EUREFAS calls on the Member States to abstain on Ecodesign for phones and tablets

EUREFAS, the European refurbishment and repair sector, calls on Member States to abstain from voting on 17 November 2022 on the European Commission’s proposal for new ecodesign requirements for mobile phones, cordless phones and slate tablets, until further technical work and amendment can be provided. In its current wording, the text will seriously affect the ability to repair phones and tablets in the future. The European authorities should take more time to address the concerns above and reconcile the proposal with its objectives for more reparable and durable devices.

The proposed legislation should be careful to not imply restraining measures to our activity and thus acknowledge that:

• The ability to repair a device should not be dependent on a participation to the original manufacturer (OEM) authorised-networks. EUREFAS strongly recommends that only a national register, managed by Member States authorities is a valid proof of the “technical competence” required to have access to repair and maintenance information;
• Part-pairing practices should be explicitly banned. This practice is increasingly used by OEMs to restrict the ability of independent professionals to refurbish and repair devices outside of their control. In practice the new part will not be recognised by the device and some key functionalities (like the battery health) will be turned down if the OEM does not remotely authorise the part through software. The repair and refurbishment operator should instead be given clear justifications with explicit evidence by OEMs if there is a reason to believe that part replacement can lead to data hacking risks, justifying a remote OEM authorisation that should remain the exception.
• EUREFAS is strongly opposed to parts being sold or distributed in bundles or assemblies. This does not make economic nor ecological sense and artificially increases the number of parts that need to be replaced, even if they donot need to be. We urge the Committee to favour the distribution of individual parts instead.
• The decision to provide updates ornot has been delegated to the manufacturer and is therefore voluntary and arbitrary. This is clearly an inappropriate approach for an ecodesign regulation. For a product's lifespan extension, it is essential to ensure that software is compatible with its hardware for as long as possible, making sure that all conformity updates are provided during 7 years after the last placing on the market of a model.