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1
EUROPEAN COMMISSION
JOINT RESEARCH CENTRE
Directorate B, Growth and Innovation (Sevilla)
Unit 5, Circular Economy and Industrial Leadership
1
Analysis and development of a scoring system for repair and upgrade of products – 2
draft version 1 3
4
Author(s):
JRC – B.5
Date:
20th
June 2018
Summary:
The European Commission has been working on the analysis and development of a possible
scoring system to inform about the ability to repair and - where relevant - upgrade products.
The overall aims of this study are:
1. To develop a general approach for the assessment of products;
2. To test the feasibility and types of results derived using the general approach on three
specific product groups (Laptops, Vacuum Cleaners, Washing Machines).
The study, carried out by the Commission's Joint Research Centre (Directorate B, Circular
Economy & Industrial Leadership Unit) on behalf of DG ENV, has a preparatory orientation
and will not have any effect on the product-specific Regulations currently in discussion. This
technical study could be used to set the framework and grounds for the development of a tool
for informing consumers.
This is the first version of the report, which has been prepared as working document for the 1st
Technical Working Group (TWG) meeting (Seville, 26 June 2018) with main aim of
discussing the general assessment framework. The report is structured in the following parts:
1. Analysis of existing methods for assessing reparability and upgradability
2. Development of a scoring system: key aspects, priority parts, scoring framework
3. Product-specific considerations
4. Additional considerations
5. Annexes
Stakeholders are kindly invited to read and comment on this report, and to send any
comments to [email protected] by 27th July 2018 (please use the
provided commenting sheet).
The second consultation round will take place in parallel with the 2nd
TWG meeting
(Brussels, November 2018, date to be confirmed) and will have a more product-specific
focus. The publication of final report is planned by the end of 2018.
Information on the study and reports will also be made available on the dedicate website:
http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/index.html.
5
DISCLAIMER: The views expressed are purely those of the writer and may not in any 6
circumstances be regarded as stating an official position of the European Commission. The 7
2
information transmitted is intended only for the Member State or entity to which it is 8
addressed for discussions and may contain confidential and/or privileged material. 9
10
3
Table of Contents 11
GLOSSARY (TO FOLLOW) 12
INTRODUCTION........................................................................................................... 5 13
1 ANALYSIS OF METHODS FOR ASSESSING REPARABILITY AND 14
UPGRADABILITY ................................................................................................. 8 15
1.1 AUSTRIAN STANDARD ONR 192102:2014 ................................................................... 8 16
1.2 I-FIXIT SCORING SYSTEM ............................................................................................ 10 17
1.3 'DESIGN FOR REPAIRABILITY' TOOL ........................................................................... 11 18
1.4 GROUPE SEB'S 'PRODUCT 10Y REPAIRABLE' LABEL.................................................. 12 19
1.5 PREN 45554 - GENERAL METHODS FOR THE ASSESSMENT OF THE ABILITY TO REPAIR, 20
REUSE AND UPGRADE ENERGY RELATED PRODUCTS .................................................. 12 21
1.6 OTHER METHODS ........................................................................................................ 14 22
1.7 SUMMARY ................................................................................................................... 14 23
2 DEVELOPMENT OF A SCORING SYSTEM FOR ASSESSING REPAIR AND 24
UPGRADE OF GENERIC PRODUCTS ............................................................ 16 25
2.1 KEY PARAMETERS FOR REPAIR AND UPGRADE ........................................................... 16 26
2.2 PRIORITY PARTS .......................................................................................................... 25 27
2.2.1 Frequencies of failure and upgrade ................................................................... 26 28
2.2.2 Functional importance ....................................................................................... 26 29
2.2.3 Price of parts and cost of repair/upgrade ........................................................... 27 30
2.2.4 Environmental impacts of parts ......................................................................... 27 31
2.2.5 Disassembly of parts and reinstallation of software .......................................... 27 32
2.2.6 Additional considerations .................................................................................. 27 33
2.3 SCORING FRAMEWORK ............................................................................................... 29 34
2.3.1 Classification and rating of individual parameters ............................................ 30 35
SCORE = (DSMAX – DSI) / (DSMAX – DSMIN) ....................................................... 30 36
2.3.2 Aggregation of individual parameters ............................................................... 45 37
2.3.3 Reporting options to assess products ................................................................ 47 38
2.4 SUMMARY ................................................................................................................... 48 39
2.5 QUESTIONS FOR STAKEHOLDERS ................................................................................ 51 40
3 PRODUCT SPECIFIC CONSIDERATIONS ..................................................... 52 41
3.1 ATTRACTIVE CONDITIONS FOR REPAIR AND UPGRADE FOR MACRO-CATEGORIES OF 42
PRODUCTS ................................................................................................................... 52 43
3.2 ASPECTS AND NEEDS FOR A PRODUCT-SPECIFIC SCORING SYSTEM ............................ 56 44
3.3 QUESTIONS FOR STAKEHOLDERS ................................................................................ 59 45
4 ADDITIONAL POINTS TO CONSIDER ........................................................... 61 46
4.1 REPARABILITY AND UPGRADEABILITY VS. DURABILITY OF PRODUCTS ..................... 61 47
4.2 LINK TO POLICY FRAMEWORK AND STANDARDISATION ............................................ 61 48
4.3 SAFETY AND LIABILITY OF THE PRODUCT .................................................................. 61 49
4.4 COMMUNICATION ISSUES ........................................................................................... 62 50
4.5 QUESTIONS FOR STAKEHOLDERS ................................................................................ 62 51
5 ANNEX I – INITIAL QUESTIONNAIRE FOR STAKEHOLDERS ............. 63 52
4
5.1 PART 1) EXISTING METHODS, LABELS, OR SCHEMES FOR THE ASSESSING REPARABILITY 53
AND UPGRADABILITY OF PRODUCTS ........................................................................... 63 54
5.2 PART 2) ASPECTS INFLUENCING THE REPARABILITY AND UPGRADABILITY OF PRODUCTS 55
IN GENERAL................................................................................................................. 65 56
5.3 PART 3) CONDITIONS INFLUENCING THE REPARABILITY AND UPGRADABILITY OF 57
SPECIFIC FAMILIES OF PRODUCTS ............................................................................... 67 58
5.4 PART 4) IDENTIFICATION OF PRIORITY PARTS ............................................................ 69 59
5.5 PART 5) GUIDANCE FOR SCORING AND AGGREGATING DIFFERENT ASPECTS OF REPAIR 60
AND UPGRADE ............................................................................................................. 71 61
5.6 PART 6) SPECIFIC ASPECTS AND NEEDS FOR THE PRODUCT GROUPS UNDER ASSESSMENT62
.................................................................................................................................... 74 63
6 ANNEX II – ANALISYS OF RESPONSES ........................................................ 75 64
65
66
5
INTRODUCTION 67
The 2015 Communication from the Commission on an EU action plan for the Circular Economy1 68
pointed out the importance of improving the resource efficiency of products in order to promote the 69
transition towards a more circular economy in the EU. The Ecodesign Working Plan 2016-20192 70
commits to explore the possibility of further developing product-specific and/or horizontal 71
requirements in areas such as durability, reparability, upgradeability, ease of reuse and recycling. In 72
particular, improving repair and upgrade possibilities for products can potentially benefit consumers, 73
the environment and the economy by limiting the early replacement of products, increasing 74
competitiveness on product design, supporting the EU repair market and saving resources. 75
In this context, the European Commission has been working on the analysis and development of a 76
possible scoring system to inform about the ability to repair and - where relevant - upgrade products. 77
Reparability and upgradability are here defined, respectively, as the ability to restore the functionality 78
of a product after the occurrence of a fault, and the ability to enhance the functionality of a product, 79
independently on the occurrence of a fault. Both can refer to one or more parts of a product3. 80
"Upgradability" can in particular refer to either the hardware or software parts/ components of 81
products. As part of the enabling framework for repair, the study will also explore the possibility to 82
take into account relevant practices, such as the provision of an extended product warranty, after-sales 83
free repair services and others. 84
The overall aims of this study are: 85
3. To develop a general approach for the assessment of products; 86
4. To test the feasibility and types of results derived using the general approach on three specific 87
product groups (Laptops, Vacuum Cleaners, Washing Machines). 88
89
90
Figure 1 From general approach to product specific methods 91
The study, carried out by the Commission's Joint Research Centre (Directorate B, Circular Economy 92
& Industrial Leadership Unit) on behalf of DG ENV, has a preparatory orientation and will not have 93
any effect on the product-specific Regulations currently under discussion. This technical study could 94
be used to set the framework and grounds for the development of a tool for informing consumers4. 95
1 COM(2015) 614 'Closing the loop - An EU action plan for the Circular Economy''
2 COM(2016) 773 'Ecodesign Working Plan 2016-2019'
3 Cordella, M.; Sanfelix, J.; Alfieri, F. (2018) Development of an Approach for Assessing the Reparability and
Upgradability of Energy-related Products. Procedia CIRP, 69, 888-892.
https://doi.org/10.1016/j.procir.2017.11.080 4 Complementary to this technical work, there will be a further study that will explore the possibility to develop
a label. However, this study will be conducted separately with the support of experts in the field of labelling and
communication and will include consultation with stakeholders and surveys with end-consumers.
6
The research builds on the in-house experience in product policy implementation and in the 96
assessment of products5, as well as on the available literature and on input from experts and other 97
stakeholders. Stakeholders who will be consulted during this process include, for example, 98
manufacturers, retailers, repair enterprises, academia, environmental and consumer NGOs, Member 99
States' representatives. Engagement with stakeholders is very important for this project, in order to 100
achieve coherent and balanced results, based on representative and up-to-date information. A 101
consultative Technical Working Group (TWG) has been set up to facilitate this process6. 102
Background information and initial input from stakeholders have been gathered at this stage via a 103
questionnaire7 (see Annex I and Annex II). Replies from 25 experts and stakeholders are integrated 104
into this document. Stakeholders were asked to provide their knowledge in the following areas: 105
Existing methods, labels, or schemes for the assessing reparability and upgradability of 106
products; 107
Aspects influencing the reparability and upgradability of products in general; 108
Conditions influencing the reparability and upgradability of specific families of products; 109
Identification of most relevant aspects and priority parts (i.e. hardware and software 110
components of products); 111
Guidance for scoring and aggregating different aspects of repair and upgrade; 112
Specific aspects and needs for the product groups under assessment. 113
Two meetings are moreover planned in order to obtain input and feedback from the TWG: 114
1st TWG meeting on 26 June 2018 in Seville, to discuss the general approach, and to obtain 115
product-specific preliminary guidance; 116
2nd
TWG meeting in November in Brussels (tbc), to discuss product-specific approaches (and 117
to iteratively revise the general approach, if needed). 118
This first version of the report has been prepared as a working document for the 1st TWG meeting and 119
mainly aims at presenting the general assessment framework. The report is structured as follows: 120
6. Analysis of existing methods for assessing reparability and upgradability 121
7. Development of a scoring system: key aspects, priority parts, scoring framework 122
8. Product-specific considerations 123
9. Additional considerations 124
10. Annexes 125
Stakeholders are kindly invited to read and comment on this report, and to send any comments to 126
[email protected] by 27th July 2018 (please use the provided commenting 127
sheet). 128
The second consultation round will take place in parallel with the 2nd
TWG meeting, and will have a 129
more product-specific focus. The publication of the final report is planned by the end of 2018. 130
Information on the study and reports will also be made available on the dedicate website: 131
http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/index.html. 132
5 Cordella, M.; Sanfelix, J.; Alfieri, F. (2018) Development of an Approach for Assessing the Reparability and
Upgradability of Energy-related Products. Procedia CIRP, 69, 888-892.
https://doi.org/10.1016/j.procir.2017.11.080 6 The Technical Working Group has more than 100 registered stakeholders on May 23
rd 2018
7 The questionnaire was launched on 7th
April 2018 and made accessible from
http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/documents.html. The questionnaire was closed on
7th
May 2018.
8
1 ANALYSIS OF METHODS FOR ASSESSING REPARABILITY AND 134
UPGRADABILITY 135
Reparability and upgradability of products can be assessed at different levels which vary from more 136
qualitative to more quantitative approaches8. This study focuses on the evaluation of the reparability 137
and upgradability of products based on parameters that can eventually be used for determining a score 138
and/or a label icon. 139
An analysis of approaches available in the literature, and which are considered relevant for the 140
development of a scoring system on repair and upgrade, is provided in this section. These include: 141
Austrian standard ONR 192102:2014 'Label of excellence for durable, repair-friendly 142
designed electrical and electronic appliances'9 143
'Design For Repairability' tool10
144
i-Fixit score11
145
Groupe SEB's 'Product 10Y Repairable' label12
146
prEN 45554 'General methods for the assessment of the ability to repair, reuse and upgrade 147
energy related products'. 148
Through the initial questionnaire, stakeholders have been asked to provide their familiarity with these 149
and other approaches, as well as their opinion about advantages, disadvantages, diffusion and 150
robustness of the approach itself. 151
1.1 Austrian standard ONR 192102:2014 152
This standard establishes criteria to obtain a quality label for durable, repair friendly designed 153
electrical and electronic appliances (white and brown goods13). White goods undergoing this process 154
are assessed against a set of 40 requirements; 53 requirements are instead considered for brown 155
goods. The system is composed of both mandatory pass/fail requirements, and requirements based on 156
graded classes. The latter ones are used to quantify a score, which is then related to a 5-10 quality 157
level and an overall rating, as shown in Table 1. 158
8 Cordella, M.; Sanfelix, J.; Alfieri, F. (2018) Development of an Approach for Assessing the Reparability and
Upgradability of Energy-related Products. Procedia CIRP, 69, 888-892.
https://doi.org/10.1016/j.procir.2017.11.080 9 ONR 192102: 2014 10 01 - Gütezeichen für langlebige, reparaturfreundlich konstruierte elektrische und
elektronische Geräte, Available at https://shop.austrian-
standards.at/action/de/public/details/527823/ONR_192102_2014_10_01 (accessed on 24th May 2018) 10 http://www.repairability.org (accessed on 10
th May 2018)
11 https://www.ifixit.com/ (accessed on 24th
May 2018) 12 http://www.groupeseb.co.uk/repairable.html (accessed on 24th May 2018) 13 No official definition is provided, however, in general: i) white goods include large electrical products used
domestically, such as refrigerators and washing machines; ii) brown goods include consumer electronics
equipment for entertainment, such as televisions and media players.
