directorate b, growth and innovation (sevilla) 1...

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EUROPEAN COMMISSION

JOINT RESEARCH CENTRE

Directorate B, Growth and Innovation (Sevilla)

Unit 5, Circular Economy and Industrial Leadership

1

Analysis and development of a scoring system for repair and upgrade of products – 2

draft version 1 3

4

Author(s):

JRC – B.5

Date:

20th

June 2018

Summary:

The European Commission has been working on the analysis and development of a possible

scoring system to inform about the ability to repair and - where relevant - upgrade products.

The overall aims of this study are:

1. To develop a general approach for the assessment of products;

2. To test the feasibility and types of results derived using the general approach on three

specific product groups (Laptops, Vacuum Cleaners, Washing Machines).

The study, carried out by the Commission's Joint Research Centre (Directorate B, Circular

Economy & Industrial Leadership Unit) on behalf of DG ENV, has a preparatory orientation

and will not have any effect on the product-specific Regulations currently in discussion. This

technical study could be used to set the framework and grounds for the development of a tool

for informing consumers.

This is the first version of the report, which has been prepared as working document for the 1st

Technical Working Group (TWG) meeting (Seville, 26 June 2018) with main aim of

discussing the general assessment framework. The report is structured in the following parts:

1. Analysis of existing methods for assessing reparability and upgradability

2. Development of a scoring system: key aspects, priority parts, scoring framework

3. Product-specific considerations

4. Additional considerations

5. Annexes

Stakeholders are kindly invited to read and comment on this report, and to send any

comments to [email protected] by 27th July 2018 (please use the

provided commenting sheet).

The second consultation round will take place in parallel with the 2nd

TWG meeting

(Brussels, November 2018, date to be confirmed) and will have a more product-specific

focus. The publication of final report is planned by the end of 2018.

Information on the study and reports will also be made available on the dedicate website:

http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/index.html.

5

DISCLAIMER: The views expressed are purely those of the writer and may not in any 6

circumstances be regarded as stating an official position of the European Commission. The 7

mailto:[email protected]

http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/index.html

2

information transmitted is intended only for the Member State or entity to which it is 8

addressed for discussions and may contain confidential and/or privileged material. 9

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Table of Contents 11

GLOSSARY (TO FOLLOW) 12

INTRODUCTION........................................................................................................... 5 13

1 ANALYSIS OF METHODS FOR ASSESSING REPARABILITY AND 14

UPGRADABILITY ................................................................................................. 8 15

1.1 AUSTRIAN STANDARD ONR 192102:2014 ................................................................... 8 16

1.2 I-FIXIT SCORING SYSTEM ............................................................................................ 10 17

1.3 'DESIGN FOR REPAIRABILITY' TOOL ........................................................................... 11 18

1.4 GROUPE SEB'S 'PRODUCT 10Y REPAIRABLE' LABEL.................................................. 12 19

1.5 PREN 45554 - GENERAL METHODS FOR THE ASSESSMENT OF THE ABILITY TO REPAIR, 20

REUSE AND UPGRADE ENERGY RELATED PRODUCTS .................................................. 12 21

1.6 OTHER METHODS ........................................................................................................ 14 22

1.7 SUMMARY ................................................................................................................... 14 23

2 DEVELOPMENT OF A SCORING SYSTEM FOR ASSESSING REPAIR AND 24

UPGRADE OF GENERIC PRODUCTS ............................................................ 16 25

2.1 KEY PARAMETERS FOR REPAIR AND UPGRADE ........................................................... 16 26

2.2 PRIORITY PARTS .......................................................................................................... 25 27

2.2.1 Frequencies of failure and upgrade ................................................................... 26 28

2.2.2 Functional importance ....................................................................................... 26 29

2.2.3 Price of parts and cost of repair/upgrade ........................................................... 27 30

2.2.4 Environmental impacts of parts ......................................................................... 27 31

2.2.5 Disassembly of parts and reinstallation of software .......................................... 27 32

2.2.6 Additional considerations .................................................................................. 27 33

2.3 SCORING FRAMEWORK ............................................................................................... 29 34

2.3.1 Classification and rating of individual parameters ............................................ 30 35

SCORE = (DSMAX – DSI) / (DSMAX – DSMIN) ....................................................... 30 36

2.3.2 Aggregation of individual parameters ............................................................... 45 37

2.3.3 Reporting options to assess products ................................................................ 47 38

2.4 SUMMARY ................................................................................................................... 48 39

2.5 QUESTIONS FOR STAKEHOLDERS ................................................................................ 51 40

3 PRODUCT SPECIFIC CONSIDERATIONS ..................................................... 52 41

3.1 ATTRACTIVE CONDITIONS FOR REPAIR AND UPGRADE FOR MACRO-CATEGORIES OF 42

PRODUCTS ................................................................................................................... 52 43

3.2 ASPECTS AND NEEDS FOR A PRODUCT-SPECIFIC SCORING SYSTEM ............................ 56 44


4 ADDITIONAL POINTS TO CONSIDER ........................................................... 61 46

4.1 REPARABILITY AND UPGRADEABILITY VS. DURABILITY OF PRODUCTS ..................... 61 47

4.2 LINK TO POLICY FRAMEWORK AND STANDARDISATION ............................................ 61 48

4.3 SAFETY AND LIABILITY OF THE PRODUCT .................................................................. 61 49

4.4 COMMUNICATION ISSUES ........................................................................................... 62 50


5 ANNEX I – INITIAL QUESTIONNAIRE FOR STAKEHOLDERS ............. 63 52

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5.1 PART 1) EXISTING METHODS, LABELS, OR SCHEMES FOR THE ASSESSING REPARABILITY 53

AND UPGRADABILITY OF PRODUCTS ........................................................................... 63 54

5.2 PART 2) ASPECTS INFLUENCING THE REPARABILITY AND UPGRADABILITY OF PRODUCTS 55

IN GENERAL................................................................................................................. 65 56

5.3 PART 3) CONDITIONS INFLUENCING THE REPARABILITY AND UPGRADABILITY OF 57

SPECIFIC FAMILIES OF PRODUCTS ............................................................................... 67 58

5.4 PART 4) IDENTIFICATION OF PRIORITY PARTS ............................................................ 69 59

5.5 PART 5) GUIDANCE FOR SCORING AND AGGREGATING DIFFERENT ASPECTS OF REPAIR 60

AND UPGRADE ............................................................................................................. 71 61

5.6 PART 6) SPECIFIC ASPECTS AND NEEDS FOR THE PRODUCT GROUPS UNDER ASSESSMENT62

.................................................................................................................................... 74 63

6 ANNEX II – ANALISYS OF RESPONSES ........................................................ 75 64

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66

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INTRODUCTION 67

The 2015 Communication from the Commission on an EU action plan for the Circular Economy1 68

pointed out the importance of improving the resource efficiency of products in order to promote the 69

transition towards a more circular economy in the EU. The Ecodesign Working Plan 2016-20192 70

commits to explore the possibility of further developing product-specific and/or horizontal 71

requirements in areas such as durability, reparability, upgradeability, ease of reuse and recycling. In 72

particular, improving repair and upgrade possibilities for products can potentially benefit consumers, 73

the environment and the economy by limiting the early replacement of products, increasing 74

competitiveness on product design, supporting the EU repair market and saving resources. 75

In this context, the European Commission has been working on the analysis and development of a 76

possible scoring system to inform about the ability to repair and - where relevant - upgrade products. 77

Reparability and upgradability are here defined, respectively, as the ability to restore the functionality 78

of a product after the occurrence of a fault, and the ability to enhance the functionality of a product, 79

independently on the occurrence of a fault. Both can refer to one or more parts of a product3. 80

"Upgradability" can in particular refer to either the hardware or software parts/ components of 81

products. As part of the enabling framework for repair, the study will also explore the possibility to 82

take into account relevant practices, such as the provision of an extended product warranty, after-sales 83

free repair services and others. 84

The overall aims of this study are: 85

3. To develop a general approach for the assessment of products; 86

4. To test the feasibility and types of results derived using the general approach on three specific 87

product groups (Laptops, Vacuum Cleaners, Washing Machines). 88

89

90

Figure 1 From general approach to product specific methods 91

The study, carried out by the Commission's Joint Research Centre (Directorate B, Circular Economy 92

& Industrial Leadership Unit) on behalf of DG ENV, has a preparatory orientation and will not have 93

any effect on the product-specific Regulations currently under discussion. This technical study could 94

be used to set the framework and grounds for the development of a tool for informing consumers4. 95

1 COM(2015) 614 'Closing the loop - An EU action plan for the Circular Economy''

2 COM(2016) 773 'Ecodesign Working Plan 2016-2019'

3 Cordella, M.; Sanfelix, J.; Alfieri, F. (2018) Development of an Approach for Assessing the Reparability and

Upgradability of Energy-related Products. Procedia CIRP, 69, 888-892.

https://doi.org/10.1016/j.procir.2017.11.080 4 Complementary to this technical work, there will be a further study that will explore the possibility to develop

a label. However, this study will be conducted separately with the support of experts in the field of labelling and

communication and will include consultation with stakeholders and surveys with end-consumers.

https://doi.org/10.1016/j.procir.2017.11.080

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The research builds on the in-house experience in product policy implementation and in the 96

assessment of products5, as well as on the available literature and on input from experts and other 97

stakeholders. Stakeholders who will be consulted during this process include, for example, 98

manufacturers, retailers, repair enterprises, academia, environmental and consumer NGOs, Member 99

States' representatives. Engagement with stakeholders is very important for this project, in order to 100

achieve coherent and balanced results, based on representative and up-to-date information. A 101

consultative Technical Working Group (TWG) has been set up to facilitate this process6. 102

Background information and initial input from stakeholders have been gathered at this stage via a 103

questionnaire7 (see Annex I and Annex II). Replies from 25 experts and stakeholders are integrated 104

into this document. Stakeholders were asked to provide their knowledge in the following areas: 105

Existing methods, labels, or schemes for the assessing reparability and upgradability of 106

products; 107

Aspects influencing the reparability and upgradability of products in general; 108

Conditions influencing the reparability and upgradability of specific families of products; 109

Identification of most relevant aspects and priority parts (i.e. hardware and software 110

components of products); 111

Guidance for scoring and aggregating different aspects of repair and upgrade; 112

Specific aspects and needs for the product groups under assessment. 113

Two meetings are moreover planned in order to obtain input and feedback from the TWG: 114

1st TWG meeting on 26 June 2018 in Seville, to discuss the general approach, and to obtain 115

product-specific preliminary guidance; 116

2nd

TWG meeting in November in Brussels (tbc), to discuss product-specific approaches (and 117

to iteratively revise the general approach, if needed). 118

This first version of the report has been prepared as a working document for the 1st TWG meeting and 119

mainly aims at presenting the general assessment framework. The report is structured as follows: 120

6. Analysis of existing methods for assessing reparability and upgradability 121

7. Development of a scoring system: key aspects, priority parts, scoring framework 122

8. Product-specific considerations 123

9. Additional considerations 124

10. Annexes 125

Stakeholders are kindly invited to read and comment on this report, and to send any comments to 126

[email protected] by 27th July 2018 (please use the provided commenting 127

sheet). 128

The second consultation round will take place in parallel with the 2nd

TWG meeting, and will have a 129

more product-specific focus. The publication of the final report is planned by the end of 2018. 130

Information on the study and reports will also be made available on the dedicate website: 131

http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/index.html. 132



https://doi.org/10.1016/j.procir.2017.11.080 6 The Technical Working Group has more than 100 registered stakeholders on May 23

rd 2018

7 The questionnaire was launched on 7th

April 2018 and made accessible from

http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/documents.html. The questionnaire was closed on

7th

May 2018.

mailto:[email protected]

http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/index.html


http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/documents.html

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133

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1 ANALYSIS OF METHODS FOR ASSESSING REPARABILITY AND 134

UPGRADABILITY 135

Reparability and upgradability of products can be assessed at different levels which vary from more 136

qualitative to more quantitative approaches8. This study focuses on the evaluation of the reparability 137

and upgradability of products based on parameters that can eventually be used for determining a score 138

and/or a label icon. 139

An analysis of approaches available in the literature, and which are considered relevant for the 140

development of a scoring system on repair and upgrade, is provided in this section. These include: 141

Austrian standard ONR 192102:2014 'Label of excellence for durable, repair-friendly 142

designed electrical and electronic appliances'9 143

'Design For Repairability' tool10

144

i-Fixit score11

145

Groupe SEB's 'Product 10Y Repairable' label12

146

prEN 45554 'General methods for the assessment of the ability to repair, reuse and upgrade 147

energy related products'. 148

Through the initial questionnaire, stakeholders have been asked to provide their familiarity with these 149

and other approaches, as well as their opinion about advantages, disadvantages, diffusion and 150

robustness of the approach itself. 151

1.1 Austrian standard ONR 192102:2014 152

This standard establishes criteria to obtain a quality label for durable, repair friendly designed 153

electrical and electronic appliances (white and brown goods13). White goods undergoing this process 154

are assessed against a set of 40 requirements; 53 requirements are instead considered for brown 155

goods. The system is composed of both mandatory pass/fail requirements, and requirements based on 156

graded classes. The latter ones are used to quantify a score, which is then related to a 5-10 quality 157

level and an overall rating, as shown in Table 1. 158



https://doi.org/10.1016/j.procir.2017.11.080 9 ONR 192102: 2014 10 01 - Gütezeichen für langlebige, reparaturfreundlich konstruierte elektrische und

elektronische Geräte, Available at https://shop.austrian-

standards.at/action/de/public/details/527823/ONR_192102_2014_10_01 (accessed on 24th May 2018) 10 http://www.repairability.org (accessed on 10

th May 2018)

11 https://www.ifixit.com/ (accessed on 24th

May 2018) 12 http://www.groupeseb.co.uk/repairable.html (accessed on 24th May 2018) 13 No official definition is provided, however, in general: i) white goods include large electrical products used

domestically, such as refrigerators and washing machines; ii) brown goods include consumer electronics

equipment for entertainment, such as televisions and media players.


https://shop.austrian-standards.at/action/de/public/details/527823/ONR_192102_2014_10_01

https://shop.austrian-standards.at/action/de/public/details/527823/ONR_192102_2014_10_01

http://www.repairability.org/

https://www.ifixit.com/

http://www.groupeseb.co.uk/repairable.html

9

Table 1 Conversion table for level of quality and rating in ONR 192102:2014 159

160

14 out of 25 (56%) respondents to the initial questionnaire reported to know, up to a certain point, the 161

standard. However, only half of them declared to be satisfactorily/ sufficiently familiar with the 162

approach. 163

According to stakeholders, some of the advantages of ONR 192102 include: 164

A comprehensive overview of criteria, covering both white and brown goods (especially valid 165

for washing machines) and both horizontal and service support issues; 166

Provision of a practical labelling framework specifically focused on reparability; 167

Involvement of experts and associated actors, and further application by different 168

organisations. 169

On the other hand, stakeholders have reported or commented the following as weaknesses for ONR 170

