 

(kWh) 

0.20 

0.44 

0.80 

A 

2 

-2.8 

-28 

B 

(kWh/ipm) 

(kWh) 

0.20 

0.44 

0.80 

5 

-2.8 

-25.0 

A 

B 

(kWh/ipm) 

(kWh) 

0.10 

0.35 

0.70 

A 

1.5 

0.5 

-6.0 

-30.0 

B 

 
 
 
 
 
 
 
 
 
 
 
 
 
X (ipm) 

(kWh/ipm) 

(kWh) 

X (ipm) 

(kWh/ipm) 

<= 32 

32<x<=58 

>58 

0.10 

0.35 

0.70 

2.8 

-5.2 

-26.0 

<= 26 

26<x<=62 

>62 

0.10 

0.35 

0.70 

3.5 

-3.0 

-25.0 

ENERGY STAR Draft 1 version 2.0 

Colour 

A 

B 

X (ipm) 

(kWh) 

(kWh) 

Monochrome 

<= 7 

Colour 

7<x<=44 

44<x<=74 

>74 

<= 45 

45<x<=70 

>70 

0.07 

0.20 

0.70 

0.07 

0.20 

0.70 

0.5 

-5.7 

-42.7 

+1.4 

-4.5 

-39.5 

 
 
 
 
 
 
 
 
 
 
 
OM 
Similar for the three ENERGY STAR versions except for Copier there ENERGY STAR 
version 1.0 differs with the ipm values are s≤50 and s>50. 

Maximum Default Delay times to Sleep for OM products 
Product type 

Media Format 

Monochrome product speed, s, as 
calculated in the Test Method (ipm 
or mppm) 

Default Delay 
time to sleep 
(minutes 

Copier 

Fax Machine 

MFD 

Printer 

Scanner 

Mailing machine 

Large 

Small or standard 

Small or standard 

Large 

Small or standard 

Large 

All 

All 

s≤30 

s>30 

All 

s≤10 

10<s≤20 

s>20 

s≤30 

s>30 

s≤10 

10<s≤20 

20<s≤30 

S>30 

s≤30 

s>30 

All 

s≤50 

50<s≤100 

100<s≤150 

s>150 

30 

60 

5 

15 

30 

60 

30 

60 

5 

15 

30 

60 

30 

60 

15 

20 

30 

40 

60 

Pmax_base (Watts) 

3.0 

3.0 

3.0 

13.0 

58.0 

3 

6.0 

3.0 

54.0 

13.0 

5.0 

1.4 

7 

1.4 

15 

30 

9 

4.6 

1.4 

14 

15 

4.3 

0.6 

5.6 

0.6 

4.9 

7.4 

9 

2.3 

0.6 

2.5 

4.9 

2.7 

Sleep Mode Power Allowance for Base Marking Engine 
Product 
type 

Media 
format 

Marketing techonology 

Impact 

Ink 
jet 

All 
other  
x 

Not 
apllicable 

Energystar 
1.0 
58.0 

Energystar 
1.1 
30 

Energystar 
2.0 
7.4 

Copier 
Fax 
Machine 
Mailing 
Machine 

MFD 

Printer 

Large 

Standard 

N/A 

Standard 

Large 

Small 

Standard 

Large 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

Scanner 

Any 

x 

Energystar 1.0 MAX sleep (W)  Energystar 1.1 MAX  Energystar 2.0 MAX 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
58 

3.0 

13 

3 

3 

6 

5 

54 

OM1 

OM2 

OM3 

OM4 

OM5 

OM6 

OM7 

OM8 

Duplexing 

Automatic duplexing requirement 

N/A 

Automatic duplexing must be offered as a 
standard feature or optional accessory at the 
time of purchase. 

Automatic duplexing is required as a 
standard feature at the time of purchase. 

Voluntary Agreement  

30 

1.4 

15 

7 

9 

4.6 

4.3 

14 

7.4 

0.6 

4.9 

5.6 

9 

2.3 

2.7 

2.5 

ENERGY STAR v.1.0 

ENERGY STAR v.1.1 

ENERGY STAR v.2.0 

Colour  Monochrome  Colour  Monochrome  Colour  Monochrome 

ipm 

<=19 

20-39 

ipm 

<=24 

25-44 

ipm 

<=19 

20-39 

ipm 

<=24 

24-44 

ipm 

<=19 

ipm 

<=19 

>=40 

>=45 

>=40 

>=45 

>19 

>19 

The VA sets design requirement concerning compliance rate, duplexing, TEC and OM values 
as stated in ENERGY STAR v.1.1.  

From  analysis  (details  of  the  analysis  are  given  below  and  Annex  6)  of  the  EU  ENERGY 
STAR  database110  on  imaging  equipment  (status  Feb.  2012),  the  following  preliminary 
conclusions were reached:  

•  The energy efficiency of registered products is currently around 40-50% better than what 
is  apparent  from  the  maximum  allowed  under  the  ENERGY  STAR  programme,  and  is 
significantly better than what was projected in the preparatory study. Already today, 50-
60% of products meet the ENERGY STAR v. 2.0 requirements that will enter into force 
in March 2013 

•  This  is  also  the  case  for  duplexing  capabilities,  where  over  80%  of  products  feature 
standard duplexing where only a duplexing option was required. In this sense over 80% of 
products already meet the future v. 2.0 duplexing requirements. 

o  From  the  above  it  can  be  concluded  that  industry  efforts  in  contributing  to 
environmental  policy  goals  are  significant  and  continuous.  If  continued  at 
similar  pace,  there  is  no  reason  to  assume  that  any  mandatory  regulatory 
instrument would achieve more savings than the voluntary agreement.  

o  The  first  review  date  will  be  in  2013  after  the  implementation  of  the  new 

ENERGY STAR programme version 2.0. 

110  www.eu-energystar.org  .  EU  ENERGY  STAR  database  =  EU  ENERGY  STAR  registered  products  +  US 
ENERGY STAR registered products available on the European market 

 
 
 
 
 
 
 
 
 
 
                                                 
Share VA manufacturers 

The table below gives an overview of the percentage of products, in the EU ENERGY STAR 
database as of 1 February 2012, manufactured by the manufacturers expected to be included 
in the voluntary agreement as Signatories111. 

Table 7: Percentage of Energy star registered products available for EU market by VA manufacturers  

Product 

Copier 
Fax 
MFD 
Printer 

112

VA manufacturers
94% 
71% 
91% 
94% 

Testing performed by the EPA in 2009, 13 on a sample of 120 products revealed that: 

• 95% of tested ENERGY STAR printers met ENERGY STAR criteria; 

• 40% of tested non-ENERGY STAR printers also met the ENERGY STAR criteria. 

Product categories  

ENERGY  STAR  v.1.1  requirements,  in  force  since  July  2009,  distinguish  the  Typical 
Electricity  Consumption  (TEC)  products  and  Operational  Mode  (OM)  products.  TEC 
products  are  Standard-size  copiers,  Multifunction  Devices  (MFDs),  and  printers  that  use 
Electrophotography  (EP),  Solid  Ink  (SI),  and  High  Performance  Ink  Jet  (IJ)  marking 
technologies,  OM  products  cover  the  remainder  of  mainly  non  high-performance  inkjet 
products.  

Duplexing requirements and compliance 

TEC  products  must  meet  the  following  duplexing  requirements,  based  on  monochrome 
product speed:  

•  For  monochrome  copiers,  MFDs  and  printers  automatic  duplexing  must  be  optional 
or standard for product speeds 25-44 ipm (images per minute); for speeds equal to or 
higher than 45 ipm automatic duplexing must be a standard feature.  

•  For  colour  copiers,  MFDs  and  printers  automatic  duplexing  must  be  optional  or 
standard  for  product  speeds  20-39  ipm  (images  per  minute);  for  speeds  equal  to  or 
higher than 40 ipm automatic duplexing must be a standard feature.  

The table below shows that, per 1 Feb 2012, 92% of EU-registered monochrome products in 
Energy star with speed ≥ 25 ipm feature automatic duplexing as standard.  

111  Brother  International  Europe,  Canon  Europe  Ltd.,  Dell,  Epson  America  Inc.,  Hewlett-Packard  Company, 
Kodak, Konica Minolta Business Solutions Europe GmbH, Kyocera Mita Europe B.V., Lexmark International 
Inc.  Océ  Technologies  BV,  OKI  Europe  Ltd.,  Panasonic  Europe  Ltd.,  Samsung  Electronics  Co.  Ltd.,  Sharp 
Electronics (Europe) GmbH., Toshiba TEC, Xerox Corporation and Ricoh Europe PLC 
112 http://www.ebpg.bam.de/de/ebpg_medien/tren4/004_workd_09-11_printing_v3-5.pdf  

 
 
 
 
 
                                                 
For  colour  products  registered  in  Energy  star  with  speed  >19  ipm,  80%  of  the  products 
feature automatic duplexing as standard. 

Table 8: Duplex capability TEC products Energy star (available on EU market) 

Automatic 
Duplex 
Output 
Capable? 

Yes 

No 

Option 

Monochrome 

Colour 

≤ 24 ipm n=839 

25-44 ipm n=1112 

≥ 45 ipm n=748 

≤ 19 ipm n=140 

20-39 ipm n=1134 

≥ 40 ipm n=297 

41% 

52% 

6% 

92% 

1% 

7% 

100% 

0% 

0% 

20% 

76% 

4% 

80% 

19% 

1% 

100% 

0% 

0% 

There  is  no  duplexing  requirement  for  OM  products  (non-high-performance  Ink  Jet)  or 
products that do not use standard-size paper. 

With monochrome OM products, where duplexing is not required, still 14% of products with 
speed ≤ 24 ipm and 20% of products with speed 25-44 ipm featured automatic duplexing.  

For colour OM products, where duplexing is not required, still 36% of products with speed ≤ 
19 ipm and 41% of products with speed 20-39 ipm featured automatic duplexing.  

Table 9: Duplex capability OM products Energy star (available on EU market) 

Automatic 
Duplex 
Output 
Capable? 

Yes 

No 

Option 

Monochrome 

Colour 

≤ 24 ipm n=284 

25-44 ipm n=169 

≥ 45 ipm n=33  ≤ 19 ipm n=122 

20-39 ipm n=225 

≥ 40 ipm n=13 

14% 

86% 

0% 

20% 

80% 

0% 

0% 

100% 

0% 

36% 

64% 

0% 

41% 

59% 

0% 

0% 

100% 

0% 

In the ENERGY STAR version 2.0, Draft 1 requirements, to be published in July 2012 and 
entering  into  force  March  2013,  the  automatic  duplexing  feature  must  be  standard  for  all 
TEC products, colour and monochrome, with a monochrome speed of 19 ipm or higher. 

The table below shows that, per 1 Feb. 2012, 84% of mono chrome and 83% of colour EU-
registered  products  with  speed  >=  19  ipm  are  already  compliant  with  the  duplexing 
requirements under version 2.0, Draft 1. 

Table  10:  Duplexing  rates  TEC  products  compliant  with  Energy  star  version  2.0  (draft  1 
requirement) 

Automatic Duplex 
Output Capable? 

Monochrome 

Colour 

≤ 19 ipm n=401 

>19ipm n=2298 

≤ 19 ipm n=140 

>19ipm n=1431 

Yes 

No 

Option 

42% 

52% 

5% 

84% 

12% 

4% 

20% 

76% 

4% 

83% 

16% 

1% 

Electricity consumption standards and compliance 

 
 
 
 
 
 
TEC products are subject to maximum energy requirements of a calculated weekly duty cycle. 
The duty cycle calculation follows these equations: 

The following two equations are used for all product types:  

Average Job Energy = (Job2 + Job3 + Job4) / 3  

Daily Job Energy = (Job1 × 2) + [(Jobs per Day – 2) × Average Job Energy)]  

The calculation method for printers, digital duplicators and MF Ds with print-capability, and 
fax machines also uses the following three equations:  

Daily Sleep Energy = [24 hours – ((Jobs per day / 4) + (Final Time × 2))] × Sleep Power  

Daily Energy = Daily Job Energy + (2 × Final Energy) + Daily Sleep Energy  

TEC  = (Daily Energy × 5) + (Sleep Power × 48)  

The  calculation  method  for  copiers,  digital  duplicators,  and  MFDs  without  print-capability 
also use the following three equations:  

Daily  Auto-off  Energy  =  [24  hours  –  ((Jobs  per  day  /  4)  +  (Final  Time  ×  2))]  ×  Auto-off 
Power 

Daily Energy = Daily Job Energy + (2 × Final Energy) + Daily Auto-off Energy  

TEC  = (Daily Energy × 5) + (Auto-off Power × 48) 

The maximum requirement for the TEC value depends on the type of product (MFD or not, 
colour or not) and the monochrome speed in ipm. The formula is as follows:  

max. TEC = A * X + B  

 
 
Table 11: Maximum TEC (kWh/week) calculation values 

TEC 1 

A 

B 

X (ipm) 

(kWh/ipm) 

(kWh) 

<= 15 

15<x<=40 

40<x<=82 

>82 

TEC 2 

0,10 

0,35 

0,70 

A 

1 

-0,5 

-10,3 

-39,0 

B 

X (ipm) 

(kWh/ipm) 

(kWh) 

<= 32 

32<x<=58 

>58 

0,10 

0,35 

0,70 

2,8 

-5,2 

-26,0 

TEC 3 

X (ipm) 

<= 10 

10<x<=26 

26<x<=68 

>68 

TEC 4 

X (ipm) 

<= 26 

26<x<=62 

>62 

A 

B 

(kWh/ipm) 

(kWh) 

0,10 

0,35 

0,70 

A 

1,5 

0,5 

-6,0 

-30,0 

B 

(kWh/ipm) 

(kWh) 

0,10 

0,35 

0,70 

3,5 

-3,0 

-25,0 

Registered products that are in the scope of the voluntary agreement (VA) achieve on average 
a TEC value that is 43% below the maximum requirement for ENERGY STAR v. 1.1. The 
best products perform 90% better than the maximum requirement. 

