"When it comes into force, it will require a level of analysis and information collection that will be fairly onerous," understates Eric Larkin, CTO of Arena Solutions, in talking about the impact of EuP on just on IT. Arena is a hosted product-lifecycle-management SaaS (software as a service) company.

Here's why Larkin believes as he does. Article 8, section 3 of EuP says in part the following: "After placing an EuP ... on the market ... the manufacturer or its authorized representative shall keep relevant documents relating to the conformity assessment performed and declarations of conformity issued available for inspection by Member States for a period of 10 years after the last of that EuP has been manufactured."

The burden will fall heavily on IT departments that must comply with a two-and-a-half-page list of "management system requirements for assessing conformity" for officials. (See Annex V of the document.)

Although Article 16 includes a three-year transitional period, some products with a "high potential for cost-effective reduction of greenhouse gas emissions" will be regulated much sooner. Among the list of products in that category are office equipment and consumer electronics.

Finally, here's a snippet from Article 1, paragraph 2, that demonstrates the scope of this directive: "The directive provides for the setting of requirements which the energy-using products covered by implementing measures must fulfill in order for them to be placed on the market."