192102: 171

It covers only a part of ICT products 172

It is a national standard and therefore it may be representative for the Austrian market only. 173

Some stakeholders moreover argue that it was developed without sufficient involvement of 174

relevant industry sectors 175

It mixes aspects such as ease of use, durability, reparability, service support, quality 176

management, documentation and commercial warranty 177

Some of the criteria used are in conflict with harmonised EU legislation (e.g. the Machinery 178

Directive [MD], Low Voltage Directive [LVD]) and some safety standard elements (e.g. 179

mandatory use of special screws) 180

The standard seems biased towards independent professional repair as there is no criteria for 181

different target groups or skill levels, and some criteria are either over-specific, not neutral, or 182

ambiguous 183

The scale of the scoring system is based on manufacturers' information and trade-offs 184

between different criteria are allowed, which brings some elements of subjectivity 185

The criteria and their means of verification are not always clearly defined 186

It is complex and costly 187

The overall opinion of stakeholders about ONR 192102 is summarised below. 188

Some stakeholders consider that ONR 192102 can be a good starting point for evaluating the 189

reparability of products, although it comes with some limitations; 190

Other stakeholders do not consider that the standard as such is suitable for the development of 191

a scoring system to use for regulatory purposes, as they see that improvements are needed, 192

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especially in terms of robustness and scope, as well as the fact that this standard is presently 193

not widely used. 194

1.2 i-Fixit scoring system 195

A reparability score between zero and ten is assigned by iFixit to different categories of devices (e.g. 196

laptops, smartphones), where a score of ten represents the easiest product to repair on the market. The 197

scoring system considers indicators such as: ease of disassembly, availability of service manuals, 198

types of fasteners used, type and number of required tools, possibility to upgradable the device, and 199

modular design14

. 200

17 out of 25 (68%) respondents to the initial questionnaire declared having a certain knowledge of the 201

i-Fixit scoring system. However, only 5 respondents declared a high level of familiarity with the 202

method. 203

According to stakeholders, the advantages of the i-Fixit scoring system include: 204

It is useful for design purposes; 205

It is simple, practical and clear for consumers, 206

It is seemingly fair and lists both positive and negative items; 207

It combines qualitative and quantitative methods; 208

It allows for the weighting of criteria 209

It provides repair guides for different high-tech products, also documenting the number and 210

type of operations and required tools, in an independent manner; 211

It provides a score in a publicly available and popular platform, which can help to increase 212

awareness regarding the topic. 213

On the other hand, weaknesses explicitly listed by stakeholders for the i-Fixit method are: 214

The current version is oriented towards the assessment of specific product categories (ICT 215

products) and therefore it is not applicable to all products. Methods could, however, be 216

adapted for other products and scenarios; 217

The scoring and weighting system used seems not sufficiently transparent. The 218

methodological guidance is currently unpublished and is under revision; 219

The availability and cost of spare parts are not included in the assessment; 220

It is oriented towards consumers, including self-repairs (e.g. repair information for free, no 221

proprietary screws, number of screws) and some industry stakeholders argue that this 222

discriminates against other repair strategies that would result in repairable devices as well. 223

The scoring methodology is partly subjective (e.g. 'discretionary feel after taking apart', 224

'components not tightly packed', 'no excessive use of adhesives', 'no substantial prying effort', 225

'critical components easily replaceable'); 226

Weighting of scoring should be calibrated based on surveys to show where major issues are. 227

Also, surveys per se could be potentially replaced by durability tests, but those tests are very 228

expensive; 229

Reparability of products is more complex than a 1-10 scoring metric; 230

It is not a fully scientific approach. 231

The overall opinion of stakeholders about the i-Fixit method is summarised below: 232

14 https://www.ifixit.com/Info/Repairability#Section_Overview (accessed on 4

th June 2018)

https://www.ifixit.com/Info/Repairability#Section_Overview

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In general, stakeholders seem to consider the method as a good starting point for the 233

development of a scoring system. 234

However, some drawbacks have been pointed out which need to be considered. The 235

assessment has been noted as suffering from a degree of subjectivity, and thus may not have a 236

good fit for legislation-related purposes, and its understanding/ use may be restricted to 237

medium-high skilled persons (i.e. not common users). Moreover, a limited availability of 238

information about how the scoring system actually works has been reported, as well as the 239

absence of major aspects, such as the availability of spare parts, and their cost. 240

Scoring systems should be neutral with regard to the target group concerned, and should 241

allow for different repair strategies to co-exist, as long as the environmental benefits of one 242

repair strategy over another (e.g. self-repair vs. repair by OEM qualified service engineers) do 243

not lead to conclusive results on which one should be preferred. 244

A more widely consensually-agreed methodology would be preferable, and that should be 245

ultimately based on the ongoing work that should result in EN standards – e.g., prEN 45554. 246

1.3 'Design for Repairability' tool 247

Starting from the approach developed by iFixit for phones and tablets and on the further work of 248

Flipsen et al. (2016)15

, key design criteria to assess the reparability of a product have been included in 249

the 'Design for Repairability' tool16

. This is a scoring system based on the assessment of 20 criteria 250

related to the ability of consumers to repair a product by themselves (i.e., 'Do-It-Yourself' repair). The 251

tool's aim is to assess brown goods (television sets, audio equipment, and similar household 252

appliances). A 0-1-2 rate is assigned to each criteria and the overall score is then normalised to a 0-to-253

10 basis. 254

8 out of 25 (32%) respondents to the initial questionnaire reported knowledge of the tool, up to a 255

certain point. However, only half of those were 'satisfactorily familiar' with the approach. 256

According to stakeholders, advantages of the 'Design for Repairability' tool include: 257

Ease of understanding and use. 258

On the other hand, weaknesses explicitly listed by stakeholders for the Design for Repairability tool 259

are: 260

It focuses on brown goods and is too general (no distinction between product categories); 261

Some criteria are over-specific or not neutral, and they are - for instance - oriented to repairs 262

made by consumers (whilst not all failures should be fixed by users, for safety reasons); also, 263

the criteria poorly represent B2B interests/ activities; 264

It mixes the evaluation of product design, service support, health & safety, commercial 265

aspects, and external factors such as 3rd

-party provision of repair information. 266

Some key aspects - in an objective way – are absent (e.g. ease of disassembly); 267

Criteria and means of verification are not always clearly defined, and results are heavily 268

influenced by operator skills; 269

It has been developed without the involvement of relevant industry sectors. 270

The overall opinion of stakeholders about the Design for Repairability tool is summarised below: 271

Some stakeholders considers that the Design for Repairability tool could be a good starting 272

point for evaluating the reparability of products, although some improvements have to be 273

applied. 274

15 Flipsen et al., 2016. Developing a Reparability Indicator for Electronic Products 16 www.repairability.org (accessed on 4

th June 2018)


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Nevertheless, other stakeholders pointed out that the tool is not sufficiently robust, as well as 275

remarking that it is possibly over-simple and too general to be used for regulatory purposes. 276

1.4 Groupe SEB's 'Product 10Y Repairable' label 277

The 'Product 10Y Repairable' label is a mark that the Group SEB applies with the aim of promoting 278

the reparability of the small household appliances that they commercialise. The label aims to indicate 279

to consumers: 280

1. Proximity of authorised and trained repair centres; 281

2. Possibility to fully disassemble and reassemble the appliance without risk of damaging the 282

product; 283

3. Fast availability of spare parts (24-48 hours shipment time), over time (to be in stock for 10 284

years or more) and at an affordable cost (at a maximum, each part must cost less than 50% of 285

the total product cost). 286

8 out of 25 (32%) participants have declared a certain knowledge of the Groupe SEB's 'Product 287

Repairable' label, and 3 respondents declared a low knowledge. 288

According to stakeholders, advantages of the Groupe SEB's Product Repairable label include: 289

It is a label that ensures that all criteria are respected; 290

It is an easily understandable and usable approach, which is also in line with the Ecodesign 291

Directive's philosophy; 292

It takes into account availability and price of spare parts, and provides a commitment on the 293

period during which the product can be repairable and on the cost of repair during that period; 294

On the other hand, weaknesses explicitly listed for the Groupe SEB's "Product Repairable" label are: 295

It is a binary pass/fail concept so that no information is provided if the product is not 296

repairable, nor if it is not possible to differentiate between products for labelling purposes; 297

It is biased towards professional repair, it needs a strong network of repairers, and it does not 298

take into account aspects for other target groups (e.g. lower skill levels); 299

It is an internal procedure which cannot be used for external verification; 300

It is too general and simplistic and does not provide clear definitions. 301

The overall opinion of stakeholders regarding Groupe SEB's Product Repairable label is summarised 302

below: 303

Some stakeholders consider the label as a good starting point to assess the reparability of 304

products. 305

Other stakeholders consider that the method does not allow taking into account the 306

complexity of design and repair at a satisfactory level. 307

1.5 prEN 45554 - General methods for the assessment of the ability to repair, reuse 308

and upgrade energy related products 309

This is a draft standard which is currently developed by CEN-CENELEC's JTC10 'Energy-related 310

products – Material Efficiency Aspects for Eco-design', in response to the standardisation mandate 311

M/54317

. The standard, planned to be published in 2019, aims to provide a toolbox of parameters and 312

methods to assess the ability to repair, reuse and upgrade energy-related products (ErP). 313

17 M/543 COMMISSION IMPLEMENTING DECISION C(2015)9096 of 17.12.2015 on a standardisation

request to the European standardisation organisations as regards Ecodesign requirements on material efficiency

aspects for energy-related products in support of the implementation of Directive 2009/125/EC of the European

13

The last available draft18 includes: 314

Guidance for the identification of parts to be covered in the assessment; 315

A list of product-related parameters influencing repair, reuse and upgrade; 316

A list of parameters related to manufacturers' support to facilitate repair, reuse or to upgrade; 317

Examples of possible classification and rating criteria for such parameters 318

('Disassemblability'; Disassembly depth; Fasteners; Tools; Working environment; Skill level; 319

Diagnostic support and interface; Availability of spare parts; Availability of information; 320

Return models; Data transfer and deletion); 321

Quantitative assessment methods (Disassemblability index; Time for disassembly; Product 322

reparability index; Product reusability index; Product upgradability index). 323

The standard provides a general approach, which should be tailored to specific products. 324

15 out of 25 (60%) respondents are 'somehow familiar' with prEN 45554. According to stakeholders, 325

advantages of the prEN 45554 standard would include: 326

It provides a toolbox with qualitative and quantitative methods; 327

It addresses a comprehensive range of aspects and takes into account a wide range of 328

repair/upgrade scenarios and target groups; 329

It allows a framework for the selection of most appropriate criteria and methods to assess the 330

reparability and upgradability of a specific product; 331

It is technologically neutral and compatible with a scoring system concept; 332

Measurable parameters are proposed, and the classification methods are rather objective and 333

relatively simple to apply; 334

It has been broadly discussed with stakeholders from different organisation during the 335

standardisation processes. 336

On the other hand, weaknesses explicitly listed by stakeholders for the pr45554 standard are: 337

The standard is still in a draft form and unpublished, and that compliance criteria are not yet 338

well defined; 339

It is theoretical and needs to be tailored to product-specific levels, including the assignment of 340

scores and weights. 341

Little guidance for aggregation is provided. The overall opinion of the stakeholders regarding the 342

prEN 45554 standard is summarised below: 343

Results of the assessment must not be subjective, but instead must be repeatable and 344

reproducible. A solid standardisation base is needed to secure measurable and enforceable 345

legal requirements. 346

This seems the best ground to develop a high-level assessment framework and to set the basis 347

for the development of product-specific approaches. The majority of stakeholders support the 348

standardisation work done within CEN-CENELEC, although it is not clear if this could fit for 349

regulatory purposes at the time being. 350

Parliament and of the Council. Available at http://ec.europa.eu/growth/tools-

databases/mandates/index.cfm?fuseaction=search.detail&id=564# (last accessed on 25th

May 2018) 18 DOCUMENT NUMBER CEN-CLC JTC10/Sec/176/DC

http://ec.europa.eu/growth/tools-databases/mandates/index.cfm?fuseaction=search.detail&id=564

http://ec.europa.eu/growth/tools-databases/mandates/index.cfm?fuseaction=search.detail&id=564

14

However, the standard is still under development and has a too general approach. Further 351

investigation will be moreover needed to capture accurately the specificities of single product 352

groups. 353

The standard prEN 45553 regarding remanufacturing of ErP was also mentioned as a possible 354

source of inspiration for the development of a scoring system on reparability and 355

upgradability. 356

1.6 Other methods 357

Respondents to the questionnaire pointed out three additional methods which could be taken into 358

account for the development of a scoring system: 359

eDiM (ease of Disassembly Metric)19: this method provides a quantitative indication of the 360

time, and thus of the difficulty, needed to disassembly and reassembly a component/product. 361

The eDiM method is based on the Maynard Operation Sequence Technique (MOST) and 362

requires information about product components and adopted fasteners, which can be directly 363

verified within the product. The tasks necessary to disassemble and reassemble a particular 364

component/product are listed and reference time values (coming from MOST) are associated 365

to each of them, representing the effort needed to perform such operation. Although this 366

method offers a theoretically comprehensive metric regarding the "disassemblability" of a 367

product, it was mentioned that its implementation is complex. Moreover, this metric seems 368

difficult to be used as a standalone method since it does not represent entirely the repair 369

process (e.g. availability of spare parts is not considered). 370

Benelux Reparability study: this is a study (work ongoing and unpublished at the time of 371

preparing this report) which aims to provide an overview of relevant criteria related to the 372

reparability of products. The repair operation is divided into steps: product identification, 373

failure diagnosis, disassembly and reassembly, replacement of spare parts, restoration to 374

working condition. For the different steps of repair, the following types of criteria are 375

considered: information provision, product design, servicing. A score is assigned to each 376

repair step. The methodology, reported to be in line with current developments of the draft 377

prEN 45554, differentiates between who carries out the evaluation (e.g. professionals vs. 378

laymen) and has been tested in three case studies (i.e. two vacuum cleaners and one washing 379

machine). 380

1.7 Summary 381

From the feedback received from the respondents to the initial questionnaire, it seems that existing 382

methods to assess the reparability and upgradability of products provide a good starting point for the 383

development of a scoring system. However, especially some aspects deserve more attention: 384

Objectivity and reproducibility of assessment and verification methods; 385

Ease of understanding of system and reported information; 386

Representativeness of requirements for products at EU level; 387

Applicability to a broad scope of repairers (DIY, independent professionals, authorised 388

professionals, OEM). 389

Of the methods presented, respondents generally recommended to use the experience already gained 390

in prEN 45554 as much as possible in the development of the possible reparability scoring system. 391

Draft standard prEN 45554 is seen as the main reference, because it has been broadly discussed for 392

almost two years during the CEN-CENELEC standardisation process with many experts involved and 393

representing different stakeholders. This draft standard could provide a framework for the selection of 394

criteria and methods to assess the reparability and upgradability of products, which have to be tailored 395

to specific categories of products and which could potentially be used to develop a scoring system. 396

19 Vanegas P. et al. (2016) Study for a method to assess the ease of disassembly of electrical and electronic

equipment. JRC Technical Reports.

