3rd PLATE Conference
September 18 – 20, 2019
Berlin, Germany
Nils F. Nissen
Melanie Jaeger-Erben (eds.)
Universitätsverlag der TU Berlin
Alfi eri, Felice; Cordella, Mauro; Sanfelix, Javier: Information requirements
to enable the repair or upgrade of products: EU policy tools and other
voluntary labels for computers . In: Nissen, Nils F.; Jaeger-Erben, Melanie
(Eds.): PLATE – Product Lifetimes And The Environment : Proceedings,
3rd PLATE CONFERENCE, BERLIN, GERMANY, 18 – 20 September 2019.
Berlin: Universitätsverlag der TU Berlin, 2021. pp. 33 – 38. ISBN 978-3-7983-
3125-9 (online). https://doi.org/10.14279/depositonce-9253.
This article – except for quotes, fi gures and where otherwise noted – is
licensed under a CC BY 4.0 License (Creative Commons Attribution 4.0).
https://creativecommons.org/licenses/by/4.0/.
33
3rd PLATE 2019 Conference
Berlin, Germany, 18-20 September 2019
Information Requirements to Enable the Repair or Upgrade of
Products: EU Policy Tools and Other Voluntary Labels for
Computers
Alfieri, Felice; Sanfelix, Javier; Cordella, Mauro
European Commission, Circular Economy and Industrial Leadership Unit, Joint Research Centre (JRC), Seville,
Spain
Keywords: Computers; Information; Label; Policy; Repair; Upgrade.
Abstract: Extending the lifetime of products can mitigate, from a life cycle perspective, their
environmental and social impacts. One of the options to extend their lifetime is repairing and/or
upgrading the product, when possible. A key measure in support of this objective is the availability of
relevant information to users and professionals to enable repair/upgrade of products.
Requirements on the provision of repair information have been introduced by different policy tools and
labels for a variety of products and services on the market. In the case of computers, minimum
requirements have to be fulfilled to enter in the EU market according to the Commission Regulation
(EU) No 617/2013, while more ambitious requirements are associated to voluntary tools such as the
EU Ecolabel and the EU Green Public Procurement (GPP) for Computers, as well as to other labels
such as Blue Angel (the German Ecolabel), TCO Certified and EPEAT. Provision of repair information
is also included in the Scoring System on Reparability developed by the Joint Research Centre.
The aim of this work is to review these initiatives to present a classification and comparison of existing
information requirements for computers in terms of: i) repair aspects covered, ii) availability of the
information to various target groups, and iii) communication vehicles. The analysis focuses on sub-
categories of computers that are relevant in terms of market share such as laptops, desktop
computers, all-in-one computers and tablets.
The results of the analysis can offer a useful basis for the improvement and harmonization of
information requirements on computers, potentially facilitating their implementation by manufacturers
and allowing more sustainable purchase decisions of consumers and public administrations.
Introduction
Significant contributions to the environmental
impacts along the life cycle of computers are
related to the manufacturing of the device itself
and sub-assemblies such as motherboards,
hard drives, batteries and display units (EC
2016a). The supply chain of computers and
other ICT products can be also associated with
conflict and human rights impacts (Köhler et al.
2013). Facilitating repair, reuse and upgrade of
computers can contribute to extend their
lifetime and reduce the impacts associated to
resource extraction, production and end of life
(Cordella et al. 2019a).
EU consumers currently lack information on
reparability (Cerulli-Harms et al. 2018).
Providing more information to consumers at
the point of the sale about the durability and
reparability of products can be an effective
measure to shift demand towards products
with better environmental credentials and
make repair easier (Cerulli-Harms et al. 2018).
At EU level, policy measures supporting repair
of products could also provide turnover gains
and create jobs in the repair sector, which is
largely composed of SMEs and social
enterprises located in the EU (Deloitte 2016).
Product policy tools such as the Ecodesign
Directive (EC 2009), the EU Ecolabel (EC
2010) and the EU Green Public Procurement
(GPP) (EC 2008b) can include requirements
on reparability and supply of information.
It should be noted that, at the moment of
preparing this work, the current Ecodesign
regulation for computers (EC 2013) and GPP
criteria for computers (EC 2016a) are under
revision, with the possibility to introduce new
requirements for the provision of repair
information.
Moreover, new tools to inform about the ability
to repair and upgrade products are under policy
34
3rd PLATE Conference Berlin, Germany, 18-20 September 2019
Alfieri F, Sanfelix J., Cordella M.
