This is a list of most frequently asked questions about The Eco-Declaration (TED) and the ECMA-370 standard. A key clause of ECMA-370 to understand is Clause 2 on Conformance and the FAQ responses are intended to further help answering questions.
What is ECMA-370?
Ecma International is a Standard Developing Organisation (SDO). Ecma developed the ECMA-370 standard (and several subsequent versions of it) in its Technical Committee TC38 on product-related environmental attributes.
ECMA-370, The ECO Declaration, is a Supplier’s Declaration of Conformity. The process for this declaration is to download the appropriate files (ECMA-370 Annexes), fill in the information and publish it or provide it as may be needed. The information provided is the supplier’s responsibility.
What is the process for declaring compliance?
To follow this process, there is no need to become a member of Ecma, there is no associated cost, and Ecma is not involved in the verification of the published Conformance Declaration information (Ecma does not certify Declarations).
To fill in the forms in a proper way (to conform to the ECMA-370 standard), a company must follow the Conformance clause (clause 2 of ECMA-370) which states: “For the European Union, declarations conform to this Standard when all mandatory fields and items that have been declared in the Annex A and B templates of this Standard, can be verified as defined in 6.2. To facilitate understanding, explanatory statements should be added to field C7 of Annex A and field P15 of Annex B.”
It is strongly recommended to first read the ECMA-370 standard, along with the guidance documents at https://ecma-international.org/publications-and-standards/standards/ecma-370/ to understand the requirements and questions in Annexes A and B2.
The mandatory fields have to be filled in the manner suggested in the forms: Annexes A (company environmental profile) and either Annex B1 (imaging equipment, that is, printers and copiers) or Annex B2 (computers and computer monitors).
The reference to clause 6.2 (declared fields and items, can be verified as defined in 6.2) means that you (your company) also have to keep your lab test documentation, as it may be requested by the customer or become part of the tender, and if a form is requested, you will have to provide it.
Ecma is not involved in this process, but will respond to general enquiries about the standard.
Is conformance to ECMA-370 mandatory?
Filling in the Ecma Eco Declaration is a voluntary process for manufacturers, for each of their products. However, some items listed in ECMA-370 have declaration requirements, which may come from a European Directive or Regulation, or from the referenced standard (EN). For example:
When this occurs, it is noted in the relevant ECMA-370 Annex.
Publication of Declaration of Conformity and related documents
As stated in the Conformance Clause (2), “The declaration may be published only when all rows and/or fields marked with * are filled-in”.
Once completed, the Declaration of conformity to ECMA-370 (The Eco Declaration) must be available on a website of your company that is publicly accessible (e.g., customers, authorities, etc.) or be made available on request.
Please note that for some items, a link is requested (e.g., P1.7, ‘add URL or mail contact’, or for items in Annex C), also pointing to one of your company’s web pages.
Other documents:
The following statement appears in Annex C:”The tables below list the verification documents that should be made available (either electronically, e.g., available on a public web-site, or in a printed form) in accordance with item 6.2 of this Standard.”
And clause 6.2 of the standard states:
All claims made in the declaration shall be verifiable on request as usual business practice. Examples of documents to be presented in such cases are: … [text cut]
Verification documents, such as listed in Annex C, should be made available within 30 days after the request.
It is sufficient to provide these other documents only following a request.
There is no central database, either maintained by Ecma or by authorities, containing all Eco Declarations; there is no registry of conformant suppliers and/or products.
What is the added value of ECMA-370?
For the one making The Eco Declaration as well as for the one reading it, the advantage of ECMA-370 is that it gathers, in a single place, all the information on the European legal requirements as well as on the main worldwide market requirements (to the extent of knowledge at the time the ECMA-370 standard was published).
What about 3rd party verifiers?
The Eco Declaration, ECMA-370, is used as a Supplier’s Self-Declaration scheme. Ecma and its members are not aware of any qualified 3rd party verifiers to perform verification.
Update of declarations when a new edition of ECMA-370 is published
Example of latest update:
ECMA-370 was updated in December 2019 because some of the referenced regulations had changed. For example:
– Directive 2014/35/EU (Low Voltage Directive) replacing Directive 2006/95/EC
– Directive 2014/30/EU (EMC Directive) replacing Directive 2004/108/EC
– Directive 2014/53/EU (RE Directive) replacing Directive 1999/5/EC
– Addition of COMMISSION REGULATION (EU) No 617/2013 of 26 June 2013 implementing Directive 2009/125/EC of the European Parliament and of the Council with regards to eco-design requirements for computers and computer servers.
This implies necessary changes in the eco-declarations, hence the update of ECMA-370.
Although this is a significant amount of work, it is strongly recommended that declarations made before 2019 are updated, at least for all company’s key products, with particular attention to the items corresponding to the modified references.
Publications of updates are made in the same way as for any other Declaration of Conformity.
Use of ECMA-370 for products not referred to by the standard
NOTE Annex B1 is for Imaging equipment, Annex B2 is for Computers and computer monitors. Considering ECMA-370 clause 1, Scope, ECMA-370 can serve as a useful purpose for products that are neither imaging equipment nor computers or computer monitors. One should however be careful: for such products, filled-in annexes do not constitute a valid Eco Declaration as for products not considered for inclusion in the ECMA-370 scope at the time of approval. Mandatory legal requirements may be missing, as well as key market requirements.
Servers – distinction between computer products
Prior to the 4th edition, Annex B was valid for all types of IT products, instead of the two annexes, B1 for “imaging equipment” and B2 for “computers and computer monitors”. This change was due to the fact that “imaging equipment” (printers, copiers) are quite different from other IT products: use of “consumables”, different chemical emission, different rules for energy or acoustic consumption.
So, for servers, the advice is to use the current Annex B2, “computers and monitors”. If “servers” means more than computers (e.g., a large computer centre or “server farm”), it would be different, as the energy consumption of such installations is outside the current scope of ECMA-370 and would need to be studied separately.
Other types of ICT devices
If you have more questions about The Eco-Declaration (TED)?
You can contact us by visiting this page on our website: https://www.ecma-international.org/contact/