Lobbying on Sustainable Products Initiative

Sustainable Products Initiative

Environment

This initiative aims to make the products placed on the EU market more sustainable. Citizens will benefit from products that are more durable, reusable, reparable, recyclable and consume less energy. The presence of hazardous chemicals in products will be addressed, to protect human health and the environment. Increased resource efficiency will help reduce the carbon and environmental footprint, contributing to address climate and sustainability challenges.

Links

Public consultation

ID: 12567

Lobbying Activity

241 responses

BUSINESSEUROPE urges sector-specific approach to circular product rules

BUSINESSEUROPE, 13 Nov 2020

The organization requests that circularity criteria be defined with business input and tailored to each sector. They argue mandatory recycled content should only apply where high-quality materials exist, and advocate for voluntary data sharing with IP protections. They want functional criteria in public procurement rather than prescriptive requirements.

This would protect existing high-recycling sectors and safeguard their intellectual property rights.

Environmental advocates lose stronger mandatory requirements that could accelerate circular economy adoption.

Consultation response

European Environmental Bureau, 17 Jun 2022

For full details, see our attached paper The EEB welcomes the transformation of the current Ecodesign Framework Directive into a new Ecodesign for Sustainable Products Regulation. We think it clearly reflects the ambition of the EU to make sustainable products the norm (we think this should be…

Environmental NGOs Push for Mandatory Sustainability Standards Across All EU Products

European Environmental Bureau, 16 Nov 2020

The organization wants ecodesign extended beyond energy products with mandatory horizontal requirements for all products, including information transparency, hazardous substance restrictions, bans on planned obsolescence and destruction of unsold goods, and mandatory extended producer responsibility. They advocate for vertical requirements on priority sectors like electronics, textiles, and furniture, with performance thresholds becoming legally binding rather than voluntary.

This would advance their mission to protect the environment by establishing binding sustainability requirements.

Manufacturers face higher compliance costs and restrictions on current production practices and business models.

Consultation response

American Chamber of Commerce to the European Union, 22 Jun 2022

The proposal for a new Ecodesign for Sustainable Products Regulation (ESPR) seeks to create a Single Market for sustainable products and improve access to sustainability information through the Digital Product Passport (DPP). The Regulation will only be successful if it ensures full harmonisation…

Consultation response

American Chamber of Commerce to the European Union, 3 Nov 2020

We understand that at the heart of the Circular Economy Action Plan, the European Commission aims to develop a product policy framework based on sustainability. While AmCham members fully support and embrace the circular economy transition and are actively committed in closing the carbon loop, we…

Consultation response

Climate Action Network Europe, 22 Jun 2022

Climate Action Network (CAN) Europe is Europe's leading NGO coalition fighting dangerous climate change. With over 185 member organisations from 38 European countries, representing over 1.700 NGOs and more than 47 million citizens, CAN Europe promotes sustainable climate, energy and development…

Consultation response

Climate Action Network Europe, 27 Oct 2020

CAN Europe welcomes the Sustainable Products initiative, and considers it a further step towards filling a considerable and important gap in the EU policy framework addressing various aspects of environmental and social challenges – from the climate and biodiversity emergencies, to resource…

Consultation response

Bundesverband der Deutschen Industrie e.V., 21 Oct 2020

The announced “sustainable product policy legislative initiative” should be used to enable the European Union's environmental product policy to be a unified whole, i.e. without the coexistence of duplicate and contradictory sets of rules for the same products. The envisaged fundamental…

Chemical Industry Seeks Clarification on Ecodesign Regulation Implementation

European Chemical Industry Council, 22 Jun 2022

Cefic requests clear interfaces between ESPR and existing chemical legislation to avoid duplication, feasible information requirements for the Digital Product Passport, amendments to environmental assessment methods, strong market incentives, full EU-wide harmonization, and transparent implementation timelines. They emphasize that restrictions should only apply to substances remaining in end products and that recyclability should be evaluated against state-of-the-art technologies.

This would reduce compliance costs and avoid competitive disadvantage versus non-EU producers.

Consumer and environmental groups lose if weaker recyclability standards allow harmful substances to persist.

Consultation response

European Chemical Industry Council, 16 Nov 2020

The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association, pinfa, www.pinfa.eu supports the objective of the Sustainable Products Initiative (SPI) to move forward product sustainability, circularity and energy and materials efficiency, including addressing chemicals. This…

Consultation response

EuroCommerce, 16 Nov 2020

Please find EuroCommerce feedback attached. We look forward to a continuous discussion. Thank you.

Consultation response

DIGITALEUROPE, 22 Jun 2022

As an organisation representing over 35,000 businesses in the digital sector, DIGITALEUROPE and its members have been at the forefront of the transition of the digital industry towards more responsible and sustainable models for some years now. We have collectively been involved in the making of…

Consultation response

DIGITALEUROPE, 16 Nov 2020

The European Green Deal and the New Circular Economy Action Plan have set out a historically ambitious agenda for environmental policy. DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver…

Consultation response

Amazon Europe Core SARL, 21 Jun 2022

In light of Amazon’s strong commitment to our customers and sustainability practices, we welcome efforts to make products increasingly recyclable, restrict single-use, and counter premature obsolescence. Setting up a framework for ecodesign requirements, an EU Digital Product Passport, and…

Amazon urges industry-led standards over mandatory product sustainability rules

Amazon Europe Core SARL, 3 Nov 2020

Amazon requests that sustainability standards remain voluntary and industry-led rather than legally mandated. They want any new requirements developed within the existing Ecodesign framework, and propose digital product information tools to reduce administrative burdens. They also seek VAT relief for donations of unsold goods.

This would avoid mandatory compliance costs and allow flexible, voluntary adoption of standards.

Environmental groups lose stronger mandatory requirements that would force faster product sustainability improvements.

Consultation response

The European Steel Association, 4 Nov 2020

European Steel Association, EUROFER, welcomes the initiative on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, once the three pillars of the sustainability are taken equally into account for controlling and removing, to the extent…

Consultation response

European Federation of Pharmaceutical Industries and Associations, 14 Nov 2020

EFPIA, the research-based pharmaceutical industry is supportive of the European Commission initiative to increase product sustainability as indicated in the roadmap for the Sustainable Products Initiative. We would like to contribute to the policy debate with recommendations that aim at…

Consultation response

EPIA SolarPower Europe, 22 Jun 2022

SolarPower Europe supports the regulatory proposal’s objective to extend the scope of Ecodesign beyond energy-related projects. As already pointed out in our feedback during the previous phases of this legislative initiative, we believe that broadening the scope of sustainability policies to…

Consultation response

EPIA SolarPower Europe, 16 Nov 2020

Feedback to the consultation is in the file attached.

Consultation response

Finnish Forest Industries Federation (Metsäteollisuus ry), 22 Jun 2022

In principle, the Finnish forest industry supports the initiative's good goal of sustainable products. An effective transition to a bio-based circular economy requires sustainable products to become the norm. The ESPR is a broad and ambitious framework law that covers all products produced by the…

Consultation response

BASF SE, 20 Jun 2022

Response to the Public Consultation of the Ecodesign for Sustainable Products Regulation BASF supports the overall objectives of the European Commission’s proposal on the Ecodesign for Sustainable Products Regulation (ESPR). We believe that the chemical industry is well positioned to contribute…

Consultation response

Confederation of Swedish Enterprise, 22 Jun 2022

This document contains Swedish Enterprise’s initial comments on the Sustainable Product Initiative and the Ecodesign requirements for sustainable products regulation (ESPR) presented on March 30 by the European Commission. Confederation of Swedish Enterprise is Sweden’s largest business federation,…

Consultation response

Confederation of Swedish Enterprise, 16 Nov 2020

Se attached file

Consultation response

Bayerische Motoren Werke Aktiengesellschaft, 22 Jun 2022

Die BMW Group hat bereits als erster deutscher Automobilhersteller den 1,5° Grad Pfad des Pariser Klimaabkommens in seiner Unternehmensstrategie fest verankert und sich zur Klimaneutralität bis 2050 bekannt. Im Rahmen ihrer ganzheitlichen Nachhaltigkeitsstrategie beabsichtigt die BMW Group…

Consultation response

Confederation of Danish Industry, 22 Jun 2022

Confederation of Danish Industry supports the proposed Ecodesign for Sustainable Products Regulation (ESPR). Overall, we find that the proposal if implemented according to the good intentions will strengthen the Single Market, push for more circular products in the EU and create more transparency…

Consultation response

Orgalim – Europe's Technology Industries, 13 Jun 2022

Orgalim represents Europe’s 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. Our industries welcome the Ecodesign for…

Consultation response

Orgalim – Europe's Technology Industries, 16 Nov 2020

Orgalim, representing Europe's Technology Industries, welcomes the Commission’s sustainable product policy legislative initiative as a key measure to further optimise the way resources are used throughout the economy and society. Please find attached Orgalim views and recommendations on the…

Consultation response

industriAll European Trade Union, 18 Jun 2022

[See industriAll Europe's complete feedback in attachment] Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europe’s industrial workforce at European Level. IndustriAll Europe is an organisation of independent…

Consultation response

Deutsche Industrie- und Handelskammer, 21 Jun 2022

Wir bedanken uns für die Gelegenheit zur Stellungnahme zum Verordnungsentwurf. Die Stellungnahme des DIHK finden Sie anbei.