9
Table 1 Conversion table for level of quality and rating in ONR 192102:2014 159
160
14 out of 25 (56%) respondents to the initial questionnaire reported to know, up to a certain point, the 161
standard. However, only half of them declared to be satisfactorily/ sufficiently familiar with the 162
approach. 163
According to stakeholders, some of the advantages of ONR 192102 include: 164
A comprehensive overview of criteria, covering both white and brown goods (especially valid 165
for washing machines) and both horizontal and service support issues; 166
Provision of a practical labelling framework specifically focused on reparability; 167
Involvement of experts and associated actors, and further application by different 168
organisations. 169
On the other hand, stakeholders have reported or commented the following as weaknesses for ONR 170
192102: 171
It covers only a part of ICT products 172
It is a national standard and therefore it may be representative for the Austrian market only. 173
Some stakeholders moreover argue that it was developed without sufficient involvement of 174
relevant industry sectors 175
It mixes aspects such as ease of use, durability, reparability, service support, quality 176
management, documentation and commercial warranty 177
Some of the criteria used are in conflict with harmonised EU legislation (e.g. the Machinery 178
Directive [MD], Low Voltage Directive [LVD]) and some safety standard elements (e.g. 179
mandatory use of special screws) 180
The standard seems biased towards independent professional repair as there is no criteria for 181
different target groups or skill levels, and some criteria are either over-specific, not neutral, or 182
ambiguous 183
The scale of the scoring system is based on manufacturers' information and trade-offs 184
between different criteria are allowed, which brings some elements of subjectivity 185
The criteria and their means of verification are not always clearly defined 186
It is complex and costly 187
The overall opinion of stakeholders about ONR 192102 is summarised below. 188
Some stakeholders consider that ONR 192102 can be a good starting point for evaluating the 189
reparability of products, although it comes with some limitations; 190
Other stakeholders do not consider that the standard as such is suitable for the development of 191
a scoring system to use for regulatory purposes, as they see that improvements are needed, 192
10
especially in terms of robustness and scope, as well as the fact that this standard is presently 193
not widely used. 194
1.2 i-Fixit scoring system 195
A reparability score between zero and ten is assigned by iFixit to different categories of devices (e.g. 196
laptops, smartphones), where a score of ten represents the easiest product to repair on the market. The 197
scoring system considers indicators such as: ease of disassembly, availability of service manuals, 198
types of fasteners used, type and number of required tools, possibility to upgradable the device, and 199
modular design14
. 200
17 out of 25 (68%) respondents to the initial questionnaire declared having a certain knowledge of the 201
i-Fixit scoring system. However, only 5 respondents declared a high level of familiarity with the 202
method. 203
According to stakeholders, the advantages of the i-Fixit scoring system include: 204
It is useful for design purposes; 205
It is simple, practical and clear for consumers, 206
It is seemingly fair and lists both positive and negative items; 207
It combines qualitative and quantitative methods; 208
It allows for the weighting of criteria 209
It provides repair guides for different high-tech products, also documenting the number and 210
type of operations and required tools, in an independent manner; 211
It provides a score in a publicly available and popular platform, which can help to increase 212
awareness regarding the topic. 213
On the other hand, weaknesses explicitly listed by stakeholders for the i-Fixit method are: 214
The current version is oriented towards the assessment of specific product categories (ICT 215
products) and therefore it is not applicable to all products. Methods could, however, be 216
adapted for other products and scenarios; 217
The scoring and weighting system used seems not sufficiently transparent. The 218
methodological guidance is currently unpublished and is under revision; 219
The availability and cost of spare parts are not included in the assessment; 220
It is oriented towards consumers, including self-repairs (e.g. repair information for free, no 221
proprietary screws, number of screws) and some industry stakeholders argue that this 222
discriminates against other repair strategies that would result in repairable devices as well. 223
The scoring methodology is partly subjective (e.g. 'discretionary feel after taking apart', 224
'components not tightly packed', 'no excessive use of adhesives', 'no substantial prying effort', 225
'critical components easily replaceable'); 226
Weighting of scoring should be calibrated based on surveys to show where major issues are. 227
Also, surveys per se could be potentially replaced by durability tests, but those tests are very 228
expensive; 229
Reparability of products is more complex than a 1-10 scoring metric; 230
It is not a fully scientific approach. 231
The overall opinion of stakeholders about the i-Fixit method is summarised below: 232
14 https://www.ifixit.com/Info/Repairability#Section_Overview (accessed on 4
th June 2018)
11
In general, stakeholders seem to consider the method as a good starting point for the 233
development of a scoring system. 234
However, some drawbacks have been pointed out which need to be considered. The 235
assessment has been noted as suffering from a degree of subjectivity, and thus may not have a 236
good fit for legislation-related purposes, and its understanding/ use may be restricted to 237
medium-high skilled persons (i.e. not common users). Moreover, a limited availability of 238
information about how the scoring system actually works has been reported, as well as the 239
absence of major aspects, such as the availability of spare parts, and their cost. 240
Scoring systems should be neutral with regard to the target group concerned, and should 241
allow for different repair strategies to co-exist, as long as the environmental benefits of one 242
repair strategy over another (e.g. self-repair vs. repair by OEM qualified service engineers) do 243
not lead to conclusive results on which one should be preferred. 244
A more widely consensually-agreed methodology would be preferable, and that should be 245
ultimately based on the ongoing work that should result in EN standards – e.g., prEN 45554. 246
1.3 'Design for Repairability' tool 247
Starting from the approach developed by iFixit for phones and tablets and on the further work of 248
Flipsen et al. (2016)15
, key design criteria to assess the reparability of a product have been included in 249
the 'Design for Repairability' tool16
. This is a scoring system based on the assessment of 20 criteria 250
related to the ability of consumers to repair a product by themselves (i.e., 'Do-It-Yourself' repair). The 251
tool's aim is to assess brown goods (television sets, audio equipment, and similar household 252
appliances). A 0-1-2 rate is assigned to each criteria and the overall score is then normalised to a 0-to-253
10 basis. 254
8 out of 25 (32%) respondents to the initial questionnaire reported knowledge of the tool, up to a 255
certain point. However, only half of those were 'satisfactorily familiar' with the approach. 256
According to stakeholders, advantages of the 'Design for Repairability' tool include: 257
Ease of understanding and use. 258
On the other hand, weaknesses explicitly listed by stakeholders for the Design for Repairability tool 259
are: 260
It focuses on brown goods and is too general (no distinction between product categories); 261
Some criteria are over-specific or not neutral, and they are - for instance - oriented to repairs 262
made by consumers (whilst not all failures should be fixed by users, for safety reasons); also, 263
the criteria poorly represent B2B interests/ activities; 264
It mixes the evaluation of product design, service support, health & safety, commercial 265
aspects, and external factors such as 3rd
-party provision of repair information. 266
Some key aspects - in an objective way – are absent (e.g. ease of disassembly); 267
Criteria and means of verification are not always clearly defined, and results are heavily 268
influenced by operator skills; 269
It has been developed without the involvement of relevant industry sectors. 270
The overall opinion of stakeholders about the Design for Repairability tool is summarised below: 271
Some stakeholders considers that the Design for Repairability tool could be a good starting 272
point for evaluating the reparability of products, although some improvements have to be 273
applied. 274
15 Flipsen et al., 2016. Developing a Reparability Indicator for Electronic Products 16 www.repairability.org (accessed on 4
th June 2018)
12
Nevertheless, other stakeholders pointed out that the tool is not sufficiently robust, as well as 275
remarking that it is possibly over-simple and too general to be used for regulatory purposes. 276
1.4 Groupe SEB's 'Product 10Y Repairable' label 277
The 'Product 10Y Repairable' label is a mark that the Group SEB applies with the aim of promoting 278
the reparability of the small household appliances that they commercialise. The label aims to indicate 279
to consumers: 280
1. Proximity of authorised and trained repair centres; 281
2. Possibility to fully disassemble and reassemble the appliance without risk of damaging the 282
product; 283
3. Fast availability of spare parts (24-48 hours shipment time), over time (to be in stock for 10 284
years or more) and at an affordable cost (at a maximum, each part must cost less than 50% of 285
the total product cost). 286
8 out of 25 (32%) participants have declared a certain knowledge of the Groupe SEB's 'Product 287
Repairable' label, and 3 respondents declared a low knowledge. 288
According to stakeholders, advantages of the Groupe SEB's Product Repairable label include: 289
It is a label that ensures that all criteria are respected; 290
It is an easily understandable and usable approach, which is also in line with the Ecodesign 291
Directive's philosophy; 292
It takes into account availability and price of spare parts, and provides a commitment on the 293
period during which the product can be repairable and on the cost of repair during that period; 294
On the other hand, weaknesses explicitly listed for the Groupe SEB's "Product Repairable" label are: 295
It is a binary pass/fail concept so that no information is provided if the product is not 296
repairable, nor if it is not possible to differentiate between products for labelling purposes; 297
It is biased towards professional repair, it needs a strong network of repairers, and it does not 298
take into account aspects for other target groups (e.g. lower skill levels); 299
It is an internal procedure which cannot be used for external verification; 300
It is too general and simplistic and does not provide clear definitions. 301
The overall opinion of stakeholders regarding Groupe SEB's Product Repairable label is summarised 302
below: 303
Some stakeholders consider the label as a good starting point to assess the reparability of 304
products. 305
Other stakeholders consider that the method does not allow taking into account the 306
complexity of design and repair at a satisfactory level. 307
1.5 prEN 45554 - General methods for the assessment of the ability to repair, reuse 308
and upgrade energy related products 309
This is a draft standard which is currently developed by CEN-CENELEC's JTC10 'Energy-related 310
products – Material Efficiency Aspects for Eco-design', in response to the standardisation mandate 311
M/54317
. The standard, planned to be published in 2019, aims to provide a toolbox of parameters and 312
methods to assess the ability to repair, reuse and upgrade energy-related products (ErP). 313
17 M/543 COMMISSION IMPLEMENTING DECISION C(2015)9096 of 17.12.2015 on a standardisation
request to the European standardisation organisations as regards Ecodesign requirements on material efficiency
aspects for energy-related products in support of the implementation of Directive 2009/125/EC of the European
13
The last available draft18 includes: 314
Guidance for the identification of parts to be covered in the assessment; 315
A list of product-related parameters influencing repair, reuse and upgrade; 316
A list of parameters related to manufacturers' support to facilitate repair, reuse or to upgrade; 317
Examples of possible classification and rating criteria for such parameters 318
('Disassemblability'; Disassembly depth; Fasteners; Tools; Working environment; Skill level; 319
Diagnostic support and interface; Availability of spare parts; Availability of information; 320
Return models; Data transfer and deletion); 321
Quantitative assessment methods (Disassemblability index; Time for disassembly; Product 322
reparability index; Product reusability index; Product upgradability index). 323
The standard provides a general approach, which should be tailored to specific products. 324
15 out of 25 (60%) respondents are 'somehow familiar' with prEN 45554. According to stakeholders, 325
advantages of the prEN 45554 standard would include: 326
It provides a toolbox with qualitative and quantitative methods; 327
It addresses a comprehensive range of aspects and takes into account a wide range of 328
repair/upgrade scenarios and target groups; 329
It allows a framework for the selection of most appropriate criteria and methods to assess the 330
reparability and upgradability of a specific product; 331
It is technologically neutral and compatible with a scoring system concept; 332
Measurable parameters are proposed, and the classification methods are rather objective and 333
relatively simple to apply; 334
It has been broadly discussed with stakeholders from different organisation during the 335
standardisation processes. 336
On the other hand, weaknesses explicitly listed by stakeholders for the pr45554 standard are: 337
The standard is still in a draft form and unpublished, and that compliance criteria are not yet 338
well defined; 339
It is theoretical and needs to be tailored to product-specific levels, including the assignment of 340
scores and weights. 341
Little guidance for aggregation is provided. The overall opinion of the stakeholders regarding the 342
prEN 45554 standard is summarised below: 343
Results of the assessment must not be subjective, but instead must be repeatable and 344
reproducible. A solid standardisation base is needed to secure measurable and enforceable 345
legal requirements. 346
This seems the best ground to develop a high-level assessment framework and to set the basis 347
for the development of product-specific approaches. The majority of stakeholders support the 348
standardisation work done within CEN-CENELEC, although it is not clear if this could fit for 349
regulatory purposes at the time being. 350
Parliament and of the Council. Available at http://ec.europa.eu/growth/tools-
databases/mandates/index.cfm?fuseaction=search.detail&id=564# (last accessed on 25th
May 2018) 18 DOCUMENT NUMBER CEN-CLC JTC10/Sec/176/DC
14
However, the standard is still under development and has a too general approach. Further 351
investigation will be moreover needed to capture accurately the specificities of single product 352
groups. 353
The standard prEN 45553 regarding remanufacturing of ErP was also mentioned as a possible 354
source of inspiration for the development of a scoring system on reparability and 355
upgradability. 356
1.6 Other methods 357
Respondents to the questionnaire pointed out three additional methods which could be taken into 358
account for the development of a scoring system: 359
eDiM (ease of Disassembly Metric)19: this method provides a quantitative indication of the 360
time, and thus of the difficulty, needed to disassembly and reassembly a component/product. 361
The eDiM method is based on the Maynard Operation Sequence Technique (MOST) and 362
requires information about product components and adopted fasteners, which can be directly 363
verified within the product. The tasks necessary to disassemble and reassemble a particular 364
component/product are listed and reference time values (coming from MOST) are associated 365
to each of them, representing the effort needed to perform such operation. Although this 366
method offers a theoretically comprehensive metric regarding the "disassemblability" of a 367
product, it was mentioned that its implementation is complex. Moreover, this metric seems 368
difficult to be used as a standalone method since it does not represent entirely the repair 369
process (e.g. availability of spare parts is not considered). 370
Benelux Reparability study: this is a study (work ongoing and unpublished at the time of 371
preparing this report) which aims to provide an overview of relevant criteria related to the 372
reparability of products. The repair operation is divided into steps: product identification, 373
failure diagnosis, disassembly and reassembly, replacement of spare parts, restoration to 374
working condition. For the different steps of repair, the following types of criteria are 375
considered: information provision, product design, servicing. A score is assigned to each 376
repair step. The methodology, reported to be in line with current developments of the draft 377
prEN 45554, differentiates between who carries out the evaluation (e.g. professionals vs. 378
laymen) and has been tested in three case studies (i.e. two vacuum cleaners and one washing 379
machine). 380
1.7 Summary 381
From the feedback received from the respondents to the initial questionnaire, it seems that existing 382
methods to assess the reparability and upgradability of products provide a good starting point for the 383
development of a scoring system. However, especially some aspects deserve more attention: 384
Objectivity and reproducibility of assessment and verification methods; 385
Ease of understanding of system and reported information; 386
Representativeness of requirements for products at EU level; 387
Applicability to a broad scope of repairers (DIY, independent professionals, authorised 388
professionals, OEM). 389
Of the methods presented, respondents generally recommended to use the experience already gained 390
in prEN 45554 as much as possible in the development of the possible reparability scoring system. 391
Draft standard prEN 45554 is seen as the main reference, because it has been broadly discussed for 392
almost two years during the CEN-CENELEC standardisation process with many experts involved and 393
representing different stakeholders. This draft standard could provide a framework for the selection of 394
criteria and methods to assess the reparability and upgradability of products, which have to be tailored 395
to specific categories of products and which could potentially be used to develop a scoring system. 396
19 Vanegas P. et al. (2016) Study for a method to assess the ease of disassembly of electrical and electronic
equipment. JRC Technical Reports.
