Hand Dryers First stakeholder consultation meeting 17/01/2019 Tom - - PowerPoint PPT Presentation

Lot 12 Ecodesign Preparatory Study on Hand Dryers

First stakeholder consultation meeting

17/01/2019 Tom Lock Laurent Petithuguenin Thomas Ramsson Mark Allington Tom.Lock@icf.com Laurent.Petithuguenin@icf.com Thomas.Ramsson@icf.com Mark.allington@icf.com

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Agenda

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• 1. Welcome & Introductions

10.30 – 10.45

• 2. Overview of Preparatory Study

10.45 – 11.15

• 3. Draft Task 1 Report - Scope

11.15 – 12.45

• 4. Lunch

12.45 – 13.30

• 5. Draft Task 2 Report – Markets

13.30 – 15.00

• 6. Coffee break

15.00 – 15.15

• 7. Draft Task 3 Report – Users

15.15 – 16.30

• 8. Feedback & Next Steps

16.30 – 16.45

• 9. AOB

16.45 – 17.00

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Overview of Preparatory Study

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Overview

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• Aims & objectives
• Method & task structure
• Project team
• Schedule for deliverables & key meetings
• Gantt chart
• Allocation of resources
• Stakeholder engagement

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Study aims & objectives

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• Aim
• To analyse the “hand dryers” product group for the creation of EU

sustainable product measures – namely Ecodesign and Energy Labelling.

• Objectives
• Investigate the potential for the environmental improvement of the product

group “hand dryers”, including aspects relevant to the circular economy.

• Provide the necessary analysis on the product group “hand dryers” that will

help inform policy makers to develop minimum Ecodesign requirements and where appropriate energy labelling requirements

• These policy options will be used in the EC’s subsequent impact assessments
• ICF are using the MEErP methodology to realise the aim of the study

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Method & task structure

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• The study is following the Methodology

for the Ecodesign of Energy related Products

• MEErP is a life cycle analysis tool used to

identify policy options for reducing the environmental impacts of ErPs

• MEErP is comprised of 7 tasks:
• Task 1 Scope (product, standards & legislation)
• Task 2 Markets (economic, market, price data; trends)
• Task 3 Users (systems, in-use impacts; circular economy)
• Task 4 Technologies (description, analysis, BAT, BNAT)
• Task 5 Environment & Economics (base case(s), impacts, costs)
• Task 6 Design Options (improvement potential, costs, LLCC, BAT)
• Task 7 Scenarios (policy options to achieve improvements,

quantifying impacts and costs)

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Project Team

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DG GROW Cesar Santos, Policy Officer Tom Lock, Project Manager ICF Europe Thomas Ramsson Laurent Petithuguenin Yeen Chan James Gardiner Melisande Couespel Jon Arteta ICF U.S. Matt Malinowski Adam Spitz Anna Lasso, UL Gerrard Fisher, QSA Partners Mark Allington, Project Director

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Schedule for deliverables & key meetings

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• Key Meetings

First Stakeholder Mtg (mid-January) Interim Mtg with Commission (end of April) Second Stakeholder Mtg (mid-November) Final Mtg with Commission (mid-November)

• Deliverables

Draft Report (Tasks 1-3) Minutes from Stakeholder mtg Interim Report (Tasks 1-5) Draft Final Report (Tasks 1-7) Minutes from Stakeholder mtg Final Report (Mid-February 2020)

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Gantt

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Competencies & allocation of resources

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Prep Study

Supporting Engineers Yeen Chan James Gardiner Adam Spitz Circular Economy of Electronics Gerrard Fisher ErP Modelling & Technical Thomas Ramsson Matt Malinowski Laurent Petithuguenin Life Cycle Assessment of Hand Dryers Anna Lasso Supporting Modellers and Administrative Melisande Couespel Jon Arteta

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Stakeholder engagement

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• Approach:
• Open, collaborative, engaging, proactive
• Utilisation of extensive existing contacts & networks
• Proactive engagement with existing manufacturer contacts
• Dialogue:
• Continuous bilateral dialogue with manufacturers, suppliers, including eHA,

