In light of the European Commission’s recent publication of the new regulation on ‘Ecodesign for Sustainable Products’, APPLiA Director General, Paolo Falcioni, sat down with Kevin Bradley, Senior Advisor at Rue Pedersen Public Affairs to discuss the impact of the proposal on the industry, in a podcast interview.
Listen to the podcast, here.
The European Commission’s sweeping plans to make products placed on the EU market fit for a climate-neutral, resource-efficient, and circular economy are a cornerstone of its renewed approach towards EU product policy.
Only in the last year, eco-design requirements saved consumers 120 billion euros in energy costs (EVP Timmermans), an indicator of the extent to which the Directive has been successful in delivering on environmental, energy efficiency, and decarbonisation objectives for energy-related products. For this reason, “broadening the scope to include non-energy related products, would risk having serious unintended consequences, questioning its proven legal ground, regulatory process, and methodology,” began Falcioni. Moving forward, APPLiA proposes that parallel legislation be introduced, with appropriate methodologies, for the latter that takes inspiration from the good practices of the current Ecodesign. Without a doubt, the Sustainable Products Initiative (SPI) has the potential to create a ‘win-win’ scenario for both EU manufacturers and environmentally speaking. Yet, for this to become a reality, “policy objectives, choices, and incentives across all policy areas must be implemented in a clear and consistent fashion to create a market for sustainable circular business models and opportunities from a product life cycle perspective,” Falcioni stated.
Unprecedentedly, the proposed Regulation also defines substances of concern in products. Falling already under the scope of ROHS and REACH, banning dangerous substances in articles, “products do not contain hazardous chemicals today,” detailed Falcioni. For this reason, the Regulation should build on the existing EU policies, complementing them rather than duplicating product requirements, which would only generate a lack of legal clarity and certainty.
When it comes to the SPI’s interpretation of a product’s Ecodesign assessment and regulation, a harmonised, consistent and robust approach must be adopted. In this regard, legislation should set objectives towards stimulating the innovation of more sustainable products whilst the industry itself should have the freedom to implement the best possible way to achieve increased levels of innovation. “EU policies should reward industry investments, while leaving manufacturers free to choose their preferred route towards greater sustainability,” affirmed Falcioni. In the Commission’s freshly released package, one means of increasing market surveillance of products towards a circular economy is through the proposed ‘Digital Product Passport’. By design, the basis of the initiative is to contain information about the composition of products on the EU market to help increase the number of applications being reused and recycled. While the tool could play an instrumental part in providing more clarity within the supply chain, “it remains unclear what problem this is trying to solve in the first place,” commented Falcioni. Information criteria must be fully assessed on a sector by sector and then product by product level, to ensure true added value is inherited by the proposed regulatory framework. A cost-benefit analysis proving the environmental benefits of such an instrument, should be carried out in order to best assess its potential, if any” Falcioni declared.
Overall, the SPI offers a promising opportunity to pave the way for a future policy landscape where sustainable products are the norm. , To this end, “moving towards a more coherent EU policy framework for a circular economy that preserves the EU Single Market, competition, and innovation, at all levels is key to a successful implementation” concluded Falcioni.
Listen to the podcast, here
Read APPLiA’s press release on the Sustainable Products Initiative