Position paper - Ecodesign for Sustainable Products Regulation (ESPR) - Analysis of the final text

It is important to remember that rules on product design are a good starting point, however, they will not automatically reduce the overall volume of products produced and then sold in the EU or reduce the industry’s material footprint - a key missing step to bring us back within the planetary boundaries that we are overstepping every day.2 The publication of the regulation in the Official Journal. [...] For many years, we have been vocal in expanding the ecodesign framework to all products, advocating wider and better ecodesign rules based on the proven success of the 2009 Ecodesign Directive – the predecessor of the EU Ecodesign for Sustainable Products Regulation (ESPR). [...] Civil society advocacy led to the inclusion or improvement of several of these parameters, namely the impact of substances on human health and environment, the use or consumption of energy and water, emissions to air, water and soil, and the release of micro/nanoplastics as well as the material footprint of products. [...] The EU, (6% of the world’s population), consumed 17% of all raw materials extracted in 2019.5 The ESPR's objective is to improve the sustainability of products, which ultimately means to reduce raw material extraction for products consumed in the EU. [...] The provisions on unsold goods will eventually apply to medium-sized companies, but small companies are regrettably not included in the scope, considering that the vast majority of EU companies are micro and small enterprises.iii We encourage policymakers to include micro and small enterprises in the scope of the unsold goods provision in the future for a more wide-reaching impact.