APPLiA and registered study stakeholders

• Milestone based dialogue at the stakeholder consultation meetings
• Engagement:
• Contact list of 68 manufacturers and suppliers
• 20 registered study stakeholders
• 14 engaged manufacturers
• 10 submitted questionnaires
• handdryers@icf.com / www.ecohanddryers.eu

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Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 12

Task 1 Scope

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Contents

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• Product Scope
• Classification & Definitions
• Performance Parameters
• First Screening
• Measurement & Test Standards
• Relevant Test Standards
• Comparative Analysis
• New Standards under Development
• Existing Legislation
• European
• Member State
• Third Country

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Product Scope

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• Classification & Definitions
• PRODCOM 27.51.23.50 electric hand drying apparatus
• 4 categories:
• Plus air taps
• Also classification by sensor type & mounting type
• Comments invited on definitions
• Any other known classifications?
• Scope exclusions – hand drying techniques that are not ErPs

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Product Scope

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• Performance Parameters / Functional Unit
• Quantified performance of the product, e.g.:
• Instances of use
• Remaining moisture content
• Time
• Test methods and schemes have quantified these product performance parameters

e.g.

• Energy Technology List: electricity consumption over 1000 drying cycles,

remaining moisture content of <0.15g, within 15 seconds

• Product Category Rule: 100,000 instances of use, remaining moisture content of

<0.25g

• NSF Protocol: remaining moisture content of <0.10g within 15 seconds

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Product Scope

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• First Screening

 Significant Sales & Trade >200,000 units per year across EU

• Almost 1M in 2017

 Significant environmental impact within the EU

• Electricity consumption in-use
• Noise
• Circular economy
• Hygiene

 Significant potential for improvement in terms of its environmental impact, without entailing excessive costs

• Electricity consumption could consider use + dryness + time
• Consider noise, circular economy and hygiene

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Measurement & Test Standards – Relevant Measurement & Test Standards

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• Covering Product Performance Parameters
• UK’s Energy Technology List Test Method for High Speed Hand Air Dryers
• NSF’s Protocol P335 for Hygienic Commercial Hand Dryers
• Germany’s Blue Angel criteria for Electric Hand Dryers
• UL’s Product Category Rule for Hand Dryer Environmental Product

Declarations

• Any other known measurement and test standards?

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Measurement & Test Standards – Noise

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• Relevant Measurement & Test Standards:
• Three schemes set noise performance requirements:
• Blue Angel scheme references: EN 60704-1: 2012 (under revision)
• Korean scheme references: ISO 1996-1
• NSF Protocol does not reference a test method

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Measurement & Test Standards – Comparative Analysis Performance Requirements (1/4)

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Measurement & Test Standards – Comparative Analysis Performance Requirements (2/4)

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Measurement & Test Standards – Comparative Analysis Performance Requirements (3/4)

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Measurement & Test Standards – Comparative Analysis Performance Requirements (4/4)

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• Blue Angel – consumption per use as opposed to aggregated value
• Material efficiency requirements introduced by Blue Angel – echoing current

requirements being introduced by the Commission under Ecodesign

• Blue Angel sets an alternate degree of dryness proportion parameter, rather

than an absolute value favoured by the other three schemes

• Blue Angel also effectively recognises conventional single point hand dryers

with the 30 second performance requirement

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Measurement & Test Standards – Comparative Analysis Test Methods (1/9)

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Measurement & Test Standards – Comparative Analysis Test Methods (2/9)

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Measurement & Test Standards – Comparative Analysis Test Methods (3/9)

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Measurement & Test Standards – Comparative Analysis Test Methods (4/9)

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Measurement & Test Standards – Comparative Analysis Test Methods (5/9)

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Measurement & Test Standards – Comparative Analysis Test Methods (6/9)

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Measurement & Test Standards – Comparative Analysis Test Methods (7/9)

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Measurement & Test Standards – Comparative Analysis Test Methods (8/9)