Consultation response

Hydrogen Europe, 22 Jun 2022

Hydrogen Europe welcomed the high ambition of the Commission’s Fit for 55 package, and calls on the European Parliament and the Council to keep those objectives. In order to achieve those overarching goals however, we need to push for a regulatory framework that incentivises the shift towards more…

Consultation response

Wirtschaftskammer Österreich, 22 Jun 2022

Die WKÖ unterstützt und bekennt sich zum Ziel der Klimaneutralität bis 2050. Jetzt ist ein konkretes Maßnahmenbündel zur Unterstützung eines nachhaltigen, ökologischen Wandels in der EU im Einklang mit einer neuen Wachstumsstrategie notwendig. Die WKÖ setzt sich für eine Gesetzgebung ein, die den…

Consultation response

Wirtschaftskammer Österreich, 2 Nov 2020

Please find attached the feedback of the Austrian Federal Economic Chamber (WKÖ) on the Sustainable products initiative.

Consultation response

EUROMETAUX, 16 Nov 2020

Eurometaux, representing the European non-ferrous metals industry fully supports the transition to a true Circular Economy. Metals are present in various products, including those listed in the Action Plan as key value chains namely, electronics and ICT, batteries and vehicles, packaging, textiles,…

Consultation response

MedTech Europe, 21 Jun 2022

MedTech Europe is the European trade association for the medical technology industry, including diagnostics, medical devices, and digital health. MedTech Europe supports the ambition towards more sustainable products in the European Union and circular business models. This is not an easy task, as…

Consultation response

UNIFE, 21 Jun 2022

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

Consultation response

IBERDROLA, 22 Jun 2022

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.…

Consultation response

Technology Industries of Finland (Teknologiateollisuus ry), 20 Jun 2022

TIF supports the Commission’s aim to modernise regulation of ecodesign requirements of products and set a legal framework for digital product passports, facilitating the combination of data with material flows. Our key messages are: The EU should be the global leader in setting standards…

Consultation response

Technology Industries of Finland (Teknologiateollisuus ry), 10 Nov 2020

Sustainable Product Policy – a necessity to fulfil Circular Economy Technology Industries of Finland welcomes the commissions initiative on Sustainable Product Policy. It is crucial for our industries that the sustainable product policy legislative initiative will provide a stable framework,…

Consultation response

European Aluminium AISBL, 21 Jun 2022

The European aluminium industry welcomes the Commission’s proposal for the ESPR and considers it as an important foundational framework which can ensure coherency and complementarity with all relevant policy areas. Such an approach would allow for a smooth and accelerated transition to a…

Consultation response

European Aluminium AISBL, 16 Nov 2020

European Aluminium represents the entire value chain of the aluminium industry in Europe. The European aluminium industry strongly supports initiatives aiming at developing more sustainable products. To do this in the most effective way and in line with better regulation principles, European…

Consultation response

Confederation of European Paper Industries, 2 Nov 2020

The Confederation of the European Paper Industry (Cepi) welcome the opportunity to comment on the EU Commission’s Sustainable Products initiative, acknowledging the importance of ensuring the placement of more sustainable products on the internal market to support Europe’s transition towards a more…

Consultation response

International Federation of Organic Agriculture Movements EU Regional Group, 22 Jun 2022

IFOAM Organics Europe welcomes the opportunity to provide feedback on the proposal for a regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC, as part of the Sustainable products initiative. Please find in the attached…

Consultation response

Bitkom e.V., 22 Jun 2022

Bitkom welcomes the European Commission's intention to work towards products that are as sustainable, environmentally conscious and circular as possible. With the revision of the existing ecodesign directive, the European Commission is taking an important step towards a sustainable and…

Consultation response

ITI - The Information Technology Industry Council, 22 Jun 2022

ITI - the Information Technology Industry Council is the premier global advocate for technology, representing the world’s most innovative companies from technology, hardware, software, services, and related industries. We appreciate the opportunity to provide comments to the Proposal for a…

Consultation response

CEMBUREAU - The European Cement Association, 16 Nov 2020

CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment (IIA) on the Sustainable Products Initiative. The European Green Deal explicitly recognises the cement industry as essential to the EU economy as it supplies…

Consultation response

Swedish Forest Industries Federation, 2 Jun 2022

Swedish Forest Industries Federation (SFIF) welcomes the European Commission’s ecodesign requirements for sustainable products as well as the establishment of overarching sustainability requirements. In the framework of the European Green Deal and the Circular Economy Action Plan, it is crucial to…

Consultation response

Swedish Forest Industries Federation, 12 Nov 2020

Swedish Forest Industries Federation (SFIF) welcomes the Commission’s action plan on circular economy and the Sustainable Product Initiative acknowledging the importance of ensuring the placement of more sustainable products on the Internal market to support Europe’s transition towards a more…

Consultation response

European Ceramic Industry Association, 21 Jun 2022

Cerame-Unie, the European Ceramic Industry Association, welcomes the objectives of the European Commission for a climate neutral, resource efficient and circular economy. Cerame-Unie thanks the European Commission for the opportunity to partake in the public consultation and set out the industry’s…

Consultation response

SUEZ Group, 2 Nov 2020

SUEZ welcomes the Impact Inception Assessment on the Sustainable Products initiative and considers it is necessary to reduce carbon emissions through circular designed products. The promotion of reuse and recycling and incorporation of recycled products is key to the transition to a low carbon and…

Consultation response

APPLiA (Home Appliance Europe), 15 Jun 2022

APPLiA is a Brussels-based trade association representing home appliance manufacturers in Europe. Our membership includes 24 Direct Members who are leading global companies in the sector, and 26 National Associations across Europe. The sector is an economic powerhouse, with an annual turnover of…

Consultation response

Verband der Chemischen Industrie e.V., 22 Jun 2022

The chemical industry contributes to the sustainability and climate goals of the EU with innovative products and processes and has been working successfully for years to avoid possible impacts on the environment and health. We therefore welcome the extension of the ecodesign criteria to include all…

Consultation response

Verband der Chemischen Industrie e.V., 16 Nov 2020

The VCI represents the politico-economic interests of around 1,700 German chemical companies and German subsidiaries of foreign businesses. In 2019 the German chemical industry realised sales of over 198 billion euros (equal to 1/3 of the European chemical industry) and employed around 464,000…

Consultation response

eBay EU liaison office, 16 Nov 2020

For 25 years, eBay has enabled millions of consumers and businesses to give a second life to goods. Whether through individuals selling items online that they no longer need, or by facilitating online access to spare parts for repair, eBay can be considered a key player in the circular economy.…

Consultation response

Plastics Europe, 30 Oct 2020

PlasticsEurope is a leading European trade association, with centres in Brussels, Frankfurt, London, Madrid, Milan and Paris. We network with European and national plastics associations and have more than 100 member companies, who are responsible for producing more than 90% of all polymers across…

Consultation response

Wirtschaftsvereinigung Stahl, 22 Jun 2022

Die Stahlindustrie begrüßt den Verordnungsentwurf zur Schaffung eines Rahmens für die Festlegung von Ökodesign-Anforderungen für nachhaltige Produkte und zur Aufhebung der Richtlinie 2009/125/EG. Das ehrgeizige Gesetzespaket hat das Potenzial, die Nachhaltigkeit von Produkten insgesamt zu…

Consultation response

Zero Waste Europe, 16 Nov 2020

The Rethink Plastic alliance welcomes the launch of the Sustainable Products Initiative (SPI) and its overarching objective to make sustainable products and services the norm. In order to achieve its overarching objective and meet the seriousness of current environmental challenges, the proposed…

Consultation response

European Association of Mining Industries, Metal Ores & Industrial Minerals, 15 Nov 2020

Euromines members are committed to facilitating and encouraging the promotion of safe use, recycling and disposal of products through an understanding of their life cycles. Primary production of metals and minerals, which remain abundant, will play an important role in delivering the European Green…

Consultation response

Wirtschaftsvereinigung Stahl, 2 Nov 2020

The German Steel Federation (WV Stahl) welcomes in principle the European Commission's proposal for a sustainable product policy. A product policy based on the three pillars of sustainability can make a significant contribution to achieving the EU's targets in terms of, for example, climate…

Consultation response

Cosmetics Europe, 16 Nov 2020

Cosmetics Europe welcomes the opportunity to engage with the European Commission. We consider the following aspects are critical elements for the upcoming European Commission policy discussion on the Sustainable Products Policy Framework: • Overarching product sustainability principles should be…