15

However, some of the respondents expressed their concerns about the possible use of the methods 397

presented, and any derived scoring systems for regulatory purposes. 398

399

400

16

2 DEVELOPMENT OF A SCORING SYSTEM FOR ASSESSING REPAIR AND 401

UPGRADE OF GENERIC PRODUCTS 402

As shown in Figure 1, a scoring system for assessing the reparability and upgradability of products is 403

founded on three pillars20

: 404

1. Key parameters for repair and upgrade; 405

2. Priority parts; 406

3. Scoring framework. 407

2.1 Key parameters for repair and upgrade 408

The first pillar of a scoring system for assessing the ability to repair and upgrade products is the 409

definition of the key parameters influencing repair and upgrade and that should be included in the 410

assessment framework. 411

The scientific/ technological literature provides examples of parameters that are used for assessing the 412

reparability and upgradability of products21,22,23,24,25,26

. Such parameters are also connected to the 413

concept of ease of disassembly, or 'disassemblability', i.e. the ability to disassemble a product. Product 414

disassembly can be defined as 'the non-destructive (reversible) taking apart of an assembled product 415

into constituent materials and/or components, in such a way that they could subsequently be 416

reassembled and made operational'27. The irreversible process is instead defined as dismantling in the 417

present context. Product disassembly can be differentiated as28

total (if concerning the whole product) 418

or selective (if concerning one or more materials and/or components). Ease of disassembly may cover 419

aspects such as29

: number, type and positioning of materials and/or parts; their identification and 420

accessibility; need of common/specialised tools; need for precision and force; time; ergonomics 421

issues. 422

An effort to harmonise such concepts has been undertaken by CEN-CENELEC Joint Technical 423

Committee JTC10 'Energy-related products – Material Efficiency Aspects for Ecodesign' with the 424

prEN 45554 standard 'General methods for the assessment of the ability to repair, reuse and upgrade 425

energy related products'. 426

Building on the information available, JRC defined a preliminary list of generic parameters 427

influencing repair and upgrade. These parameters were analysed and commented upon by the 428

stakeholders who responded to the initial questionnaire. Figure 2 and Figure 3 show how respondents 429

qualitatively evaluated the identified parameters, as relevant for repair and upgrade. The relevance of 430

the parameters was ranked by giving a score to each of the options (high = 3; medium = 2; low = 1; no 431

= 0), and it is reported in 432



https://doi.org/10.1016/j.procir.2017.11.080 21 https://www.ifixit.com/Info/Repairability#Section_Overview 22 Flipsen et al., 2016. Developing a Reparability Indicator for Electronic Products 23 COMMISSION DECISION (EU) 2016/1371 of 10 August 2016 establishing the ecological criteria for the

award of the EU Ecolabel for personal, notebook and tablet computers (available at: http://eur-

lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016D1371&from=EN) 24 IEEE 1680.1 Standard for Environmental Assessment of Personal Computer Products 25 1680.3-2012 - IEEE Standard for Environmental Assessment of Televisions 26 1680.1/Draft_23, March 7, 2017 Draft Standard for Enviromental Assessment of Personal Computers

Products Including Notebook Personal Computers, Desktop Personal Computers, Slate/Tablets, Small Scale

Servers, Signage Displays and Personal Computer Monitors 27 Based on BS 8887-2:2009 and EN 62542:2013 28 A. Desai, A. Mital / International Journal of Industrial Ergonomics 32 (2003) 265–281 29 T.F. Go et al. / Journal of Cleaner Production 19 (2011) 1536e1546


17

Table 2. The results showed in table 2 are merely indicative of the relevance of each parameter on the 433

basis of the feedback received from stakeholders. 434

It can be observed that all parameters are relevant for both reparability and upgradability:The most 435

important parameter for reparability of products, according to the feedback received, is the availability 436

of spare parts. This is followed by: ease of access to parts, information on the disassembly sequence, 437

and availability of information. Working environment is the least important parameter, but still 438

relevant for repair. The results are in line with the outcomes of the behavioural study on 'Consumers' 439

engagement in the Circular Economy' (commissioned by DG JUST, now in its final stage), indicating 440

that spare parts, availability of repair services, and availability of information are important factors for 441

users. 442

The most important parameter for the upgradability of products, according to the feedback received, is instead the 443 instead the availability and ease of installation of software and firmware (where applicable). This is followed by: ease 444 followed by: ease of access to parts, provision of diagnostic support and interfaces, availability of information, and 445 information, and availability of spare parts. The relative importance of the disassembly sequence and other 446 other parameters related to disassemblability are rated lower in the case of upgradability than for reparability. The 447 reparability. The working environment is the least important parameter, but is still relevant for repair. 448

Table 3Table 2 sums up the respective rankings of parameters for reparability and upgradability, and 449

Table 3 summarises the input received with regard to the assessment and verification of these 450

parameters. 451

452

453

Figure 2 Relevance of parameters influencing reparability on the basis of the input received from the respondents to 454 the initial questionnaire 455

456

18

457

Figure 3 Relevance of parameters influencing upgradability on the basis of the input received from the respondents 458 to the initial questionnaire 459

460

Table 2 Ranking of the parameters based on the analysis of the input received from the respondents to the initial 461 questionnaire 462

463 464

Table 3 Technical parameters generally influencing repair and upgrade of products 465

Parameter Technical considerations

1. Disassembly sequence Assessment and verification based on documentation of

disassembly steps in instruction manuals and/or other on-line

information systems (e.g. I4R platform for recyclers).

Penalisations to apply in case of destructive disassembly of

some parts.

Alternatively, calculation of disassembly times based on

standard time units (e.g. MOST, eDIM, iFIXIT). In case of data

gaps, time to be determined through field research.

2. Type, number and visibility

of fastenings and connectors

Assessment and verification based on information provided by

the manufacturer (e.g. with illustrated disassembly instructions).

Information could be provided in manuals and/or other on-line

platforms. A categorisation is required, which should be

Availability of spare parts 2.9 2.7 Availability and ease of installation of software and firmware

Ease of access to parts 2.8 2.7 Ease of access to parts

Disassembly sequence 2.7 2.5 Provision of diagnostic support and interfaces

Availability of information 2.7 2.5 Availability of information

Provision of diagnostic support and interfaces 2.6 2.5 Availability of spare parts

Availability and ease of installation of software and firmware 2.5 2.2 Type, number and visibility of fastenings and connectors

Type, number and visibility of fastenings and connectors 2.5 2.2 Level of skills required to undertake the operations

Tools needed (availability, complexity, cost) 2.4 2.2 Disassembly sequence

Level of skills required to undertake the operations 2.4 2.2 Tools needed (availability, complexity, cost)

Working environment 1.6 1.5 Working environment

Reparability Upgradeability

19

performed according to prEN 45554.

Marking was also suggested to improve visibility of fasteners.

3. Tools needed (availability,

complexity, cost)

The manufacturer should document the type of tools needed to

repair the product. The use of standard/basic tools should be

granted, but a penalisation applied when proprietary tools are

needed. A categorisation is required, which should be done

according to prEN 45554.

Other aspects suggested for possible consideration are cost and

complexity.

4. Ease of access to parts This element is considered to be a difficult parameter to assess

and verify, as it also requires the satisfactory definition of

'priority part', which is also very much related to other

parameters (1, 2, 3, as well as identification of parts). The

measurement of standardised time units could be used.

5. Working environment (e.g.

home, professional repair

site, manufacturing plant)

The classification used in prEN 45554 was suggested for

assessment and verification, although some refinements and

clarifications may be needed to allow verification.

Safety issues and type of operations should be considered in the

classification.

Moreover, it was suggested its possible split into 'repair at home'

and 'repair by professionals', which would require the definition

of which operations can be performed by a user.

6. Level of skills required to

undertake the operations

Assessment and verification based on documentation provided

by the manufacturer indicating which operations can be

performed by the users.

7. Provision of diagnostic

support and interfaces

The classification used in prEN 45554 was suggested for

assessment and verification. Information to be provided by the

manufacturer, e.g. troubleshooting, manual or portals for

authorised repairers.

The interface is specific of the product design.

8. Availability of spare parts Information by the manufacturer about the availability of spare

parts in years, complemented by verification of actual

availability.

The definition of 'parts that are more likely to fail' is needed.

Price of spare parts and their delivery time are also important,

although these might perhaps fit better as minimum

requirement.

9. Availability and ease of

installation of software and

firmware

Declaration by the manufacturer about the availability of

software and firmware in years, complemented by verification

of actual availability.

10. Availability of information

(e.g. repair and/or upgrade

manuals, exploded

diagrams)

Assessment and verification based on the public information

supplied by the manufacturer (e.g. manuals, on-line platforms,

manufacturer website), complemented by audits for assessing

the availability of restricted information.

Classification of information for different users is needed, as

presented in prEN 45554.

466

20

In addition to the parameters discussed above, the repair and upgrade of products can also be limited 467

by other aspects (e.g. purchase price of the product and labour cost of repair, demand for new vs. 468

repaired/upgraded products, guarantee issues, support networks facilitating the repair process, 469

business models, compatibility issues). Stakeholders were asked to provide scenarios/conditions for 470

these aspects, where repair and upgrade operations are more likely to occur. Table 4, below, compiles 471

this initial additional feedback from stakeholders. 472

Guarantee issues related to the repair of products is an aspect that deserves more discussion (see 473

Section 2.3) since its inclusion in a scoring system could be a relevant factor to promote the effective 474

repair and durability of products. 475

Additional parameters that could be of potential interest for discussion (see Section 2.3) are: 476

1. Return of models 477

2. Data transfer and deletion 478

3. Safety issues 479

4. Availability of OEM qualified service engineers. 480

5. Ease of restoring product to working condition after repair. 481

Some aspects highlighted by stakeholders, such as emotional attachment to products, attitude and 482

education of consumers, repair costs, tax exemptions and labour cost reductions are considered to be 483

mainly related to socio-economic issues, which can be difficult to integrate into this type of study, i.e., 484

to explicitly work to develop a potential scoring system. 485

21

Table 4 Other factors influencing repair and upgrade according to stakeholders 486

Aspects Favourable conditions for Repair Favourable conditions for Upgrade Other comments

Functional,

technological and

behavioural factors

(e.g. demand for new

vs. repaired/upgraded

products)

Conscious design, also aimed at

reducing the complexity of

products, using resistant

materials, and slowing down the

development and innovation

cycles (especially for products

where design and fashion are not

important)

Functionality of the product must

be fully recovered after repair

Emotional attachment and high

reliance on the functions of the

product

Other factors (e.g. age of user,

relationship with technology,

functionalities offered by new

technologies, attitude towards

new vs. conserving the old,

social pressures).

Provision of information about

the product, and web-based

access to such information

Education about material

efficiency issues

Conscious design, also aimed at

reducing the complexity of

products and customising products

(especially for fast moving

products where functions can be

more important than aesthetics)

Knowledge/information of

possibility to upgrade and

availability of software upgrades

Upgrade must not negatively affect

other functionalities of the product

Emotional attachment and high

reliance on the functions of the

product

Other factors (e.g. age of user,

relationship with technology,

functionalities offered by new

technologies, attitude towards new

vs. conserving the old, social

pressures).

Provision of information about the

product, and web-based access to

such information

Education about material efficiency

issues

Not as important as other factors.

More important for upgrade than

for repair

Economic factors

(e.g. purchase price

for product and spare

Purchase price, which is

associated with the quality of the

product

Low prices for software/parts

upgrades, compared to the product

purchase price

Very important for repair, not so

relevant for upgrade

Consumers would be generally

22


parts, labour costs) Spare parts not more expensive

than 20% of new product.

Tax exemption for repair

activities

Offering products as service, (i.e.

leasing)

EPR (extended product

responsibility) fees used to

support the repair sector over and

above the recycling sector (in

line with waste hierarchy)

Tax exemption for upgrade

activities

Offering products as service, (i.e.

leasing)

EPR fees used to support upgrading

activities over and above the

recycling sector (in line with waste

hierarchy)

willing to repair their products

when the total repair cost is lower

than 33% of the purchase price for

a new appliance. 10% of

consumers would accept repairing

a product when the total repair

cost is between 33%-50% of

purchase price for a new

appliance. Repair would not be

likely when the total repair cost is

above 50% the price of a new

appliance30

Organisational factors

(e.g. access to

professional repair

services or support

networks)

Official registration platform of

professional repairers (receiving

a licence to repair)

Support awareness and education

to final users in circular economy

aspects like repair

Manufacturer support network

easily accessible

Availability of OEM qualified

service engineers

Expand repair options beyond

manufacturer authorised

networks (e.g. non-profit

initiatives and DIY)

Support awareness and education to

final users in circular economy

aspects like repair

Manufacturer support network

easily accessible

Expand repair options beyond

manufacturer authorised networks

(e.g. non-profit initiatives and DIY)

Proximity of upgrade providers

New business models: product as a

service and repair as a business

strategy

Consumers sometimes do not

know where to take their broken

appliance to get them repaired

Manufacturers or their authorised

repairers can provide official

services, but these may be more

expensive than independent

repairers

Companies should work together

with independent repairers to

ensure that the repairs are done in

a responsible way

30 Emission Cash, 2012, "La mort programée de nos appareils" http://www.inexplique-endebat.com/article-cash-investigation-la-mort-programmee-de-nos-appareils-le-

lobby-du-sel-106398577.html (accessed 22/05/18)

http://www.inexplique-endebat.com/article-cash-investigation-la-mort-programmee-de-nos-appareils-le-lobby-du-sel-106398577.html

http://www.inexplique-endebat.com/article-cash-investigation-la-mort-programmee-de-nos-appareils-le-lobby-du-sel-106398577.html

23


Proximity of repair providers

Limiting time and cost of repairs

for the typical faults

New business models: product as

a service and repair as a business

strategy

Legal factors (e.g.

legal guarantee,

commercial

guarantee31, liability

issues)

Provision of an additional

commercial guarantee (X years):

in order to support repair, the

commercial guarantee could

include a 'hierarchy of remedies'

with for example product repair

as first option ('commitment to

repair for free') and, only if the

producer determines that the

repair is impossible or more

expensive than the other

remedies, the product will be

either replaced or refunded.

The commercial guarantee,

covering the entire product or

only specific parts, can either be

included in the price of the

product or purchased at an extra

cost. In the latter case, cheaper

guarantee extensions could come

The guarantee should cover also

the use of the product after its

upgrade

Business models (service models)

It is important to understand how

repair operations can affect

consumer safety and liability.

Companies should get more

involved and contribute to the

definition of which repairs can be

done by whom

Manufacturers should work

together with repairers to support

repair rather than use liability as

an excuse

According to the Consumer Sales

and Guarantees Directive

1999/44/EC, a minimum of 2

years legal guarantee must be

offered by the seller for any

product put on the market. When

manufacturers cover only 1 year

31

As defined in the Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights, the commercial guarantee (often also called

(extended) 'warranty') means any undertaking by the trader or a producer (the guarantor) to the consumer, in addition to his legal obligation relating to the guarantee of

conformity, to reimburse the price paid or to replace, repair or service goods in any way if they do not meet the specifications or any other requirements not related to

conformity set out in the guarantee statement or in the relevant advertising available at the time of, or before the conclusion of the contract.

