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Environmental Coalition on Standards

ECOS

ECOS is an international NGO advocating for environmentally friendly technical standards, policies, and laws.

Lobbying Activity

Meeting with Ilaria Salis (Member of the European Parliament) and European Environmental Bureau and Climate Action Network Europe

8 Jan 2026 · Housing affordability

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and European Environmental Bureau and

9 Dec 2025 · Exchange of views on the forthcoming Industrial Accelerator Act (IAA), and other relevant industrial policies.

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

ECOS welcomes the opportunity to provide feedback to the European Commission on existing taxonomy criteria, in a view to foster their continuous improvement. The attachment to this response draws on the CSO and academic review published at https://science-based-taxo.org/.
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Meeting with Valdis Dombrovskis (Commissioner) and

4 Dec 2025 · Industrial Accelerator Act

Meeting with Heiko Kunst (Head of Unit Climate Action)

20 Nov 2025 · Product benchmark update – grey and white clinker

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Transport and Environment (European Federation for Transport and Environment) and

19 Nov 2025 · Exchange of views on raw materials, on the side of the EU Raw Materials Week 2025

Environmental NGO urges EU to protect future generations from pollution and resource depletion

7 Nov 2025
Topic — EU strategy to ensure today's decisions don't harm future generations.
Message — The organization calls for urgent phase-out of persistent chemicals like PFAS, stricter chemical regulations using precautionary approach, and actions to reduce plastic production. They demand the strategy explicitly link intergenerational fairness with environmental protection and establish impact assessments for all legislation.12345
Why — This would strengthen environmental protections aligned with their core mission since 2001.67
Impact — Chemical and plastic industries lose ability to continue production without strict oversight.8
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Meeting with Guillaume Roty (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2025 · The quarterly meeting between the DG GROW H3 and the organisations listed in Annex III to the EU standardisation Regulation.

ECOS urges caution on AI data centre expansion

5 Nov 2025
Topic — Roadmap for digitalisation and AI adoption across Europe's energy sector.
Message — ECOS calls for strict safeguards on AI and data centre growth, including binding resource-use targets, sufficiency principles to prioritize essential services, and mandatory lifecycle reporting on energy, water, and emissions. They want AI deployment aligned with decarbonisation pathways and conditioned on verifiable renewable energy that doesn't undermine electrification elsewhere.1234
Why — This protects their environmental advocacy mission by preventing AI growth from derailing climate commitments.56
Impact — Tech companies and data centre operators lose freedom to expand without environmental constraints.78
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Environmental Coalition Urges Stronger Life-Cycle Assessment Rules for Buildings

20 Oct 2025
Topic — EU framework for calculating life-cycle global warming potential of new buildings.
Message — The organization supports establishing a data hierarchy that incentivizes producers to develop primary environmental data. They request that Member State methodologies be validated by the Commission and remain compatible with EN15804. They also call for mandatory assessment of all life-cycle stages including B5 and B7 modules.123
Why — This would strengthen environmental standards and ensure consistent assessment across Member States.45
Impact — Building industry loses flexibility to exclude certain assessment modules from life-cycle calculations.6
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Environmental Coalition urges EU to prioritize electric heat pumps over biomass

9 Oct 2025
Topic — EU strategy on decarbonizing heating and cooling systems in buildings and industry.
Message — The organization calls for stronger regulations on heat pump efficiency and flexibility, financial support for low-income households, and public procurement guidelines favoring electric heat pumps. They request swift implementation of ecodesign rules and warn against supporting hydrogen or biomass technologies.1234
Why — This would create favorable market conditions for environmental standards in heating technologies.56
Impact — Fossil fuel and biomass heating industries lose market share to electric alternatives.78
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Environmental coalition urges smart standards to accelerate EU electrification

9 Oct 2025
Topic — Action plan to increase electricity use across heating, transport and industry sectors.
Message — The organization requests future-proof communication standards for heat pumps and EVs, robust smart charging protocols, and deployment of industrial heat pumps. They emphasize avoiding vendor lock-in through standardized protocols like EN50491-12-2.123
Why — This would ensure their preferred environmental standards become mandatory across multiple sectors.456
Impact — Device manufacturers lose flexibility in proprietary systems and face requirements for open standards.78
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ECOS urges EU to ban nature offsetting and greenwashing

30 Sept 2025
Topic — European Commission consultation on a roadmap to develop nature credit systems.
Message — ECOS demands a ban on nature offsetting and harmful subsidies. They argue credits should only implement the polluter-pays principle.12
Why — Strong regulation prevents market-driven deregulation and safeguards long-term public funding.3
Impact — Companies lose the ability to use cheap offsets to justify destructive practices.4
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Environmental group urges strict rules to protect CBAM integrity

25 Sept 2025
Topic — EU methodology for calculating embedded emissions under Carbon Border Adjustment Mechanism.
Message — The organisation requests maintaining actual emissions calculations over default values, implementing proportional mark-ups on national averages, and using existing ETS benchmarks rather than creating separate CBAM benchmarks. They emphasize regulatory stability is essential for frontrunner companies that built business cases around free allowance phase-out.123
Why — This would strengthen environmental protections and prevent producers from evading carbon pricing through default value loopholes.45
Impact — High-emitting producers in countries with low national averages lose competitive advantage from weak carbon pricing enforcement.67
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Environmental group urges strict carbon pricing rules to protect CBAM integrity

25 Sept 2025
Topic — EU regulation on certification and conversion of carbon prices paid in third countries.
Message — The organization requests strict enforcement of 'effective payment' rules and opposes weakening CBAM through broad use of default emission values. They urge maintaining the phase-out of free allowances and using ETS benchmarks rather than creating separate CBAM benchmarks. They emphasize keeping certification rules simple while ensuring robust verification.12345
Why — This would strengthen environmental standards and expand their influence over EU carbon pricing policy implementation.67
Impact — High-emission producers in third countries lose the ability to use national averages to avoid full carbon costs.8910
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Environmental coalition backs swift CBAM rollout, warns against watering down rules

25 Sept 2025
Topic — EU rules on adjusting Carbon Border Adjustment Mechanism certificates for free ETS allowances.
Message — The organization calls for regulatory stability and timely CBAM implementation in 2026. They urge basing calculations on existing ETS benchmarks rather than creating new CBAM benchmarks, and warn against allowing easier use of average emission values that could undermine environmental integrity.123
Why — This would preserve strong climate protections and support EU industrial frontrunners who invested in decarbonization.45
Impact — Heavy industrial emitters lose the ability to evade carbon costs using favorable default values.678
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Meeting with Guillaume Roty (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs), Guillaume Roty (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and

23 Sept 2025 · The upcoming revision of the Standardisation Regulation 1025/2012 and in particular the issue of inclusiveness in standardisation work.

Environmental Coalition Urges EU to Prioritize Circularity and Green Procurement in Housing Strategy

16 Sept 2025
Topic — European Strategy for Housing Construction to support construction sector and close housing supply-demand gap.
Message — The organization requests the EU prioritize reusing existing buildings over new construction, mandate environmental considerations in public procurement beyond lowest price, and remove standards barriers to low-carbon cement alternatives. They argue current policies favor short-term costs while ignoring life-cycle impacts and proven sustainable technologies.123
Why — This would align construction practices with their environmental mission and increase influence over EU housing policy.45
Impact — Traditional cement and construction industries lose market advantages from recipe-based standards and price-only procurement.67
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ECOS urges Commission to halt expansion of industrial subsidies

4 Sept 2025
Topic — The consultation reviews state aid guidelines for industries facing high electricity costs.
Message — ECOS opposes expanding the list of sectors eligible for state aid compensation. They suggest lowering prices through renewable energy instead of using public subsidies.12
Why — This avoids depleting public budgets and prevents long-term dependence on state subsidies.345
Impact — Electro-intensive companies lose the chance to receive new government financial support.6
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Response to Revision of the 'New Legislative Framework'

29 Aug 2025

ECOS welcomes the European Commissions intention to improve the EU product legislation to address market developments, circularity and digital needs. The revision of the New legislative Framework (NLF) which underpins mandatory product requirements through harmonised standards (hENs), should aim at improving the overall EU product framework adapting it to the current environmental and market challenges of new products and businesses, thereby supporting the implementation of environmental legislation. While ECOS acknowledges that a full-scale overhaul of the NLF could undermine trust among market players and create instability of the Single Market, the NLF should evolve and promote sustainable business models and responsible consumption patterns. Addressing emerging digital elements and circularity principles is necessary to ensure a consistent future proof EU product legislation system aligned with EUs climate and environmental objectives. It is key for us that the NLF: Secures inclusive and timely hENs for a trusted European product legislation, and Adapts for a circular and innovative Europe. See our paper attached for further details.
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ECOS urges tougher online marketplace accountability and repair rights

26 Aug 2025
Topic — The EU is setting consumer policy priorities for 2025-2030 to ensure market fairness.
Message — ECOS recommends making online marketplaces accountable for the non-compliant products they sell. They also call for a real right to repair for consumers.12
Why — This would ensure the environmental standards ECOS promotes are strictly followed and enforced.3
Impact — Online marketplaces would face new legal responsibilities and costs for hosting non-compliant products.4
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ECOS Urges EU to Base CBAM Changes on Solid Evidence

26 Aug 2025
Topic — The consultation concerns extending carbon border taxes to downstream products and preventing circumvention.
Message — ECOS recommends that the Commission only act upon solid and verifiable evidence of circumvention. They argue improvements are only possible once there is experience with the real introduction.12
Why — This ensures CBAM remains a robust, data-driven instrument for driving global industrial decarbonisation.3
Impact — EU industries facing unfair competition may suffer while the Commission gathers necessary empirical evidence.4
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ECOS demands end to loopholes for destroying unsold clothing

11 Aug 2025
Topic — This consultation concerns exceptions to the ban on destroying unsold apparel and footwear.
Message — The coalition demands stricter conditions for exceptions, ensuring products are only destroyed when repair is technically impossible. They call for the deletion of broad exemptions for licensing agreements and branded items.12
Why — Tight rules force companies to reduce overproduction and follow circular principles.3
Impact — Fast fashion brands lose their easy route for disposing of excess inventory.4
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Response to Commission Implementing Act establishing a Strategic Project application template under the Critical Raw Materials Act

4 Aug 2025

ECOS welcomes the development of a single template for Strategic Project applications under the Critical Raw Materials Act (CRMA) but is concerned that the current draft does not ensure robust environmental and social safeguards. The Strategic Project designation grants projects access to fast-tracking and this must require strong safeguards to maintain public trust and EU credibility. The template largely relies on self-declared information from project promoters, with minimal verification or enforceable criteria. This risks Strategic Projects being recognised without demonstrating high sustainability performance or alignment with EU requirements and values on environmental protection, human rights, and circularity. An independent evaluation layer or audit mechanism should verify self-reported data before Strategic Project status is granted. The section (3) on standards and certification schemes is overly generic and inadequate. No standard has been harmonised yet with the CRMA, and no certification scheme has been formally recognised by the European Commission, and the template allows any voluntary scheme to be cited regardless of its scope, credibility, or ambition. This creates a risk that weak schemes could be used to legitimise projects without meaningful and verified sustainability performance. ECOS recommends establishing minimum criteria for recognition of schemes, including: 1- Independent third-party auditing and public reporting. 2- Comprehensive environmental and social safeguards, aligned with EU law (e.g. EIA Directive, Habitats Directive, Birds Directive, Water Framework Directive, Waste Framework Directive). 3- Explicit requirements on GHG emissions, water, waste, and biodiversity. 4- Clear human and Indigenous Peoples rights protections, including Free, Prior and Informed Consent. 5- Transparent grievance mechanisms, aligned with UNGP effectiveness criteria General environmental and circularity provisions are also insufficient. Questions on air, water, and waste remain vague and lack requests for quantitative data or concrete commitments. Projects are not required to present GHG reduction plans, quantify expected emissions, or demonstrate circularity measures such as closed-loop systems and recovery efficiency. Extractive waste minimisation, alignment with the waste hierarchy and land rehabilitation are insufficiently addressed. The template should require: - Specific circularity measures (e.g., recovery rates, closed-loop recycling, material efficiency) - Precise quantitative environmental indicators - Detailed plans for land use, rehabilitation, and extractive waste minimisation. Finally, the application process is neither standardised nor transparent. Leaving excessive discretion to project promoters risks inconsistent applications and misuse of the Strategic Project label. Making all Strategic Project applications, evaluations, and supporting environmental and social documentation publicly accessible would not only enhance accountability but also benefit EU institutions, Member States, research bodies, civil society, and responsible investors by enabling independent scrutiny, informed decision-making, and effective monitoring of CRMA implementation. To strengthen credibility, the template should: - Include more structured fields with clear, measurable requirements - Require that all supporting environmental and social documentation be publicly accessible. The template includes a section on consultation of Indigenous Peoples but does not require demonstration of Free Prior and Informed Consent, as recognised in the UN Declaration on the Rights of Indigenous Peoples and ILO Convention 169. This should be a clear and non-negotiable requirement wherever Indigenous Peoples are affected.
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ECOS Warns EU Plastic Rules Risk Widespread Corporate Greenwashing

1 Aug 2025
Topic — New rules for calculating and reporting recycled content in single-use plastic beverage bottles.
Message — The organization calls for replacing the complex fuel-exempt methodology with a proportional attribution system to ensure transparency. They demand that only post-consumer waste is counted to prevent rewarding inefficient production processes.12
Why — This would protect the credibility of environmental standards and ensure a fair market for recyclers.34
Impact — Mechanical recycling businesses face unfair competition and potential job losses under the current proposal.5
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ECOS advocates for energy labels on low-temperature radiators

29 Jul 2025
Topic — The European Commission is developing energy labels for low-temperature heat emitters.
Message — ECOS wants labels showing how radiator size affects efficiency and testing for lower operating temperatures. They also want indicators for noise levels and the total environmental impact of materials used.12
Why — Implementing these standards strengthens their influence in promoting environmentally friendly heating technology across Europe.3
Impact — Manufacturers of inefficient equipment will face market pressure as the worst performers are penalized.4
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ECOS demands green public procurement for heavy industry

8 Jul 2025
Topic — The Industrial Decarbonisation Accelerator Act aims to speed up the transition of energy-intensive industries.
Message — ECOS suggests using public procurement to create lead markets for green materials. They want to end price-only bidding and move toward performance-based industrial standards.123
Why — Strict environmental standards would increase the organization's influence over industrial manufacturing rules.4
Impact — Producers of high-carbon materials lose their competitive edge in price-focused public tenders.5
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ECOS urges faster phase-out of free industrial carbon allowances

8 Jul 2025
Topic — The consultation reviews policies for the EU emissions trading system through 2026.
Message — ECOS urges ending free carbon allowances to ensure heavy polluters pay for their emissions. They propose moving to a cement-based benchmark to encourage using cleaner alternative materials.12
Why — Removing subsidies would drive industry adoption of the environmental technical standards ECOS promotes.3
Impact — Energy-intensive industries would lose financial profits generated through the overallocation of free credits.4
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Cleantech for Europe and

7 Jul 2025 · Letter with 16 signatories for European Competitiveness Fund to deliver climate and energy security for EU citizens and SMEs

ECOS Demands Stricter Disclosure Rules for Unsold Products

2 Jul 2025
Topic — EU proposal on reporting requirements for companies that discard unsold consumer products.
Message — ECOS calls for granular reporting using 4-digit codes and mandatory verification for all covered companies. They demand specific details on waste treatment destinations and clear links in sustainability reports. Prevention plans must include budgets and KPIs to avoid empty promises.12
Why — This provides environmental groups with credible data to push for future destruction bans.3
Impact — Large retailers would face increased costs for auditing and complex supply chain tracking.4
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Meeting with Jessika Roswall (Commissioner) and

1 Jul 2025 · Circular and toxic-free plastic

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and European Environmental Bureau and

30 Jun 2025 · Simplification agenda, EPR and waste prevention in WEEE

ECOS Calls for Bioeconomy Strategy to Respect Planetary Boundaries

23 Jun 2025
Topic — The EU is developing a strategy for a circular, regenerative and competitive bioeconomy.
Message — ECOS requests a strategy that fosters regenerative systems and nature restoration. They propose circular business models to reduce primary material extraction and support ecological farming and forestry.123
Why — This would align industrial policy with the organization's core environmental and sustainability goals.4
Impact — Intensive biomass extraction industries would see their current business models restricted by circularity.5
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Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur)

19 Jun 2025 · Public procurement

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

10 Jun 2025 · Standardisation request for cement under the Construction Products Regulation

Response to European Affordable Housing Plan

4 Jun 2025

Feedback in attachment.
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

14 May 2025 · Decarbonizing construction

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and European Environmental Bureau and Reuse and Recycling European Union Social Enterprises

12 May 2025 · Circular Economy

Response to Correcting act of Commission Regulation (EU) 2023/1670 laying down ecodesign requirements for smartphones and tablets

8 May 2025

In the corrective act, the European Commission states that (3) Annex II to Regulation (EU) 2023/1670 establishes different disassembly requirements for various parts of the product. There is an error regarding the requirements for the replacement of the display assembly, which was erroneously included in two separate sections of the requirements. For clarity and consistency this error in parts A, B and D, section 1.1, point (5), of that Annex, needs to be rectified. As a result, in the annex to the corrective act, the Commission suggests the following amendments: Part A, section 1.1 (mobile phones other than smartphones), part B, section 1.1 (smartphones), and part D, section 1.1 (tablets), are corrected as follows: (b) in point (5) point (b) is replaced by the following: (b) From 20 June 2025, manufacturers, importers or authorised representatives shall ensure that the process for replacement of parts [available for both professional repairers and end-users], with the exception of the battery or batteries and the display assembly, meet the following criteria: (i) fasteners shall be removable, resupplied or reusable; (ii) the process for replacement shall be feasible with no tool, a tool or set of tools that is supplied with the product or spare part, or basic tools; (iii) the process for replacement shall be able to be carried out in a use environment; (iv) the process for replacement shall be able to be carried out by a layman. The display assembly has been added to the exemption, meaning that its disassembly requirements correspond to what is requested in (b) point (5) point (a) of the same articles. This means that the display assembly would be covered by disassembly requirements which are less stringent than those of the other spare parts listed in point 1(c), even though it is a spare part that is supposed to be accessible by end-users. We understand that this was the intention of the legislator to provide this exemption for display assemblies, but still believe that it would make much more sense to ensure that the process for replacement shall, as a minimum, be able to be carried out in a use environment and by a generalist with supplied/basic tools.
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Meeting with Nikola Minchev (Member of the European Parliament)

24 Apr 2025 · Meeting on EU policies related to the IMCO report on public procurement

Meeting with Martin Hojsík (Member of the European Parliament) and European Environmental Bureau

24 Apr 2025 · Housing situation in Europe

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and European Youth Forum and

23 Apr 2025 · Environmental action

Meeting with Delara Burkhardt (Member of the European Parliament, Rapporteur) and European Environmental Bureau and Bureau Européen des Unions de Consommateurs

16 Apr 2025 · Green Claims

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Alliance for Low-Carbon Cement and Concrete

16 Apr 2025 · Lead markets for cement and concrete products in CID and IDAA

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

1 Apr 2025 · Standardization of Heat Pumps

ECOS warns against watering down EU Taxonomy pollution rules

26 Mar 2025
Topic — This consultation reviews amendments to simplify reporting for the EU Taxonomy Delegated Acts.
Message — The group requests maintaining current chemical safety criteria to prevent toxic pollution. They argue that reducing oversight would encourage companies to replace one hazardous substance with another.12
Why — Keeping original requirements protects human health while ensuring investments align with green goals.34
Impact — Citizens and the environment face increased exposure to persistent toxins like forever chemicals.56
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Meeting with Pierre Jouvet (Member of the European Parliament, Shadow rapporteur)

26 Mar 2025 · marchés publics

Meeting with Giorgio Gori (Member of the European Parliament)

21 Mar 2025 · Presentation and overview of activities

Response to Persistent organic pollutants - PBDEs

18 Mar 2025

ECOS supports the EC draft delegated act amending the Annex I of the POPs Regulation to set the Unintentional Trace Contaminant (UTC) limit for the sum of the PBDEs, while recommending a fast timeline for lower limits for childrens products and toys and an accelerated lower limit for other products made of recycled materials. We urge the timely adoption of this proposal to ensure that the updated decreased limit for toys and childrens products is applied as soon as possible. In the Annexes, on points (b), we recommend a more accelerated decreasing content limit. The EU must take a comprehensive and holistic approach to hazardous substances in recycled materials, utilising every mechanism to prevent their use and limit potential exposures. While this consultation is not addressing enforcement of chemicals regulations, we also note that regulation and enforcement of e-commerce sites must be improved as its been shown by ECHA and MS enforcement actions that products are frequently not in compliance with regulations like the Toy Safety Directive, POPs, RoHS, and REACH. Please see attached document for more details.
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Response to Evaluation of the Public Procurement Directives

7 Mar 2025

ECOS (Environmental Coalition on Standards) welcomes the initiative of the European Commission to evaluate the Public Procurement Directives. Attached our feedback looking back at the implementation of the Directives in four key areas, as well as our most recent study (performed by Ramboll) on green public procurement in the construction sector.
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and

13 Feb 2025 · Clean Industrial Deal

Meeting with Majdouline Sbai (Member of the European Parliament, Rapporteur)

12 Feb 2025 · Révision du règlement Détergents

Meeting with Katharina Knapton-Vierlich (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

11 Feb 2025 · Exchange of views on the implementation of the construction products regulation (CPR) and the links of this policy with other related EU initiatives.