Consultation response

Environmental Coalition on Standards, 16 Nov 2020

ECOS welcomes the Commission’s intention to make sustainable products and circular business models the norm by transferring the principles of ecodesign to all products on the EU market. For sustainable products to become the norm in the EU, the primary focus of the regulator must be on removing…

Consultation response

Verband Kommunaler Unternehmen e.V., 2 Nov 2020

Die EU-Kommission hat mit dem Green Deal erstmals einen ganzheitlichen Ansatz für die Bewältigung klima- und umweltbedingter Herausforderungen in Europa gewählt. Der VKU begrüßt ausdrücklich, dass die Kommission die Kreislaufwirtschaft und die damit verknüpfte Initiative für eine nachhaltige…

Consultation response

The European Organisation for Packaging and the Environment, 22 Jun 2022

EUROPEN, the European Organization for Packaging and the Environment, supports the overall objectives of the European Commission’s Ecodesign for Sustainable Products Regulation (ESPR) proposal to reduce the negative life cycle environmental impacts of products and improve the functioning of the…

Consultation response

ASD-Eurospace, 20 Jun 2022

We welcome and support the overall objectives and product-specific framework approach of the ESPR Proposal, as well as the explicit acknowledgment in recital (16) of the ESPR Proposal of key specificities of space products with regard to any ecodesign requirements. The European Space Sector…

Consultation response

SSAB AB, 22 Jun 2022

SSAB COMMENTS ON THE ECODESIGN REQUIREMENTS FOR SUSTAINABLE PRODUCTS SSAB welcomes the European Commission’s work on the proposal to set Ecodesign requirements for sustainable products (ERSP) and that steel products might be among the first group of products to be regulated. This will promote…

Consultation response

SSAB AB, 16 Nov 2020

SSAB supports the objectives set out in the EU Green Deal. SSAB's plan is to convert to a fossil-free steelmaking process based on the hydrogen-based HYBRIT technology, developed by SSAB together with our partners (LKAB and Vattenfall) within the framework of the HYBRIT initiative. SSAB's ambition…

Consultation response

European Tyre & Rubber Manufacturers' Association, 10 Nov 2020

The European Tyre & Rubber Manufacturers’ Association (ETRMA) and its members count around 4.300 companies in the EU, employing directly 360.000 people. ETRMA tyre company members represent 59% of the global tyre sales. We have strong presence in the EU and candidate countries with 93…

Consultation response

Bund für Umwelt und Naturschutz Deutschland e. V., 22 Jun 2022

Please see attached/ Bitte Anhang beachten

Consultation response

Video Games Europe, 16 Nov 2020

The video games sector shares the European Commission’s conviction that addressing climate change is one of the most critical challenges of the 21st century and welcomes the opportunity to contribute to the roadmap consultation on the sustainable products initiative. The sector has taken numerous…

Consultation response

European Heat Pump Association, 22 Jun 2022

EHPA would like to thank the European Commission for the opportunity given to send feedback on the Commission proposal. General remarks Overall, when discussing about the Ecodesign for Sustainable Products Regulation and its requirements, it is important to keep in mind the following: - EHPA…

Consultation response

International Copper Association Europe, 22 Jun 2022

ECI welcomes the European Commission’s ambition for a sustainable product policy framework. The EC proposal on Eco-design for Sustainable Products Regulation (ESPR) has great potential in driving product design towards more sustainability. However, to deliver on the ambition of reducing the…

Consultation response

International Copper Association Europe, 13 Nov 2020

The European Copper Institute (ECI) welcomes the EC's ambition for a sustainable product policy framework, to decouple economic growth from environmental & climate impacts. We believe a holistic, life-cycle management approach, from product design to efficient recycling, with reliable, relevant…

Consultation response

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 22 Jun 2022

Independent Retail Europe members believe that the new process to determine ecodesign requirements truly has the potential to change the way products will be consumed in future and that retail will play a pivotal role in this transition to greener products. Retailers’ in-store advisors and experts…

Consultation response

Clean Clothes Campaign / Stichting Schone Kleren Kampagne, 22 Jun 2022

At Clean Clothes Campaign – an international network of over 230 NGOs and trade unions focused on workers’ rights in the garment industry – we strongly believe that traceability and transparency are indispensable tools to ensure that products produced worldwide and consumed on the EU market are…

Consultation response

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 7 Oct 2020

We welcome the Commission’s efforts to create incentives for more a sustainable Single Market. We are confident that a solution can be found that achieves greater sustainability without damaging the interests of consumers or businesses. In this context, we appreciate in particular the attention…

Consultation response

European Recycling Industries' Confederation, 22 Jun 2022

EuRIC strongly welcomes the publication of the proposal for a Regulation on Ecodesign for Sustainable products (2022/0095 (COD)) accompanied by the Communication on making sustainable products the norm (COM (2022) 140 final). Eco-design for recycling is a pre-condition to move towards a more…

Consultation response

Plastics Recyclers Europe, 12 Nov 2020

Please see enclosed file.

Consultation response

Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien, 3 Nov 2020

A.I.S.E. welcomes the objectives of the ‘Sustainable Products Initiative’. A holistic approach towards sustainability, incl. social, environmental and economic aspects should be taken, also using the potential of digitalisation. A.I.S.E. calls for measures that: • are based on sound science and in…

Consultation response

Stichting Fair Trade Advocacy Office, 15 Nov 2020

The Fair Trade Advocacy Office (FTAO) welcomes the opportunity to participate in this public consultation. The FTAO speaks out on behalf of the Fair Trade Movement for Fair Trade and Trade Justice with the aim to improve the livelihoods of marginalised producers and workers in the South. The FTAO…

Consultation response

CONFCOMMERCIO - IMPRESE PER L'ITALIA, 4 Nov 2020

Attached you can find Confcommercio - Imprese per l'Italia's comment to the Commission's Sustainable products initiative - Inception impact assessment - Ares(2020)4754440.

Consultation response

Norsk Hydro, 16 Nov 2020

Hydro is an aluminium producer, with activities in the entire value chain. We welcome the Sustainable Product Policy Initiative (SPPI) and strongly supports initiatives aiming at driving demand towards low-carbon and circular products. We support establishing sustainability principles and common…

Consultation response

Climate Strategy, 20 Jun 2022

We believe that these are key considerations for all "intermediate products" (eg. cement & steel): 1) Introduce mandatory Ecodesign Requirements on information and performance for all relevant performance and lifecycle parameters, communicated via a robust, accessible, and harmonised B2B Digital…

Consultation response

Toy Industries of Europe, 16 Nov 2020

TIE, Toy Industries of Europe, welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment for the Sustainable Products Initiative. TIE’s members are reputable toy manufacturers who prioritise toy safety. The toy sector is one of the most diverse European sectors…

Consultation response

Confédération des Petites et Moyennes Entreprises, 22 Jun 2022

La prise en compte croissante des critères environnementaux dans l’activité des entreprises fait apparaître l'éco-conception comme l'une des clés pour parvenir à des modèles économiques plus durables. En se dotant de la loi " AGEC " (Anti-gaspillage et pour une économie circulaire) de février 2020…

Consultation response

EUROPEAN APPAREL AND TEXTILE CONFEDERATION, 22 Jun 2022

EURATEX supports the efforts of the European Commission to improve the sustainability of products that circulate in the European internal market through the Ecodesign Requirements for Sustainable Products Regulation proposal. However, there are critical points that require attention and revision…

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 22 Jun 2022

With the attached paper we take the opportunity to comment on the draft Ecodesign Regulation (COM(2022) 142 final) published by the European Commission on 30 March 2022 as part of its Sustainable Product Initiative (SPI). We welcome that the EU Commission continues to pursue the ecodesign approach.…

Consultation response

Compagnie de SAINT-GOBAIN, 16 Nov 2020

Saint-Gobain welcomes the European Commission’s Sustainable Product Policy Initiative: sustainable products are at the heart of Saint-Gobain, a multinational company that designs, manufactures and distributes construction products and services to improve our habitat and achieve sustainable…

Consultation response

Bellona Europa, 16 Nov 2020

We welcome the Sustainable Product Policy Initiative’s intention to assess the true environmental impact of products and correct existing market failures which do not take into account their externalities. The current EU policy framework needs to be amended to reflect the true cost of all products.…

Consultation response

European Construction Industry Federation, 29 Oct 2020

These are the comments from FIEC, European Construction Industry Federation, on the Road Map on the Sustainable Products Policy Legislative Initiative. First and foremost, this initiative must not duplicate or be incompatible with the Construction Products Regulation in particular, but also with…

Consultation response

FIGIEFA - Fédération Internationale des Grossistes, Importateurs & Exportateurs en Fournitures Automobiles / International Federation of Automotive Distributors, 22 Jun 2022