24


with discounts for official repairs

and create more favourable

conditions for repair.

Transparency of rules on how 3rd

party repairs can affect legal and

commercial guarantees

Provision of a warranty for

repaired products

Possibility to denounce cases

where a guarantee has not been

honoured

Mandatory information about

availability and price of spare

parts

Guarantees facilitating the

handling of issues related to

damages during shipments

Business models (service

models)

of the guarantee, the remaining

time period is under the sole

responsibility of the seller.

Anecdotal evidence shows that

consumers can encounter some

difficulties in implementing their

legal guarantee rights. For

example, according to the

information from 'trop vite usé'32

most of the complaints from

mobile phones concerned

appliances that were less than 2

years old. 70% of the users who

reported a complaint tried to have

their mobile phone repaired but

only 7% succeeded. The study

also reports that the greatest

complaint from people who have

repaired their appliances is that

the same problems persist even

once the products are returned,

often related to issues within

electronics circuits (e.g. printed

circuit board [PCBs], which some

companies do not consider as

'their' problem).

487

32 https://www.test-achats.be/trop-vite-use# (accessed 23/05/2018)

https://www.test-achats.be/trop-vite-use

25

2.2 Priority parts 488

In this context, the term 'priority parts' refers to those parts with a higher need/ importance/ frequency 489

to be repaired and/or upgraded. In products with a large list of parts, it might be indeed relevant to 490

make a selection parts to reduce the complexity of the assessment and focus only on those that are 491

more prone to be repaired or upgraded. 492

Several aspects could be considered for the definition of priority parts. Figure 4 and Figure 5 show the 493

indications gathered from the participants in the initial questionnaire regarding the relevance of 494

different aspects. From the two figures it can be seen that: 495

The failure of parts is in general indicated as the most important aspect for repair, which is 496

followed by the functional importance of the part itself. The difficulty to disassembly parts, 497

expressed in this case in terms of steps, is also somehow important but is ranked lower. 498

Stakeholders ranked economic and environmental aspects per se with lower importance. 499

In the case of upgradability, the differences in importance are fuzzy between frequency of 500

upgrade, functional importance, economic value and the difficulty to disassemble parts, 501

expressed in this case in terms of steps. The relative importance of the frequency of 502

failure/replacement is lower compared to reparability, whilst it becomes slightly higher for the 503

economic value. Stakeholders also gave a low ranking to environmental aspects per se. 504

505

506

Figure 4 Relevance of different aspects for the definitions of priority parts for repair 507

26

508 Figure 5 Relevance of different aspects for the definitions of priority parts for upgrade 509

510

2.2.1 Frequencies of failure and upgrade 511

The frequency of the failure of parts is in general seen by stakeholders as the most important aspect 512

for determining priority parts, with respect to reparability issues. This is also related to reliability 513

concepts defined as the mean time between failures. Nevertheless, the frequency of failures can only 514

be evaluated when market and users have gained experience with a certain product and typical repair 515

requests have been identified. 516

According to the feedback received by stakeholders, most companies aim to have no more than a 517

small fraction of products (e.g. less than 3%) failing during warranty periods, because of cost reasons. 518

Data on failure rates should thus be collected after the warranty period. 519

The frequency of upgrade of parts and software is highly relevant for the upgradability of products 520

and it can to some extent determine the likelihood of obsolescence of the product. The frequency of 521

upgrade is not a criterion in itself, but is reflected by its consequence in factors such as rapid 522

technology change, changes in the use given to a part, design and specifications of a product. 523

524

2.2.2 Functional importance 525

If a part (either hardware or software) is important for the functioning of the product, it should have 526

high priority. The part is instead less relevant if related to secondary functions. Functional importance 527

of parts is nevertheless relevant only if combined with likelihood of failure/upgrade. 528

From a technical point of view, the functional importance of parts could be for instance categorised as 529

follows: 530

1) The part does not affect the functioning nor the performance of the product 531

2) The part can affect the performance of the product 532

3) The part can affect the functioning of the product. 533

27

User experience and more subjective elements such as aesthetics and personalisation could also play a 534

role, especially for upgradability. However, according to the feedback received, lists of functional 535

parts cannot be generalised and could also depend on the market strategy of manufacturers. 536 537

2.2.3 Price of parts and cost of repair/upgrade 538

According to some of the feedback received, the cost of the spare part should not define how 539

important it is for the product (e.g. although carbon brushes are very cheap, a washing machine cannot 540

work without them). 541

On the other hand, if a part is likely to fail and is key for the functioning of the product, the price of 542

replacement should not be too high: the lower the price, the higher is the likelihood of repair. The 543

price for repair is highly dependent on the labour costs. 544

For upgrade it was reported by some stakeholders that the economic value is not a good indicator, 545

since this could penalise high-quality products and ICT products, where subsequent important 546

upgrades (software) can often come for free. 547

548

2.2.4 Environmental impacts of parts 549

Although considered important for the sustainability of products, some concerns were received from 550

stakeholders: 551

Environmental considerations can be relevant only if combined with the failure/upgrade 552

likelihood. Repair and upgrade hold the potential to increase the lifetime of products and 553

reduce their impacts. However, the repair/upgrade of products is often driven by other socio-554

economic factors; 555

It could result in false incentives for repair and upgrade, for instance, as a consequence of the 556

integration of many functions in circuit boards, which would be detrimental for the economic 557

feasibility of repair. 558

There is no commonly agreed or standardised method to analyse the environmental impact of 559

appliances. 560

561

2.2.5 Disassembly of parts and reinstallation of software 562

Split views were registered for this aspect: 563

On the one hand, there are those who think that the difficulty of disassembly, for instance 564

expressed in terms of disassembly steps, is important to identify priority parts. However, it 565

has to be considered that different kinds of appliances exist. For instance, a freestanding 566

fridge will have fewer steps to access a certain part than for a built-in fridge. 567

On the other hand, there are those who do not consider the difficulty to undertake disassembly 568

relevant in assessing the importance of parts to be repaired/ upgraded. This could be viewed 569

more as an outcome of the assessment, and not as an element to decide what should be 570

assessed, since the latter depends mainly on the frequency of failure/upgrade. 571

Some stakeholders suggested referring to the measurement of disassembly and reassembly times 572

based on standard time units instead of considering disassembly steps only. 573

574

2.2.6 Additional considerations 575

The feedback received from stakeholders recommends that ad-hoc lists of priority parts need to be 576

determined: 577

On a product-by-product basis and taking into account for different models of the same 578

product on the market, 579

28

After engaging with manufacturers, repairers and other relevant experts 580

Including expert-judgement, safety and functional considerations, 581

Taking into consideration the likelihood that a replacement may be needed for repairing or 582

upgrading the product, and the conditions under which a given part is deemed to be a priority 583

part (e.g. batteries with a life below X recharge cycles, electric motors that last below X hours 584

of operation), 585

Limited accessibility should be considered for certain features (e.g. water tightness and 586

climate resistance). 587

Moreover, additional aspects should be taken into account when determining priority parts with 588

regard to upgradability: 589

The complexity of the product, since the likelihood of the need to upgrade appliances can 590

increase with the complexity of their design 591

Evaluation of parts for upgrading is expected to focus mainly, but not exclusively, on parts 592

subject to rapid technology changes, or changes in use profiles over the lifetime of the 593

product. Specific attention, however, should be given to the role of software and firmware. 594

For laptops, the operating system is the most important part which determines functionality 595

and which requires frequent updating. Hardware parts such as storage chips can be relevant in 596

cases below a certain minimum configuration. 597

Parts that are planned to be upgraded and have standardised interfaces in typical products 598

should have the highest priority. However, it is difficult to predict, at the time of placing an 599

appliance on the market, what will be the future updates. Updates can be to an extent 600

predicted based on market and user experience with the product, or similar products. 601

602

29

2.3 Scoring framework 603

The parameters identified in the previous sections can be used to assess the reparability and 604

upgradability of products through pass/fail requirements and scores. This requires the definition of 605

classification/rating criteria to use for the evaluation of single parameters. An example is provided in 606

Table 5 which presents three classes of scores: 0 (negative attribute), 0.5 (neutral attribute), 1 607

(positive attribute). Scores could be expressed in a different scale (e.g. 0 to 1, 0 to 5, or 0 to 10), or 608

weighted (if some criteria are considered to be more important) and – optionally - aggregated into one 609

or more indices. 610

611

Table 5 Examples of possible rating criteria for the evaluation of parameters 612

Parameter Description of the proposed rating criteria (illustrative purposes only)

Availability of

spare parts

Score:

0 points: Original spare parts are not available to replace priority parts

0.5 points: Original spare parts are available for less than 5 years after

purchase of the product, and not for all priority parts

1 point: Original spare parts are widely available to replace all priority

parts. Availability is ensured for at least 5 years following the end of

production of the model

Types of tools

needed

Score:

0 points: Advanced specialised tools (e.g. a soldering iron, proprietary

screwdrivers) are needed to disassemble priority parts

0.5 points: Specialized tools (like screwdrivers, electric drill and small

magnets) are needed to disassemble priority parts

1 point: No tools or only basic tools (e.g. scissors, flathead and cross

recess (Phillips) screwdrivers) are needed to disassemble priority parts

613

30

2.3.1 Classification and rating of individual parameters 614 Different options for the generic classification of individual parameters are noted in 615

Table 6, and are taking into account discussions held for the development of prEN 45554 and the 616

feedback received from stakeholders. A rating score could be assigned to each class and for each 617

parameter, and could also be 'normalised', as indicated in the table. For some parameters it could be 618

more relevant to have minimum pass/fail requirements, or the reporting of the underlying information 619

(e.g. 'spare parts available for X years'). The classification and rating options shown in Table 6 refer to 620

generic products, and would have to be tailored to specific product group(s) and related priority 621

part(s), if they were to be used in practice. Moreover, to ensure a level playing field across 622

manufacturers, it was indicated by stakeholders that criteria should: 623

1. Be measurable & enforceable in an objective way (i.e. not interpretable in different ways 624

depending on who is doing the evaluation) 625

2. Not be biased towards particular repair business models; 626

3. Avoid possible trade-offs (e.g. highly durable products may be less repairable). 627

628

Table 6 Classification and rating criteria for different parameters 629

Parameter Classification/rating options (a) (b)

Technical considerations of the

study team

1) Disassembly

sequence ('DS')

A) Based on number of steps required to remove a

part from a specific product:

I. Less than X steps

II. Between X and Y steps

III. More than Y steps

Favourite option for the study team

since objective and practical.

Disassembly steps could be

replaced by disassembly time (e.g.

based on eDiM).

B) Semi-quantitative based on design characteristics:

I. Can be disassembled into individual parts.

Time required to do it is low.

II. Can be disassembled into individual parts.

Time required to do it is acceptable.

III. Can be disassembled into individual parts

but time taken is very long.

IV. Can be disassembled into individual parts

but some critical parts are gathered together

in blocks that cannot be disassembled.

V. Cannot be disassembled into individual

parts or some parts are likely to be broken

during the process.

Alternative classification, more

complete but including elements

that risk being more subjective

C) Percentile score within known spread:

Score = (DSmax – DSi) / (DSmax –

DSmin)

Where:

DSmax is the performance of the worst

product (e.g. longest disassembly

sequence or time)

DSmin is the performance of the best

product (e.g. shortest disassembly

sequence or time), which could be 1 as

a mimimum value

DSi is the performance of the analysed

Possible normalisation approach to

refer class scores to a number from

0 to 1

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study team

product

2) Type, number

and visibility of

fastenings and

connectors

A) Semi-quantitative based on type of fastenings and

connectors:

I. Reusable fasteners are used: the original

fasteners can be reused for the new part or

the fastener is supplied with the part

II. Removable fasteners are used: the original

fasteners are not reusable, but can be

removed without causing damage or leaving

residue which precludes reassembly (in case

of repair or upgrade) or reuse of the

removed part (in case of reuse)

III. Non-removable fasteners are used: the

original fasteners are not removable or

reusable

Favourite option for the study team


Visibility could be less relevant if

indicated in repair manuals

B) Semi-quantitative based on type and number of

fastenings and connectors:

I. Fastenings are standard/widely available

and clearly visible and they are a limited

number so that time required for

disassembly is low

II. Fastenings are standard/widely available

and clearly visible and they are a reasonable

number so that time required for

disassembly is acceptable

III. Fastenings are standard/widely available

and clearly visible but they are so numerous

that the time required for disassembly is

very long

IV. Fastenings used are standard/widely

available but some are not clearly visible

V. Proprietary or rare fastenings are used



that risk being subjective

C) Semi-quantitative based on type, number and

location of fastenings and connectors:

I. Fasteners/connectors are reversible, easy to

localise, and less than X in number OR only

reversible 'click' fastenings/connectors are

used and easy to localise

II. Fasteners/connectors are reversible, easy to

localise, and more than X in number

III. One or more non-reversible

fastenings/connectors (e.g. glue, soldering,

connectors that break when disassembled)

are used OR reversible

fastenings/connectors are used but they are

not immediately visible.




D) Percentile score within known spread:

Score = Fi / Fmax

Where:

Normalisation of above approaches

to refer class scores to a number

from 0 to 1

32



study team

Fmax is the score corresponding to the

best classification achievable for the

product (in terms of identification and

removal of fastenings/connectors)

Fi is the score corresponding to the

class of the analysed product

3) Tools needed

(availability,

complexity, cost)

A) Semi-quantitative based on type and availability

of tools:

I. Common tools: Repair/upgrade operation

feasible without any tools, or with tools that

are supplied with the product, or with

common general purpose tools

II. Product-specific tools (if needed):

Repair/upgrade operation feasible either

with no specific tools, or a finite list of

specific tools

III. Other commercially available tools (if

needed): Repair/upgrade operation feasible

without the use of proprietary tools

IV. Proprietary tools: Repair/upgrade process

feasible only with one or more proprietary

tools, which are not available to the general

public.

V. No tools: Repair/upgrade operation is

unfeasible with existing normally-available

tools

Favoured option for the study team


Visibility could be less relevant if

indicated in repair manuals

B) Semi-quantitative based on type, availability,

cost, and number of tools:

I. Maximum X types (e.g. 1, 2) of

standard/common tools are required

II. A limited number of tools are required,

some of which are expensive

III. Many different type of widely available

tools are required, and some of them are

expensive

IV. Special tools are required that are not easy

to obtain

V. Proprietary tools are required.





Score = Ti / Tmax

Where:

Tmax is the score corresponding to the


product (in terms of type, availability

and cost of tools)

Ti is the score corresponding to the




from 0 to 1

33



study team

4) Ease of access

to parts

A) See Parameters 1, 2 and 3 Although important, this parameter

is considered the sum of the

disassembly sequence, fastenings

and tools.

Time for disassembly could be an

alternative and overall indicator, as

described for parameter 1.