ECOS demands mandatory reporting for national nature restoration plans

7 Feb 2025
Topic — The Commission is standardising the format for Member States to report nature restoration plans.
Message — ECOS wants optional reporting fields made mandatory and demands specific data on ecosystem connectivity. They suggest the template should distinguish between conservation and production forests and include detailed funding entries.12
Why — Standardized data helps the organisation monitor compliance and pressure governments to meet environmental targets.3
Impact — Member States face increased administrative burdens and transparency requirements that reveal restoration shortcomings.4
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Meeting with Delara Burkhardt (Member of the European Parliament)

4 Feb 2025 · Ecodesign

Meeting with Benedetta Scuderi (Member of the European Parliament)

27 Jan 2025 · Buildings/ Labelling/Steel

ECOS calls for sustainable products in Single Market Strategy

23 Jan 2025
Topic — The EU is consulting on the further development of its Single Market Strategy.
Message — ECOS advocates for the Single Market to prioritize sustainable products and circular business models. They request ambitious ecodesign requirements and inclusive technical standards that reflect societal interests. Furthermore, they call for stricter surveillance of online marketplaces.123
Why — More transparent standardisation would increase their influence over technical environmental requirements.4
Impact — Online marketplaces would face new legal liabilities for third-party sellers' non-compliant products.5
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ECOS calls for cement benchmark to boost low-carbon industry

3 Jan 2025
Topic — The consultation updates rules for adjusting free emission allowance allocations based on activity levels.
Message — ECOS advocates for a targeted revision of the Free Allocation Rules to introduce a cement benchmark. They argue this would stop penalising companies for reducing clinker output and support innovative low-carbon technologies.12
Why — A cement benchmark would create a level playing field for the low-carbon technologies ECOS represents.3
Impact — Traditional cement producers would lose financial incentives for maintaining high-clinker production levels.4
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Response to Standards for wireless recharging, electric road system and vehicle-to grid-communication of recharging infrastructure

20 Dec 2024

ECOS welcomes the proposal for a Delegated Act requiring EV chargers to implement EN ISO 15118-20:2022 from 2027. It sends a clear signal to manufacturers to equip their products with bidirectional communication capabilities and other ISO 15118-20 features facilitating smart charging. We have three concrete concerns regarding the proposed text: Firstly, we want to caution against explicitly mentioning the possibility of delaying the 2027 implementation date. The explanatory memorandum states that the Commission may delay the mandatory implementation of EN ISO 15118-20 when the testing standards are not ready. While we agree that these standards are key to implementing ISO 15118-20 correctly, referring to potential delays creates confusion among manufacturers, and may annul a sense of urgency. We recommend the Commission to remove this sentence and to press standardisers to speed up the development of the testing standards. Secondly, we want to highlight the risk of citing specific editions of standards in legislation. The standards will evolve to solve issues previous versions have not solved yet. Legislation will need an update to mandate the latest version. This takes time, during which the legislation enforces outdated standards. Therefore, we recommend considering mandating all newer editions that offer backward compatibility with the standards in the legislation. Thirdly, it may be more beneficial to require EV chargers equipped on private premises to correctly document which ISO 15118-20 features they offer, rather than requiring all private chargers to be ISO 15118-20 compliant. The product claims should be checked by market surveillance authorities. This will avoid products falsely claiming the implementation of ISO 15118-20. Furthermore, we want to highlight that smooth EV grid integration requires the implementation of EN ISO 15118-20 by car manufacturers too. We appreciate Recital 20 calling on EV OEMs to upgrade their cars to EN ISO 15118-20. To this end, the dedicated Commission services responsible for car regulation should propose legislation ensuring EN ISO 15118-20 implementation so that EVs can become an asset instead of a burden to the grid. Car OEMs have privileged access to certain data or parameters needed to unlock important ISO 15118 features through their over-the-air interface. These interfaces need internet access, which is not always guaranteed, e.g. in underground parking spaces. Furthermore, the interfaces are not documented nor standardised. OEMs can block EV owners/drivers, third-party operators and chargers from freely accessing data and therefore key smart charging features. To prevent this, it is paramount that OEMs are required to provide the EV owner/driver with the option to enable access to all data or parameters the OEM has access to, if these can be exposed over ISO 15118. It will enable EV owners/drivers to fully benefit from all ISO 15118 features. For instance, the EV owner/driver or third-party can opt for dynamic control mode. If the choice is left to the vehicle, it will mostly choose scheduled mode, giving the vehicle control over the charging process. It grants the OEM leverage over actors such as eMSPs. However, dynamic control enables more nuanced control over the charging process. This is important for managing charging fleets or unlocking advanced smart charging features such as fast response mechanisms for grid services. The choice whether to unlock these features should be up to the EV owner/driver, not the OEM. Given that this is directly linked to EV charging through ISO 15118 it could be considered in scope of AFIR. It would be even more appropriate to tackle the monopoly on certain data access through the access to in-vehicle data legislation. We therefore call on the Commission to resume the process of this important law ensuring that EVs provide in-vehicle configuration options so that the EV owner can decide which optional ISO 15118 features to enable.
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Response to Review of ecodesign and information requirements for external power supplies (EPS)

16 Dec 2024

Please find our feedback in the attachment. Overall, we are very pleased with the direction that you took with this new draft, particularly with the following: • Refinements to definitions related to wireless chargers and requirements on their standby mode power consumption. • More ambitious no-load power consumption, low load efficiency and active efficiency requirements, and clarifications on how these apply to different types of EPS. • Inclusion of common charger/interoperability requirements, clarity on detachable cables and inclusion of wording to justify exemptions. • The inclusion of the common charger logo on the nameplate, packaging and in the instruction manual plus port markings showing max output power and maximum supported power markings on cables.
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Meeting with Ana Vasconcelos (Member of the European Parliament)

12 Dec 2024 · Forest Monitoring Law

ECOS Urges Stricter GHG Limits for Low-Carbon Hydrogen

25 Oct 2024
Topic — The consultation establishes a lifecycle methodology for calculating greenhouse gas savings from low-carbon fuels.
Message — ECOS calls for a stricter, dynamically decreasing emissions threshold for hydrogen to reach 1kg by 2050. They also demand the inclusion of methane leakage and hydrogen’s global warming potential in calculations.12
Why — Stricter rules would prevent low-carbon fuels from diverting investment away from renewable energy alternatives.3
Impact — Hydrogen producers benefit from a lenient threshold that fails to encourage high-standard emissions reduction.4
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ECOS demands iron and phosphorus inclusion in battery recycling targets

18 Oct 2024
Topic — The Commission is defining how to calculate and verify battery recycling efficiency rates.
Message — ECOS requests that iron and phosphorus be included in mandatory recycling efficiency calculations. They want to remove exemptions that allow these materials to be treated as waste.12
Why — Mandatory targets would promote technical innovation in recycling, a key organizational priority.3
Impact — LFP battery manufacturers would lose their current regulatory advantage over other battery chemistries.4
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Meeting with Delara Burkhardt (Member of the European Parliament, Rapporteur)

15 Oct 2024 · Green Claims

Meeting with Sara Matthieu (Member of the European Parliament)

14 Oct 2024 · Update on Ecodesign Regulation

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

3 Oct 2024 · General discussion on heat pumps and Heating and Cooling decarbonisation

Meeting with Delara Burkhardt (Member of the European Parliament)

25 Sept 2024 · Textiles

Meeting with Majdouline Sbai (Member of the European Parliament, Rapporteur)

25 Sept 2024 · Révision du règlement Détergents

ECOS backs battery-based footprint rules to curb SUV dominance

28 May 2024
Topic — Methodology for the calculation and verification of life-cycle carbon footprint for EV batteries.
Message — ECOS supports requirements for battery makers to publicly report the absolute carbon footprint. They approve moving away from calculations that risked promoting bigger batteries in inefficient vehicles. They also advocate for warranties that reflect real-world battery durability.123
Why — This ensures environmental regulations effectively drive down real-world emissions from vehicle batteries.4
Impact — Makers of heavy SUVs lose the benefit of calculations that hide their footprint.5
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Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

Dear madam, sir, Please find attached ECOS' position on the guidance on applying the 'do no significant harm' principle in relation to the disbursement of the Social Climate Fund. ECOS remains available should further clarification be needed.
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ECOS Urges Rejection of Loosened Rules for Manure Fertilisers

17 May 2024
Topic — The consultation addresses amending Annex III rules for manure-derived fertilising materials.
Message — ECOS calls for policymakers to reject the amendment and not to further loosen existing rules. They argue that higher thresholds for manure-derived fertilisers will not improve water quality or reduce pollution. They demand stricter implementation and quality standards for all fertilisers.123
Why — Blocking these changes prevents the weakening of environmental protections and maintains strict limits.45
Impact — Intensive agricultural producers lose the opportunity to increase livestock numbers and nitrogen application.67
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Meeting with Michael Bloss (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

2 May 2024 · Green Industrial Deal

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and European Environmental Bureau and

9 Apr 2024 · European Green Deal and sustainable resource management

Response to Aligning the biodegradability criteria for polymers in EU fertiliisng products to the REACH restriciton on microplastics

5 Apr 2024

ECOS welcomes this opportunity to contribute to the public consultation on the biodegradability criteria for polymers in several different types of products used in the EU. As an Annex III organisation, we have been contributing in standardisation technical working groups at the CEN and ISO levels on plastic biodegradability. Our aim in contributing to this public consultation is ensuring scientific accuracy, alignment with standards, and above all, the reduction of plastics, microplastics, and polymers in the environment. It is imperative that the limits proposed in these amendments provide for the reduction of polymers in the environment. Overall, the proposed delegated regulations should be improved in technical accuracy and specificity. Some assumptions are made that do not necessarily hold up in real world conditions. We find that some requirements are not applied to all products being regulated (toxicity). We also find that some of the pass criteria are too low. Recommendations: improve specificity and references in noted areas, remove assumptions regarding timelines and biodegradation; if something can be proven or referenced, please include a reference, apply toxicity testing to coating agents as well as mulch films, ensure pass criteria align with other regulations and standards. We address specific issues and recommendations in the attached document.
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Response to Recommendation to promote the development of innovative forms of solar energy deployment

1 Apr 2024

ECOS welcomes the Commissions initiative to provide guidance to tackle barriers to the deployment of innovative solar energy. Below we outline specific barriers and potential solutions, providing examples focusing on France. 1 Agri-PV An important difficulty is the lack of planning by local authorities and the farming community. In some countries such as France the legal framework is still being defined and therefore unstable. Various models are explored to involve farmers. Farmers are approached by many developers who offer a wide range of rents for land. Providing support to deal with this is key. Rent control is a solution worth investigating. Furthermore, it is vital that agricultural activity is maintained. Agri-PV can complicate the transfer of farmland to younger farmers because of the high revenue from renting land for solar energy production. The Commission could work on a fair distribution of value between developers, the farming community, local authorities, the owner, the operator, etc. In France, for instance, the implementation of rules and legislation on Agri-PV is complicated due to limited experience. Therefore, few tested practices exist. The wide variety of possible technologies and associated crops and different environments (climate, soil type, etc.) make it harder to generalise. 2 Floating-PV Expertise with floating PV remains limited to date, while biodiversity concerns are not well known, nor documented. The products are complex, which implies risks in terms of product certification, insurance difficulties, and regarding anchoring and deadweight to resist e.g. strong winds. Installation costs are high due to the price of buoys, construction costs, anchoring, loss of yield, etc. Many sites are unsuitable or technically difficult due to dam impoundment or high tidal storage, etc. 3 Transport infrastructure PV Different technologies exist to install PV on transport infrastructure: -Freeway and railroad sides: huge opportunity for development. The concessionary model is the only barrier identified. -Shading systems over roads: a potential difficulty is the accessibility for maintenance. -Ground mounting PV, PV pavements or solar roads: many technical barriers. E.g. in 2016, 1km of solar road was installed in the North of France: - the speed limit was decreased to 70km/h due to the high noise levels - too much dirt due to the moisture of tree leaves - technical issues with joints after 2 years - cracks in the protective layer of the PV cells - fast decrease of performance after a year 4 Building-integrated PV (BI-PV) The biggest difficulty for BI-PV is training installers. It requires expertise in both roof waterproofing and electrical systems. Leakage problems have created fears among insurers, making it difficult for new installers to obtain professional insurance at reasonable prices. Standardisation of training courses could be a solution: short courses for people who have a degree in waterproofing and longer courses including on-site training modules for others. Once the right training has been obtained, insurers should be obliged to insure new installers. Another barrier to BI-PV is the replacement of broken modules. As module sizes have evolved considerably, it is often necessary to change a large part of the installation to fix a broken module or a new module has to be manufactured at a high cost. A third barrier concerns the lower efficiency of these installations due to sub-optimal orientation of the modules and lower yields because of poor ventilation of the modules. Generally, more energy can be generated with optimized PV installation. Overall, BI-PV requires a lot of R&D and has high cost, while delivering less efficient installations. However, a reason to pursue BI-PV is the large urban areas available. 5 Vehicle-integrated PV Even though some proof of concepts exist, the technology does not grant a real short or mid-term return on investment given the scale of the investments needed.
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ECOS demands tougher restrictions on bisphenols in food packaging

8 Mar 2024
Topic — The Commission is consulting on banning bisphenol A in food packaging.
Message — ECOS demands banning all harmful bisphenols, including BPS, in all materials. They call for shorter transition periods and updated testing standards for products.12
Why — Stronger rules would help achieve their vision of toxic-free material cycles.3
Impact — Packaging vendors would lose the ability to sell old stock indefinitely.4
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ECOS demands environmental and circularity standards in energy auctions

1 Mar 2024
Topic — This consultation provides guidance on non-price criteria for Member State renewable energy auctions.
Message — Member States should prioritize carbon footprints and circularity in auction procedures. ECOS advocates for common standards to support the disassembly and reuse of wind turbines. They also recommend rewarding projects that manage supply and demand smartly to avoid grid congestion.12
Why — This would secure a role for ECOS in developing environmental impact standards for wind projects.3
Impact — Developers who do not adhere to circular economy principles would be disadvantaged in auctions.4
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

21 Feb 2024 · Sustainable Built Environment, Beyond GDP, Taxonomy

Meeting with Dino Toljan (Cabinet of Vice-President Maroš Šefčovič)

15 Feb 2024 · Decarbonization of the cement industry

ECOS urges mandatory national planning for EU forest monitoring

7 Feb 2024
Topic — The proposal establishes a framework for regular and timely monitoring of EU forests.
Message — Member States should be required to develop mandatory integrated long-term forest plans. The law must serve as a comprehensive shop for all forest monitoring indicators.12
Why — Enhanced data collection strengthens the case for higher environmental standards and restoration.3
Impact — The bioenergy sector faces reduced wood supply as policies prioritize material use over burning.4
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ECOS urges technology-neutral rules for industrial emission allowances

19 Dec 2023
Topic — Update to European Union rules regarding free emission allowances for heavy industry.
Message — ECOS requests that free emission allowances are allocated based on final products rather than polluting intermediate stages. They argue for a "one product - one benchmark" principle to support recycling and low-carbon technologies.12
Why — The proposal would establish a competitive market for the clean and circular technologies ECOS supports.3
Impact — Highly polluting industries would lose the financial advantage of receiving extra free emission permits.4
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

11 Dec 2023 · Relevant Circular Economy issues

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

7 Dec 2023

ECOS recognizes the Commission's commitment to reducing regulatory burdens while fostering long-term competitiveness. Nevertheless, delaying the implementation of sector-specific standards will not alleviate the reporting burden, making this proposal counterproductive. In the attached document, we outline key counterarguments to the Commissions proposal, emphasizing the importance of maintaining momentum toward sustainable business practices.
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ECOS Demands Tougher Eco-design and Faster Vehicle Recycling Rules

4 Dec 2023
Topic — Revision of EU rules on vehicle recycling, design, and waste management.
Message — ECOS demands a double legal basis to permit stricter national waste laws and tougher eco-design standards. They advocate for faster implementation timelines and including all road vehicles, like motorhomes, in the regulation.123
Why — These changes would ensure more robust environmental protections and high-quality recycling standards.4
Impact — Vehicle manufacturers would face higher production costs and more stringent technical requirements.56
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Response to Interim Evaluation of the Single Market Programme (SMP)

4 Dec 2023

As project beneficiaries, ECOS Environmental Coalition on Standardrs, welcomes the opportunity to provide feedback on the SMP. The SMP is key for the implementation of Union legislation on the proper functioning of the internal market. It is critical to support the participation of underrepresented interests in standardisation and implement Regulation 1025/2012. The SMP has proved effective as it is indispensable for the operation of Annex III organisations; therefore, to ensure adequate working of the European Standardisation System. The SMP needs to secure that environmental stakeholders can effectively contribute to the increasing standardisation needs on environmental matters. The observed increasing trend in funding over the last years must continue. Environmental stakeholders and interests will play a crucial role in shaping the greening of the European economy and the global competitiveness of key value chains based on environmental ambition, and ECOS will facilitate their representation in the European and international standardisation process. Such relevance is recognised in the EU Strategy on Standardisation "The EUs ambitions towards a climate neutral, resilient and circular economy cannot be delivered without European standards on testing methods, management systems or interoperability solutions". The SMP should explore options to provide additional support to balanced representation of environmental stakeholders also in national and international standardisation. Similarly, reinforcing education and capacity building of standardisation experts - particularly within civil society as contributors to standars-making - must be considered. Regarding the operational aspects, ECOS would welcome improvements in the efficiency of the administrative processes to optimize the use of the resources in activities linked to implementation, rather than project management. Elements to be considered include: Longer grants. Yearly actions are highly disruptive in a context of processes that run for longer. What is more, longer actions will significantly reduce the resources dedicated to annual project proposals and annual mid- and final reporting obligations. Simplification of project proposal templates and lighter reporting mechanisms must be considered. Reconsider travel unit costs. Reporting travel costs following the unit costs ratio is an administrative burden for beneficiaries and may bring about losses. We acknowledge the good intentions from the EC on that as a mean to reduce the administrative burden for the grantees. However, we hereby flag the negative impact that this decision is having on our daily operations and on the overall travel and administrative costs. The possibility of reporting actual travel costs for the SMP grants therefore must be considered. Unit cost Vs local regulations: In most countries, unit costs are not eligible under local Generally Accepted Accounting Principles, which require actual costs to give an accurate view of the financial result of an organisation. Applying unit costs on a travel-by-travel level for EU reporting purposes that differ from the actual costs paid by the organisation de facto creates financial deviations. These differences must be accounted for in local accounts as a profit or a loss. When grantees are non-for-profit organisations, such as ECOS, recording such profits/losses in local accounts is inconsistent with their intrinsic organisational nature. Administrative burden: the unit costs ratio for travels represents an additional burden for grantees. In the local accounts we must record actual costs, hence the dual system monitoring requires additional resources in terms of working hours, infrastructure, and process development. Risk of losses: unit rates set up in the EC Decision are objectively lower than the actual travel rates. Meetings are often confirmed 1-2 months in advance, and only booked then.
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Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and Deutsche Umwelthilfe e.V.

