Ref. Ares(2023)2118450 - 23/03/2023
Sustainable Products Initiative
Tata Consultancy Services Europe
May 3, 2022
Introduction
The ‘‘European Green Deal’ is the EU’s vision for ensuring a prosperous future for the European
Union region in economic, environmental and social terms. To achieve its goal of constructing a
modern, globally competitive, climate neutral and circular economy, as well as considering the
unprecedented effects of the COVID19 crisis, the EU envisages a twin ‘green and digital’ transition.
The March 2020 Circular Economy Action Plan (CEAP) is a cornerstone of this twin strategy providing
a roadmap for achieving a cleaner and more competitive Europe. The CEAP targets achieving 2030
climate and energy efficiency goals, climate neutrality by 2050 and ensuring economic prosperity
without being held hostage to environmental, social and climate impacts.
The Sustainable Product Initiative (SPI) is a key legislation within the CEAP and aims to make
products manufactured and traded in the EU region ‘fit for a climate neutral, resource efficient and
circular economy, reduce waste and ensure that the performance of frontrunners in sustainability
progressively becomes the norm’. The SPI will repeal the existing legislation on this front- called the
Eco-design Directive. The latter is to be widened beyond energy-related products and make it
applicable to the broadest possible range of products. The SPI will go hand in hand with other
initiatives announced in the CEAP, with the initiative on empowering consumers for the green
transition and the initiative on the substantiation of environmental claims using product and
organizational environmental footprint methods.
The SPI regulation will address the mechanisms for setting eco-design requirements such as product
durability, reusability, upgradability and reparability, the presence of substances of concern in
products, product energy and resource efficiency, recycled content of products, product
remanufacturing and high-quality recycling, and for reducing products’ carbon and environmental
footprints.
TCS’ Vision on SPI
At TCS we believe that the Sustainable Products initiative is a major opportunity to ensure that
products designed, manufactured and traded in the EU region set a global norm for realizing a truly
circular economy. Technology will be at the center of supporting durability, reusability, upgradability
and repairability standards.
1. Repairability by Design
Repairability must be embedded in the design consideration to make it easier to dis-assemble
and repair. The design must not be complex from the point of view of assembly or repair.
Modularity of products must not be only from a point of view of assembly and construction of
product but also in terms of repairability, i.e., modular assembly should allow access and
replacement of parts, especially for components that are prone to failure. Examples of this are
using removable fasteners instead of adhesives, parts that are most likely to fail should be the
most accessible to remove, incorporating less complex, or modular designs, etc. Obsolescence
by design or other such anti-repair behavior must be controlled.
Repairability by design would include ‘designing’ in access to the required specifications and
design documents by the repairer. Repairability by design would include End of life (EOL)
protocols for dismantling as well as legal protocols for sale of parts with certification. Digital
passports tagged to products or components thereof will help in designating the critical parts
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that must be made repairable and the protocols for it. This will be an invaluable technological
means to advance circular economy goals, applied across a product lifecycle.
Supporting technology
x Data Modelling / Simulation platforms can be used when designing products to simulate
working in real time
x Incorporating axiomatic design principles in the analysis and design process in the
simulation platform will allow for inclusion of eco-factors into the design process as
functional requirements and design parameters.
2. Access to defective/End of Life parts
Access for replacements to defective or End of Life (EOL)parts must be accessible to the cross-
industry ecosystem as well as the manufacturer’s own ecosystem. To scale repairing for extending
product life governing bodies need to have access to ecosystem which handles defective, end of life
parts from multiple industries so that it can be disassembled for recycle/upcycle. Digital platforms
will help qualify recommend, certify, repair and network- this must become a key part of OEM
ecosystem. These will function as ‘digital marketplaces’ but governed by 3rd party accreditation and
industry standards.
A clear guideline on classifying a part as repairable, recyclable or discarded can help in enabling 2nd
life and responsibly disposing EOL parts. There must be access to a fault / repair database across the
ecosystem to facilitate decisions on design feasibility. Common replacement techniques as well a
tools and schematics would be a part of this.
There must be legal protection and clarity on liability and IP issues to make the above possible,
including third-party access to OEM parts. Accreditation bodies can provide independent standards
to support this.
Supporting technology
x Track and trace solutions and analysis supported by IoT sensors and platforms
x RFID and RTLS to signal repair / replacement requirements in real time
x Blockchain-based ecosystem developed by OEM’s for publishing guidelines and supporting
decisions on repairability and consequent actions for relevant players in the value chain.
3. Enable Seamless Repair
Seamless repair is about making repair activities beneficial for planet, consumers and everyone
involved in that ecosystem by making repairs sustainable and reliable.
Access to relevant data to anticipate, signal and identify repairs is critical to making seamless
repair successful. Equally and critically, access to the tools and the skillsets required for enabling
seamless repair must be designed into the product through the length of its lifecycle.
Supporting technology
x XR & Immersive technology supported by the attendant ecosystem
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x Digital Twin technology will support testing and collection of data. Digital Twin Technology
can be used to simulate finishing of products, access to specifications and critically also the
access to required skillsets
x 3-D printing technology will provide access to spare parts as well as tools to enable
decentralization of the repair process
4. Consumer behavior
The SPI must include measures to extend product life cycles by incentivize appropriate consumption
and repair behavior on the consumer side. For this tracking of repair rates at an industry level or
other measures to estimate the footprint of repair behavior would be important.
Consumer purchase behavior could be used to predict requirement of parts by manufacturers.
Maintaining contact with products/ assets once sold– and incentivizing customers to keep the
contact as well as adopt appropriate EOL behaviors through warranty schemes etc. these are aspects
that will be supported by technology.
17 Mar 2022
TCS Europe Corporate Affairs
For more information please contact:
@tcs.com
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