Correcting act of Commission Regulation (EU) 2023/1670 laying down ecodesign requirements for smartphones and tablets

This proposal completely removes removability criteria for the display assembly, even though it has to be provided to end-users. This is not logic. The repairability criteria for the back cover and display assembly should be identical to the criteria that apply for the battery if there is a dependency between these parts during disassembly.

The European Commission recently published a draft act concerning Ecodesign requirements for smartphones and tablets in order to correct Regulation (EU) 2023/1670. The draft corrective act proposes corrections to the respective sections 1.1 (5) in parts A, B, and D, as well as deletion of point 2.1 (5) c) i section C of the regulation.

First of all, I greet everyone with respect and love. I have an idea about phones, as you know, many network providers are already giving away phones based on talk time. In order not to look for recycling materials, it would be more logical for them to replace all devices that are 5 years old with new ones. In fact, there will be a summit with telecommunication companies in France on the 16th of this month.

DECT Forum response to European Commissions proposal for correcting (EU) 2023/1670 laying down Ecodesign requirements for cordless phones among other electronic devices DECT Forum appreciates the opportunity to provide feedback regarding the implementation of Ecodesign Regulation (EU) 2023/1670 and would like to take this opportunity to share our position and concerns regarding the interpretation and implementation…

In the corrective act, the European Commission states that (3) Annex II to Regulation (EU) 2023/1670 establishes different disassembly requirements for various parts of the product. There is an error regarding the requirements for the replacement of the display assembly, which was erroneously included in two separate sections of the requirements.

The Right to Repair Europe coalition represents over 180 organisations from 30 European countries, including environmental NGOs and repair actors such as community repair groups, social economy actors, spare parts distributors, self-repairers, repair and refurbishing businesses.

We write on behalf of manufacturers of industrial technologies used in hazardous environments and governed by the ATEX Directive (EU) 2014/34. Our members products include rugged smartphones, tablets, and touchscreen devices, which are used for configuring, maintaining, and communicating with industrial equipment in the field.

Equipment falling under the scope of the ATEX Directive (2014/34/EU), also known as Ex Products, are equipment and protective systems intended for use in potentially explosive atmospheres. Ex Products are primarily designed to ensure the health and safety of users. Ex Products are found in various industries, ranging from the energy sector and foodstuff to pharmaceutical manufacturing.

ATEX products are designed for environment where reliability and safety are the key. ATEX equipment according to the corresponding directive (EU) 2014/34 must provide means to prevent the ignition of a potentially explosive atmosphere. This means that for example repairs may only be carried out by specialists with specific knowledge, competency and tools.

ATEX products are designed for very specific use case and environment, where reliability and safety are the key element. These devices are sold in very small volumes and sales is very focused for industrial customers who are professional to arrange the service as well as recycling properly.

Addition of an exemption for ATEX products Smartphones and tablets for Ex applications are a high technology niche, where European companies are currently leading worldwide manufacturers. Those Ex products are intended only for professional users in Ex environments. They are often used among others features for important communication and locating personnel in large facilities.

The Ecodesign Regulation (EU) 2023/1670 rightly aims to improve the repairability and sustainability of smartphones and tablets. However, it remains unclear whether industrial-grade specialist devicesparticularly those certified under the ATEX Directive (EU) 2014/34are intended to fall within its scope.

At Balluff GmbH, we recognize the importance of smartphones and tablets for Ex applications as a high technology niche where European companies are leading global manufacturers. These Ex products are designed exclusively for professional users in Ex environments and are often utilized for critical communication and personnel location in large facilities.

As a leading manufacturer for products used in potentially explosive atmospheres Pepperl+Fuchs voices concerns about a missing exemption for Ex Products. In it's current format Regulation (EU) 2023/1670/EU jeopardizes the high safety level for Ex Products established by the ATEX Directive and subsequently by harmonised Standards and therefore subsequently threatens the Health and Safety of workers in the industry.

Add an exemption for ATEX products. These types of products must not be opened or repaired by anyone other than an Ex professional because explosion-proof applications require safety-related requirements and these requirements are applicable during the repair phase. Refer to directive (EU)2014/34. The market for Ex phones and tablets is small when compared to consumer-grade phones and tablets.

Addition of an exemption for ATEX products Smartphones and tablets for Ex applications are a high technology niche, where European companies are currently leading worldwide manufacturers. Those Ex products are intended only for professional users in Ex environments. They are often used among others features for important communication and locating personnel in large facilities.