For  OM  products  the  ENERGY  STAR  v.1.1  requirements  sets  maximum  power  values  for 
Standby-mode  (1  Watts),  Sleep-mode  (between  1,4  -  30  W  depending  on  OM  class)  and 
functional adders like interface (e.g. wired, wireless, infrared) and storage (e.g. CCFL lamps, 
memory, cordless handset). On average the registered products showed values that were also 
35%  below  maximum  levels.  The  best  products  perform  85%  better  than  the  maximum 
requirement. 

In the ENERGY STAR version 2.0, Draft 1 requirements, to be published in July 2012 and 
entering  into  force  March  2013,  the  maximum  requirements  for  both  the  TEC  and  the  OM 
products are set around 40-50 % more ambitious. 

 50% of the registered TEC products that are in the scope of the voluntary agreement comply 
with  the  draft  1  version  2.0  requirements.  Around  50%  of  the  currently  registered  OM 
products meet the draft v 2.0 requirements.  

In  a  ‘business-as-usual’  scenario  it  may  be  expected  that  per  1  March  2015  around  90%  of 
EU-registered products meet the draft v. 2.0 requirements.  

Tables below first give the sales and stock data (from BAU-scenario, see Annex 10) and then 
the electricity consumption values. 

Sales and Stock 

SALES (in mln. units/year) 

Category               1995  2005  2006  2007  2008 2009 2010 2011 2012 2013 2014 2015 2016  2017  2018  2019 2020

EP-Copier mono 

2.00  1.02  0.97  0.92  0.88 0.83 0.78 0.71 0.63 0.55 0.48 0.40 0.37  0.34  0.31  0.28 0.25

EP-Copier colour 

- 

0.14  0.15  0.17  0.18 0.20 0.22 0.23 0.25 0.27 0.28 0.30 0.33  0.36  0.39  0.42 0.45

EP-printer mono 

3.58  3.68  3.64  3.59  3.55 3.50 3.46 3.31 3.16 3.00 2.85 2.70 2.58  2.46  2.34  2.22 2.10

EP-printer colour 

- 

0.83  0.89  0.95  1.01 1.07 1.13 1.27 1.40 1.53 1.67 1.80 2.00  2.20  2.40  2.60 2.80

IJ SFD printer 

7.80  12.33 10.72  9.11  7.51 5.90 4.29 3.93 3.58 3.22 2.86 2.50 2.30  2.10  1.90  1.70 1.50

IJ MFD printer 

6.45  10.11 12.32 14.54 16.76 18.98 21.19 21.96 22.72 23.48 24.24 25.00 25.20 25.40 25.60 25.80 26.00

 
 
 
 
 
 
 
Total 

19.83  28.11 28.70 29.30 29.89 30.48 31.08 31.40 31.73 32.05 32.38 32.70 32.78 32.86 32.94 33.02 33.10

Stock (in mln. units/year) 

Category               1995  2005  2006  2007  2008 2009 2010 2011 2012 2013 2014 2015 2016  2017  2018  2019 2020

EP-Copier mono 

5.00  5.97  5.60  5.23  4.86 4.49 4.12 3.81 3.50 3.19 2.87 2.56 2.25  1.94  1.62  1.31 1.00

EP-Copier colour 

- 

0.38  0.44  0.51  0.57 0.63 0.69 1.12 1.55 1.98 2.41 2.85 3.28  3.71  4.14  4.57 5.00

EP-printer mono  11.90  14.74 14.65 14.56 14.48 14.39 14.31 13.88 13.44 13.01 12.58 12.15 11.72 11.29 10.86 10.43 10.00

EP-printer colour 

- 

1.92  2.37  2.83  3.29 3.74 4.20 4.78 5.36 5.94 6.52 7.10 7.68  8.26  8.84  9.42 10.00

IJ SFD printer 

29.48  68.41 60.99 53.58 46.16 38.74 31.32 30.06 28.79 27.53 26.26 25.00 24.00 23.00 22.00 21.00 20.00

IJ MFD printer 

24.17  21.76 32.96 44.17 55.37 66.57 77.78 80.22 82.67 85.11 87.56 90.00 92.00 94.00 96.00 98.00 100.0

Total 

70.55  113.1 117.0 120.8 124.7 128.5 132.4 133.8 135.3 136.7 138.2 139.6 140.9 142.2 143.4 144.7 146.0

Electricity consumption Scenario’s 

TEC electricity consumption TWh 

2005 

2006

2007

2008

2009

2010

2011

2012 

2013 

2014

2015

2016

2017

Energystar  

     9,48      9,61      9,73      9,86      4,33      4,43      4,64      4,84      2,40      2,42      2,45      2,48      2,51      

VA  

BAU 

     4,74      4,80      4,87      4,93      3,25      3,06      2,92      2,76      1,80      1,70      1,59      1,49      1,50      

     6,28      6,31      6,34      6,38      6,41      6,45      6,46      6,46      6,45      6,44      6,41      6,57      6,72      

OM electricity consumption TWh 

2005 

2006

2007

2008

2009

2010

2011

2012 

2013 

2014 

2015

2016

2017

2

Energystar  

     1,15      1,20      1,25      1,30      0,73      0,76      0,76      0,77      0,41      0,42      0,42      0,42      0,43      0

VA  

BAU 

Total Electricity 
consumption TWh 
Energystar  

VA  

BAU 

     0,81      0,76      0,75      0,65      0,55      0,54      0,52      0,50      0,31      0,29      0,27      0,25      0,26      0

     1,48      1,61      1,75      1,89      2,02      2,16      2,11      2,05      1,99      1,93      1,87      1,89      1,92      

2005  2006  2007  2008  2009 2010 2011 2012 2013 2014 2015 2016  2017  2018  2019 2020

10,63  10,81  10,98  11,16  5,06 5,19 5,40 5,62 2,81 2,84 2,87 2,90  2,93  2,97  3,00 3,03

5,55  5,56  5,62  5,58  3,80 3,60 3,44 3,26 2,11 1,99 1,87 1,74  1,76  1,78  1,80 1,82

7,75  7,92  8,09  8,26  8,44 8,61 8,56 8,51 8,45 8,37 8,28 8,46  8,64  8,82  9,00 9,17

Paper energy consumption 

ENERGY STAR programme v.1.1 

In the 2012 research, a duplexing rate of 84% was calculated according to ENERGY STAR 
version  1.1  requirements  (see  Annex  5)  and  assuming  15%  N-printing113.  This  results  in  a 
paper consumption of around 12 500 pages, i.e. approximately 62 kg/unit at 80g/m2. Thus, it 
is estimated that imaging equipment in the EU27 consumes almost 8 200 million kg (8.2 Mt) 
of paper annually, of which 820 million kg (0.82 Mt) in IJ equipment and 7 380 million kg 
(7.38 Mt) in EP equipment. Energy consumption to produce this paper is 328 PJ in primary 

113  90%  of  images  are  produced  by  EP  equipment,  of  which  90%  has  duplex  capabilities  (according  to  EU 
ENERGY STAR database) that are used in 90% of all prints. 10% of images are produced by IJ equipment, of 
which  26%  has  duplex  capabilities  (according  to  EU  ENERGY  STAR  database)  that  are  used  in  90%  of  all 
prints.  N-printing  (2  images  per  page)  is  assumed  relevant  for  medium  volume  equipment  (20-40  ppm, 
workgroup printing) and for legal documents or similar (large font, large line space, few graphs).     

 
 
 
 
 
 
 
 
 
                                                 
energy (equivalent to around 32.8 TWh electricity) and the related greenhouse gas emissions 
amount to 5.0 Mt CO2 equivalent per year.  

ENERGY STAR programme v.2.0 

In the 2012 research, a duplexing rate of 88% was calculated according to ENERGY STAR 
version  2.0  requirements  (see  Annex  5)  and  assuming  15%  N-printing114.  This  results  in  a 
paper consumption of around 12 000 pages (approximately 60 kg/unit at 80g/m2). Thus, it is 
estimated that imaging equipment in the EU27 consumes almost 7 900 million kg (7.9 Mt) of 
paper annually, of which 790 million kg (0.79 Mt) in IJ equipment and 7 110 million kg (7.11 
Mt) in EP equipment. Energy consumption to produce this paper is 315 PJ in primary energy 
(equivalent to around 31.5 TWh electricity) and the related greenhouse gas emissions amount 
to 4.7 Mt CO2 equivalent per year. 

114  90%  of  images  are  produced  by  EP  equipment,  of  which  98%  has  duplex  capabilities  (according  to  EU 
ENERGY STAR database) that are used in 90% of all prints. 10% of images are produced by IJ equipment, of 
which  26%  has  duplex  capabilities  (according  to  EU  ENERGY  STAR  database)  that  are  used  in  90%  of  all 
prints.  N-printing  (2  images  per  page)  is  assumed  relevant  for  medium  volume  equipment  (20-40  ppm, 
workgroup printing) and for legal documents or similar (large font, large line space, few graphs).     

 
 
                                                 
ANNEX 7   RESEARCH 2012 

Analysis of EU ENERGY STAR database imaging equipment (status Feb. 
2012) 

The EU ENERGY STAR database is accessible at www.eu-energystar.org. At the time of the 
analysis  this  database  contained  2 612  registered  models  of  imaging  equipment  on  the  EU 
market that have to comply with a maximum TEC value (Typical Electricity Consumption) in 
accordance with ENERGY STAR requirements version 1.1. 

There are four TEC categories: 

•  TEC  1  -  Copiers,  printers,  digital  duplicators  and  fax  machines  with  monochrome 

marking technology (sample size n= 662);  

•  TEC  2  -  Copiers,  printers,  digital  duplicators  and  fax  machines  with  colour  marking 

technology (n=445); 

•  TEC 3 - MFDs with monochrome marking technology (n=868);  

•  TEC 4 - MFDs with colour marking technology (n=642). 

Each of these TEC categories is subdivided in 3 or 4 ipm (images per minute) subcategories, 
indicating ranges of product speed. ENERGY STAR defines maximum TEC values through 
specific equations per TEC-category and per ipm class, whereby the ipm number is also part 
of the equation (see Annex5). 

All TEC classes have standard size paper format and the marking technologies predominantly 
contain  electro  photographic  (‘laser’)  and  solid  ink.  Other  marking  technologies  are  dye 
sublimation, thermal transfer, direct thermal, stencil and high performance ink jet.  

The  underlying  detailed  analysis  concerns  only  the  electro  photographic  and  solid  ink 
categories. Ink jet and impact technologies, which have to comply with OM values, as well as 
imaging  equipment  for  non-standard  paper  represent  a  far 
impact 
(approximately 15% of total).  

lower  energy 

The data base does not contain sales values per model, but given the size of the data base it is 
plausible that the number of models per TEC classes can be used for weighting purposes in 
order to make an estimate of impacts. 

The  pragmatic  yardstick  that  is  chosen  here  for  the  energy  efficiency  is  the  fraction  of  the 
maximum TEC value (‘x’% max TEC), divided in discrete 10% classes.  

TEC 1 (Monochrome copiers, printers, etc.) 

Figure 14 shows the distribution of the energy efficiency of the TEC1 category, subdivided by 
ipm subcategories. The distribution is a straight, not weighted count of the number of models.  

 
 
 
 
 
Figure 14 shows that 55% of the models (370 of n=662) have an energy performance in the 
range  of  80  to  100%  of  max  TEC.  The  other  45%  of  the  models  are  lower  than  80%  max 
TEC. There are only a few very energy efficient models featuring a 10% max TEC.  

Overall, the average energy efficiency in TEC 1 is around 78% max TEC. Note that this is the 
value for registered products. As stated in the VA, it should also be taken into account  that 
some 10% of products on the EU market are not registered.  