Information requirements to enable the repair or upgrade of products:
EU policy tools and other voluntary labels for computers
discussion, such as a scoring system to rate
the ability to repair and upgrade products. In
that context, product-specific criteria have been
defined for laptops (Cordella et al. 2019b).
Voluntary Type I ecolabels (ISO 2018) such as
TCO Certified (TCO Certified 2018a, b, c, d),
EU Ecolabel (EC 2016b) and Blue Angel (Blue
Angel 2017), as well as rating system such as
EPEAT (IEEE 2018), also include
requirements on the provision of repair
information. These labels can be also used in
support of the formulation and verification of
GPP criteria to include in public tenders or to
implement sustainable procurement strategies
in organizations.
This work provides a classification and
analysis of repair/upgrade information
requirements set for computers in EU relevant
policy initiatives and voluntary programmes.
These are finally compared to crosscheck the
coherence and level of harmonization between
different approaches with the final aim to
promote their implementation by
manufacturers and allow consumers and
public administrations to make better purchase
decisions.
Scope and methodology
The scope of this analysis has been restricted
to repair/upgrade operations, defined
according to Cordella et al. (2019a) as:
• Repair: the process of returning a faulty
product, or a part of a product, to a condition
where it can fulfil its intended use;
• Upgrade: the process of enhancing the
functionality, performance, capacity or
aesthetics of a products or a part of a product.
In terms of technologies, this study covers the
following sub-categories of computers (EC
2013):
• Notebooks: a computer designed specifically
for portability and to be operated for extended
periods of time either with or without a direct
connection to an AC power source;
• Desktop computers: a computer where the
main unit is intended to be located in a
permanent location and is not designed for
portability and which is designed for use with
an external display and external peripherals
such as a keyboard and mouse;
• Integrated desktop computers: a computer in
which the computer and the display function as
a single unit, which receives its AC power
through a single cable;
• Tablets: a product which is a type of
notebook computer that includes both an
attached touch-sensitive display and an
attached physical keyboard.
Information requirements are analysed for the
following EU product policy tools: Ecodesign
(EC 2013), EU GPP (EC 2016a), EU Ecolabel
(EC 2016b). Requirements from other
international voluntary labels are also
analysed. Among the labels, only those
recently developed or updated (i.e. after 2016)
have been taken into consideration. These
are: TCO Certified, Blue Angel and EPEAT.
The scoring system developed by JRC
(Cordella et al. 2019b), also referred to as
Repair Scoring System, has been moreover
considered. More details of the analysed
initiatives and related background information
are listed in Table 1.
Type Policy/in
itiative
Rev. Application
EU
policy
tools
Eco-
design
(EC,
2013)
2013 Mandatory
application at EU
level
EU GPP
(EC
2016a)
2016 Voluntary
inclusion of
criteria in public
tenders.
EU
Ecolabel
(EC
2016b)
2016 Voluntary type I
ecolabel
Labels TCO
(TCO
2018
a,b,c,d)
2018 Voluntary type I
label ecolabel
(mainly oriented
to sustainable
procurement in
organizations)
Blue
Angel
(Blue
Angel
2017)
2017 Voluntary type I
ecolabel
EPEAT
(IEEE
2018)
2019 Environmental
rating system
and label (mainly
oriented to
sustainable
procurement in
organizations)
Others Repair
Scoring
System
(Cordella
et al
2019b)
2019 Under
discussion.
Product specific
methodology
developed for
laptops.
Table 1. Details of the Initiatives analysed and
their applicability.
35
3rd PLATE Conference Berlin, Germany, 18-20 September 2019
Alfieri F, Sanfelix J., Cordella M.
Information requirements to enable the repair or upgrade of products:
EU policy tools and other voluntary labels for computers
The presence of key words as "repair",
"information", "instructions", "access", has been
crosschecked in the corresponding reference
documents in order to identify requirements
specifically requesting provision of information /
instructions to facilitate the repair process. The
level of market uptake has been also verified
through the consultation of the product
registries and considered in the discussion of
the results. The repair information has been
grouped based on topics covered. Associated
target groups (e.g. professional repairers,
users) and vehicle of communication / media
required (e.g. free access website, user
manual, other product documents, .external
packaging) have been identified.
EU product policies on computers
The Ecodesign Regulation (EC 2013) mainly
focuses on energy efficiency aspects; however
this regulation already requires manufacturers
to inform about the skills needed to replace
batteries in notebooks. The Commission is
exploring the possibility of including additional
requirements such as disassembly instructions
to be shared with professional repairers
(Viegand Maagøe and VITO 2018). Similar
requirements about the availability of repair
information have been implemented in recent
Ecodesign implementing measures for ICT
products like servers (EC 2019a) and displays
servers (EC, 2019b).