16 Nov 2023 · End-of-Life Vehicles Regulation

ECOS urges mandatory EU targets for healthy soil restoration

30 Oct 2023
Topic — This consultation addresses a proposal to monitor and restore European soil health.
Message — ECOS requests legally binding targets for 2030, 2040, and 2050 to ensure healthy soils. They advocate for mandatory national strategies and science-based thresholds for key pollutants.123
Why — Binding targets would empower environmental groups to use legal channels for enforcement.4
Impact — Major stakeholders responsible for soil degradation would face increased accountability and costs.5
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Response to Revision of EU rules on textile labelling

29 Sept 2023

ECOS welcomes the initiative from the Commission to revise the Textile Labelling Regulation (TLR) to introduce specifications for physical and digital labelling of textiles, including sustainability and circularity parameters. EU mandatory legislation is needed and necessary to ensure harmonised, consistent and clear rules to provide robust information on the textile labelling. We welcome the Commissions approach to not only revise the text of the current Regulation, but also build on the upcoming Digital Product Passport. The initiative should be ambitious to boost a clear level playing field and clear robust rules on information to be displayed on the labelling, and more information to be available electronically. It is relevant to strive for an EU-wide alignment of labelling requirements which include clear and robust indications on fibre composition, the origin (made in), presence of allergenic substances and hazardous chemicals, microplastic shedding warning pictogram when the product contains more than 50% synthetic fibres by weight, production year and volumes, care instructions, sizes, durability, warranty, fibre composition revamp.
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Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

28 Sept 2023

It is fundamental to strengthen the role and input of environmental stakeholders in the development of standards. The European Standarisation System (ESS) will only be capable of delivering standards to support a green, digital and resilient EU single market, and that are of global relevance in a timely manner if: - the effective participation of societal stakeholders is ensured at all levels, - a strategic leadership approach is taken by the EC with appropriate control of the ESS, and - standardisation is used in support of democratically agreed environmental ambition, providing market access to clean innovative products and services. Streamline inclusiveness in EU, national and international standardisation EU stakeholder organisations representing societal interests have long requested to reinforce inclusiveness in standardisation at all levels. Our experience shows that, despite a few improvements in recent years, decision-making processes and operations within the ESOs still do not fully solve the issue of underrepresentation of key stakeholders at all levels. Access alone does not guarantee that public interest is considered. Having access is not the same as ensuring effective participation. As both international and national standardisation have a strong impact on the ESS, it is necessary to tackle effective participation at all levels simultaneously: - The lack of systematic facilitation of participation of civil society in NSBs has a fundamental knock-on effect on their representation in EU and international standardisation. - The conditions framing the interplay between EU and international standards must be revisited, which is particularly urgent in the growing number of cases where international standards are adopted as European. Despite the legal obligation to consider the view of societal stakeholders in standards developed internationally, we are not guaranteed participation in international TCs. The standardisation framework must effectively enable environmental stakeholders to contribute their technical knowledge to standardisation efforts at all levels. Standards that serve the environment Standards can influence the deployment of an environmental technology by a first-mover company or determine if GHG emissions are measured reliably. Consequently, standards should act as enablers and not barriers towards environmental ambition. Standards are in growing demand due to the wide sectorial coverage of the ECs standardisation agenda in support of the green transition. For environmental stakeholders to effectively participate in all relevant standardisation work, securing the necessary resources is a must. EC control The control by the EC in adopting harmonised standards should be strengthened to ensure standards are fit for their regulatory purpose. Harmonised standards serve the public interest as a necessary implementation measure. This is particularly relevant in cases where standards become mandatory despite their voluntary nature. For example, under the Construction Products Regulation, groups lacking balanced representation of all interests are tasked with setting legal requirements. This must be urgently corrected. Adequate use of standards ECOS believes that, in democratic systems, regulation is the only appropriate and effective tool to address societal concerns, even though standards are often seen as an easier (and faster) option. It is crucial to maintain ambitious policy goals and the primacy of legislation over voluntary standards in areas of public interest such as the environment. The growing volume of standardisation developments makes it critical to ensure standards are delivered in support of EU legislation, not in replacement. Finally, the Regulation should consider all available options, such as the common technical specifications, and use them systematically when the official standardisation route hinders the development of methodologies vital for policy. See attachment.
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Response to Energy labelling requirements for electronic displays

21 Sept 2023

ECOS, Deutsche Umwelthilfe, IFixIt, and the Coolproducts campaign welcome the publication of the call for evidence for an impact assessment on the review of the eco-design and energy labelling requirements for electronic displays. We strongly support the assessment which has been done of the problems that this review should tackle, particularly concerning the scope of the regulation, the balance of stringency between larger and smaller products, the lack of information to consumers, the room for improvement concerning material efficiency and the limitation of substances of concern. Our feedback to the call for evidence (detailed version attached) contains both relevant information about the way eco-design and energy labelling requirements for electronic displays are currently implemented, as well as recommendations on how to solve the problems identified by the call for evidence. SCOPE In its call for evidence, the Commission expresses the intention to extend the scope of the ecodesign and energy labelling regulations for electronic displays. This extension would consider signage displays. We strongly support this initiative. To maximise the energy and resource savings resulting from this regulation, we encourage the Commission to go further and integrate the following types of electronic displays in the scope: - Integrated displays - Digital photo frames - Professional, broadcast and security displays SCOPE OF ACTORS AND OBLIGATIONS Online platforms and fulfilment service providers play a crucial role in ensuring compliance with environmental and consumer protection regulations for imaging equipment within the EU. Online platforms must check whether there is a liable actor in the EU who guarantees compliance with the environmental requirements of the implementing act on electronic displays. ENERGY EFFICIENCY - Analysis of EPREL test reports suggests the current regulatory approach to set minimum luminance limits for the default TV mode and power testing is being inconsistently applied by manufacturers: - Energy labels fail to empower consumers to make energy conscious purchasing choices - The stringency of the energy label is not uniform across different screen sizes and resolutions, with a tendency to be more accommodating with the higher power demanding technologies - As HDR content is more readily available, particularly because of movie and series streaming services, and as HDR playback consumes more energy, the primary energy class should now include HDR playback. RESOURCE EFFICIENCY - Need to access information on price of spare parts and expected lifetime - Need to improve availability of spare parts - Bundling of spare parts must be limited - The serialisation of spare parts should not result in part pairing practices limiting independent repair - Electronic displays that are parts of other products should be made replaceable (following the principles of article 11 of the new Batteries Regulation) - Electronic displays should have more accessible and replaceable spare parts - The use of halogenated flame retardants and other problematic substances should be banned - Screen panels, external power supplies and remote controls should be standardised to facilitate repair, replacement and decrease cost of these spare parts - Software updates should be available for 10 years minimum - Sustainable materials and recycled content should be used more often for the manufacturing of electronic displays
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ECOS urges EU to prioritize circularity over carbon capture

30 Aug 2023
Topic — This initiative assesses the role of carbon capture technologies in decarbonising the EU economy.
Message — ECOS demands prioritising upstream measures like circularity over carbon capture technologies. CCUS should be limited to strictly residual, hard-to-abate emissions.12
Why — Prioritising upstream solutions promotes ECOS's goals for robust environmental standards and sustainable production.3
Impact — Waste incineration sectors lose CCS support that could create perverse incentives against recycling.4
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ECOS urges ban on offsets in Green Claims Directive

20 Jul 2023
Topic — EU initiative requiring companies to substantiate environmental claims using standard footprint methods.
Message — ECOS calls for a ban on environmental claims involving carbon offsets or hazardous substances. They request standardized methods to prevent verifiers from rubberstamping greenwashing through inconsistent interpretations.123
Why — Stricter rules ensure green marketing promotes sustainable consumption instead of supporting polluting industries.4
Impact — Polluting companies lose the ability to protect their market share through misleading green branding.5
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ECOS urges tougher carbon reporting rules for energy-intensive imports

11 Jul 2023
Topic — The consultation covers reporting obligations during the Carbon Border Adjustment Mechanism's transitional period.
Message — ECOS calls for including indirect emissions for steel, aluminium, and hydrogen to ensure reporting consistency. They also recommend expanding the mechanism's scope to all carbon-intensive goods by 2030.12
Why — A robust CBAM framework helps ECOS promote stricter global environmental standards and industrial accountability.3
Impact — Energy-intensive industries lose the financial advantage of free allowances and face stricter emission accountability.4
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Response to European Critical Raw Materials Act

30 Jun 2023

ECOS calls for a Critical Raw Materials Regulation that is based on circular principles and promotes both sufficiency and resource efficiency. This can be achieved by adopting the following circular strategies, in order of importance: - Rethink and reduce: lower the demand for CRMs by promoting systemic change; - Circular design, repair, and reuse: extend the life of products to keep CRMs in use for longer; - Collect and recycle: focus on the separate collection, reuse, and treatment of CRMs, and invest in high-quality recycling to bring them back into circulation. We urge the European Parliament and Council of the EU to link the text of the Critical Raw Materials Act to an EU wide material footprint reduction target, to focus on waste prevention rather than recycling, and to enhance recycled content. The CRM Regulation should focus on the reuse and recovery of secondary raw materials from products and components, while ensuring that CRM value chains meet strict environmental and social requirements. This will ensure the energy transition is climate-proof, material efficient, and socially just. Please find the full position in the paper attached.
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ECOS urges EU to reach net zero emissions by 2040

22 Jun 2023
Topic — The EU is establishing a new greenhouse gas emission target for 2040.
Message — The EU should aim for net zero emissions by 2040. They want separate targets for removing carbon versus cutting emissions. Finally, they suggest ending free pollution permits for big industries.123
Why — This would accelerate industrial transformation by forcing companies to pay for pollution.4
Impact — Fossil fuel companies and heavy polluters would lose significant financial subsidies.56
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Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

21 Jun 2023 · Stakeholder meeting on WFD revision

ECOS demands strict standards for recycled plastic bottle content

30 May 2023
Topic — Common rules for calculating and reporting recycled plastic content in beverage bottles.
Message — ECOS demands that recycled content only includes post-consumer waste and excludes all recycling losses. They advocate for mandatory third-party audits to verify reporting and ensure market trust. The group also insists on proportional accounting methods to prevent misleading labels on products.123
Why — Stronger rules protect the credibility of recycled content claims and prevent greenwashing.4
Impact — Inefficient recycling technologies lose the ability to use flexible accounting to claim targets.5
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Environmental group ECOS demands aviation removal from EU taxonomy

3 May 2023
Topic — This initiative establishes a classification system for identifying environmentally sustainable economic activities.
Message — ECOS recommends removing aviation activities and strengthening rules for electrical equipment using fluorinated greenhouse gases. They also urge mandatory reporting of whole life carbon for buildings to prevent taxonomy shopping.12
Why — Stricter criteria ensure the taxonomy maintains high environmental integrity and prevents greenwashing.3
Impact — Aviation firms and manufacturers of specific electrical equipment would face exclusion from green funding.4
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ECOS Urges More Ambitious EU Circular Economy Taxonomy Rules

3 May 2023
Topic — This consultation defines economic activities that contribute substantially to the EU circular economy transition.
Message — ECOS requests including textiles and furniture sectors while strengthening recycled content requirements. They advocate for adopting the Platform on Sustainable Finance's higher ambition recommendations.12
Why — Robust criteria would ensure financial investments drive real environmental change rather than greenwashing.3
Impact — Manufacturers of single-use plastics and low-recycled concrete lose access to sustainable finance labels.45
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ECOS Urges Stricter Standards to Prevent Packaging Greenwashing

24 Apr 2023
Topic — The European Commission is reviewing rules to reduce packaging waste and promote reuse.
Message — ECOS calls for a right to use personal containers and expanded bulk sales. They demand specific minimum reuse cycles to prevent single-use items from being rebranded as reusable.123
Why — Stricter definitions prevent companies from evading environmental taxes through deceptive packaging labels.45
Impact — Producers of low-quality plastics would lose the ability to bypass single-use regulations.6
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Response to Waste Electric and Electronic Equipment

27 Mar 2023

ECOS understands the legal context of the Commissions proposal for targeted amendments of the WEEE Directive. But such weakening of EU e-waste rules seems even more a missed opportunity to perform its complete overhaul for PV and all EEEs. It also goes against the EU ambition to recover important materials, including Critical Raw Materials, in line with the EU 2023 CRM Act. We thus welcome the following points to be considered for the directive review. The European 2021 study on WEEE quality standards pointed to the huge environmental, health and social benefits from higher e-waste minimum quality standards at EU level. The WEEE Directive requirements are today outdated, do not reflect the latest technical and scientific progress, and are inconsistently applied across the EU. This calls for an EU WEEE Regulation laying down ambitious minimum quality standards supported by a credible and independent surveillance system. Many EEE products that could be collected for preparing for reuse are actually leaking outside the collection regime. A 2019 case study in Bavaria revealed the damages occurring to reusable products during collection and storage. The EU should provide for waste prevention and preparing for reuse targets of WEEE that are distinct from the existing recycling targets if these issues are to be properly tackled. Requirements should also be adapted to preparing for re-use operators. The Ecodesign article from the WEEE Regulation should be better aligned with the EU objectives of the Ecodesign for Sustainable Products Regulation (ESPR), once this will be adopted. Appropriate measures should especially be allowed for EEE reusability, upgradability, reparability, maintenance, and refurbishment, without exception. Moreover, online marketplaces should be fully liable for the EEE they place on the EU market, as well as WEEE take back and proper treatment. The WEEE Regulation should take stock of the EU Battery Regulation, once adopted. Potential gaps on portable batteries could however hamper the way batteries are treated at the end of their first life or their durability. WEEE legislation should therefore address these gaps and make sure that all waste portable batteries collected undergo preparation for reuse, preparation for repurposing or a recycling process. Minimum common part design requirements should be applied to facilitate these processes. WEEE should be treated as containing hazardous substances or POPs unless it can be proved that levels in the item are below the concentration limits of the POP Regulation. The WEEE Regulation should also be better aligned with latest legislative developments and should include more systematic depollution monitoring processes not only for each step of the process but also for each output fraction likely to contain hazardous substances. 6.3 million tonnes of CO2-equivalent emissions could be saved every year if CENELEC standards for treatment of discarded fridges and freezers were made mandatory across Europe. The WEEE Regulation should use these standards as a baseline and enforce stricter rules. For instance, a more cautious and thorough extraction of refrigerants and foam propellants from old appliances in recovery facilities, as well as stricter transport rules would lead to fewer leaks in transit. WEEE recovery target for photovoltaics is based on weight and reached with glass & aluminium (90% of PV module). Complementary requirements on individual materials should help recover metals, especially CRMs and polymers. Moreover, solar thermal and inverters should be in scope. The WEEE Directive obligations apply to boilers in some EU Member States but not in others. This discrepancy prevents coherent treatment of these products at their end-of-life and the liability of producers to finance their collection, treatment, recovery and environmentally sound disposal. This calls for full harmonisation in the EU and further clarification of of Annex IV.
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Response to Carbon Removal Certification

20 Mar 2023

Having assessed the Proposal for establishing a Union certification framework for carbon removals (CRCF), ECOS would like to highlight some fundamental features we consider highly problematic and that need to be taken into account to ensure the proposed framework is trustworthy and avoids greenwashing. 1. Prioritisation and definitions: a. Removals and emission reductions should be kept separate to maintain the focus on reducing cumulative emissions into the atmosphere, while at the same time enhancing carbon sinks. Reduction of carbon release from a biogenic carbon pool to the atmosphere should be kept out from the definition of carbon removal as in Article 2 of the proposal for Regulation. The proposal identifies 4 types of Carbon Removals which differ in terms of technological maturity and storage potential as well as potential risks and co-benefits. Only those removals complying with the four principles outlined in Tanzer & Ramírez, 2019 should be defined as removals. 2. Governance of the certification process: a. The system should be owned and managed by public authorities with ensured transparency and access to information at each step of the process. Private certification schemes all face the same inherent conflict of interest, whereby the certifier is paid by the certified, which can bias the certification process. In the EU framework, certifiers should be compensated by the authority owning the scheme and operating under strict rules. b. The EC and Member States need to secure adequate administrative, institutional, financial and human resources to ensure the effective implementation of the scheme. Responsibilities should be shared among public bodies for specific processes such as training, accreditation schemes for certifiers, independent quality control, and enforcement of non-compliance. c. The EC responsible for supervising the system at the EU level shall receive annual reports by the certification schemes including information on how the schemes certification operations comply with the standards and how socio-economic risks and conflicts of interest are avoided. 3. Use of the certificates: a. As highlighted in the impact assessment, the duration of carbon removals and the likelihood of carbon reversals are difficult to predict ex-ante. This makes it challenging to guarantee that the activity results in the sequestration of atmospheric CO2 for periods relevant to the mitigation of climate change. Therefore, CRCF should set guardrails on how certificates are used. Importantly, the use of removals certificates to counterbalance companies carbon footprint and substantiate climate neutrality claims should be prohibited to avoid the CRCF incentivising greenwashing. b. The implementation of the carbon removal activities should lead to a positive impact and generate co-benefits, particularly for nature restoration. The use of the term neutral as in article 7 is insufficient. Carbon Removal solutions should have positive impacts on other environmental or social objectives, such as biodiversity, water quality, zero-pollution, circularity, or food security. To this aim, specific environmental and sustainability criteria should be included in each certification scheme. 4. Land-based removals and carbon storage in products: a. These are the most challenging types of storage to quantitatively account for and monitor reliably. A certification framework for products should only include bio-based products with assured longevity (e.g. structural elements in buildings lasting over 100 years). At best, a mixed qualitative/quantitative multicriteria approach could be used which includes ensuring that buildings and their components are long-lasting (durable, reusable at end-of-life), and addressing the impact of forest management and agriculture on biodiversity and soil carbon. In the absence of a robust framework addressing these issues, no carbon credit should be granted to such projects to prevent greenwashing.
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Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau

23 Feb 2023 · Ecodesign for Sustainable Products Regulation

Response to Measures addressing the environmental impact of imaging equipment including consumables

20 Feb 2023

Environmental NGOs including the Right to Repair Europe and Coolproducts campaigns welcome the publication of the call for evidence for an impact assessment on imaging equipment including the Commission's understanding of the problem and possible solutions. We call for the implementation of Option 4 a combination of ecodesign requirements and energy labelling. There is a need for an ambitious Ecodesign and Energy Labelling regulation to address the energy and material efficiency of imaging equipment and their associated consumables. Such a regulation would send a strong signal to manufacturers of other wasteful products: EU institutions can legislate if no concrete action is taken by manufacturers to end these practices. The attached document explains where we observe there is potential for improvement in the Commission's understanding of the problem and possible solutions. In particular, we have: - Highlighted data that was not considered by the call for evidence in the identification of problems that the initiative aims to tackle. - Suggested additional objectives and policy options that must be considered by the Commission in order to avoid loopholes and build futureproof ecodesign requirements
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Meeting with Delara Burkhardt (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

8 Feb 2023 · Textiles

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and industriAll European Trade Union

6 Feb 2023 · packaging waste

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and Seas At Risk

18 Jan 2023 · Green Deal implementation on the fight against microplastic pollution

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Seas At Risk

18 Jan 2023 · Green Deal implementation on the fight against microplastic pollution

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Seas At Risk

18 Jan 2023 · Green Deal implementation on the fight against microplastic pollution

Meeting with Margrete Auken (Member of the European Parliament) and Seas At Risk

13 Jan 2023 · Microplastic in EU law

Meeting with Pär Holmgren (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

11 Jan 2023 · EU Textile Strategy (staff level)

Meeting with David Cormand (Member of the European Parliament, Rapporteur for opinion)

28 Nov 2022 · Ecodesign Regulation

Response to European Critical Raw Materials Act

25 Nov 2022

ECOS welcomes the initiative to establish a European Critical Raw Materials (CRMs) Act. However, this must be based on circular principles and promote both sufficiency and resource-efficiency. This can be achieved by adopting the following circular strategies and measures: 1. Rethink and reduce demand through systemic change, promote access over ownership: o Set an EU-wide material footprint reduction target (incl. CRMs) to reduce overall demand across the economy; o When possible, substitute CRMs in manufacturing processes. o Limit the use of CRMs for non-priority applications and emphasise the use of CRMs for the production of renewable energies, sustainable forms of mobility and technologies that help achieve climate goals, environmental protection and respect for human rights. 2. Reuse: extend product life to keep CRMs longer in use, at the highest level of utility as possible: o Establish minimum recycled content targets of CRMs in key products and components and develop a methodology for the calculation of recycled content of all types of CRM equipment. The methodology should use segregation or a batch-level mass balance approach with proportional allocation (to assess the recovery rate in each product model and batch per manufacturing plant if mixed with raw materials). This method should then be homogeneously applied throughout the EU, to allow for comparable accounting, relying on third party certification to ensure trustworthy claims. o Set strong circular design requirements to ensure good performance and durability, reusability and repairability of CRM equipment and components, thus extending product lifetime and keeping CRMs longer in use. This requires prioritising reuse over repurposing and remanufacturing over recycling; a ban on single-use products containing CRMs (e.g. portable batteries); the introduction of mandatory second-life assessment requirements for CRM equipment and components; minimum design requirements so that components containing CRMs can be easily accessed/disassembled for reuse or recycling. 3. Recycle: invest in high-quality recycling to bring CRMs back into circulation: o Establish binding targets for the final recycling of specific CRMs from different (post-consumer) waste streams. o End-of-life products and infrastructure containing CRMs (e.g. e-waste and renewable energy infrastructure), manufacturing scrap and materials (e.g. black mass from batteries) should be kept in the EU for high-quality recycling. o The collection and separation of CRM products and components respectively should also be improved to concentrate fractions of CRM-rich products into larger quantities to enable the economic viability of recycling. The collection of CRM-rich equipment could be stimulated through deposit-return systems or similar financial incentives. o Furthermore, cost-effective methods to disassemble WEEE, isolate CRM bearing components, and upgrade/concentrate CRMs should be scaled up for industrial adoption. o Create market incentives to spur the economic viability of recovering CRMs and to stimulate the use of recovered CRMs in new products. Regulatory and non-regulatory actions should focus on the reuse and recovery of secondary raw materials from products and components, while CRM value chains have to meet strict environmental and social requirements. To safeguard from supply disruptions, a mandatory, legal requirement to reuse and recycle CRMs in selected e-waste categories detailed in this paper is needed. This way, the energy transition will not only be climate-proof, but also material-efficient and socially just. More details about ECOS position are included in the position paper attached.
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

