We have a serious concern on the scope of “Supplier facilities constituting at least 80% of production spend”.
Imaging equipment is composed of a very large number of parts, components and materials as compared with other product categories, because imaging equipment requires precision mechanism to generate high resolution images and driving mechanisms for image development and accurate positioning of paper feeding, and have unique high temperature and high voltage units as well as consumables as chemicals, which are completely different from other product categories. In addition, imaging equipment has a very wide variety of product range from household use to office use and high-end models.
Moreover, most of imaging equipment manufacturers have their own manufacturing facilities for final assembly, so the “production spend” of imaging equipment manufacturers corresponds to the lower case of the Annex D. Imaging equipment manufacturers have thousands of direct contract suppliers, so hundreds of suppliers are covered in “80% of production spend” suppliers.
On the other hand, in case that manufacturers outsource their final assembly for most of products, we assume that a large portion of their spend will be covered by the spend to “outsourced final assemblers (a)$)”. In other words, we think that the suppliers numbers covered in 80% production spend will have a large difference between imaging equipment manufacturers and other product categories manufacturers using only a few outsourced final assemblers. We think that the business size is also extremely different between “major outsourced final assemblers” and “parts/materials suppliers of imaging equipment”.
Under the current conditions which “suppliers spend” by “outsourced final assemblers” are not covered, we do not think that the draft criteria is not balanced due to an extremely difficulty to the imaging equipment.
If “80% production spend” is kept as a “required criteria” but not changed, we are afraid that almost all of imagining equipment may be non-conformance, though thousands of imaging equipment models are currently registered as EPEAT.
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