EGMF EPTA position paper on the Ecodesign for Sustainable Products Regulation proposal

We are pleased to share our joint position paper, developed with EPTA, on the European Commission’s Ecodesign for Sustainable Products Regulation (ESPR) proposal, which aims to provide our comments on various aspects of high relevance to us.

This paper follows our participation in the Sustainable Products Initiative consultations, our previous joint position paper, and latest response to the Commission’s ESPR consultation.

We express strong support for:

• The proposal’s push to improve the resource efficiency of the European economy, while levelling the playing field by harmonising European rules.
• The intended product-by-product approach to tackle the various product categories that will be regulated.
• The Commission’s intention to integrate the input and specialised knowledge of external stakeholders into the EPSR and setting out an ESPR standardisation roadmap.

However, we would also like to draw attention to several aspects that we believe need clarification or are highly concerning for us, including:

• The granularity, type, and accessibility of information in the Digital Product Passport.
• The clarity, relevance and necessity to tailor specific performance and information requirements to given product groups.
• The need to include concepts such as intended use, specified conditions of use, and maintenance.
• The vital importance of not regulating chemicals under the ESPR, rather through existing legislation on substances such as the REACH Regulation or the RoHS Directive.