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JTC10/Sec494/NP - General method to declare the use of critical raw materials in products

Scope

The main intended use of this document is to provide a means for information on the use of CRMs to be exchanged up and down the supply chain and with other relevant stakeholders.

Potential users of this document are any public, private or social enterprises involved in the production of physical products, such as manufacturers (including SMEs) and other organisations in the product supply chain. It is also relevant to European market surveillance and trade authorities as well as European policy makers.

This document is horizontal in nature and can be applied directly to any type of product that fall under the scope of JTC 10. This document proposes a standardized format for reporting use of CRMs in products by applying the ISO-IEC 82474-1 materials declaration standard. However, this document does not provide or determine any specific method or tool to collect CRM data.

Emissions during product manufacturing are not in scope of this document.

Purpose

Raw materials are at the core of concepts such as resource efficiency and circular economy, which are crucial to the European economy and essential to maintaining and improving the quality of life. Securing reliable and unhindered access to certain raw materials is a growing concern within the European Union (EU) and across the globe. To address this challenge, the European Commission has introduced methodology to assess critical raw materials (CRMs).

CRMs combine a high economic importance to the EU with a high risk associated with their supply, both of which are determined according to an objective methodology. The CRMs Act regulation, which has just been published, introduces, additional to CRM also a list of strategic raw materials (SRMs), which are critical raw materials that score among the highest in terms of strategic importance, forecasted demand growth and difficulty of increasing production. This aspect is not yet accounted for the in the current version of the standard.

EN 45558 specifies a method for the declaration of CRMs based on EN IEC 62474 on material declaration of and for the electrotechnical industry. EN 45558 is therefore essential in supporting manufacturers of products to obtain information and report on the use of certain CRMs needed to comply with specific requirements in product-specific legislations. Because the EN IEC 62474 will soon be replaced by the cross-sector ISO-IEC 82474-1, it is necessary to review EN 45558 and update it with the new ISO-IEC material declaration standard.

Currently the (normative) reference to EN IEC 62474 is undated. In the event this document will be referred to in products specific regulations (e.g. discussions ongoing about Servers regulation), dated reference is needed.

Last, the revision is also necessary to account for the expansion of CEN-CLC JTC10’s scope to cover the Ecodesign directive and its future revisions, namely the ESPR that is expected to be published in the next weeks. The current EN 45558 covers energy-related products. Following the EN 45560, which was the first document to consider the expansion of scope, it was recommended by the JTC10 CAG that in the future when other parts of EN 4555X such as EN 45558 will be revised, they should take the following approach in relation to the product scope:

- Change title to cover “products” rather than ErP (Energy-related Products) and

- Include additional information on the scope, namely a note indicating ESPR product exclusions.

Comment on proposal

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Please email further comments to: debbie.stead@bsigroup.com

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