15
However, some of the respondents expressed their concerns about the possible use of the methods 397
presented, and any derived scoring systems for regulatory purposes. 398
399
400
16
2 DEVELOPMENT OF A SCORING SYSTEM FOR ASSESSING REPAIR AND 401
UPGRADE OF GENERIC PRODUCTS 402
As shown in Figure 1, a scoring system for assessing the reparability and upgradability of products is 403
founded on three pillars20
: 404
1. Key parameters for repair and upgrade; 405
2. Priority parts; 406
3. Scoring framework. 407
2.1 Key parameters for repair and upgrade 408
The first pillar of a scoring system for assessing the ability to repair and upgrade products is the 409
definition of the key parameters influencing repair and upgrade and that should be included in the 410
assessment framework. 411
The scientific/ technological literature provides examples of parameters that are used for assessing the 412
reparability and upgradability of products21,22,23,24,25,26
. Such parameters are also connected to the 413
concept of ease of disassembly, or 'disassemblability', i.e. the ability to disassemble a product. Product 414
disassembly can be defined as 'the non-destructive (reversible) taking apart of an assembled product 415
into constituent materials and/or components, in such a way that they could subsequently be 416
reassembled and made operational'27. The irreversible process is instead defined as dismantling in the 417
present context. Product disassembly can be differentiated as28
total (if concerning the whole product) 418
or selective (if concerning one or more materials and/or components). Ease of disassembly may cover 419
aspects such as29
: number, type and positioning of materials and/or parts; their identification and 420
accessibility; need of common/specialised tools; need for precision and force; time; ergonomics 421
issues. 422
An effort to harmonise such concepts has been undertaken by CEN-CENELEC Joint Technical 423
Committee JTC10 'Energy-related products – Material Efficiency Aspects for Ecodesign' with the 424
prEN 45554 standard 'General methods for the assessment of the ability to repair, reuse and upgrade 425
energy related products'. 426
Building on the information available, JRC defined a preliminary list of generic parameters 427
influencing repair and upgrade. These parameters were analysed and commented upon by the 428
stakeholders who responded to the initial questionnaire. Figure 2 and Figure 3 show how respondents 429
qualitatively evaluated the identified parameters, as relevant for repair and upgrade. The relevance of 430
the parameters was ranked by giving a score to each of the options (high = 3; medium = 2; low = 1; no 431
= 0), and it is reported in 432
20 Cordella, M.; Sanfelix, J.; Alfieri, F. (2018) Development of an Approach for Assessing the Reparability and
Upgradability of Energy-related Products. Procedia CIRP, 69, 888-892.
https://doi.org/10.1016/j.procir.2017.11.080 21 https://www.ifixit.com/Info/Repairability#Section_Overview 22 Flipsen et al., 2016. Developing a Reparability Indicator for Electronic Products 23 COMMISSION DECISION (EU) 2016/1371 of 10 August 2016 establishing the ecological criteria for the
award of the EU Ecolabel for personal, notebook and tablet computers (available at: http://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016D1371&from=EN) 24 IEEE 1680.1 Standard for Environmental Assessment of Personal Computer Products 25 1680.3-2012 - IEEE Standard for Environmental Assessment of Televisions 26 1680.1/Draft_23, March 7, 2017 Draft Standard for Enviromental Assessment of Personal Computers
Products Including Notebook Personal Computers, Desktop Personal Computers, Slate/Tablets, Small Scale
Servers, Signage Displays and Personal Computer Monitors 27 Based on BS 8887-2:2009 and EN 62542:2013 28 A. Desai, A. Mital / International Journal of Industrial Ergonomics 32 (2003) 265–281 29 T.F. Go et al. / Journal of Cleaner Production 19 (2011) 1536e1546
17
Table 2. The results showed in table 2 are merely indicative of the relevance of each parameter on the 433
basis of the feedback received from stakeholders. 434
It can be observed that all parameters are relevant for both reparability and upgradability:The most 435
important parameter for reparability of products, according to the feedback received, is the availability 436
of spare parts. This is followed by: ease of access to parts, information on the disassembly sequence, 437
and availability of information. Working environment is the least important parameter, but still 438
relevant for repair. The results are in line with the outcomes of the behavioural study on 'Consumers' 439
engagement in the Circular Economy' (commissioned by DG JUST, now in its final stage), indicating 440
that spare parts, availability of repair services, and availability of information are important factors for 441
users. 442
The most important parameter for the upgradability of products, according to the feedback received, is instead the 443 instead the availability and ease of installation of software and firmware (where applicable). This is followed by: ease 444 followed by: ease of access to parts, provision of diagnostic support and interfaces, availability of information, and 445 information, and availability of spare parts. The relative importance of the disassembly sequence and other 446 other parameters related to disassemblability are rated lower in the case of upgradability than for reparability. The 447 reparability. The working environment is the least important parameter, but is still relevant for repair. 448
Table 3Table 2 sums up the respective rankings of parameters for reparability and upgradability, and 449
Table 3 summarises the input received with regard to the assessment and verification of these 450
parameters. 451
452
453
Figure 2 Relevance of parameters influencing reparability on the basis of the input received from the respondents to 454 the initial questionnaire 455
456
18
457
Figure 3 Relevance of parameters influencing upgradability on the basis of the input received from the respondents 458 to the initial questionnaire 459
460
Table 2 Ranking of the parameters based on the analysis of the input received from the respondents to the initial 461 questionnaire 462
463 464
Table 3 Technical parameters generally influencing repair and upgrade of products 465
Parameter Technical considerations
1. Disassembly sequence Assessment and verification based on documentation of
disassembly steps in instruction manuals and/or other on-line
information systems (e.g. I4R platform for recyclers).
Penalisations to apply in case of destructive disassembly of
some parts.
Alternatively, calculation of disassembly times based on
standard time units (e.g. MOST, eDIM, iFIXIT). In case of data
gaps, time to be determined through field research.
2. Type, number and visibility
of fastenings and connectors
Assessment and verification based on information provided by
the manufacturer (e.g. with illustrated disassembly instructions).
Information could be provided in manuals and/or other on-line
platforms. A categorisation is required, which should be
Availability of spare parts 2.9 2.7 Availability and ease of installation of software and firmware
Ease of access to parts 2.8 2.7 Ease of access to parts
Disassembly sequence 2.7 2.5 Provision of diagnostic support and interfaces
Availability of information 2.7 2.5 Availability of information
Provision of diagnostic support and interfaces 2.6 2.5 Availability of spare parts
Availability and ease of installation of software and firmware 2.5 2.2 Type, number and visibility of fastenings and connectors
Type, number and visibility of fastenings and connectors 2.5 2.2 Level of skills required to undertake the operations
Tools needed (availability, complexity, cost) 2.4 2.2 Disassembly sequence
Level of skills required to undertake the operations 2.4 2.2 Tools needed (availability, complexity, cost)
Working environment 1.6 1.5 Working environment
Reparability Upgradeability
19
performed according to prEN 45554.
Marking was also suggested to improve visibility of fasteners.
3. Tools needed (availability,
complexity, cost)
The manufacturer should document the type of tools needed to
repair the product. The use of standard/basic tools should be
granted, but a penalisation applied when proprietary tools are
needed. A categorisation is required, which should be done
according to prEN 45554.
Other aspects suggested for possible consideration are cost and
complexity.
4. Ease of access to parts This element is considered to be a difficult parameter to assess
and verify, as it also requires the satisfactory definition of
'priority part', which is also very much related to other
parameters (1, 2, 3, as well as identification of parts). The
measurement of standardised time units could be used.
5. Working environment (e.g.
home, professional repair
site, manufacturing plant)
The classification used in prEN 45554 was suggested for
assessment and verification, although some refinements and
clarifications may be needed to allow verification.
Safety issues and type of operations should be considered in the
classification.
Moreover, it was suggested its possible split into 'repair at home'
and 'repair by professionals', which would require the definition
of which operations can be performed by a user.
6. Level of skills required to
undertake the operations
Assessment and verification based on documentation provided
by the manufacturer indicating which operations can be
performed by the users.
7. Provision of diagnostic
support and interfaces
The classification used in prEN 45554 was suggested for
assessment and verification. Information to be provided by the
manufacturer, e.g. troubleshooting, manual or portals for
authorised repairers.
The interface is specific of the product design.
8. Availability of spare parts Information by the manufacturer about the availability of spare
parts in years, complemented by verification of actual
availability.
The definition of 'parts that are more likely to fail' is needed.
Price of spare parts and their delivery time are also important,
although these might perhaps fit better as minimum
requirement.
9. Availability and ease of
installation of software and
firmware
Declaration by the manufacturer about the availability of
software and firmware in years, complemented by verification
of actual availability.
10. Availability of information
(e.g. repair and/or upgrade
manuals, exploded
diagrams)
Assessment and verification based on the public information
supplied by the manufacturer (e.g. manuals, on-line platforms,
manufacturer website), complemented by audits for assessing
the availability of restricted information.
Classification of information for different users is needed, as
presented in prEN 45554.
466
20
In addition to the parameters discussed above, the repair and upgrade of products can also be limited 467
by other aspects (e.g. purchase price of the product and labour cost of repair, demand for new vs. 468
repaired/upgraded products, guarantee issues, support networks facilitating the repair process, 469
business models, compatibility issues). Stakeholders were asked to provide scenarios/conditions for 470
these aspects, where repair and upgrade operations are more likely to occur. Table 4, below, compiles 471
this initial additional feedback from stakeholders. 472
Guarantee issues related to the repair of products is an aspect that deserves more discussion (see 473
Section 2.3) since its inclusion in a scoring system could be a relevant factor to promote the effective 474
repair and durability of products. 475
Additional parameters that could be of potential interest for discussion (see Section 2.3) are: 476
1. Return of models 477
2. Data transfer and deletion 478
3. Safety issues 479
4. Availability of OEM qualified service engineers. 480
5. Ease of restoring product to working condition after repair. 481
Some aspects highlighted by stakeholders, such as emotional attachment to products, attitude and 482
education of consumers, repair costs, tax exemptions and labour cost reductions are considered to be 483
mainly related to socio-economic issues, which can be difficult to integrate into this type of study, i.e., 484
to explicitly work to develop a potential scoring system. 485
21
Table 4 Other factors influencing repair and upgrade according to stakeholders 486
Aspects Favourable conditions for Repair Favourable conditions for Upgrade Other comments
Functional,
technological and
behavioural factors
(e.g. demand for new
vs. repaired/upgraded
products)
Conscious design, also aimed at
reducing the complexity of
products, using resistant
materials, and slowing down the
development and innovation
cycles (especially for products
where design and fashion are not
important)
Functionality of the product must
be fully recovered after repair
Emotional attachment and high
reliance on the functions of the
product
Other factors (e.g. age of user,
relationship with technology,
functionalities offered by new
technologies, attitude towards
new vs. conserving the old,
social pressures).
Provision of information about
the product, and web-based
access to such information
Education about material
efficiency issues
Conscious design, also aimed at
reducing the complexity of
products and customising products
(especially for fast moving
products where functions can be
more important than aesthetics)
Knowledge/information of
possibility to upgrade and
availability of software upgrades
Upgrade must not negatively affect
other functionalities of the product
Emotional attachment and high
reliance on the functions of the
product
Other factors (e.g. age of user,
relationship with technology,
functionalities offered by new
technologies, attitude towards new
vs. conserving the old, social
pressures).
Provision of information about the
product, and web-based access to
such information
Education about material efficiency
issues
Not as important as other factors.
More important for upgrade than
for repair
Economic factors
(e.g. purchase price
for product and spare
Purchase price, which is
associated with the quality of the
product
Low prices for software/parts
upgrades, compared to the product
purchase price
Very important for repair, not so
relevant for upgrade
Consumers would be generally
22
Aspects Favourable conditions for Repair Favourable conditions for Upgrade Other comments
parts, labour costs) Spare parts not more expensive
than 20% of new product.
Tax exemption for repair
activities
Offering products as service, (i.e.
leasing)
EPR (extended product
responsibility) fees used to
support the repair sector over and
above the recycling sector (in
line with waste hierarchy)
Tax exemption for upgrade
activities
Offering products as service, (i.e.
leasing)
EPR fees used to support upgrading
activities over and above the
recycling sector (in line with waste
hierarchy)
willing to repair their products
when the total repair cost is lower
than 33% of the purchase price for
a new appliance. 10% of
consumers would accept repairing
a product when the total repair
cost is between 33%-50% of
purchase price for a new
appliance. Repair would not be
likely when the total repair cost is
above 50% the price of a new
appliance30
Organisational factors
(e.g. access to
professional repair
services or support
networks)
Official registration platform of
professional repairers (receiving
a licence to repair)
Support awareness and education
to final users in circular economy
aspects like repair
Manufacturer support network
easily accessible
Availability of OEM qualified
service engineers
Expand repair options beyond
manufacturer authorised
networks (e.g. non-profit
initiatives and DIY)
Support awareness and education to
final users in circular economy
aspects like repair
Manufacturer support network
easily accessible
Expand repair options beyond
manufacturer authorised networks
(e.g. non-profit initiatives and DIY)
Proximity of upgrade providers
New business models: product as a
service and repair as a business
strategy
Consumers sometimes do not
know where to take their broken
appliance to get them repaired
Manufacturers or their authorised
repairers can provide official
services, but these may be more
expensive than independent
repairers
Companies should work together
with independent repairers to
ensure that the repairs are done in
a responsible way
30 Emission Cash, 2012, "La mort programée de nos appareils" http://www.inexplique-endebat.com/article-cash-investigation-la-mort-programmee-de-nos-appareils-le-
lobby-du-sel-106398577.html (accessed 22/05/18)
23
Aspects Favourable conditions for Repair Favourable conditions for Upgrade Other comments
Proximity of repair providers
Limiting time and cost of repairs
for the typical faults
New business models: product as
a service and repair as a business
strategy
Legal factors (e.g.
legal guarantee,
commercial
guarantee31, liability
issues)
Provision of an additional
commercial guarantee (X years):
in order to support repair, the
commercial guarantee could
include a 'hierarchy of remedies'
with for example product repair
as first option ('commitment to
repair for free') and, only if the
producer determines that the
repair is impossible or more
expensive than the other
remedies, the product will be
either replaced or refunded.
The commercial guarantee,
covering the entire product or
only specific parts, can either be
included in the price of the
product or purchased at an extra
cost. In the latter case, cheaper
guarantee extensions could come
The guarantee should cover also
the use of the product after its
upgrade
Business models (service models)
It is important to understand how
repair operations can affect
consumer safety and liability.
Companies should get more
involved and contribute to the
definition of which repairs can be
done by whom
Manufacturers should work
together with repairers to support
repair rather than use liability as
an excuse
According to the Consumer Sales
and Guarantees Directive
1999/44/EC, a minimum of 2
years legal guarantee must be
offered by the seller for any
product put on the market. When
manufacturers cover only 1 year
31
As defined in the Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights, the commercial guarantee (often also called
(extended) 'warranty') means any undertaking by the trader or a producer (the guarantor) to the consumer, in addition to his legal obligation relating to the guarantee of
conformity, to reimburse the price paid or to replace, repair or service goods in any way if they do not meet the specifications or any other requirements not related to
conformity set out in the guarantee statement or in the relevant advertising available at the time of, or before the conclusion of the contract.
24
Aspects Favourable conditions for Repair Favourable conditions for Upgrade Other comments
with discounts for official repairs
and create more favourable
conditions for repair.
Transparency of rules on how 3rd
party repairs can affect legal and
commercial guarantees
Provision of a warranty for
repaired products
Possibility to denounce cases
where a guarantee has not been
honoured
Mandatory information about
availability and price of spare
parts
Guarantees facilitating the
handling of issues related to
damages during shipments
Business models (service
models)
of the guarantee, the remaining
time period is under the sole
responsibility of the seller.
Anecdotal evidence shows that
consumers can encounter some
difficulties in implementing their
legal guarantee rights. For
example, according to the
information from 'trop vite usé'32
most of the complaints from
mobile phones concerned
appliances that were less than 2
years old. 70% of the users who
reported a complaint tried to have
their mobile phone repaired but
only 7% succeeded. The study
also reports that the greatest
complaint from people who have
repaired their appliances is that
the same problems persist even
once the products are returned,
often related to issues within
electronics circuits (e.g. printed
circuit board [PCBs], which some
companies do not consider as
'their' problem).
