Ref. Ares(2020)734447 - 05/02/2020
Ref. Ares(2020)2498329 - 12/05/2020
Ref. Ares(2020)734447 - 05/02/2020
Ref. Ares(2020)734447 - 05/02/2020
Ref. Ares(2020)2498329 - 12/05/2020
Test & Measurement Coalition - Circular Economy
January 2020
Introduction to the T&M Coalition
The Test & Measurement Coalition represents an ad-hoc group of companies active in producing test &
measurement industrial type products. The Coalition includes leading companies in the sector including
Agilent Technologies, Fluke Corporation, Keithley Instruments, Keysight Technologies, National
Instruments, Thermo Fisher Scientific and Tektronix. We estimate the coalition membership represents
over 60% of the global production of industrial test and measurement products and other industrial
equipment including chemical analysers.
Products include a wide range of sophisticated electronic instruments such as signal generators, logic
analysers, oscilloscopes, spectrum analysers, digital multimeters, electron microscopes, chemical and
biological analysers, complex chromatography systems and their detectors, etc. The instruments are used
in Research, Quality Control and Testing laboratories (including field testing) in Universities, Manufacturing
facilities and by Governmental Agencies (for conformance verification and environmental testing). They
are essential to the good functioning of electronic communications networks, heavy industrial processes
such as steel manufacturing, the testing of vehicles for compliance with emissions standards, and the
monitoring of complex and critical systems of all types.
The whole of the monitoring and control category of equipment represents by weight 1.8% of the total
Electrical and Electronic Equipment (EEE) put on the EU market and 0.7% of the total Waste EEE (WEEE)
collected in the EU (EU official figures, Eurostat 2016.) Industrial Test & Measurement instruments, a
subset of monitoring and control category, therefore only represent a fraction of these values: an
insignificant contribution to the waste stream as compared to other EEE categories.
Logic of the Circular Economy
The aim of the industrial sustainability transition is to move in a
strategic shift from a linear (“take, make,
dispose”) to a circular economic model (“reduce, reuse and recycle”), in which consumption of scarce
resources is limited and negative climate and environmental externalities are reduced as much as possible,
at all stages of the value chain. A circular economy favours activities that preserve value in the form of
energy, labour and materials. This means
designing for long-lasting use, reuse, remanufacturing, and
recycling to keep products, components, and materials circulating in the economy.
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Circular Economy model
(Ellen MacArthur Foundation 2013 – adapted from Cradle to Cradle Design Protocol by Braungart & McDonough)
Circular Economy model for Test & Measurement instruments
The core loops of the Circular Economy model for technical materials are: maintain, reuse, refurbish and
recycle. How are they translated for industrial test & measurement instruments?
In regards to the Circular Economy principles, industrial test & measurement instruments are very
different from high-volume consumer products which are frequently re-designed to follow consumer
trends (every 1.5 year on average).
Industrial test & measurements instruments are intentionally designed for long useful lifespans with high reliability. Test and measurement instruments (category 9
under the RoHS Directive) are designed: exclusively for professional and industrial use; to meet high
performance requirements in critical applications; and last up to 40 years (10 years typical first life).
Redesign is not frequent and happens every 7 years on average after which they typically enter a long-
term customer support period.
The main focus of the test & measurement sector within Circular Economy is therefore on the use phase
and how to prolong it.
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x
MAINTAINING: Our instruments are expected to provide repeatable and accurate results
throughout their lifetime. With a typical first use of ten years and an overall life of up to forty
years; great care is taken during design and qualification to assure these stringent performance
and rigorous reliability requirements can be met, as well as incorporate design for serviceability.
To extend availability, instruments can be leased or rented; directly or through brokers; helping
SMEs avoid capital expenditure and improve utilization. We provide periodic calibration services
to assure the quality and traceability of instruments measurements are sustained year after year.
x
REPAIRING: While our instruments are designed for long term reliability, failures do occur over
such an extended use period. Our repair services help minimize any instrument down-time and
customer disruption. Equipment is typically supported for a minimum of five years after market
withdrawal. Towards the later stages of useful life, specific parts and sub-assemblies no longer
available on the open market may be recovered from end-of-life equipment specifically to extend
the support period.
x
REFURBISHING: Technology does not stand still, and enhancements and upgrades are made
available to extend the useful life of equipment. When a newer piece of equipment is finally
required, substantial trade-in discounts are offered to customers to reflect the residual asset value
of the instruments. This provides a steady supply chain of equipment for refurbishment. Extended
life via resale is of great economic and environmental benefits.
Secondary markets
(refurbishment and resale) are significant in this sector as they often account for 4-5% of producer
turnover for test & measurement producers.
x
RECYCLING: Equipment only enters the waste stream many decades after being placed on the EU
market. Our contribution to the stream of waste electrical and electronic equipment (WEEE) is
insignificant (< 0.7% by weight of EU WEEE1.) WEEE is collected exclusively through business to
business – B2B schemes.
This strong focus on maximizing the use phase is completely in line with the first loops of the Ellen
McArthur Foundation Circular Economy model, which is at the heart of the European Commission’s
ongoing discussions on the regulatory framework for a Circular Economy 2.0 in the European Union.
1 Eurostat: WEEE Data 2016 – no distinction between industrial and non-industrial equipment
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The specificities of the test & measurement sector is also translated in
specific challenges in the field of
the Circular Economy, which need to be understood by policy-makers, especially in the framework of
debates on the tracking of certain substances, or possible future restrictions of certain substances:
x
Feasibility challenges in tracking substances:
o Traceability is challenging
given the extreme complexity of Test & Measurement
products: 25 - 35% of the components used in Test & Measurement products are custom-
designed for instruments. Member companies of the Test and Measurement Coalition
have supply chains that can exceed 100 000 suppliers for the quarter of a million parts
used to produce our equipment; with portfolio scale of up to 5000 active products from
any one producer. Traceability will therefore pose significant feasibility challenges for the
sector.
o As a result of their long product life, some instruments may only enter the waste stream
up to 40 years after they are placed on the EU market. Taking into account the
constant
evolution of the list of substances of concern – especially over the course of several
decades – this raises questions on the value of this information for the recyclers.
x
Need to assess the cost-effectiveness of restricting substances in products:
o Test & measurement members
proactively started to work on redesign before entering
the scope of the RoHS Directive, and it took them 12 years to be RoHS-compliant.
Substitution is very challenging as test & measurement instruments have to guarantee
very high long-term reliability criteria during an extended lifetime.
o
The impact on innovation for the users of test & measurement products would also need
to be assessed. This
includes SMEs which would be critically impacted in their ability to
develop/ test new products if access to equipment is removed or availability of second-
hand / refurbished products is made more difficult.
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o
After detailed risk assessments, a number of exemptions were granted to test &
measurement companies to be able to use minimal quantities of certain substances of
concern in very specific applications, under sectoral legislation. These exempted
applications are essential for ensuring the performance and long-term reliability of test &
measurement products during their entire lifetime. The
overall long-term benefits from
circular use in these cases outweigh the health and environmental concern related to
these substances, where the use is made in close loop professional systems with
appropriate controls, or where use is possible without raising environment and health
concerns.
o
A cautious approach is therefore needed, taking into account the cost-effectiveness and
impact of potential restriction measures.
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