FIGIEFA (the European federation and political representative in Brussels of the independent wholesalers and retailers of automotive replacement parts and their associated repair chains) welcomes the objectives of the new EU Commission proposal for a Regulation setting ecodesign requirements for…

Consultation response

H M Hennes Mauritz AB, 22 Jun 2022

H&M Group welcomes the European Commission’s proposal for a Regulation on Ecodesign for Sustainable Products and the development of product specific requirements. In our view, this will provide the needed granularity to drive change towards more circular, durable, and recyclable products and as…

Consultation response

European Insulation Manufacturers Association, 16 Nov 2020

Eurima welcomes the Commission’s intention to harmonize and set a baseline of principles for a market of sustainable products in Europe. We support the objectives of the Circular Economy Action Plan in this regard as it will contribute to a fairer market and allow for a better valorisation of the…

Consultation response

Teknikföretagen, 16 Nov 2020

We thank the European Commission for the opportunity to provide comments to the inception Impact Assessment for the Sustainable Product Initiative. Teknikföretagen welcomes the EU Commission's action plan on circular economy and the initiative on Sustainable Product Initiative as it has the…

Consultation response

ABB Ltd, 22 Jun 2022

ABB welcomes the European Commission’s proposal for the draft Ecodesign for Sustainable Products Regulation (ESPR) launched as part of the broader Sustainable Product Initiative on 30 March 2022. Building on the success of the existing EU Ecodesign framework, the proposal has the potential to…

Consultation response

FEAD, 22 Jun 2022

FEAD fully supports the Commission’s Sustainable Products Initiative and its main objectives of reducing the negative life cycle environmental impacts of products, and the improvement of the internal market through a harmonised ecodesign approach. A holistic approach to sustainability through…

Consultation response

FEAD, 30 Oct 2020

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative on sustainable products under the European Green Deal and the new Circular Economy Action Plan (CEAP). Private waste…

Consultation response

TUSIAD-Turkish Industry&Business Association, 22 Jun 2022

TUSIAD - Turkish Industry & Business Association perceives Green Deal as a model of economic growth focusing on fair and inclusive development for all. In this respect, Paris Agreement and European Green Deal are among our strategic priorities. Since its inception in 1995, EU – Türkiye Customs…

Consultation response

VELUX A/S (VELUX Group), 22 Jun 2022

The VELUX Group welcomes the EU Commission's proposal on Ecodesign for Sustainable Products Regulation (ESPR) and supports the broader scope, moving away from a one-sided focus on energy efficiency to also factor in resource efficiency in a life cycle perspective. Making sustainable products the…

Consultation response

Inter Ikea Systems BV, 28 Oct 2020

As a global home-furnishing brand, IKEA has a big responsibility – and a big growth opportunity – to make a large-scale, positive impact on climate and resource use by adopting a circular business model. IKEA is committed to become a circular and climate positive business by 2030. We are taking a…

Consultation response

Luossavaara Kiirunavaara Aktiebolag, 22 Jun 2022

LKAB initial comments on the Ecodesign Requirements for Sustainable Products LKAB is a sustainable frontrunner in Europe’s iron and steel value chain Luossavaara-Kiirunavaara AB (LKAB) is an international high-tech mining and mineral group of iron ore in Sweden for the global steel market. More…

Consultation response

Luossavaara Kiirunavaara Aktiebolag, 16 Nov 2020

The international high-tech mining and minerals group LKAB has the ambition to be one of the industry’s most innovative, resource-efficient and responsible companies and hopes that the SPI can help to make the performance of frontrunners in sustainability, progressively the norm – as the Circular…

Consultation response

VIER PFOTEN International, 16 Nov 2020

FOUR PAWS / VIER PFOTEN welcomes the Commission’s intention to further develop the sustainable products policy and the opportunity to provide feedback to the Inception Impact Assessment. Please find FOUR PAWS feedback in the attachment.

Consultation response

Back Market, 17 Jun 2022

Back Market welcomes the European Commission's proposal on ESPR. However, we fear some of its provisions may threaten the viability of the second-hand market, and that of refurbishment in particular. Indeed, the current definition of refurbishment proposed by ESPR does not matches the…

Consultation response

International Chemical Secretariat, 2 Nov 2020

ChemSec supports the Commissions ambition to address the prerequisites of producing sustainable products, in line with the Green Deal, the Circular Economy Action Plan and the Chemical Strategy. ChemSec is positive towards widening of the ecodesign directive beyond energy related products and the…

Consultation response

Covestro AG, 30 Oct 2020

Feedback to the Commission’s Inception Impact Assessment on the Sustainable Products Initiative Summary Covestro welcomes the Commission’s Sustainable Products Initiative and its ambitious aim to make products placed on the EU market more sustainable, reducing their environmental footprint over…

Consultation response

Association of European Automotive and Industrial Battery Manufacturers, 21 Jun 2022

EUROBAT welcomes the already-tabled Ecodesign for Sustainable Products Regulation and re-‎confirms its full support for the creation of a fully-decarbonised economy by 2050. It is important ‎to further optimise products and create a circular economy ecosystem through more efficient ‎common…

Consultation response

DSM-Firmenich, 16 Nov 2020

We at DSM thank the European Commission for the chance to comment on the inception impact assessment of the Sustainable Products Initiative (SPI), which is an important next step to enhance Europe’s market for high-quality secondary raw materials and circular products. As the new Circular Economy…

Consultation response

CIP - Confederação Empresarial de Portugal, 16 Nov 2020

Enviamos em anexo os nossos comentários. Obrigada CIP

Consultation response

Reuse and Recycling European Union Social Enterprises, 17 Jun 2022

RREUSE welcomes the revision of the Ecodesign Directive through the Sustainable Products Initiative (SPI) as a major opportunity to enhance product sustainability and to pave the way for a transition towards sustainability within European markets. We strongly defend the need to take eco-design…

Consultation response

Reuse and Recycling European Union Social Enterprises, 16 Nov 2020

RREUSE welcomes the release of the “Sustainable Products Initiative” inception impact assessment. Ensuring durability, reusability and repairability is essential to improve the quality of products placed on the EU market and, in the long run, of second-hand products. The Commission’s ambition to…

Consultation response

Solvay SA, 10 Nov 2020

Solvay welcomes the opportunity to provide feedback on the Commission’s Roadmap on Sustainable Products Initiative. The chemical industry is highly committed to bringing products to the market that are safe and have a low environmental impact, while maximising value for the consumers and the…

Consultation response

European Committee for Standardization, 22 Jun 2022

At its heart, the revision of the Directive 2009/125/EC on Ecodesign requirements for energy-related products to become a Regulation of the Ecodesign on sustainable products (ESPR), entails sustainability requirements as one of the means to achieve the European Green Deal and Circular Economy…

Consultation response

Decathlon SE, 22 Jun 2022

We share the aims of the Green Deal and fully support the European Commission’s drive to offer solutions so that products sold on the European market respect increasingly strict sustainability criteria. We’re supportive of implementing new circular economy initiatives and encouraging consumers to…

Consultation response

Policy Hub - Circularity for Apparel and Footwear, 22 Jun 2022

The Policy Hub – Circularity for Apparel and Footwear, uniting more than 700 brands, retailers, manufacturers, and other stakeholders within the industry, and representing more than 50% of the apparel and footwear sector, welcomes the European authorities' efforts to reduce the environmental impact…

Consultation response

amfori - Trade with Purpose, 16 Nov 2020

amfori, advocating for sustainable trade, welcomes a Sustainable Product Initiative (SPI) that will mainstream sustainable requirements in the EU market. Such an initiative can guide all companies towards their transition towards more circularity and provide a competitive advantage for…

Consultation response

TIC Council, 13 Nov 2020

The testing, inspection and certification (TIC) sector welcomes the sustainable products’ initiative. TIC Council members provide services that help manufacturers assess the compliance of their products with all legislation, including on energy, resource efficiency, traceability, social…

Consultation response

Policy Hub - Circularity for Apparel and Footwear, 2 Nov 2020

The Policy Hub welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment "Sustainable Products Initiative". The transition towards a circular economy in which materials can be used and reused at their highest potential, is one of the priorities of the apparel and…

Consultation response

Japan Business Council in Europe, 22 Jun 2022

The Japan Business Council in Europe (JBCE) welcomes this opportunity to provide feedback on the Commission's proposal for the Ecodesign for Sustainable Products Regulation (ESPR). JBCE is a cross-sectoral association of companies with Japanese parentage. We support the EU’s ambition to make…

Consultation response

Jernkontoret, 16 Nov 2020

The Swedish Steel Producer's Association, Jernkontoret, welcomes the initiative taken by the EU Commission on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, as part of Circular Economy Action Plan. It is important that the three…

Consultation response

Japan Business Council in Europe, 16 Nov 2020

Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding the Commission’s Sustainable Products Initiative. JBCE supports the EU’s target to achieve climate neutrality by 2050 and JBCE has committed to the European Commission’s objective to ensure that products placed on…

