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Ecodesign for Sustainable Products - Product priorities

Environment

The Commission’s recent proposal on Ecodesign for Sustainable Products aims to make products sold in the EU more sustainable, by setting performance and information-related requirements on them. To set priorities in a transparent and inclusive way, the Commission intends to launch a public consultation on the categories of new products and measures on which priority action should be taken.

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Public consultation

ID: 13682

Lobbying Activity

99 responses

Consultation response

Climate Action Network Europe, 12 May 2023

CAN Europe submits its response to this public consultation, attaching a document with our responses to questions set earlier and supporting information on some intermediary products we consider priority.

Chemical industry urges focus on end-products not intermediates

European Chemical Industry Council, 12 May 2023

The organization requests that ESPR focus on sustainability of chemicals in end-products rather than regulating intermediate chemicals. They argue chemicals embedded in products like synthetic amorphous silica should be excluded since they're not released into the environment.
This would avoid duplicate regulation of their chemicals already covered under REACH.
Environmental groups lose additional oversight of chemicals used in manufacturing processes.

Consultation response

EuroCommerce, 12 May 2023

We welcome the opportunity to provide input to the survey and look forward to continuing the dialogue with EU policymakers. We welcome the proposal and ESPR and state this is the key framework regulation in enabling circularity. To meet Europe's climate ambitions, we will also need a strong Single…

Consultation response

The European Steel Association, 12 May 2023

The steel industry welcomes European Commissions this consultation under Ecodesign for Sustainable Products Regulation (ESPR) to prepare the ESPR working plan. Steel produced in the EU plays a crucial role in achieving the challenging goals of the EU Green Deal and transitioning to a circular…

Consultation response

SMEunited aisbl, 9 May 2023

The revised Ecodesign Regulation will have positive repercussions on the world of repairers, a sector mostly composed of SMEs. However, it will certainly have an impact on SMEs manufacturing these products but also supplying components to bigger manufacturers. Many SMEs manufacturing products or…

Consultation response

BASF SE, 12 May 2023

BASF supports the overall objectives of the European Commissions proposal on the Ecodesign for Sustainable Products Regulation (ESPR). We believe that the chemical industry is well positioned to contribute to the EU Green Deals circular economy objectives, including the Chemicals Strategy for…

Consultation response

Orgalim – Europe's Technology Industries, 12 May 2023

Orgalim represents Europes technology industries, providing innovative technology solutions which are underpinning the twin green and digital transitions and can unlock a greener, healthier and more prosperous future for the European Union and its citizens. To build on the success of the existing…

Consultation response

industriAll European Trade Union, 11 May 2023

On the Ecodesign For Sustainable Products Regulation, industriAll Europe is calling: - To include social aspects in the definition of sustainability, which in this proposal, only cover environmental requirements. A sustainable product should guarantee that it is a product made under good working…

Consultation response

Wirtschaftskammer Österreich, 11 May 2023

The WKÖ supports and is committed to the goal of climate neutrality by 2050. What is needed now is a concrete package of measures to support sustainable, ecological change in the EU in line with a new growth strategy. The WKÖ advocates legislation that meets the requirements of effective climate…

Consultation response

Neste Oyj, 5 May 2023

Attachment: 1. Life Cycle Assessment of renewable liquid hydrocarbons, propylene and polypropylene, derived from bio-waste and residues (Elsevier, 2022) Polymer and plastics as intermediates The Ecodesign for Sustainable Products Regulation (ESPR) is an opportunity to make a major leap towards more…

Consultation response

EUROMETAUX, 12 May 2023

The European non-ferrous metals industry, represented by Eurometaux, delivers primary and secondary raw materials for the green and digital transitions. Metals are present in various products, including those listed in the 2020 Circular Economy Action Plan (CEAP) as key value chains namely,…

Consultation response

UNIFE, 4 May 2023

UNIFE, the association of the European rail supply industry - welcomes the opportunity to provide feedback on the first working plan on the proposal for a regulation establishing a framework for setting eco-design requirements for sustainable products and repealing Directive 2009/125/EC. - Unleash…

