The proposal for a Regulation on Ecodesign for Sustainable Products addresses product design, which determines up to 80% of a product lifecycle environmental impact. It sets new requirements to make products more durable, reliable, reusable, upgradable, reparable, easier to maintain, refurbish and recycle, and energy and resource efficient. In addition, product-specific information requirements will ensure consumers know the environmental impacts of their purchases. All regulated products will have Digital Product Passports.
The Commission’s proposal extends the existing Ecodesign framework in two ways:
- First, it covers the broadest possible range of products, where the Commission has identified that product categories such as textiles, furniture, mattresses, tyres, detergents, paints, lubricants, as well as intermediate products like iron, steel and aluminium have a high environmental impact and potential for improvement, and may thus be suitable candidates for the first work plan.
- Second, it wants to broaden the scope of the requirements with which products are to comply, setting criteria not only for energy efficiency, but also for circularity and an overall reduction of the environmental and climate footprint of products. The Commission hopes this will lead to more energy and resource independence and less pollution.
All regulated products will be required to have a Digital Product Passport. The information to be included in these passports will be determined when preparing product-specific rules. It may include information such as the environmental footprint of a product, information useful for recycling purposes, the recycled content of a certain material, information about the supply chain, and others.
The proposed Regulation sets a framework that will enable to lay down product-level rules in a second stage, through delegated acts, product by product or for groups of products, if appropriate.
Overall, we support the Commission’s ambition to improve the environmental performance of products. We are however worried how the inclusions of new criteria in the framework of EU product policy will be implemented. We have observed many difficulties with environmental assessments such as the PEF and OEF methods, where even small differences between products, even in the same product category, can lead to large differences in the assessment of the environmental performance of a product, often unjustifiably so. The Commission has opened an 8-week feedback period. You will soon receive a circular for your feedback. Please do make sure to give us your feedback on this important topic!