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Measurement & Test Standards – Comparative Analysis Test Methods (9/9)

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• NSF’s protocol is far less prescriptive on the hand wetting and drying

procedure, with no volunteer sampling or calculation method for remaining moisture content

• There are a number of departures within the Blue Angel test method from the

NSF Protocol (given the former is based on the latter)

• Blue Angel’s method for determining degree of dryness is quite different from
• ther schemes such as ETL. Instead a reference scenario is used, and the

effectiveness of the hand dryer is compared to the reference

• Electricity consumption testing varies between ETL and PCR – the former

extrapolates over 1000 cycles, whereas the latter tests individual units

• Alignment over test room conditions and commonalities over hand wetting and

drying procedure

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Measurement & Test Standards – New Standards under Development

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• Largely focused on Material Efficiency, following mandate M543 to the

European Standardisation Organisations

• Covers three material efficiency aspects
• Extending product lifetime
• The ability to re-use components or recycle materials
• Use of re-used components and recycled materials
• Draft standard prEN 45550 is under consultation
• Commission targeted March 2019 for adoption of the outputs of M543
• Is anyone involved in the work of CEN-CENELEC TC10?
• Any other known test standards under development?

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Existing Legislation

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• European
• Observation of the following:

LVD, EMC, WEEE, RoHS, REACH, Machinery Directive

• Ecodesign standby – 801/2013 amending 1275/2008, though no explicit

reference to hand dryers. Is it still effectively adopted and followed?

• Member State
• UK (ETL) and Germany (Blue Angel)
• Third Country Legislation
• Korean’s Eco-Label for electric hand dryers
• No current plans from the U.S. EPA regarding ENERGY STAR

(concern regarding the variability introduced from human hands)

• Any other known legislation or schemes?

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Discussion

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Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 35

Task 2 Markets

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Contents

• Generic Economic Data
• Market And Stock Data
• Market Channels
• General Trends In Product Design And Product Features
• Market Segmentation
• Consumer Expenditure Base Data

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Study participation

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41 3 10 4 14

Study participation

Not Engaged Declined Submitted Questionnaire Awaiting Answer

• Questionnaire respondents

currently were manufacturers. These include:

• Airdri Limited
• Dyson
• Excel Dryer
• Ffuuss
• Genebre
• Hokwang
• JVD
• Mediclinics
• Starmix
• World Dryer

Participants on average responded with 60% completion to questionnaires.

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2.1 Generic Economic Data

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• Review of PRODCOM 2017 data indicated
• Production in UK, Denmark, France,

Germany, Italy, Spain and Romania

• Import and export values for each EU

Member state

• Consistent image is shown of high value

EU production

• Strong dependency on imports to meet

demand

Volume (units) Value (€) Value per unit (calc. €) EU production sold 247,009 26,014,090 105 Intra-EU trade 189,184 14,493,075 77 Extra-EU export 97,240 11,382,970 117 Extra-EU import 828,619 29,830,740 36 EU sales and trade 978,388 44,461,860

Data prior to 2017 was collected from PRODCOM. However, inconsistencies were shown in the data. PRODCOM are currently reviewing this data before insertion into this report.

Source: PRODCOM

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2.2 Market and Stock Data - Stock

Hand dryer category 1990 1995 2000 2005 2010 2015 2020 2030 2050 Conventional single point 200 600 1,000 1,375 1,925 1,635 1,727 1,789.2 1,400 High speed single point 60 354.4 694 1,150 2,560 High speed multi-point 68.4 92.8 152.8 143 High speed trough style 10 77.5 173.5 299.0 957.5

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 39 Hand dryer category 2015 2020 Conventional single point 1,500 2,000 High speed single point 1,500 3,000 High speed multi-point 250 500 High speed trough style 1,000 2,000

Manufacturer feedback

Estimated Hand dryer Installed stock (in thousands) 3rd party installed stock values (in thousands)

• Clear uptake of high speed technologies taking

increased market share.

• High speed single point becoming the preferred

technology by 2050.