Consultation response

Federazione Nazionale dell'Industria Chimica italiana, 22 Jun 2022

Federchimica recognises the overall objectives of the European Commission proposal on the Ecodesign for Sustainable Products Regulation (ESPR) and believes that the Regulation will have a significant impact on its members as producers of chemicals (substances and mixtures). To achieve the ambitious…

Consultation response

Publyon, 16 Nov 2020

The members of the Closed Pallet Pooling Coalition (CPPC) – CHEP/IPP/LPR - welcome the opportunity to contribute to the Inception Impact Assessment on the Sustainable Products Initiative. The Coalition welcomes the European Commission’s ambition to propose – as mentioned in the Inception Impact…

Consultation response

CLG Europe, 16 Nov 2020

The Corporate Leaders Group Europe, a leading cross-sectoral business voice convened across the EU in support of a climate neutral economy, welcomes the sustainable products initiative and the revision of the Ecodesign Directive, as we believe that the Commission should make its new sustainable…

Consultation response

Construction Products Europe, 13 Nov 2020

Construction Products Europe shares the views of the EC about the need to build a fairer, greener and more digital Europe. Our industry worked during the last years to accomplish these goals under a European approach considering that the environmental performance of construction products only make…

Consultation response

Eurogypsum, 22 Jun 2022

Eurogypsum, the European federation of national associations of producers of gypsum products (such as plaster and plasterboard), welcomes the Sustainable Products Initiative (SPI) and its core objective of making products placed on the EU market more sustainable. Gypsum is an eternally recyclable…

Consultation response

Eurogypsum, 16 Nov 2020

Eurogypsum, the association representing the interests of the European industry extracting and processing gypsum, welcomes the inception impact assessment on a sustainable product policy. Gypsum is a cost-efficient, low carbon, sustainable mineral that has been used for centuries to produce…

Consultation response

TÜV-Verband e. V., 16 Nov 2020

The TÜV-Association welcomes the Commissions initiative to develop an initiative for more sustainable products and would like to provide feedback on the following issues. Establishing and enforcing EU’s sustainability rules Currently, there is no comprehensive set of requirements for a more…

Consultation response

European Partnership for Energy and the Environment, 22 Jun 2022

EPEE, representing the Refrigeration, Air-Conditioning and Heat-Pump (RACHP) industry, welcomes the European Commission’s proposal for a new Ecodesign for Sustainable Products Regulation as an ambitious piece of legislation. Enclosed position paper aims to highlight the loopholes where the draft…

Consultation response

Classifieds Marketplaces Europe, 22 Jun 2022

Members of Classifieds Marketplaces Europe (CME) operate online marketplaces across 17 European countries where we empower our users to reduce their purchase of new products by promoting circular consumption choices. By selling their pre-owned goods, our users play an active role in enabling the…

Consultation response

European Bioplastics, 21 Jun 2022

European Bioplastics (EUBP) welcomes the initiatives taken at Commission level to address unnecessary adverse environmental impacts of products placed on the EU market, while harmonising industry requirements. The objectives set in the COM proposal for the Ecodesign for sustainable products…

Consultation response

Grundfos Holding A/S, 16 Nov 2020

Please find attached input from Grundfos Holding

Consultation response

European Panel Federation, 22 Jun 2022

Please find here attached the feedback from EPF & EPLF.

Consultation response

Polski Związek Przemysłu Kosmetycznego, 22 Jun 2022

The Polish Union of the Cosmetics Industry supports the objectives of the Green Deal and the European Commission's proposal for a Regulation on Ecodesign for Sustainable Products (ESPR). Cosmetic products are outside the scope of the ESPR in the first step. However, the European Commission is…

Consultation response

Autodesk, Inc., 22 Jun 2022

Autodesk, one of the global leaders in design and make technologies, welcomes the European Commission’s proposal for Ecodesign for Sustainable Products Regulation (ESPR) and the opportunity to share its views on it (see attached document for full comment). The potential of digital transformation…

Consultation response

Polski Związek Przemysłu Kosmetycznego, 16 Nov 2020

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals. The Union would like to raise the following…

Consultation response

Hutnicza Izba Przemysłowo-Handlowa, 16 Nov 2020

The main goal of the circular economy should be supported, i.e. increasing the use of secondary raw materials, and thus reducing the amount of waste directed and deposited in landfills. Creating a catalog of critical secondary raw materials toi be considered that should be governed by other /…

Consultation response

European Panel Federation, 13 Nov 2020

The European Panel Federation (EPF), warmly welcomes the Inception Impact Assessment on the Sustainable Products Initiative and the review of the Ecodesign Directive. The wood-based panels industry believes that this initiative will be a key element in implementing a coherent framework allowing for…

Consultation response

ORGANIZACIÓN NACIONAL DE CIEGOS ESPAÑOLES, 30 Oct 2020

● CONTRIBUCIÓN DEL GRUPO SOCIAL ONCE A LA CONSULTA PÚBLICA SOBRE INICIATIVA SOBRE PRODUCTOS SOSTENIBLES. El Grupo Social ONCE es una de las organizaciones sociales dedicadas a las personas con discapacidad de referencia mundial y también uno de los mayores grupos ejemplo de la economía social.…

Consultation response

CO2 Value Europe AISBL, 22 Jun 2022

CO2 Value Europe is the European Association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030 and 2050, and for the development of the CCU industry. We represent more than 70…

Consultation response

Ecopreneur.eu, 21 Jun 2022

Ecopreneur.eu - The European Sustainable Business Federation - highly welcomes the European Commission’s proposal for a European Sustainable Product Initiative (SPI) including an Ecodesign for Sustainable Products Regulation (ESPR) and a Digital Product Passport (DPP). Our Federation however calls…

Consultation response

Refurbed Marketplace GmbH, 15 Jun 2022

refurbedTM is a marketplace for circular products. Our mission is to build the leading platform for sustainable products and services. refurbed provides : - Refurbished electronic devices, combining the quality and security of a new product with the sustainability and low price of a used one (40%…

Consultation response

CO2 Value Europe AISBL, 16 Nov 2020

CO2 Value Europe very much supports the EU’s goals to increase the circularity of the EU’s economy, while preserving its natural environment and supporting the contribution of the EU’s industry to achieve a climate-neutral continent. As a consequence, we welcome the Sustainable Products…

Consultation response

Ecopreneur.eu, 12 Nov 2020

Ecopreneur.eu, the sustainable business federation representing 3000 SMEs, welcomes the European Green Deal, the Circular Economy Action Plan and, as part of that, the Sustainable Products Initiative. We share their ambitious goals and advocate swift implementation. We also recommend additional…

Consultation response

ANSOL - Associação Nacional para o Software Livre, 22 Jun 2022

The main objectives of this regulation are to reduce the negative life cycle environmental impacts of products and improve the functioning of the internal market. ANSOL supports that goal and wants to highlight specific necessary regulations to reduce the negative life cycle environmental impacts…

Consultation response

Finnwatch ry, 21 Jun 2022

Finnwatch welcomes the initiative to establish a framework for setting ecodesign requirements for sustainable products. Current level of consumption in the European Union is utterly unsustainable and in direct contradiction with the EU goals of stopping climate change and the loss of biodiversity.…

Consultation response

TotalEnergies Corbion B.V., 7 Jun 2022

TotalEnergies Corbion welcomes the “Ecodesign Requirements for Sustainable Products” Regulation, we believe it is important that a balanced and science based regulation (and subsequent measures) will help to set a level-playing field for European companies while achieving the overall goals set by…

Consultation response

Bureau Brussels Consulting, 2 Nov 2020

The European Data Centre Association (EUDCA) represents the European data centre operator community. EEE (Electrical and Electronic Equipment) technologies are critical to energy transition and decarbonisation of EU and global economy. We believe is it crucial to push EU towards: • Transparent and…

Consultation response

Federation of Small Businesses, 22 Jun 2022

FSB supports the objective of the proposed Regulation to foster greater product sustainability and circularity, and agrees that a Regulation is the most effective means of ensuring greater harmonisation and levelling the playing field for businesses operating within the Single Market. We are…

Consultation response

European Ventilation Industry Association, 22 Jun 2022

The European Ventilation Industry Association (EVIA) support the need to keep legislation up-to-date and in line with the latest technological developments. In that light, we appreciate the European Commission’s proposals for an Ecodesign for Sustainable Products Regulation (ESPR). We believe that…

Consultation response

Extended Producer Responsibility Alliance, 20 Jun 2022

EXPRA calls for regulatory consistency across Circular Economy legislations Input to call for feedback on the Ecodesign for Sustainable Products Regulation (2022/0095(COD)) EXPRA backs the ambitions set by the European Commission’s Proposal for an Ecodesign for Sustainable Products Regulation…

Consultation response

Novamont SpA, 28 Oct 2020

The promotion of circular bioeconomy should be considered as a key element in the strategy aimed at making products placed on the EU market more sustainable. In fact, the circular bioeconomy is the economic sector that is based on the sustainable use of renewable resources for the development of…

Consultation response

European Council of the Paint, Printing Ink and Artists' Colours Industry, 21 Jun 2022

CEPE welcomes the opportunity to comment on the adopted Ecodesign for Sustainable Product Regulation (ESPR) proposal. CEPE finds the following elements to be critical for its industry sectors. • CEPE finds the ESPR proposal a tool for ensuring a level-playing field for certain product…

Consultation response

European Confederation of Woodworking Industries, 16 Nov 2020

Please see the document attached.

