Ecodesign for Sustainable Products Regulation (ESPR) - a BusinessEurope position paper
BusinessEurope welcomes the European Commission’s efforts to establish a functioning EU market for secondary raw materials and circular products. The proposal for a Regulation on Ecodesign for Sustainable Products (ESPR) is a unique opportunity to reach this objective by removing current questions of inconsistencies between the EU and the national levels.
The ESPR proposal rightly maintains the principles of the current Ecodesign Directive, which has proven to be effective, including setting tailored requirements per product group and in coordination with relevant experts and stakeholders.
In 10 specific areas, the proposal needs further work for better enforceability:
- Require information on substances of concern based on their relevance, usefulness and information demand in the value chain.
- Set up a Digital Product Passport which is strictly relevant to circular economy purposes, protects confidential business information and relies on good quality, consistent, comparable and interoperable data.
- Establish a strong inclusion of key stakeholders, notably from the industry, in policy making process, including by means of the Ecodesign Forum and appropriate consultations, and immediately set up a dialogue with EU’s major trading partners.
- Set up comprehensive assessments based on impact focused LCA approach for the development of ecodesign requirements.
- Ensure policy coherency of scope and requirements between the ESPR and other EU legislations.
- Base performance requirements and compliance methods on harmonised European or international standards. The Commission should issue common specifications only in exceptional instances.
- Avoid requiring third-party conformity assessments, as unnecessary and costly.
- Define products to be prioritised according to their environmental and economic potentials.
- Gradually implement requirements on destroyed goods.
- For legal clarity, harmonise definitions with existing legislations and initiatives.
The Annex of the position paper includes detailed amendment proposals.