Orgalime comments on draft EuP Methodology Study
Published: 21 October 2005
Policies & Issues: Environment
At present, VHK is carrying out a study on an EuP methodology on behalf of DG Enterprise & Industry. The stated aim of the study is "to contribute to the creation of a methodology allowing to evaluate whether and to which extent various energy using products fulfil certain criteria (listed in atricle 15 of the directive) that make them eligible for implementing measures under the Eco Design of EuP Directive 2005/32/EC".
In principle, Orgalime supports the development of such a methodology in the interest of more legal certainty and consistency. Nevertheless, we believe that in order to enable the effective and correct use of the EuP methodology, a number of essential improvements are necessary since the present draft final report includes significant uncertainties. In some areas, the present draft final report also seems to predict certain steps and to go beyond its stated aim.
We provide more details on the areas where we see that these concerns are particular evident in this position paper. Detailed information on the VHK study is available at www.eupproject.org.