487
32 https://www.test-achats.be/trop-vite-use# (accessed 23/05/2018)
25
2.2 Priority parts 488
In this context, the term 'priority parts' refers to those parts with a higher need/ importance/ frequency 489
to be repaired and/or upgraded. In products with a large list of parts, it might be indeed relevant to 490
make a selection parts to reduce the complexity of the assessment and focus only on those that are 491
more prone to be repaired or upgraded. 492
Several aspects could be considered for the definition of priority parts. Figure 4 and Figure 5 show the 493
indications gathered from the participants in the initial questionnaire regarding the relevance of 494
different aspects. From the two figures it can be seen that: 495
The failure of parts is in general indicated as the most important aspect for repair, which is 496
followed by the functional importance of the part itself. The difficulty to disassembly parts, 497
expressed in this case in terms of steps, is also somehow important but is ranked lower. 498
Stakeholders ranked economic and environmental aspects per se with lower importance. 499
In the case of upgradability, the differences in importance are fuzzy between frequency of 500
upgrade, functional importance, economic value and the difficulty to disassemble parts, 501
expressed in this case in terms of steps. The relative importance of the frequency of 502
failure/replacement is lower compared to reparability, whilst it becomes slightly higher for the 503
economic value. Stakeholders also gave a low ranking to environmental aspects per se. 504
505
506
Figure 4 Relevance of different aspects for the definitions of priority parts for repair 507
26
508 Figure 5 Relevance of different aspects for the definitions of priority parts for upgrade 509
510
2.2.1 Frequencies of failure and upgrade 511
The frequency of the failure of parts is in general seen by stakeholders as the most important aspect 512
for determining priority parts, with respect to reparability issues. This is also related to reliability 513
concepts defined as the mean time between failures. Nevertheless, the frequency of failures can only 514
be evaluated when market and users have gained experience with a certain product and typical repair 515
requests have been identified. 516
According to the feedback received by stakeholders, most companies aim to have no more than a 517
small fraction of products (e.g. less than 3%) failing during warranty periods, because of cost reasons. 518
Data on failure rates should thus be collected after the warranty period. 519
The frequency of upgrade of parts and software is highly relevant for the upgradability of products 520
and it can to some extent determine the likelihood of obsolescence of the product. The frequency of 521
upgrade is not a criterion in itself, but is reflected by its consequence in factors such as rapid 522
technology change, changes in the use given to a part, design and specifications of a product. 523
524
2.2.2 Functional importance 525
If a part (either hardware or software) is important for the functioning of the product, it should have 526
high priority. The part is instead less relevant if related to secondary functions. Functional importance 527
of parts is nevertheless relevant only if combined with likelihood of failure/upgrade. 528
From a technical point of view, the functional importance of parts could be for instance categorised as 529
follows: 530
1) The part does not affect the functioning nor the performance of the product 531
2) The part can affect the performance of the product 532
3) The part can affect the functioning of the product. 533
27
User experience and more subjective elements such as aesthetics and personalisation could also play a 534
role, especially for upgradability. However, according to the feedback received, lists of functional 535
parts cannot be generalised and could also depend on the market strategy of manufacturers. 536 537
2.2.3 Price of parts and cost of repair/upgrade 538
According to some of the feedback received, the cost of the spare part should not define how 539
important it is for the product (e.g. although carbon brushes are very cheap, a washing machine cannot 540
work without them). 541
On the other hand, if a part is likely to fail and is key for the functioning of the product, the price of 542
replacement should not be too high: the lower the price, the higher is the likelihood of repair. The 543
price for repair is highly dependent on the labour costs. 544
For upgrade it was reported by some stakeholders that the economic value is not a good indicator, 545
since this could penalise high-quality products and ICT products, where subsequent important 546
upgrades (software) can often come for free. 547
548
2.2.4 Environmental impacts of parts 549
Although considered important for the sustainability of products, some concerns were received from 550
stakeholders: 551
Environmental considerations can be relevant only if combined with the failure/upgrade 552
likelihood. Repair and upgrade hold the potential to increase the lifetime of products and 553
reduce their impacts. However, the repair/upgrade of products is often driven by other socio-554
economic factors; 555
It could result in false incentives for repair and upgrade, for instance, as a consequence of the 556
integration of many functions in circuit boards, which would be detrimental for the economic 557
feasibility of repair. 558
There is no commonly agreed or standardised method to analyse the environmental impact of 559
appliances. 560
561
2.2.5 Disassembly of parts and reinstallation of software 562
Split views were registered for this aspect: 563
On the one hand, there are those who think that the difficulty of disassembly, for instance 564
expressed in terms of disassembly steps, is important to identify priority parts. However, it 565
has to be considered that different kinds of appliances exist. For instance, a freestanding 566
fridge will have fewer steps to access a certain part than for a built-in fridge. 567
On the other hand, there are those who do not consider the difficulty to undertake disassembly 568
relevant in assessing the importance of parts to be repaired/ upgraded. This could be viewed 569
more as an outcome of the assessment, and not as an element to decide what should be 570
assessed, since the latter depends mainly on the frequency of failure/upgrade. 571
Some stakeholders suggested referring to the measurement of disassembly and reassembly times 572
based on standard time units instead of considering disassembly steps only. 573
574
2.2.6 Additional considerations 575
The feedback received from stakeholders recommends that ad-hoc lists of priority parts need to be 576
determined: 577
On a product-by-product basis and taking into account for different models of the same 578
product on the market, 579
28
After engaging with manufacturers, repairers and other relevant experts 580
Including expert-judgement, safety and functional considerations, 581
Taking into consideration the likelihood that a replacement may be needed for repairing or 582
upgrading the product, and the conditions under which a given part is deemed to be a priority 583
part (e.g. batteries with a life below X recharge cycles, electric motors that last below X hours 584
of operation), 585
Limited accessibility should be considered for certain features (e.g. water tightness and 586
climate resistance). 587
Moreover, additional aspects should be taken into account when determining priority parts with 588
regard to upgradability: 589
The complexity of the product, since the likelihood of the need to upgrade appliances can 590
increase with the complexity of their design 591
Evaluation of parts for upgrading is expected to focus mainly, but not exclusively, on parts 592
subject to rapid technology changes, or changes in use profiles over the lifetime of the 593
product. Specific attention, however, should be given to the role of software and firmware. 594
For laptops, the operating system is the most important part which determines functionality 595
and which requires frequent updating. Hardware parts such as storage chips can be relevant in 596
cases below a certain minimum configuration. 597
Parts that are planned to be upgraded and have standardised interfaces in typical products 598
should have the highest priority. However, it is difficult to predict, at the time of placing an 599
appliance on the market, what will be the future updates. Updates can be to an extent 600
predicted based on market and user experience with the product, or similar products. 601
602
29
2.3 Scoring framework 603
The parameters identified in the previous sections can be used to assess the reparability and 604
upgradability of products through pass/fail requirements and scores. This requires the definition of 605
classification/rating criteria to use for the evaluation of single parameters. An example is provided in 606
Table 5 which presents three classes of scores: 0 (negative attribute), 0.5 (neutral attribute), 1 607
(positive attribute). Scores could be expressed in a different scale (e.g. 0 to 1, 0 to 5, or 0 to 10), or 608
weighted (if some criteria are considered to be more important) and – optionally - aggregated into one 609
or more indices. 610
611
Table 5 Examples of possible rating criteria for the evaluation of parameters 612
Parameter Description of the proposed rating criteria (illustrative purposes only)
Availability of
spare parts
Score:
0 points: Original spare parts are not available to replace priority parts
0.5 points: Original spare parts are available for less than 5 years after
purchase of the product, and not for all priority parts
1 point: Original spare parts are widely available to replace all priority
parts. Availability is ensured for at least 5 years following the end of
production of the model
Types of tools
needed
Score:
0 points: Advanced specialised tools (e.g. a soldering iron, proprietary
screwdrivers) are needed to disassemble priority parts
0.5 points: Specialized tools (like screwdrivers, electric drill and small
magnets) are needed to disassemble priority parts
1 point: No tools or only basic tools (e.g. scissors, flathead and cross
recess (Phillips) screwdrivers) are needed to disassemble priority parts
613
30
2.3.1 Classification and rating of individual parameters 614 Different options for the generic classification of individual parameters are noted in 615
Table 6, and are taking into account discussions held for the development of prEN 45554 and the 616
feedback received from stakeholders. A rating score could be assigned to each class and for each 617
parameter, and could also be 'normalised', as indicated in the table. For some parameters it could be 618
more relevant to have minimum pass/fail requirements, or the reporting of the underlying information 619
(e.g. 'spare parts available for X years'). The classification and rating options shown in Table 6 refer to 620
generic products, and would have to be tailored to specific product group(s) and related priority 621
part(s), if they were to be used in practice. Moreover, to ensure a level playing field across 622
manufacturers, it was indicated by stakeholders that criteria should: 623
1. Be measurable & enforceable in an objective way (i.e. not interpretable in different ways 624
depending on who is doing the evaluation) 625
2. Not be biased towards particular repair business models; 626
3. Avoid possible trade-offs (e.g. highly durable products may be less repairable). 627
628
Table 6 Classification and rating criteria for different parameters 629
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
1) Disassembly
sequence ('DS')
A) Based on number of steps required to remove a
part from a specific product:
I. Less than X steps
II. Between X and Y steps
III. More than Y steps
Favourite option for the study team
since objective and practical.
Disassembly steps could be
replaced by disassembly time (e.g.
based on eDiM).
B) Semi-quantitative based on design characteristics:
I. Can be disassembled into individual parts.
Time required to do it is low.
II. Can be disassembled into individual parts.
Time required to do it is acceptable.
III. Can be disassembled into individual parts
but time taken is very long.
IV. Can be disassembled into individual parts
but some critical parts are gathered together
in blocks that cannot be disassembled.
V. Cannot be disassembled into individual
parts or some parts are likely to be broken
during the process.
Alternative classification, more
complete but including elements
that risk being more subjective
C) Percentile score within known spread:
Score = (DSmax – DSi) / (DSmax –
DSmin)
Where:
DSmax is the performance of the worst
product (e.g. longest disassembly
sequence or time)
DSmin is the performance of the best
product (e.g. shortest disassembly
sequence or time), which could be 1 as
a mimimum value
DSi is the performance of the analysed
Possible normalisation approach to
refer class scores to a number from
0 to 1
31
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
product
2) Type, number
and visibility of
fastenings and
connectors
A) Semi-quantitative based on type of fastenings and
connectors:
I. Reusable fasteners are used: the original
fasteners can be reused for the new part or
the fastener is supplied with the part
II. Removable fasteners are used: the original
fasteners are not reusable, but can be
removed without causing damage or leaving
residue which precludes reassembly (in case
of repair or upgrade) or reuse of the
removed part (in case of reuse)
III. Non-removable fasteners are used: the
original fasteners are not removable or
reusable
Favourite option for the study team
since objective and practical.
Visibility could be less relevant if
indicated in repair manuals
B) Semi-quantitative based on type and number of
fastenings and connectors:
I. Fastenings are standard/widely available
and clearly visible and they are a limited
number so that time required for
disassembly is low
II. Fastenings are standard/widely available
and clearly visible and they are a reasonable
number so that time required for
disassembly is acceptable
III. Fastenings are standard/widely available
and clearly visible but they are so numerous
that the time required for disassembly is
very long
IV. Fastenings used are standard/widely
available but some are not clearly visible
V. Proprietary or rare fastenings are used
Alternative classification, more
complete but including elements
that risk being subjective
C) Semi-quantitative based on type, number and
location of fastenings and connectors:
I. Fasteners/connectors are reversible, easy to
localise, and less than X in number OR only
reversible 'click' fastenings/connectors are
used and easy to localise
II. Fasteners/connectors are reversible, easy to
localise, and more than X in number
III. One or more non-reversible
fastenings/connectors (e.g. glue, soldering,
connectors that break when disassembled)
are used OR reversible
fastenings/connectors are used but they are
not immediately visible.
Alternative classification, more
complete but including elements
that risk being more subjective
D) Percentile score within known spread:
Score = Fi / Fmax
Where:
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
32
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
Fmax is the score corresponding to the
best classification achievable for the
product (in terms of identification and
removal of fastenings/connectors)
Fi is the score corresponding to the
class of the analysed product
3) Tools needed
(availability,
complexity, cost)
A) Semi-quantitative based on type and availability
of tools:
I. Common tools: Repair/upgrade operation
feasible without any tools, or with tools that
are supplied with the product, or with
common general purpose tools
II. Product-specific tools (if needed):
Repair/upgrade operation feasible either
with no specific tools, or a finite list of
specific tools
III. Other commercially available tools (if
needed): Repair/upgrade operation feasible
without the use of proprietary tools
IV. Proprietary tools: Repair/upgrade process
feasible only with one or more proprietary
tools, which are not available to the general
public.
V. No tools: Repair/upgrade operation is
unfeasible with existing normally-available
tools
Favoured option for the study team
since objective and practical.
Visibility could be less relevant if
indicated in repair manuals
B) Semi-quantitative based on type, availability,
cost, and number of tools:
I. Maximum X types (e.g. 1, 2) of
standard/common tools are required
II. A limited number of tools are required,
some of which are expensive
III. Many different type of widely available
tools are required, and some of them are
expensive
IV. Special tools are required that are not easy
to obtain
V. Proprietary tools are required.
Alternative classification, more
complete but including elements
that risk being more subjective
C) Percentile score within known spread:
Score = Ti / Tmax
Where:
Tmax is the score corresponding to the
best classification achievable for the
product (in terms of type, availability
and cost of tools)
Ti is the score corresponding to the
class of the analysed product
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
33
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
4) Ease of access
to parts
A) See Parameters 1, 2 and 3 Although important, this parameter
is considered the sum of the
disassembly sequence, fastenings
and tools.
Time for disassembly could be an
alternative and overall indicator, as
described for parameter 1.
However, this could add significant
complications, possibly also in
terms of assessment and
verification.
B) Semi-quantitative based on design characteristics:
I. All the priority parts are easy to access
(quick access, few steps required)
II. All priority parts can be accessed and
require a limited number of steps/time
III. All priority parts can be accessed but some
of them require too many steps
IV. All priority parts can be accessed but it is
difficult to know how without instructions
due to the complexity of the product design
V. Some priority parts are not easy to access
because glue or other permanent assembly
methods are used
Risk of subjective classification
C) Percentile score within known spread:
Score = Ai / Amax
Where:
Amax is the score corresponding to the
best classification achievable for the
product (in terms of ease of
accessibility)
Ai is the score corresponding to the
class of the analysed product
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
5) Working
environment (e.g.
home,
professional
repair site,
manufacturing
plant)
A) Semi-quantitative based on conditions of work:
I. General environment: repair/upgrade can be
performed where the product is in use
without special conditions
I. Workshop environment: repair/upgrade
cannot be performed in the environment
where the product is in use but does not
require a production site environment
II. Production site environment: repair/upgrade
can only be carried out in an environment
that is comparable with the environment in
which the product was manufactured
Favoured option for the study team
since it is objective and practical.
B) Semi-quantitative based on type of repair/upgrade
process:
I. Repair/upgrade can be easily done at home
Alternative classification, that
includes elements that risk being
more subjective.