28 Oct 2022

ECOS welcomes the evaluation of the WEEE Directive to overhaul e-waste rules in the EU and put an end to the e-waste tsunami. 2019 data showed that 24 out of 27 member states failed to collect sufficient WEEE separately and did not reach the EU target of 65% collection. Up to 4.8 million tonnes of WEEE are still improperly disposed of every year and lost for reuse and recycling. The European 2021 study on quality standards for WEEE treatment pointed to the huge environmental, health and social benefits from higher e-waste minimum quality standards at EU level. The WEEE Directive requirements are today outdated, do not reflect the latest technical and scientific progress, and are inconsistently applied across the EU. This calls for an EU WEEE Regulation laying down ambitious minimum quality standards supported by a credible and independent surveillance system. Many EEE products that could be collected for preparing for reuse are actually leaking outside the collection regime. The EU should provide for waste prevention and preparing for reuse targets of WEEE that are distinct from the existing recycling targets. Requirements should also be adapted to preparing for re-use operators, e.g. through simplified reporting and information access. The Ecodesign article from the WEEE Regulation should be better aligned with the EU objectives of the ESPR. Appropriate measures should especially be allowed for EEE reusability, upgradability, reparability, maintenance, and refurbishment, without exception. Moreover, online marketplaces should be fully liable for the EEE they place on the EU market, as well as WEEE take back and proper treatment. The WEEE Regulation should take stock of the new Battery Regulation. Potential gaps on portable batteries could however hamper the way batteries are treated at the end of their first life or their durability. WEEE legislation should therefore address these gaps and make sure that all waste portable batteries collected undergo preparation for reuse, preparation for repurposing or a recycling process. Minimum common part design requirements should be applied to facilitate these processes. WEEE should be treated as containing hazardous substances or POPs unless it can be proved that levels in the item are below the concentration limits of the POP Regulation. The WEEE Regulation should also be better aligned with latest legislative developments (e.g. POP thresholds and conditions) plus it should include more systematic depollution monitoring processes (not only for each step of the process but also for each output fraction likely to contain hazardous substances). 6.3 million tonnes of CO2-equivalent emissions could be saved every year if CENELEC standards for treatment of discarded fridges and freezers were made mandatory across Europe. The WEEE Regulation should use these standards as a baseline and enforce stricter rules. For instance, a more cautious and thorough extraction of refrigerants and foam propellants from old appliances in recovery facilities, and stricter transport rules would lead to fewer leaks in transit. WEEE recovery target for photovoltaics is based on weight and reached with glass and aluminium (90% of PV module). Complementary requirements on individual materials should help recover metals, especially CRMs such as copper, electrical connections (incl. lead soldering) and polymers (incl. the backsheet containing fluorinated chemicals). Moreover, solar thermal and inverters should be in scope. The WEEE Directive obligations apply to boilers in some EU Member States but not in others. This discrepancy prevents coherent treatment of these products at their end-of-life and the liability of producers to finance their collection, treatment, recovery and environmentally sound disposal. This calls for full harmonisation in the EU and further clarification of Annex IV. ECOS look forward to continuing to play an active role in the stakeholder engagement on this important upcoming revision.
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Meeting with Malte Gallée (Member of the European Parliament, Rapporteur for opinion) and European Environmental Bureau and ClientEarth AISBL

5 Oct 2022 · Empowering consumers for the green transition

ECOS urges tougher repair and energy labels for mobile devices

28 Sept 2022
Topic — New EU rules requiring energy and repairability labels for phones and tablets.
Message — They want the repair index to include spare part prices and longer software updates. They also suggest stricter fastener definitions to ensure devices can be easily reassembled.1234
Why — These rules would validate ECOS's advocacy for mandatory repairability standards for electronics.5
Impact — Manufacturers lose control over proprietary data and must support devices for longer.6
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ECOS urges EU to strengthen smartphone repair and update rules

28 Sept 2022
Topic — EU initiative setting energy efficiency and durability standards for mobile devices.
Message — They demand seven-year spare part availability and software updates for all users. They also seek to ban software practices that prevent independent repairs.12
Why — This allows the group to drive change by embedding strong environmental principles into law.3
Impact — Smartphone manufacturers would face higher costs and more complex design requirements for devices.4
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Meeting with Biljana Borzan (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

9 Sept 2022 · Empowering consumers for the green transition

Response to Regulation correcting energy labelling regulations for air conditioners, displays, light sources, refrigerating products

2 Aug 2022

PDF version of this text attached ECOS Feedback on Energy efficiency labelling – minor changes Air conditioners, displays, lighting and refrigerating appliances 02/08/2022 Annex II, 1(a) – Amendment to Annex II point B Table 3 ECOS supports this amendment that seeks to avoid that, for models with low luminance peak value (<500), the correction factor becomes a negative value and degrades the efficiency index. However, ECOS still questions the bonus given to displays with high luminance as it ends up favouring highest luminance displays, and therefore higher energy use. Annex II, 2(c) – Amendment to Annex III point 2.(a) ECOS is opposed to this amendment as it will allow manufacturers and retailers to decrease even more the size of the labels displayed. It means even less visibility and impact for the consumers. At present the provision reads as a tolerated reduction of the size (area) of the label to no less than 60%. The amendment would tolerate in fact even more since the width and height could be reduced to 60%, meaning a division by 3 of the label area (0.6 x 0.6 = 0.36). Screens of all sizes, even small, can perfectly show a normal-sized label, or perhaps slightly reduced, but a division by 3 of the size should not be supported.   Annex II, 3(a) – Amendment to Annex VI Table 5, rows 24 and 26 This change seeks to have a consistent approach with the Ecodesign Regulation about what parameters should be measured or not measured. However, knowing the values of the peak luminance and luminance ratio for all products for all products put on the EU market could be useful. Indeed, this could help detect potential future issues or loopholes in the regulation.
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ECOS urges EU to accelerate phase-out of climate-damaging F-gases

27 Jun 2022
Topic — The European Commission is reviewing rules to further reduce fluorinated greenhouse gas emissions.
Message — The organization urges accelerating the HFC phase-down according to the maximum technical feasibility. They suggest a blanket ban on all new HFC-based equipment by 2030.123
Why — Mandating natural refrigerants would help the organization fulfill its mission of establishing robust environmental standards.4
Impact — Incumbent chemical companies would lose significant windfall profits from the current HFC quota system.5
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Meeting with David Cormand (Member of the European Parliament, Rapporteur for opinion)

27 Jun 2022 · Ecodesign Regulation and Empowering consumers in the Green Transition

Response to Type approval of motor vehicles regarding access to in-vehicle generated data

21 Jun 2022

ECOS welcomes the Commission’s initiative to further regulate access to vehicle data. This is key to avoid vendor lock-in while Europe transitions to electrified mobility and to facilitate services such as smart charging needed for the electricity grid to handle the rise of electric vehicles (EVs). We support policy Option 3 as presented in the Call for Evidence since this option sets governance rules on how data should be shared, in addition to essential aspects of Option 1 and Option 2. Guaranteeing equal, non-discriminatory access and transparency as proposed by Option 1 is important from the perspective of the EV user, in the spirit of the General Data Protection Regulation (GDPR) and to prevent vendor lock-in. A minimum list of vehicle data, functions and resources should always be made available by the OEM, as foreseen by Option 2, especially over the on-board diagnostic port. This is necessary to enable robust automotive after-market solutions through a well-defined machine-to-machine interface. Exposing the same data and functions only over the human-machine interface de-facto prevents automation of important tasks - such as EV battery or cabin preconditioning, e-mobility service provider (EMSP) certificate installation and vehicle-to-grid (V2G) grid parameter configuration for PV self-consumption. It also prevents integration with other systems such as a customer energy management system, fleet management system, charging station reservation and trip planning. In addition to requiring access to a dedicated list of data, Option 3 foresees explicit governance rules on how access is provided. This is essential since the automotive industry has a bad track record ensuring a level playing field for car services or equal, non-discriminatory access and transparency. Furthermore, Option 3 could enforce the usage of a single well-defined machine-to-machine interface to speed up the deployment of EV specific in-vehicle data and function access. We would especially like to see a strong role for the existing on-board diagnostic port (OBD). It can guarantee long term stability of the interface, rapid deployment in the market, a high level of privacy and cybersecurity due to the need of physical in-vehicle access. The existing OBD port is also completely independent of the cloud-based backend systems, which are becoming a potential single point of failure or a source of premature product obsolescence. The OBD port is a pragmatic and very stable technology, which can be enhanced quickly to meet many of the strategic goals related to the access to vehicle data, functions and resources. To rapidly implement the necessary features, the existing European OBD standards (based on ISO 15031, ISO 14229) should be expanded at the EU level to at least include the necessary data points and functions as identified by the European Commission Sustainable Transport Forum Expert Group on Governance & Standards Activity 1 report. A non-exhaustive list of data points is provided below. -Detailed energy consumption and charging records -Fine grained control of (smart) charging settings -Switching or (de)installation of charging (payment) certificates -Configured grid code settings of the on-board charger -Selection and configuration of user charging preferences according to the specific options enabled by the standards (e.g. ISO 15118) -Controllability of battery preconditioning (e.g. to cool battery prior to arriving at fast charger) -Detailed information about the present energy consumption of the driving vehicle, to allow more precise predictions about suitable recharging locations -Access to the car’s location information (GPS) -Charging history (when, where, how much,...) An additional aspect includes access to EV cabin preconditioning, for instance, to align the cooling or heating with PV production. These functions are essential for smart charging and the efficient integration of EVs into the grid and should be supported by data access
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Response to Empowering the consumer for the green transition

28 May 2022

ECOS welcomes the European Commission’s proposal on strengthening the role of consumers in the green transition, notably the ban on unsubstantiated generic claims, new information requirements on product durability and repairability, and stronger regulation of labels and information tools. However, the choice to amend existing policies rather than creating a new framework, as well as the very wording of the amendments show less ambition than originally foreseen. Between the Inception Impact Assessment and the Impact Assessment, the definition of options has been significantly modified. The most ambitious option presented in the IIA, a new stand-alone consumer protection instrument, which was favored by stakeholders over amending existing legislation, has disappeared without justification. The proposal also fails to ensure its mission as a safety net, leaving too much to be tackled by initiatives not yet adopted. For example, access to information on repairability will depend on the potential release of a legislative proposal on the right to repair, which is not even clearly mentioned in the proposal. If it is not released, no binding access to repair information will be provided to consumers. Similarly, Empowering Consumers leaves specific claims out of its scope, while they were supposed to be partially addressed in the original project as mentioned in the IA. The proposal assumes that the initiative on Substantiating Green Claims will regulate these, but as it is expected to only cover specific claims that can be assessed through the PEF method, many other types of specific claims are left out, e.g. on biodiversity; circularity or end of life of products (reusability, recycled-content, biodegradability); plastic (‘not plastic’ bio-based products, edible plastics). Moreover, climate neutrality claims should be banned in all instances, even when substantiated, as such claims only make scientific sense at global or state level. The proposal should be stronger when regulating claims on future environmental performance, with a detailed definition of ‘clear, objective and verifiable commitments and targets’ and of independent monitoring systems and schemes, which should be pre-approved by authorities to prevent companies from pretending to reduce their emissions when they are not. Currently the definitions have no substance and are open to interpretation. As regards the problem of nontransparent or incredible labels and digital information tools, the IA fails to assess how introducing a pre-approval of labels and tools could ease regulators’ difficulties to conduct retroactive assessments as these tools multiply in time. As the IA never explains what the pre-approval option does, it concludes that it offers the same benefits as the preferred option but at a higher cost, which we strongly disagree with. The proposed definition of ‘top environmental performance’ in Art.2 of the Unfair Commercial Practices Directive should add ‘such as a class A in accordance with the Energy label.’ to avoid a looser interpretation. Using commercial guarantees as a proxy on durability is an appropriate horizontal measure. However, the Commission should still investigate more reliable ways to assess durability (e.g. usage counter), at least for a selection of relevant products such as household appliances. Amendments only suggest banning the omission of information on early obsolescence practices and stop short from actually banning these practices. As these practices will have to be identified anyway to allow the proper implementation of the suggested amendments, bans should be provided. Finally, we agree with the problem definition as far as it relates to environmental sustainability, but we regret that social sustainability has been set aside.
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Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur) and The European Consumer Voice in Standardisation

6 May 2022 · Amendment to the Standardisation Regulation

Response to Review of ecodesign and information requirements for external power supplies (EPS)

4 May 2022

Following the consultation forum (CF) meeting held on 31st March 2022, in which the Commission presented a new approach to review the Ecodesign regulation on External Power Supplies (EPS), ECOS would like to provide the Commission with our comments. Limits of “Back-to-back evaluation” procedure: We support a faster process but urge the Commission to improve on the proposed approach to ensure that there are sufficient opportunities for stakeholder comments to be considered. It is essential that the work is organised in such a way that allows for the necessary depth and breadth of technical analysis that is customary in a review study. Neglect of some technical aspects: Based on the CF proposals, there is a risk that important technical improvements to the EPS Ecodesign regulation are neglected: • New efficiency requirements at different loads: Due to the Common Charger initiative, EPS may be used at a wide range of loading levels. Therefore, it is important to revise Ecodesign energy efficiency rules to include a 10% load efficiency requirement. Current US Department of Energy (DOE)’s work shows that further savings are also possible through tightening the efficiency requirements, or efficiency requirements could be specified at each of the loading points without averaging them. • Wireless charging efficiency: The Commission’s current proposal to leave wireless charging under the remit of the Radio Equipment Directive would fail to address wireless charging efficiency. It would be a huge oversight not to address this in the current review. • Extending scope: Scope should be extended to maximise savings by including high power EPS, active power over Ethernet injectors, and external power supplies used with a wide range of radio equipment. Need for additional consumer information: This is necessary beyond USB PD availability, so that consumers have clarity on the capabilities of their common cables and EPS units. For more detail on each of these points, please consult the short PDF attached.
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Meeting with Alice Kuhnke (Member of the European Parliament) and European Environmental Bureau and Ellen MacArthur Foundation

7 Apr 2022 · EU Textile Strategy (staff level)

Response to Ecodesign requirements for vacuum cleaners (review)

5 Apr 2022

ECOS (Environmental Coalition on Standards) and the EEB (European Environmental Bureau) are relieved to see the revision of these regulations moving forward again after lengthy delays, and we welcome the considered options to extend the scope, reintroduce energy labels, and introduce ambitious requirements for material efficiency and lifetime of vacuum cleaners. Ambitious Ecodesign requirements combined with clear and relevant information through Energy Labels are crucial to harness the savings potential of vacuum cleaners. - Scope. We support the option to include battery-operated and robot vacuum cleaners into the scope of the regulations. We have been calling for this throughout the review process and are pleased to see it as a main policy option to be considered in the impact assessment. We are convinced that the assessment will show the considerable and easy-to-obtain environmental benefits to be gained with this option. In view of the scope extension, we want to stress that battery-operated and main powered vacuum cleaners should be evaluated to the same standards to ensure a level playing field. - Energy labelling. We also strongly support the reintroduction of energy labels. The annulment of the energy label for vacuum cleaners was deeply concerning from an environmental point of view and has meant a grave loss of opportunity for energy savings and subsequent climate mitigation. In our view, the reintroduced labels should include information on the product’s energy efficiency (energy class, annual energy consumption) and service capacity (max. usable volume, battery run time) as well as information directing consumers to more durable and repairable products, e.g. through repairability score and warranty period. - Material efficiency and lifetime requirements. We also view very positively the considered option to address material efficiency aspects and lifetime through the introduction of specific requirements. Spare parts are pivotal for resource efficiency, and therefore we urge the Commission to introduce ambitious requirements ensuring their availability and that they can be ordered unbundled. Spare parts for vacuum cleaners should be available from the day that the product is placed on the market, and remain available for 8 years, with a maximum delivery time of one week. Furthermore, as the general rule, access to spare parts should be granted to end-users, not just professional repairers. Finally, the list of spare parts should include all relevant commonly failing parts (see our position from 2019 for our recommended list). Regulations should also set requirements for ease of non-destructive disassembly, not only ease of dismantling. Another important aspect of material efficiency is the materials and the substances they contain. As vacuum cleaners contain large amounts of plastic, mandatory minimum recycled content for plastic parts should be introduced, or - as an intermediate first step - at least an obligation to provide information on recycled content. Vacuum cleaners should also be subject to mandatory marking of plastics and additives, to facilitate recycling. Ecodesign should also be used to regulate the use of hazardous substances in products, notably with regard the use of flame retardants in plastic. A positive example was given by the French EPR scheme, which provides a bonus for vacuum cleaners without flame retardants hampering recycling. We welcome the consideration of requirements on minimum lifetime, particularly on battery-operated vacuum cleaners. It is essential that these requirements set in a precise way battery lifetime in charge cycles and depth of charge/discharge, but also the rate of charging and discharging, and that this information is shown as an additional icon on the energy label. Taking these numerous aspects into account, we urge the Commission to create and assess a policy option consisting of a set of ambitious material efficiency requirements.
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Response to Promoting sustainability in consumer after-sales

5 Apr 2022

ECOS, welcomes the Commission’s initiative to directly address repair and reuse in the context of sustainable consumption of goods. Considering that e-waste is one of the fastest growing waste streams in the world, and that the amount of household appliances failing within 5 years of purchase is skyrocketing, this is an area that requires urgent and focused policy attention. To date, EU policy related to the Right to Repair has been limited to i) the consumer rights for faulty products to be repaired during the legal guarantee covered within EU contract laws, and ii) some product-specific ecodesign regulations (for products to be able to be sold on the European market) which require the availability of spare parts for a specified time period, plus provision of disassembly information. Although reparability is also considered in some voluntary instruments such as the EU Green Public Procurement criteria or the EU Ecolabel, by their nature voluntary measures are insufficient to establish a genuine right to repair. Together with the Right to Repair (R2R) Europe campaign we emphasize universal right to repair: to ensure that all parties can collaborate to make the EU a thriving market for repair. Horizontal measures are necessary, that are applicable across all categories of electric and electronic goods and preferably even beyond (furniture, textiles, clothing). These need to be compulsory across the board and very clearly specified in order that they have an impact on the market. They must also address the right to repair beyond the warranty period, secure the right for consumers (and other parties such as volunteers in community repair initiatives) to repair products themselves. The current policy options are very vague in terms of the requirements that would be specified and how they would be implemented, and are significantly lacking in scope and ambition. See our comments on the specific policy options proposed in the attached document.
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Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

5 Apr 2022

ECOS supports improvements on good governance principles in the European Standardisation System (ESS). While progress has been made on stakeholder participation and inclusiveness by some European Standardisation Organisation (ESOs) since the adoption of Regulation (EU) No 1025/2012, under-represented stakeholders still face limitations. Effective participation remains challenging, notably in national and international standardisation. The text of the proposed amendment rightly refers to the need for balanced participation of stakeholders in standardisation, e.g.: • “when the European standardisation organisations should focus on supporting EU legislation and policies, safeguards are needed to ensure sound procedure and a balanced representation of stakeholders’ interests, in line with the strategic priorities and legislative needs” • “the internal governance of the European standardisation organisations must duly take into account the views of all European stakeholders (including small and medium enterprises and civil society organisations). This is even more pertinent given that some European standardisation organisations are mainly composed by economic operators who have voting rights and the participation of civil society organisations and public authorities is limited in some cases.” Regrettably, the proposed modification to Article 1 does not sufficiently reinforce the push for National Standardisation Bodies (NSBs) to “encourage and facilitate the participation of stakeholders” as already foreseen in Regulation (EU) No 1025/2012. ECOS would therefore propose an addition to the revised Article 1, as follows: 2a. Each European standardisation organisation shall ensure that the following decisions concerning European standards and European standardisation deliverables referred to in paragraph 1 are taken exclusively by representatives of the national standardisation bodies – having facilitated participation in and consensus on those decisions among all interested national stakeholders - within the competent decision-making body of that organisation: (…) We acknowledge the central role of NSBs in standards-making, which must actively ensure societal stakeholder participation - this is not yet the case. Proactive support by national governments, NSBs, international bodies and the European Commission is needed to ensure societal stakeholders enjoy the same access as industry, to get involved in standardisation decision-making processes, and have a voice when standards are developed in public interest areas, including under the ISO London Declaration.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

ECOS welcomes the European Commission's proposal to revise the Energy Performance of Buildings Directive (EPBD), including the addition of many essential elements to improve the energy efficiency and energy performance of buildings. These include common Minimum Energy Performance Standards (MEPS) and increased criteria as part of Energy Performance Certificates (EPC). Still, there is consensus that the ambition of these measures needs to be strengthened to support the achievement of EU climate law targets and to become Paris aligned. To deliver a 1.5-degree future, the EU needs to enact a steep decarbonisation trajectory that leaves residual emissions and achieves climate neutrality by 2030 at the latest. This underlines the need for urgent action on WLC in the built environment, and this is exacerbated by a proposed delay to the next EPBD update to 2027, meaning a potential wait until 2030 for more robust measures on decarbonisation to be introduced, plus delays regarding entry into force, and impact. To limit global warming to 2 degrees, a 50% decrease in Whole Life Carbon (WLC) by 2030 is necessary . Of this 50%, at least a 40% reduction in embodied carbon is required, a significant portion of which will have to come from reducing the impacts of construction products used for construction and energy renovations. Addressing the WLC of renovation will avoid a '2-steps forward, 1-step back' approach to decarbonisation with the benefits of avoiding an embodied energy and carbon cost of renovation of up to 30% . ECOS commends the proposed expansion of the EPBD to assume its role as the central EU policy for building sustainability to address the built environment's carbon emissions. Integrating embodied carbon from construction products to complete the Whole Life Carbon (WLC) picture is essential. However, in response to the proposed legislation, ECOS would like to highlight several specific issues that should be addressed in the finalisation of the EPBD revision that can be found in the attached file containing full details of our feedback.
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Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

23 Mar 2022 · Views of group of civil society organisations regarding the EU strategy for sustainable textiles

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders) and European Environmental Bureau and

22 Mar 2022 · Corporate Sustainability Due Diligence

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

22 Mar 2022 · Circular Economy and EU Strategy on Textiles

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and

10 Mar 2022 · Sustainable Textile Strategy

Response to Ecodesign requirements for water pumps (review)