Consultation response

European Aluminium AISBL, 11 May 2023

European Aluminium, the industry association of the full aluminium value chain in Europe, welcomes the ESPR as an opportunity to facilitate a smooth and expedited transition to a circular and resource-efficient economy. Ensuring the recovery of secondary raw materials and achieving high-quality…

Consultation response

International Federation of Organic Agriculture Movements EU Regional Group, 18 Apr 2023

IFOAM Organics Europe welcomes the Commissions product-by-product approach reflected in the new product priorities under the proposed Ecodesign for Sustainable Products Regulation (ESPR) and the consideration of textiles as a priority product, as laid out in the preliminary JRC study. The study…

Consultation response

CEMBUREAU - The European Cement Association, 12 May 2023

Please find attached CEMBUREAU - the European Cement Association's feedback to the call for evidence. Thanks.

Consultation response

The Danish Chamber of Commerce, 10 May 2023

Please see the attached file.

Consultation response

GSMA Europe, 12 May 2023

The GSMA which represent mobile telecommunication operators welcomed the EU Circular Economy Action Plan, which introduced a sustainable product policy framework in Europe and rightly identified electronics and ICT as a critical product value chain. While various initiatives have been taken in this…

Consultation response

APPLiA (Home Appliance Europe), 10 May 2023

To whom it may concern, Please find attached APPLiA's position paper on the Working Plan under the Ecodesign for Sustainable Products Regulation (ESPR). Below are also included APPLiA's two key messages on the drafting of the Working Plan: The success of the ecodesign is a product-by-product…

Consultation response

Verband der Chemischen Industrie e.V., 12 May 2023

VCI against eco-design requirements for Chemicals as Intermediates: In the current consultation on product group prioritization under the ESPR, chemicals as intermediates are foreseen as one possible product group to be covered under ESPR via delegated acts. With the purpose of providing answers in…

Consultation response

eBay EU liaison office, 12 May 2023

eBay welcomes the opportunity to provide feedback on the consultation to identify the New product priorities for Ecodesign for Sustainable Products. We appreciate the Commissions initiative to ensure a more environmentally virtuous Single Market for consumer goods and to promote the growth of the…

Consultation response

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 12 May 2023

Retailers are directly involved in the sale of products within the scope of the eco-design Regulation and are in close contact with consumers on the one hand and manufacturers on the other hand. We would like to encourage the Commission to be more ambitious regarding some aspects and would like to…

Consultation response

Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien, 12 May 2023

A.I.S.E., the International Association for Soaps, Detergents and Maintenance Products, welcomes the objectives of the European Commission proposal for a new Regulation on Ecodesign for Sustainable Products (ESPR), which will enable a comprehensive and harmonised set of requirements for the…

Consultation response

Teknikföretagen, 12 May 2023

Teknikföretagen (the Association of Swedish Engineering Industries) represents over 4 300 member companies that constitute one third of Swedens exports. Our member companies comprise both major, renowned, global corporations as well as a majority of micro, small and medium-sized enterprises. A…

Consultation response

RTE Réseau de transport d'électricité, 12 May 2023

The implementation of ESPR should take into consideration two approaches: one regarding industrial products and another for consumer products. We suggest implementing an industrial approach for intermediary products as Aluminum (Al) and its alloys; Non-ferrous metal products as Copper (Cu), Steel,…

Consultation response

European Insulation Manufacturers Association, 12 May 2023

Please find Eurima's position on new product priorities for Ecodesign for Sustainable Products attached.

Consultation response

Inter Ikea Systems BV, 11 May 2023

As a global home-furnishing brand, IKEA has a big responsibility and with it, big growth opportunities to make a large-scale, positive impact on climate and resource use by adopting a circular business model. One key piece of the puzzle is to adopt circular thinking during the product design…

Consultation response

Back Market, 11 May 2023

Back Market, a French Tech Next40 company with unicorn status, is the first marketplace that provides consumers with access to thousands of electrical and electronic products refurbished by professionals across 18 countries. Our work is driven by a purpose: to expand the lifespan of e-products by…

