EuroVAprint and remanufacturers responds to comments by NGOs regarding the Voluntary Agreement ahead of the next meeting on the 27 September.
In July NGOs recently published their comments on the draft Voluntary Agreement (VA) submitted by EuroVAprint (EVAP) to the Commission on 9 April 2021.
Ahead of the next meeting with the JRC (Joint Research Centre) on 27 September 2021 EVAP and the remanufacturers group (Remanufacturers) have jointly submitted the VA to the Commission (“Remanufacturers”) wish to respond to the comments made by the NGOs.
In their response the Remanufacturers comment: “It is important to reiterate that the proposed VA presents innovative solutions to challenges that were preventing finalisation of the VA in 2019 and is a breakthrough voluntary agreement in having been developed by competing actors in the industry.”
The response takes not that: “The NGOs criticise the VA arguing that it does not reflect existing Eco-Design regulations.” But comments that: “In many areas the VA does reflect existing Eco-Design regulations” and says that: “There are cases where provisions have been tailored to better reflect the realities of the sector” and comments that this “is a key value of having a VA.”
On the NGO comment that the does not “reflects ambitious ecolabel standards.” Remanufacturers respond: “It does not make sense, however, for all criteria to be drawn from those ecolabels because the ecolabels are typically designed to be achievable for only the top performing products and act as a market differentiator while for a VA to be successful it needs to be achievable for all/virtually all products of manufacturers representing a sufficient market share.”
On the NGO’s point that that printers are “short lived” and “unrepairable.” “Manufacturers do not agree with these statements. Printers are durable and long-lasting with low failure rates,” and call for the NGOs to provide hard data or reports to substantiate these claims.
The remanufacturers group consists of Armor Group, Clover Imaging Group, KMP AG and 3T Supplies AG (Peach).
In July 2021, The Recycler reported that the responsibility for the VA switched directorates within the European commission from DG Energy to DG Environment.
Subsequently the VA was passed to the JRC for review. The JRC is the science and knowledge service of the European Commission and their mission is to support EU policies with independent evidence throughout the whole policy cycle.
You can read the full response to the NGOs comments here.
Our take on this: The response to the NGOs comments are well made, but the VA remains contentious and despite the collective approach some OEMs don’t relish a VA that includes the aftermarket. And well reasoned as the comments are, the VA not address the whole market where legislation will work.