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 22 Jun 2022

Please find FNADE's feedback attached.

Consultation response

Verband der deutschen Lack- und Druckfarbenindustrie e. V., 21 Jun 2022

Bitte beachten Sie die angehängte Datei als Rückmeldung des Verbandes der deutschen Lack- und Druckfarbenindustrie (VdL). Vielen Dank.

Consultation response

Free Software Foundation Europe e.V., 20 Jun 2022

The main objectives of this regulation are to reduce the negative life cycle environmental impacts of products and improve the functioning of the internal market. The Free Software Foundation Europe supports that goal and wants to highlight specific necessary regulations to reduce the negative life…

Consultation response

Verband der deutschen Lack- und Druckfarbenindustrie e. V., 16 Nov 2020

Bitte beachten Sie die angehängte Datei als Rückmeldung des VdL e.V. (Verband der deutschen Lack- und Druckfarbenindustrie).

Consultation response

Fur Europe, 16 Nov 2020

Fur Europe welcomes the inception impact assessment on the Sustainable Product Initiative (SPI). The European fur industry sees the SPI as a major opportunity to foster the shift of European businesses towards full circularity by removing present obstacles and fostering best practices and features…

Consultation response

Sandbag Climate Campaign, 12 Nov 2020

The Sustainable Products Initiative (SPI) offers the possibility to introduce effective, enforceable and holistic sustainability requirements for products in the EU. It is relevant for a wide variety of products, but particularly for emissions-intensive commodity products. Emissions-intensive…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 2 Nov 2020

Feedback to the Sustainable Products Initiative FNADE, the French association of environmental services companies, welcomes the commission's new initiative on sustainable products, which will lead to implement a coherent policy framework both on product environmental footprint and on consumers…

Consultation response

LKQ Europe, 21 Jun 2022

LKQ Europe, a subsidiary of LKQ Corporation, with its head office in Zug, Switzerland, is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe. It currently employs approximately 26,000 people with a network of more than 1,000 branches…

Consultation response

Confederation of the European Bicycle Industry ASBL, 10 Jun 2022

CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its national industry members. In the EU there are about 1000 companies, the majority of them being small and medium sized enterprises (SMEs), providing more than 150,000 direct/indirect jobs. Via the…

Consultation response

Reusable Packaging Europe, 16 Nov 2020

Reusable Packaging Europe (RPE) fully supports the European Commission in its ambition to widen the scope of the Eco-design Directive and promote sustainable packaging (design), and calls on the Commission to respect the respect the waste hierarchy in doing so, thus promoting reusable (transport)…

Consultation response

Generation Climate Europe AISBL, 22 Jun 2022

Generation Climate Europe welcomes the Commission’s proposal for an Ecodesign for Sustainable Products Regulation (ESPR) replacing the current Ecodesign Directive. We consider that, overall, its level of comprehensiveness and ambition are the necessary ones that are needed in light of the need to…

Consultation response

C&A Mode GmbH & Co. KG, 22 Jun 2022

We support the overall vision set by the European Union to reach climate neutrality and optimise the use of our resources. C&A has a long been committed to offer more sustainable products at affordable prices. • C&A is committed to offer more sustainable products at affordable prices and has set…

Consultation response

International Wool Textile Organisation, 21 Jun 2022

The International Wool Textile Organisation (IWTO), representing the global wool textile industry, welcomes the European Commission’s proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products, the Ecodesign for Sustainable Products Regulation…

Consultation response

FSC International Center GmbH (IC), 21 Jun 2022

The Forest Stewardship Council (FSC), the pioneer of forest certification with nearly +50 million hectares of certified forests in Europe, supports the EU Commission objective of improving the overall sustainability and circularity aspects of products. In the attached document we have elaborated…

Consultation response

Unión de Empresas Siderúrgicas, 16 Nov 2020

The Spanish Steel Association, UNESID, in representation of the Spanish Steel Industry welcomes the opportunity to give feedback on the Inception Impact Assessment of the Sustainable Products Initiative. The European Green Deal has defined ambitious aspirations that will entail a converging point…

Consultation response

FSC International Center GmbH (IC), 16 Nov 2020

The Forest Stewardship Council (FSC), the pioneer of forest certification with nearly 50 million of forest hectares certified in Europe, strives to support the EU Commission in making products more sustainable. In this framework, FSC recommends the following: 1. Design for renewables:…

Consultation response

BSEF - The International Bromine Council, 20 Jun 2022

BSEF, The International Bromine Council, attaches the enclosed position paper on the EU Regulation on Eco-design for Sustainable Products. A summary of the key messages are as follows; • Develop a new methodology for the ESPR • Put in place a representative Eco-design Forum • Avoid duplication of…

Consultation response

Confédération des Associations Nationales de Tanneurs et Mégissiers de la Communauté Européenne, 18 Jun 2022

COTANCE, the representative body of the European Leather-Making Industry, welcomes this opportunity to give its feedback to the Commission Ecodesign proposal. Leather is the material that results from the recycling of hides & skins which arise as a residue (ABP) during slaughter of animals for…

Consultation response

Syctom Agence métropolitaine des déchets ménagers, 13 Nov 2020

La lutte contre l’augmentation progressive des déchets engendrées par les activités humaines nécessite d’agir simultanément sur plusieurs fronts, dans le respect de la hiérarchie des déchets. Le Syctom soutient l’instauration de principes visant à améliorer la durabilité, le réemploi et la…

Consultation response

CITEO, 22 Jun 2022

Citeo, the French company in charge of Extended Producer Responsibility (EPR) for household packaging and graphic papers, would like to share its views on the proposal for a regulation on ecodesign for sustainable products presented by the European Commission on 30 March 2022, as part of the…

Consultation response

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 22 Jun 2022

Eurovent supports the Ecodesign Regulation for Sustainable Products proposal. Product sustainability must be addressed in harmonised way across the EU to ensure the free movement of products within the Single Market. For the new Ecodesign framework to be as successful as possible while stimulating…

Consultation response

Offshore Wind Foundations Alliance, 22 Jun 2022

The Offshore Wind Foundations Alliance (OWFA) is a coalition of five European companies producing offshore wind foundations: Bladt Industries A/S (Denmark), EEW Special Pipe Constructions GmbH (Germany), SIF Netherlands BV (the Netherlands), Smulders Projects Belgium (Belgium), and Steelwind…

Consultation response

Clariant Produkte (Deutschland) GmbH, 21 Jun 2022

Clariant welcomes the European Commission proposal on the Ecodesign for Sustainable Products Regulation and supports the overall objectives of this ambitious initiative. We are convinced that sustainable products can bring a decisive contribution in achieving the EU’s flagship goals established…

Consultation response

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 16 Nov 2020

The Sustainable Products Initiative builds upon Circular Economy Action Plan and intends to extend the scope of the Ecodesign Directive. While not addressing directly the policy objective, the revision Methodology of Ecodesign of Energy Related Products (MEErP) is paving the way for the…

Consultation response

Hazardous Waste Europe, 30 Oct 2020

Non toxic material cycles are key to ensure a clean and sustainable circular economy to create confidence in secondary raw materials. This happens by implementing safe and sustainable by-design requirements, but also by taking into account a few principles at the recycling phases. As pointed out in…

Consultation response

FEDERACIÓN EMPRESARIAL DE LA INDUSTRIA QUÍMICA ESPAÑOLA, 22 Jun 2022

Feique, en línea con los comentarios remitidos por la industria química europea representada por Cefic, valora positivamente la propuesta de la Comisión Europea sobre el Reglamento de diseño ecológico para productos sostenibles y apoya los objetivos generales de esta ambiciosa iniciativa. Una…

Consultation response

Bureau International du Béton Manufacturé, 16 Nov 2020

BIBM supports the objectives of the Sustainable Product Policy Initiative (SPPI) within the new Circular Economy Action Plan, one of the action plan’s most important initiative to shift towards a well-functioning European market for secondary raw materials and circular products. Construction…

Consultation response

European Remanufacturing Council, 16 Nov 2020

The European Remanufacturing Council welcomes the opportunity to provide feedback on the Sustainable Products Initiative. Please see the attached document for our full response.