Consultation response

European Producers Union of Renewable Ethanol, 12 May 2023

ePURE feedback to the Commission consultation on Ecodesign for sustainable products About ePURE ePURE the European renewable ethanol association represents EU producers of sustainable ethanol from crops, waste, and residues. Our members operating in 50 plants across the EU and the UK account for…

Consultation response

Reuse and Recycling European Union Social Enterprises, 11 May 2023

RREUSE welcomes the possibility to give feedback on new product priorities under the upcoming Ecodesign for Sustainable Products Regulation. As an organisation that promotes the reuse and repair of products, we believe that mandatory eco-design requirements can play a key role in reducing waste and…

Consultation response

Jernkontoret, 12 May 2023

Jernkontoret welcomes the opportunity to give feedback on product priorities under the Ecodesign for Sustainable Products Regulation (ESPR). Steel produced in the EU plays a crucial role in achieving the challenging goals of the EU Green Deal and transitioning to a circular European economy.…

Consultation response

Japan Business Council in Europe, 12 May 2023

Being a cross-sector association with member companies operating in different industries and across various stages in the supply chain, JBCE welcomes the opportunity to contribute to the public consultation on the new product priorities under the Ecodesign for Sustainable Products Regulation…

Consultation response

Natural Mineral Waters Europe aisbl, 12 May 2023

Please find attached NMWE's contribution to the public consultation on new product priorities for Ecodesign for Sustainable Products. Best regards, the NMWE Secretariat.

Consultation response

EUMEPS, 11 May 2023

EUMEPS (European Manufacturers of Expanded Polystyrene) welcomes the proposal for a new Regulation establishing a framework for setting eco-design requirements for sustainable products, as it considers it essential to increase the circularity of goods placed on the European market and as well EU…

Consultation response

European Partnership for Energy and the Environment, 12 May 2023

EPEE, representing the Refrigeration, Air-Conditioning and Heat-Pump (RACHP) industry, welcomes the European Commissions technical report on new product priorities under the Ecodesign for Sustainable Products Regulation (ESPR) for non-Energy-related Products. The present position aims to highlight…

Consultation response

European Bioplastics, 12 May 2023

At European Bioplastics (EUBP), the association representing the interests of around 80 member companies from the entire bioplastics value chain, we believe that for sustainable products to become the norm across the EU, the potentials of biobased, biodegradable and compostable plastics need to be…

Consultation response

EDANA AISBL, 12 May 2023

Dear Commission, EDANA, the voice of the nonwovens and related industries, represents amongst others, the producers of baby diapers, menstrual products and incontinence care products, as well as technical nonwovens such as agrotextiles and construction product textiles. We would like to provide our…

Consultation response

CO2 Value Europe AISBL, 11 May 2023

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 85 members along the CCU value chain, from CO2 producers, converters and users of CCU products to researchers and project developers. CCU refers to established and innovative…

Consultation response

LANXESS AG, 11 May 2023

LANXESS AG, as a leading speciality chemicals company, welcomes the opportunity to contribute to the European Commission´s preparatory work in defining the order of priority in which intermediate and end-products should be tackled and whether horizontal measures identified as potential priorities…

Consultation response

Novamont SpA, 11 May 2023

For sustainable products to become the norm across the EU, the potentials of biobased, biodegradable and compostable plastics need to be considered. It is crucial that the ESPR sets concrete incentives to promote properties such as renewability, biodegradability and compostability, to deliver on…

Consultation response

European Ventilation Industry Association, 11 May 2023

The European Ventilation Industry Association (EVIA) welcomes the Commission proposal for an Ecodesign for Sustainable Products Regulation (ESPR) and appreciates the opportunity to provide feedback to the prioritisation of product groups. Energy-related Products (ErP) have been subject to ecodesign…

Consultation response

Logitech, 11 May 2023

Logitechs comments on the new product priorities for Ecodesign for Sustainable Products Logitech sees the Commissions proposal for Ecodesign for Sustainable Products Regulation (the Ecodesign Regulation) as an excellent starting point for creating a global sustainability standard, while giving…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 11 May 2023