34
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
II. Professional repair sites are required only
for the repair/upgrade of parts that involve
safety aspects
III. Professional repair sites are required for the
repair/upgrade of some priority parts
IV. Repair/upgrade of all priority parts can be
done only in the manufacturing plant
V. Repair/upgrade of parts can be done only in
the manufacturing plant
C) Percentile score within known spread:
Score = WEi / WEmax
Where:
WEmax is the score corresponding to the
best classification achievable for the
product (in terms of type of
environment)
WEi is the score corresponding to the
class of the analysed product
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
6) Level of skills
required to
undertake the
operations
A) Semi-quantitative based on skills required:
I. The repair/upgrade process can be carried
out by a person without any specific
experience or related qualifications
(layman)
II. The repair/upgrade process can be carried
out by a person with a general knowledge of
basic repair/upgrade techniques and safety
precautions (generalist, if needed).
III. The repair/upgrade process has to be carried
out by a person with specific training and/or
experience related to the product category
concerned (independent expert)
IV. The repair/upgrade process has to be carried
out by a person who is directly trained and
audited by the manufacturer (authorised
expert)
V. The repair/upgrade process has to be carried
out by the manufacturer
The repair/upgrade process is not feasible
with any existing skill
Favoured option for the study team
since it is objective and practical
B) Semi-quantitative based on skills required:
I. Reparable/upgradable by everyone with a
basic knowledge
II. Reparable/upgradable by everyone after
tutorial watching or documentation reading
III. Reparable/upgradable only for trained
specialists.
Alternative and simpler
classification
35
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
C) Percentile score within known spread:
Score = Si / Smax
Where:
Smax is the score corresponding to the
best classification achievable for the
product (in terms of skills needed)
Si is the score corresponding to the
class of the analysed product
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
7) Provision of
diagnostic
support and
interfaces
A) Semi-quantitative based on type of diagnosis
interface:
I. Visually intuitive interface: a repair/upgrade
process that can be carried out by just a
visual interface that can be understood
without the need for any supporting
documentation or software
II. Coded interface with public reference table:
a repair/upgrade process that can only be
carried out with supporting documentation
or software, and through reading and/or
entering codes which are available in a
table, which is supplied with the product
and / or publicly available
III. Publicly available hardware / software
interface: a repair/upgrade process that can
only be carried out through the use of
hardware and software which is publicly
available (This can include hardware
functionality testing software tools
developed by a third party, provided the
software tools are publicly available and the
manufacturer provides information on their
accessibility and applicable updates. The
product can be equipped with an
appropriate interface for hardware and
software to do fault diagnosis and reading,
adjustment or resetting of parameters or
settings (e.g. external memory device; data
cable connection; or from a remote source
using a network connection). The port, slot,
or connector that is used for the hardware
and software interface is accessible without
tools)
IV. Proprietary interface: a repair/upgrade
process that can only be carried out using
proprietary tools for diagnosis, change of
settings or transfer of software, which are
not included with the product, that process
is categorised as needing a proprietary
interface
V. Not possible with any type of interface: a
repair/upgrade process that cannot be
carried out with any type of interface
Favoured option for the study team
since objective and practical
36
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
B) Semi-quantitative based on type of diagnostic
equipment:
I. Only basic and common diagnostic
equipment is required (e.g., easily-
obtainable polymeters and similar)
II. Diagnostic equipment and interfaces are
standard/common and are required for a
limited type of reparations
III. Diagnostic equipment and interfaces are
standard/common but it is required for most
of the reparations
IV. Expensive (not special) diagnostic
equipment/interfaces required
Special/proprietary diagnostic equipment is required
Alternative classification but more
ambiguous/subjective
C) Semi-quantitative based on type of diagnosis
interface and manufacturer support:
I. Manufacturer support (e.g. website,
troubleshooting FAQ, help line) available,
and repair/upgrade can be carried out with
the use of hardware and software which is
publicly available
II. Repair/upgrade can be carried out with the
use of hardware and software which is
publicly available
III. Repair/upgrade can be carried out through
the use of hardware and software which is
proprietary
IV. No diagnosis interface nor support
Alternative classification including
also manufacturer support
D) Percentile score within known spread:
Score = DIi / DImax
Where:
DImax is the score corresponding to the
best classification achievable for the
product (in terms of intuitiveness and
accessibility of interface and support
tools required)
DIi is the score corresponding to the
class of the analysed product
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
8) Availability of
spare parts
A) Semi-quantitative based on the availability of
spare parts to target groups:
I. Spare parts are publicly available to all
interested parties
II. Spare parts are available at least to
independent repair service providers
III. Spare parts are available at least to
manufacturer-authorised repair services
IV. Spare parts are available to the
manufacturer only
Favoured option for the study team
since it is objective and practical.
Also time considerations can be
integrated
37
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
V. No spare parts are available
B) Semi-quantitative based on the availability over
time of spare parts:
I. The required spare part(s) is/are available
for a duration of time post-manufacture that
reflects the expected maximum useful life
of the product (long-term).
II. The required spare part(s) is/are available
for a duration of time that reflects the
expected average useful life of the product
(mid-term)
III. The required spare part(s) is/are available
for 2 years after the time of sale of the
product (short-term)
IV. The required spare part(s) is/are available at
the time of sale, but the duration of
availability cannot be determined.
Complementary, if not integrated.
C) Semi-quantitative based on the availability of
spare parts, including also time and cost
considerations:
I. Spare parts are available for 10 years or
more, and price is reasonable compared to
the product price
II. Spare parts are available for 5-9 years, and
price is reasonable compared to the product
price
III. Spare parts are available for less than 5
years, and price is expensive compared to
the product price
IV. Spare parts are available only for priority
parts
V. Spare parts are not available
Alternative classification, more
complete but with risk to be
subjective.
D Percentile score within known spread:
Score = TGi / TGmax x Di / Dmax
Where,
TGmax is the score corresponding to the
best classification achievable for the
product (in terms of target group)
TGi is the performance of the product
(in terms of target group)
Dmax is the score corresponding to the
best classification achievable for the
product (in terms of availability of
spare parts)
Di is the score corresponding to the
class of the analysed product (in terms
of availability of spare parts)
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
9) Availability
and ease of
installation of
A) See parameter 8 Favoured option
38
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
software and
firmware
B) Semi-quantitative based on the availability of
software/firmware for a certain time and cost:
I. Software/Firmware updates are periodically
available; bug/vulnerability fixing is free of
charge for 5 years or more. Upgrades for
improvements have a reasonable price or
are free of charge.
II. Software/Firmware updates are periodically
available; bug/vulnerability fixing is free of
charge for 5 years or more. Upgrades for
improvements are expensive.
Software/Firmware updates are periodically
available, bug/vulnerability fixing is free of
charge for 5 years or more
III. Software/Firmware support is offered free
of charge for critical bugs/vulnerabilities
only and for less than 3 years
IV. Software/firmware support is not offered
Alternative option
C) Semi-quantitative based on the availability of
information to target groups:
I. Software and firmware is publicly available
to all interested parties
II. Software and firmware is available only to
authorized experts and manufacturers
Possibility to differentiate between
software and firmware offered 'free
of charge' vs. 'at a cost' and
between automatic download from
the internet vs. multi-step
procurement process
D) Percentile score within known spread:
Score = Ti / Tmax
Where,
Tmax is the score corresponding to the
best classification achievable for the
product (in terms of type, availability
and cost of tools)
Ti is the score corresponding to the
class of the analysed product
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
10) Availability
of information
(e.g. repair and/or
upgrade manuals,
exploded
diagrams)
A) Semi-quantitative based on comprehensiveness of
available information:
I. Complete information available: A repair,
reuse or upgrade process, for which all
relevant information is available. Complete
information may include circuit board
schematics of electronic parts, functional
specification of parts (e.g. resistance value
of resistors, viscosity grade of lubricants)
and information on compatibility of parts
with other products.
II. Comprehensive information available: A
repair, reuse or upgrade process, for which
not all relevant information is available as
described above, but for which reasonably
comprehensive information is available.
Comprehensive information may include
step-by-step disassembly instructions with
Favoured option for the study team
since it is objective and practical.
Also target group considerations
can be integrated
39
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
identification of tools needed,
recommended torque for fasteners,
diagnostic and error resetting codes, testing
procedures, reference values for
measurements
III. Basic information available: A repair, reuse
or upgrade process, for which complete or
comprehensive information is not available
as described above, but for which some
information is available. Basic information
may include product identification,
instructions for regular maintenance, an
overview of repair or upgrade services
offered by the manufacturer,
troubleshooting charts, a list of available
updates, an exploded view and spare parts
list.
IV. No information available: A repair, reuse or
upgrade process, for which no relevant
information is available.
Alternative:
I. automatic troubleshooting and provision of
any information that might be relevant for
the specific problem/reparation/upgrade via
an app, download link or the like AND
access to chat/phone support with employee
II. online availability of repair and upgrade
manuals by search on the product/model
number
III. only provision of legally defined material
and nothing more
B) Semi-quantitative based on target group:
I. Publicly available: A repair/upgrade process
for which the relevant information
(comprehensive or complete information to
facilitate repair/upgrade, as relevant) is
available to all interested parties.
II. Available to independent repair service
providers: A repair/upgrade process for
which the relevant information (the
procedure by which each target group can
obtain the relevant information, including
any fees related to the access to the
information concerned) is not publicly
available as described above, but is
available to any self-employed professional,
as well as any legally established
organisation, providing repair services
(Channels for communicating information
to independent service providers may
include printed manuals, password-
protected websites and digital information
carriers such as DVDs or flash drives)
III. Available to manufacturer-authorised repair
service providers: A repair/upgrade process
for which the relevant information (the
procedure by which each target group can
Complementary, if not integrated.
Information is considered to be
available to a target group must
also consider the unequivocal
identification of the product and of
the information available for that
product, based on the commercial
product name.
40
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
obtain the relevant information, including
any fees related to the access to the
information concerned) is not available to
the general public or to independent repair
service providers as described above, but is
available to service providers authorised by
the product manufacturer to offer repair
services.
IV. Available to the manufacturer only: A
repair, reuse or upgrade process, for which
the relevant information (the price for repair
or upgrade by the manufacturer of the part,
for which information availability is
assessed) is not available to the general
public or to independent or authorised
repair service providers as described above,
but is available to the product manufacturer.
Alternative:
I. Repair/upgrade information is publicly
available to all interested parties
II. Repair/upgrade information is available to
independent repair service providers
III. Repair/upgrade information is available
only to manufacturer-authorised repair
services
IV. Repair/upgrade information is available
after the payment of a fee
V. Repair/upgrade information is not available
C) Percentile score within known spread:
Score = TGi / TGmax x Ci / Cmax
Where,
TGmax is the score corresponding to the
best classification achievable for the
product (in terms of target group)
TGi is the score corresponding to the
class of the analysed product (in terms
of target group)
Dmax is the score corresponding to the
best classification achievable for the
product (in terms of
comprehensiveness of information)
Di is the performance of the product (in
terms of comprehensiveness of
information)
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
Others
11) Guarantee
issues
A) Semi-quantitative based on the 'commercial
guarantee/ extended warranty' offered by
manufacturers/retailers, for example with repair
being the first option of remedy (e.g. 'commitment to
This parameter can be seen as a
possibly relevant 'proxy indicator'
for the reparability or the
durability/quality of products.
41
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
free repair')
I. More than 6 years of commercial guarantee
offered as included in the price of the
product.
II. 5 years of commercial guarantee offered as
included in the price of the product
III. 4 years of commercial guarantee offered as
included in the price of the product
IV. 3 years of commercial guarantee offered as
included in the price of the product
V. No commercial guarantee available
Further discussion is needed, in
particular with respect to its
evaluation options and to the
reference to entire product or
specific parts (e.g. the motor of a
washing machine).
B) Semi-quantitative based on the possibility of
repair by non-authorised repairers
I. Repair by non-authorised repairers will not
affect the warranty of the product
II. Repair by non-authorised repairers will void
the warranty of the product
Based on repairability.org, more
critical than the option above.
C) Percentile score within known spread:
Score = Gi / Gmax
Where,
Gmax is the score corresponding to the
best classification achievable for the
product (in terms of guarantee)
Gi is the score corresponding to the
class of the analysed product
Normalisation of above approaches
to refer class scores to a number
from 0 to 1
12) Return
models
A) semi-quantitative based on return models offered
by the manufacturer to facilitate repair:
I. Lease, product as a service: A
repair/upgrade process, for a product which
is sold as a subscription model (a service is
sold instead of a product.) The customer
does not own the product, and instead it
remains property of the manufacturer. For
the repair, reuse or upgrade process it is
sent back to a location designated by the
manufacturer.
II. Advanced replacement scheme: A
repair/upgrade process, for which there is a
service contract between customer and
manufacturer in which an advanced
replacement scheme is applied. The
manufacturer commits to collect the
defective product and replace it
immediately with a
new/remanufactured/repaired unit. The
defective product is sent to a location
designated by the manufacturer for repair
after which it can be used again for advance
This parameter and the related
classification/rating can be relevant
for all products.
42
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
replacement for another customer.
III. Mail-back program: A repair/upgrade
process, for which the manufacturer offers a
program whereby the user posts the product
to a location designated by the
manufacturer.
IV. User delivers product: A repair/upgrade
process, for which the user drops product
off at local repair facility or at a collection
point of a local shop from where product is
shipped to a repair facility.
V. No return model: A repair/upgrade process,
for which no collection is organised.
Product repair is left up to the owner.
B) Percentile score within known spread:
Score = RMi / RMmax
Where:
RMmax is the score corresponding to the
best classification achievable for the
product (in terms of return model)
TGi is the score corresponding to the
class of the analysed product
Normalisation of above approach
to refer class scores to a number
from 0 to 1
13) Data transfer
and deletion
A) semi-quantitative based on availability of data
transfer and deletion functionality:
I. Built in: built-in secure data transfer and
deletion functionality is available to support
the deletion of all data contained in data
storage parts (i.e. hard drives and solid state
drives) in function of the risks faced and in
order to grant the security of personal data
and to facilitate the reuse of these parts.
II. On request: secure data transfer and
deletion is available under request to
support the deletion of all data contained in
data storage parts (i.e. hard drives and solid
state drives) in function of the risks faced
and in order to grant the security of personal
data and to facilitate the reuse of these
parts.
III. Not available: A reuse process, for which
secure data transfer and deletion is not
available
B) Percentile score within known spread:
Score = Di / Dmax
Where:
Dmax is the score corresponding to the
best classification achievable for the
product (in terms of data transfer and
This parameter and the related
classification/rating, proposed by
stakeholders, can be relevant for
ICT products.
43
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
deletion)
Di is the score corresponding to the
class of the analysed product
14) Safety issues A) semi-quantitative based on the risks associated
with repair operations:
I. There are no injury risks involved in the
repair of the product
II. There is some risk of injury during the
repair process, so that the repair cannot be
undertaken by the consumer
III. There is a high risk of injury during the
repair process, so that the repair cannot be
undertaken by non-authorised repairers.
Consideration of this parameter
proposed by stakeholders.
Classification inspired by
repairability.org. However, it can
be merged with parameter 5, unless
other specific points are raised.
15) Availability
of OEM qualified
service engineers
A) Semi-quantitative based on the availability of
OEM qualified service engineers:
I. The manufacturer provides support of OEM
qualified service engineers during the
warranty period
II. The manufacturer provides support of OEM
qualified service engineers at any time
III. The manufacturer does not provide support
of OEM qualified service engineers
This parameter, proposed by
stakeholders, can be relevant, alone
or integrate in other parameters.
