French electronic product repairability index sustainability index evaluation service

The Repair Index for electronic products in France is a policy implemented by the French government to promote a circular economy, reduce electronic waste, and increase consumer awareness of the difficulty of product repair. This index has been implemented in the French market since January 1, 2021, and gradually expanded to more product categories.

How to measure and compare the maintainability of a product? It's actually a complex problem. Firstly, is the product designed to be easy to maintain? Is non-destructive disassembly possible? Are the components easy to obtain? Secondly, is maintenance easy to carry out? What tools, skills, and environmental conditions are required for the process of diagnosis, disassembly, and repair? Finally, is the repair price reasonable? In order to help consumers better understand the repairability of purchased products and incentivize manufacturers to design products that are easier to repair and durable, France has implemented a repairability index policy since 2021. Similarly, the EU's new Battery Law (EU) 2023/1542 also proposes requirements for product disassembly assessment.

The "Maintenance Index" was implemented on January 1, 2021, across five product categories (smartphones, laptops, televisions, lawn mowers, and drum washing machines). Starting from November 4th, 2022, it will cover four new product categories (top up washing machines, dishwashers, vacuum cleaners, and high-pressure washers). This tool is designed to provide consumers with more information about whether the products they purchase are easier to repair, in accordance with the Anti Waste and Circular Economy Law.

可维修指数（Repairability Index）

On April 5, 2024, a new durability index law related to the French Anti Waste Law was released. This index will gradually replace the repairability index implemented in France since 2021 and will be implemented starting from 2025. Regarding this index, France has issued one decree and three decisions: Decree No. 2024-316 on the durability index of electrical and electronic equipment; Decision on Display Methods on April 5, 2024; Decision on TV rating standards on April 5, 2024; Decision on Washing Machine Rating Standards on April 5, 2024.

Mandatory enforcement date for television: January 5, 2025; Washing machine: April 5th, 2025.

In 2024, the Anti Waste and Circular Economy Law stipulates that this index will become a sustainability index, in which new standards such as product durability or reliability will be added.

可持续性指数(Sustainability Index)

Background and purpose of the index

The French government, through regulations such as the Anti Waste and Circular Economy Law, requires electronic product manufacturers to indicate the repair index on their products. This index aims to provide consumers with more information about whether the products they purchase are easier to repair, thereby guiding them to extend the lifespan of their devices, especially by choosing products that are easier to repair when purchasing, and encouraging more repairs in case of malfunctions to reduce waste and protect the environment.

Scope of application of the index

The repair index initially applied to five product categories including smartphones, laptops, televisions, drum washing machines, and electric lawn mowers. Subsequently, the application scope of the index gradually expanded, covering four new product categories from November 4, 2022, including top loading washing machines, dishwashers, vacuum cleaners, and high-pressure cleaning machines.

Calculation and scoring of indices

The calculation of maintenance index is based on a series of standards, including the ease of product disassembly, availability of spare parts and technical documents, availability and price of parts supply, etc. These standards collectively determine the difficulty level of product maintenance and are converted into a 10 point rating system. The detailed information of the rating must be provided by the seller to the consumer at the time of purchase.

Rating range: from 1 to 10, where "1" represents the most difficult product to repair, while "10" represents very easy to repair.

Color codes: In order to display the repair index more intuitively, France also uses color codes to represent different rating ranges. For example, 0 ≤ score ≤ 1.9 is marked in red, indicating extremely high maintenance difficulty; And 8 ≤ score ≤ 10 is dark green, indicating that maintenance is very easy.

The calculation of repairability index is based on five main criteria:

-Technical documentation: The manufacturer promises to provide free technical documentation to maintenance personnel and consumers within a certain period of time.

-Disassembly difficulty: Score based on the ease of disassembly of the product, the type of tools required, and the characteristics of the fixing method.

-Component availability: Score based on the manufacturer's commitment to component availability and delivery time.

-Component price: Score based on the ratio of component sales price to product price.

-Product category maintenance difficulty: Score based on specific sub criteria of the product category.