18 Feb 2022

ECOS, the EEB & the Coolproducts campaign welcome the revision of the Ecodesign Regulation for water pumps. Pumps within the scope of the preparatory study consume 225 TWh/year and can save up to 48 TWh/ year more. Regulating the energy use of this product is key for improving energy efficiency and reaching the EU’s climate and energy policy objectives. The current delay in adopting this review is leading to 3.2Mt annual CO2 savings lost by 2030 and 14.8 billion € savings lost for end users. Concretely, we urge the Commission to assess the following in the Impact Assessment: 1. We welcome the intention to include horizontal multistage and booster-sets into the scope. However, we regret that the inclusion of wastewater pumps and swimming pool pumps is not considered. This could at least save 0.51 TWh/year. At the very minimum information requirements should be set to inform a future review of the regulation. o Regarding swimming pool pumps we believe regulatory measures are needed since these are often oversized using 10% more energy than needed. Correctly sizing these pumps could approx. save 0.58 TWh/year (in addition to the 0.51 TWh/year). A labelling scheme could help consumers buy the correct size of pump, and can promote the use of Variable Speed Drives (VSD). A label can promote the design of more efficient pumps and systems by classifying which swimming pool size the pump is designed for. Industry has formed a Working Group to develop harmonised methodologies for calculating energy efficiency that could be the basis of a Voluntary Agreement. Since we have no experience VA’s bringing about energy savings we urge the Commission to regulate swimming pool pumps instead o Regarding wastewater pumps, the argument that a harmonised methodology to quantify their efficiency has not been developed should not be used to oppose regulation. Instead, a standardisation request should be issued to develop a method that can support regulatory measures. Furthermore, the reasoning that wastewater pump subcategories do not represent significant savings is not a sufficient argument since overall savings should be considered 2. We regret the exclusion of self-priming water pumps that generally perform less efficiently. Since some pumps currently covered have self-priming functions this creates a potential loophole 3. The preparatory study has not considered pumps designed to comply with hygienic requirements like for the food & beverages industry. This should be addressed since it could create a loophole as manufacturers could declare their products are designed for this purpose 4. The exemptions in pumps size, type and fluid type should be kept at a minimum. Precise description and declaration of exempt pumps are necessary 5. We believe the energy efficiency levels – MEI – set in 2012 should be strengthened by setting 2 tiers: Tier 1 at MEI ≥0,70 in 2023 and Tier 2 for constant flow pumps at MEI ≥0,09 in 2025 6. We support the potential introduction of the Extended Product Approach if the motor and VSD products continue to comply with all requirements set in their respective Ecodesign Regulations 7. Since only 50% of pump systems benefit from a VSD we believe these should be only required when needed, so no material is wasted 8. We support an Energy Label for pump units since this could promote pumps with VSD and facilitate market surveillance 9. To facilitate reuse and recycling marking of permanent magnet motors containing rare earth magnets above a certain minimum weight (e.g. >10g) should be required as these are critical materials at risk of supply shortage. Information on location and extraction process should be given, and requirements set to make extraction easier (e.g. no glue or welding hampering extraction) 10. We urge the Commission to seriously consider a requirement for spare part availability of 15 years after the last unit has been placed on the market to ensure efficient repair and longer lifetimes of pumps
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Response to Energy labelling requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans [review]

18 Feb 2022

The adoption of reviewed regulation for this product group is already heavily delayed. With this consultation we are relieved to see the process finally moving forward and we expect the Commission to make sure any further delays in the final steps of the review are strictly avoided. We welcome the ambition to ensure comparability of similar products and the introduction of requirements for comfort fans, but we regret the absence of a reference to F-gases. With regards to the policy options to be considered in the impact assessment, we especially welcome the explicit intent to assess solutions addressing the problem of lacking comparability between different types of air conditioners. For way too long, inefficient portable air conditioners have been given an unfair advantage and consumers have been misled by confusing separate labels. That is why we are supporting a common energy label. We are also pleased to see the mentioning of introducing minimum requirements for comfort fans and means to address material efficiency. In accordance with what is stated as the likely impact, we are also convinced that any increase in product purchase cost resulting from improved product quality and performance can be absorbed by savings on energy cost during the product lifetime. However, policy options should also tackle refrigerants. Leakage of high-GWP refrigerants, from all stages of the product lifetime, have a non-negligible impact on global warming and must be tackled for this product group. We are disappointed to see that the policy options listed for the impact assessment contain no actions to this end. The review clause of the 2012 Regulation clearly specified that an approach to promote the use of low-global warming potential (low GWP) refrigerants should be assessed. Tackling F-gases in the ecodesign regulation would provide a clear market signal to support and accelerate the implementation of the F-Gas Regulation, which is lagging especially in this sector. As part of policy options, we therefore urge the Commission to consider measures that steer the market away from high-GWP refrigerants, and as such strengthen and speed up the effect of the F-gas Regulation. Low-GWP and natural refrigerants-based air-to-air conditioners and heat pumps are available but their uptake will be considerably slower without further incentives. Our proposed measure in this context is the introduction of a malus scheme on the relevant products’ energy efficiency requirements to penalise appliances using refrigerants with a GWP in the high end of what is allowed on the market (e.g. GWP > 150). This can be completed with pictograms and clear consumer information about climate detrimental impact of high-GWP refrigerants on products that contain them. Given the extreme urgency of the climate crisis, regulators must take every opportunity for ambitious climate mitigation. Therefore, it is our opinion that the impact assessment must include a policy option 6 that represents the highest possible ambition, with regards to mitigating climate and environmental impact of these products. A highly ambitious scenario is the only type of policy option that the European Union should adopt if it is to respect the Paris Agreement. These comments are submitted on behalf of ECOS, EEB and the Coolproducts campaign. As an annex to this comment we are attaching a joint paper on the contribution of these products to climate change.
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Response to Energy labelling requirements for household tumble dryers [review]

18 Feb 2022

We welcome the review of the regulations for tumble driers. We are particularly pleased to see the explicit focus on material efficiency requirements in the considered policy options. However, we are missing an approach to the problem of high-GWP refrigerants – an issue that is listed as an outcome of the study but left without a proposed action. We would also like to see ecodesign requirements being utilised to tackle microplastic pollution. Finally, we urge the Commission to allocate the necessary resources to ensure no further delays on this product group, as well as others currently undergoing or pending review. Considering that tumble driers are luxury products rather than essentials, there is little reason to allow environmentally mediocre products on the market. Therefore, all environmental requirements should be set very ambitiously. We support the proposal in the preparatory study to set ecodesign requirements that effectively removes heating element driers from the market. Heat pump driers are now more cost effective over the long term and far more energy efficient than heating element driers. There is no longer a case for allowing heating element driers to be sold. Furthermore, it is our opinion that an energy efficiency requirement of an EEI not higher than 80 is necessary and feasible. We also believe that a second tier for condensation efficiency requirements should be introduced after two years, to further drive improvement and prevent backsliding. We ask for this ambitious policy option to be considered in the impact assessment. The presence of high-GWP refrigerants in tumble driers is listed as an issue raised by the preparatory study, and the possibility of pulling the market towards better alternatives by providing the information to consumers is mentioned as a possible initiative. In the section “Likely impact” of this call, the transition to environmentally better refrigerants is also mentioned as an expected contributor to a decreased climate impact of tumble driers. However, there is no mention in policy options of any concrete measures that will ensure this transition. It is our opinion that Ecodesign and Energy Labelling regulations for products containing refrigerants, including tumble driers, can be used to compliment the F-gas regulation and speed up the phase-down of fluorinated greenhouse gases. Organic refrigerants with low-GWP such as R290 have been shown to provide effectiveness equivalent to traditional high-GWP refrigerants such as R134a. Information requirements that encourage consumers to purchase products with environmentally friendly refrigerants, as mentioned in the study outcomes, can be complimented by a malus system on the energy efficiency requirements where products containing high-GWP refrigerants are penalised. We want to see this policy option included in the impact assessment. Lastly, the environmental issue of microplastics pollution appears to be omitted in the planned impact assessment. For Europe, the estimated range for microplastics generated from the washing and tumble drying of synthetic clothing is 18,430—46,175 tonnes per year, the third most important source of primary microplastics. We regret to see that nothing is included in the policy options to address this. Ecodesign requirements could be introduced to limit pollution. We ask that the impact assessment explores such a policy option. As an annex to this comment we are attaching a paper by ECOS and their partners providing more background to our asks.
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Meeting with Alice Kuhnke (Member of the European Parliament) and European Environmental Bureau and Ellen MacArthur Foundation

3 Feb 2022 · EU Textile Strategy (staff level)

Response to Review of ecodesign requirements for standby and off mode electric power consumption

27 Jan 2022

EU Ecodesign Regulations for off, standby, and networked standby modes have represented major achievements in mitigating energy waste when first introduced. However, we regret that the review of the instrument has failed to keep up with market developments, and that the proposed update to the requirements comes half a decade later than planned. While the technology evolution that has taken place since the regulation was first introduced offers indisputable potential for setting much stricter requirements, the proposed regulatory text fails to capture latest market developments and runs the risk of having no effect on the market whatsoever. Moreover, the text contains a number of potential loopholes which we call to be tackled prior to adoption. Our comments are outlined in greater detail in the position paper attached, co-singed by ECOS, the EEB and the membership of the Coolproducts campaign.
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Response to Measures to reduce microplastic pollution

18 Jan 2022

ECOS welcomes the initiative from the Commission to reduce the presence in the environment of unintentionally released microplastics. Microplastics release and accumulation are ramping up at a dramatic scale, and the EU should take significant steps to address and stop this stream of plastic pollution with mandatory regulatory actions. Rightly so, the document recognises that “the environmental, health and economic grounds for action are (…) clear” and “it is likely that without EU action, the problem would worsen”. We agree that “voluntary approaches are limited and have achieved little to no reduction so far” and have proven to be largely insufficient to address the issue. Decades of scientific research on the negative impacts of microplastics are more than enough to justify ambitious and legally binding policy measures at EU level to fight microplastics pollution at source. Microplastics are pervasive, chronic, persistent, transboundary pollutants with proven harmful impacts on environment, biodiversity, and public health. The EU needs to give full effect to the prevention and precautionary principles and take as a legal basis the principles of the environmental policy (articles 191 to 1932 of the Treaty of the Functioning of the European Union). The initiative proposed by the EC should be more ambitious to boost a reduction at source. Prevention and upstream/reduction at source are the fundamental strategies to stop microplastics pollution and should be further reinforced, rather than focus on damage control measures. An integrated regulatory approach - including changes in product design, production processes, and/or practices at supply chain level - is needed with complementary measures across all responsible sectors. This is why we recommend an EU wide approach tackling all the different sources of microplastics. Overcoming plastic pollution means tackling both macro- and microplastic with mandatory measures across all sources. Other primary and secondary microplastics to be addressed are: microplastic pollution from the breakdown of plastic used in agriculture; geotextiles, paints (including marine paints) and road markings; medical (covid) waste and face masks; artificial tuft, microplastic-contaminated wastewater, including its use on agricultural fields, etc. Moreover, ECOS recommends that the initiative provides: •A harmonized definition of microplastics with the REACH restriction, where aspects like no lower limit, the inclusion of (bio)degradable polymers and of water-soluble and liquid polymers should be included. •EU source specific emission reduction targets with clear mandatory timeline. •Measures to address the toxicity of microplastics’ additives, also increasing transparency and traceability on products, materials, and ingredients. •The environmental costs of microplastic pollution needs to be accounted for and included in the price. More stringent measures such as introducing compulsory environmental risk assessment for all products containing plastics requiring mitigating actions obliging producers to contribute proportionally to tackle the microplastics issue (including via extended producer responsibility). •Evaluate and consider the environmental cost of microplastics in all compartments. The roadmap needs to recognize and consider negative externalities, including costs related to air quality, environment/marine pollution, and public health, food security, etc. •Ultimately, to effectively decrease the risk and impact linked with microplastic pollution on the environment, the volume of plastic production needs to be reduced. Please find further recommendations for specific sources of microplastics in the document attached. ECOS looks forward to continuing to play an active role in the stakeholder engagement around this important upcoming initiative.
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards

Response to Common chargers for mobile phones and similar devices

18 Nov 2021

ECOS welcomes the common charger initiative unveiled by the European Commission on 23 September. With an estimated half a billion chargers shipped for portable devices in Europe each year, the initiative to reduce consumer inconvenience and easily avoidable e-waste caused by the prevalence of different, incompatible chargers is, we believe, both necessary and much overdue. Smartphone chargers alone generate some 11,000 to 13,000 tonnes of e-waste each year in the EU, with the associated lice cycle emissions of around 600-900 kilotonnes of CO2 equivalent. If we add chargers for other portable products such as laptop computers, this number easily triples and goes up to well over 35,000 tonnes of e-waste per year, equivalent to nearly 100 thousand cars in weight. These huge impacts are not unavoidable, however. Our estimates show that a well-designed and fully implemented common charger initiative - tackling electronic devices, chargers and cables together - has the potential to result in savings of around 29,000 tonnes of e-waste per year, which weighs as much as over 70 International Space Stations put together. It would also reduce the associated greenhouse gas emissions by over 1,800 kilotonnes of CO2 equivalent, corresponding to some 1 million cars being taken off our roads. While providing a solid basis for regulatory discussions, the proposed revision of the Radio Equipment Directive, in our view, falls short of achieving its full potential. Notably, we call on the following changes to be made to the proposed regulatory text of the Radio Equipment Directive: • Introduce minimum wireless charging interoperability requirements; • Extend the scope to e-readers, low-powered laptops and earbuds; • Make unbundled charger, cable and device sales the default option; • Improve consumer information on charging plugs and cables; • Ensure that the harmonisation of fast charging technology delivers; • Shorten the period prior to the entry into force of requirements. The attached paper outlines the proposed set of improvements to the tabled revision in greater detail.
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Response to Environmental impact of photovoltaic modules, inverters and systems - Energy Labelling

28 Oct 2021

ECOS, EEB and the Coolproducts and Right to Repair campaigns welcome this initiative. It is necessary to address the environmental impacts of solar energy production while supporting the uptake of this key technology to reach the EU climate objectives. We consider a revised version of Option 6 most appropriate: stringent ecodesign requirements and GPP criteria, combined with an Ecolabel instead of an Energy Label. We call for stringent mandatory Ecodesign requirements. This is the most effective tool to lower the environmental impact from PV production processes and extend the qualitative lifetime of PV installations. The following minimum and information requirements are key: 1. Ecodesign requirements must enhance durability for PV modules to generate high yields for as long as possible. This should include a requirement on withstanding UV exposure and a threshold for lifetime performance degradation. Default values should be reviewed every 5 years as the quality of modules increases. In line with the expected lifetime of PV modules, documentation should remain available to national authorities for 30 years after being placed on the market. To improve their quality, the warranty of PV modules should rely on an insurance contract mentioned on the product warranty notice 2. Ecodesign requirements must enhance repairability by ensuring spare parts are available for at least 30 years. Manufacturers must provide information on how to access and replace spare parts, and on how to safely and effectively repair or replace parts 3. Ecodesign requirements on recyclability must facilitate dismantling and set information requirements on material use. This should include an information requirement on recycled content, a requirement to declare the percentage of materials that could be dismantled for material recovery and a requirement to recover critical raw materials from components that are not covered by the WEEE recycling objective. All relevant raw materials should be declared and localised, regardless of the amount contained in the product. Due to the usefulness for recyclers, aluminium content should also be declared 4. To address the carbon footprint of solar energy an LCA based “ecological profile” approach is key. We urge the Commission to investigate the inclusion of the following LCA criteria: a minimum threshold for GWP excluding the most polluting products and a metric for the energy payback time that indicates how long it will take to generate the same amount of energy that was used to produce the module 5. PV inverters must be smart ready for them to perform grid services using a common and open communication protocol To effectively implement the Ecodesign requirements proper harmonised standards must be developed and cited accordingly. While less relevant for the policy options under consideration we’d like to stress the need for a 2nd hand market. Given the short replacement cycles of PV equipment (e.g. at solar farms) modules that function well are replaced early by a new ones with higher energy yields. Instead of being recycled or landfilled these panels could have a 2nd life, e.g. in the residential sector. While we support the ‘pull’ role of the mandatory energy label, in this case we believe the Ecolabel is a better fit to encourage the uptake of PV modules and systems with a lower environmental impact. We encourage the Commission to assess whether an energy label risks reinforcing the wrong idea that PV panels consume more energy than they produce. A standard PV installation would be class D. This can deter citizens from even investing in clean energy production. Moreover, preliminary proposals for an energy label focus on the energy yield and durability aspects. Since there is already a clear evolution towards higher yields we believe that the main purpose of a label should be to differentiate products on aspects as carbon footprint, repairability or recyclability. Our detailed position is attached.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

Please find attached ECOS' response to this roadmap. Summary: ECOS welcomes the European Commission’s ambition to apply the waste hierarchy principles to all types of plastics regardless of the feedstock, thus ensuring that material use is first and foremost reduced to what is necessary, that products are then reusable and recyclable. Our contribution to this consultation focuses on the issues with existing standards. It is essential that standards are developed that are comprehensive in addressing environmental impacts of all forms of plastics, and which support overarching EU objectives. A policy framework based on current voluntary standards will facilitate greenwashing of bio-based, biodegradable and compostable plastics (BBP/BDCP) and will not contribute to better environmental and human health protection from plastic pollution, including the toxic substances they contain. Instead, we support the development of mandatory European minimum requirements for BBP and BDCP to comply with, ensuring that circularity principles prevail over false solutions, and request appropriate review of existing standards.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

19 Oct 2021 · Preparation of the Sustainable Product Policy Initiative and Consumer Empowerment for the Green Transition

Response to Standardisation Strategy

23 Jul 2021

As the representative of the environmental interest in European Standardisation, ECOS sees the Standardisation Strategy as a key opportunity to deliver for the environment by moving towards an inclusive standardisation system in support of high environmental ambition. For this, the Standardisation Strategy must consider: -Concerted proactive action to identify, eliminate or amend standards which are barriers to the deployment of clean technologies, environment-friendly materials or secondary raw materials -Environmentally ambitious Standardisation Requests are essential to make EU the standards maker, achieve geostrategic ambition, and support the EU Green Deal -Commission control in initiating, assessing, managing and monitoring the procedure for the adoption of harmonised standards is crucial -Inclusiveness is work-in-progress and needs continued political push at the national, international and European level, including within the EC On the particular points where feedback is sought, it is ECOS views that: 1)Whether the current EU standardisation system is fit for purpose to support EU strategic interests For EU to be the standards maker, fulfil its geostrategic ambitions and support the EU Green Deal, SRs need to be environmentally ambitious and be used to its fullest potential to frame the standardisation deliverables and how those support environmental policy goals. The Strategy should take a proactive approach to eliminating standards that pose barriers to the deployment of clean technologies and develop standards that enable their uptake. Service standards should be reinforced to set technical requirements for digital services with an increasing environmental impact. 2)How the EU can leverage and promote global leadership in standards-setting While seeking to improve the EU standardisation system, the Strategy must clarify the way it interacts with international and national standardisation. Outsourcing EU standard-setting to international standardisation is growing. However, the conditions for drafting international standards are different from the European, in particular, on the facilitation of effective participation of societal stakeholders. To avoid circumvention of inclusiveness, openness or transparency, the Standardisation Strategy must push for Aarhus-compliant international standardisation. Timing and anticipation of needs are critical for the Commission to act as standard maker. It is crucial to reflect on the strategic dependencies (e.g. raw materials, lead on clean energy, batteries) and move in a timely and proactive manner in terms of regulation and standardisation. The Strategy should serve as a bridge between the implementation of international environmental agreements, trade policy and the use of standards for their implementation which should all support the realisation of the Sustainable Development Goals. Regarding national standardisation, proactive support of societal stakeholders is not systematic across Member States. Ways to improve inclusiveness at national level must be set too. Capacity building on standardisation will be key also to engage societal stakeholders at national level. 3)Whether changes in governance and working methods are required to improve the performance of the EU standardisation system Progress has been made since the adoption of the Standardisation Regulation in 2012 but there is need for further improvement. The Standardisation Strategy should reiterate that harmonised standards are a necessary implementation measure and hence part of the Union law. The control exercised by the Commission along the procedure for the adoption of harmonised standards is key and should be strengthened to ensure standards are fit for the regulatory purpose they serve. Furthermore, the Strategy should encourage that policy-makers use alternative methods to avoid delays in the enforcement of the regulation. See full reference in attachment
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Response to RoHS deleting exemptions for mercury in double-capped linear fluorescent lamps for general lighting purposes

