Navigating the French Sustainability Index: Is your HVAC Product in Scope?

Underestanding The French Sustainability Index

Are HVAC products in scope of the French Sustainability Index of Electrical and Electronic Equipment, Draft Decree, August 2023?
As HVAC products are considered EEE do businesses need to provide a sustainability index for these products?

Key Legislation: Circular Economy Law 2020

The repairability index and new sustainability index are based on Article L541-9-2 of the French Environmental Code which was introduced by the Circular Economy Law 2020.

The Transition from Repairability Index to Sustainability Index

L541-9-2 states that from 1 January 2024, the sustainability index will be introduced for certain products. https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000041555848/

This new Draft Decree on the sustainability index for EEE implements Article L541-9-2 by proposing to add a new Art. R 541-233 to the Code which says: “For each category of equipment covered by Order of the Environment and Economy Ministers, and adopted pursuant to this Article, the sustainability index shall replace the repairability index provided for in I of Article R. 541-210, as from the entry into force of the sustainability index for the category of equipment concerned.”

Which Products are Currently in Scope?

My reading of this proposed Article is that the sustainability index will apply to the EEE that are already subject to the repairability index by virtue of a Ministerial Order issued by the Ministry Environment and Economy in order to replace the repairability index with the sustainability index. 

To date, Ministerial Orders have been issued on the repairability index for the following products (smartphones, laptops, TV monitors, electric lawn mowers, top-loading washing machines, dishwashers, vacuum cleaners, and high pressure cleaners.) so these are the products that will be selected firstly for the sustainability index in accordance with Art. R 541-233.

As HVAC are not currently covered in this list, there is no requirements to apply the sustainability index to these products at this stage. If the French Government decide to include HVAC at a later stage we would expect to see this issued in accordance with a specific Decree. 

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