Cost-Benefits analysis on the introduction of an e-labelling scheme in the EU

EXECUTIVE SUMMARY

This document is the final report of the study “Cost-Benefits analysis on the introduction of an e-labelling scheme in Europe”, commissioned by DigitalEurope and the Mobile & Wireless Forum. This study was conducted by Valdani Vicari & Associati (VVA).

The study analyses the costs and benefits associated with the potential introduction of an e-labelling scheme in Europe. The analysis is based on desk research, an online survey of enterprises across the EU-28 and in-depth interviews with selected industry representatives and market surveillance authorities.

The consumer electronics market encompasses a wide range of goods, including audio and video products, smartphones and printers, which can be used for entertainment, communication purposes or home-office activities.

From an economic perspective, the three largest product categories in the consumer electronics market are:

• Telephony, which comprises fixed phones and mobile phones including smartphones;
• Computing, including PCs, laptops, tablets and ancillary equipment such as printers or keyboards; and
• TV/radio/multimedia, such as TVs, radios, cameras, speakers, headphones, etc.

Together they represent 60% of the product categories in the consumer electronic market.

In terms of economic contributions, telephony accounts for 43.7% of total European revenues in the three segments (2016 data). In particular, mobile phones hold the “lion’s share” with € 69 billion in revenues across Europe, out of a
total of € 71 billion in the entire telephony segment.

Like other goods, consumer electronics products must comply with a set of European Directives in order to be placed on the European Union’s Internal Market. The key EU Directives that apply to the sector include:

• Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment;
• Directive 2009/125/EC on the Eco-design requirements for energy-related products;
• Directive 2014/35/EU related to Electrical equipment designed for use within certain voltage limits;
• Directive 2014/30/EU on Electromagnetic compatibility;
• Directive 2014/53/EU on Radio equipment;
• Directive 2010/30/EU on Energy labelling;
• Directive 2001/95/EC on General Product Safety.

Each product within the scope of these regulations is marked with a label to indicate compliance with Internal Market rules.

The Blue Guide on the implementation of EU products rules 2016 lists the types of information that product labels must provide. Manufacturers must ensure their products comply with applicable legislation and, in order to ease the traceability of products, labels should provide (among others) the following information:

• Identification of the manufacturer;
• Elements of identification of the product;
• Marks showing compliance with applicable legislation;
• Information about the components of the product.

In Europe, this information is currently provided through the following documentation:

• The technical product documentation: Union harmonisation legislation obliges the manufacturer to draw up technical documentation containing information to demonstrate the conformity of the product with the applicable requirements.
• CE Marking must be affixed on products and must be visible, legible and indelible. CE marking is a self-certification which proves that a product has been assessed and meets the essential requirements of the applicable Directives.
• The EU Declaration of Conformity: The manufacturer or the authorised representative established within the Union must also draw up and sign an EU Declaration of Conformity as part of the conformity assessment procedure provided for in Union harmonisation legislation.
• Manufacturers have to meet traceability requirements by indicating their name, registered trade name or registered trade mark and the address where they can be contacted. This information must be displayed on the product, on its packaging or in a document which accompanies the product.

While product labels remain mostly physical in Europe, a growing number of advanced economies have now introduced the possibility for companies to indicate regulatory compliance through electronic label (e-label). This study assesses the costs and benefits of introducing an electronic labelling system in Europe.

The proposed e-labelling scheme is designed as an optional approach to a physical label and consists of:

• A label displayed electronically for devices with built-in screen or devices without a built-in screen that can be connected to a screen.
• A QR code, or other machine-readable code, for equipments without an inbuilt screen and which cannot be connected to a screen.
• A temporary label (e.g. film label) to allow consumers and any market surveillance authority to see all product regulatory markings at the time of purchase/check without having to switch the device on.

The following information should be retrieved from the proposed e-labelling scheme:

• CE Mark (for products with a screen the certification mark can be resized proportionally to the screen);
• Notified Body identification number – when applicable;
• Equipment Class Identifier – when applicable;
• Type, batch and/or serial numbers and the name of the manufacturer or the person responsible for placing the apparatus on the market.