16 Jul 2021

We support the Commission’s proposal to phase out categories 2(a)(1) T2 and 2(a)(4) T12 fluorescent lamps over a period of 12 months. This is in line with the Ecodesign Regulation that already phases out T2 and T12 fluorescent lamps on 1 September 2021 (see e.g. https://eeb.org/publications/60/mercury/100990/eeb_rohs-lamps-letter_dg-environment.pdf). We also support the proposal to phase out category 2(a)(5) for long-life linear fluorescent lamps over 12 months, since LED replacement tubes already have a longer lifetime than fluorescent lamps, LED tubes are widely available at 60,000 – 70,000 hours (sources: https://www.gecurrent.com/products/product-category-filter/2111/sub-cat-group/4446/sub-cat-group/4481/sub-cat-group/4496/operating-life/70%2C000%20hours; https://www.ledvance.com/professional/products/product-stories/led-tubes-online-special; https://www.sylvania-lighting.com/product/en-GB/category/light-sources/led-c/families/led-t8-tubes/toledo-superia-t8-universal/). Regarding the phase-out period for 2(a)(2) T5 and 2(a)(3) T8 linear fluorescent lamps, we call for the Commission to reduce this from 18 months to 12 months, as there are already plenty of direct, drop-in mercury-free LED retrofits available on the market (see e.g. p. 101 and 110 in https://www.clasp.ngo/wp-content/uploads/2021/01/SEA-CLASP-Clarifications-on-Industry-Comments_final.pdf#page=102. Finally, we want to see a fast-tracking of this Delegated Act, moving as quickly as possible to publication in the Official Journal of the European Union, so that the phase-out period of 12 months starts as soon as possible. The on-going delay is costing European citizens and businesses €15-16 million per day (see e.g. https://www.clasp.ngo/wp-content/uploads/2021/02/Quantifying-Lighting-Benefits-under-the-RoHS-Directive.pdf).
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

ECOS welcomes the opportunity to provide feedback on this draft delegated act. Overall, the draft is in line with the overall objective of the taxonomy : promote transparency in the corporate and financial sector, support sectors and economic actors making a substantial contribution to the environment, and prevent greenwashing. For us, it is crucial that the following aspects are kept in the final delegated act : - Disaggregated reporting for every activity and whether the activity is enabling or transitional - Clarity of the reporting templates However, the following needs further improvements: - The treatment of SMEs should be clarified and their inclusion should be earlier. With the current rules, taxonomy-aligned SMEs will not have benefit from a facilitated access to green finance until 2025 as investors would not have to be able to report on those investments under this draft. - The way the aggregated GAR is calculated should be laid down in this act. We call for such aggregation to be made using absolute values rather than ratios (which would in the vast majority of cases automatically inflate CapEx). - Finally and most importantly, the CapEx plan referred to in the draft currently seems to encompass potential future taxonomy alignment. This is very concerning: not only does it open the door to massive greenwashing, it also fails to encourage a fast transition into taxonomy aligned activities as it does not distinguish between invesments into activities not yet environmentally sustainable and those into taxonomy aligned activities. Reporting of taxonomy alignment should only be based on actual alignment, not theoretical one. We urge the Commission to clarify that the extent to which the CapEx plan can be used is to report on multi-annual investments into taxonomy-eligible activities, not into activities which may become aligned in the future.
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Response to Ecodesign and energy labelling working plan 2020-2024

25 May 2021

The ecodesign and energy labelling policies have enabled achieving a quarter of the EU’s emission reduction targets to date and nearly half of the EU’s 2020 energy savings. These policies have the potential to significantly contribute to the Green Deal, bringing important GHG emission reductions but only if they are used to their full capability and level of ambition. This is currently not the case: chronic delays are hampering the successful implementation of this policy, as highlighted by the European Court of Auditors in January 2020 and evidenced by the timing for the adoption of this Working Plan. The plan is supposed to cover the period 2020-2024 but it will probably not be adopted before the end of 2021, with a two-year delay. The measures included in the previous Working Plan (2016-2019) are also delayed, and not a single new implementing measure has been adopted since the Von der Leyen Commission took office 1.5 years ago. Such delays are unacceptable, the Commission should urgently prioritise this file within its services and dedicate adequate human resources to the development of product measures. The climate and environmental emergency must mean that all potential energy, CO2 emission and material savings are reaped as early as possible. The prioritisation exercise between the introduction of new regulations and the reviews of existing regulation proposed in the roadmap is therefore not acceptable and not justifiable by the lack of resources within the Commission to correctly implement the policy. Timely revision of existing regulations is responsibility of the legislator, and so is to assess the adequacy of setting new legal requirements for other products in view of achieving the climate objectives the Commission has committed to. The Working Plan should also clearly set out the timetable for each measure: the current lack of clear timing and prioritisation has led to a substantial accumulation of draft measures which have not been presented or concluded and have significantly stymied the achievement of product policy objectives to date. Regarding the preparatory study for the Working Plan 2020-2024 in particular, we strongly recommend to only consider science-based and objective evidence in the selection process leading to the establishment of a shortlist. The proposed shortlist was developed ‘in a dialogue/in agreement with the European Commission’ (Task 4 report). While we understand the need for some pragmatism, political aspects should not be considered at this preparatory stage; we insist on the importance of transparency and objectivity being main drivers for the technical assessment of the product selection. Looking at the savings potential and the expected development of certain products and technologies, we propose an alternative shortlist, keeping the majority of the products selected by the study team but introducing four crucial product groups that have been discarded despite their environmental relevance: base stations, electric vehicles chargers, universal batteries and heaters for outdoor spaces. Find the reasoning and full alternative shortlist proposal in the position paper attached. Furthermore, we strongly believe that the Working Plan should foresee the development of horizontal material efficiency requirements for a broader set of energy-related products. This should lead to the introduction of repairability requirements for an enlarged set of household electrical appliances, by means of an overarching regulation similarly to the existing one on standby energy consumption – in line with the Commission’s ambition to progressively make sustainable products the norm and the forthcoming Sustainable Products Initiative. Finally, the Working Plan should aim at reinforcing market surveillance to ensure the forecasted savings are achieved. The possibility to extend the use of the EPREL database to products without an energy label could be explored should it prove to facilitate the work of MSAs.
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Meeting with Thierry Breton (Commissioner) and

19 May 2021 · Clean Hydrogen Alliance; Hydrogen Strategy

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The Environmental Coalition on Standards (ECOS) welcomes the expedient revision of the Energy Performance of Buildings Directive (EPBD) and sees it as a major opportunity to effectively drive improvements to the sustainability of buildings in Europe and deliver a major contribution to the EU ‘Fit for 55’ for 2030, and beyond to 2050. This revision represents a unique opportunity to reinforce existing measures and better connect the EPBD to other relevant legislations and policy frameworks and contribute to the achievement of the climate policy goals the EU has set itself. Primarily, the EPBD must support climate policy by revising the outdated 80-95% emissions reduction target to target zero carbon. This revision will also provide timely reinforcement of the Renovation Wave and subsequent Member State Long-Term Renovation Plans (LTRP), which were recently criticised for their lack of compatibility with EU 2050 climate goals. Finally, the revision should aim to deliver on the Sustainable and Smart Mobility Strategy by ensuring sufficient charging stations for electric vehicles (EVs) in buildings. ECOS therefore strongly supports an ambitious revision of the EPBD based on ‘option 3’, complemented by non-regulatory measures proposed under ‘option 2’, an effective combination which is needed to accelerate renovation and tackle environmental impacts of buildings. On the other hand, ECOS believes that the ‘targeted’ proposals detailed within the inception Impact Assessment risk falling short of providing the required structure and ambition needed to achieve decarbonisation of existing building stock. Instead, a comprehensive review of the EPBD is required at this important moment in the evolution of EU building policy. Namely, a review is required that enables the EPBD to evolve from an energy performance only policy to tackle decarbonisation of buildings across its lifecycle while addressing other impacts. Our full feedback can be found in attachment, and ECOS looks forward to engaging with the European Commission further on the review and revision of the Energy Performance of Buildings Directive.
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Response to Technical amendments to the annexes to the Fertilising Products Regulation

16 Mar 2021

ECOS (Environmental Coalition on Standards) and EEB (European Environmental Bureau) welcome the proposed amendments to the Fertilising Products regulation (FPR) that can overall help to improve its applicability. They notably contribute to clarifying the exclusion of materials from mixed municipal waste and widening permitted processing of plant fibres that can substitute peat. We are also satisfied that the total content is maintained for all contaminant measurements, with the small exception of nickel in mineral growing media. Moreover, the adjustment allowing the end point for animal by-products to occur during composting or anaerobic digestion is important to allow their recycling. These strong, harmonised rules are essential to protect the soil. We are nevertheless dubitative about the loosening of tolerance levels of nutrients for inorganic fertilisers, produced in large quantities from relatively homogeneous substrates, whilst those for organic-based products remain sometimes overly strict despite the variability inherent to living matter and biological processes. As for mineral growing media, giving a CE mark to products that must not be added to soil, but are collected by the producers, is a dangerous precedent and unworkable outside a few limited countries. As for polymers, our organisations regret that non-biodegradable polymers are allowed until 2026 under the FPR.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

ECOS welcomes the European Commission’s proposal for a new Regulation on batteries and waste batteries (replacing the current Battery Directive) and is pleased to contribute to the consultation on this matter. Together with other European NGOs, namely the EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany), and Transport & Environment, we have developed a joint paper with our feedback to the Commission’s proposal. Please note that this paper has been submitted by Transport & Environment. In addition, ECOS would also like to highlight the need for technical requirements and specifications listed in the legislative proposal. These will underpin very important provisions such as on performance and durability, reuse and repurposing, as well as safety. The European Commission should ensure a timely and appropriate development of these specifications and the related European Standards. In particular, we urge the European Commission to avoid that a late development of standardisation deliverables comes at the expenses of the effectiveness of the upcoming Battery Regulation, thus hindering the possibility for the European Union to be at the forefront of the sustainable battery industry. We attach our paper on the standardisation needs for sustainable batteries.
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Response to Pyrolysis and gasification materials in EU fertilising products

15 Feb 2021

ECOS comments to the draft STRUBIAS delegated acts N.B. the “Report” refers to the JRC STRUBIAS report of 2019: “Technical proposals for selected new fertilising materials under the Fertilising Products Regulation (Regulation (EU) 2019/1009)” General comments ECOS thanks the JRC for the careful and thorough study of the different materials involved, and regrets it lacked capacity to be involved in the working group or to master the 476 page report. ECOS supports the recycling to soil of materials with true agronomical value and low risk of contaminating soils, in line with JRC’s priorities. ECOS has some reservations about the relevance of the processes involved, which in some cases transform a substrate that can be used on soil directly or after composting or digestion (manure, biowaste, some waste from food processing industries etc.) into a new material which is richer in certain substances but poorer in others, particularly in organic matter. The Report and the draft delegated acts seem to underestimate the importance of organic matter in soils, and indeed limit the amount of organic matter allowed in the component material. Pyrolysis and gasification materials ECOS has reservations about the inclusion of these materials in the fertilising products directive. The process of pyrolysis may produce aromatic compounds (PAH) which may have adverse effects on soil quality. ECOS is not convinced that the category should have been changed from ‘biochar’ which covers a more homogeneous product. However, even this product is the subject of much controversy. Experts disagree about its benefits to soil, with some actors being almost fanatical about it (for recreating “terra preta’) and others pointing out disadvantages. In the case of these materials, the aromatic compounds may be strongly bound to the matrix, so that they may not be measured by analysis. Biochar can help to store carbon in soils in an organic form. Input materials (d) source-separated biowaste: ECOS fails to understand the advantage of submitting biowaste to pyrolysis or gasification, when it could simply be digested and/or composted. Does pyrolysis and gasification count as “aerobic or anaerobic treatment” required by the 2018 Directive amending Directive 2008/98/EC to be applied to biowaste? There seems to be some doubt about the agronomical value of pyrolysis and gasification materials, while there is no doubt about compost and digestate. This point should be checked in order to avoid contradiction. (e) additives: this seems to be a wide group of ingredients. ECOS is concerned about the inclusion of biodegradable polymers, considering their potential risk to human, animal or plant health, to safety or to the environment. The fact that additives may constitute up to 25% of the input material is also worrying. How will the absence of substances of concern be ensured?
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Response to Thermal oxidation materials and derivates in EU fertilising products

15 Feb 2021

ECOS comments to the draft STRUBIAS delegated acts N.B. the “Report” refers to the JRC STRUBIAS report of 2019: “Technical proposals for selected new fertilising materials under the Fertilising Products Regulation (Regulation (EU) 2019/1009)” General comments ECOS thanks the JRC for the careful and thorough study of the different materials involved, and regrets it lacked capacity to be involved in the working group or to master the 476 page report. ECOS supports the recycling to soil of materials with true agronomical value and low risk of contaminating soils, in line with JRC’s priorities. ECOS has some reservations about the relevance of the processes involved, which in some cases transform a substrate that can be used on soil directly or after composting or digestion (manure, biowaste, some waste from food processing industries etc.) into a new material which is richer in certain substances but poorer in others, particularly in organic matter. The Report and the draft delegated acts seem to underestimate the importance of organic matter in soils, and indeed limit the amount of organic matter allowed in the component material. Thermal oxidation materials and derivates Input materials • Sewage sludge is included despite the statement in section 5.2.5 of the Report that sewage sludge ashes contain metals… above the limit values. • In (g) any waste can be an input material with a few exceptions (hazardous waste, mixed municipal waste…). ECOS would prefer a clearer definition of acceptable wastes, since otherwise unsuitable wastes could fall into this category. Not all possible wastes were considered in the Report. • (h) covers auxiliary fuels. There seems to be no definition of “auxiliary”. ECOS is concerned at the inclusion of the ashes of fossil fuels as a fertiliser. Coal ashes notoriously cause severe pollution problems in the USA. It is necessary to define a strict limit for the content of these fuels as inputs, to ensure that their use is no more than a small percentage of the materials used in the thermal oxidation plants. • (I) “substances which are used in production processes of the iron and steel industry” seems too vague; unsuitable substances could be included as input materials. • (j) “substances and mixtures” is an extremely wide category! It is dangerous to be so vague in a legal text. Also, it is unclear why “waste within the meaning of point 1 of Article 3 of Directive 2008/98/EC” is excluded when waste within the meaning of the same Directive is explicitly cited in point (g), which is already included in the exceptions for (j). Point 5: “the thermal oxidation materials shall be ashes or slags”: it is not specified whether the ashes are fly or bottom ashes. In the Report there are several warnings about fly ash: in section 5.4.3.2 it is stated that biomass plant operators typically discard the fly ash fraction due to its high content of metals and other contaminants, and in section 5.4.4.3 the boron toxicity of fly ash is mentioned. In section 5.4.5.1 after table 4 it is stated that “Wood fly ash, the lightest component that accumulates in the flue system, can contain high concentrations of cadmium, copper, chromium, lead and arsenic which is why this ash cannot be used as an EU fertiliser”. But nothing in the draft delegated act excludes wood fly ash. It is also noted that different pollutants tend to be more concentrated in either fly ash or bottom ash, from which we might conclude that by mixing these ashes together the product may pass within the contaminant limits set. This does not seem very satisfactory. Point 7: ECOS strongly supports setting the limit for total chromium, for reasons already set out in discussions about whether CrVI or total Cr should be limited in the FPR. ECOS also supports the other limits.
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Response to EU strategy for sustainable textiles

2 Feb 2021

ECOS welcomes the Commission’s initiative to set out an EU vision for an environmentally sustainable, circular EU textile sector that delivers on EU zero pollution objectives and climate neutrality targets by 2050, and addresses the environmental and social impacts of textiles. The EU has the opportunity to take significant steps towards making textiles truly circular, making sustainable products the norm and inspiring the rest of the world. It is urgent to turn this vision into action since the “important climate and environmental” impacts of the textile sector continue to grow within the current linear system. Below, we set out ECOS views on how the EU Strategy for Textiles can go even further : -The strategy should be more ambitious to boost a shift towards circularity and discourage the EU textiles sector to maintain a linear economy. It needs to better promote upstream solutions. Measures should follow a real circular economy hierarchy, where value retention is prioritised, and where prevention strategies to avoid material consumption in the first place are adequately valued. -The strategy should include the need for an absolute reduction of global textile production and consumption to significantly reduce the overall environmental footprint of the sector. Make sustainable products the norm -In line with the Sustainable Products Policy Initiative, the primary focus must be on removing inefficient, toxic, wasteful and polluting products from the EU market. -Design for durability, reuse and repairability need to be a priority. -Minimum ecodesign requirements are needed to address durability, reusability and recyclability, eliminate hazardous chemicals, providing clarification on the expected lifespan of textile products and tackling microplastics release. -Microplastics release considerations should be incorporated in all main instruments tackling textile products. -The Strategy should extend the right to repair to textile products. -Textiles need a product passport (including, bill of materials and chemicals, environmental and material efficiency information and due diligence). -More sustainable and consumption production patterns are needed. -Ensure environmental claims are relevant, transparent, and reliable: mandatory standardised labelling and claims on sustainable and circular textiles. -Inclusion of the ban on the destruction of textile products. Regulate the use of chemicals in the production process and in final products systematically -The strategy is currently lacking a restriction on the manufacture, marketing, import, and export of textile products containing hazardous substances of concern -Disclosure on chemicals used in finished products and during production processes and ensure their traceability -Specific complementary measures to address textiles specificities, going beyond testing hazardous chemicals within products. Set up EPR schemes for textiles in line with the EU waste hierarchy -EPR schemes for textile products must respect and implement the EU waste hierarchy, not only focusing of the end-of-life stage, with a clear transparent governance. -EPR schemes to be coupled by ambitious re-use & preparing for re-use targets. -EPR fees should be eco-modulated. Ensure coherence and provide a clear direction for change -The EU Strategy for textiles must act as the overarching framework, tying together and reinforcing new and existing legal instruments affecting a textile product and the different impact areas (environmental, social, human rights, etc.), preventing trade-offs and loopholes. -Ensure and enforce sustainable production processes inside and outside the EU is key for a level playing field where EU rules can set the bar, also through trade related initiatives. See the full ECOS response in the attached pdf.
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Response to Environmental impact of mobile phones and tablets - Energy Labelling

27 Jan 2021

We strongly support the planned legislative initiative to reduce the environmental impacts of mobile phones and tablets. With more mobile phones in use globally than the total number of people living on Earth and more than 150 million purchased each year in the EU alone , the climate and environmental footprint of these devices is tremendous. Just the Europe’s stock of 600 million active devices is responsible for some 14 million tonnes of CO2 emissions – more than the annual carbon budget of Latvia . Given that an estimated 72% of their climate impacts are due to manufacturing, distribution and disposal and that EU citizens replace their smartphones on average every 2 to 3 years , business as usual can no longer be sustained and far-reaching measures are needed aimed at extending the useful lifetime of these devices. By ensuring that smartphones and tablets are more durable and easier to reuse, repair and remanufacture, such measures would not only reduce their combined life cycle impacts, but also the amount of e-waste generated as well as precious resources required for their manufacture, including lessening the environmental and social impacts arising from the mining of well over 50 different metals needed to make an average device . It is our view that the best way to ensure that smartphones and tablets are energy efficient, durable, easy to repair and to upgrade is through a combination of minimum ecodesign requirements coupled with consumer information requirements under the Energy Labelling Regulation (option 5 in the inception impact assessment). The dedicated ecodesign regulation should specify requirements for the entry to the European market that ensure minimum levels of repairability, upgradeability, reusability, durability and recyclability of smartphones and tablets, while Energy Labelling should provide relevant and comparable information to consumers that promotes a shift in consumer purchases towards most environmentally friendly options. Since batteries are a key lifetime-limiting component, the new Energy Label should be focused on an A-G score on battery endurance alongside key additional aspects. Most notably and building on the recent policy developments in France that demonstrate the potential for scoring approaches to inform consumers on the reparability and durability of their devices this should include an A-G repairability and durability scores that would be prominently displayed on the same label. Our views on the different policy options considered under the inception impact assessment are presented in the position paper attached.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

ECOS welcomes the initiative to evaluate whether certain aspects of the New Legislative Framework (NLF) remain fit for purpose. We request that ‘environmental organisations’ are also considered as an additional category of stakeholders that will be consulted throughout the evaluation process. As an Annex III organisation under Regulation (EU) No 1025/2012, ECOS represents environmental interests in European standardisation activities and thus, we recognise the need to improve the internal market for goods and to strengthen the conditions for placing products on the EU market. We acknowledge the growing use of standards in EU legislation and their role within the NLF. In this sense, we believe that it is necessary to ensure that standards developed to support EU policy and legislation under the NLF (and beyond) serve the needs of all and that its development should be carefully triggered and observed by legislators and be transparent and as inclusive as possible. Specifically there is a strong need for European Commission’s oversight to the entire process of the preparation of harmonised standards and the publication of their references in the Official Journal of the European Union, as highlighted by the ECJ judgement of the Court in case C-613/14 (James Elliott).
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Response to Sustainable Products Initiative