Number of products per efficiency class TEC 1

s
t
c
u
d
o
r
p
f
o
r
e
b
m
u
N

200

180

160

140

120

100

80

60

40

20

0

Outside Energy Star

>82

40-82

15-40

<=15

0-10% 10-20% 20-30% 30-40% 40-50% 50-60% 60-70% 70-80% 80-90% 90-100% >100%

Percentage of max. TEC 

Figure 14: Distribution of the energy efficiency of the TEC 1 category 

In order to investigate whether distribution of the energy efficiency also depends on product 
speed,  the  average  energy  consumption  in  kWh/year  was  calculated  per  ipm  subcategory, 
using  the  max  TEC  equation  for  that  product  category  and  the  average  ipm  value.  This  is 
shown in the table 12 below. 

Table 12: TEC 1 calculations per subcategory 

Product speed class (ipm) 

Average product speed (ipm) 
Max. TEC kWh/week 

<=15  15-40  40-82 
55.3 
28.2 
9.3 
9.1 
14.1 
1.0 

>82 
121.9 
46.3 

Annual Max. TEC kWh/year 

52.0 

733.2  471.6  2408.6 

The  annual  kWh/year  figures  were  then  used  to  give  a  weighting  to  the  straight  count  in 
Figure 15. 

As mentioned, this is not exactly a sales weighted outcome but it is as close as data allows. 
The figure below shows that the distribution is similar to the energy efficiency graph above. 
The average saving is more or less the same.  

Note that for products in the scope of the VA the max speed for monochrome products is <66 
ipm.  

 
 
 
 
 
 
 
 
TEC 1 electricity use distribution
Based on EU Energy Star database (Feb 2012), number of models (n=662) weighted by specific TEC 
energy value, subdivided by product speed in ipm

40%

35%

30%

25%

20%

15%

10%

5%

0%

0-10%

10-20%

20-30%

30-40%

40-50%

50-60%

60-70%

70-80%

80-90%

90-100%

>82

40-82

15-40

<=15

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

1%

3%

0%

0%

2%

2%

0%

7%

3%

5%

0%

3%

2%

7%

0%

4%

3%

22%

0%

5%

4%

27%

0%

Figure 15: TEC 1 Electricity use distribution 

TEC 2 (Colour copiers, printers, etc.) 

Figure 16 shows the distribution of the energy efficiency of the TEC2 category, subdivided by 
ipm subcategories. The distribution is a straight, not weighted count of the number of models.  

Figure 16shows that 51% of the models (227 of n=445) have an energy performance in the 
range  of  60  to  100%  of  max  TEC.  The  other  49%  of  the  models  are  lower  than  60%  max 
TEC. There are only a few very energy efficient models featuring a 10% max TEC.  

Overall, the average energy efficiency in TEC 2 is around 58% max TEC. Note that this is the 
value for registered products. As stated in the VA, it should also be taken into account  that 
some 10% of products on the EU market are not registered.  

 
 
 
 
 
 
Number of products per efficiency class TEC 2

Outside Energy Star

>58

32-58

<=32

s
t
c
u
d
o
r
p
f
o
r
e
b
m
u
N

140

120

100

80

60

40

20

0

0-10%

10-20% 20-30% 30-40% 40-50% 50-60% 60-70% 70-80% 80-90% 90-100% >100%

Percentage of max. TEC

Figure 16: Distribution of the energy efficiency of the TEC 2 category 

In order to investigate whether distribution of the energy efficiency also depends on product 
speed,  the  average  energy  consumption  in  kWh/year  was  calculated  per  ipm  subcategory, 
using  the  max  TEC  equation  for  that  product  category  and  the  average  ipm  value.  This  is 
shown in the table 13 below. 

Table 13: TEC 2 calculations per subcategory 

Product speed class (ipm) 

>58 
80.1 
Average product speed (ipm) 
30.1 
Max. TEC kWh/week 
Annual Max. TEC kWh/year  269.4  455.8  1565.2 

<=32  32-58 
39.9 
23.8 
8.8 
5.2 

The  annual  kWh/year  figures  were  then  used  to  give  a  weighting  to  the  straight  count  in 
Figure 17. 

As mentioned, this is not exactly a sales weighted outcome but it is as close as data allows.  

The figure below shows that the distribution is similar to the energy efficiency graph above. 
The average saving is more or less the same.  

Note that for products in the scope of the VA the max speed for monochrome products is <51 
ipm.  

 
 
 
 
 
 
 
 
TEC 2 electricity use distribution
Based on EU Energy Star database (Feb 2012), number of models (n=445) weighted by specific TEC 
energy value, subdivided by product speed in ipm

40%

35%

30%

25%

20%

15%

10%

5%

0%

0-10%

10-20%

20-30%

30-40%

40-50%

50-60%

60-70%

70-80%

80-90%

90-100%

>58

32-58

<=32

0%

0%

0%

1%

0%

0%

1%

1%

1%

0%

1%

2%

5%

3%

3%

0%

6%

6%

19%

7%

12%

6%

8%

4%

7%

0%

5%

0%

3%

0%

Figure 17: TEC 2 Electricity use distribution 

TEC 3 (Monochrome MFDs) 

Figure 18 shows the distribution of the energy efficiency of the TEC3 category, subdivided by 
ipm subcategories. The distribution is a straight, not weighted count of the number of models.  

Figure 18  shows  that 70% of  the models (611of n=868) have an energy performance in the 
range  of  30  to  100%  of  max  TEC.  The  other  30%  of  the  models  are  lower  than  30%  max 
TEC. There are no models featuring a 10% max TEC.  

Overall, the average energy efficiency in TEC 3 is around 43% max TEC. Note that this is the 
value for registered products. As stated in the VA, it should also be taken into account  that 
some 10% of products on the EU market are not registered.  

Number of products per efficiency class TEC 3  

s
t
c
u
d
o
r
p
f
o
r
e
b
m
u
N

250

200

150

100

50

0

Outside Energy Star

>68

26-68

10-26

<=10

0-10% 10-20% 20-30% 30-40% 40-50% 50-60% 60-70% 70-80% 80-90% 90-100% >100%

Percentage of max. TEC

Figure 18: Distribution of the energy efficiency of the TEC 3 category 

 
 
 
 
 
 
In order to investigate whether distribution of the energy efficiency also depends on product 
speed,  the  average  energy  consumption  in  kWh/year  was  calculated  per  ipm  subcategory, 
using  the  max  TEC  equation  for  that  product  category  and  the  average  ipm  value.  This  is 
shown in the table 14 below. 

Table 14: TEC 3 calculations per subcategory 

Product speed class (ipm) 

Average product speed (ipm) 
Max. TEC kWh/week 
Annual Max. TEC kWh/year 

>68 
<=10  10-26  26-68 
98.1 
40.9 
20.5 
10.0 
1.5 
38.7 
8.3 
2.5 
132.5  431.6  2010.3 
78.0 

The  annual  kWh/year  figures  were  then  used  to  give  a  weighting  to  the  straight  count  in 
Figure 19. 

As mentioned, this is not exactly a sales weighted outcome but it is as close as data allows.  

The figure below shows that the distribution is similar to the energy efficiency graph above. 

The average saving is more or less the same.  

Note that for products in the scope of the VA the max speed for monochrome products is <66 
ipm.  

TEC 3 electricity use distribution
Based on EU Energy Star database (Feb 2012), number of models (n=868) weighted by specific TEC 
energy value, subdivided by product speed in ipm

30%

25%

20%

15%

10%

5%

0%

0-10%

10-20%

20-30%

30-40%

40-50%

50-60%

60-70%

70-80%

80-90%

90-100%

>68

26-68

10-26

<=10

0%

0%

0%

0%

0%

1%

1%

0%

6%

5%

1%

0%

12%

7%

3%

0%

2%

11%

3%

0%

7%

7%

0%

0%

12%

12%

0%

0%

8%

4%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

Figure 19: TEC 3 Electricity use distribution 

TEC 4 (Colour MFDs) 

Figure 20 shows the distribution of the energy efficiency of the TEC4 category, subdivided by 
ipm subcategories. The distribution is a straight, not weighted count of the number of models.  

Figure 20 shows that 64% of the models (408 of n=642) have an energy performance in the 
range  of  50  to  100%  of  max  TEC.  The  other  36%  of  the  models  are  lower  than  50%  max 
TEC. There are no models featuring a 10% max TEC.  

 
 
 
 
Overall, the average energy efficiency in TEC 4 is around 61% max TEC. Note that this is the 
value for registered products. As stated in the VA, it should also be taken into account  that 
some 10% of products on the EU market are not registered.  

Number of products per efficiency class TEC 4 

s
t
c
u
d
o
r
p
f
o
r
e
b
m
u
N

120

100

80

60

40

20

0

Outside Energy Star

>62

26-62

<=26

0-10% 10-20% 20-30% 30-40% 40-50% 50-60% 60-70% 70-80% 80-90% 90-100% >100%

Percentage of max. TEC

Figure 20: Distribution of the energy efficiency of the TEC 4 category 

In order to investigate whether distribution of the energy efficiency also depends on product 
speed,  the  average  energy  consumption  in  kWh/year  was  calculated  per  ipm  subcategory, 
using  the  max  TEC  equation  for  that  product  category  and  the  average  ipm  value.  This  is 
shown in the table 15 below. 

Table 15: TEC 4 calculations per subcategory 

Product speed class (ipm) 
Average product speed (ipm)  21.0 
5.6 
Max. TEC kWh/week 
Annual Max. TEC kWh/year  291.1  575.7  1382.1 

<=26  26-62  >62 
73.7 
40.2 
26.6 
11.1 

The  annual  kWh/year  figures  were  then  used  to  give  a  weighting  to  the  straight  count  in 
Figure 21. 

As mentioned, this is not exactly a sales weighted outcome but it is as close as data allows.  

The figure below shows that the distribution is similar to the energy efficiency graph above. 

The average saving is more or less the same.  

Note that for products in the scope of the VA the max speed for colour products is <51 ipm.  

 
 
 
 
 
 
 
 
TEC 4 electricity use distribution
Based on EU Energy Star database (Feb 2012), number of models (n=642) weighted by specific TEC 
energy value, subdivided by product speed in ipm

30%

25%

20%

15%

10%

5%

0%

0-10%

10-20%

20-30%

30-40%

40-50%

50-60%

60-70%

70-80%

80-90%

90-100%

>62

26-62

<=26

0%

0%

0%

0%

0%

0%

0%

3%

1%

1%

4%

1%

4%

3%

1%

5%

3%

4%

10%

3%

3%

7%

5%

2%

3%

6%

4%

2%

20%

2%

Figure 21: TEC 4 Electricity use distribution 

 
 
 
 
 
 
ANNEX 8   ENERGY STAR COUNTRIES 

Energy Star countries 2004 

30%

13%

3%

2%

3%

49%

0%

1%

2%

EU-27

USA

Japan

Canada

Taiwan

Australia

NZ

Norway, Iceland and Liechtenstein

Figure 22: Countries where ENERGY STAR applied as percentage of inhabitants per country in 2004 
Source: http://www.eu-energystar.org/en/en_042.shtml  

ENERGY STAR is an international voluntary labelling scheme for energy-efficiency started 
by the US Environment Protection Agency (EPA) in 1992. Through an Agreement with the 
US government, the European Union participates in the ENERGY STAR scheme as far as it 
is related to office equipment.  

In 2007 the European Union (EU-27) represents a market of over 494 million consumers, or 
49% of the total of all ENERGY STAR countries (EC, US, Canada, Japan, Taiwan and 
Australia). In 2006 this EU market absorbed 79 million PCs including approx. 48 million 
laptops (Gartner, IDC), and over 12 million PC printers and 2 million copiers. In terms of 
market value, the EC represents roughly 170 billion EUR/year (EICTO), or roughly one third 
of the total ICT hardware market in the present ENERGY STAR countries. This shows that 
there is considerable potential for growth.  