However, this could add significant

complications, possibly also in

terms of assessment and

verification.

B) Semi-quantitative based on design characteristics:

I. All the priority parts are easy to access

(quick access, few steps required)

II. All priority parts can be accessed and

require a limited number of steps/time

III. All priority parts can be accessed but some

of them require too many steps

IV. All priority parts can be accessed but it is

difficult to know how without instructions

due to the complexity of the product design

V. Some priority parts are not easy to access

because glue or other permanent assembly

methods are used

Risk of subjective classification


Score = Ai / Amax

Where:

Amax is the score corresponding to the


product (in terms of ease of

accessibility)

Ai is the score corresponding to the




from 0 to 1

5) Working

environment (e.g.

home,

professional

repair site,

manufacturing

plant)

A) Semi-quantitative based on conditions of work:

I. General environment: repair/upgrade can be

performed where the product is in use

without special conditions

I. Workshop environment: repair/upgrade

cannot be performed in the environment

where the product is in use but does not

require a production site environment

II. Production site environment: repair/upgrade

can only be carried out in an environment

that is comparable with the environment in

which the product was manufactured


since it is objective and practical.

B) Semi-quantitative based on type of repair/upgrade

process:

I. Repair/upgrade can be easily done at home

Alternative classification, that

includes elements that risk being

more subjective.

34



study team

II. Professional repair sites are required only

for the repair/upgrade of parts that involve

safety aspects

III. Professional repair sites are required for the

repair/upgrade of some priority parts

IV. Repair/upgrade of all priority parts can be

done only in the manufacturing plant

V. Repair/upgrade of parts can be done only in

the manufacturing plant


Score = WEi / WEmax

Where:

WEmax is the score corresponding to the


product (in terms of type of

environment)

WEi is the score corresponding to the




from 0 to 1

6) Level of skills

required to

undertake the

operations

A) Semi-quantitative based on skills required:

I. The repair/upgrade process can be carried

out by a person without any specific

experience or related qualifications

(layman)

II. The repair/upgrade process can be carried

out by a person with a general knowledge of

basic repair/upgrade techniques and safety

precautions (generalist, if needed).

III. The repair/upgrade process has to be carried

out by a person with specific training and/or

experience related to the product category

concerned (independent expert)

IV. The repair/upgrade process has to be carried

out by a person who is directly trained and

audited by the manufacturer (authorised

expert)

V. The repair/upgrade process has to be carried

out by the manufacturer

The repair/upgrade process is not feasible

with any existing skill


since it is objective and practical

B) Semi-quantitative based on skills required:

I. Reparable/upgradable by everyone with a

basic knowledge

II. Reparable/upgradable by everyone after

tutorial watching or documentation reading

III. Reparable/upgradable only for trained

specialists.

Alternative and simpler

classification

35



study team


Score = Si / Smax

Where:

Smax is the score corresponding to the


product (in terms of skills needed)

Si is the score corresponding to the




from 0 to 1

7) Provision of

diagnostic

support and

interfaces

A) Semi-quantitative based on type of diagnosis

interface:

I. Visually intuitive interface: a repair/upgrade

process that can be carried out by just a

visual interface that can be understood

without the need for any supporting

documentation or software

II. Coded interface with public reference table:

a repair/upgrade process that can only be

carried out with supporting documentation

or software, and through reading and/or

entering codes which are available in a

table, which is supplied with the product

and / or publicly available

III. Publicly available hardware / software

interface: a repair/upgrade process that can

only be carried out through the use of

hardware and software which is publicly

available (This can include hardware

functionality testing software tools

developed by a third party, provided the

software tools are publicly available and the

manufacturer provides information on their

accessibility and applicable updates. The

product can be equipped with an

appropriate interface for hardware and

software to do fault diagnosis and reading,

adjustment or resetting of parameters or

settings (e.g. external memory device; data

cable connection; or from a remote source

using a network connection). The port, slot,

or connector that is used for the hardware

and software interface is accessible without

tools)

IV. Proprietary interface: a repair/upgrade

process that can only be carried out using

proprietary tools for diagnosis, change of

settings or transfer of software, which are

not included with the product, that process

is categorised as needing a proprietary

interface

V. Not possible with any type of interface: a

repair/upgrade process that cannot be

carried out with any type of interface


since objective and practical

36



study team

B) Semi-quantitative based on type of diagnostic

equipment:

I. Only basic and common diagnostic

equipment is required (e.g., easily-

obtainable polymeters and similar)

II. Diagnostic equipment and interfaces are

standard/common and are required for a

limited type of reparations

III. Diagnostic equipment and interfaces are

standard/common but it is required for most

of the reparations

IV. Expensive (not special) diagnostic

equipment/interfaces required

Special/proprietary diagnostic equipment is required

Alternative classification but more

ambiguous/subjective

C) Semi-quantitative based on type of diagnosis

interface and manufacturer support:

I. Manufacturer support (e.g. website,

troubleshooting FAQ, help line) available,

and repair/upgrade can be carried out with

the use of hardware and software which is

publicly available

II. Repair/upgrade can be carried out with the

use of hardware and software which is

publicly available

III. Repair/upgrade can be carried out through

the use of hardware and software which is

proprietary

IV. No diagnosis interface nor support

Alternative classification including

also manufacturer support


Score = DIi / DImax

Where:

DImax is the score corresponding to the


product (in terms of intuitiveness and

accessibility of interface and support

tools required)

DIi is the score corresponding to the




from 0 to 1

8) Availability of

spare parts

A) Semi-quantitative based on the availability of

spare parts to target groups:

I. Spare parts are publicly available to all

interested parties

II. Spare parts are available at least to

independent repair service providers

III. Spare parts are available at least to

manufacturer-authorised repair services

IV. Spare parts are available to the

manufacturer only



Also time considerations can be

integrated

37



study team

V. No spare parts are available

B) Semi-quantitative based on the availability over

time of spare parts:

I. The required spare part(s) is/are available

for a duration of time post-manufacture that

reflects the expected maximum useful life

of the product (long-term).

II. The required spare part(s) is/are available

for a duration of time that reflects the

expected average useful life of the product

(mid-term)

III. The required spare part(s) is/are available

for 2 years after the time of sale of the

product (short-term)

IV. The required spare part(s) is/are available at

the time of sale, but the duration of

availability cannot be determined.

Complementary, if not integrated.

C) Semi-quantitative based on the availability of

spare parts, including also time and cost

considerations:

I. Spare parts are available for 10 years or

more, and price is reasonable compared to

the product price

II. Spare parts are available for 5-9 years, and

price is reasonable compared to the product

price

III. Spare parts are available for less than 5

years, and price is expensive compared to

the product price

IV. Spare parts are available only for priority

parts

V. Spare parts are not available


complete but with risk to be

subjective.

D Percentile score within known spread:

Score = TGi / TGmax x Di / Dmax

Where,

TGmax is the score corresponding to the


product (in terms of target group)

TGi is the performance of the product

(in terms of target group)

Dmax is the score corresponding to the


product (in terms of availability of

spare parts)

Di is the score corresponding to the

class of the analysed product (in terms

of availability of spare parts)



from 0 to 1

9) Availability

and ease of

installation of

A) See parameter 8 Favoured option

38



study team

software and

firmware

B) Semi-quantitative based on the availability of

software/firmware for a certain time and cost:

I. Software/Firmware updates are periodically

available; bug/vulnerability fixing is free of

charge for 5 years or more. Upgrades for

improvements have a reasonable price or

are free of charge.

II. Software/Firmware updates are periodically

available; bug/vulnerability fixing is free of

charge for 5 years or more. Upgrades for

improvements are expensive.

Software/Firmware updates are periodically

available, bug/vulnerability fixing is free of

charge for 5 years or more

III. Software/Firmware support is offered free

of charge for critical bugs/vulnerabilities

only and for less than 3 years

IV. Software/firmware support is not offered

Alternative option

C) Semi-quantitative based on the availability of

information to target groups:

I. Software and firmware is publicly available

to all interested parties

II. Software and firmware is available only to

authorized experts and manufacturers

Possibility to differentiate between

software and firmware offered 'free

of charge' vs. 'at a cost' and

between automatic download from

the internet vs. multi-step

procurement process


Score = Ti / Tmax

Where,

Tmax is the score corresponding to the


product (in terms of type, availability

and cost of tools)

Ti is the score corresponding to the




from 0 to 1

10) Availability

of information

(e.g. repair and/or

upgrade manuals,

exploded

diagrams)

A) Semi-quantitative based on comprehensiveness of

available information:

I. Complete information available: A repair,

reuse or upgrade process, for which all

relevant information is available. Complete

information may include circuit board

schematics of electronic parts, functional

specification of parts (e.g. resistance value

of resistors, viscosity grade of lubricants)

and information on compatibility of parts

with other products.

II. Comprehensive information available: A

repair, reuse or upgrade process, for which

not all relevant information is available as

described above, but for which reasonably

comprehensive information is available.

Comprehensive information may include

step-by-step disassembly instructions with



Also target group considerations

can be integrated

39



study team

identification of tools needed,

recommended torque for fasteners,

diagnostic and error resetting codes, testing

procedures, reference values for

measurements

III. Basic information available: A repair, reuse

or upgrade process, for which complete or

comprehensive information is not available

as described above, but for which some

information is available. Basic information

may include product identification,

instructions for regular maintenance, an

overview of repair or upgrade services

offered by the manufacturer,

troubleshooting charts, a list of available

updates, an exploded view and spare parts

list.

IV. No information available: A repair, reuse or

upgrade process, for which no relevant

information is available.

Alternative:

I. automatic troubleshooting and provision of

any information that might be relevant for

the specific problem/reparation/upgrade via

an app, download link or the like AND

access to chat/phone support with employee

II. online availability of repair and upgrade

manuals by search on the product/model

number

III. only provision of legally defined material

and nothing more

B) Semi-quantitative based on target group:

I. Publicly available: A repair/upgrade process

for which the relevant information

(comprehensive or complete information to

facilitate repair/upgrade, as relevant) is

available to all interested parties.

II. Available to independent repair service

providers: A repair/upgrade process for

which the relevant information (the

procedure by which each target group can

obtain the relevant information, including

any fees related to the access to the

information concerned) is not publicly

available as described above, but is

available to any self-employed professional,

as well as any legally established

organisation, providing repair services

(Channels for communicating information

to independent service providers may

include printed manuals, password-

protected websites and digital information

carriers such as DVDs or flash drives)

III. Available to manufacturer-authorised repair

service providers: A repair/upgrade process

for which the relevant information (the

procedure by which each target group can

Complementary, if not integrated.

Information is considered to be

available to a target group must

also consider the unequivocal

identification of the product and of

the information available for that

product, based on the commercial

product name.

40



study team

obtain the relevant information, including

any fees related to the access to the

information concerned) is not available to

the general public or to independent repair

service providers as described above, but is

available to service providers authorised by

the product manufacturer to offer repair

services.

IV. Available to the manufacturer only: A

repair, reuse or upgrade process, for which

the relevant information (the price for repair

or upgrade by the manufacturer of the part,

for which information availability is

assessed) is not available to the general

public or to independent or authorised

repair service providers as described above,

but is available to the product manufacturer.

Alternative:

I. Repair/upgrade information is publicly

available to all interested parties

II. Repair/upgrade information is available to

independent repair service providers

III. Repair/upgrade information is available

only to manufacturer-authorised repair

services

IV. Repair/upgrade information is available

after the payment of a fee

V. Repair/upgrade information is not available


Score = TGi / TGmax x Ci / Cmax

Where,

TGmax is the score corresponding to the


product (in terms of target group)

TGi is the score corresponding to the

class of the analysed product (in terms

of target group)



product (in terms of

comprehensiveness of information)

Di is the performance of the product (in

terms of comprehensiveness of

information)



from 0 to 1

Others

11) Guarantee

issues

A) Semi-quantitative based on the 'commercial

guarantee/ extended warranty' offered by

manufacturers/retailers, for example with repair

being the first option of remedy (e.g. 'commitment to

This parameter can be seen as a

possibly relevant 'proxy indicator'

for the reparability or the

durability/quality of products.

41



study team

free repair')

I. More than 6 years of commercial guarantee

offered as included in the price of the

product.

II. 5 years of commercial guarantee offered as

included in the price of the product

III. 4 years of commercial guarantee offered as


IV. 3 years of commercial guarantee offered as


V. No commercial guarantee available

Further discussion is needed, in

particular with respect to its

evaluation options and to the

reference to entire product or

specific parts (e.g. the motor of a

washing machine).

B) Semi-quantitative based on the possibility of

repair by non-authorised repairers

I. Repair by non-authorised repairers will not

affect the warranty of the product

II. Repair by non-authorised repairers will void

the warranty of the product

Based on repairability.org, more

critical than the option above.


Score = Gi / Gmax

Where,

Gmax is the score corresponding to the


product (in terms of guarantee)

Gi is the score corresponding to the




from 0 to 1

12) Return

models

A) semi-quantitative based on return models offered

by the manufacturer to facilitate repair:

I. Lease, product as a service: A

repair/upgrade process, for a product which

is sold as a subscription model (a service is

sold instead of a product.) The customer

does not own the product, and instead it

remains property of the manufacturer. For

the repair, reuse or upgrade process it is

sent back to a location designated by the

manufacturer.

II. Advanced replacement scheme: A

repair/upgrade process, for which there is a

service contract between customer and

manufacturer in which an advanced

replacement scheme is applied. The

manufacturer commits to collect the

defective product and replace it

immediately with a

new/remanufactured/repaired unit. The

defective product is sent to a location

designated by the manufacturer for repair

after which it can be used again for advance

This parameter and the related

classification/rating can be relevant

for all products.

42



study team

replacement for another customer.

III. Mail-back program: A repair/upgrade

process, for which the manufacturer offers a

program whereby the user posts the product

to a location designated by the

manufacturer.

IV. User delivers product: A repair/upgrade

process, for which the user drops product

off at local repair facility or at a collection

point of a local shop from where product is

shipped to a repair facility.

V. No return model: A repair/upgrade process,

for which no collection is organised.

Product repair is left up to the owner.

B) Percentile score within known spread:

Score = RMi / RMmax

Where:

RMmax is the score corresponding to the


product (in terms of return model)

TGi is the score corresponding to the


Normalisation of above approach


from 0 to 1

13) Data transfer

and deletion

A) semi-quantitative based on availability of data

transfer and deletion functionality:

I. Built in: built-in secure data transfer and

deletion functionality is available to support

the deletion of all data contained in data

storage parts (i.e. hard drives and solid state

drives) in function of the risks faced and in

order to grant the security of personal data

and to facilitate the reuse of these parts.

II. On request: secure data transfer and

deletion is available under request to

support the deletion of all data contained in

data storage parts (i.e. hard drives and solid

state drives) in function of the risks faced

and in order to grant the security of personal

data and to facilitate the reuse of these

parts.

III. Not available: A reuse process, for which

secure data transfer and deletion is not

available


Score = Di / Dmax

Where:



product (in terms of data transfer and

This parameter and the related

classification/rating, proposed by

stakeholders, can be relevant for

ICT products.