B) Percentile score within known spread:
Score = ORi / ORmax
Where:
ORmax is the score corresponding to the
best classification achievable for the
product (in terms of availability of
OEM qualified service engineers)
ORi is the score corresponding to the
class of the analysed product
Normalisation of above approach
to refer class scores to a number
from 0 to 1
16) Ease of
restoring to full
working
condition after
repair
A) Semi-quantitative based on the ease of restoring
the product to working condition post-repair:
I. The product functions as before, with no or
minimal loss of quality and aesthetics
II. The product functions as before, however
there is some loss of quality and/or
aesthetics
III. The product does not function as before
Consideration of this parameter
proposed by stakeholders.
Classification inspired by
repairability.org (although
subjective)
B) Percentile score within known spread:
Score = Ri / Rmax
Where:
Rmax is the score corresponding to the
best classification achievable for the
product (in terms of ease of restoring to
Normalisation of above approach
to refer class scores to a number
from 0 to 1
44
Parameter Classification/rating options (a) (b)
Technical considerations of the
study team
working conditions)
Ri is the score corresponding to the
class of the analysed product
(a) To be tailored to specific product group(s) and referred to priority part(s) 630
(b) A score can be assigned to each class and for each parameter. However, for some parameters it could be 631 more relevant to have minimum pass/fail requirements or reporting on the underlying information (e.g. 'spare 632 parts available for X years'). 633
45
2.3.2 Aggregation of individual parameters 634
The reparability and upgradability of products could be reported either with respect to one or more 635
individual parameters (e.g. type of tools needed vs. the whole set of parameters) and either in an 636
isolated or aggregated form (i.e. as the scores for individual parameters, or as combined scores for a 637
set of parameters). Stakeholders were asked to provide their views on different levels of aggregation; 638
their input is compiled in Table 7. 639
640
Table 7 Technical considerations about aggregation levels for the scoring system – responses from stakeholders 641
Options Technical considerations
Only a limited number of individual
parameters (e.g. the 3-4 most
relevant ones) are considered and
reported separately
More than half of respondents to the initial questionnaire
expressed some concerns over covering only a limited
number of parameters, because:
This would not be sufficient to evaluate the
reparability of products.
A restricted list of parameters may result in
optimisation of the assessed parameters at the
expense of others, leading to repair-unfriendly
scenarios (despite the good rating of the assessed
parameters).
Less than half of respondents instead favoured focusing on a
limited number of parameters separately, which would ensure
transparency.
However, the relevant issue is whether the product is
reparable or not. Separate information might not be easy to
understand by consumers, whilst aggregated information
could be less valuable.
A possible solution to this issue could be to rate parameters
separately, and then to aggregate them into an overall score.
This would be important to ensure that key information is not
lost, and that the process is transparent. Information could be
either provided in a label or in a data sheet.
All relevant parameters related to
product design (e.g. disassembly
sequence and tools needed) are
aggregated into one index
More than a half of respondents to the initial questionnaire
expressed some concerns over the aggregation of product-
design parameters into one index, because:
It would imply implicit value choices or judgements
in the evaluation. Moreover, it could allow trade-offs
across parameters, so that a 'good' rating could be
achieved at the expense of other important aspects.
It could result in loss of information, and it should be
checked, for instance via appropriate assessment
methods with consumers, if the delivered message is
sufficiently well understood.
All relevant parameters related to the
repair service support (e.g. spare
parts and information availability)
are aggregated into one index
More than half of respondents to the initial questionnaire
expressed some concerns over the aggregation of parameters
related to the repair service support into one index, because:
It would imply implicit value choices or judgements
in the evaluation. Moreover, it could allow trade-offs
46
Options Technical considerations
across parameters, so that a 'good' rating could be
achieved at the expense of other important aspects.
It could result in loss of information, and it should be
checked, for instance through consumer assessment
methods if the delivered message is understood.
Less than half of respondents were favourable to this
approach, which could integrate aspects such as: support
offered by OEM, availability and delivery time of spare parts.
The approach could be complemented by the provision of
separate additional information (e.g. 'X' years of spare parts
availability).
All relevant parameters related to
design characteristics are aggregated
into one index, and all relevant
parameters related to operation
characteristics are aggregated into
another index
More than half of respondents to the initial questionnaire
expressed some concerns over the aggregation of parameters
related to product design, and to the repair service support
into two indices, because:
It would imply implicit value choices or judgements
in the evaluation. Moreover, it could allow trade-offs
across parameters, so that a 'good' rating could be
achieved at the expense of other important aspects.
It could result in loss of information, and it should be
checked, for instance through consumer assessment
methods if the delivered message is understood.
Less than half of respondents instead favoured showing two
indices. This could be complemented by the provision of
separate additional information (e.g. 'X' years of spare parts
availability).
All relevant parameters are
aggregated into one overall index
About half of respondents to the initial questionnaire
expressed some concerns over the aggregation of all relevant
parameters into one index, because:
It would imply implicit value choices or judgements
in the evaluation. Moreover, it could allow trade-offs
across parameters, so that a 'good' rating could be
achieved at the expense of other important aspects.
It could result in loss of information, and it should be
checked, for instance through consumer assessment
methods if the delivered message is understood.
Less than half of respondents instead favoured showing two
indices. This could be complemented by the provision of
separate additional information (e.g. 'X' years of spare parts
availability).
642
If aggregation of scores were actively proposed, most respondents to the initial questionnaire 643
considered that different parameters should have different weights. Weighting should reflect the 644
importance of each parameter for the repair/ upgrade operation. 645
Some stakeholders suggested that the highest weight should be assigned to the availability of parts. 646
Tools and information (including software) were in general considered by stakeholders as more 647
47
important than disassembly sequences, type of fasteners, working environment, skills, and diagnostic 648
support. Visibility of fasteners was also considered more important than the type of fastener. 649
However, weighting implies implicit value choices or judgements between parameters which could 650
change depending on the industry sector concerned and on the product considered (B2B vs. B2C). 651
It was also suggested by some stakeholders that weighting could be combined with 'pass/fail' 652
requirements for some parameters. For instance, disassembly sequence only becomes relevant if a 653
certain pass threshold is reached. 654
Indications provided by stakeholders did not conclusively converge to one widely supported option, 655
since they identified pros and cons are for each alternative analysed. However, also on the basis of the 656
analysis of the comments received from stakeholders, the scoring framework could be shaped as 657
follows: 658
1. A selection of relevant parameters for a certain product group is made; 659
2. Minimum requirements for the product group are set (to ensure reparability/upgradability of 660
the product), as well scoring requirements 661
3. Scoring requirements are weighted and aggregated into a single index to differentiate between 662
different product options 663
4. Details of individual parameters are provided for transparency reasons. 664
665
2.3.3 Reporting options to assess products 666
Reporting of the final score can be carried out with different methods/scales. Table 8 includes options 667
proposed for discussion with stakeholders, as well opinions collected about the suitability of each 668
option. 669
670 Table 8 Technical considerations regarding scales for reporting the final score – responses from stakeholders 671
Scale for
reporting
Suitability (*) Technical considerations
Binary (pass/fail) In general 'Low'
(1.1 out of 3 as
average)
In general, stakeholders consider that a pass/fail approach
could be too simple and might not allow the assessment of
the degree of reparability/upgradability of products and
differentiating between them. Nevertheless, some separate
binary criteria could be integrated into a scoring system.
On the other side, other stakeholders think that this could
be a realistic approach, since consumers might be not
interested in knowing a percentage of chance, but could
rather prefer a commitment from manufacturers (for
instance, that products will be repaired at a maximum cost
for a given period).
Traffic lights In general 'Low'(1
out of 3 as average)
In general, stakeholders consider that traffic light symbols
could be easy to understand. However, they might not
facilitate a sufficient differentiation between products.
0-to-5 stars In general
'Medium'/'High' (2
out of 3 as average)
In general, stakeholders consider that this kind of grading
could be useful to differentiate between products in an
intuitive way.
Other symbols (e.g. spanners/ wrenches) might be more
suitable to use for this purpose rather than stars.
Alphabetic (A, B,
C, D, E, F, G)
In general 'Medium'
(1.4 out of 3 as
In general, this approach raised split views from
stakeholders:
48
Scale for
reporting
Suitability (*) Technical considerations
average) On the one hand there are those who think that
aligning with a similar approach to that used in the
EU Energy Labelling scheme would be good
On the other hand, there are those who consider
that this could be confusing.
Decimal number
between 0-1 (or a
number between
0-10 or 0-100)
In general
'Medium'/'High'
(1.9 out of 3 as
average)
In general, stakeholders consider this kind of grading as
the most understandable system to differentiate between
products.
The scale could be from 0 to 10. Numerical scores could
also be represented as bar charts.
However, there is the risk that this option is too detailed
and uncertain. For instance, a small difference in score
between two products may not correspond to a noticeable/
reliable difference in reality.
(*) Based on the analysis of the feedback received from stakeholders (for all options answers to the 672
initial questionnaire ranged from 'No' to 'Low', 'Medium' or 'High') 673
674
2.4 Summary 675
A comprehensive list of parameters that could be used to assess the repair and upgrade of products is 676
shown in Table 9. The list consists of both 1) the initial parameters included for discussion in the 677
initial questionnaire, and 2) additional parameters which were considered relevant for discussion by 678
the study team. 679
Based on the elements gathered so far, some parameters could be excluded: 680
Working environment seems to be less relevant for repair and upgrade compared to other 681
parameters. This parameter is neither related to product design nor to the provision of 682
information or a service by the manufacturer. For the majority of stakeholders who responded 683
to the initial questionnaire, this parameter would not have a direct influence in the 684
repair/upgrade of products. 685
The ease of access to parts appears as a highly relevant parameter. However, the feedback 686
received from stakeholders seems to point out that this parameter may not be simple, or easy 687
to assess and verify. Moreover, it can be indirectly addressed through other parameters like 688
disassembly sequence, tools needed and the type, number and visibility of fasteners. 689
Safety issues, such as the specific aspect of the working environment concerned, and because 690
of the difficulties associated to the assessment of this parameter. 691
Ease of restoring to working condition after repair, because of the difficulties associated to the 692
assessment of this parameter. 693
In terms of assessment and verification, different options of classification and rating are proposed in 694
Table 6. The study team supports a classification and scoring that is kept as much as possible adherent 695
to the discussion held in the development of prEN 45554. This generally corresponds to the options 696
with the nomenclature of 'A' as shown in Table 6 previously, and the related normalisation 697
approaches. Moreover, classification and rating options should be: 698
1. Tailored to specific product group(s) and related priority part(s) and not be biased towards 699
particular repair business models 700
2. Measurable and enforceable, via: 701
49
- Limiting the presence of value choices or judgements and 702
- Avoiding both the risk of resulting in different interpretations depending on who is 703
doing the evaluation and possible trade-offs (e.g. a highly durable product may be 704
less repairable). 705
Identification of priority parts needs to be made on a product-by-product basis, and must take into 706
account specific aspects for that product, such as the frequency of failure/upgrade, functional 707
importance and price of parts. Discussion and agreement with manufacturers, repairers and other 708
relevant experts is needed. 709
With respect to the possible aggregation of individual parameters, three main options were identified, 710
on the basis of the analysis of the comments received from stakeholders: 711
1. A binary system based on a selection of pass/fail requirements, indicating if the product is 712
reparable or not 713
2. A scoring framework based on a selection of scoring requirements, indicating to what extent/ 714
how much a product is reparable and allowing trade-offs between requirements 715
3. A hybrid system composed of both minimum and scoring requirements. 716
Preliminary indications gathered about the possible reporting options seem to suggest that overall the 717
reparability/upgradability of products should be differentiated based on 5-10 classes. 718
719
50
Table 9 Summary table regarding the selection, assessment and verification of individual parameters to be considered for the scoring framework 720
Parameter Relative importance/ Ranking (a)
Preliminary considerations for
the parameter selection
Min/Score requirement (b)
Reparability Upgradability
1. Disassembly sequence #3 #8 Yes To be discussed
2. Type, number and visibility of fastenings and connectors #7 #6 Yes To be discussed
3. Tools needed (availability, complexity, cost) #8 #3 Yes To be discussed
4. Ease of access to parts #2 #2 Difficult to define and assess
Addressed with other parameters
Proposed to be
DISCARDED (to be
discussed)
5. Working environment (e.g. home, professional repair site,
manufacturing plant)
#10 #10 Less relevant Proposed to be
DISCARDED (to be
discussed)
6. Level of skills required to undertake the operations #9 #7 Yes To be discussed
7. Provision of diagnostic support and interfaces #5 #9 Yes To be discussed
8. Availability of spare parts #1 #5 Yes To be discussed
9. Availability and ease of installation of software and
firmware
#6 #1 Yes, possible merging with
parameter 8
To be discussed
10. Availability of information (e.g. repair and/or upgrade
manuals, exploded diagrams)
#4 #4 Yes To be discussed
11. Guarantee issues NA NA Yes To be discussed
12. Return models NA NA Yes To be discussed
13. Data transfer and deletion NA NA Yes To be discussed
14. Safety issues NA NA No (see parameter 5) Proposed to be
DISCARDED (to be
discussed)
15. Availability of OEM qualified service engineers. NA NA Yes To be discussed
16. Ease of restoring to working condition after repair. NA NA Challenges for evaluation Proposed to be
DISCARDED (to be
discussed) (a)
Indications about the relative weight of each parameter are shown in Table 2 721 (b)
Assessment and verification options: see options under the heading of 'A', plus normalisation options, as discussed in Table 6 722
723
51
2.5 Questions for stakeholders 724
Q1. Which of the following options is technically preferable? Please explain why, and provide any
further indications on how you would implement it.
1. Binary system based on a selection of pass/fail requirements, indicating if the product is
reparable or not
2. Scoring framework based on a selection of scoring requirements, indicating how much a
product is reparable and allowing trade-offs between requirements
3. Hybrid system composed of both minimum and scoring requirements
4. Others
Answer
Q2. Among those discussed in this document, which parameters should be explicitly excluded from
the scoring framework? Please explain why.
Answer
Q3. Which parameters should be necessarily included in the scoring framework? Please explain why.
Answer
Q4. What should be the relative importance of each of the parameters that you would consider in the
scoring framework? Please explain why.
Answer
Q5. Which parameters should be considered as minimum requirements? How should they be assessed
and verified? Please provide explanations and details.
Answer
Q6. Which parameters should be rated? Which classification and rating criteria would you apply?
Please provide explanations and details.
Answer
Q7. Could you please provide indications to follow for the identification of priority parts (for a
specific product group)? Please provide explanations and details about the proposed
methodology/ideas.