Current GPP criteria (EC 2016a) focus on the
provision of disassembly and repair
instructions during the service contract, as well
as the information on the availability of spare
parts; additionally, information on spare parts
cost can be requested as awarding criteria.
However, it has to be remarked that the
provision of repair and spare parts information
to the public administrations can be useful
during the contract performance only when the
public authority is actually responsible for the
repair/upgrade of the equipment. It is
moreover difficult to evaluate the level of
implementation of GPP criteria since public
authorities are free to select and adapt the
criteria to integrate in their tender process.
The EU Ecolabel for computers (EC 2016b)
introduces criteria on the availability of repair
information such as the availability of a repair
manual including clear disassembly and repair
instructions and the provision of information on
repair service. Nevertheless, there are no
models registered under the European
Ecolabel and the criteria expired in August
2019.
Voluntary labels on computers
Despite all the analysed labels have been
available on the market at least in the past
three years, only TCO and EPEAT have been
able to reach a good level of market uptake in
Europe (Table 2). Currently there are no
computers registered neither under the EU
Ecolabel nor under the Blue Angel.
Type of
computer
Number of certified models
EPEAT TCO
v.8
Blue
Angel
EU
Ecolabel
Notebooks 135 48 0 0
Desktop
Computers
90 21 0 0
Integrated
Desktop
Computers
42 23 0 0
Tablets 5 1 0 0
Table 2. Computer models certified in the EU
under different voluntary labels (June 2019).
Identified information criteria
Based on the analysis of existing criteria, the
following types of information on repair have
been compiled (Table 3):
• Information on the availability of
professional repair services;
• Instructions on how to identify failures;
• Instructions on data erasure;
• Information on replaceable components
and skills needed;
• Information on the availability of spare
parts;
• Disassembly instructions (for battery
and/or other key components);
• Self-repair implication on computers
warranty.
The implementation of such information differs
from initiative to initiative as described in the
sections below.
Availability of professional repair services
Information on the availability of professional
repair services is required by EPEAT, EU
Ecolabel, Repair Scoring system. This
information should let the user know where to
find professional services for the repair and
upgrade of the computer.
36
3rd PLATE Conference Berlin, Germany, 18-20 September 2019
Alfieri F, Sanfelix J., Cordella M.
Information requirements to enable the repair or upgrade of products:
EU policy tools and other voluntary labels for computers
Instructions on how to identify failures
It can include troubleshooting instructions,
software diagnostic tools (e.g. battery health
tools), troubleshooting videos or other
troubleshooting guidance. The provision of
instructions to identify failures is optional under
EPEAT while this prescription is considered as
a pass/fail criterion in the application of the
Repair Scoring System to laptops.
Type of information E
C
D
G
P
P
E
L
T
C
O
B
A
E
P
E
A
T
R
S
S
A
vailability of professional
repair services
X X X
How to identify failures X
X
Instructions on data erasure X
X
X
Replaceable components
and skills needed
X
X X
Information on the
availability of spare parts
X X X X
Disassembly instructions X X X
X X X
Self-repair implication on
computers warranty
X X
Note:
- ECD = Ecodesign
- GPP = EU Green Public Procurement
- EL = EU Ecolabel
- TCO = TCO Certified
- BA = Blue Angel
- EPEAT = EPEAT
- RSS = Repair Scoring System
Table 3. Information requirements included in
different initiatives for computers.
Instruction on data erasure
By providing software that wipes the storage of
the device, the computers owners can more
safely send out products for repair (TCO 2018a,
b, c, d). TCO requires that manufacturers, in
case data erasure software is not preinstalled
on the product, provide the link to download the
software on their webpage. EPEAT includes
this requirement as optional. According to the
Repair Scoring System, the data erasure
software has to be provided (either pre-installed
or as web-link), and complemented by
information for installation.
Information on replaceable components
and skills needed
According to the current Ecodesign Regulation
for computers, manufacturers have to disclose
whether the battery (notebook) cannot be
easily replaced by users themselves. This
information has to be made available on a
free-access website and on the external
packaging of the notebook computer. EPEAT
explicitly requires a statement from
manufacturers about the possibility to replace
batteries; the other ecolabels require other
components to be replaceable as well (see
Table 3). Despite the initiatives analysed
require a design of replaceable components
(see Table 3) there is no obligation to disclose
this information, except from battery for
EPEAT. A repair scoring system label could
address this aspect.
