EuroVAprint
EVAP
EuroVAprint ASBL is a non-profit association grouping all major manufacturers of imaging equipment that operate in Europe.
ID: 807343126141-19
Lobbying Activity
Response to Measures addressing the environmental impact of imaging equipment including consumables
17 Feb 2023
EVAP agrees that all the issues identified in the Commissions communication are relevant for consideration in developing the regulation. EVAP also supports the high-level objectives, the range of aspects and the range of four options set out by the Commission. EVAP considers that the Commission needs to take great care in considering the likely impacts of all these elements and to not over-simplify the analysis of whether the particular measures will result in the benefits the Commission is aiming for. Given the complexities, EVAP has expressed previously the concern that a failure to analyse proposals in sufficient depth runs a significant risk of driving outcomes that are overall negative for the environment, end users and the Imaging Equipment Industry. EVAP continues to stress the importance of the Commission carefully assessing all legal, environmental and economic aspects, the reasons for the current situation and how all the aspects interrelate with each other including but not limited to: different imaging equipment technologies; different product architectures; different business models; technical aspects and impacts of different options; impacts of cartridge requirements on installed base printers; the influence of the market including how measures adopted will affect the market; customer usage, requirements, expectations and behaviours; impacts on non-ecodesign issues such as cybersecurity, data protection, protection of intellectual property and counterfeit prevention; economic aspects such as shrinking market size and reduced printed pages in a digitalised environment. EVAP is fundamentally concerned about the temporal overlap and legislative cumulation of ESPR and the 'Imaging equipment and consumables' project under the Ecodesign Directive. In our view, there is a risk of regulatory inconsistencies and/or changes to the legal framework in close succession due to these competing initiatives. EVAP members plan their product design several years in advance and need planning as well as legal certainty. ESPR would include performance and information requirements. Requirements for the Imaging Equipment industry could even go beyond the Ecodesign Directive (e.g. Digital Product Passport). EVAP therefore proposes to temporarily suspend the 'Imaging equipment and consumables' project until the legislative process leading to ESPR is concluded, this in order to accomplish effective implementation of environmental goals while avoiding unnecessary harm to the industry by an unhealthy cumulation of environmental legislative initiatives. EVAP stands ready to continue engaging actively, by written communication and/or face to face meetings, throughout the consultation process and to support the Commission with its analysis and development of the regulation.
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