Policy Recommendations Smartphones

1. Functional and security updates for minimum 5 years

The draft Ecodesign regulation proposes 3 years of functionality updates. This is not enough considering the average lifetime of a smartphone is today 2½ - 3½ years and this is what the regulation is trying to lengthen. The minimum period of OS support should be 5 years. This would ensure compatibility with third party apps without which the consumer experience is heavily limited, hence a need for a new phone arises.

2. Repair score presented on the Energy Label

The current draft version of the EL regulation does not provide information on how easy it is to repair a device. This crucial information should be assessed and displayed on the Energy Label. A repair score should indicate how easy it is to repair a phone including a number of parameters, such as ease of dismantling the phone, and availability and cost of spare parts and tools. While the JRC study team is setting up a repairability scoring methodology, the EC could start by using the French method (Indice de Réparabilité).

3. Repairs must be open to independent repairers

To lower the barrier for consumers to repair rather than replace their smartphone, the repair process must be fast, transparent, and affordable. This can only be achieved if independent repair shops have the possibility to handle device repairs. Manufacturers oppose this stand and claim only authorized repair shops can deliver a safe and quality repair. As a consequence, they restrict distribution of parts, diagnostics, and repair tools.

The EU regulation should therefore (i) ensure that independent repairers can carry out repairs and (ii) clearly list what professional repairers need and need not to provide in order to be granted access to repair information through the manufacturers.

4. Display resistance against water in consumer-friendly way

The scale to assess the resistance to water and dust is based on an existing scale that is unknown to the average consumer. The pictogram representing dust/water protection in the Energy Label draft regulation is too difficult to understand for the consumer. A scale from A (best) through D (minimum Ecodesign requirement) appears more suitable.

According to the draft EL regulation, the protection against dust and water is displayed on the label using a code based on IEC 60529. The IP code (“ingress protection”) is composed of two digits, for example IP67.

Consumers should be able to decide based on the Energy Label alone and should not have to be aware of an existing scale that is not mainstream to interpret the pictogram. A scale from A to D appears suitable.

5. Reasonable pricing of spare parts

The draft Ecodesign regulation requires the publication of spare part prices as such. These prices must not increase during the defined time period in which the spare parts must be made available. The draft regulation, however, does not set any price limits, for instance the maximum cost of a spare part in relation to the cost of the smartphone as a whole.

At least, the regulation should add that prices for spare part should be “reasonable” or “proportionate”.

6. Empty A-Class when regulation enters into force

The energy efficiency classes should be defined in a way that the best class is empty when the regulation enters into force. According to the framework for energy labelling “a newly rescaled label should leave the top class empty to encourage technological progress”.

In Annex V, the draft Ecodesign regulation mentions smartphones already in class A. This is not allowed and the regulation contradicts the above principle.

Therefore, the EEI limits should be re-adjusted with the goal of an empty class A in 2023.

7. Clarifications for test conditions determining the EEI

The battery endurance per cycle is calculated using the maximum duration that a number of activities can carried out on the smartphone before the battery is empty. How long can you watch a video or make a phone call until the phone shuts off?

Comment 1: None of the four activity tests should be interrupted by a possible pop-up message or other that can appear when a device reaches a certain low battery threshold.

Comment 2: There should be a standard webpage used for the web browsing test with a representative amount of pictures/size that is close to real-life conditions.

Both suggestions aim to standardize the test conditions, make tests more comparable independent from the configuration and behaviour of the smartphone model, avoid loopholes, and make testing conditions closer to real-life scenarios.