Regulation and impact of indices

Although the French government has not yet mandated that all manufacturers disclose the repair index of their products, some companies have begun to proactively disclose this information. In addition, France has also legislated penalties for violations of information disclosure obligations, including administrative fines.

The implementation of maintenance index has had a profound impact on electronic product manufacturers, sellers, and consumers. Manufacturers need to pay more attention to the maintainability design of their products in order to improve their repair index; Sellers need to provide consumers with accurate repair index information; Consumers can choose products more wisely, extend the service life of equipment, and reduce waste through the repair index.

The risk of violating French anti waste laws

If you sell the above specific products in France, regardless of which country your business is registered in, you must provide repair indices in specific product categories in accordance with French EPR legal requirements.

Regulatory agencies have begun to check the compliance of the repairable index display and format, as well as whether consumers can obtain specific parameter rating forms. In 2022, the French anti fraud agency DGCCRF inspected over 500 institutions that produce or sell household appliances to check the display of repairability indices. 65% of the products have problems, especially in providing index calculation methods. A total of 256 institutions have received warnings, 89 institutions have received bans, 1 institution has received a penalty report, and 5 institutions have imposed administrative fines as high as 3500 euros.

If selling unmarked products, the penalty standard is:

Natural persons up to 3000 euros

The maximum amount for legal entities is 15000 euros

laws and regulations:

On February 10, 2020, France promulgated Law No. 2020-105 on Waste and Circular Economy, which stipulates that from January 1, 2021, manufacturers, importers, distributors, or other operators of electronic and electrical equipment sold in the French market shall provide free of charge the repairability index of the equipment and the parameters for determining the index to consumers of their products and anyone who requests it. On October 30, 2020, France issued nine TBT notifications through the WTO Secretariat, including the "Regulations on the Maintainability Index of Electronic and Electrical Equipment", the "Regulations on the Calculation Method of Maintainability Index", and the maintainability index standard requirements for five categories and seven types of products included in the first implementation scope.

The details are as follows:

G/TBT/N/FRA/195: Regulations on the Maintainability Index of Electronic and Electrical Equipment

G/TBT/N/FRA/196: Regulations on the Display Method, Marking, and General Parameter Calculation of Maintainable Index

G/TBT/N/FRA/197: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of front loading household washing machines

G/TBT/N/FRA/198: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of laptops

G/TBT/N/FRA/1999: Regulations related to the standards, sub standards, and scoring systems for calculating and displaying the repairability index of smartphones

G/TBT/N/FRA/200: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of televisions

G/TBT/N/FRA/201: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of battery electric lawn mowers

G/TBT/N/FRA/202: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of wired electric lawn mowers

G/TBT/N/FRA/203: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of robot electric lawn mowers

On February 3, 2022, France issued six TBT notifications through the WTO Secretariat, covering new requirements for the repairability index of six products including vacuum cleaners, washing machines, dishwashers, and high-pressure washers. The details are as follows:

G/TBT/N/FRA/217: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of wireless vacuum cleaners

G/TBT/N/FRA/218: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of wired vacuum cleaners

G/TBT/N/FRA/219: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of robot vacuum cleaners

G/TBT/N/FRA/220: Regulations related to the standards, sub standards, and scoring systems for calculating and displaying the repairability index of overhead household washing machines

G/TBT/N/FRA/221: Regulations related to the calculation and display of the repairability index of electric household dishwashers, including integrated and embedded dishwashers, including standards, sub standards, and scoring systems

G/TBT/N/FRA/222: Regulations related to standards, sub standards, and scoring systems for calculating and displaying the repairability index of high-pressure cleaning machines

Shenzhen Element Testing Co., Ltd. (referred to as Element Testing) focuses on providing testing and compliance services for battery/mobile power and electronic atomizer enterprises.

Element adheres to the research of laws, regulations, and testing standards, continuously delivers the latest legal and regulatory information to customers, completes the method validation of new testing standards in the first time, and applies them to the testing of related products.