43



study team

deletion)

Di is the score corresponding to the


14) Safety issues A) semi-quantitative based on the risks associated

with repair operations:

I. There are no injury risks involved in the

repair of the product

II. There is some risk of injury during the

repair process, so that the repair cannot be

undertaken by the consumer

III. There is a high risk of injury during the

repair process, so that the repair cannot be

undertaken by non-authorised repairers.

Consideration of this parameter

proposed by stakeholders.

Classification inspired by

repairability.org. However, it can

be merged with parameter 5, unless

other specific points are raised.

15) Availability

of OEM qualified

service engineers

A) Semi-quantitative based on the availability of

OEM qualified service engineers:

I. The manufacturer provides support of OEM

qualified service engineers during the

warranty period

II. The manufacturer provides support of OEM

qualified service engineers at any time

III. The manufacturer does not provide support

of OEM qualified service engineers

This parameter, proposed by

stakeholders, can be relevant, alone

or integrate in other parameters.


Score = ORi / ORmax

Where:

ORmax is the score corresponding to the


product (in terms of availability of

OEM qualified service engineers)

ORi is the score corresponding to the




from 0 to 1

16) Ease of

restoring to full

working

condition after

repair

A) Semi-quantitative based on the ease of restoring

the product to working condition post-repair:

I. The product functions as before, with no or

minimal loss of quality and aesthetics

II. The product functions as before, however

there is some loss of quality and/or

aesthetics

III. The product does not function as before

Consideration of this parameter

proposed by stakeholders.

Classification inspired by

repairability.org (although

subjective)


Score = Ri / Rmax

Where:

Rmax is the score corresponding to the


product (in terms of ease of restoring to



from 0 to 1

44



study team

working conditions)

Ri is the score corresponding to the


(a) To be tailored to specific product group(s) and referred to priority part(s) 630

(b) A score can be assigned to each class and for each parameter. However, for some parameters it could be 631 more relevant to have minimum pass/fail requirements or reporting on the underlying information (e.g. 'spare 632 parts available for X years'). 633

45

2.3.2 Aggregation of individual parameters 634

The reparability and upgradability of products could be reported either with respect to one or more 635

individual parameters (e.g. type of tools needed vs. the whole set of parameters) and either in an 636

isolated or aggregated form (i.e. as the scores for individual parameters, or as combined scores for a 637

set of parameters). Stakeholders were asked to provide their views on different levels of aggregation; 638

their input is compiled in Table 7. 639

640

Table 7 Technical considerations about aggregation levels for the scoring system – responses from stakeholders 641

Options Technical considerations

Only a limited number of individual

parameters (e.g. the 3-4 most

relevant ones) are considered and

reported separately

More than half of respondents to the initial questionnaire

expressed some concerns over covering only a limited

number of parameters, because:

This would not be sufficient to evaluate the

reparability of products.

A restricted list of parameters may result in

optimisation of the assessed parameters at the

expense of others, leading to repair-unfriendly

scenarios (despite the good rating of the assessed

parameters).

Less than half of respondents instead favoured focusing on a

limited number of parameters separately, which would ensure

transparency.

However, the relevant issue is whether the product is

reparable or not. Separate information might not be easy to

understand by consumers, whilst aggregated information

could be less valuable.

A possible solution to this issue could be to rate parameters

separately, and then to aggregate them into an overall score.

This would be important to ensure that key information is not

lost, and that the process is transparent. Information could be

either provided in a label or in a data sheet.

All relevant parameters related to

product design (e.g. disassembly

sequence and tools needed) are

aggregated into one index

More than a half of respondents to the initial questionnaire

expressed some concerns over the aggregation of product-

design parameters into one index, because:

It would imply implicit value choices or judgements

in the evaluation. Moreover, it could allow trade-offs

across parameters, so that a 'good' rating could be

achieved at the expense of other important aspects.

It could result in loss of information, and it should be

checked, for instance via appropriate assessment

methods with consumers, if the delivered message is

sufficiently well understood.

All relevant parameters related to the

repair service support (e.g. spare

parts and information availability)

are aggregated into one index


expressed some concerns over the aggregation of parameters

related to the repair service support into one index, because:



46

Options Technical considerations




checked, for instance through consumer assessment

methods if the delivered message is understood.

Less than half of respondents were favourable to this

approach, which could integrate aspects such as: support

offered by OEM, availability and delivery time of spare parts.

The approach could be complemented by the provision of

separate additional information (e.g. 'X' years of spare parts

availability).

All relevant parameters related to

design characteristics are aggregated

into one index, and all relevant

parameters related to operation

characteristics are aggregated into

another index


expressed some concerns over the aggregation of parameters

related to product design, and to the repair service support

into two indices, because:








Less than half of respondents instead favoured showing two

indices. This could be complemented by the provision of


availability).

All relevant parameters are

aggregated into one overall index

About half of respondents to the initial questionnaire

expressed some concerns over the aggregation of all relevant

parameters into one index, because:








Less than half of respondents instead favoured showing two

indices. This could be complemented by the provision of


availability).

642

If aggregation of scores were actively proposed, most respondents to the initial questionnaire 643

considered that different parameters should have different weights. Weighting should reflect the 644

importance of each parameter for the repair/ upgrade operation. 645

Some stakeholders suggested that the highest weight should be assigned to the availability of parts. 646

Tools and information (including software) were in general considered by stakeholders as more 647

47

important than disassembly sequences, type of fasteners, working environment, skills, and diagnostic 648

support. Visibility of fasteners was also considered more important than the type of fastener. 649

However, weighting implies implicit value choices or judgements between parameters which could 650

change depending on the industry sector concerned and on the product considered (B2B vs. B2C). 651

It was also suggested by some stakeholders that weighting could be combined with 'pass/fail' 652

requirements for some parameters. For instance, disassembly sequence only becomes relevant if a 653

certain pass threshold is reached. 654

Indications provided by stakeholders did not conclusively converge to one widely supported option, 655

since they identified pros and cons are for each alternative analysed. However, also on the basis of the 656

analysis of the comments received from stakeholders, the scoring framework could be shaped as 657

follows: 658

1. A selection of relevant parameters for a certain product group is made; 659

2. Minimum requirements for the product group are set (to ensure reparability/upgradability of 660

the product), as well scoring requirements 661

3. Scoring requirements are weighted and aggregated into a single index to differentiate between 662

different product options 663

4. Details of individual parameters are provided for transparency reasons. 664

665

2.3.3 Reporting options to assess products 666

Reporting of the final score can be carried out with different methods/scales. Table 8 includes options 667

proposed for discussion with stakeholders, as well opinions collected about the suitability of each 668

option. 669

670 Table 8 Technical considerations regarding scales for reporting the final score – responses from stakeholders 671

Scale for

reporting

Suitability (*) Technical considerations

Binary (pass/fail) In general 'Low'

(1.1 out of 3 as

average)

In general, stakeholders consider that a pass/fail approach

could be too simple and might not allow the assessment of

the degree of reparability/upgradability of products and

differentiating between them. Nevertheless, some separate

binary criteria could be integrated into a scoring system.

On the other side, other stakeholders think that this could

be a realistic approach, since consumers might be not

interested in knowing a percentage of chance, but could

rather prefer a commitment from manufacturers (for

instance, that products will be repaired at a maximum cost

for a given period).

Traffic lights In general 'Low'(1

out of 3 as average)

In general, stakeholders consider that traffic light symbols

could be easy to understand. However, they might not

facilitate a sufficient differentiation between products.

0-to-5 stars In general

'Medium'/'High' (2

out of 3 as average)

In general, stakeholders consider that this kind of grading

could be useful to differentiate between products in an

intuitive way.

Other symbols (e.g. spanners/ wrenches) might be more

suitable to use for this purpose rather than stars.

Alphabetic (A, B,

C, D, E, F, G)

In general 'Medium'

(1.4 out of 3 as

In general, this approach raised split views from

stakeholders:

48

Scale for

reporting

Suitability (*) Technical considerations

average) On the one hand there are those who think that

aligning with a similar approach to that used in the

EU Energy Labelling scheme would be good

On the other hand, there are those who consider

that this could be confusing.

Decimal number

between 0-1 (or a

number between

0-10 or 0-100)

In general

'Medium'/'High'

(1.9 out of 3 as

average)

In general, stakeholders consider this kind of grading as

the most understandable system to differentiate between

products.

The scale could be from 0 to 10. Numerical scores could

also be represented as bar charts.

However, there is the risk that this option is too detailed

and uncertain. For instance, a small difference in score

between two products may not correspond to a noticeable/

reliable difference in reality.

(*) Based on the analysis of the feedback received from stakeholders (for all options answers to the 672

initial questionnaire ranged from 'No' to 'Low', 'Medium' or 'High') 673

674

2.4 Summary 675

A comprehensive list of parameters that could be used to assess the repair and upgrade of products is 676

shown in Table 9. The list consists of both 1) the initial parameters included for discussion in the 677

initial questionnaire, and 2) additional parameters which were considered relevant for discussion by 678

the study team. 679

Based on the elements gathered so far, some parameters could be excluded: 680

Working environment seems to be less relevant for repair and upgrade compared to other 681

parameters. This parameter is neither related to product design nor to the provision of 682

information or a service by the manufacturer. For the majority of stakeholders who responded 683

to the initial questionnaire, this parameter would not have a direct influence in the 684

repair/upgrade of products. 685

The ease of access to parts appears as a highly relevant parameter. However, the feedback 686

received from stakeholders seems to point out that this parameter may not be simple, or easy 687

to assess and verify. Moreover, it can be indirectly addressed through other parameters like 688

disassembly sequence, tools needed and the type, number and visibility of fasteners. 689

Safety issues, such as the specific aspect of the working environment concerned, and because 690

of the difficulties associated to the assessment of this parameter. 691

Ease of restoring to working condition after repair, because of the difficulties associated to the 692

assessment of this parameter. 693

In terms of assessment and verification, different options of classification and rating are proposed in 694

Table 6. The study team supports a classification and scoring that is kept as much as possible adherent 695

to the discussion held in the development of prEN 45554. This generally corresponds to the options 696

with the nomenclature of 'A' as shown in Table 6 previously, and the related normalisation 697

approaches. Moreover, classification and rating options should be: 698

1. Tailored to specific product group(s) and related priority part(s) and not be biased towards 699

particular repair business models 700

2. Measurable and enforceable, via: 701

49

- Limiting the presence of value choices or judgements and 702

- Avoiding both the risk of resulting in different interpretations depending on who is 703

doing the evaluation and possible trade-offs (e.g. a highly durable product may be 704

less repairable). 705

Identification of priority parts needs to be made on a product-by-product basis, and must take into 706

account specific aspects for that product, such as the frequency of failure/upgrade, functional 707

importance and price of parts. Discussion and agreement with manufacturers, repairers and other 708

relevant experts is needed. 709

With respect to the possible aggregation of individual parameters, three main options were identified, 710

on the basis of the analysis of the comments received from stakeholders: 711

1. A binary system based on a selection of pass/fail requirements, indicating if the product is 712

reparable or not 713

2. A scoring framework based on a selection of scoring requirements, indicating to what extent/ 714

how much a product is reparable and allowing trade-offs between requirements 715

3. A hybrid system composed of both minimum and scoring requirements. 716

Preliminary indications gathered about the possible reporting options seem to suggest that overall the 717

reparability/upgradability of products should be differentiated based on 5-10 classes. 718

719

50

Table 9 Summary table regarding the selection, assessment and verification of individual parameters to be considered for the scoring framework 720

Parameter Relative importance/ Ranking (a)

Preliminary considerations for

the parameter selection

Min/Score requirement (b)

Reparability Upgradability

1. Disassembly sequence #3 #8 Yes To be discussed

2. Type, number and visibility of fastenings and connectors #7 #6 Yes To be discussed

3. Tools needed (availability, complexity, cost) #8 #3 Yes To be discussed

4. Ease of access to parts #2 #2 Difficult to define and assess

Addressed with other parameters

Proposed to be

DISCARDED (to be

discussed)

5. Working environment (e.g. home, professional repair site,

manufacturing plant)

#10 #10 Less relevant Proposed to be

DISCARDED (to be

discussed)

6. Level of skills required to undertake the operations #9 #7 Yes To be discussed

7. Provision of diagnostic support and interfaces #5 #9 Yes To be discussed

8. Availability of spare parts #1 #5 Yes To be discussed

9. Availability and ease of installation of software and

firmware

#6 #1 Yes, possible merging with

parameter 8

To be discussed

10. Availability of information (e.g. repair and/or upgrade

manuals, exploded diagrams)

#4 #4 Yes To be discussed

11. Guarantee issues NA NA Yes To be discussed

12. Return models NA NA Yes To be discussed

13. Data transfer and deletion NA NA Yes To be discussed

14. Safety issues NA NA No (see parameter 5) Proposed to be

DISCARDED (to be

discussed)

15. Availability of OEM qualified service engineers. NA NA Yes To be discussed

16. Ease of restoring to working condition after repair. NA NA Challenges for evaluation Proposed to be

DISCARDED (to be

discussed) (a)

Indications about the relative weight of each parameter are shown in Table 2 721 (b)

Assessment and verification options: see options under the heading of 'A', plus normalisation options, as discussed in Table 6 722

723

51

2.5 Questions for stakeholders 724

Q1. Which of the following options is technically preferable? Please explain why, and provide any

further indications on how you would implement it.

1. Binary system based on a selection of pass/fail requirements, indicating if the product is

reparable or not

2. Scoring framework based on a selection of scoring requirements, indicating how much a

product is reparable and allowing trade-offs between requirements

3. Hybrid system composed of both minimum and scoring requirements

4. Others

Answer

Q2. Among those discussed in this document, which parameters should be explicitly excluded from

the scoring framework? Please explain why.

Answer

Q3. Which parameters should be necessarily included in the scoring framework? Please explain why.

Answer

Q4. What should be the relative importance of each of the parameters that you would consider in the

scoring framework? Please explain why.

Answer

Q5. Which parameters should be considered as minimum requirements? How should they be assessed

and verified? Please provide explanations and details.

Answer

Q6. Which parameters should be rated? Which classification and rating criteria would you apply?

Please provide explanations and details.

Answer

Q7. Could you please provide indications to follow for the identification of priority parts (for a

specific product group)? Please provide explanations and details about the proposed

methodology/ideas.