Table 16: Population and number of households in millions, 2006 sources: http://www.eu-
energystar.org/en/en_042.shtml  

Country 

Population  Households 

AT 
BE  
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 

8.3 
10.51 
0.78 
10.29 
82.35 
5.45 
1.34 
11.17 
44.47 
5.28 
63.39 
10.06 

3.5 
4.5 
0.2 
4.1 
38.3 
2.5 
0.6 
3.9 
15.7 
2.4 
28.2 
4.4 

 
 
 
 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
SE 
SI 
SK 
UK 
BU 
RO 
EU-27 
NO 
IS 
LI 
EEA 
ENERGY STAR 
2007 

4.21 
58.75 
3.38 
0.46 
2.28 
0.41 
16.36 
38.13 
10.6 
9.11 
2.01 
5.39 
60.39 
7.68 
21.57 
494 
4.68 
0.31 
0.04 
5.03 
499 

1.4 
26.2 
1.4 
0.2 
0.9 
0.2 
7.3 
14.4 
3.8 
4.3 
0.7 
2.7 
27 
2.9 
8.2 
210 
2 
0.1 
0 
2.1 
212 

Other ENERGY STAR countries: 

USA  
Canada 
Japan 
Taiwan 
Australia 
NZ 
Total 

301.1 
33.4 
127.4 
22.9 
20.4 
4.1 
509 

Sources: 
Eurostat, CIA, US Census Bureau, Statistics 
Canada, US Department of State, Boverket, 
PRIMES, Australian Bureau of Statistics, NSI 
Bulgaria, INS Romania 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
ANNEX 9   VOLUNTARY AGREEMENT 

----------- DRAFT ----------- 

INDUSTRY VOLUNTARY AGREEMENT TO IMPROVE THE 
ENVIRONMENTAL PERFORMANCE 

 OF 

IMAGING EQUIPMENT PLACED ON THE EUROPEAN MARKET 

Version 3.5 

15 February 2011 

 
 
 
 
 
 
 
 
 
 
Contents 

1 

Introduction......................................................................................................................................87 

2  Objectives ........................................................................................................................................88 

3  Scope................................................................................................................................................88 

4  Commitments Part I – Design Requirements...................................................................................89 

5  Commitments Part II – Information Requirements .........................................................................91 

6  Reporting and monitoring ................................................................................................................93 

7  Nature and Organization of the Voluntary Agreement....................................................................94 

8  Voting Rules ....................................................................................................................................95 

9  Non Compliance ..............................................................................................................................95 

10  Verification ......................................................................................................................................96 

11  Revision of the Commitment ...........................................................................................................97 

12  Termination of the Voluntary Agreement........................................................................................97 

 
 
 
 
1 

INTRODUCTION 

The  Imaging  Industry  is  an  innovative  industry  with  a  long  track  record  on  environmental 
improvements.  The  Imaging  Industry  wishes  to  formalize  their  commitment  to  continuous 
improvement via this voluntary agreement (VA) which we believe will help to contribute to 
the achievement of the EU Action Plan on Energy Efficiency. It is expected that the proposed 
Commitments as defined herein will enable energy savings of around 1 to 1,5 TWh per year 
in  EU27  excluding  the  additional  savings  that  will  be  made  through  increased  resource 
efficiency.  This  Voluntary  Agreement  should  enable  customers  to  make  more  sustainable 
purchasing  decisions  by  providing  them  more  accurate  information  on  the  environmental 
performance of our products. 

The Imaging Industry has been working on this Voluntary Agreement since spring 2009 and 
has  been  open  for  participation  from  all  producers.  The  current  market  coverage  of  the 
companies involved in the drafting process is over 90% based on units sold in the EU. The 
goal is to continue to expand the coverage of the voluntary agreement and to include as many 
companies as possible.  

The scope of the voluntary agreement is based on the EuP Preparatory Study and linked with 
ENERGY STAR. It aims to target the highest sales volume products and technologies on the 
household  and  office  market.  Technologies  of  declining  markets  such  as  small  photo  and 
scanner devices have been excluded from the scope of the agreement to ensure that companies 
can focus resources on improving the performance of our products in the high volume, high 
growth markets/sectors..  

It became clear from the EuP Preparatory Studies on “Imaging Equipment” (Lot 4), that the 
product category Imaging Equipment contains a wide variety of product types, designed and 
marketed  for  a  wide  variety  of  markets  and  applications.  Products  range  from  a  very 
affordable  personal  printer  that  is  used  occasionally  by  a  private  household  user,  through 
multifunctional devices used in offices to accommodate the daily needs for copying, printing, 
scanning  and  faxing  of  documents  for  groups  of  office  workers,  up  to  highly  productive 
printing  systems  that  are  designed  to  run  continuously  in  print  rooms.  For  such  widely 
different  applications,  widely  different  imaging  technologies  have  been  developed  since 
instant printing emerged in the market in the 1920’s: inkjet printing and electrophotographic 
printing  are  the  most  well-known  of  the  core  technologies  used  in  the  printers  to  transfer 
information  onto  paper.  In  addition  to  the  core  technologies,  a  wide  range  of  additional 
convenient functionalities have been added to imaging equipment: ranging from modules for 
automated  duplex  printing,  into  modules  for  stapling,  punching  and  even  digital  document 
storage inside the printer’s memory. Each technology and each additional function has its own 
environmental  impact.  It  should  be  noted  that  the  implementations  of  the  core  technologies 
and  additional  functions  is  very  different  between  the  different  producers  in  the  imaging 
industry.  

When setting out to develop the underlying Voluntary Agreement, the imaging Industry was 
faced with the challenge to formulate requirements that are not only relevant and significant 
for  achieving  environmental  efficiency,  but  also  applicable  to  the  wide  range  of  different 
imaging products present in the market. Despite the fact that the imaging industry focussed on 
the products that are sold in the highest numbers, by limiting the product scope to household 
and office equipment, still the problem of diversity remained, which is mainly driven by the 
wide variety of customer requirements in the imaging market. 

 
 
 
 
For the reasons outlined above, the Imaging Industry will commit to the requirements in this 
Voluntary  Agreement  for  the  vast  majority  of  its  products.  Nevertheless  the  allowance  of 
exemptions could not be avoided.  

In  line  with  the  European  Commission  ‘Communication  on  Environmental  Agreements  at 
Community  level  within  the  Framework  of  the  Action  Plan  on  the  Simplification  and 
Improvement of the Regulatory Environment’115, this Agreement should be acknowledged by 
the European Commission through an exchange of letters with the Signatories. 

2 

OBJECTIVES 

2.1 

2.2 

Continuously  improve  the  environmental  performance  of  the  types  of  imaging 
equipment in scope of this agreement.  

Contribute  to  the  objectives  of  Directive  2009/125/EC  establishing  a  framework  for 
the setting of ecodesign requirements for energy-related products, in line with Recitals 
18-20 and Annex VIII on self-regulation. 

2.3 

Ensure  the  involvement of  all  stakeholders represented in the Consultation Forum in 
monitoring of the results and updating the requirements of the Voluntary Agreement. 

3 

SCOPE  

3.1  General:  All  terms  used  in  this  section  are  defined  in  Annex  C,  Part  VII  to  the 
Agreement  between  the  Government  of  the  United  States  and  the  European 
Community on the coordination of energy-efficiency labelling programmes for office 
equipment, as set out in the Annex of Commission Decision 2009/347/EC (ENERGY 
STAR). 

3.2 

For the purposes of this Agreement, “products” are understood as imaging equipment 
meeting the conditions in section 3.3. The terms “imaging equipment” and “product” 
do not include cartridges or other consumables 

3.3 

Scope: 

3.3.1  Product  categories:  The  Voluntary  Agreement  covers  imaging  equipment 
belonging to one of the following product categories that have been reviewed 
in the EuP Lot 4 preparatory study:  

•  Copiers 

•  Multifunction Devices (MFDs) 

•  Printers 

•  Fax machines 

115 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52002DC0412:EN:NOT  

 
 
 
 
 
                                                 
3.3.2  Cartridges: cartridges produced by or recommended by the OEM for use in the 
products set out in 3.3.1 

3.3.3  Marking  technologies:  This  Agreement  is  limited  to  the  following  marking 

technologies: 

•  Electrophotography (EP) 

• 

Inkjet (IJ), including high performance IJ 

•  Solid Ink (SI) 

3.3.4  Household and office equipment: This Agreement is limited to household and 
office equipment, meaning: 

•  Standard  BW  format  products  with  maximum  speed  <  66  A4  images  per 

minute  

•  Standard  Colour  format  products  with  maximum  speed  <51  A4  images  per 

minute  

(Speed to be rounded to the nearest integer as prescribed in the ENERGY STAR 
agreement). 

Other format products can be included in their reporting by individual Signatories 
on a voluntary basis but will not count but do not count for the target specified in 
4.1 a).. 

4 

COMMITMENTS PART I – DESIGN REQUIREMENTS 

Signatories commit to: 

4.1 

Compliance on primary requirements: 

a) Products as defined in section 3 and placed by Signatories on the EU market will 
meet the specifications of ENERGY STAR v1.1 and to duplex settings in accordance 
with the following target: 

By 1 January 2012: 90% or more of the products placed by a Signatory on the market. 

b) The specifications in ENERGY STAR v1.1 and duplex settings concern: 

1.  energy consumption requirements (TEC and OM products); 

2.  default delay times (OM products); and 

3.  duplex availability (TEC products). 

4.  duplex-printing is set as default when printing from the computer, meaning that the 
relevant software (driver or firmware) will be configured so that the first print-job 
will be in duplex unless the print settings have been modified at the stage when the 
product is first installed to function as intended. 

 
 
 
Summary of Duplex requirements for TEC approach products

Monochrome Print Speed

Duplex Requirements as per  Energy Star V 1.1

Colour 
products
<=19ppm

Monochrome 
products
<=24ppm No requirement

20-39ppm

25-44ppm

>=40ppm

>=45ppm

Automatic duplexing must be offered as a standard feature or optional 
accessory at the time of purchase.
Automatic duplexing is required as a standard feature at the time of 
purchase.

Default Duplex set at 
shipment or at installation

Not applicable
At discretion of either the user 
or manufacturer

Required

c) For the purposes of compliance with section (a) above, the rate of compliance shall 
be calculated following the methodology described in Annex B.  

d) A preliminary baseline will be established and published by 1 October 2011 on the 
basis of products placed by Signatories on the market during the first half of calendar 
year 2011 and their compliance to the above criteria. 

4.2   Availability of N-up printing. 

All  printing  products  placed  on  the  market  after  1  January  2012  offer  as  a  standard 
feature the capability to print several pages of a document on one sheet of paper, when 
the product is managed by an original software provided by the manufacturer (printer 
driver).  

4.3 

Design for recycling116 

For all new product models introduced after 1 January 2012 

4.3.1  Plastic parts >100 g shall be manually separable into recyclable plastic streams 

with commonly available tools. 

4.3.2  Product  shall  utilize  commonly  used  fasteners  for  joining  components, 

subassemblies, chassis and enclosures. 

4.3.3  Non-separable  connections  (e.g.  glued,  welded)  between  different  materials 

shall be avoided unless they are technically or legally required. 

4.3.4   Product  plastics  shall  be  marked  by  material  type  (ISO  11469  referring  ISO 
1043,  resin  identification  code,  SPI,  DIN,  or  country  specific).  Marking 
requirement  does  not  apply  to  plastic  parts  weighing  less  than  25g  or  with 
surface  area  less  than  50  cm2;  tape;  plastic  protective  and  stretch  wraps  and 
labels; or plastic pieces when due to shape marking is not possible. Exempted 
are plastic parts contained in reused complex modules 

4.4 

Cartridges117 

116 Following commitments are drawn from section 4.3.1 Disassemble-ability of the IEEE 1680.2 Draft Standard 

for Environmental Assessment of Imaging Equipment (EPEAT criteria)  

117  Following  commitments  are  drawn  from  section  4.9.4.  “Not  inhibiting  reuse  of  cartridges”  and  4.9.2  4. 
“Allow  use  of  Non-OEM  Cartridges”  of  the  IEEE  1680.2  Draft  Standard  for  Environmental  Assessment  of 
Imaging Equipment (EPEAT criteria)  

 
 
 
 
                                                 
 
For all products placed on the market after 1 January 2012 

4.4.1  any cartridge produced by or recommended by the OEM for use in the product 

is not designed to prevent its reuse and recycling. 

4.4.2 

the machine is not designed to prevent the use of a Non-OEM Cartridge. 

The requirements of paragraph 4.4 shall not be interpreted in such a way that would 
prevent  or  limit  innovation,  development  or  improvements  in  design  or  functionality 
of the products, cartridges, etc. 

An exception from the criteria in section 4.2 and 4.3 will be acceptable for models that 
are  sold  in  small  numbers  (less  than  5000  per  year),  on  the  ground  that  the  cost  of 
implementing  the  criteria  is  disproportionate  to  the  sales  of  the  product.  Exceptions 
should be reported to the Independent Inspector (see Annex C, section 4 for reporting 
template). 

5 

COMMITMENTS PART II – INFORMATION REQUIREMENTS 

Signatories commit to: 

5.1 

Environmental information for end-users in relation to use and end-of-life 

5.1.1  Resource- and energy-efficiency 

For  new  models  introduced  after  1  January  2012  Signatories  commit  to 
providing end-users with information regarding resource efficiency when using 
imaging equipment. The intent is to ensure the end-user is made aware of good 
efficiency  practices  when  they  first  begin  to  use  a  new  product.  Signatories 
shall achieve this through one of the following methods: 

•  A pop-up screen on the end-users’ computer during the initial installation 

of software (preferred)118 

•  An  insertion  sheet  provided  in/on  the  box  of  the  product  as  defined  in 

Section 3 above 

•  An  information  sheet  to  be  provided  at  the  time  of  sale  of  the  product  as 

defined in Section 3 above 

The following information shall be provided as a minimum119 where applicable: 

118 This can only be implemented when imaging equipments are managed through computers under mainstream 
Operating Systems (Microsoft Windows or Mac/OS)  
119 Not all 5 statements mentioned in section 5.1.1 may be applicable to the product that is equipped with this 
information. Manufacturers are free to choose if they add a statement to this effect to the information, or leave 
out statements that are not applicable, such as the statement regarding electrophotography and duplex printing. 