Consultation response

Industrial Minerals Association - Europe, 30 Oct 2020

The Industrial Minerals Association, IMA-Europe, and its members welcome the opportunity to share comments on the inception impact assessment of the SPPI. Minerals' unique properties provide specific functions in a myriad of products and processes. The magazines we read, the water we drink, the…

Consultation response

Confédération Européenne de l’Industrie de la Chaussure, 22 Jun 2022

The European Footwear Confederation (CEC) welcomes the main concepts of the EC proposal for a review of Eco-design Directive and their integration in the EU Strategy for Sustainable Textiles. We recognise the capacity of the proposal to ensure a sustainable future for our industry, a priority for…

Consultation response

European Garden Machinery industry Federation, 22 Jun 2022

EGMF is the European federation representing major garden, landscaping, forestry and turf equipment manufacturers. Through its 30 European corporate members and 7 National Associations, EGMF represents 18 million units placed on the European market and its members employ over 120,000 people in the…

Consultation response

European Refurbishment Association, 21 Jun 2022

EUREFAS - the European Refurbishment Association welcomes the proposal of Ecodesign for Sustainable Products setting up ambitious principles of durability, reusability and reparability at the design and manufacturing stages, in order to implement the green transition. New sustainable products are…

Consultation response

FREE ICT EUROPE FOUNDATION, 16 Nov 2020

Free ICT Europe Foundation(FIE) is a not-for-profit foundation actively promoting the ICT Secondary Market within Europe. Our objective is to secure the right of ownership and the freedom for consumers and businesses alike to freely choose their providers to trade, maintain and repair hardware and…

Consultation response

Federation of Aluminium Consumers in Europe, 11 Nov 2020

FACE supports the EU Green Deal and warmly welcomes the Sustainable Products initiative. This proposal aligns with FACE green ambition by incentivizing businesses and industries to place more sustainable products on the EU market. Sustainability and the green transition have always been at the…

Consultation response

Confédération Internationale des Négociants en Oeuvres d'Art, 10 Nov 2020

Established in 1935, CINOA is the principal international confederation of Art & Antique dealer associations representing more than 5,000 dealer world-wide. Affiliated dealers, from 30 leading dealer associations, cover a wide array of specialties from antiquities to contemporary art. CINOA’s…

Consultation response

European Garden Machinery industry Federation, 9 Nov 2020

EGMF - the European Garden Machinery Industry Federation - fully supports the European Commission’s ambition to realise a circular economy. The European garden and outdoor power equipment industry shares with households, municipalities, landscapers, greenkeepers, gardeners and farmers the…

Consultation response

Sympatex Technologies, 22 Jun 2022

Sympatex fully supports EU policy to regulate that design for circularity becomes the norm for new products in order to ensure that waste is avoided at the end of life and material ressources are used in the most economic way. This is not only a moral imperative for future generations, but it will…

Consultation response

The Restart Project, 22 Jun 2022

Right to Repair Europe’s reaction to ESPR Right to Repair Europe is enthusiastic about the publication of the Ecodesign for Sustainable Products Regulation (ESPR) which has the potential to improve the way products on the EU market are designed and serviced. This regulation could mean a leap…

Consultation response

European Furniture Industries Confederation, 22 Jun 2022

The European furniture industry is following closely Green Deal initiatives aimed at making circular economy the norm, such as the Sustainable Products Initiative (SPI). As such, building on the EFIC position on the SPI of June 2021, we welcome the possibility to provide our views on the Ecodesign…

Consultation response

Tarkett, 22 Jun 2022

Tarkett, a global leader in innovative and sustainable solutions for flooring, welcomes the European Commission’s proposal on Ecodesign for Sustainable Products Regulation (ESPR), aiming at creating an EU-wide Single Market for sustainable products across the European Union, while improving…

Consultation response

European Vending & Coffee Service Association, 1 Jun 2022

Please find attached comments on behalf of the European Vending & Coffee Service Association (EVA) on the proposed Ecodesign for Sustainable Products Regulation.

Consultation response

European Furniture Industries Confederation, 4 Nov 2020

EFIC, the European Furniture Industries Confederation, welcomes the opportunity to provide comments on the inception impact assessment of the upcoming Sustainable Products Initiative. Please see our main considerations below and detailed argumentation in the attached document. A) Need for…

Consultation response

European Association of Chemical Distributors, 28 Oct 2020

Fecc supports Sustainable Products Initiative roadmap and the measures proposed to assess the presence of certain chemicals in products present in the EU market. In this context we would like to raise the following points on behalf of the European chemical distribution sector and in particular the…

Consultation response

International Fur Trade Federation, 22 Jun 2022

IFF supports the regulation objective of improving the sustainability of products and wishes to bring the Commission’s attention on a number of elements in the draft that IFF believes require further consideration and refinement. Article 2. The proposal defines product groups through the lens of…

Consultation response

Adolf Würth GmbH & Co. KG, 22 Jun 2022

Die Adolf Würth GmbH & Co. KG (AWKG) unterstützt die Ziele des Vorschlags der Europäischen Union zur Ökodesign-Richtlinie für die Verordnung zu nachhaltigen Produkten. Dabei bemüht sich die Adolf Würth GmbH & Co. KG nachhaltig zu wirtschaften, beispielsweise durch die Entwicklung innovativer…

Consultation response

Norges Naturvernforbund (Friends of the Earth Norway), 22 Jun 2022

See attached file

Consultation response

Refashion, 22 Jun 2022

Refashion welcomes the publication of the proposal for a Regulation establishing Ecodesign requirements for sustainable products (ESPR). In particular, Refashion supports the extension of the previous Directive’s scope to key sets of products, such as textiles. Refashion backs the described…

Consultation response

European Infrared Heating Alliance, 22 Jun 2022

The European Infrared Heating Alliance (EIHA) supports the need to keep legislation updated and in line with the latest technological developments. In that light, we appreciate the European Commission’s proposals for an Ecodesign for Sustainable Products Regulation (ESPR). We believe that…

Consultation response

ETSA (EUROPEAN TEXTILE SERVICES ASSOCIATION), 22 Jun 2022

ETSA’s feedback to the European Commission on establishing a framework for setting eco-design requirements for sustainable products We at ETSA, the European Textile Service Association wholly support the European Commission’s framework in establishing eco-design requirements for sustainable…

Consultation response

Electric Underfloor Heating Alliance, 22 Jun 2022

The Electric Underfloor Heating Alliance (EUHA) supports the need to keep legislation updated and in line with the latest technological developments. In that light, we appreciate the European Commission’s proposals for an Ecodesign for Sustainable Products Regulation (ESPR). We believe that…

Consultation response

European Diisocyanate and Polyol Producers Association, 22 Jun 2022

ISOPA, the Association of Diisocyanates and Polyols Producers, shares the vision of a Circular Economy and is committed to the Chemicals Strategy for Sustainability. We welcome the opportunity to provide comments feeding into the upcoming Ecodesign Sustainable Products Regulation (ESPR), formerly…

Consultation response

Pyrowave, 21 Jun 2022

Pyrowave is a pioneer in the electrification of chemical processes based on low carbon footprint microwaves. Pyrowave is also a Canadian leader in the plastics circular economy and chemical recycling to regenerate post-consumer and post-industrial plastics into new plastics, reclaiming these…

Consultation response

Alliance for AI, IoT and Edge Continuum Innovation IVZW, 21 Jun 2022

The European Commission published on 31 March 2022 a proposal for a Regulation on Ecodesign for Sustainable Products (the Regulation). The proposal addresses product design, which determines up to 80% of a product's lifecycle environmental impact. It sets new requirements to make products more…

Consultation response

HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V., 20 Jun 2022

In general, HKI supports the Ecodesign instrument which already delivered for EU consumers, industry and the planet by taking due consideration of all aspects of the life cycle of the product, setting measurable and enforceable requirements and based on the proportionality principle. It is the…

Consultation response

EURALARM, 20 Jun 2022

Euralarm, the European association representing the electronic fire safety and security industry, welcomes the opportunity provided by the European Commission to give feedback on the proposal for ESPR. We generally support the proposal but also wishes to raise some comments, concerns and…

Consultation response

SEKAB Biofuels & Chemicals AB, 1 Jun 2022

Sekab, a leading producer of bio-based chemicals, welcomes the European Commission’s Sustainable Products Initiative and its ambition to reduce the negative life cycle environmental impacts of products through an updated Eco-Design Directive. We are, however, concerned about the proposal to use…

Consultation response

Association of Medical Device Reprocessors, 16 Nov 2020

The Association of Medical Device Reprocessors (AMDR) appreciates the Commission’s efforts to promote a cleaner and more competitive Europe. We welcome the opportunity to provide feedback to the Inception Impact Assessment on the Sustainable Products Initiative. - AMDR strongly agrees with the…

Consultation response

Institut Bauen und Umwelt e.V., 16 Nov 2020

Institut Bauen und Umwelt e.V. (IBU) is one of Europe’s largest programme operators for environmental product declarations (EPDs) of construction products. With its around 170 member companies and around 50 member associations at German, European, and global levels it represents far more than 3’000…