FNADE, the French association for waste management and environmental services welcomes the initiative of the Commission to identify categories of new products and measures that need to be addressed as a priority in the revision of the Ecodesign for Sustainable Products Regulation. Indeed, in order…

Consultation response

Verband der deutschen Lack- und Druckfarbenindustrie e. V., 11 May 2023

Übereinstimmend mit der JRC sind wir der Auffassung, dass Farben und Lacke im ersten Arbeitsprogramm der Kommission nicht vorrangig behandelt werden sollten. Lacke und Farben sind bereits nachhaltige Produkte: Ihre wichtigste Aufgabe ist die Verlängerung der Lebensdauer von Bauwerken, Anlagen,…

Consultation response

Union of the European Lubricants Industry, 10 May 2023

The Union of the European Lubricants Industry (UEIL) represents the interests of the lubricants industry in Europe, with a special focus on SMEs and independent companies that produce lubricants and metal processing fluids essential for the automotive and industrial sectors. Through its 35 members,…

Consultation response

Downstream Users of Chemicals Co-ordination Group, 12 May 2023

DUCC represents 11 European associations, whose member companies use chemicals to formulate mixtures, ranging from cosmetics and detergents to aerosols, paints, inks, toners, pressroom chemicals, adhesives and sealants, construction chemicals, fragrances, lubricants, crop protection and chemical…

Consultation response

SOCIETE BIC, 12 May 2023

Our concern lies in the needed full clarity and enforceability of all requirements, so as to allow their effective enforcement, without which they would be only a useless burden on responsible European based manufacturers, counterproductive both for sustainability and for a level playing field.…

Consultation response

Association of Manufacturers and Formulators of Enzyme Products, 12 May 2023

AMFEP, the Association of Manufacturers and Formulators of Enzyme Products, welcomes the ‎European Commissions consultation on the new product priorities under the upcoming Ecodesign ‎for Sustainable Products Regulation (ESPR). AMFEP members represent 90% of the European ‎enzymes market, accounting…

Consultation response

Associação Técnica da Indústria de Cimento, 12 May 2023

Dear Sirs, Please find attached the Portuguese Cement Industry Technical Association (ATIC) position on new product priorities for Ecodesign for Sustainable Products. Yours Sincerely, Fátima Rato

Consultation response

Syctom Agence métropolitaine des déchets ménagers, 12 May 2023

Syctom is a French local public authority and a public service. It is the leading European public operator in municipal waste management. Syctom welcomes the Commission's consultation on New product priorities for Ecodesign for Sustainable Products (ESPR). From a municipal waste management…

Consultation response

European Precious Metals Federation, 12 May 2023

Please find the EPMF feedback in the document attached.

Consultation response

Groupe Avril, 2 May 2023

Veuillez trouver ci-joint la contribution écrite du Groupe Avril à l'appel à contributions en cours sur les 'Nouvelles priorités en matière décoconception pour des produits durables'.

Consultation response

Amis de la Terre France, 12 May 2023

See attached file

Consultation response

Offshore Wind Foundations Alliance, 12 May 2023

The Offshore Wind Foundations Alliance (OWFA) encourages the Commission to consider downstream products made from priority intermediate goods covered by the regulation. Following the JRCs preliminary study on new product priorities under the ESPR, steel was identified as a priority intermediate…

Consultation response

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 12 May 2023

Eurovent represents the European Industry of Indoor Climate (HVAC), Process Cooling, and Food Cold Chain Technologies. With this paper, Eurovent wishes to convey four main points to feed into the definition of priorities for the new Ecodesign for Sustainable Products Regulation: - The review of…

Consultation response

UNITI Bundesverband EnergieMittelstand e.V., 12 May 2023

UNITI ist der Bundesverband mittelständischer Mineralölunternehmen e. V. und repräsentiert rund 90 Prozent des organisierten Mineralölmittelstandes in Deutschland sowie die meisten unabhängigen mittelständischen Schmierstoffhersteller und Schmierstoffhändler in Deutschland. UNITI begrüßt die…

Consultation response

Beryllium Science & Technology Association, 11 May 2023

The Beryllium Science and Technology Association (BeST) represents the manufacturers, suppliers and users of beryllium metal, beryllium containing alloys and beryllium oxide ceramics in the EU market. BeST has the objective of promoting sound policies, regulations, science and actions related to…

Consultation response

European Advanced Carbon and Graphite Materials Association, 25 Apr 2023

The European Carbon and Graphite Association is pleased to submit its contribution to the consultation on product priorities under the new ESPR. Our full analysis can be found in the attached position paper.