 
 
 
 
 
                                                 
Information that recycled as well as virgin paper certified under 
5.1.1.1  
environmental stewardship initiatives, or carrying recognised ecolabels, may be 
suitable  providing  that  it  meets  appropriate  quality  standards  as  defined,  for 
example, in EN 12281 on “Printing and business paper for dry toner imaging 
processes” for papers in the range 75-250 g/m2. For specific applications, the 
lower boundary may be chosen at 64 g/m2. 

5.1.1.2  
For Electro Photography printers: indication that these can print 
on 64 gr/m2 paper and that this paper contains less raw material per print, thus 
saving significant resources.  

5.1.1.3  
products 

Energy can be saved by purchasing ENERGY STAR compliant 

5.1.1.4    
products having a duplex function) 

Description of the benefits of printing in duplex mode (for TEC 

5.1.1.4  

The environmental benefits of power management  

The  information  as  described  in  sections  0  through  0  will  be  provided  in  the 
form of compact statements.  

This paragraph 0 applies to: all new product models introduced after January 1, 
2012.  Paper  weight  mentioned  in  the  pop-up  window  (or  alternatives  as 
described above) will be consistent with the paper weight specifications of the 
product. 

5.1.2  Cartridge disposal and treatment 

For  products  placed  on  the  market  after  1  January  2012,  Signatories  will 
provide end-users with information on suitable end-of-life management options 
for  used  cartridges.  This  information  may  be  communicated  via  a  company 
website. 

5.2 

Information on product environmental characteristics to be provided by Signatories  

The following applies to products placed on the market after 1 January 2012. 

5.2.1  Signatories  will  make  information  on  the  environmental  performance  of  their 
products  available  to  customers.  This  information  may  take  the  form  of  for  example 
ECMA 370 The Eco Declaration120, EPEAT verification documentation121, or similar 
company formats.  

120 The eco declaration (ECMA 370) is a communication tool for customers.  ECMA 370 declaration was developed to 
answer questions from customers to choose the best supplier. The standard addresses individual company programs and 
product related attributes.  
121 EPEAT, the Electronic Product Environmental Assessment Tool, is a set of environmental criteria to support 
green  public  procurement  and  environmentally  conscious  purchasing  decisions.  For  Imaging  Equipment,  an 
EPEAT  standard  is  being  developed  (IEEE1680.2)  that  will  include  a  specification  of  the  verification 
documentation that the manufacturer has to make available in order to have a product registered with EPEAT. 
This documentation will provide disclosure of environmental performance. 

 
 
 
                                                 
5.2.2  Signatories will make information on inkjet and toner cartridge yield available 
to  customers  based  on  the  measurement  standards  specified,  for  example,  in 
ISO/IEC 24711:2006 (for ink), ISO/IEC 19752:2004 (for monochrome toner) , 
or ISO/IEC 19798:2006 (for colour toner). or through other company methods. 

An exception from the criteria in section 5.1 and 5.2 will be acceptable for models that 
are  sold  in  small  numbers  (less  than  5000  per  year),  on  the  ground  that  the  cost  of 
implementing  the  criteria  is  disproportionate  to  the  sales  of  the  product.  Exceptions 
should be reported to the Independent Inspector (see Annex C, section 4 for reporting 
template). 

6 

REPORTING AND MONITORING 

6.1 

Signatories shall submit to an Independent Inspector reports based on compliance with 
the Voluntary Agreement (the “Reports”) according to the guidelines in this Section 

6.2 

The reports shall include:  

•  Company name 

•  Compliance status (compliant/non-compliant) + sales data per model (to allow for 

verification) 

•  Rate of compliance with the commitments listed in section 4.1. 

•  Compliance confirmation for all other commitments 

Annex C shows the template according to which the Reports shall be prepared by the 
Signatories. 

Compliance  to  all  Commitments  has  to  be  reported  according  to  the  following 
schedule:  

- 

,A first Report by October 1st 2011 shall cover products placed on the market and 
Signatory  commitments  between  January  1st,  2011  and  June  30th  ,  2011.  This 
Report will establish the initial baseline for the Voluntary Agreement. 

-  A  second  Report  by  July  1st  2012  shall  cover  products  placed  on  the  market 
between October 1st 2011 and March 31st 2012 and demonstrate compliance with 
targets set for January 1, 2012. 

-  Unless  differently  stated  in  next  revisions  of  the  current  Voluntary  Agreement, 
following reports will be established by March 31st every year covering products 
placed  on  the  market  during  the  previous  full  calendar  year  ,  e.g.  by  March 
31st,2013  for  products  placed  on  the  market  between  January  1st,  2012  and 
December 31st, 2012 

Within two weeks following the end of a reporting period, the Independent Inspector 
shall send a request to the Signatories to file their Reports. These shall be submitted no 
later  than  three  months  after  the  end  of  the  reporting  period  to  the  Independent 
Inspector.  

 
 
 
 
The Reports shall be compiled by the Independent Inspector into an annual progress 
report  (the  “Annual  Progress  Report”)  that  will  be  submitted  to  the  Steering 
Committee  within  4  months  following  the  end  of  a  period.  This  Annual  Progress 
Report will be prepared by the Independent Inspector and will only show anonymous 
results.  Signatories  will  not  be  named  although  individual  achievements  shall  be 
disclosed (company A, company B, etc). 

The Independent Inspector shall be responsible for ensuring that confidentiality of the 
Signatory’s identity and any data or information provided to it under or in relation to 
this  agreement  is  maintained  this  shall  include  entering  into  a  non-disclosure 
agreement with each Signatory if requested by the Signatory..  

6.3 

The Steering Committee will meet at least once a year to discuss the Annual Progress 
Report  and  shall  decide  if  an  independent  audit  is  required  to  verify  the  accuracy  of 
"Annual Progress Report" or of an individual signatory. The results of the independent 
audit  will  be  submitted  to  the  Steering  Committee.  Any  independent  auditor  will  be 
required  to  treat  the  identity  and  data  of  the  Signatories  as  confidential  and  shall  if 
requested by any Signatory enter into a non-disclosure agreement with each Signatory 
before having access to the data. 

7 

NATURE AND ORGANIZATION OF THE VOLUNTARY AGREEMENT  

7.1 

Nature of the Voluntary Agreement 

The  Signatory  signs  and  enters  into  this  Agreement  for  and  on  behalf  of  itself  and 
makes  its  Commitment  under  the  Agreement  to  the  European  Commission.  The 
consequences of non-compliance are set out in section 9. 

This Agreement shall not amount to a commercial agreement and shall not give rise to 
any  commercial  expectations  or  liabilities  between  the  Signatories  in  respect  of  the 
fulfilment of their individual Commitments as listed in this Voluntary Agreement.  

All Signatories will be treated equally and there shall be no special arrangements for 
individual Signatories. 

7.2 

Organisation of the Voluntary Agreement 

Each Signatory to the Agreement as well as the European Commission shall have the 
right to nominate one person to represent it at the Steering Committee. 

The  Steering  Committee  shall  elect,  from  amongst  its  members,  a  Chair.  The  Chair 
shall be responsible for convening the Steering Committee at regular intervals (and at 
least  twice  within  every  Reporting  Period)  and  for  running  such  meetings  of  the 
Steering  Committee.  The  Chair  shall,  however,  have  no  executive  or  representative 
function unless this is delegated to them by the Steering Committee. 

Meetings of the Steering Committee shall be open to  

•  any person representing a Signatory or potential signatory to agreement,  

• 

to any representatives of the European Commission or Member States, as well as 
member states of the EEA or EFTA, and  

 
 
 
 
 
•  organizations that have a permanent seat on the Consultation Forum. 

The Steering Committee will seek to achieve agreement by consensus at all times. If 
consensus  cannot  be  achieved,  the  Steering  Committee  may  reach  a  decision  in 
accordance  with  the  voting  procedures  described  in  Section  8  of  this  Voluntary 
Agreement. The Steering Committee may decide to develop and adopt further rules of 
procedure  where  it  deems  it  necessary  and  may  decide  to  delegate  powers  where  it 
deems it to be necessary to specific individuals or to sub-committees. 

8 

VOTING RULES  

All  reasonable  efforts  shall  be  taken  to  ensure  that  the  decisions  of  the  Steering  Committee 
are taken on the basis of a consensus.  

However, where consensus on an issue cannot be achieved in the course of a meeting of the 
Steering  Committee,  a  call  for  an  indicative  vote  may  be  made  by  the  Steering  Committee 
Chair or by a Quorum. 

During  any  voting  procedure  of  the  Steering  Committee  each  Signatory  shall  be  entitled  to 
cast a single vote. 

If the indicative vote indicates a favourable outcome (two-thirds majority or greater in favour) 
but  a  consensus  is  nonetheless  not  achieved,  a  call  for  a  deciding  vote  may  be  made  by  a 
Quorum  to  be  held  at  the  following  meeting  of  the  Steering  Committee.  At  such  second 
meeting,  the  adoption  of  a  decision  shall  be  made  in  accordance  with  the  Voting  Rules.  At 
such second meeting, the adoption of a decision shall require: 

a.  a Quorum  

b.  the agreement of a two-thirds majority of the Quorum. 

9 

NON COMPLIANCE  

Individual  companies  will  work  towards  the  fulfilment  of  the  compliance  rate set  out  in 
section  4.1  of this  Voluntary  Agreement.  In  case  a  Signatory  fails  to  meet  the  compliance 
rate, actions will be taken, depending on the level of non-compliance: 

•  Under achievement of the target by ≤ 5%: The Signatory will have a grace period of 6 
months to achieve the target and present an updated semester progress report. During 
those 6 months, the Signatory will not be required to achieve any new target set out in 
a revision of the Voluntary Agreement. If the Signatory fails to achieve the target, the 
Steering  Committee  will  start  discussions  with  the  Signatory  in  order  to  develop  a 
suitable way forward. The Steering Committee may decide to change the Signatory’s 
status  from  Signatory  to  Defaulting  Signatory.  Until  the  Defaulting  Signatory  fulfils 
the target, no new targets will apply.  

•  Under  achievement  of  the  target  by  >  5%:  the  Steering  Committee  will  start 
discussions  with  the  Signatory  in  order  to  develop  a  suitable  way  forward.  The 
Steering Committee shall change the status from Signatory to Defaulting Signatory.  

 
 
 
 
• 

If the Signatory does not comply within the set deadline as agreed with the Steering 
Committee, the Signatory shall be deemed not to take part any more in the Voluntary 
Agreement and shall be deleted from the list of Signatories.  

10  VERIFICATION 

10.1  Compliance  to  commitments  Part  I  -  Design  Requirements  as  described  in  section  4 
shall  be  verified  on  the  basis  of  the  signatory’s  report  according  to  the  template  as 
given in Annex C. 

10.2  Compliance  to  Commitments  Part  II  –  Information  Requirements  as  described  in 
section  5  can  be  verified  by  the  Independent  Inspector  by  requesting  the 
documentation  as  described  below.  Signatories  shall  provide  the  Independent 
Inspector with the requested documentation within 4 weeks of a request.  

a.  For section 5.1.1 

Resource- and energy-efficiency: Upon request, the software or 
information  sheet,  according  to  the  delivery  method  for  a  given  product  will  be 
provided to the Independent Inspector. 

b.  For section 5.1.2 

Cartridge  disposal  and  treatment:  Upon  request,  the  respective 
documents  and/or  the  website  address  shall  be  made  available  to  the  Independent 
Inspector. 

For  section  5.2  Information  on  product  environmental  characteristics:  Upon  request, 
the respective documents (5.2.1 and 5.2.2) will be made available to the Independent 
Inspector 

10.3 

In  case  an  organization  as  listed  in  section  7.2  wants  to  verify  the  compliance  of  a 
product that falls under the Voluntary Agreement, the request has to be addressed to 
the  Independent  Inspector  and  the  Signatory.  Only  the  Independent  Inspector  shall 
provide  the  organization  with  the  compliance  status  of  a  model  (yes/no)  on  a 
confidential basis within 2 weeks. Within 4 weeks of receiving the compliance status, 
the  organization  shall  be  required  to  inform  both  the  Independent  Inspector  and  the 
Signatory of the results of the verification.  

The  Independent  Inspector  shall  only  respond  to  requests  for  specific  models  and  is 
not  allowed  to  disclose  lists  on  the  compliance  status  of  a  Signatory’s  product 
portfolio. 