Consultation response

European Parquet Federation, 13 Nov 2020

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Sustainable Products Initiative”. While this initiative is not directly focused on the products we are representing, we guess that its overarching sustainability principles will concern…

Consultation response

maki Consulting GmbH, 22 Jun 2022

maki Consulting welcomes the comprehensive legislation with its expansion to non energy-related products, its many options for measures to be selected and tailored for the specific product group (while considering the individual product’s characteristics). The tie-in with the complementary Green…

Consultation response

L'ENTE ITALIANO DI ACCREDITAMENTO, 22 Jun 2022

ACCREDIA, Ente unico di accreditamento italiano, propone alcune osservazioni sul testo del Regolamento che si augura vengano prese in considerazione per apportare al Regolamento stesso i chiarimenti o le modifiche che si ritengono necessari perché raggiunga i suoi obiettivi. 1. Nell’art. 43 al…

Consultation response

International Thin-Film Solar Industry Association, 22 Jun 2022

PVthin – the international trade body promoting thin-film photovoltaic (PV) technologies – supports the regulatory proposal’s objective to extend the scope of Ecodesign beyond energy-related projects. PVthin, having closely followed the ongoing work by the Commission to define Ecodesign…

Consultation response

, 22 Jun 2022

Corbion welcomes the Commission’s initiatives to address unnecessary adverse environmental impacts of products placed on the EU market, while harmonizing industry requirements. The objectives set in the COM proposal for the Ecodesign for sustainable products Regulation (ESPR) are core to Corbion’s…

Consultation response

HUGO BOSS AG, 22 Jun 2022

In line with the EU Green Deal and the Circular Economy Action Plan, we as HUGO BOSS aim to contribute to continuously lowering the environmental impact of our business activities. We are convinced that the future of business will be a circular system, where products are made to last, and made from…

Consultation response

Stichting Global Organization for PHA, 22 Jun 2022

Dear Members of the European Commission, We are pleased to respond to your proposal for “establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC”. We believe that such an initiative is extremely important and that it should further…

Consultation response

Confindustria Toscana Nord, 22 Jun 2022

Confindustria Toscana Nord, follows with particular attention the roadmap on the 'Sustainable Product Initiative' published by the European Commission. In fact, the Prato area is home to the largest textile cluster in Italy and Europe, which has been based on a circular business model for…

Consultation response

Verband der Mineralfarbenindustrie e. V., 22 Jun 2022

The Verband der Mineralfarbenindustrie e.V. (VdMi) welcomes the EU Commission's efforts to strengthen the circular economy through the Ecodesign Regulation for Sustainable Products (ESPR), which is part of the 2020 Circular Economy Action Plan, as part of the Green Deal. Nevertheless, when…

Consultation response

The Japan Refrigeration and Air Conditioning Industry Association, 22 Jun 2022

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) deeply appreciate European Commission’s effort taken for an Ecodesign for Sustainable Products Regulation (ESPR), and welcomes this opportunity to feedback regarding the proposal for the ESPR. Executive Summary 1. In the…

Consultation response

EuroWindoor AISBL, 21 Jun 2022

EuroWindoor appreciates the opportunity to give feedback to the ESPR consultation und supports the aim of making sustainable products the norm while at the same time strengthening a level playing field with a fair and smooth functioning internal market. EuroWindoor would however like to stress…

Consultation response

, 20 Jun 2022

FENA, representing the European furniture retail sector, supports the EU's ambitious sustainability goals. On 30 March 2022, the European Commission presented its strategy and concrete proposals to strengthen the circular economy. According to these, sustainable products are to become the norm in…

Consultation response

European Committee of Manufacturers of Electrical Machines and Power Electronics, 16 Jun 2022

CEMEP welcomes the draft Ecodesign for Sustainable Products Regulation (ESPR) as presented by the European Commission on 30 March 2022. CEMEP believes that the draft regulation will support further development of sustainable products and markets, and we strongly encourage a common European…

Consultation response

electric Handdryer Association, 14 Jun 2022

eHA’s Comments on the Sustainable Products Initiative – 13 June 2022 The electric Hand Dryers Association (eHA) highly welcomes the European Commission’s proposal for a Sustainable Products Policy Initiative (SPI). eHA is an international association comprising small and medium-sized electric hand…

Consultation response

Roundtable for Reusable Crates Trays and Pallets, 8 Jun 2022

The Roundtable for Reusable Containers Trays and Pallets (RCTP) is happy to submit feedback on the Ecodesign for Sustainable Product Regulation proposal. The RCTP supports the ambitions to make products in the EU market more sustainable, ensuring that waste generation is prevented and used…

Consultation response

Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület, 4 Apr 2022

Dear European Commission, Dear DGs, Dear Ladies/Gentlemen, After reading this Initiative as the Commission's work program, our Association will provide the following professional information to Ms Ursula von der Leyen, President of the European Commission, to Mr Frans Timmermans EVP., to the named…

Consultation response

maki Consulting GmbH, 16 Nov 2020

We welcome the potentially far reaching and inspiring approach of a complete overhaul of the Ecodesign Directive, substantially deepening and broadening it. The Ecodesign Directive has very substantially helped to improve the environmental performance of a range of important energy-using (and to…

Consultation response

Federation of European Rigid Polyurethane Foam Associations, 16 Nov 2020

PU Europe welcomes the opportunity to comment the roadmap on the “Sustainable Products” initiative and firmly believes that PU insulation products have a key role to play in a greener and more sustainable future. The views expressed below reuse and complement our submission to the “substantiating…

Consultation response

European Union of Electrical Wholesalers, 16 Nov 2020

The European Union of Electrical Wholesalers (EUEW ) welcomes the opportunity to contribute its feedback to the consultation on the roadmap for the Sustainable Products Initiative (SPI). Electrification is the key measure to reduce CO2-emissions and build a more sustainable world. At the same…

Consultation response

European DIY Retail Association, 16 Nov 2020

Dear Sir/Madam, The European DIY Retail Association (EDRA) is pleased to share their feedback on the SPI with the Commission. Best regards, Julien BOUYERON Director of European Affairs European DIY Retail Association (EDRA)

Consultation response

European Bedding Industries Association, 16 Nov 2020

The European Bedding Industry welcomes the EU Product Policy Initiative and thanks the Commission for the opportunity to contribute. At the EU-28 level, 520 million mattresses are currently in-use and the stock is growing by 4.5 million units per year. 45.1 million new mattresses are sold…

Consultation response

The International Confederation of Paper and Board Converters in Europe, 15 Nov 2020

The paper & board converters welcome the Sustainable Products Initiative of the European Commission aiming to establish sustainability principles and leading the way to a cleaner and more competitive Europe. The sustainable products policy could be a real driver for circularity starting from…

Consultation response

, 13 Nov 2020

My feedback is attached as a file.

Consultation response

European Autoclaved Aerated Concrete Association, 12 Nov 2020

The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s Sustainable Products Initiative and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. EAACA promotes the interests of producers of autoclaved aerated…

Consultation response

Conselho Empresarial para o Desenvolvimento Sustentável, 2 Nov 2020

Please, see attached the BCSD Portugal's feedback on the Roadmap for the Sustainable Products Initiative.

Consultation response

Associazione Italiana Ricostruttori Pneumatici, 30 Oct 2020

Founded in 1963, AIRP represents the tyre retreading industry in Italy. Among its objectives, it aims to foster and follow activities in defence of industry and members, to sponsor activities supporting and increasing the importance of the tyre retreading industry socially, technically and…

Consultation response

Associação Portuguesa para a Defesa do Consumidor, 22 Oct 2020

We welcome the European Commission's initiative to extend the scope of the Ecodesign Directive to a wider range of products within the framework of the “European Green Deal”. We appreciate the attention given to the overall life-cycle of the products placed on the EU market, in order to achieve…

Consultation response

Bundesverband Reifenhandel und Vulkaniseur-Handwerk e.V., 9 Oct 2020

The BRV Bundesverband Reifenhandel und Vulkaniseur-Handwerk e.V. (German Tyre Retail and Vulcanisation Trade Association) represents the interests of German retreaders and tire disposal companies in addition to the tire retail branch. We welcome the fact that the scope of application of the…

Consultation response

International Association of Lighting Designers Europe, 5 Oct 2020

See file attached

Consultation response

Baumer hhs GmbH, 3 Oct 2020

The term sustainable is very vague. As a result, everything is advertised with sustainability. Often individual aspects of sustainability are picked out in advertising, but this leads to confusion among customers. "Bio-based" is perceived by customers as valuable and good, even if biomass base…

Consultation response

Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület, 17 Sept 2020

Dear European Commission, Dear Lady/Sir, INCEPTION IMPACT ASSESSMENT After read the Inception Impact Assessment, we will briefly explain our environmental management engineer proposal below. In order to create Sustainable Products, the first step in changing the product structure is to create an…