Consultation response

European Remanufacturing Council, 12 May 2023

The European Remanufacturing Council represents companies that take-back used products for disassembly within an industrial process, replacing all worn and damaged parts before testing and returning the products to customers, as new, often with an equivalent guarantee. The sector has sales of…

Consultation response

The Bureau of European Design Associations, 16 Apr 2023

Dear European Commission, BEDA The Bureau of European Design Associations, together with the Verband Deutscher Industrie Designer e.V. (VDID) and the Deutscher Designtag e.V., is pleased to send you our contribution (file attached) about the Have Your Say: New product priorities for Ecodesign for…

Consultation response

European Safety Federation, 12 May 2023

see attached document

Consultation response

European Federation for Elevator Small and Medium-sized Entreprises aisbl, 12 May 2023

EFESME is the European Federation for Elevator Small and Medium-sized Enterprises, and it is active at European and international level to support lift SMEs in their daily work and activities. EFESME represents fifteen members in fourteen member states. Actively interested and involved at the…

Consultation response

European Refurbishment Association, 12 May 2023

EUREFAS - the European refurbishment association - welcomes the European Commissions work on building a strong Ecodesign for Sustainable Products framework to make products sold in the EU subject to performance and information-related requirements, and ensure greater sustainability. As product…

Consultation response

Confédération Européenne de l’Industrie de la Chaussure, 12 May 2023

The textiles ecosystem is one of the 14 priority industrial ecosystems launched on the New Industrial Strategy for Europe in March 2020 and aggregates the textile, clothing, leather and footwear sectors (TCLF). Against the opportunity to addressed certain common issues, the establishment of the…

Consultation response

K+S Aktiengesellschaft, 12 May 2023

The EU Commissions proposal for the Ecodesign for Sustainable Products Regulation (ESPR) will broaden the scope of current ecodesign legislation significantly to contribute to the goals of the Circular Economy Action Plan. In the current call for evidence, different products for end users,…

Consultation response

FREE ICT EUROPE FOUNDATION, 12 May 2023

Dear Commission, The Free ICT Europe Foundation welcomes to opportunity to share our views on priority ESPR products. Being an organisation that is representing the independent EU ICT Aftermarket, we are pleased to contribute. We strongly call for two ICT product groups to be selected as a…

Consultation response

Comité Européen des Fabricants d’Appareils de Chauffage et de Cuisine Domestiques, 11 May 2023

CEFACD is the European industry association representing manufacturers of local space heaters (LSH) and cooking appliances. We support the need to keep legislation up-to-date and in line with the latest technological developments. In that light, we welcome the Commissions efforts and proposal to…

Consultation response

Renewable Carbon Initiative, 10 May 2023

The Renewable Carbon Initiative and its members welcome the Commissions proposal on Ecodesign for Sustainable Products (ESPR) The proposal contains many issues that are in line with the RCIs objective to decrease the dependence on fossil carbon and speed up the transition to renewable carbon for…

Consultation response

UL GmbH, 9 May 2023

A global safety science leader, UL Solutions helps companies to demonstrate safety, enhance sustainability, strengthen security, deliver quality, manage risk and achieve regulatory compliance. UL Solutions welcomes the European Commissions intention to improve the EU products circularity, energy…

Consultation response

European PVC Window Profiles and related Building Products Association, 28 Apr 2023

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of 4 billion with profile systems and building…

Consultation response

European General Galvanizers Association, 12 May 2023

European General Galvanizers Association welcomes this opportunity to contribute to the development of the Ecodesign for Sustainable Products Regulation regarding both prioritisation of product groups and the application of horizontal criteria. The attached document provides details of EGGAs…