• Mismatch between industry estimates and 3rd

party reference on high speed categories. Further data would help reconcile differences.

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2.2 Market and Stock Data - Sales

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Hand dryer category 1990 1995 2000 2005 2010 2015 2016 2017 2020 2030 2050 Conventional single point 100 130 175 240 220 265 282 290 300 349 180 High speed single point 40 116 131 145 161 194 220 High speed multi- point 20 25 29 34 47 11 High speed trough style 1 8 24 29 33 37 52 85 Hand dryer category 1990 2015 2016 2017 2020 Conventional single point 50 100 100 100 100 High speed single point 250 275 300 400 High speed multi-point 50 50 50 50 High speed trough style 200 210 220 250 Manufacturer feedback

Estimated Hand dryer annual sales (in thousands) 3rd party annual sales (in thousands)

• Clear uptake of high speed technologies taking

increased market share.

• Mismatch between industry estimates and 3rd party

reference.

• Total numbers will be verified with PRODCOM

values. Further data from manufacturers would help reconcile differences.

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• Clear uptake of high speed technologies taking

increased market share. What is driving the transition to the high speed hand dryers? What are the factors driving sales growth? Demographics urbanisation, building regs

2.2 Market and Stock Data – Sales growth rate

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Hand dryer category 1990 1995 2000 2005 2010 2015 2016 2017 2020 2030 2050 Conventional single point 6% 7% 7%

• 2%

4% 6% 3% 1% 2%

• 1%

High speed single point 38% 13% 11% 4% 2% 1% High speed multi- point 24% 14% 6% 4% 2% High speed trough style 280% 44% 21% 14% 4% 4%

• 1%

Hand dryer category 2015 2016 2017 2020 Conventional single point 4% 0% 0% 0% High speed single point 10% 9.1% 11.1% High speed multi-point 0% 0% 0% High speed trough style 5% 4.8% 4.5%

Manufacturer feedback

Estimated Hand dryer annual sales growth rate 3rd party annual sales growth rate

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2.2 Market and Stock Data – Product lifetime

• Variability regarding technical and economic lifetimes, and the approach
• f end user with regards to repair and replacement.

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Hand dryer category Average Technical lifetime Maximum Technical lifetime Minimum Technical lifetime Average Economic lifetime Maximum Economic lifetime Minimum Economic lifetime Conventional single point 10.8 20 6 11.4 20 6 High speed single point 9.3 20 5 9.25 20 5 High Speed multi-point 7.2 8 5 9.25 7.5 5 High speed trough style 8.3 15 5 8.1 15 5

Insight into the calculation method of technical lifetime will allow for estimated lifetimes according to location. Derived replacement and new stock sales were calculated but were inconsistent with previous data. We intend to include these once a full model has been done. The importance and effect of maintenance need to be quantified. How often are hand dryers repaired rather than replaced?

Source: Study participants

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2.3 Market Channels

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• Complicated and varied routes to

market

• Some routes were identified, but

no values were attributed to their trade

• Manufacturers do not

necessarily have visibility over sales when using an importer

• 9% of sales were attributed to

B2C, in direct contradiction with data for the channels schematic

• Definitions for supplier,

distributor, wholesaler, contractor, purchaser, consumer and end user should be commented upon. (for e.g. In a commercial office building, who will own and repair the device? Tenant? Landlord? Etc.)

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2.4 General trends in product design and features

• Key features for each category are:
• Conventional single point: typically feature automatic operation (some push button)

and use warm air (sometimes controllable)

• High speed single point: typically feature automatic operation, some dry times <12

seconds, heating, HEPA filters

• High speed multi-point: typically feature automatic operation, some dry times <12

seconds, HEPA filters and antimicrobial technology.

• High speed trough style: all with a dry time <12 seconds, predominantly with HEPA

filter, some use heating,

• Product design trends have focused on these major points:
• Noise reduction for high speed dryers
• Improved HEPA lifecycle/ usability
• Better monitoring technologies (IoT)
• Improved water collection design for trough style hand dryers.

