eceee comments on a voluntary agreement for imaging equipment

(25 Mar 10) The proposal of 19 February has some improvements compared to the first proposal, but is still not sufficient to satisfy the requirements for a solid and reliable voluntary agreement as a replacement for regulation.

We have the following specific comments:

• The market coverage is acceptable.
• We believe that at least 90% of the products should meet EnergyStar criteria by 1 January 2012, 80% is not ambitious enough. This is particularly important since some exemptions are also proposed.
• The first tier proposed by 1 January 2011 could be removed. It is better to go for the second tier directly in order to make the voluntary agreement less complicated.
• We don’t understand why there should be exemptions for recycling of toners from products sold in small numbers. As we understand it, toner recycling is not connected to individual models.
• Why would a voluntary agreement need special promotion activities? A voluntary agreement is a replacement for regulation and not a consumer information activity.

See eceee's full comments (pdf)
See eceee's eco-design products pages

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