Answer
725
52
3 PRODUCT-SPECIFIC CONSIDERATIONS 726
3.1 Attractive conditions for repair and upgrade for macro-categories of products 727
Because each product has its own characteristics and peculiarities, they should be, in so far as it is 728
applicable, assessed at an individual level. Nevertheless, there are some aspects influencing the repair 729
and upgrade operations that could allow a classification of products according to certain 730
characteristics, as for example their size. 731
For the purpose of describing generic aspects influencing the repair and upgrade of products 732
according to such characteristics, an initial classification of products was proposed as defined below: 733
a) Small appliances (e.g. vacuum cleaners, kettles, coffee machines, handheld drills, hair-734
dryers): goods which can be easily transported to a repair shop and which are generally 735
perceived as less sophisticated by consumers attempting to repair them; 736
b) Medium/large appliances (e.g. washing machines, dishwashers, refrigerators, freezers, 737
cookers): goods for which a trained technician might normally come to your home to repair 738
the product or you would have to make a dedicated logistics effort to transport them to be 739
repaired; 740
c) Installed products (e.g. a boiler or heat pump, or air conditioning appliances): goods for which 741
a trained technician would normally be required to come out to examine the products, and 742
where the product repair is normally related to and interacts with the environment in which it 743
is placed; 744
d) Electronic products (e.g. imaging equipment, DVD players, mobile phones, tablets, personal 745
computers, laptops): goods with a faster innovation cycle compared to the former categories 746
and a size allowing a relatively easy displacement of the device for repair/upgrade. 747
Respondents to the initial questionnaire pointed out that: 748
Although categorisation of products into families may seem logical, there is a sensible 749
variation of function, performance and complexity between products and models of the same 750
type. Reparability and upgradability is product specific. 751
Apart from the size, also complexity is an aspect that should be considered for the 752
classification of small appliances. 753
Personal computers and laptops (but also tablets and servers) are the most modular products. 754
Hard drives and memories have standardised interfaces and can be upgraded in many cases. 755
TVs and DVD players are very different and not modular at all. Electronic products should be 756
split at least into 3 sub-groups: d1) Small & portable ICT products like smartphones, d2) 757
Medium sized ICT products like desktop computers, d3) Large or installed ICT products like 758
servers. 759
There are some fuzzy areas. For instance: 760
- with the increasing diffusion of connected devices ('internet of things'), it is likely 761
that category (a) overlaps with category (d) and that some aspects apply to both (e.g. 762
the availability of software updates) 763
- products as DVD players could also belong to group a) 764
- products such as large TVs could belong also to group b). 765
Consumables, such as ink cartridges for printers, are missing. 766
Stakeholders were asked to define a series of scenarios/conditions under which the repair and upgrade 767
operations would be more favourable, or more likely to happen. The input from stakeholders has been 768
collated and is shown in Table 10 (Repair) and Table 11 (Upgrade), respectively. 769
53
Table 10 Conditions that could make repair attractive from a consumers-targeted perspective 770
Aspect Small appliances Medium/Large appliances Installed products Electronic products
Maximum cost of repair
which would make it
attractive, expressed as % of
the product's purchase price
In the range of 15-40%,
although it depends highly on
the product and its
technological development.
Repair could be less
attractive for this product
category because of the
relatively low price of new
products.
In the range 15-40% In the range 15-40% In general up to 30%,
however repair cost threshold
is a function of different
aspects motivating the repair
decision (e.g. functional
needs, emotional
attachment).
Minimum lifetime
expectancy for the product at
the time of purchase, which
would make repair attractive
(in years)
From 5 to 10 years,
depending on the product.
Due to the lower
attractiveness of repair for
this product category,
warranty coverage is
considered more important.
From 8 to 15 years,
depending on the product.
From 10 to 20 years,
depending on the product
From 5 to 7 years depending
on the product.
Maximum time of repair,
including delivery of spare
parts, which would make it
attractive (in weeks)
In general, 1 week max.
However this could rise up to
2-10 weeks for some
stakeholders. Availability of
spare parts is crucial.
In general 1-2 weeks max.
In case the product is
difficult to replace a larger
period can be accepted by the
consumer. Availability of
spare parts is crucial.
In a wide range (few days – 2
weeks).
In case the product is
difficult to replace a larger
period can be accepted by the
consumer.
In a wide range (few days – 2
weeks)
Maximum acceptable time
for repair is highly subjective
and depends on the
customers’ emotional and
functional reliance or needs.
Important to provide
temporary devices to replace
the absence of the product
during the time of repair.
Other comments For all products also the following aspects are highlighted as relevant:
54
Aspect Small appliances Medium/Large appliances Installed products Electronic products
Cultural aspects and habits (i.e. what consumers use to do when a product breaks or becomes functionally obsolete)
The availability of an effective service network of trained professionals (either service engineers of the manufacturer
or independent authorised and qualified professionals). This leads to proximity and quality, which contributes
positively to the repair decision.
The ease of access to a repair shop is considered more relevant for small appliances. No matter how cheap the repair
is, many consumers might be willing to pay for new products solely due to the inconvenience of taking it to a
repair/service location.
771
Table 11 Conditions that could make upgrade attractive from a consumers-targeted perspective 772
Aspect Small appliances Medium/Large appliances Installed products Electronic products
Maximum cost of upgrade which
would make it appealing (free of
charge, or expressed as % of the
product's purchase price)
Range of costs reported
from 5% to 25% of the
product's purchase cost.
High dependent on the
product type and upgrade
benefits.
Range of costs reported from
5% to 25% of the product's
purchase cost.
High dependent on the
product type and upgrade
benefits.
Range of costs reported
from 10% to 25%.
Due to the difficulty of
new installation,
upgrading might be more
attractive than for other
product groups.
Range of costs reported
from 0% to 20%. Free of
charge when linked to
software or firmware
upgrade (bug fixes or
vulnerabilities).
Hardware upgrade
reported in the range of
10-20% of the product's
purchase price.
Minimum lifetime expectancy for the
product, at the time of purchase, which
would make upgrade attractive (in
years)
From 5 to 10 years,
depending on the
product.
From 7 to 15 years,
depending on the product.
From 10 to 20 years,
depending on the product
From 5 to 7 years in
general.
Maximum time of upgrade, including
delivery of new parts/functions, which
would make it attractive (in weeks)
From 1 week to 5 weeks.
This is considered a less
critical point from the
point of view of the
consumer, as the
appliance is still
Highly dependent on
product.
This is considered a less
critical point from the point
of view of the consumer, as
the appliance is still
Highly dependent on
product.
This is considered a less
critical point from the
point of view of the
consumer, as the
From 1 day to 1 week is
reported as maximum time
of upgrade.
Also in this case time is
considered a less critical
aspect.
55
Aspect Small appliances Medium/Large appliances Installed products Electronic products
functional. functional. appliance is still
functional.
Other comments For upgradability it is more difficult to find objective conditions. There can be significant variations also between
products of the same product category, depending on the complexity of their design.
773
56
3.2 Aspects and needs for a product-specific 774
scoring system 775
The scoring framework discussed in Section 2 is planned to be adapted to three product groups: 776
laptops, vacuum cleaners and washing machines. The generic scoring framework thus needs to be 777
tailored to the specific characteristic of each product group. Preliminary information about the 778
analysed product groups have been gathered from stakeholders and shown in Table 12 and Table 13. 779
780
Table 12 Specific aspects influencing reparability and upgradeability of laptops, vacuum cleaners and washing 781 machines – Summary of the responses from stakeholders 782
Product Specific aspects influencing reparability Specific aspects influencing
upgradability
Laptops Ease of access, disassembly and
substitution. In particular,
application of glues and soldering
can make a laptop less reparable.
Connections should thus be
removable to avoid any damage.
Target parts for this aspect are
battery, keypads, SSD.
Manufacturer support: online
availability of troubleshooting
guidelines, overview and pricing
of repair options, availability of
direct repair services (or
authorized and trained by the
manufacturer)
Software / firmware availability
and data deletion in the case of
refurbishment / resale
Interoperability of chargers and
battery has been also pointed as an
important aspect for reparability,
which could be improved through
the use of standardised interfaces
Software upgradability, and cost
and availability of software
upgrades
Software upgrade should not
negatively impact the performance
of the laptop (e.g. slowing down its
performance). A trial should be
offered to verify the impacts of
software upgrade a rollback should
be possible.
Regarding the hardware, same
aspects presented for reparability
are pointed out. Hard drives and
memory (RAM) are considered the
most relevant parts.
Software availability and hardware
upgradability are particularly
important when the performance is
below a certain threshold (e.g. 4GB
for the RAM).
Interoperability of chargers and
battery has been also pointed as an
important aspect for upgradability,
which could be improved through
the use of standardised interfaces
Vacuum
cleaners Ease of access, disassembly and
substitution of parts
Availability and cost of spare
parts
Interoperability and standardised
sizes of components (e.g. tubes,
nozzles, dust bags and filters)
Complexity and safety of the
product
Software/firmware upgradability
for robot vacuum cleaner.
In general not considered very
relevant for this product group
Washing
machines Design of crucial parts such as the
drum vs. cost of others parts, e.g.,
Modularity / standardisation of
interface
57
Product Specific aspects influencing reparability Specific aspects influencing
upgradability
control panel
Availability of diagnostic
tools/interfaces to target groups
Availability of technical service
via web
Cost of repair vs. cost of new
product
Time of repair
Availability and cost of spare
parts
Cross-compatibility of parts
between different models or
brands
Easy positioning and replacement
of parts with common tools
Availability of information about
maintenance and repair (e.g.
exploded diagrams)
Easy connection to apps for
software update
In general not considered very
relevant for this product group
783
Table 13 Specific issues and needs to take into account when assessing reparability and upgradability of laptops, 784 vacuum cleaners and washing machines – Summary of the responses from stakeholders 785
Product Specific needs for assessing reparability Specific needs for assessing
upgradability
Laptops Priority parts should include at least
the battery. Whether a battery is
accessible without opening the
casing/laptop should be the most
important criterion (for which there
should be no possibility of trade-off).
The design of weak points (subject to
wear) like screen hinges, surfaces
around keyboard and back of screen
is crucial for the perceived
obsolescence and therefore for the
attractiveness of the reparation for the
costumers.
Modularity of the laptop
Most effective strategies:
- to regulate the maximum repair cost
within the warranty
- to regulate an increased warranty
time
- to ensure the achievement of the
Ease of access to internal parts (e.g.
bios, battery, fan, HDD, RAM).
Whether hard drive and RAM are
accessible without opening the laptop
should be the most important criterion
(for which there should be no
possibility of trade-off).
Compatibility with other ICT products
connected to the laptops (e.g. printers
need to have drivers which can be
supported or not in upgraded laptops)
Amount of expansion slots
Level of skills required for the
operation
Most users expect a problem-free
software upgrade for at the most a
couple of years above the warranty
time. However, the operating system is
often out of the control of the
manufacturer of the laptop.
58
Product Specific needs for assessing reparability Specific needs for assessing
upgradability
collection rate targets
Additional strategies for reparability:
- no extra tools needed for the
removal of components;
- no fixed gluing;
- labels linked to the web (e.g.
through QR codes).
See strategies reported on the left.
Vacuum
cleaners Priority parts should include at least
motor and hose. For robot vacuums,
priority parts should also include
software/firmware.
Relevant parameters of assessment
should include: availability of
information; ease of access to internal
parts (motor, PCB, and cable); tools
needed; visibility of screws;
availability and price of spare parts
Product and consumer safety must
always be ensured. The repair of
products needs appropriate technical
skills that most consumers do not
have
Upgrade is less likely for this product
group, with the exception of robot
vacuum cleaners, for which priority
parts should include software/firmware.
Washing
machines Priority parts assessed should include:
electronic control and user interface
boards; motors; pumps; shock
absorbers; drum/ball bearings;
heaters; door hinges; drum spiders
and seals
Availability and cost of spare parts is
considered important, as well as the
steps and the tools needed to
disassemble them.
The three lethal faults for washing
machines are reported to be: 1) the
high price of the control panel, 2) the
full replacement of the motor instead
of the brushes; 3) the difficulty to
replace and repair shaft and bearings.
Product and consumer safety have
always to be ensured. Professional
repair will be mostly required for
washing machines.
In general not considered very
relevant for this product group
786
59
3.3 Questions for stakeholders 787
Q1. Which are the main repair/upgrade operations applied to laptops and the related priority parts?
Please explain why.
Answer
Q2. Which parameters should be taken into account for assessing the reparability/upgradability of
laptops? How they should be tailored (in terms of minimum requirements, classes and rating) for
assessing the reparability/upgradability of this product group? Please explain why; you can use
Section 2.4 as reference.
Answer
Q3. How should the parameters for laptops be aggregated? Please explain why; you can use Section
2.4 as reference.
Answer
Q4. Which are the main repair/upgrade operations applied to vacuum cleaners and the related priority
parts? Please explain why.
Answer
Q5. Which parameters should be taken into account for assessing the reparability/upgradability of
vacuum cleaners? How they should be tailored (in terms of minimum requirements, classes and
rating) for assessing the reparability/upgradability of this product group? Please explain why; you can
use Section 2.4 as reference.
Answer
Q6. How should the parameters for vacuum cleaners be aggregated? Please explain why; you can use
Section 2.4 as reference.
Answer
Q7. Which are the main repair/upgrade operations applied to washing machines and the related
priority parts? Please explain why.
Answer
Q8. Which parameters should be taken into account for assessing the reparability/upgradability of
washing machines? How they should be tailored (in terms of minimum requirements, classes and
rating) for assessing the reparability/upgradability of this product group? Please explain why; you can
use Section 2.4 as reference.
Answer
Q9. How should the parameters for washing machines be aggregated? Please explain why; you can
use Section 2.4 as reference.