11  REVISION OF THE COMMITMENT  

A  revision  of  the  Voluntary  Agreement  will  take  place  at  the  earliest  of  the  following  two 
dates: 

•  3  months  after  the  publication  of  a  new  version  of  the  ENERGY  STAR  programme 

Requirements for Imaging Equipment 

•  1 January 2013. 

 
 
 
 
 
The  Steering  Committee  may  decide  if  a  revision  of  the  Voluntary  Agreement  is  required 
after 2013. 

12  TERMINATION OF THE VOLUNTARY AGREEMENT 

Signatories  can  terminate  their  individual  participation  in  the  Voluntary  Agreement  by 
sending  a  letter  to  the  chair  of  the  Steering  Committee  to  an  address  that  will  be 
communicated in due time in writing by the chair.  

The  Steering  Committee  may  decide  to  terminate  the  Voluntary  Agreement  at  any  time  . 
Reasons for termination could be, but are not limited to: 

•  Signatories no longer represent a significant majority of the market (i.e. over 80%); 

•  A majority of Signatories do not meet the Commitments of the Voluntary Agreement 

•  Legislation is implemented that overrules or conflicts with the Voluntary Agreement 

•  Signatories have a considerable disadvantage over “free riders” 

ANNEX A: DEFINITIONS 

All terms used in this document and not defined in this Annex A are defined in Annex C, Part 
VII  to  the  Agreement  between  the  Government  of  the  United  States  and  the  European 
Community  on  the  coordination  of  energy-efficiency  labelling  programmes  for  office 
equipment, as stated in the Annex of Commission decision 2009/347/EC (EU Energy star) 

1.  Signatories:  means  all  member  companies  that  have  signed  this  Voluntary 
Agreement. See in section 1 the name of Signatories of this Voluntary Agreement.  

2.  Potential Signatories: means printer producers, which produce and distribute at least 

one device of the product categories listed in Section 3.3. 

3.  Commitments:  means  the  Commitments  described  in  Sections  4  and  5  to  this 

Agreement altogether. 

4.  Defaulting Signatories: means all Signatories given the status of Defaulting Signatory 

by the Commission in accordance with Section 9.  

5.  Copier:  A  commercially-available  imaging  product  whose  sole  function  is  the 
production of hard copy duplicates from graphic hard copy originals. The unit must be 
capable  of  being  powered  from  a  wall  outlet  or  from  a  data  or  network  connection. 
This  definition  is  intended  to  cover  products  that  are  marketed  as  copiers  or 
upgradeable digital copiers (UDCs).  

6.  Fax Machine:  commercially-available  imaging  product whose primary functions are 
scanning hard copy originals for electronic transmission to remote units and receiving 
similar electronic transmissions to produce hard copy output. Electronic transmission 
is primarily over a public telephone system, but also may be via computer network or 
the Internet. The product also may be capable of producing hard copy duplicates. The 
unit must be capable of being powered from a wall outlet or from a data or network 

 
 
 
 
connection.  This  definition  is  intended  to  cover  products  that  are  marketed  as  fax 
machines.  

7.  Multifunction Device (MFD): A commercially-available imaging product, which is a 
physically-integrated device or a combination of functionally-integrated components, 
that  performs  two  or  more  of  the  core  functions  of  copying,  printing,  scanning,  or 
faxing.  The  copy  functionality  as  addressed  in  this  definition  is  considered  to  be 
distinct  from  single  sheet  convenience  copying  offered  by  fax  machines.  The  unit 
must  be  capable  of  being  powered  from  a  wall  outlet  or  from  a  data  or  network 
connection. This definition is intended to cover products that are marketed as MFDs or 
multifunction products (MFPs).  

8.  Printer: A commercially-available imaging product that serves as a hard copy output 
device,  and  is  capable  of  receiving  information  from  single-user  or  networked 
computers, or other input devices (e.g., digital cameras). The unit must be capable of 
being  powered  from  a  wall  outlet  or  from  a  data  or  network  connection.  This 
definition  is  intended  to  cover  products  that  are  marketed  as  printers,  including 
printers that can be upgraded into MFDs in the field.  

9.  Electrophotography (EP): A marking technology characterized by illumination of a 
photoconductor  in  a  pattern  representing  the  desired  hard  copy  image  via  a  light 
source, development of the image with particles of toner using the latent image on the 
photoconductor to define the presence or absence of toner at a given location, transfer 
of the toner to the final hard copy medium, and fusing to cause the desired hard copy 
to  become  durable.  Types  of  EP  include  Laser,  LED,  and  LCD.  Color  EP  is 
distinguished from monochrome EP in that toners of at least three different colors are 
available in a given product at one time. Two types of color EP technology are defined 
below:  

a. Parallel Color EP – A marking technology that uses multiple light sources and 
multiple photoconductors to increase the maximum color printing speed.  

b. Serial Color EP – A marking technology that uses a single photoconductor in a 
serial  fashion  and  one  or  multiple  light  sources  to  achieve  the  multi-color  hard 
copy output.  

10. Ink Jet (IJ): A marking technology where images are formed by depositing colorant 
in small drops directly to the print media in a matrix manner. Color IJ is distinguished 
from  monochrome  IJ  in  that  more  than  one colorant  is  available  in  a  product  at  any 
one  time.  Typical  types  of  IJ  include  Piezo-electric  (PE)  IJ,  IJ  Sublimation,  and 
Thermal IJ.  

11. High  Performance  IJ:  The  use  of  an  IJ  marking  technology  in  high-performance 
business  applications  usually  occupied  by  electrophotographic  marking  technology. 
This  difference  between  the  conventional  IJ  product  and  the  High  Performance  IJ 
product  is  denoted  by  the  presence  of  nozzle  arrays  that  span  the  width  of  a  page 
and/or  the  ability  to  dry  the  ink  on  the  media  through  additional  media  heating 
mechanisms.  

12. Solid Ink (SI): A marking technology where the ink is solid at room temperature and 
liquid when heated to the jetting temperature. Transfer to the media can be direct, but 
is  most  often  made  to  an  intermediate  drum  or  belt  and  then  offset  printed  to  the 
media.  

 
 
13. Member States: The member states of the European Community 

14. Quorum:  Two  thirds  of  the  Signatories  who  requested  to  be  on  the  Steering 

Committee being present at a meeting. 

15. Consultation  Forum:  as  defined  by  Article  18  of  the  2009/125/EC  Directive,  and 
2008/591/EC Commission Decision, the assembly ensuring a balanced participation of 
Member  States’  representatives  and  all  interested  parties  concerned  with  the  product 
or product group in question 

16. Steering  Committee:  The  co-ordinating  and  governing  body  of  this  Voluntary 

Agreement, appointed in accordance with the principles set out in Section 7  

17. Compliance  period:  the  period  over  which  companies  measure  their  performance 

against the Commitments of the Voluntary Agreement 

18. Placing  on  market:  the  act  of  making  a  product  available  for  the  first  time  on  the 
Community  market  with  a  view  to  its  distribution  or  use  within  the  Community 
whether  for  reward  or  free  of  charge  and  irrespective  of  the  selling  technique. 
Guidance  on  this  definition  is  available  in  the  Guide  to  the  Implementation  of 
Directives Based on New Approach and Global Approach.  
http://ec.europa.eu/enterprise/newapproach/legislation/guide/index.htm  

19. Independent  Inspector:  The  independent  third  party  designated  by  the  Steering 
Committee (on behalf of all Signatories) and who is tasked with, and responsible for, 
the  collection  and  processing  of  information  supplied  by  Signatories  pursuant  to 
Section  6  and  Annex  B,  and  determining  a  Signatory’s  compliance  with  the 
Agreement  in  accordance  the  Commitments..  The  Steering  Committee  shall  engage 
the services of the Independent Inspector upon terms and conditions that shall require 
undertakings  of  confidentiality from the Independent Inspector, and which shall also 
set out any requirements or applicable mechanisms for a process of appeal, in case this 
is ever be necessary; 

20. End-user:  A  person  who  uses  the  imaging  equipment  for  one  of  its  main  functions 
(e.g.  printing,  scanning,  copying).  The  end-user  has  control  over  the  environmental 
impact of the product by choosing the type and weight of paper and by using duplex 
and/or  n-up  printing.  Further,  the  end-user  can  be  expected  to  exhange  consumables 
e.g. cartridges. 

21. Customer: A person or legal entity who takes purchasing decisions for the products 

covered in this voluntary agreement. 

22. TEC: Typical Electricity Consumption method for the Version 1.1 ENERGY STAR 
Imaging  Equipment  (IE)  specification.  The  procedure  is  to  be  used  to  obtain  and 
evaluate the TEC of Standard-size IE products such as copiers, digital duplicators, fax 
machines,  multifunction  devices  (MFDs),  and  printers  that  use  high-temperature 
technologies  such  as  Electrophotography  (EP)  and  Solid  Ink  (SI),  and  those  that 
provide comparable functionality. It is not intended for low-temperature technologies 
such  as  conventional  Ink  Jet  (IJ)  or  Impact,  nor  for  Large-format  or  Small-format 
products. The key result of this test procedure is a value for typical weekly electricity 
consumption. 

 
 
23. OM: Operational Mode: ENERGY STAR Imaging Equipment (IE) specification. The 
procedure is to be used to quantify the power consumption of imaging products that do 
not utilize the Typical Electricity Consumption (TEC) method. Examples of products 
that will be tested with this OM method include those that use marking technologies 
such  as  Ink  Jet,  Dot  Matrix  or  Impact,  as  well  as  scanners  and  all  large-format  and 
small-format  devices.  The  key  results  of  this  test  procedure  are  power  values  for 
Ready, Sleep, and Off modes. 

24. Standard  Size  Format  Product:  Products  categorized  as  Standard  include  those 
designed  for  standard-sized  media  (e.g.,  Letter,  Legal,  Ledger,  A3,  A4,  and  B4), 
including  those  designed  to  accommodate  continuous-form  media  at  widths  between 
210  mm  and  406  mm.  Standard-size  products  may  also  be  capable  of  printing  on 
small-format media. 

25. Commonly available tools: Widely used, commercially available tools..  

26. Non-OEM  Cartridge:  A  toner  or  ink  cartridge  not  sold  by  the  OEM  that  is 

remanufactured and/or refilled.  

 
 
ANNEX B: CALCULATING THE COMPLIANCE RATE 

The compliance rate is the percentage of compliant units in scope and placed on the market in 
relation to the total number of units in scope and placed on the market. A model is considered 
compliant when it meets all the requirements as detailed in section 4.1. This means that if a 
model  doesn’t  meet  a  requirement  it  will  not  be  counted  towards  the  company  compliance 
rate.  The  compliance  rate  will  be  calculated  to  2  significant  figures  as  a  sales  weighted 
number meaning that models with high sales will weigh heavier in calculating the compliance 
rate than low sales models.  

            Compliance rate = 

Compliant units in scope and placed on the market-
Total units in scope and placed on the market 

Table 17 shows a simplified example of how the compliance rate can be calculated internally 
by a company.  

Table 17; calculating the compliance rate on sales for a given period 

EU shipments from 1st October 2011 to 31st March 2012

Compliance to requirements

Model 
name

product 
description

Model 1

IJ printer

Model 2

IJ MFD

Model 3

IJ MFD

Model 4

IJ printer

Model 5 EP mono printer 

Model 6 EP mono MFD

Model 7 EP color printer 

Model 8 EP color MFD

Model 9 EP mono printer

Energy Star 
qualifying 
approach 
(TEC or OM)

Mono print 
speed 
(ipm)

Sleep 
power(W)

OM Max 
sleep 
power 
allowance 
(W)

OM 
default 
delay time 
(Y/N)

TEC 
(kWh/we
ek)

Max 
TEC(kWh/
week)

duplex 
capability 
(Y/N)

duplex set 
as default 
(Y/N)

Product 
compliant 
(Y/N)

Total units 
shipped

Total 
compliant 
units

OM

OM

OM

OM

TEC

TEC

TEC

TEC

TEC

NA

NA

NA

NA

35

50

40

35

35

2

4,5

4

2,5

NA

NA

NA

NA

NA

1,4

4,9

4,9

2,9

NA

NA

NA

NA

NA

Y

Y

Y

Y

NA

NA

NA

NA

NA

NA

NA

NA

NA

2,5

13

8

9

2,7

NA

NA

NA

NA

3

11,5

8,8

9,25

3

NA

NA

NA

NA

N

Y

Y

N

Y*

NA

NA

NA

NA

NA

N

N

NA

NA

N

Y

Y

Y

N

N

N

N

Y

*optional

Total

20

20

60

100

40

100

10

20

100

470

0

20

60

100

0

0

0

0

100

280

Compliance rate

60%

 
 
 
 
  
 
 
 
 
ANNEX C: REPORTING FORM TO BE USED TO REPORT TO INDEPENDENT INSPECTOR 

Section 1: general information 

The organisation/company:………………………………………………… 

Reporting Period: …………………………………………………………… 

Section 2: report on compliance to commitments in section 4.1 

Table 2: reporting table 

Model 

Units placed on 
in 
the  market 
EU 

Product 
compliant? 

