APPLiA feedback to the Commission's proposal for an Ecodesign for Sustainable Products Regulation

In response to the Commission's Have Your Say consultation, APPLiA has consolidated a set of recommendations on the recently adopted proposal for an Ecodesign for Sustainable Products Regulation. 

Home appliance manufacturers are a clear example of how the EU industry can contribute to EU policy goals, through a longstanding commitment on developing and implementing Ecodesign and Energy Labelling legislation to make products as energy efficient as possible, as well as addressing chemical content and end of life management. Only in the past year, eco-design requirements saved consumers 120 billion euros in energy costs (EVP Timmermans). This data point is a clear indication of the good work the industry has been doing in the past 25 years and paves the way for the implementation of a future policy landscape for sustainable products that continues to drive Circular Appliances, building on the successes driven by the current product legislation. For this to happen however, we deem it necessary for policy objectives, choices and incentives across all policy areas to be clearly and consistently implemented with an eye to create a market for sustainable circular business models and opportunities from a product life cycle perspective.

This is where the EU’s proposed Ecodesign for Sustainable Products Regulation (ESPR) comes into play. In principle, the initiative has the potential to establish a win-win scenario for both the environment and European manufacturers. Yet, a number of adjustments are still needed in order to ensure a successful and effective implementation. By design, the ESPR looks as a catch-all legislation, putting together an all-encompassing ecodesign, energy label, waste legislation, chemical legislation and market surveillance legislation. As such, it is imperative for the proposal to be fully harmonised with all existing/upcoming EU legislation, with an eye to avoid double or cascading product requirements. This is the case for the proposed requirements related to “substances of concern”, among others, where chemicals legislation is already in place. Another example is provided by the proposed Digital Product Passport. Its introduction should ensure bringing an added value to users, avoiding unnecessary and burdensome replications of information in databases already existing, i.e. EPREL and SCIP. In this context, the successful experience of the Ecodesign Directive provides, once again, a good precedent towards the implementation of legislation on a product group-specific basis by means of a clear methodology assessing relevant, individual aspects across the product’s lifecycle. Future regulations within the ESPR establishing ecodesign requirements should identify the most appropriate variables to improve environmental sustainability, while considering that product parameters can be interdependent and affect each other (e.g. repairability can affect reliability etc.). We recommend evaluating the possibility to assess these parameters not individually, but in combination to ensure optimum contribution to the EU Green Deal objectives. Building on this, a bankable ESPR must ensure the well-functioning of the EU Single Market, in keeping markets open and cross-border trade for products flowing. Here, harmonisation of both requirements and standards is key, given that sufficient lead-time is granted to the industry for process adaptation, between the publication of legislation and the ultimate application of requirements. 

To conclude, the new Initiative seems to be a promising solution towards the establishment of a policy landscape where sustainable products are the norm. However, in order to make the most of it, it is key to move towards a coherent EU policy framework for a circular economy that preserves the EU Single Market, competition, and innovation, at all levels.