Consultation response

Fédération de la Haute Couture et de la Mode, 12 May 2023

Feedback attached

Consultation response

COSMED, 12 May 2023

COSMED confirms that Cosmetic SMEs remain engaged to achieve the objectives of the green deal and further improve the sustainability of cosmetic products. However, considering all ongoing initiatives we insist on the need to wait for the implementation of these other initiatives and for industry…

Consultation response

European Furniture Industries Confederation, 12 May 2023

EFIC, the European Furniture Industries Confederation, is pleased to contribute to this consultation on first priorities under the ESPR. EFIC represents over 70% of the total turnover of the European Furniture Industries, a sector employing 1 million people in about 120.000 enterprises across the…

Consultation response

The Restart Project, 11 May 2023

Feedback from Right to Repair Europe on the exclusion of electronic products from the list of priority products The Right to Repair Europe coalition represents over 100 organisations from 21 European countries. It represents environmental NGOs and repair actors such as community repair groups,…

Consultation response

European Steel Tube Association, 11 May 2023

European Steel Tubes Association (ESTA) members see with interest the Ecodesign for Sustainable Products Regulation (ESPR) initiative of the European Commission. The extension of the Ecodesign Directive 2009/125/EC to a new wider range of products will be a fundamental step to grant to the EU the…

Consultation response

RISE Research Institutes of Sweden AB, 11 May 2023

1. General comments regarding new product priorities for Ecodesign for Sustainable Products: RISE supports the proposal for a regulation on ecodesign for sustainable products and has, in addition to a continuous focus on the environmental sustainability of materials and products, for a number of…

Consultation response

EUnited European Engineering Industries Association, 2 May 2023

EUnited welcomes the proposal for a regulation establishing a framework for setting ecodesign requirements for sustainable products. Improving individual sustainability aspects of a product can have negative consequences on the sustainability of the product in other areas (potential examples can be…

Consultation response

Deutsche Feuerfest-Industrie e. V., 12 May 2023

Please find enclosed the feedback from the German refractories association (DFFI).

Consultation response

Fachverband der Stein- und keramischen Industrie, 12 May 2023

Please find our input attached.

Consultation response

European Infrared Heating Alliance, 12 May 2023

The European Infrared Heating Alliance (EIHA) supports the need to keep legislation up-to-date and in line with the latest technological developments. We believe that technological progress coupled with the current climate crisis necessitates measures that go beyond energy efficiency by including…

Consultation response

European Expanded Clay Association, 11 May 2023

Please find attached the European Expanded Clay Association (EXCA)'s feedback on the new product priorities for Eco-design for Sustainable Products

Consultation response

Electric Underfloor Heating Alliance, 11 May 2023

The Electric Underfloor Heating Alliance (EUHA) supports the need to keep legislation up-to-date and in line with the latest technological developments. We believe that technological progress coupled with the current climate crisis necessitates measures that go beyond energy efficiency by including…

Consultation response

FEBELCEM - The Belgian Cement Association, 11 May 2023

FEBELCEM, the Belgian Cement Association, is grateful for the opportunity to provide input to this consultation and supports the Commissions non-inclusion of cement in the new product priorities for Ecodesign for Sustainable Products and keeping it under the Construction Products Regulation (CPR).…

Consultation response

International Release Liner Association, 12 May 2023

The International Release Liner Association (IRLA) acknowledges and welcomes the proposed focus on Paper, Pulp Paper & Board as intermediate products under the ESPR and supports their prioritisation within the initial Work Plan bearing in mind their importance to the circular economy. However, when…

Consultation response

EUROMCONTACT, 12 May 2023

EuromContact, the European association of contact lens and lens care manufacturers, supports the general objective of the proposal for a new Ecodesign for Sustainable Products Regulation (ESPR) to improve circularity and other environmental sustainability aspects of products. The contact lens and…

Consultation response

Asociación de Empresas de Detergentes y de Productos de Limpieza, Mantenimiento y Afines, 12 May 2023