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 unnecessary, inefficient, toxic, wasteful and polluting products from the EU market, complemented with (and not driven by) better consumer information. In order to design a sustainable products initiative (SPI) that delivers, we urge the European Commission to take the following asks into account: Define and assess ambitious policy options. An ambitious set of legal requirements supported by appropriate technical standards should enhance the design and manufacturing phases of products, and dramatically increase their potential to be reused, repaired and recycled, as well as improve the information to be conveyed to consumers and stakeholders across the value chain. The Commission’s intentions need to materialise into ambitious legislative tools based on comprehensive and clear methodologies to ensure measurability, enforceability and comparability among products and services, but also to address trade-offs between different sustainability parameters. Enlarge the scope of the SPI to all key product groups: include also sectors such as batteries, packaging and construction products to be coherent with the Circular Economy Action Plan and the key value chains it has identified.. All sectors with significant impacts on the environment should be subject to a generic policy that will act as a sustainability and circularity enabler, combined with complementary sector-specific policies when necessary. Build on experience to expand Ecodesign. We welcome the intention to broaden the scope of the Ecodesign Directive to cover a wide range of other sectors, but we call on the Commission to build on the lessons learnt in this process, and not to compromise on any of the elements that have proven successful for energy-related products. At the same time, the issues identified when regulating energy-related products should be effectively tackled, including addressing the frequent regulatory delays, the failure of voluntary agreements, and increasing the resources dedicated to the enforcement of the Regulation at both EU and national levels. Furthermore, particular attention needs to be paid to the improvement of the methodology which is the basis for designing the implementing measures. Get the right measures…right. We support the set of principles and measures put forward by the Commission however, we urge to also include the absence of substances of concern as an overarching requirement into all sectors to be covered because it is currently completely absent from the proposal. In addition, it is fundamental to develop a robust methodology common to all sectors to quantify environmental impacts and identify priority actions across the entire product lifecycle so that worst performers that should be banned from entering the EU market can be directly identified. Furthermore, we believe that measures to address circularity should follow a real circular economy hierarchy where value retention is prioritised, and where prevention strategies to avoid material consumption in the first place are adequately valued. While consumer information is key to complement minimum requirements, provide transparency across the value chain and in some cases pull the market towards better solutions, we believe sustainability labelling should be approached with caution to avoid being an outlet for greenwashing strategies. Ensure effective market surveillance through targeted measures in order to guarantee the full delivery of the expected environmental benefits. (see full ECOS response in attached pdf)
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Response to Energy labelling omnibus amendment of 2019 regulations

3 Nov 2020

ECOS, EEB and members of the Coolproducts campaign fully agree with the need for unequivocal wording and provisions in order to facilitate timely and uniform implementation of the implementing measures and therefore support the intention of the regulator to correct technical errors and improve the accuracy, consistency and cross-referencing across regulatory texts. With the exception of a few technical comments which we highlight in the attached detailed position paper and which we believe should be addressed by the regulator, we are happy to support the adoption of the proposed changes. We note, however, that is important to ensure consistency between Ecodesign and Energy Labelling regulations, and would therefore call for any provision that is changed in the Energy Labelling delegated regulations to be reflected in the corresponding regulation on Ecodesign whenever relevant.
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Response to Ecodesign omnibus amendment of 2019 regulations

3 Nov 2020

ECOS, EEB, iFixit and the members of Coolproducts and Right to Repair campaigns fully agree with the need for unequivocal wording and provisions in order to facilitate timely and uniform implementation of the implementing measures and therefore support the intention of the regulator to correct technical errors and improve the accuracy, consistency and cross-referencing across regulatory texts, including through the consistent inclusion of dedicated anti-circumvention clauses. However, we are concerned to see some of the proposed changes, notably in relation to Ecodesign regulations on displays and lighting products, that go well beyond the rationale outlined above, making amends to the scope of the regulations and putting into question essential requirements previously agreed upon by the Member States after a thorough consultation with all stakeholders. The changes in question do not only set a highly worrying precedent of requirements being reconsidered without a thorough regulatory scrutiny or impact assessment, but also pose risks to the timely adoption and implementation of implementing regulations in the future. In light of this, we invite the regulator to reconsider proposed changes, and only adopt amendments that improve clarity and consistency, as per the proposed recital (9) of the omnibus regulation. Our views on the points in question and concrete suggestions are set out in the detailed position paper attached.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

29 Sept 2020 · Circular economy and resource efficiency in the construction sector, initiatives foreseen in the new CEA.

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

ECOS welcomes the initiative of the European Commission to review the current Renewable Energy Directive 2018/2001 and align it with an increased climate ambition to 2030 as well as with the objectives set out in the Paris Agreement. The Renewable Energy Directive is a key policy tool to drive the European Union towards a zero-emission and fossil-free energy system. To this end, we urge the European Commission to: • Increase the renewable energy target from 32% to at least 45% by 2030 and translate it accordingly into renewable energy sub-targets (electricity, heating and cooling, transport). This is the only way to ensure compatibility with the Paris Agreement objectives and a 65% cut of greenhouse gas (GHG) emissions by 2030, and it should be reflected in the impact assessment. • Imperatively exclude any support (direct or indirect) to fossil and non-renewable energy sources from the focus of the Renewable Energy Directive and its impact assessment. This translates into the need to: o Exclude “low-carbon” energy sources from the focus of the Renewable Energy Directive, including the so-called low-carbon fossil-based hydrogen (i.e. hydrogen produced from fossil sources with sequestration of CO2). Although the Commission already expressed its support for fossil-based hydrogen as a transitional solution in the Energy System Integration and Hydrogen strategies , we believe that by no means this should be included in the Renewable Energy Directive, even if only for a transitional period and in the short- and medium-term. o Consider only renewable and non-fossil energy sources under the heating and cooling sub-target. Heating and cooling represent 12% of the CO2 emissions in Europe and a large-scale switch to appliances powered with renewable energies is critical. o Prioritise direct electrification and enable the integration of flexible loads such as electric vehicles to act as energy storage and support the grid during peak hours. Indirect renewable electrification should only be supported after a thorough assessment on energy efficiency grounds when revising the transport sub-target. Energy carriers such as renewable hydrogen should only be used in those sectors where direct electrification is not possible. As mentioned in the points above, “low-carbon” fuels, including fossil-based hydrogen, should not count against the renewable energy sub-target for transport. • Effectively encourage the use of waste heat (for instance from industry or data centres), and ensure that policy tools aimed at achieving climate-neutral data centres by 2030 are coupled with measures to ensure that they are highly energy efficient and sustainable – at building, hardware and software levels. • Ensure that additional renewable energy production is also included in a new certification system and that GHG emissions are accounted based on the actual potential of recycled carbon fuels to provide substantial GHG reductions, i.e. calculated on the basis of the full chain accounting without the concept of “avoided emissions” and “emissions savings from carbon recycling”. We strongly support the European Commission’s decision to establish a robust system that includes also sustainability criteria and a full life-cycle assessment GHG emissions. These requirements, together with the lack of additionality, are currently not addressed in EU Guarantees of Origin system put in place by the Renewable Energy Directive, which therefore remains a mere chain of custody system and does not offer any incentive to produce more renewable energy. Please find supporting sources in the attached document.
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Response to Review of EU rules on fluorinated greenhouse gases

7 Sept 2020

The F-Gas Regulation is a landmark piece of European Union (EU) climate legislation for transitioning away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). As an environmental civil society organisation, ECOS strongly welcomes the initiative of the European Commission to anticipate the update of the legislation and calls for significant improvements to safeguard our climate system by: • accelerating the HFC phase-down schedule, in particular by adjusting the penultimate step in 2027 to 10% and the final step in 2030 to 5%, in excess of what is required by the Kigali Amendment; • updating antiquated standards to allow for the introduction of safe and energy-efficient climate-friendly refrigerant technologies relying on A3 refrigerants; • evaluating and assessing the environmental impact of hydrofluoro-olefin (HFO) refrigerants in terms of chemical release and chronic toxicity; • requiring mandatory producer responsibility schemes that meet certain minimum requirements to be detailed in the legislation with further rules adopted via implementing or delegated acts; • requiring mandatory training on natural refrigerants and technologies as part of certification programmes; • promoting incentive schemes and public procurement for HFC-free alternatives; • strengthening the placing on the market prohibitions in Annex III for HFC-based equipment, including immediate bans for subsectors that could have already converted to HFC-free alternatives based on natural-refrigerant technologies available a decade ago, as identified in the Impact Assessment, and adopt prospective bans for 2025 and 2030 for the remaining subsectors (including new ones) based on a more recent analysis of natural-refrigerant and low-GWP technologies available today, including in HFC-based room air-conditioning, hydronic heat pumps and condensing units; • introducing bans and containment measures for SF6-based switchgear; and • aligning the revised F-Gas Regulation with the Paris Agreement and evaluate the climate impact of an accelerated EU HFC phase-down and market prohibitions in terms of GWP20 in parallel to the current GWP100 to provide policymakers and the public with an accurate snapshot of the near-term climate benefit of fast action on HFCs. These amendments are needed to improve implementation and attain the climate ambition as set out in the European Green Deal (EGD) and the EU climate neutrality target. Please find a more complete response in the joint position paper attached.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

ECOS supports the provision of environmental information to consumers environmentally relevant, reliable, comparable and verifiable, through the development of an EU legal framework requiring companies to substantiate claims via the Environmental Footprint methods. Having said this, for sustainable products to become the norm in the EU, the primary focus of the regulator must be on removing inefficient, toxic, wasteful and polluting products from the EU market altogether, complemented with, and not driven by, better consumer information (as is the case with the Ecodesign and Energy Labelling frameworks for energy-related products). In the attached document, we provide a set of recommendations to properly design and implement an EU framework on substantiating green claims using the PEF methodology.
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Response to Empowering the consumer for the green transition

26 Aug 2020

ECOS welcomes the Commission’s initiative to empower consumers to play an active role in the green transition. Despite the clear preference of European consumers for more sustainable products, the absence of reliable information deprives from them of the opportunity to make informed purchasing decisions and fails to translate that preference into market demand and potentially market transformation. Therefore, a new dedicated regulatory instrument is of vital importance in order to meet the objectives stipulated in the European Green Deal. Such an instrument should establish new rules and ensure a minimum harmonisation for the mandatory provision of information to consumers on sustainability aspects, while protecting them against environmentally detrimental commercial practices. Having said this, for sustainable products to become the norm in the EU, the primary focus of the regulator must be on removing inefficient, toxic, wasteful and polluting products from the EU market altogether, complemented with, and not driven by, better consumer information (as is the case with the Ecodesign and Energy Labelling frameworks for energy-related products). Our views in relation to the planned legislative initiative are set out in detail in the response attached.
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Response to Review of the Construction Products Regulation

19 Aug 2020

Revising the CPR for sustainability The construction sector has a significant global impact on the environment, including here in Europe. Business-as -usual is no longer an option, but the current regulatory framework is not sustainability-ready. The planned revision of the Construction Product Regulation (CPR) can play an important role in reducing the impact of the sector, but incremental change will not be enough. The revision of the CPR must go beyond enhancements proposed (options D1 and D2): a deeper transformation of the CPR is needed for construction products to enable a more sustainable built environment. Therefore, the CPR should go beyond the options outlined and include ambitious environmental performance requirements, using the successful example of the Ecodesign framework as a basis. The Ecodesign directive has achieved significant results by setting technical specifications to measure, test and verify performance in product-specific regulations, in conjunction with EU harmonized standards to measure, test and verify performance, has achieved significant results. We believe the CPR should be revised and take a similar approach than the Ecodesign directive by: Establishing a range of ambitious mandatory environmental performance requirements, implemented through harmonised technical specifications focused on:  Reuse of construction products, as well as the use of secondary and locally available raw materials for construction products;  Full lifecycle environmental (including CO2) footprint requirements for end-products and intermediaries such as cement and steel to improve resource efficiency, and better contribute to improved energy performance of buildings;  Product take-back and Extended Producer Responsibility (EPR) requirements to transform construction products and associated waste management;  Greater resource efficiency in the design, production and use of construction products and all constituent materials. Requiring on a mandatory basis that comprehensive information on the performance and impacts of a construction product throughout the entire lifecycle is readily available and accurately assessed through updated measurement standards; Adopting an Ecodesign-framework-style implementing process for the development of technical requirements to help lower the environmental impact of construction products. This process should be based upon preparatory work concerning all relevant technical information, involving broad stakeholder consultations with MS representatives, civil society, industry, and other organisations with a relevant interest; Increasing coherence with relevant industrial, chemicals, product and waste policy by ensuring that construction product requirements at the interface between relevant legislation are well aligned. This includes emission limit values under the industrial emissions directive, chemical restrictions under REACH, as well as reduction of construction and demolition waste goals under the Waste Framework Directive. Ambitious, clear and comprehensive regulatory requirements following the positive example of the Ecodesign Directive are needed to regulate construction products at EU level. Implementation through a robust process for developing technical specifications and harmonised standards will be important to deliver upon such requirements, and ultimately to support the commitments under the European Green Deal.
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Response to Sustainable and Smart Mobility Strategy

28 Jul 2020

ECOS welcomes the initiative of the Commission to set out a vision for an environmentally sustainable, zero-emission mobility sector that delivers on Europe’s climate ambition. The urgency of turning this vision into action is demonstrated by the fact that emissions from the transport sector continue to rise, while contributing significantly to microplastics release through tyre abrasion. While greatly reducing GHG emissions compared to fossil-fuel powered transport, the environmental impact of EVs – for instance its batteries (mining of raw materials, carbon footprint, recycling) and tyres (release of microplastics) – is non-negligible. The strategy should be guided by the energy efficiency first principle. This should lead to less and better transport through maximum direct electrification and reduced demand for transport modes whenever more sustainable modes are available. Below we set out ECOS’ views on how the strategy can support the transition to smart electromobility while at the same time tackling its environmental footprint. MODAL SHIFT First and foremost, the aim of this strategy should be to reduce demand for transport and effectively realize a modal shift towards zero-emission mobility, prioritizing the most sustainable modes of transport being walking, cycling and public transport. Passenger cars are ideally shared and only used for essential trips. SMART ELECTRIC MOBILITY Secondly, appropriate transport and energy legislation such as AFID, EPBD and TEN-E, should facilitate the shift to smart electric mobility. This is essential to reduce emissions from public transport as well as from remaining passenger cars and freight. To maintain a stable electricity grid when more sectors switch to direct electrification, Europe should fully capitalise on the potential of EVs to charge during off peak hours while integrating increasing amounts of renewable energy into the grid. Concretely this means essential smart charging standards should be harmonised to support European legislation regulating e-mobility charging infrastructure. INDIRECT ELECTRIFICATION Thirdly, the policy framework should only support indirect electrification after a thorough assessment on energy efficiency grounds. Energy carriers such as renewable hydrogen should only be used in those sectors where direct electrification is not possible. ENVIRONMENTAL IMPACTS OF BATTERIES Fourthly, given the shift to smart electro-mobility it is important to address the environmental impacts of batteries. When assessing the overall environmental footprint of transport activities the mining of raw materials, the carbon footprint of the full battery value chain, as well as reuse and recycling of batteries, should be taken into account. The Strategy should thus create synergies with the upcoming EU legislative framework for sustainable batteries and with the future European standards that can create a sustainable battery value chain in the European Union. ENVIRONMENTAL IMPACTS OF TYRE WEAR Finally, in order to address the release of microplastics through tyre abrasion, a legal threshold for tyre wear should exclude most wearing tyres from the EU market, and this threshold should be raised over time. The new tyre label regulation specifies car and truck tyres need to include information on their abrasion rate by 2025. In order to be effective, these requirements should be supported by appropriate standards. Therefore, a standardisation request should be issued to develop harmonised test methods for the measurement of tyre abrasion as soon as possible and at the latest by 2023.
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Response to Modernising the EU’s batteries legislation

9 Jul 2020

Batteries are an essential product to ensure decarbonisation in the EU and its demand is set to grow substantially in the upcoming years. As an environmental civil society organisation, we strongly welcome the initiative of the European Commission to update the legislation that ensures a circular and sustainable value chain for all batteries produced in the EU and placed on the single market. Together with what already mentioned in the inception impact assessment, we urge the European Commission to: 1. Transform the current legislation into a robust stand-alone EU Regulation for sustainable batteries. 2. Define and harmonise characterisation metrics for batteries to enhance durability and reusability, such as End-of-Life and State of Health. These metrics are used to characterise the batteries as well as for evaluation tests, and as such they are essential to define durability and reusability requirements. 3. Ensure that batteries are removable, replaceable and interoperable within product groups, to allow for a higher material recovery and a longer product lifetime. By no means should these principles affect the durability of the battery, and safety should be addressed at both use and end-of-life phases. 4. Require open battery data to facilitate repair, reuse and recycling. Necessary battery data is needed to allow repair, reuse and recycling, especially in the case of industrial and EV batteries. Appropriate standards or other instruments (such as EU delegated acts) must describe and mandate which data is to be disclosed openly, and in which format. 5. Define minimum design requirements to ease disassembly and recycling. Due to the lack of standardisation, there is variation in the materials used, the design, the location of the battery, and the shape of the battery pack. This makes the recycling of batteries complex and time-consuming. Complete standardisation at module and pack level is both unrealistic and a burden to innovation, given that it restricts design options. A trade-off would be to establish a minimum set of standards for basic components, such for example lifting parts. This would allow standard lifting tools to be used for disassembly. 6. Implement extended producer responsibility (EPR) obligations to address information provision and design requirements for reusability and recyclability. These will need to focus on issues related to Input/output information provision and design requirements for recyclability & reuse as these issues were put to evidence in ECOS’ recent position paper . 7. Propose the adoption by the European Commission of an EU implementing act laying down minimum quality standards for the recycling of Critical Raw Materials (CRMs) from waste batteries in the new battery legislation, within maximum two years. This should be developed in synergy with the EU implementing act on quality standards for WEEE (Waste Electrical and Electronic Equipment), which should include ambitious requirements for the treatment, transport and logistics of WEEE, since most (lithium-ion) batteries are collected together with the WEEE in which they are embedded. These acts should then be complemented by a European standardisation request to develop further standards for CRM recycling. Please find further information in the full position paper attached.
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Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

16 Jun 2020 · European Green Deal, new circular economy action plan and the circular plastics economy

Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

ECOS welcomes the Commission’s initiative to accelerate improvements to the sustainability of Europe’s existing building stock by targeting energy efficiency and associated emissions through the Renovation Wave. In achieving the aim to double the renovation rate of existing building stock1, the Renovation Wave must prioritise net emissions reductions and eliminate energy poverty in Europe to support the aims of the European Green Deal and the Circular Economy Action Plan. Beyond energy efficiency, ECOS believes the Renovation Wave has the potential to drive more circular and resource efficient practices in the sector, as actions under this initiative should also be in line with the Strategy for a Sustainable Built Environment and its circularity objectives. To do so, it is essential to apply circular principles at building and product level when considering options for renovation. Construction products to be used for renovation should be made from low-carbon, sustainable and non-toxic materials, and should be easy to repair and reuse in future. Heating and cooling of buildings under this initiative must also align with decarbonisation and depollution goals, using clean technologies and energy is crucial in doing so. The Renovation Wave therefore presents the opportunity to promote sustainability from a holistic perspective throughout the entire value chain. ECOS would therefore like to highlight the following priorities in the next stages of developing this legislative initiative. The full response of ECOS can be found in attachment.
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Response to A EU hydrogen strategy

8 Jun 2020

ECOS is committed to a clean, renewable and efficient energy system. While we welcome EU efforts to transform the energy sector through a new dedicated EU strategy on hydrogen, we also see the risk of greenwashing hydrogen as a way to allow a continued use of fossil energy. To make the EU Hydrogen Strategy a real solution towards a sustainable climate, the European Commission should take the following recommendations into account: 1. Support renewable energy by prioritising renewable-based hydrogen production. The sustainability of hydrogen highly depends on the energy source it is obtained from. At present, 98% of hydrogen produced globally comes from dirty fossil fuels, such as natural gas and coal. As highlighted in the Roadmap, technologies exist to make hydrogen cleaner, such as renewable hydrogen produced through water electrolysis using renewable electricity. Public support should target renewable-based hydrogen which is currently only a minimum share of the total production. The Clean Hydrogen Alliance and the future legislative and non-legislative measures should focus on making renewable-based hydrogen production the main priority in order for it to be cheaper than its alternative (fossil) production methods by 2030. Fossil fuel-based hydrogen coupled to carbon capture and storage should not be an obstacle to renewable solutions and as should not be promoted. Misleading terminology and definitions on hydrogen (such as colour coding) should be avoided. The European Commission must ensure that definitions are science-based and reflect a life-cycle analysis of associated emissions and environmental impacts. Traceability and certification of hydrogen should be based on a robust system that supports renewable energy solutions through additionality and that is reflected in the upcoming standard on Guarantees of Origin. A chain of custody system that traces hydrogen production should consider the system boundaries where hydrogen is injected. Trade of GOs should take place only among two systems that are interlinked. 2. Channel public support towards hard-to-decarbonise sectors only. Hydrogen should complement renewable energy, energy efficiency and flexibility measures to serve as long-term energy storage for renewables and to help decarbonise sectors that are difficult to electrify. A clear example are energy intensive industries needing high-density energy carriers such as chemicals and cement, as well as steel for which the iron production process that cannot be easily and directly electrified. Hydrogen is not an option for heating in buildings: efficiency rates are poor and H2-methane blending would only lock in the fossil gas grid and compete with the renewables-supplied electrification of heating and with district heating. Similarly, promoting the use of hydrogen in cars and vans plus the accompanying refuelling infrastructure will distract from and compete with the roll-out of charging infrastructure for electric vehicles where direct renewable electrification is more efficient. 3. Do not use hydrogen to justify continued use of fossil fuel or gas grid expansion. It is very unlikely that hydrogen contributes to decarbonisation when it is blended with natural gas, such as methane. While its proponents see it as a way of “greening” the gas sector, fossil natural gas is still used, bringing about indirect and direct emissions (i.e. methane leakage). Hydrogen should be produced following the cleanest non-fossil pathway and should never be used to support a continued use of dirty fossil energy sources, such as natural gas or coal, or to justify expansion of fossil energy infrastructure, such as gas pipelines.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