Answer

725

52

3 PRODUCT-SPECIFIC CONSIDERATIONS 726

3.1 Attractive conditions for repair and upgrade for macro-categories of products 727

Because each product has its own characteristics and peculiarities, they should be, in so far as it is 728

applicable, assessed at an individual level. Nevertheless, there are some aspects influencing the repair 729

and upgrade operations that could allow a classification of products according to certain 730

characteristics, as for example their size. 731

For the purpose of describing generic aspects influencing the repair and upgrade of products 732

according to such characteristics, an initial classification of products was proposed as defined below: 733

a) Small appliances (e.g. vacuum cleaners, kettles, coffee machines, handheld drills, hair-734

dryers): goods which can be easily transported to a repair shop and which are generally 735

perceived as less sophisticated by consumers attempting to repair them; 736

b) Medium/large appliances (e.g. washing machines, dishwashers, refrigerators, freezers, 737

cookers): goods for which a trained technician might normally come to your home to repair 738

the product or you would have to make a dedicated logistics effort to transport them to be 739

repaired; 740

c) Installed products (e.g. a boiler or heat pump, or air conditioning appliances): goods for which 741

a trained technician would normally be required to come out to examine the products, and 742

where the product repair is normally related to and interacts with the environment in which it 743

is placed; 744

d) Electronic products (e.g. imaging equipment, DVD players, mobile phones, tablets, personal 745

computers, laptops): goods with a faster innovation cycle compared to the former categories 746

and a size allowing a relatively easy displacement of the device for repair/upgrade. 747

Respondents to the initial questionnaire pointed out that: 748

Although categorisation of products into families may seem logical, there is a sensible 749

variation of function, performance and complexity between products and models of the same 750

type. Reparability and upgradability is product specific. 751

Apart from the size, also complexity is an aspect that should be considered for the 752

classification of small appliances. 753

Personal computers and laptops (but also tablets and servers) are the most modular products. 754

Hard drives and memories have standardised interfaces and can be upgraded in many cases. 755

TVs and DVD players are very different and not modular at all. Electronic products should be 756

split at least into 3 sub-groups: d1) Small & portable ICT products like smartphones, d2) 757

Medium sized ICT products like desktop computers, d3) Large or installed ICT products like 758

servers. 759

There are some fuzzy areas. For instance: 760

- with the increasing diffusion of connected devices ('internet of things'), it is likely 761

that category (a) overlaps with category (d) and that some aspects apply to both (e.g. 762

the availability of software updates) 763

- products as DVD players could also belong to group a) 764

- products such as large TVs could belong also to group b). 765

Consumables, such as ink cartridges for printers, are missing. 766

Stakeholders were asked to define a series of scenarios/conditions under which the repair and upgrade 767

operations would be more favourable, or more likely to happen. The input from stakeholders has been 768

collated and is shown in Table 10 (Repair) and Table 11 (Upgrade), respectively. 769

53

Table 10 Conditions that could make repair attractive from a consumers-targeted perspective 770

Aspect Small appliances Medium/Large appliances Installed products Electronic products

Maximum cost of repair

which would make it

attractive, expressed as % of

the product's purchase price

In the range of 15-40%,

although it depends highly on

the product and its

technological development.

Repair could be less

attractive for this product

category because of the

relatively low price of new

products.

In the range 15-40% In the range 15-40% In general up to 30%,

however repair cost threshold

is a function of different

aspects motivating the repair

decision (e.g. functional

needs, emotional

attachment).

Minimum lifetime

expectancy for the product at

the time of purchase, which

would make repair attractive

(in years)

From 5 to 10 years,

depending on the product.

Due to the lower

attractiveness of repair for

this product category,

warranty coverage is

considered more important.

From 8 to 15 years,


From 10 to 20 years,

depending on the product

From 5 to 7 years depending

on the product.

Maximum time of repair,

including delivery of spare

parts, which would make it

attractive (in weeks)

In general, 1 week max.

However this could rise up to

2-10 weeks for some

stakeholders. Availability of

spare parts is crucial.

In general 1-2 weeks max.

In case the product is

difficult to replace a larger

period can be accepted by the

consumer. Availability of

spare parts is crucial.

In a wide range (few days – 2

weeks).

In case the product is

difficult to replace a larger

period can be accepted by the

consumer.

In a wide range (few days – 2

weeks)

Maximum acceptable time

for repair is highly subjective

and depends on the

customers’ emotional and

functional reliance or needs.

Important to provide

temporary devices to replace

the absence of the product

during the time of repair.

Other comments For all products also the following aspects are highlighted as relevant:

54


Cultural aspects and habits (i.e. what consumers use to do when a product breaks or becomes functionally obsolete)

The availability of an effective service network of trained professionals (either service engineers of the manufacturer

or independent authorised and qualified professionals). This leads to proximity and quality, which contributes

positively to the repair decision.

The ease of access to a repair shop is considered more relevant for small appliances. No matter how cheap the repair

is, many consumers might be willing to pay for new products solely due to the inconvenience of taking it to a

repair/service location.

771

Table 11 Conditions that could make upgrade attractive from a consumers-targeted perspective 772


Maximum cost of upgrade which

would make it appealing (free of

charge, or expressed as % of the

product's purchase price)

Range of costs reported

from 5% to 25% of the

product's purchase cost.

High dependent on the

product type and upgrade

benefits.

Range of costs reported from

5% to 25% of the product's

purchase cost.

High dependent on the

product type and upgrade

benefits.


from 10% to 25%.

Due to the difficulty of

new installation,

upgrading might be more

attractive than for other

product groups.


from 0% to 20%. Free of

charge when linked to

software or firmware

upgrade (bug fixes or

vulnerabilities).

Hardware upgrade

reported in the range of

10-20% of the product's

purchase price.

Minimum lifetime expectancy for the

product, at the time of purchase, which

would make upgrade attractive (in

years)

From 5 to 10 years,

depending on the

product.

From 7 to 15 years,


From 10 to 20 years,

depending on the product

From 5 to 7 years in

general.

Maximum time of upgrade, including

delivery of new parts/functions, which

would make it attractive (in weeks)

From 1 week to 5 weeks.

This is considered a less

critical point from the

point of view of the

consumer, as the

appliance is still

Highly dependent on

product.


critical point from the point

of view of the consumer, as

the appliance is still

Highly dependent on

product.


critical point from the

point of view of the

consumer, as the

From 1 day to 1 week is

reported as maximum time

of upgrade.

Also in this case time is

considered a less critical

aspect.

55


functional. functional. appliance is still

functional.

Other comments For upgradability it is more difficult to find objective conditions. There can be significant variations also between

products of the same product category, depending on the complexity of their design.

773

56

3.2 Aspects and needs for a product-specific 774

scoring system 775

The scoring framework discussed in Section 2 is planned to be adapted to three product groups: 776

laptops, vacuum cleaners and washing machines. The generic scoring framework thus needs to be 777

tailored to the specific characteristic of each product group. Preliminary information about the 778

analysed product groups have been gathered from stakeholders and shown in Table 12 and Table 13. 779

780

Table 12 Specific aspects influencing reparability and upgradeability of laptops, vacuum cleaners and washing 781 machines – Summary of the responses from stakeholders 782

Product Specific aspects influencing reparability Specific aspects influencing

upgradability

Laptops Ease of access, disassembly and

substitution. In particular,

application of glues and soldering

can make a laptop less reparable.

Connections should thus be

removable to avoid any damage.

Target parts for this aspect are

battery, keypads, SSD.

Manufacturer support: online

availability of troubleshooting

guidelines, overview and pricing

of repair options, availability of

direct repair services (or

authorized and trained by the

manufacturer)

Software / firmware availability

and data deletion in the case of

refurbishment / resale

Interoperability of chargers and

battery has been also pointed as an

important aspect for reparability,

which could be improved through

the use of standardised interfaces

Software upgradability, and cost

and availability of software

upgrades

Software upgrade should not

negatively impact the performance

of the laptop (e.g. slowing down its

performance). A trial should be

offered to verify the impacts of

software upgrade a rollback should

be possible.

Regarding the hardware, same

aspects presented for reparability

are pointed out. Hard drives and

memory (RAM) are considered the

most relevant parts.

Software availability and hardware

upgradability are particularly

important when the performance is

below a certain threshold (e.g. 4GB

for the RAM).

Interoperability of chargers and

battery has been also pointed as an

important aspect for upgradability,

which could be improved through

the use of standardised interfaces

Vacuum

cleaners Ease of access, disassembly and

substitution of parts

Availability and cost of spare

parts

Interoperability and standardised

sizes of components (e.g. tubes,

nozzles, dust bags and filters)

Complexity and safety of the

product

Software/firmware upgradability

for robot vacuum cleaner.

In general not considered very

relevant for this product group

Washing

machines Design of crucial parts such as the

drum vs. cost of others parts, e.g.,

Modularity / standardisation of

interface

57

Product Specific aspects influencing reparability Specific aspects influencing

upgradability

control panel

Availability of diagnostic

tools/interfaces to target groups

Availability of technical service

via web

Cost of repair vs. cost of new

product

Time of repair

Availability and cost of spare

parts

Cross-compatibility of parts

between different models or

brands

Easy positioning and replacement

of parts with common tools

Availability of information about

maintenance and repair (e.g.

exploded diagrams)

Easy connection to apps for

software update



783

Table 13 Specific issues and needs to take into account when assessing reparability and upgradability of laptops, 784 vacuum cleaners and washing machines – Summary of the responses from stakeholders 785

Product Specific needs for assessing reparability Specific needs for assessing

upgradability

Laptops Priority parts should include at least

the battery. Whether a battery is

accessible without opening the

casing/laptop should be the most

important criterion (for which there

should be no possibility of trade-off).

The design of weak points (subject to

wear) like screen hinges, surfaces

around keyboard and back of screen

is crucial for the perceived

obsolescence and therefore for the

attractiveness of the reparation for the

costumers.

Modularity of the laptop

Most effective strategies:

- to regulate the maximum repair cost

within the warranty

- to regulate an increased warranty

time

- to ensure the achievement of the

Ease of access to internal parts (e.g.

bios, battery, fan, HDD, RAM).

Whether hard drive and RAM are

accessible without opening the laptop

should be the most important criterion

(for which there should be no

possibility of trade-off).

Compatibility with other ICT products

connected to the laptops (e.g. printers

need to have drivers which can be

supported or not in upgraded laptops)

Amount of expansion slots

Level of skills required for the

operation

Most users expect a problem-free

software upgrade for at the most a

couple of years above the warranty

time. However, the operating system is

often out of the control of the

manufacturer of the laptop.

58

Product Specific needs for assessing reparability Specific needs for assessing

upgradability

collection rate targets

Additional strategies for reparability:

- no extra tools needed for the

removal of components;

- no fixed gluing;

- labels linked to the web (e.g.

through QR codes).

See strategies reported on the left.

Vacuum

cleaners Priority parts should include at least

motor and hose. For robot vacuums,

priority parts should also include

software/firmware.

Relevant parameters of assessment

should include: availability of

information; ease of access to internal

parts (motor, PCB, and cable); tools

needed; visibility of screws;

availability and price of spare parts

Product and consumer safety must

always be ensured. The repair of

products needs appropriate technical

skills that most consumers do not

have

Upgrade is less likely for this product

group, with the exception of robot

vacuum cleaners, for which priority

parts should include software/firmware.

Washing

machines Priority parts assessed should include:

electronic control and user interface

boards; motors; pumps; shock

absorbers; drum/ball bearings;

heaters; door hinges; drum spiders

and seals

Availability and cost of spare parts is

considered important, as well as the

steps and the tools needed to

disassemble them.

The three lethal faults for washing

machines are reported to be: 1) the

high price of the control panel, 2) the

full replacement of the motor instead

of the brushes; 3) the difficulty to

replace and repair shaft and bearings.

Product and consumer safety have

always to be ensured. Professional

repair will be mostly required for

washing machines.



786

59


Q1. Which are the main repair/upgrade operations applied to laptops and the related priority parts?

Please explain why.

Answer

Q2. Which parameters should be taken into account for assessing the reparability/upgradability of

laptops? How they should be tailored (in terms of minimum requirements, classes and rating) for

assessing the reparability/upgradability of this product group? Please explain why; you can use

Section 2.4 as reference.

Answer

Q3. How should the parameters for laptops be aggregated? Please explain why; you can use Section

2.4 as reference.

Answer

Q4. Which are the main repair/upgrade operations applied to vacuum cleaners and the related priority

parts? Please explain why.

Answer


vacuum cleaners? How they should be tailored (in terms of minimum requirements, classes and

rating) for assessing the reparability/upgradability of this product group? Please explain why; you can

use Section 2.4 as reference.

Answer

Q6. How should the parameters for vacuum cleaners be aggregated? Please explain why; you can use

Section 2.4 as reference.

Answer

Q7. Which are the main repair/upgrade operations applied to washing machines and the related

priority parts? Please explain why.

Answer


washing machines? How they should be tailored (in terms of minimum requirements, classes and

rating) for assessing the reparability/upgradability of this product group? Please explain why; you can


Answer

Q9. How should the parameters for washing machines be aggregated? Please explain why; you can


Answer

60

788

61

4 ADDITIONAL POINTS TO CONSIDER 789

This section compiles the comments received from stakeholders, which reflect their general opinions 790

regarding a scoring system for assessing the reparability and upgradability of products and its possible 791

policy implications at EU level. 792

793

4.1 Reparability and upgradeability vs. durability of products 794

Some stakeholders indicated that an overarching analysis would be needed to assess and discuss on 795

advantages and drawbacks associated to different options (including a scoring system for assessing 796

reparability and upgradability of products) allowing the provision of durability-related information to 797

consumers. It was also pointed out that reliability and durability could have higher importance in the 798

circular economy than reparability and upgradeability. 799

800

4.2 Link to policy framework and standardisation 801

According to some industry stakeholders, the necessary services to ensure the proper and safe repair 802

of products are already available on the market. Repair is part of brands after-sales strategies and a 803

way for companies to compete to offer appropriate services to consumers. Nevertheless, complaints 804

received by consumer associations around Europe show that the repair service offered by some 805

companies does not reflect this, especially during the guarantee period. 806

Industry stakeholders are in general in favour of the developing of an internal evaluation tool for 807

assessing the reparability and upgradability of products (e.g. as done in standardisation). However, 808

some of them have concerns with respect to the possible use of such a tool as the basis for setting 809

legal requirements, due to the inherent elements of subjectivity associated to any rating and weighting 810

approach. For any regulatory application, the Better Regulation agenda must apply to ensure 811

coherence and legal certainty. 812

When legal requirements are set, they must be clear and consistent, supporting innovation and 813

creating the conditions for competitiveness. Legal requirements that are based on evaluation methods 814

that are not sufficiently precise would impact the current competitive landscape between companies 815

and will lead to market distortions. Market surveillance authorities must be able to test any legal 816

requirement efficiently. 817

Measurement methods used for regulatory purposes have thus to respect the following requirements: 818

i) It has to leave no or minimal room of interpretation or doubt; 819

ii) It has to be enforceable by Member States; 820

iii) There is sufficient laboratory capacity to perform testing, when needed. 821

Some industry stakeholders do not consider that the draft standard developed by CEN/CENELEC JTC 822

10 – WG3 describe repeatable and reproducible measurement methods. These stakeholders remarked 823

the need to link the ongoing work of the JTC10 WG 3 to the analysis of this scoring system for 824

reparability and upgradeability. 825

826

4.3 Safety and liability of the product 827

Consumer protection and safety was reported to be a key element to maintain trust with consumers 828

and not to jeopardise efforts for the circular economy. The repair of products needs appropriate 829

technical skills that most consumers do not have. If an appliance is not properly repaired, consumer 830

safety within the home could be compromised. If a consumer has repaired a product, the liability for 831

the safety of the product is not with the manufacturer. According to some manufacturers, to ensure the 832

safety and conformity of products, repair of appliances must be made by authorised repair operators. 833