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2.5 Market segmentation

• Major players feedback has been fragmented:
• The top 7 manufacturers have been estimated to be responsible for the sales of 10-

41% on the market.

• The market share seems to be larger for the major manufacturers for the newer

technologies, such as trough style and multi-point hand dryers.

• Opinions are divided on which are the major players in each technology.
• 78% of the market share is estimated to be sold by SMEs

Supplementary data may help reconcile the differences noted between on market share for different categories according to each manufacturer.

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2.5 Market segmentation

Main manufacturer product ranges split by category

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Manufacturer Conventional single point High speed single point High speed multi- point High speed trough style No % No % No % No % Airdri 6 15 1 4 Dyson 1 4 1 17 1 8 Excel Dryer 3 12 FFUUSS 2 15 Genebre 5 13 4 15 2 15 Hokwang 3 8 5 19 1 8 JVD 4 10 2 8 3 50 4 31 Mediclinics 6 15 3 12 1 8 Starmix 3 8 2 8 2 33 1 8 World Dryer 12 31 5 19 1 8 Total 39 26 6 13

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Consumer Expenditure Base Data

• The economic lifecycle of a hand dryer was reviewed:
• Purchase of a dryer varies from €188 to €715
• Production costs haven’t been reviewed. Could an average per category be calculated?
• Installation is averaged at €100. No special training required labour costs of an

electrician only – Is this true for all categories of hand dryers? Would installation time vary?

• The only consumable identified is HEPA filters, to be changed every 3 to 12 months,

costing on average €50. – what is the variability of these filters according to hand dryer category?

• Repair as averaged at €78 and to only be the cost of a replacement motor and labour
• cost. Is this an accurate statement? Are there product category differences?
• Disposal costs have been mentioned in accordance to WEEE but not linked to a per

unit basis

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 47

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Discussion

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 48

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Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 49

Coffee Break

Please return by 15.15

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Task 3 Users

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 50

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Contents

• Product component and extended product approaches
• Direct vs indirect Energy-related-Products
• Maintenance, Reparability and end-of-life Behaviour
• Local infrastructure

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 51

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3.1 Product component and extended product approaches

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 52

Hand Dryer

Input power conditioning Activation circuits

• Sensors
• Push button
• n switch
• Timers

External casing Housing components Wall plate

Lights/displays

Air treatment Heating components HEPA filters Air flow Fan + ducting Mechanical force

• Motor
• A strict product/component scope

is not deemed adequate in the case of hand dryers as although components (such as the motor and fan) may be regulated under Ecodesign, its assembly and use within the hand dryer must be

• ptimised.
• The attached schematic shows

an example of the components in a hand dryer. – do you agree with this schematic? Should a VSD be included

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3.1 Systems aspects of the use phase for ErPs with direct impact

• Under an extended product approach, the

study incorporates a view on the various

• peration modes, frequency and characteristics
• f use.

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 53 Hand dryer category Average usage time (seconds/use)

Conventional single point dryer 24.7 High-speed single point dryer 12.6 High-speed multi- point dryer 13.7 High-speed trough style dryer 11.4

• Preliminary results indicate how the

high speed hand dryers approximately halve the average usage time to dry hands.

• Hand dryers usually function as either “on” (air flowing) and standby (awaiting

sensor/button activation).

• User variables affecting drying process will also be considered such as: size, shape, hair,

gender, skin type, wrist creases, movement, presence of jewellery. As well as hand wetting and drying.

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3.1 Systems aspects of the use phase for ErPs with direct impact

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 54 Hand dryer location Average usage per day Minimum usage per day Maximum usage per day

Airports 2355 300 3000 Railway Stations 950 250 2000 Shopping, commercial and multiplexes 800 200 2000 Education Institutions 625 150 2500 Hospitals 550 100 2500 Hotels & Restaurants 166 25 500 Office Buildings 163 50 300

• Busier locations such as airports and railway stations have much higher

average usage per day of dryers. This will affect maintenance and lifetime expectations for hand dryers.