Number 
compliant units 

of 

Number  of  non 
compliant units 

Total 

Total 

Compliance 
rate 

Section 3: manufacturers declarations 

The manufacturer states that: 

(cid:133)  : All printing products placed on the market after 1 January 2012 offer N-up printing 
as a standard feature in conformity with section 4.2.2 of the voluntary agreement 

(cid:133)  :  All  new  models  introduced  after  1  January  2012  are  designed  in  view  of  their 
recycling in conformity with section 4.3 of the voluntary agreement 

(cid:133)  :  For  all  printing  products  placed  on  the  market  after  1  January  2012  manufacturers 
ensure that equipment and cartridges are not designed in a way to prevent re-use and the use 
of non-OEM consumables in conformity with section 4.4 of the voluntary agreement 

(cid:133)  :  End-user  information  has  been  implemented  for  all  new  models  introduced  after  1 
January 2012, in conformity with section 5.1.1 of the voluntary agreement 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(cid:133)  : information on the environmental performance of all the company’s products sold in 
the  EU  has  been  made  available  to  customers  in  conformity  with  section  5.2.1  of  the 
voluntary agreement 

(cid:133)  : information on inkjet and toner cartridge yield has been made available to customers 
in  conformity  with  section  5.2.2  of  the  voluntary  agreement  (the  following  measurement 
standards were used) 

(cid:133)  : information on suitable end of life management options for used cartridges has been 
provided to end-users 

Section 4: list of products that are exempted from the statements in section 3 of this report 

The following products are exempted from the statements as done in section 3 of this report: 

Reports on exceptions should include: 

To what requirement is the excemption reported 

Which are the excepted products 

What are the annual sales of these products 

Section 5: Signature 

The signer hereby declares that the information stated in this report is correct and represents 
all information available with respect to the Commitments in the INDUSTRY VOLUNTARY 
AGREEMENT TO IMPROVE THE ENVIRONMENTAL PERFORMANCE OF IMAGING 
EQUIPMENT PLACED ON THE EUROPEAN MARKET. 

Name of manufacturer: 

Name of authorized person 

- 

- 

Function 

Date 

- 

Signature 

- 

- 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
8. 

ANNEX D: SIGNING FORM  

The organisation/company/ 

 ……………………………………………………………….. 

Signs  this  Voluntary  Agreement  with  the  objective  to  improve  the  Environmental 
Performance of its imaging equipment as covered by the scope of the Voluntary Agreement. 
More specifically the Signatory commits to:  

Meet the Commitments and compliance rate as set out in section 4and 5  

Provide annual reports on its performance as set out in section 6 

For the Signatory  

Director or person authorised to sign: 

Name:  ……………………………………………… 
Function:…………………………………………….. 
Address:…………………………………………….. 
……………………………………………… 
……………………………………………… 
..…………………………………………….. 

Date: …………………………………. 
Signature…………………………………. 
Contact Person for the Organisation/Company: 
Name:  ……………………………………………… 
Function:…………………………………………….. 
Email:………………………………………………... 
Telephone:………………………………………….. 

Please send a duly signed and completed Signing Form to: 
European Commission 
Directorate-General for Energy and Transport 
Directorate D - New and renewable sources of energy, Energy efficiency & Innovation 
Unit D3 - Energy efficiency of products & Intelligent Energy - Europe 
Office DM24, 04/24 
Rue de Mot 24-26 
B-1049 Brussels 

ANNEX E: EXAMPLE OF PRODUCT ENVIRONMENTAL INFORMATION 

Following  is  an  example  of  product  environmental  information  provided  by  Signatories, 
based  on  the  ECMA  370  standard.  Other  standard  formats  can  be  used  by  Signatories.

 
 
 
 
 
 
 
 
ANNEX 10   SCENARIO DATA 

Stock model methodology & detailed results  

The impact analysis uses the variable inputs as defined in the following paragraphs and used 
in Chapter 5.  

The calculation method for the analysis is a so-called Stock Model, which means that it is 
derived from accumulated annual sales of imaging equipment over the period 1995-2030.  

The  stock-model  sets  the  pace  for  the  sub-options.  The  direction  is  determined  by 
characteristics (TEC, standby, DFE etc.) and number of print pages. From these stock data the 
fitting sales data were calculated 

Outputs for each sub-option are: 

•  Electricity consumption in TWh/a; 

•  Carbon  emission  in  Mt  CO2  equivalent/a,  using  a  multiplier  based  on  electricity  and 
gas shares (see below) and the values from the EcoReport in the preparatory study, 

•  Paper consumption (duplexing) 

Final  outcomes  are  presented  at  a  high  aggregation  level  (totals),  but  in  the  intermediate 
stages a distinction is made by the typology and by size.  

For  the  economic  calculations,  an  average  energy  price  in  €/  kWh  primary  energy  is  built 
from: 

•  Electricity  rates  per  kWh  primary  energy.  For  electricity,  the  assumption  is  to  use 

residential electricity rates excluding taxes in 2006, i.e. € 0.16/kWh;  

•  Annual (long-term 2011-2030 average) electricity price rate increase of 4%. 

Data from Chapter 2 and 5 are used for the definition of the base case and calculated on the 
basis of the relative market shares of the lamp categories considered.  

Baseline- and scenario’s additional information 

Sales and stock 

The sales of imaging equipment have been assessed by the preparatory study on the basis of 
PRODCOM EU trade data and data presented by InfoTrends.  

In the period 1995 – 2005 an average market growth of between 1 and 2,5% per year has been 
used in order to level out big fluctuations. This number has been checked according to sales 

 
 
 
 
and stock data presented by Telecompaper122 and indications mentioned in the beginning of 
task 2 of the preparatory study.  

The preparatory study covers the sales and stock data for the period 2005-2030. 

Sales 

Table 18: Sales data IE in EU-27 (in millions) 

EP-Copier mono 
EP-Copier colour 

EP-printer mono 

EP-printer colour 
IJ SFD printer 

IJ MFD printer 

1995 
2.00 
0.00 

3.58 

0.00 
7.87 

6.46 

2005 
1.33 
0.14 

3.68 

0.76 
12.33 

10.11 

Sales Total 

19.91 

28.34 

2010 
0.94 
0.19 

3.35 

1.29 
9.66 

16.09 

31.52 

2013 
0.72 
0.61 

3.15 

1.63 
7.90 

19.69 

33.68 

2016 
0.48 
0.93 

2.82 

2.07 
5.88 

23.28 

35.46 

2019 
0.25 
1.19 

2.50 

2.50 
5.00 

25.00 

36.44 

2022 
0.21 
1.31 

2.31 

2.76 
4.25 

26.50 

37.34 

2025 
0.18 
1.40 

2.05 

3.10 
3.50 

28.00 

38.23 

2030 
0.11 
1.53 

1.83 

3.60 
3.00 

30.50 

40.56 

Sales data EU-27 IE

EP-Copier mono

EP-Copier colour

EP-printer mono

EP-printer colour

IJ SFD printer

IJ MFD printer

)
s
n
o

i
l
l
i

m

(
d
o
s

l

s
t
i
n
U

35,0

30,0

25,0

20,0

15,0

10,0

5,0

0,0

1995

2005

2010

2013

2016

2019

2022

2025

2030

Figure 23: EU-27 IE sales data per base case (in millions) 

Stock 

122 http://www.telecompaper.com/news/copier-market-is-currently-around-13-mil-unitsy  

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 19: Stock data IE in EU-27 (millions) 

Millions 

EP-Copier mono 
EP-Copier colour 

EP-printer mono 

EP-printer colour 
IJ SFD printer 

IJ MFD printer 

1995 
5.00 
0.00 

11.91 

0.00 
29.49 

24.17 

2005 
5.97 
0.38 

14.74 

1.92 
68.41 

37.85 

2010 
4.12 
0.69 

14.31 

4.20 
31.32 

77.78 

2013 
3.19 
1.98 

13.01 

5.94 
27.53 

85.11 

2016 
2.25 
3.28 

11.72 

7.68 
24.00 

92.00 

2019 
1.31 
4.57 

10.43 

9.42 
21.00 

98.00 

2022 
0.90 
5.20 

9.40 

10.80 
18.00 

2025 
0.75 
5.50 

8.50 

12.00 
15.00 

2030 
0.50 
6.00 

7.50 

14.00 
12.50 

104.00 

110.00 

120.00 

Stock Total 

70.56 

129.27 

132.42 

136.76 

140.93 

144.73 

148.30 

151.75 

160.50 

EU-27 stock IE

)
s
n
o

i
l
l
i

M

(
k
c
o
t
S

140,0

120,0

100,0

80,0

60,0

40,0

20,0

0,0

EP-Copier mono

EP-Copier colour

EP-printer mono

EP-printer colour

IJ SFD printer

IJ MFD printer

1995

2005

2010

2013

2016

2019

2022

2025

2030

Figure 24: EU-27 stock data IE per base case (in millions) 

The BAU shares its input values as regards sales and stock of IE, electricity prices, product 
life and many more economic variables with the sub-options considered. The impacts of the 
sub-options are compared with BAU, which provides the reference.  

Electricity consumption 

BAU 

On  the  basis  of  the  preparatory  study  data  and  the  research  2012  data  the  total  electricity 
consumption in the period 2005-2022 of the stock is calculated. For the period 1995-2005 the 
preparatory study supplies no data and this was derived from the Top Runner trend123, using 
2005 as a stationary point. In 2022 there has been a full stock change of products subject to 

123 In 1997 the weighted average energy consumption efficiency of copiers was 155 Wh/h and in the fiscal year 
2006 this was reduced to 42,7 Wh/h. This results in an improvement of 72,5%.  

The  electricity  used  in  1997  was  3,5  times  the  2006  level  and  towards  1995  the  factor  has  been  increased 

slightly. 

 
 
 
 
 
 
                                                 
measures  proposed  here.  For  2022-2030  there  is  some  degree  of  uncertainty  of  the 
technological trends and no new measures are envisaged. 

Regarding the EP-products the preparatory study assumes that the average energy efficiency 
improves  from  factor  0.8  TEC  (Energy  star  v.1.0.  requirements)  in  2005  to  factor  0.7  TEC 
(Energy star v.1.0. requirements) in 2015. 

For the IJ-products the preparatory study assumes a quite high average network standby based 
on the idea that network capability will increase. This will lead not only to longer periods in 
which  a  product  might  be  kept  in  standby  but  also  to  higher  power  consumption  for  the 
maintenance of network integrity. IJ personal MFD (or single function devices) are assumed 
to be on (standby) 8 hours per day and the IJ workgroup MFD 12 hours per day.  

Voluntary 

The  base  cases  assessed  in  the  preparatory  study  were  already  45%  below  the  ENERGY 
STAR  v.1.0.  TEC  requirements,  but  the  authors  used  the  electricity  consumption  discussed 
above in the BAU scenario. The base case electricity consumption levels are the basis for the 
Voluntary  scenario,  which  further  on  follows  the  ENERGY  STAR  v.1.1.  and  draft  v.2.0. 
criteria.  From  January  2012  this  scenario  will  follow  the  requirements  that  are  set  out  in 
version  3.5  of  the  VA.  For  this  scenario,  the  additional  data  is  available  according  to  the 
analysis of the EU-ENERGY STAR database performed in 2012. This analysis gave insight 
in  the  number  of  imaging  products  registered,  electricity  consumption,  duplexing  rates 
(Annex  6  and  7).  The  2012  research  showed  that  in  2012  the  registered  products  are  on 
average 40% more energy efficient than required in ENERGY STAR v.1.1. and it is used as 
reference point for this scenario.  

Ecodesign 

The  Ecodesign  scenario  will  follow  the  BAU  electricity  consumption  line  till  the  minimum 
efficiency requirements are set in 2014 (40% below BAU) and 2016 (60% below BAU). 

Table 20: Electricity consumption and CO2 emission IE in case of different scenarios 

Electricity consumption (TWh)  1995 

BAU 
Voluntary 

Ecodesign 
CO2 emissions (Mt)124 
BAU 

Voluntary 

Ecodesign 

2005 
27.01  11.97 
9.04 
27.01 

2010 
8.67 
3.54 

27.01  11.97 

8.67 

12.56 

12.56 

12.56 

5.03 

3.80 

5.03 

3.56 

1.45 

3.56 

2013 
8.75 
2.09 

8.75 

3.51 

0.84 

3.51 

2016 
8.69 
1.26 

5.67 

3.41 

0.49 

2.22 

2019 
9.01 
1.21 

3.53 

3.45 

0.46 

1.35 

2022 
9.37 
1.24 

3.68 

3.49 

0.46 

1.37 

2025 
9.74 
1.27 

3.83 

3.51 

0.46 

1.38 

2030 
10.40 
1.33 

4.08 

3.54 

0.45 

1.39 

In the figure below ENERGY STAR is not included as a scenario but as an index level. This 
is  to  show  how  the  ENERGY  STAR  labels  requirements  help  to  lower  the  electricity 
consumption of imaging equipment and increase energy efficiency.  

