Comments on the approach and questionnaire of the framework study to support Ecodesign measures to improve reparability of products

DIGITALEUROPE has been contacted in the framework of a study that Deloitte is currently carrying out, together with the Sustainable Europe Research Institute (SERI) and the Institute for European Environmental Policy (IEEP), for the European Commission (DG Environment) with the objective to support Ecodesign measures to improve reparability of products. Having carefully assessed the questionnaire, we decided to comment already at this stage on the approach of the study and the questionnaire itself.

At a high-level, we suggest a review of the approach taken already at this point in time. As our comments and concerns on approach, terminology and the questionnaire will show, the questionnaire does not cater for the complexity and the diversity of the repair sector. We are concerned that the closed questions are not formulated in a neutral, open-ended way and therefore risk not delivering meaningful results that can support policy development.

1. The focus of the study is large and small white goods, brown and grey goods. With grey goods the consultants mean ICT equipment. Industry is not using this term and the Cambridge dictionary defines “grey goods” as ” products that are bought in a foreign country and sold more cheaply than in the manufacturer’s usual distribution system: The biggest problem in buying grey goods is the lack of support and warranties.” The term is consequently inappropriate and we request the use a different term.

2. The questionnaire fails to distinguish between repair under warranty (legal and commercial) and out-of-warranty period. That is problematic as the sophistication of actors’ approaches vary. For example, manufacturers have reverse logistics systems in place for repairs within the warranty period.

3. We are concerned that the questionnaire is not neutral: most questions are closed-ended and formulated in a way that they preclude a desired answer from stakeholders. The resulting study risks not doing justice to reality. We would caution any kind of hasty conclusions drawn from it and recommend that the questionnaire be reworded in a more neutral way.

4. Large companies of the electronics sector have regional approaches and not country specific ones.