• Location of the hand dryer

will greatly affect its usage, both on the number of uses per day and the time of use.

Source: Study participants

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3.2 Direct versus indirect Energy-related Products

• Electric hand dryers are considered a direct ErP, as the product uses

electricity during its use phase.

• Indirect ErPs would for example include insulation. The product itself does

not consume energy, but its installation within a wider system will effect the energy consumption e.g. within the building envelope. Electric hand dryers cannot be considered an indirect ErP.

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 55

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3.3 Maintenance, reparability and end-of-life behaviour

• Referring back to Task 2, the technical lifetime of hand dryers is heavily

dependent on the motor wear and proportional to usage. – Are there categories

• r designs better suited for certain applications? Could improvements be made

to extend the motor life?

• Economic lifetime was seen to be mainly influenced by the users disposition to

replace or repair. On a usage perspective do aesthetics influence the displacement of hand dryers? Are corrosion resistant standards present in the sector to maintain aesthetics?

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 56

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3.3 Maintenance, reparability and end-of-life behaviour

• Good practice and maintenance were identified to be linked mostly to regular

change of HEPA filters and water reservoirs. For trough style hand dryers, how

• ften is water reservoir emptying required?
• What misuse or poor installation issues have manufacturers experienced? E.g.

Washing the device causing malfunction? Wrong installation? Not replacing filters? Vandalism? Are some categories and designs more sensitive than

• thers?
• Changing HEPA filters is estimated to cost €16 over the lifetime of the asset.

For trough style dryers, maintenance includes HEPA filter changes and water tray emptying and is estimated at €338 over the life of the asset. – What happens when HEPA filters aren’t changed? Online research of prices found average of ~€50. Are these price estimates consistent? There are very large difference for hands in versus hands under dryers. Are filter replacements done by non-technical personnel?

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 57

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3.3 Maintenance, reparability and end-of-life behaviour

• Repair: Repair was estimated to be the replacement of the motor (which is the

item most likely to fail). As such the cost was the price of the motor and the labour cost, all estimated on average €78. – Is this accurate? Are there differences according to hand dryer type?

• Second-hand use: Respondents estimated that there was “no real” second-

hand market. Evidence was found online of small sales values (2,004 in UK).

• Refurbishment: Refurbishment was estimated to be a niche market, easily

done but usually only done on request of the customer as cost of refurbishment is close to that of a new device. – is this accurate? Would labour costs not drive up this price?

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 58

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3.3 Maintenance, reparability and end-of-life behaviour

• Recycling:
• Estimated only to happen in the frame of the WEEE directive.
• Opinions differing that recycling rate was up to 90% or near to none.
• Are recycled rates referred to here the amount of a material recycled from a device? Or

the % of the ones collected for recycling?

• Have there been different rates of recycling in different Member States? Are there

differences according to product type?

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 59

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3.4 Local infrastructure

• Three areas of local infrastructure to be reviewed for this study:
• Electricity generation: the nature of the electricity mix will be considered for each

Member state during the modelling tasks 5, 6, and 7.

• Installers: installation has been estimated to be simple and not requiring special training

beyond that of a qualified electrician. – is this true for all installations? Does it vary according to category? Are the same qualifications needed for maintenance?

• Physical environment: consequences of sharing the hand dryer across 2000 uses in a

day need to be considered. - Is there a potential issue of water damage from puddles? Would some categories of hand dryers be considered less damaging to their surroundings?

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 60

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Discussion

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 61

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Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 62

Feedback & Next steps

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Feedback & Next Steps

Lot 12 Ecodesign Preparatory Study on Hand dryers – 1st stakeholder consultation 63

• Written comments due on tasks 1, 2 and 3 by 31st January.
• Submitted to handdryers@icf.com
• Updated versions of the task reports will then be produced and

circulated

• In the meantime the study team will produce and circulate minutes

from the first stakeholder meeting

• …and progress with Task 4, Technologies.

AOB & Thanks tom.lock@icf.com laurent.petithuguenin@icf.com thomas.ramsson@icf.com mark.allington@icf.com