834

62

4.4 Communication issues 835

Communicating information does not have to be misleading and has to be simple and understandable 836

by consumers. 837

Transparency is a 'must', in order to establish trust in the legitimacy of the assessment. Some 838

stakeholders consider that any aggregation of results into one overall score is not feasible, as it will 839

always run the risk of being misrepresentative, depending on of consumers' individual conditions and 840

the use situation, and the type of product being examined. 841

842


Q1. Please let us know if you have any other specific comments to make

Answer

844

63

5 ANNEX I – INITIAL QUESTIONNAIRE FOR STAKEHOLDERS 845

5.1 Part 1) Existing methods, labels, or schemes for the assessing reparability and 846

upgradability of products 847

Q1.1 Please give your opinion on the methods, labels or schemes listed below, and which 848

can be used to assess the reparability and upgradability of products 849

Please fill in the table below based on your knowledge about the reported methods and labels. 850

If you are not familiar, please indicate that the 'method is not known'. 851

Method/Label Familiarity

with the

method

Advantages Disadvantages Overall opinion

about the

diffusion and

robustness of the

use of the

method as a

scoring system

Austrian standard ONR

192102

Design For

Repairability tool33

i-Fixit scoring system

Groupe SEB's Product

Repairable label

prEN 45554 - General

methods for the

assessment of the

ability to repair, reuse

and upgrade energy

related products

852

Q1.2 Please provide information regarding any other methods, labels or schemes which 853

you are aware of, and which can be used to assess the reparability and upgradability of 854

products 855

Please fill in the table below about additional methods and labels. 856

Method/Label Scope Advantages Disadvantages Familiarity with

the method, and

overall opinion

about diffusion

and robustness of

the use of the

method as a

scoring system

33 http://www.repairability.org/#


64

857

65

5.2 Part 2) Aspects influencing the reparability and upgradability of products in 858

general 859

860

Q2.1 Which are in your opinion the most relevant parameters influencing repair and 861

upgrade of products? How could these be assessed and verified? 862

Please fill in the table below by firstly evaluating their relevance based on your experience 863

(H: high, M: medium, L: low, N: no), and secondly describing if and how they could be 864

assessed and verified in practice. Note: an example of assessment and verification option 865

could be to make available the instructions about the steps needed to disassemble a part. 866

Parameter Relevance for repair

(High/Medium/Low/No)

Relevance for upgrade

(High/Medium/Low/No)

Options for

the

assessment

and

verification

Disassembly sequence

Type, number and

visibility of fastenings

and connectors

Tools needed

(availability,

complexity, cost)

Ease of access to parts

Working environment

(e.g. home, professional

repair site,

manufacturing plant)

Level of skills required

to undertake the

operations

Provision of diagnostic

support and interfaces

Availability of spare

parts

Availability and ease of

installation of software

and firmware

66

Availability of

information (e.g. repair

and/or upgrade manuals,

exploded diagrams)

Others34

(please

specify)

867

Q2.2 Besides the technical aspects listed above, other factors currently limit the repair 868

and upgrade of products (e.g. purchase price and labour costs, demand for new vs. 869

repaired/upgraded products, support networks facilitating the repair process, business 870

models, compatibility issues). In your opinion, under which conditions are repair and 871

upgrade operations more likely to occur? 872

Aspect Favourable conditions for

repair

Favourable conditions for

upgrade

Functional, technological and

behavioural factors (e.g.

demand for new vs.

repaired/upgraded products)

Economic factors (e.g.

purchase price for product and

spare parts, labour costs)

Organisational factors (e.g.

access to professional repair

services or support networks)

Legal factors (e.g. legal

guarantee, liability issues)

Others (please specify)

873

874

34 For instance, an overall measure of disassemblability (ease/difficulty of the disassembly operation), as

combination of some of the parameters listed in the table

67

5.3 Part 3) Conditions influencing the reparability and upgradability of specific 875

families of products 876

In Part 3 of the questionnaire, we would like you to consider the different motivations and 877

aspects regarding repair and upgrading for different families of products. These might be split 878

in various ways, but we have suggested - as examples – four representative subsets based on 879

the following characteristics: 880

(a) Small appliances (e.g. vacuum cleaners, kettles, coffee machines, handheld drills, hair-881

dryers): goods which can be easily transported to a repair shop and which are generally 882

perceived as less sophisticated by consumers attempting to repair them; 883

(b) Medium/large appliances (e.g. washing machines, dishwashers, refrigerators, freezers, 884

cookers): goods for which a trained technician might normally come to your home to repair 885

the product or you would have to make a dedicated logistics effort to transport them to be 886

repaired; 887

(c) Installed products (e.g. a boiler or heat pump, or air conditioning appliances): goods for 888

which a trained technician would normally be required to come out to examine the products, 889

and where the product repair is normally related to and interacts with the environment in 890

which it is placed; 891

(d) ICT products (e.g. imaging equipment, TVs, DVD players, mobile phones, tablets, 892

personal computers, laptops): goods with a faster innovation cycle compared to the former 893

categories and a size allowing a relatively easy displacement of the device for repair/upgrade. 894

895

Q3.1 Do you agree with the suggested subdivisions into the four families of products 896

described above? 897

GRADED RESPONSE: Completely agree – mostly agree – partly agree – disagree mostly – 898

Completely disagree 899

900

Q3.2 Do you have alternative approaches to propose? 901

OPEN QUESTION/RESPONSE 902

903

Q3.3 Which are the specific technical and economic conditions that could make repair 904

attractive for the above mentioned families of products from a consumers-targeted 905

perspective? Please also consider the alternative aspects/ suggestions, if any. 906

Aspect Small

appliances

Medium/Large

appliances

Installed

products

ICT

products

Max cost of repair which would

make it attractive, expressed as %

of the product's purchase price

Minimum lifetime expectancy for

the product at the time of

purchase, which would make

repair attractive (in years)

68

Maximum time of repair,

including delivery of spare parts,

which would make it attractive (in

weeks)

Other comments

907

Q3.4 Which are the specific technical and economic conditions that could make upgrade 908

attractive for the above mentioned families of product from a consumers-targeted 909

perspective? Please also consider the alternative aspects/ suggestions, if any. 910

Aspect Small

appliances

Medium/Large

appliances

Installed

products

ICT

products

Max cost of upgrade which would

make it appealing (free of charge,

or expressed as % of the product's

purchase price)

Minimum lifetime expectancy for

the product, at the time of

purchase, which would make

upgrade attractive (in years)

Maximum time of upgrade,

including delivery of new

parts/functions, which would make

it attractive (in weeks)

Other comments

911

912

69

5.4 Part 4) Identification of priority parts 913

914

Q4.1 Do you consider that the draft standard prEN 45554 is suitable as basis for the 915

development of a generic scoring system for the assessment of the repair/upgrade of 916

products? 917

YES 918

Up to a certain extent 919

NO 920

921

Q4.2 Please describe which modifications and integrations are needed in the context of 922

this study about the development of a scoring system, or where other parameters and 923

aspects could be used either to complement or replace those described in the standard. 924

Please reply (OPEN RESPONSES) 925

926

Q4.3 From the aspects listed below, which in your opinion are more relevant to identify 927

priority parts with respect to reparability? 928

Please firstly evaluate their relevance based on your experience (H: high, M: medium, L: low, 929

N: no), and secondly provide indications for differentiating between priority and non-relevant 930

parts 931

Parameter Relevance

(H/M/L/N)

Further indications for evaluating the

importance of parts with respect to

reparability

Frequency of failure of parts

Functional importance of

parts and software

Economic value of parts

(e.g. purchase price) and

related repair operations as

% of the product price

Environmental impacts of

parts as % of the total

environmental impacts of

the product

Steps needed to disassembly

parts


932

933

934

70

Q4.4 From the aspects listed below, which in your opinion are more relevant to be able 935

to identify priority parts with respect to upgradability? 936

Please firstly evaluate their relevance based on your experience (H: high, M: medium, L: low, 937

N: no), and secondly provide indications for differentiating between priority and non-relevant 938

parts 939

Parameter Relevance

(H/M/L/N)

Indications for evaluating the importance of

parts with respect to upgradability

Frequency of upgrade of

parts and software, where

relevant

Functional importance of

hardware and software,

where relevant

Economic value of parts

(e.g. purchase price) and

software, where relevant, as

% to the product price

Environmental impacts of

parts and software, where

relevant, as % of the total

environmental impacts of

the product

Steps/time needed to

disassemble parts and

uninstall and reinstall

software, where relevant


940

941

71

5.5 Part 5) Guidance for scoring and aggregating different aspects of repair and 942

upgrade 943

Parameters identified in the former sections can be used to assess the reparability and 944

upgradability of products through pass/fail requirements and/or scoring systems. This 945

requires the definition of rating criteria to use for the evaluation of single parameters. An 946

example is provided below which presents three classes of scores: 0 (negative attribute), 0.5 947

(neutral attribute), 1 (positive attribute). 948

Parameter Description of the proposed rating criteria (illustrative purposes only)

Availability of

spare parts

Score:

0 points: Original spare parts are not available to replace priority

parts

0.5 points: Original spare parts are available for less than 5 years

after purchase of the product, and not for all priority parts

1 point: Original spare parts are widely available to replace all

priority parts. Availability is ensured for at least 5 years following

the end of production of the model

Types of tools

needed

Score:

0 points: Advanced specialized tools (like a soldering iron, a puller

and/or proprietary screwdrivers) are needed to disassemble priority

parts

0.5 points: Specialized tools (like torx screwdrivers, electric drill

and small magnets) are needed to disassemble priority parts

1 point: No tools or only basic tools (like scissors, flathead and

cross recess (Phillips) screwdrivers) are needed to disassemble

priority parts

The score can be normalised to a different scale (e.g. 0 to 1, 0 to 5, or 0 to 10). Moreover, 949

scores could be weighed (if some criteria are considered to be more important) and 950

aggregated into one or more indices. 951

952

Q5.1 Taking the examples provided above for spare parts and tools, which rating 953

criteria would you apply to each single parameter described in Q2.1 in order to evaluate 954

their influence on reparability and upgradability of products? 955

Parameter Description of the proposed rating

criteria

(see the examples provided in the

introduction to section 5)

Disassembly sequence

Type, number and visibility of fastenings and

connectors

Tools needed (availability, complexity, cost)

Ease of access to parts

72

Working environment (e.g. home, professional

repair site, manufacturing plant)

Level of skills required to undertake the operations

Provision of diagnostic support and interfaces

Availability of spare parts

Availability and ease of installation of software and

firmware

Availability of information (e.g. repair and/or

upgrade manuals, exploded diagrams)

Others35

(please specify)

956

Q5.2 Reparability and upgradability of products could be reported for instance either 957

with respect to one or more single parameters (e.g. type of tools needed vs. all the 958

identified parameters) and either in isolate or aggregated form (i.e. as individual 959

parameter's score or as combined scores for a set of parameters). Which level of 960

aggregation should be reached when reporting the reparability and upgradability of 961

products? 962

Please choose and explain why 963

Options Y/N Comment

Only a limited number of individual parameters (e.g. the 3-4 most relevant

ones) should be considered and reported separately

All relevant parameters related to product-design (e.g. disassembly

sequence and tools needed) should be aggregated into 1 index

All relevant parameters related to the repair service support (e.g. spare parts

and information availability) should be aggregated into 1 index

All relevant parameters related to design characteristics should be

aggregated into 1 index, and all relevant parameters related to operation

characteristics should be aggregated into another index

All relevant parameters should be aggregated into 1 overall index


964

Q5.3 In case of aggregation, should an equal weight be considered for all relevant 965

parameters or should a weighting factor be assigned to some parameters to reflect their 966

relatively higher importance with respect to the others (see question 2.1)? (e.g. the score 967

of a high relevance parameter could weight 3 times that of a low relevance parameter) 968

Please reply and explain how and why 969

970

35 For instance, an overall measure of 'disassemblability' (ease/difficulty of the disassembly operation), as

combination of some of the parameters listed in the table

73

Q5.4 With reference to questions 5.1 and 5.2, which scale should be used to report the 971

product reparability/upgradability score? 972

Please firstly evaluate their suitability (H: high, M: medium, L: low, N: no), and secondly 973

provide supporting comments to explain why. 974

Reporting option Suitability

(H/M/L/N)

Supporting

comments

Binary (pass/fail)

Traffic lights

0-to-5 stars

Alphabetic (A, B, C, D, E, F, G)

Decimal number between 0-1 (or a number between

0-10 or 0-100)

Other iconographies and/or scales (please specify)

975

976

74

5.6 Part 6) Specific aspects and needs for the product groups under assessment 977

978

Q6.1 Considering the information provided on products in general (see sections 1, 2, 3 979

and 4), which are the specific aspects of importance for the reparability and 980

upgradability of laptops/ vacuum cleaners/ washing machines? 981

Please specify the product group and indicate the related specificities 982

Product Specific aspects influencing

reparability

Specific aspects influencing

upgradability

Laptops

Vacuum

cleaners

Washing

machines

983

Q6.2 Considering the information provided about the general scoring system approach 984

(see sections 4 and 5), which are the specific needs to take into account for the potential 985

design of a scoring system for laptops/ vacuum cleaners/ washing machines? 986


Product Specific needs for assessing

reparability

Specific needs for assessing

upgradability

Laptops

Vacuum

cleaners

Washing

machines

988

Q6.3 Please provide any additional comments you might have about other specific 989

aspects (e.g. links with standards, eco-design measures, and market specificities) 990


Product Additional comments

Laptops

Vacuum cleaners

Washing machines

75

6 ANNEX II – ANALYSIS OF RESPONSES 992

25 responses to the initial questionnaire were received36. This corresponds to about one reply 993

out of four from the stakeholders registered in the Technical Working Group for this project37. 994

In terms of organisations (see pie chart below): 995

15 responses were received from industry and trade associations (equivalent to 60% 996

of the respondents) 997

3 responses each were received from governmental agencies and NGOs (12%) 998

2 responses were received from independent repairers (8%) 999

1 response each was received from academia and retailers. 1000

1001

1002

1003

In terms of geographical representativeness of the respondents (see pie chart below): 1004

6 respondents are based in Belgium (24%) 1005

4 respondents are based in France (16%) 1006

3 respondents are based in Germany (12%) 1007

2 respondents are based in Italy (8%), as well as in Spain and in the Netherlands; 1008

Other respondents are based in Czech Republic, Denmark, Ireland, Sweden and the 1009

UK. 1010

1011

36 The questionnaire was launched on 7

th April 2018 and made accessible from

http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/documents.html. The questionnaire was closed

on 7th

May 2018. 37 The share of participation to the questionnaire would be higher if calculated based on the number of

organisations, since more representatives per organisation are in general registered as stakeholders.

http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/documents.html

76

1012

1013

77

1014

1015

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