Information on available spare parts
Transparent information and procedures on
how to obtain spare parts are required by Blue
Angel, EPEAT and Repair Scoring System. EU
GPP criteria include the declaration of the
spare parts that will be made available to the
contracting authorities. More comprehensive
information on their availability period, price,
functional specifications and compatibility is
awarded through the Repair Scoring System.
Disassembly instructions
EU GPP, Ecolabel and TCO require that the
disassembly information for the key
components should be made publicly
available. EPEAT includes the availability of
this information as an optional criterion, while
the Repair Scoring System requires
disassembly information available to
professional repairers as entry level. The list of
replaceable components varies depending on
the initiative considered. Instructions on how to
replace the battery must be publicly available
according to TCO, EU Ecolabel and Blue
Angel, while EPEAT require, as an alternative,
providing information on how to obtain and
replace the battery. The Repair Scoring
System requires, in addition, that functional
specifications and compatibility with other
products of parts (such as batteries and
external power supplies) is made available.
Information on self-repair implication on
computers warranty
Some warranty clauses can affect the actual
possibility of repairing the product. EU GPP
criteria require confirming which parts are
covered by service agreements under the
warranty. A product is considered to score
points under the Repair Scoring System only if
37
3rd PLATE Conference Berlin, Germany, 18-20 September 2019
Alfieri F, Sanfelix J., Cordella M.
Information requirements to enable the repair or upgrade of products:
EU policy tools and other voluntary labels for computers
the warranty is ensured for the entire product.
The Repair Scoring System also requires to
inform consumers about any implications of
self-repair or non-professional repair for the
safety of the end-user and for the legal
guarantee (and when applicable also to the
commercial guarantee).
Availability of information to
different target groups and
communication vehicles
Depending on its level of sensitiveness, the
information reported above can be accessible
to different target groups. The voluntary labels
analysed require, whenever an information
requirement is included, to have information
accessible to the generic public (i.e. all
possible users). A graded approach is
presented in the Repair Scoring System,
where information to carry out a repair has to
be made available to professionals (either
authorised repair centres or qualified
independent repairers) in order to enter the
assessment framework (corresponding to a
minimum requirement under Ecodesign);
higher scores are then assigned in case
relevant information is made publicly available.
Different communication vehicles can be used
including external packaging, publicly
accessible websites and manuals (e.g. service
/ repair or user manuals). This wide range of
information sources and vehicles could make
difficult the comparison of products, especially
at the decision stage (e.g. the point of sale).
Conclusions
This research shows a spectrum of repair
information and instructions required by
different policy tools and voluntary labels for
computers.
As "entry level" in the EU market, the
Ecodesign regulation obliges manufacturers to
inform consumers about the skills needed to
replace a notebook battery. However, the
ongoing revision of the EU regulation
617/2013 could introduce a more ambitious set
of mandatory information supporting the repair
of computers, as already done for related
product groups (e.g. servers, displays).
Among the voluntary labels analysed it is
evident that only those more oriented to
business to business procurement have been
able to reach a good level of market
penetrations.
Type I Ecolabels (such as TCO, the Blue Angel
and the EU Ecolabel) aim to award the best
environmental performing products on the
market that are, together with other
characteristics, repairable. These ecolabels aim
to ensure the reparability of key components
and require providing comprehensive
information available to the end-users (e.g.
contacts of professional repairers, disassembly
instructions, information on the availability of
spare parts).
EPEAT, although characterized by a less
ambitious entry level, can stimulate the market
by qualifying the products according to the
different level of ambitions reached
(bronze/silver/gold). The best performing
products meet optional criteria such as the
provision of detailed disassembly instructions,
diagrams and the availability of troubleshooting
instructions in a publicly accessible website.
A similar approach is proposed in the Repair
Scoring System, where an entry level is
associated to the availability of repair
information limited to professional independent
repairers. A potential label based on the Repair
Scoring System would have the advantages of
addressing specifically reparability issues and
being more complete and granular in terms of
requirements. However, how to best
communicate this information with consumers
is still under discussion.
In this context, and in absence of further
initiatives, consumers could still have some
difficulties in the access to reparability
information, especially in the purchase decision
stage.
This work, showing examples and results
achieved by voluntary labels and initiatives
established in the EU market, can serve
decision makers as guidance for a broader and
harmonized diffusion of repair information. This
could support the formulation of relevant
policies and strategies allowing more
sustainable purchase decisions of consumers
and public administrations.
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3rd PLATE Conference Berlin, Germany, 18-20 September 2019
Alfieri F, Sanfelix J., Cordella M.
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EU policy tools and other voluntary labels for computers
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