124 CO2 emissions are calculated according to the MEErP methodology 2011 part 2 

 
 
 
 
 
 
 
 
 
 
 
                                                 
27,01 

 30,00

 25,00

 20,00

 15,00

 10,00

 5,00

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

 -

1995

EU-27 Electricity consumption TWh/year

14,24 

10,98

6,54 

5,06

5,62

8,75 

2,81

4,36 

3,53 

1,26 

BAU(preparatory study)

Voluntary

Ecodesign

Energystar

10,40 

4,08 
3,28

1,33 

2000

2005

2010

2015

2020

2025

2030

Year

Figure 25: EU-27 total electricity consumption of IE per scenario in TWh/year 

Indirect energy 

BAU 

Single print 

According  to  the  preparatory  study  the  average  unit  is  producing  24 400  images  per  year 
(122kg/ unit at 80 g/m2) single page print only. On the basis of single page printing the stock 
would consume 16 100 million kg (16.1 Mt) of paper per year of which 1 700 million kg (1.7 
Mt)  in  the  IJ  equipment  and  14  400  million  kg  (14.4  Mt)  in  the  EP  equipment.  Energy 
consumption  to  produce  this  paper  would  be  645  PJ  primary  energy125  and  GHG  emissions 
9.6 Mt CO2 eq. per year. 

Duplexing 

In real life duplexing will be used. Assuming 65% duplexing rate and 15% N-printing126 in 
2005, this results in a paper consumption of around 15 000 pages (approximately 75 kg/unit at 
80g/m2). Thus, it is estimated that imaging equipment in the EU27 consumes almost 10 000 
million kg (10 Mt) of paper annually, of which 1 700 million kg (1.7 Mt) in IJ equipment and 
8 300 million kg (8.3 Mt) in EP equipment. Energy consumption to produce this paper is 400 
PJ  in  primary  energy  (equivalent  to  around  40  TWh  electricity)  and  the  related  greenhouse 
gas emissions amount to 6 Mt CO2 equivalent per year.  

Voluntary 

125 According to MEErP Office paper 40 MJ/kg 
126  90%  of  images  are  produced  by  EP  equipment,  of  which  74%  has  duplex  capabilities  (according  to  EU-
ENERGY STAR database) that are used in 90% of all prints. 10% of images are produced by IJ equipment, of 
which 21% has duplex capabilities (according to Energy star database) that are used in 90% of all prints. N-
printing  (2  images  per  page)  is  assumed  relevant  for  medium  volume  equipment  (20-40  ppm,  workgroup 
printing) and for legal documents or similar (large font, large line space, few graphs).     

 
 
 
 
 
                                                 
In research 2012, 78% of the registered products were capable of performing duplex printing. 

An  estimation  is  made  for  2013  (ENERGY  STAR  version  2.0  will  be  put  into  force)  were 
85% of the registered products will be able to perform duplex printing. 

Ecodesign 

The ecodesign scenario follows the BAU scenario till the requirements are set in 2014 here 
they duplexing rate has to be at least 75% of the IE products and in 2016 it has to be 85%. 

 Table 21: Indirect energy consumption and CO2 emissions IE in case of different scenarios 

Energy consumption (TWh) 

BAU 
Voluntary 

Ecodesign 
CO2 emissions (Mt CO2) 
BAU 

Voluntary 

Ecodesign 

1995 
23.42 
23.42 

2005 
33.14 
33.14 

2010 
38.77 
36.67 

2013 
40.04 
35.11 

2016 
41.26 
34.39 

2019 
42.38 
35.31 

2022 
43.42 
36.19 

2025 
44.43 
37.03 

2030 
46.99 
39.16 

23.42 

33.14 

38.77 

40.04 

38.88 

36.47 

36.19 

37.03 

39.16 

3.51 

3.51 

3.51 

4.97 

4.97 

4.97 

5.82 

5.50 

5.82 

6.01 

5.27 

6.01 

6.19 

5.16 

5.83 

6.36 

5.30 

5.47 

6.51 

5.43 

5.43 

6.66 

5.55 

5.55 

7.05 

5.87 

5.87 

EU-27 Energy consumption paper production TWh/year 
(electricity equivalent)

38,77

40,04

36,52

39,69

36,67

35,11

34,39

35,90

46,99

39,16

23,42

BAU (Preperatory study)

Voluntary

Ecodesign

l

t
n
e
a
v
i
u
q
e

y
t
i
c
i
r
t
c
e
l
E
h
W
T

50,00

45,00

40,00

35,00

30,00

25,00

20,00

15,00

10,00

5,00

0,00

1995

2000

2005

2010

2015

2020

2025

2030

Year

Figure 26: EU-27 indirect paper energy consumption per scenario in TWh/year (electricity equivalent) 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 11    COMPLIANCE WITH VA CRITERIA (ART. 17)  

According  to  Article  17  of  the  Ecodesign  Directive,  voluntary  agreements  and  other  self-
regulation presented as alternatives to ecodesign mandatory Regulations shall be assessed on 
the basis of nine criteria laid down in Annex VIII to the Directive:  

1.  Openness  of  participation  -  Self-regulatory  initiatives  must  be  open  to  the 
participation  of  third  country  operators,  both  in  the  preparatory  and  in  the 
implementation phases.'  

The process of developing and implementing the agreement has been open to any third 
companies.  The  agreement  including  its  requirements  has  been  discussed  with  all 
interested stakeholders including at the Consultation Forum meeting. Furthermore, the 
Steering  Committee  meetings  (two  per  year)  dedicated  to  the  application  of  the 
agreement  remain  open  to  all  interested  stakeholders,  including  companies  not-being 
Signatories. In April 2012 a special website  was published to provide all stakeholders 
with the complete information about the agreement127.  

2.  Added value - Self-regulatory initiatives must deliver added value (more than ‘business 
as usual’) in terms of the improved overall environmental performance of the product 
covered.'  

The agreement aims at improving the energy efficiency of imaging equipment beyond 
business as usual. A detailed overview of its expected impact and comparison with the 
other viable option(s) is provided in Chapter 4.2.2 and Chapter 5.  

3.  Representativeness  -  Industry  and  their  associations  taking  part  in  a  self-regulatory 
action  must  represent  a  large  majority  of  the  relevant  economic  sector,  with  as  few 
exceptions as possible. Care must be taken to ensure respect for competition rules.'  

The  Ecodesign  Directive  requires  that  Signatories  to  the  agreement  must  'represent  a 
large  majority  of  the  relevant  economic  sector'.  In  its  explanatory  document  on 
voluntary  agreements  concluded  under  the  Ecodesign  Directive128,  the  Commission 
specified that the proven market share of a valid agreement must be at least 70%. So far, 
17 manufacturers who represent together over 90% of the European market joined the 
VA on imaging equipment.129  

4.  Quantified and staged objectives - The objectives defined by the stakeholders must be 
set in clear and unambiguous terms, starting from a well-defined baseline. If the self-
regulatory initiative covers a long time-span, interim targets must be included. It must 
be possible to monitor compliance with objectives and (interim) targets in an affordable 
and  credible  way  using  clear  and  reliable  indicators.  Research  information  and 

127 www.eurovaprint.eu  
128 EDWB 2010 Doc03 
129 Percentage is based on the units sold in the EU 

 
 
 
 
                                                 
scientific  and  technological  background  data  must  facilitate  the  development  of  these 
indicators.  

The  agreement  provides  for  quantified  objectives  that  can  be  monitored.130  As 
mentioned in Chapter 4.2.2., the agreement sets out unambiguous objectives for energy 
consumption (TEC and OM), but also for compliance rate, duplexing, recycling and use 
of  cartridges.  The  Independent  Inspector131  shall  compile  individual  signatory  reports 
into  an  annual  progress  report  that  will  be  submitted  to  the  Steering  Committee.  An 
additional tool that could be used to evaluate the progress132 could be the EU-ENERGY 
STAR database.   

5. 

Involvement of civil society  

With  a  view  to  ensuring  transparency,  self-regulatory  initiatives  must  be  publicised, 
including  through  the  use  of  the  Internet  and  other  electronic  means  of  disseminating 
information.  

The  same  must  apply  to  interim  and  final  monitoring  reports.  Stakeholders  including 
Member  States,  industry,  environmental  NGOs  and  consumers’  associations  must  be 
invited to comment on a self-regulatory initiative.  

The  agreement  stipulates  that  meetings  of  the  Steering  Committee  that  governs  the 
application of the agreement are opened to: 

• any person representing a signatory or potential signatory to agreement, 

• 

to any representatives of the European Commission or Member States, as well as 
member states of the EEA or EFTA, and 

• organizations that have a permanent seat on the Consultation Forum. 

So far, two meetings of the Steering Committee took place with the participation of the 
above mentioned actors. For minutes from these meetings, please see Annexes 1 and 2. 
Secondly, the annual reports that will be submitted by the industry to the Commission 
will  be  presented  and  discussed  at  the  Steering  Committee  meetings  and  the 
Consultation  Forum  meetings.  Thirdly,  as  requested  by  the  Commission  and 
stakeholders, in April 2012 a special website dedicated to the VA was published133.  

6.  Monitoring and reporting  

Self-regulatory initiatives must contain a well-designed monitoring system, with clearly 
identified  responsibilities  for  industry  and  independent  inspectors.  The  Commission 
services, in partnership with the parties to the self-regulatory initiative, must be invited 
to monitor the achievement of the objectives.   

130 VA version 3.5, 15 February 2011, Chapter 6 reporting and monitoring  
131 ERA Technology Ltd 
132 Energy consumption, duplexing  
133 www.eurovaprint.eu  

 
 
                                                 
The  plan  for  monitoring  and  reporting  must  be  detailed,  transparent  and  objective.  It 
must  remain  for  the  Commission  services,  assisted  by  the  Committee  referred  to  in 
Article  19(1),  to  consider  whether  the  objectives  of  the  voluntary  agreement  or  other 
self-regulatory measures have been met.'  

(cid:190) 

Monitoring  

The Commission, in cooperation with Member States and stakeholders, will monitor the 
application of the agreement and will consider whether it meets its objectives.  

• The monitoring of the agreement will be performed by the Commission mainly on the 
basis of the annual reports produced by the Independent Inspector134.  

• To  properly  monitor  the  progress  and  results  achieved  under  the  agreement,  its 
management has been handed over to the Steering Committee. 

• As  required  by  the  Directive,  the  effectiveness  of  the  agreement  will  be  regularly 
assessed by the Consultation Forum established under Article 18 of the Directive.  

• Finally,  the  effectiveness  of  the  agreement  will  be  assessed  in  the  process  of 
evaluating  the  Energy  Labelling  Directive  and  certain  aspects  of  the  Ecodesign 
Directive (intended to take place in 2014). 

  For more information see Chapter 4.2.2. 

Reporting  

(cid:190) 
Each signatory must provide, specified in the agreement, information to the Independent 
Inspector  who  will  generate  reports  that  will  be  submitted,  for  assessment,  to  the 
Commission  and  the  Steering  Committee  and  the  Consultation  Forum.  Reporting  will 
be done by Signatories on an annual basis in the format specified in the VA. A company 
that has failed to comply with its commitments under the agreement will risk forfeiting 
its signatory status. For more information see Chapter 4.2.2. 

7.  Cost-effectiveness of administering a self-regulatory initiative  

The  cost  of  administering  self-regulatory  initiatives,  in  particular  as  regards 
monitoring, must not lead to a disproportionate administrative burden, as compared to 
their objectives and to other available policy instruments.  

It  is  expected  that  the  administrative  burden  as  compared  to  other  available  policy 
instruments will remain limited. For more information see Chapter 5.8. 

8. 

Sustainability  

Self-regulatory  initiatives  must  respond  to  the  policy  objectives  of  the  Ecodesign 
Directive, including the integrated approach, and must be consistent with the economic 

134 'ERA' has been chosen to act as the Inspector for the agreement on imaging equipment 

 
 
 
 
 
                                                 
and  social  dimensions  of  sustainable  development.  The  protection  of  the  interests  of 
consumers, health, quality of life and economic interests, must be integrated  

The  self-regulatory  initiative  is  in  line  with  the  objectives  of  the  Ecodesign  Directive 
and in particular: free circulation, enhanced environmental performance of products in a 
lifecycle perspective. 

9. 

Incentive compatibility  

Self-regulatory initiatives are unlikely to deliver the expected results if other factors and 
incentives  —  market  pressure,  taxes,  and  legislation  at  national  level  —  send 
contradictory signals to participants in the self-regulatory initiative. Policy consistency 
is  essential  in  this  regard  and  must  be  taken  into  consideration  when  assessing  the 
effectiveness of the initiative.  

It is considered that the VA is consistent with existing framework conditions.