First of all: The working committee KU-AK 7 "Resource protection and environmentally compatible product and process design" in the DIN Standards Committee Coordination Body for Environmental Protection (KU) has published the Technical Specification DIN/TS 35205 (September 2024). This can be downloaded free of charge from the DIN Media GmbH webshop.
Such technical specifications are part of the German body of standards and are the result of standardization work, but are not yet published as a DIN standard due to certain reservations regarding their content.
Content: The so-called Waste Framework Directive 2008/98/EC addresses waste prevention and resource conservation. Reuse plays an important role in this. In addition, this product aspect is increasingly being addressed in national legislation.
The Waste Framework Directive sets out an order of priority. Waste prevention is the top priority. However, it also obliges the Member States to take measures to promote reuse as part of national waste prevention programs and to submit data on reuse.
In Germany, the so-called Circular Economy Act (KrWG) implements the waste hierarchy from this EU Directive 2008/98/EC at national level.
In KrWG § 6, prevention is the first level in the waste hierarchy, but is not subject to waste legislation. The following 4 levels, however, are subject to waste legislation:
- Preparation for reuse
- Recycling
- Other recovery
- Disposal
On the basis of the German Resource Efficiency Program (ProgRess), Germany defined goals, guiding principles and approaches for the protection of natural resources in 2012. On the basis of a progress report addressed to the German Bundestag, ProgRess II was adopted by the Federal Cabinet on March 2, 2016 and ProgRess III on June 17, 2022.
ProgRess III includes measure no. 50, which states that market players should be supported in setting quality standards for testing, cleaning and repair. This DIN/TS entitled "Guidelines for the reuse and preparation for reuse of electrical appliances, textiles, furniture and other household items - Recommendations for setting up, implementing and optimizing corresponding business models" is intended to support commercial users in setting up and optimizing the processes in the respective reuse companies.
In addition, there are many terms in circulation in connection with the reuse of items, some of which are used incorrectly, arbitrarily or unclearly. In the interest of standardized terminology, this DIN/TS is intended to contribute to a uniform and unambiguous application of the terms.
The following product groups are included in the scope of this DIN/TS:
- Electrical appliances (brown goods, white goods, ITC products, small household appliances, etc.)
- Furniture
- Textiles
- Household goods such as books, recordings, games or garden accessories
- Sports equipment including bicycles
Section 4.1.2 provides background information on the legal context, among other things. This includes references to the Blue Guide 2022, the harmonization legislation regarding the CE marking of products and the Product Liability Directive in its current version (85/374/EEC). This includes the reconditioning of products, maintenance and the significant modification of products.
The following recommendations for action are particularly relevant for refurbishers:
- Ensure that product conformity is maintained by using the manufacturer's specification for corresponding spare parts.
- Adequate insurance cover for the remanufacturer for damage arising from product liability should be ensured.
In the initial assessment, this guideline is a useful document. It remains to be seen whether this DIN/TS will be adopted into the German body of standards at a later date.
Basically, it should be noted that in the next decade, the environmental aspect (in addition to the classic product conformity aspects such as safety, cybersecurity, electromagnetic compatibility and other requirements) will play a major role in the industry with regard to the entire product life cycle. The keywords here are circular economy, Green Deal, Right 2 Repair, to name but a few. In terms of economic policy, the question currently arises as to how companies, and in particular small and medium-sized enterprises (SMEs), can keep pace and are even able to implement these increasing regulatory requirements in a compliant manner. The impression is growing that overregulation is taking place here.
Author
Dipl.-Ing. (FH) Michael Loerzer
Regulatory Affairs Specialist
