The European Commission’s Joint Research Centre (JRC) has published the final version of its report on possible new product priorities to be developed under the “Ecodesign of Sustainable Products Regulation” (ESPR).
From an initial list of 33 product groups, 18 products (11 final and 7 intermediate) were selected based on environmental, market, and policy considerations. The 18 selected product groups were then evaluated in terms of environmental relevance (i.e., impacts and potential for improvement) for 10 impact categories that address the EU’s main climate, environmental and energy objectives.
The paper stresses that the results presented do not constitute final decisions for the regulation of priority products, but will feed into the Commission’s future decisions on the work plan and preparatory studies for the upcoming Delegated Acts.
We know for certain that this report is the basis for finally establishing the products (or product groups), and horizontal measures that will be included in the first regulation work plan, which is scheduled to be published in April 2025.
But what has changed from the previous version of the same Report and what requirements should we expect?
We did a careful comparison analysis, going to assess the different product categories to understand what requirements we should probably expect with the delegated acts. Our analysis also took into account, both guidance and clarifications that the EU Commission itself published last September with the Frequently Asked Questions (FAQ) document, as well as performance and information requirements already in other delegated acts.
The final framework that emerged is quite clear especially for product groups such as furniture, textiles, toys, cosmetics, iron and steel, aluminum and plastics where environmental product requirements are already present, or are mentioned, in other regulations and therefore can only be included. For other products or product groups, it seems quite clear that since there must be transversality in the application of the regulation to facilitate/help consumer understanding at the purchasing stage, we expect consistency in both performance and information requirements.
Companies need to begin to take action regarding the new circular design approach required by the regulation and for the collection and management of information from the supply chain in anticipation of the implementation of the Digital Product Passport (DPP). Underestimate the scope of this regulation is a mistake that companies cannot afford.