Answer
61
4 ADDITIONAL POINTS TO CONSIDER 789
This section compiles the comments received from stakeholders, which reflect their general opinions 790
regarding a scoring system for assessing the reparability and upgradability of products and its possible 791
policy implications at EU level. 792
793
4.1 Reparability and upgradeability vs. durability of products 794
Some stakeholders indicated that an overarching analysis would be needed to assess and discuss on 795
advantages and drawbacks associated to different options (including a scoring system for assessing 796
reparability and upgradability of products) allowing the provision of durability-related information to 797
consumers. It was also pointed out that reliability and durability could have higher importance in the 798
circular economy than reparability and upgradeability. 799
800
4.2 Link to policy framework and standardisation 801
According to some industry stakeholders, the necessary services to ensure the proper and safe repair 802
of products are already available on the market. Repair is part of brands after-sales strategies and a 803
way for companies to compete to offer appropriate services to consumers. Nevertheless, complaints 804
received by consumer associations around Europe show that the repair service offered by some 805
companies does not reflect this, especially during the guarantee period. 806
Industry stakeholders are in general in favour of the developing of an internal evaluation tool for 807
assessing the reparability and upgradability of products (e.g. as done in standardisation). However, 808
some of them have concerns with respect to the possible use of such a tool as the basis for setting 809
legal requirements, due to the inherent elements of subjectivity associated to any rating and weighting 810
approach. For any regulatory application, the Better Regulation agenda must apply to ensure 811
coherence and legal certainty. 812
When legal requirements are set, they must be clear and consistent, supporting innovation and 813
creating the conditions for competitiveness. Legal requirements that are based on evaluation methods 814
that are not sufficiently precise would impact the current competitive landscape between companies 815
and will lead to market distortions. Market surveillance authorities must be able to test any legal 816
requirement efficiently. 817
Measurement methods used for regulatory purposes have thus to respect the following requirements: 818
i) It has to leave no or minimal room of interpretation or doubt; 819
ii) It has to be enforceable by Member States; 820
iii) There is sufficient laboratory capacity to perform testing, when needed. 821
Some industry stakeholders do not consider that the draft standard developed by CEN/CENELEC JTC 822
10 – WG3 describe repeatable and reproducible measurement methods. These stakeholders remarked 823
the need to link the ongoing work of the JTC10 WG 3 to the analysis of this scoring system for 824
reparability and upgradeability. 825
826
4.3 Safety and liability of the product 827
Consumer protection and safety was reported to be a key element to maintain trust with consumers 828
and not to jeopardise efforts for the circular economy. The repair of products needs appropriate 829
technical skills that most consumers do not have. If an appliance is not properly repaired, consumer 830
safety within the home could be compromised. If a consumer has repaired a product, the liability for 831
the safety of the product is not with the manufacturer. According to some manufacturers, to ensure the 832
safety and conformity of products, repair of appliances must be made by authorised repair operators. 833
834
62
4.4 Communication issues 835
Communicating information does not have to be misleading and has to be simple and understandable 836
by consumers. 837
Transparency is a 'must', in order to establish trust in the legitimacy of the assessment. Some 838
stakeholders consider that any aggregation of results into one overall score is not feasible, as it will 839
always run the risk of being misrepresentative, depending on of consumers' individual conditions and 840
the use situation, and the type of product being examined. 841
842
4.5 Questions for stakeholders 843
Q1. Please let us know if you have any other specific comments to make
Answer
844
63
5 ANNEX I – INITIAL QUESTIONNAIRE FOR STAKEHOLDERS 845
5.1 Part 1) Existing methods, labels, or schemes for the assessing reparability and 846
upgradability of products 847
Q1.1 Please give your opinion on the methods, labels or schemes listed below, and which 848
can be used to assess the reparability and upgradability of products 849
Please fill in the table below based on your knowledge about the reported methods and labels. 850
If you are not familiar, please indicate that the 'method is not known'. 851
Method/Label Familiarity
with the
method
Advantages Disadvantages Overall opinion
about the
diffusion and
robustness of the
use of the
method as a
scoring system
Austrian standard ONR
192102
Design For
Repairability tool33
i-Fixit scoring system
Groupe SEB's Product
Repairable label
prEN 45554 - General
methods for the
assessment of the
ability to repair, reuse
and upgrade energy
related products
852
Q1.2 Please provide information regarding any other methods, labels or schemes which 853
you are aware of, and which can be used to assess the reparability and upgradability of 854
products 855
Please fill in the table below about additional methods and labels. 856
Method/Label Scope Advantages Disadvantages Familiarity with
the method, and
overall opinion
about diffusion
and robustness of
the use of the
method as a
scoring system
33 http://www.repairability.org/#
65
5.2 Part 2) Aspects influencing the reparability and upgradability of products in 858
general 859
860
Q2.1 Which are in your opinion the most relevant parameters influencing repair and 861
upgrade of products? How could these be assessed and verified? 862
Please fill in the table below by firstly evaluating their relevance based on your experience 863
(H: high, M: medium, L: low, N: no), and secondly describing if and how they could be 864
assessed and verified in practice. Note: an example of assessment and verification option 865
could be to make available the instructions about the steps needed to disassemble a part. 866
Parameter Relevance for repair
(High/Medium/Low/No)
Relevance for upgrade
(High/Medium/Low/No)
Options for
the
assessment
and
verification
Disassembly sequence
Type, number and
visibility of fastenings
and connectors
Tools needed
(availability,
complexity, cost)
Ease of access to parts
Working environment
(e.g. home, professional
repair site,
manufacturing plant)
Level of skills required
to undertake the
operations
Provision of diagnostic
support and interfaces
Availability of spare
parts
Availability and ease of
installation of software
and firmware
66
Availability of
information (e.g. repair
and/or upgrade manuals,
exploded diagrams)
Others34
(please
specify)
867
Q2.2 Besides the technical aspects listed above, other factors currently limit the repair 868
and upgrade of products (e.g. purchase price and labour costs, demand for new vs. 869
repaired/upgraded products, support networks facilitating the repair process, business 870
models, compatibility issues). In your opinion, under which conditions are repair and 871
upgrade operations more likely to occur? 872
Aspect Favourable conditions for
repair
Favourable conditions for
upgrade
Functional, technological and
behavioural factors (e.g.
demand for new vs.
repaired/upgraded products)
Economic factors (e.g.
purchase price for product and
spare parts, labour costs)
Organisational factors (e.g.
access to professional repair
services or support networks)
Legal factors (e.g. legal
guarantee, liability issues)
Others (please specify)
873
874
34 For instance, an overall measure of disassemblability (ease/difficulty of the disassembly operation), as
combination of some of the parameters listed in the table
67
5.3 Part 3) Conditions influencing the reparability and upgradability of specific 875
families of products 876
In Part 3 of the questionnaire, we would like you to consider the different motivations and 877
aspects regarding repair and upgrading for different families of products. These might be split 878
in various ways, but we have suggested - as examples – four representative subsets based on 879
the following characteristics: 880
(a) Small appliances (e.g. vacuum cleaners, kettles, coffee machines, handheld drills, hair-881
dryers): goods which can be easily transported to a repair shop and which are generally 882
perceived as less sophisticated by consumers attempting to repair them; 883
(b) Medium/large appliances (e.g. washing machines, dishwashers, refrigerators, freezers, 884
cookers): goods for which a trained technician might normally come to your home to repair 885
the product or you would have to make a dedicated logistics effort to transport them to be 886
repaired; 887
(c) Installed products (e.g. a boiler or heat pump, or air conditioning appliances): goods for 888
which a trained technician would normally be required to come out to examine the products, 889
and where the product repair is normally related to and interacts with the environment in 890
which it is placed; 891
(d) ICT products (e.g. imaging equipment, TVs, DVD players, mobile phones, tablets, 892
personal computers, laptops): goods with a faster innovation cycle compared to the former 893
categories and a size allowing a relatively easy displacement of the device for repair/upgrade. 894
895
Q3.1 Do you agree with the suggested subdivisions into the four families of products 896
described above? 897
GRADED RESPONSE: Completely agree – mostly agree – partly agree – disagree mostly – 898
Completely disagree 899
900
Q3.2 Do you have alternative approaches to propose? 901
OPEN QUESTION/RESPONSE 902
903
Q3.3 Which are the specific technical and economic conditions that could make repair 904
attractive for the above mentioned families of products from a consumers-targeted 905
perspective? Please also consider the alternative aspects/ suggestions, if any. 906
Aspect Small
appliances
Medium/Large
appliances
Installed
products
ICT
products
Max cost of repair which would
make it attractive, expressed as %
of the product's purchase price
Minimum lifetime expectancy for
the product at the time of
purchase, which would make
repair attractive (in years)
68
Maximum time of repair,
including delivery of spare parts,
which would make it attractive (in
weeks)
Other comments
907
Q3.4 Which are the specific technical and economic conditions that could make upgrade 908
attractive for the above mentioned families of product from a consumers-targeted 909
perspective? Please also consider the alternative aspects/ suggestions, if any. 910
Aspect Small
appliances
Medium/Large
appliances
Installed
products
ICT
products
Max cost of upgrade which would
make it appealing (free of charge,
or expressed as % of the product's
purchase price)
Minimum lifetime expectancy for
the product, at the time of
purchase, which would make
upgrade attractive (in years)
Maximum time of upgrade,
including delivery of new
parts/functions, which would make
it attractive (in weeks)
Other comments
911
912
69
5.4 Part 4) Identification of priority parts 913
914
Q4.1 Do you consider that the draft standard prEN 45554 is suitable as basis for the 915
development of a generic scoring system for the assessment of the repair/upgrade of 916
products? 917
YES 918
Up to a certain extent 919
NO 920
921
Q4.2 Please describe which modifications and integrations are needed in the context of 922
this study about the development of a scoring system, or where other parameters and 923
aspects could be used either to complement or replace those described in the standard. 924
Please reply (OPEN RESPONSES) 925
926
Q4.3 From the aspects listed below, which in your opinion are more relevant to identify 927
priority parts with respect to reparability? 928
Please firstly evaluate their relevance based on your experience (H: high, M: medium, L: low, 929
N: no), and secondly provide indications for differentiating between priority and non-relevant 930
parts 931
Parameter Relevance
(H/M/L/N)
Further indications for evaluating the
importance of parts with respect to
reparability
Frequency of failure of parts
Functional importance of
parts and software
Economic value of parts
(e.g. purchase price) and
related repair operations as
% of the product price
Environmental impacts of
parts as % of the total
environmental impacts of
the product
Steps needed to disassembly
parts
Others (please specify)
932
933
934
70
Q4.4 From the aspects listed below, which in your opinion are more relevant to be able 935
to identify priority parts with respect to upgradability? 936
Please firstly evaluate their relevance based on your experience (H: high, M: medium, L: low, 937
N: no), and secondly provide indications for differentiating between priority and non-relevant 938
parts 939
Parameter Relevance
(H/M/L/N)
Indications for evaluating the importance of
parts with respect to upgradability
Frequency of upgrade of
parts and software, where
relevant
Functional importance of
hardware and software,
where relevant
Economic value of parts
(e.g. purchase price) and
software, where relevant, as
% to the product price
Environmental impacts of
parts and software, where
relevant, as % of the total
environmental impacts of
the product
Steps/time needed to
disassemble parts and
uninstall and reinstall
software, where relevant
Others (please specify)
940
941
71
5.5 Part 5) Guidance for scoring and aggregating different aspects of repair and 942
upgrade 943
Parameters identified in the former sections can be used to assess the reparability and 944
upgradability of products through pass/fail requirements and/or scoring systems. This 945
requires the definition of rating criteria to use for the evaluation of single parameters. An 946
example is provided below which presents three classes of scores: 0 (negative attribute), 0.5 947
(neutral attribute), 1 (positive attribute). 948
Parameter Description of the proposed rating criteria (illustrative purposes only)
Availability of
spare parts
Score:
0 points: Original spare parts are not available to replace priority
parts
0.5 points: Original spare parts are available for less than 5 years
after purchase of the product, and not for all priority parts
1 point: Original spare parts are widely available to replace all
priority parts. Availability is ensured for at least 5 years following
the end of production of the model
Types of tools
needed
Score:
0 points: Advanced specialized tools (like a soldering iron, a puller
and/or proprietary screwdrivers) are needed to disassemble priority
parts
0.5 points: Specialized tools (like torx screwdrivers, electric drill
and small magnets) are needed to disassemble priority parts
1 point: No tools or only basic tools (like scissors, flathead and
cross recess (Phillips) screwdrivers) are needed to disassemble
priority parts
The score can be normalised to a different scale (e.g. 0 to 1, 0 to 5, or 0 to 10). Moreover, 949
scores could be weighed (if some criteria are considered to be more important) and 950
aggregated into one or more indices. 951
952
Q5.1 Taking the examples provided above for spare parts and tools, which rating 953
criteria would you apply to each single parameter described in Q2.1 in order to evaluate 954
their influence on reparability and upgradability of products? 955
Parameter Description of the proposed rating
criteria
(see the examples provided in the
introduction to section 5)
Disassembly sequence
Type, number and visibility of fastenings and
connectors
Tools needed (availability, complexity, cost)
Ease of access to parts
72
Working environment (e.g. home, professional
repair site, manufacturing plant)
Level of skills required to undertake the operations
Provision of diagnostic support and interfaces
Availability of spare parts
Availability and ease of installation of software and
firmware
Availability of information (e.g. repair and/or
upgrade manuals, exploded diagrams)
Others35
(please specify)
956
Q5.2 Reparability and upgradability of products could be reported for instance either 957
with respect to one or more single parameters (e.g. type of tools needed vs. all the 958
identified parameters) and either in isolate or aggregated form (i.e. as individual 959
parameter's score or as combined scores for a set of parameters). Which level of 960
aggregation should be reached when reporting the reparability and upgradability of 961
products? 962
Please choose and explain why 963
Options Y/N Comment
Only a limited number of individual parameters (e.g. the 3-4 most relevant
ones) should be considered and reported separately
All relevant parameters related to product-design (e.g. disassembly
sequence and tools needed) should be aggregated into 1 index
All relevant parameters related to the repair service support (e.g. spare parts
and information availability) should be aggregated into 1 index
All relevant parameters related to design characteristics should be
aggregated into 1 index, and all relevant parameters related to operation
characteristics should be aggregated into another index
All relevant parameters should be aggregated into 1 overall index
Others (please specify)
964
Q5.3 In case of aggregation, should an equal weight be considered for all relevant 965
parameters or should a weighting factor be assigned to some parameters to reflect their 966
relatively higher importance with respect to the others (see question 2.1)? (e.g. the score 967
of a high relevance parameter could weight 3 times that of a low relevance parameter) 968
Please reply and explain how and why 969
970
35 For instance, an overall measure of 'disassemblability' (ease/difficulty of the disassembly operation), as
combination of some of the parameters listed in the table
73
Q5.4 With reference to questions 5.1 and 5.2, which scale should be used to report the 971
product reparability/upgradability score? 972
Please firstly evaluate their suitability (H: high, M: medium, L: low, N: no), and secondly 973
provide supporting comments to explain why. 974
Reporting option Suitability
(H/M/L/N)
Supporting
comments
Binary (pass/fail)
Traffic lights
0-to-5 stars
Alphabetic (A, B, C, D, E, F, G)
Decimal number between 0-1 (or a number between
0-10 or 0-100)
Other iconographies and/or scales (please specify)
975
976
74
5.6 Part 6) Specific aspects and needs for the product groups under assessment 977
978
Q6.1 Considering the information provided on products in general (see sections 1, 2, 3 979
and 4), which are the specific aspects of importance for the reparability and 980
upgradability of laptops/ vacuum cleaners/ washing machines? 981
Please specify the product group and indicate the related specificities 982
Product Specific aspects influencing
reparability
Specific aspects influencing
upgradability
Laptops
Vacuum
cleaners
Washing
machines
983
Q6.2 Considering the information provided about the general scoring system approach 984
(see sections 4 and 5), which are the specific needs to take into account for the potential 985
design of a scoring system for laptops/ vacuum cleaners/ washing machines? 986
Please specify the product group and indicate the related specificities 987
Product Specific needs for assessing
reparability
Specific needs for assessing
upgradability
Laptops
Vacuum
cleaners
Washing
machines
988
Q6.3 Please provide any additional comments you might have about other specific 989
aspects (e.g. links with standards, eco-design measures, and market specificities) 990
Please specify the product group and indicate the related specificities 991
Product Additional comments
Laptops
Vacuum cleaners
Washing machines
75
6 ANNEX II – ANALYSIS OF RESPONSES 992
25 responses to the initial questionnaire were received36. This corresponds to about one reply 993
out of four from the stakeholders registered in the Technical Working Group for this project37. 994
In terms of organisations (see pie chart below): 995
15 responses were received from industry and trade associations (equivalent to 60% 996
of the respondents) 997
3 responses each were received from governmental agencies and NGOs (12%) 998
2 responses were received from independent repairers (8%) 999
1 response each was received from academia and retailers. 1000
1001
1002
1003
In terms of geographical representativeness of the respondents (see pie chart below): 1004
6 respondents are based in Belgium (24%) 1005
4 respondents are based in France (16%) 1006
3 respondents are based in Germany (12%) 1007
2 respondents are based in Italy (8%), as well as in Spain and in the Netherlands; 1008
Other respondents are based in Czech Republic, Denmark, Ireland, Sweden and the 1009
UK. 1010
1011
36 The questionnaire was launched on 7
th April 2018 and made accessible from
http://susproc.jrc.ec.europa.eu/ScoringSystemOnReparability/documents.html. The questionnaire was closed
on 7th
May 2018. 37 The share of participation to the questionnaire would be higher if calculated based on the number of
organisations, since more representatives per organisation are in general registered as stakeholders.