Cefic Advocates Strategic Approach for Effective Implementation of Ecodesign for Sustainable Products Regulation in EU

The European Union is pushing forward with the Ecodesign for Sustainable Products Regulation (ESPR) as part of the broader Sustainable Product Initiative. ESPR extends the scope of the existing Ecodesign Directive beyond energy-related products, setting legal requirements to enhance the sustainability of a wide range of physical goods in the EU market.

The regulation focuses on aspects such as resource efficiency, carbon neutrality, and transparency, aiming to promote product durability, reusability, and repairability. One notable feature is the requirement for all regulated products to have a "Digital Product Passport," offering detailed information about their environmental sustainability.

Recognizing that product design significantly impacts a product's lifecycle environmental footprint, the EU anticipates that fostering more energy and resource-efficient products will contribute to the goals outlined in the Green Deal.

As part of the ESPR, the term "substances of concern" is introduced to address the role of specific elements during recycling processes. The EU chemical industry is supportive of transparent communication about these substances along the value chain, enhancing the circularity of products and materials.

The EU chemical industry emphasizes the importance of addressing substances of concern on a case-by-case basis, with customized restrictions ensuring effective circularity management. The challenge lies in the broad definition, potentially encompassing around 12,000 out of the 23,000 registered chemical substances in the EU, making implementation a complex task for manufacturers and recyclers.

To navigate these challenges, Cefic recommends defining groups of substances of concern specific to each product group and regularly reviewing these lists to align with evolving recycling technologies. Additionally, they propose maintaining REACH as the primary legislation for substance safety, clarifying that safety concerns unrelated to recycling or reuse should fall under REACH rather than ESPR. A clear definition of "negatively affects re-use and recycling" is also suggested for legal clarity, with involvement of relevant experts in committees to maintain a clear distinction between safety and circularity restrictions.