ADELMA supports A.I.S.E.`s considerations indicated in the attached document

Consultation response

EuroWindoor AISBL, 12 May 2023

EuroWindoor would like to underline the importance of having requirements on intermediary products such as aluminium, plastic, glass etc. to accelerate data availability throughout the value chains. Data availability and data quality is not sufficiently mature in many cases, why a push in this…

Consultation response

Clariter, 12 May 2023

This public consultation aims at identifying ESPRs priority product groups. Considering its volume of sales, and its impact on the environment, we believe that chemicals shall be part of the product groups regulated first. The chemical sector is the fourth largest industry in the European Union,…

Consultation response

European Bedding Industries Association, 11 May 2023

EBIA supports the objectives of ESPR and is actively developing a programme of work on ecodesign to take a leadership role on this subject. Although research on ecodesign has been initiated by the existing 3 EPR schemes, currently there is a level of mismatch in the approach and supporting data.…

Consultation response

European Federation for Construction Chemicals, 11 May 2023

We support the exclusion of construction products as end-use products under the ESPR as construction products are already covered under the Construction Products Regulation, CPR. We oppose the inclusion of (construction) chemicals under the ESPR, as (i) construction chemicals are well covered under…

Consultation response

GIDARA-Energy, 11 May 2023

Gidara Energy welcomes the opportunity to share its recommendations on the new product priorities for Ecodesign for Sustainable Products as regard to chemicals and plastics (as intermediate products) and to paints, and toys (as end-use products). - Gidara is of the view that methanol should be…

Consultation response

Puutuoteteollisuus ry, 11 May 2023

Inclusion of Furniture in the ESPR is welcome as it will create generic rules that harmonize the communication on the market and ensures the level playing field. However, the scope is extensive as furniture has numerous functions and raw materials, and the scale in manufacturing varies from private…

Consultation response

Association Technique de l'Industrie Européenne des Lubrifiants, 11 May 2023

ATIEL is the Technical Association of the European Lubricants Industry. ATIEL welcomes the opportunity to comment on the proposed EU Ecodesign for Sustainable Products Regulation (ESPR). We would like to take this opportunity to describe to the Commission the unique aspects of lubricants that need…

Consultation response

Bundesverband Holz und Kunststoff, 9 May 2023

Sustainable wood as an essential raw material for furniture can only be ensured by government regulators through the ETR, and not by manufacturers - especially SMEs. Requirements for recycling should be limited to non-renewable materials. Recycling of wood is limited due to risk of dangerous…

Consultation response

Instituto Tecnológico Metalmecánico, Mueble, Madera, Embalaje y Afines, 4 May 2023

AIDIMME supports the assessment done by JRC and thus the selection of furniture and mattresses to be eco-designed according to the proposed regulation since they offer a huge potential to apply most of the ecodesign strategies. There are legislations aligned with the proposed ESPR regulation.…

Consultation response

Global Standard gGmbH, 3 May 2023

The JRC preliminary study on new product priorities provides a comprehensive overview of the product priorities for the Ecodesign for Sustainable Products Regulation (ESPR). It provides relevant detail on the textile sector. Global Organic Textile Standard (GOTS) acknowledge that textiles represent…

Consultation response

European Electronics Recyclers Association, 10 Feb 2023

EERA welcomes the overall objectives and aspirations of the proposed Regulation on Ecodesign for Sustainable Products (ESPR), as it has long been our viewpoint that the key to good recycling opportunities to recover secondary materials must begin at the design stage. This is so there is prior…

Consultation response

Instituto Español del Cemento y sus Aplicaciones, 9 Feb 2023

La propuesta de Reglamento de Productos de Construcción, RPC, establece en su considerando 28 que: in particular, in the case of energy-related products included in ecodesign working plans which are also construction products and for intermediary products, with the exception of cement, priority for…

Consultation response

Free Pack Net Holding, 2 Feb 2023

Ecodesign for Sustainable Products ANALYZED SECTOR: LARGE HOUSEHOLD APPLIANCES (LHA) The Packaging problem. 1. Disposable packaging or better Problematic Packaging (Expanded Polystyrene and cardboard) in the LHA sector, are not able to protect adequately appliances during warehousing, transports…