ECOS supports the Commission’s initiative to review the Alternative Fuel Infrastructure (AFI) Directive 2014/94/EU. Strengthening this policy framework is key for the increase of EVs on European roads, as envisioned by the European Green Deal, to become a reality. Overall, we welcome the objectives and policy options outlined in the Inception Impact Assessment (IIA). Below we outline our views on what measures the upcoming Impact Assessment (IA) should investigate regarding interoperability and network integration of Electric Vehicles (Problem No 3 and 4). To address both Problem No 3 and 4, it is essential that the wide roll-out of public charging infrastructure is equipped with smart charging facilities, notably V2G services. Contrary to what is mentioned in the IIA (Problem No 4), electricity system operators will be able to ensure the integration of EVs by adapting their networks. However, proper management of power supply and demand remains key during peak hours. Therefore, the IA should assess the potential of the deployment of smart charging functionalities for the grid integration of EVs, in order to safeguard a balanced grid and to enable the integration of increased shares of renewable energy. The IA should look into the potential for minimum technical requirements facilitating smart charging and interoperability, which should be supported by appropriate and tested standards. Here it is essential to assess the status of standards currently developed at international level and how their implementation can be facilitated. The IA should thus assess how the European Commission can act to, firstly, boost the finalisation of these international standards and secondly, ensure the standards developed are fit for purpose at European level by issuing a standardisation request to the relevant European standardisation bodies. ECOS explicitly supports the 3rd objective laid out in the IIA to foresee adequate information for consumers. The IA should investigate the potential of requirements for all EV manufacturers to provide enough open documentation and access to the cars charging control (for example via an onboard diagnostics interface). This would enable EV users to fully exploit the potential of smart charging, for instance to facilitate the integration of the EV into a home energy management system, even when EV manufacturers are not able or willing to support emerging technical smart charging standards. Concretely, ECOS recommends the IA analyses the following measures to strengthen the deployment of charging infrastructures in the EU: 1. The deployment of smart charging functionalities in public infrastructure for the grid integration of EVs. Concretely, the potential for minimum technical requirements facilitating smart charging and interoperability supported by appropriate and tested standards should be assessed. More information can be found in our accompanying EV Smart Charging Briefing. 2. Requirements for all EV manufacturers to provide sufficient open documentation and access to the cars’ charging control. More information can be found in our accompanying EV Smart Charging Briefing. 3. Mandatory requirements on charging infrastructure provisions for medium and large commercial properties, i.e. office and leisure buildings or car parks in cities, including for smart charging, which will be key as e-Mobility enters the mass market. 4. Support for practical opportunities of smart charging technologies for public charging infrastructures. In this regard, initiatives should be carried out to create business conditions for EV drivers to use the smart charging in public infrastructure. 5. Last but not least, ECOS would like to stress the importance for the IA to assess the potential of turning the AFI Directive into a Regulation. This to allow for a swift and harmonised adoption addressing charging interoperability.
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Response to Review of energy labelling for residential ventilation units

28 Apr 2020

ECOS believes that the EU should act to further reduce the environmental impact of ventilation units (VUs) by reviewing its ecodesign and energy labelling requirements. The current regulations have brought about significant energy savings. However, as sales of VUs are expected to increase significantly (see Task 2 of the ongoing Preparatory Study) it is essential to assess how energy and resource efficiency requirements can be further improved. Regarding the policy options presented, ECOS considers that Option 3 is most appropriate to deliver these improvements. We do not believe that self-regulation by industry (Option 2) would be sufficient to attain further energy and resource savings. Furthermore, Option 1 would not adequately address the issues that remain, such as the need for more stringent Ecodesign requirements. Building on Option 3, we welcome the possibility to impose more ambitious Ecodesign requirements, improving both energy and resource efficiency. It is ECOS opinion that the current review should at the very least address all eight aspects listed below. 1. ECOS supports an assessment to broaden the scope to include VUs with an electric power input of less than 30 W per air stream, as well as the intention to consider effects of filters on the energy efficiency of VUs. 2. Air leakage is one of the important parameters related to the loss of efficiency for both residential and non-residential VUs. We therefore strongly encourage the Commission to conduct an assessment of the impact of the leakage rates of all VUs, and to set Ecodesign requirements accordingly. 3. The distinction made between residential and non-residential ventilation units can create loopholes since many VUs fall into both categories. We therefore urge the Commission to investigate the effects of this differentiation and assess the benefits of setting the same requirements for all these products. 4. We welcome any clarifications and improvements of definitions set in the Regulations. We want to stress that these adjustments should however not lead to additional exemptions. The definition of VUs currently proposed by the Preparatory Study, for instance, refers to the presence of human beings. This could create a loophole for VUs used in buildings that are not used by people. 5. ECOS is supportive of assessing the impact of climatic conditions on heat recovery to improve the requirements for heat recovery. In addition to these five issues already mentioned by the IIA, it is key that the following aspects are addressed as well: 6. In line with Article 8 of Ecodesign Regulation (EU) No 1253/2014 on the review of the regulation, an assessment of the current verification tolerances set out in Annex VI is needed. 7. In line with Article 8 of Energy labelling Regulation (EU) No 1254/2014, the broadening of the scope of the energy label should be assessed to include i.a. non-residential VUs and VUs with an electric power input of less than 30 W per air stream. 8. Last but not least, the potential circular economy gains that can be delivered by further regulating VUs should be assessed as it has and is been done for the rest of the product groups under the Ecodesign Framework. Material efficiency requirements should be introduced, for example to facilitate recyclability. In this regard it is essential to consider design evolutions, such as the increased use of plastics, that may complicate current practices.
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Response to Review of ecodesign requirements for ventilation units

28 Apr 2020

ECOS believes that the EU should act to further reduce the environmental impact of ventilation units (VUs) by reviewing its ecodesign and energy labelling requirements. The current regulations have brought about significant energy savings. However, as sales of VUs are expected to increase significantly (see Task 2 of the ongoing Preparatory Study) it is essential to assess how energy and resource efficiency requirements can be further improved. Regarding the policy options presented, ECOS considers that Option 3 is most appropriate to deliver these improvements. We do not believe that self-regulation by industry (Option 2) would be sufficient to attain further energy and resource savings. Furthermore, Option 1 would not adequately address the issues that remain, such as the need for more stringent Ecodesign requirements. Building on Option 3, we welcome the possibility to impose more ambitious Ecodesign requirements, improving both energy and resource efficiency. It is ECOS opinion that the current review should at the very least address all eight aspects listed below. 1. ECOS supports an assessment to broaden the scope to include VUs with an electric power input of less than 30 W per air stream, as well as the intention to consider effects of filters on the energy efficiency of VUs. 2. Air leakage is one of the important parameters related to the loss of efficiency for both residential and non-residential VUs. We therefore strongly encourage the Commission to conduct an assessment of the impact of the leakage rates of all VUs, and to set Ecodesign requirements accordingly. 3. The distinction made between residential and non-residential ventilation units can create loopholes since many VUs fall into both categories. We therefore urge the Commission to investigate the effects of this differentiation and assess the benefits of setting the same requirements for all these products. 4. We welcome any clarifications and improvements of definitions set in the Regulations. We want to stress that these adjustments should however not lead to additional exemptions. The definition of VUs currently proposed by the Preparatory Study, for instance, refers to the presence of human beings. This could create a loophole for VUs used in buildings that are not used by people. 5. ECOS is supportive of assessing the impact of climatic conditions on heat recovery to improve the requirements for heat recovery. In addition to these five issues already mentioned by the IIA, it is key that the following aspects are addressed as well: 6. In line with Article 8 of Ecodesign Regulation (EU) No 1253/2014 on the review of the regulation, an assessment of the current verification tolerances set out in Annex VI is needed. 7. In line with Article 8 of Energy labelling Regulation (EU) No 1254/2014, the broadening of the scope of the energy label should be assessed to include i.a. non-residential VUs and VUs with an electric power input of less than 30 W per air stream. 8. Last but not least, the potential circular economy gains that can be delivered by further regulating VUs should be assessed as it has and is been done for the rest of the product groups under the Ecodesign Framework. Material efficiency requirements should be introduced, for example to facilitate recyclability. In this regard it is essential to consider design evolutions, such as the increased use of plastics, that may complicate current practices.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Please find attached ECOS' feedback to the proposed initiative.
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Response to A new Circular Economy Action Plan

20 Jan 2020

We welcome the European Commission’s intention to continue to develop its Circular Economy efforts, framed in the context of the wider European Green Deal agenda. In this response, we focus on key elements we consider priority for the effective development of an EU circular economy. The EU, as the world’s largest and most affluent single market on the planet, needs to bend the trends of the past few decades very considerably. This means that transformational, disruptive and systemic change is needed in our economy, particularly in key sectors. As detailed in the paper attached to our answer, the next Circular Economy Action Plan should deliver the following priorities: • Resource efficiency will not bend long-standing trends of over-consumption of resources – the EU needs to include an absolute resource reduction target in its circular economy action plan. A high-level political objective is needed to provide the direction of travel and level of ambition for legislative decisions affecting product design, production processes and the necessary development of a circular economy infrastructure providing reverse logistics, repair, reuse, refurbishment or remanufacture, before recycling. • The sustainable products policy must result in ambitious and homogeneous ecodesign framework for key economic sectors, with requirements on all key products, addressing issues from resource use and material selection to chemicals, pollution and circularity. • Chemicals need to be addressed explicitly within the sustainable products policy, beyond REACH. Synergies between the circular economy and the EU’s zero-pollution and toxic-free environment objectives are essential if companies and the public are to develop trust in reused, remanufactured or recycled products. • The biodiversity crisis demands that biological resource be more strongly integrated in circular economy measures. Use of biological resources for materials and energy is increasingly promoted by EU policies to help in the development of a circular economy and to address challenges such as the climate emergency. Yet overuse of biological resources inevitably leads to increased habitat destruction, biodiversity loss and land-use change. • Efforts to continue to develop the Plastics Strategy are essential. The focus of further measures needs to shift to plastic use prevention, using an ecodesign approach. • More attention needs to be paid to the “inner circles” of circularity (prevention, reuse and remanufacturing), while recycling should be energy-efficient, ensure material health of secondary materials, and bring about only minimal residual waste. • Further development of environmental assessment instruments can also help achieve high-level objectives. Instruments such as the Product and Organisation Environmental Footprints and Life Cycle Assessment should better reflect circular economy principles, follow the “polluter pays” principle and account for the negative externalities of certain product characteristics or end-of-life options. • Financing the circular economy needs greater attention to better harness investments to circularity. The Sustainable Finance Action Plan includes a commitment to identify and help channel investor money to economic activities significantly contributing to the “transition to a circular economy, waste prevention and recycling” while not causing significant harm to the environment.
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Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

8 Mar 2019

The adoption of RED II confirmed the EU’s intention to minimize incentives for food-crop based biofuels, especially those causing the biggest indirect impacts such as ILUC emissions. The legislator gave a mandate to the European Commission for the development of criteria to characterise high and low ILUC risks biofuels. ECOS believes that this draft delegated act does not properly fulfill this mandate: - It sets a too high threshold for feedstocks to be considered high ILUC risk; - It sets too low reaquirements for ILUC risk biofuels to be certified low ILUC. The attached document lists amendments we suggest to the draft delegated act, to better ensure that indirect adverse effects of certain biofuels are minimised.
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Response to Sustainability requirements for batteries

6 Feb 2019

ECOS believes that at the EU should take action to reduce the environmental impact of batteries, using existing legislation and by introducing new legal instruments addressing all phases of the value chain, from (ethical) sourcing of raw materials to recovery. Regarding the policy options presented, ECOS considers that a combination of options 3, 4 and 5 would be appropriate. We do not believe that self-regulation by industry or voluntary agreements would be sufficient to establish a sustainable European battery industry. On the other hand, Option 3 alone would not adequately address the issue, which goes well beyond energy performance. The Ecodesign Directive 2009/125/EC is a powerful tool to address a wide range of issues linked to the sustainability of batteries, provided that the scope and analysis of the ongoing preliminary study are adequate. As outlined in the Inception Impact Assessment, the demand for batteries will increase mostly because of the growth of the electric vehicle (EV) market. Key aspects of the sustainability of batteries (besides sourcing of materials) are their durability and energy performance. Most importantly, Ecodesign requirements should aim to extend the lifetime of batteries by enabling repairability and replacement of defective battery cells. Furthermore, the disassembly of EV batteries should be facilitated, to enable reuse or repurposing (the total lifetime of EV batteries can be extended by at least 10 years by using them in electrical energy storage systems). Lastly, the Ecodesign Regulation could introduce minimum recycled content requirements, together with mandatory declarations on the content and location of CRMs in the batteries, which would facilitate their recovery. Other issues need to be addressed through the revision of the Batteries Directive 2006/66/EC. The dependence of the European Union on raw materials from unstable third countries could be reduced by using secondary raw materials recovered from end-of-life batteries in the EU to manufacture new batteries. To reach this objective, the collection and recycling targets set in the Batteries Directive need to be increased. The Directive should also be revised to reflect the evolution of the market, in particular regarding the categories (portable, industrial…) and the obligations associated with these. Extended producers’ responsibility schemes for EV batteries should be introduced to maximise their collection. The secondary use of the batteries should be encouraged, and the revision of the Directive should clarify the legal status and responsibilities of each actor in the value chain. To facilitate a binding regulatory provision, the EC should consider issuing a Standardisation Request addressed to the European Standardisation Bodies, in order to adequately adapt existing or develop European Standards that would support the regulatory requirements.
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Response to Common chargers for mobile phones and similar devices

31 Jan 2019

Following the expiration of the MoU of 2014 and the continuation of market fragmentation for mobile phone chargers, ECOS calls for the adoption of binding regulatory measures ECOS believes voluntary agreements (VAs) have proven to be ineffective in fostering market change and a single competitive market. Examples include VAs within the Ecodesign Directive for products such as printers and game consoles, characterised by limited scope, low ambition and lack of effective monitoring and reporting Similarly, in the case of mobile phone chargers, a fragmented market translates into significant detrimental market effects, including an increase of e-waste and use of plastic, consumer frustration, and competition barriers in charger manufacturing The introduction of the USB 3.1 standard and USB Type C connectors facilitates standardisation by enabling quality adaptive charging. Adaptive EPS are able to provide different output voltages using the same output port, so one power supply can serve a wide range of products requiring charging at a range of different standardised voltages (there is communication between the device and the charger to determine the voltage required) Therefore, binding regulatory provisions should be set, obliging producers to implement common charging solutions. We propose the specification of requirements on common EPS be formulated as follows: •Regulatory requirement via an amendment to the Radio Equipment Directive or the Ecodesign Regulation on External Power Supplies containing the following: -Application of requirements to the following products (with mobile, wifi or bluetooth connections) and rated power 100W or less: smartphones, tablets and e-readers, GPS/PND, Personal care products (toothbrushes etc), small network equipment, set-top boxes, small notebook computers, portable speakers, digital cameras/camcorders, portable games consoles, radio controlled toys, sports/activity monitors Implementation could begin with smartphones, with clearly defined timings for other products. Many of these devices already use a USB 2.0 Micro B connector. Clear definitions will be necessary to ensure no loopholes are created for non-compliant products •Separation of cable and charger plug, and specification of connector standards: The cable/connector to the product shall be separable from the plug charger to the mains and: -the connection between the cable/connector and mains plug charger will be either standard USB Type A/B or, USB Type C and compliant with the USB 3.1 standard, where the charger plug will be clearly marked to show which USB 3.1 voltage profiles it is able to supply (ensuring reuse with other appliances) -the connection between the cable/connector and the product shall be either USB Type C or USB 2.0 Micro B Alternatively, the product can be equipped with wireless charging functionality, where the compatible wireless charger is shipped separately from the product, can be used for multiple products, and meets minimum requirements for energy efficiency and no load power in line with the requirements for AC-DC power supplies of Regulation 278/2009. EPS plug chargers and cables shall be shipped and sold separately from the product they are intended to be used with •Quality and durability standards should also be specified within the regulation to prevent premature cable wear-out (e.g.durability of interfaces between cable and end connectors is a common point of failure) and ensure safety and durability of charger plugs. The casing of the plug charger shall comprise one single type of recyclable plastic •Transitional methods should be defined for the marking of plug chargers with USB-3.1 profiles, based off an EC preparatory study or similar •A Standardisation Request addressed to the European Standardisation Bodies should be launched to adequately adapt existing or develop European Standards that would support the regulatory requirements in aspects such as marking and durability
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Response to Ecodesign for refrigerating appliances with a direct sales function

17 Dec 2018

Ahead of the Member States’ vote, we would like to support the Ecodesign and Energy Label regulations proposed by the European Commission. We strongly believe it is crucial that the text is adopted swiftly, and oppose any postponement of the entry into force date beyond 1 September 2020 as currently proposed. In the event of a change in the implementation dates, thresholds’ ambition should be revised accordingly. We also have a number of recommendations on how to further improve the text which can be found in the attached document.
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Response to Energy labelling for refrigerating appliances with a direct sales function

17 Dec 2018

Ahead of the Member States’ vote, we would like to support the Ecodesign and Energy Label regulations proposed by the European Commission. We strongly believe it is crucial that the text is adopted swiftly, and oppose any postponement of the entry into force date beyond 1 September 2020 as currently proposed. In the event of a change in the implementation dates, thresholds’ ambition should be revised accordingly. We also have a number of recommendations on how to further improve the text which can be found in the attached document.
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Response to Ecodesign requirements for (other) electric motors

19 Nov 2018

We would like to welcome the draft Ecodesign requirements proposed by the European Commission which include some major improvements in terms of scope and ambition over the current regulation. We confirm our support for having motors integrated in other products in the scope of the regulation, and also have the following recommendations on how to further improve the proposals: - Anticipate implementation of requirements for certain motors: we do not see any technical reason for delaying the entry into force of Tier 1 for 8-pole motors, brake motors, explosion proof motors, small motors with a rated output from 0.12kW up to 0.75kW. - Increase ambition for Tier 2 to IE4 for motors from 0.75kW to 375kW which use asynchronous or advanced motor technologies like permanent magnet and synchronous reluctance motors. - Increase ambition on VSDs: the VSDs scope should match the motors scope and we therefore call for the inclusion of VSDs that are rated for operating with motors down until 0.12 kW. Not covering these products already in Tier 1 represents a missed opportunity since their efficiency is very low and they are widely sold. We also firmly believe that the Tier 2 requirements should be taken to the next level by requiring IE3. - Support recycling of rare earth elements in permanent magnet motors: resource aspects have been left to the next revision, which is a missed opportunity and not in line with the Circular Economy strategy of the European Union. At a very minimum, action needs to be taken on permanent magnet motors, that can contain rare earth elements which have been identified as critical materials in the medium-term based on supply risk, demand growth and recycling restrictions. Devices with rare earth magnets are hard to identify as such without having very specific technical know-how or without conducting intensive testing/dismantling of devices. Recycling should be facilitated by a mandatory and standardised marking of products containing rare earth magnets, including information on their localisation, information on the applied type (e.g. SmCo, FeNdB) and their extraction process. A clause ensuring the ease of dismantling of permanent magnets when they contain rare earth elements, as proposed in other regulations in discussion.
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Response to Small, medium and large power transformers - Commission Regulation amending Regulation (EU) No 548/2014

19 Nov 2018

The current proposal sets a dangerous precedent with regards to the certainty of European regulations. The Commission’s actions run counter to Article 7 in Regulation 548/2014 which does not call for a review of the ambition of Tier 2. Weakening the existing regulation would undermine regulatory stability and the climate for investment. Regulatory revisions shall only lead to increased requirements' ambition based on the latest technological developments. We regret to see that the number of exemptions from the scope and derogations risk generating massive loopholes and undermine the energy savings of the current regulation. The Commission has postponed to 2023 crucial aspects of the current revision. Building on the proven facts available, that transformers can fulfil Tier 1 without difficulties and there remain no major technical barriers to meet Tier 2, we have the following recommendations: - Toughen derogations Whilst recognising the challenges of resolving derogations for certain situations, we are convinced that exemptions and particular derogations based on costs or technical feasibility completely undermine the political objective of the Ecodesign Directive. Specifically, alarming NEW provisions have been inserted, which allow derogations that do not meet Tier 1 nor ANY efficiency requirements in the case of the one-to-one replacement or the installation in an existing site AND for new installations in new sites, of large power transformers. These extreme and previously unannounced derogations must be removed as they contravene the nature of the implementing measure itself. If the Commission refuses to withdraw them, then both must be mitigated with strict core loss limits. As it stands, the proposal sets modest conditions for accepting a derogation, but the default approach remains weak and perpetuates massive loopholes for far too many product types. That is why we urge the Commission to add the following five criteria: Core losses limit for any alternative offered, Exclusion of green field sites, Exclusion of industrial sites, Disallow batch exemptions, Place additional specific limitations on exemptions for new installations. Additionally, we urge a staged transition to removing the concessions for pole-mounted transformers as evidence overwhelmingly shows that the old technology deployed for these applications does not belong in the efficient grid needed for the coming decades. - Tighten MEPS We are disappointed to see the proposal fails to address the poor ambition of EU MEPS for medium power transformers below 60 kVA which remain weak compared with all other economies. And we regret that the new specific requirements for dry type and liquid immersed transformers below 4 MVA have been significantly relaxed. By doing so, the Commission is no longer in alignment with IEC 60076-20 which is a step backwards. - Set MEPS for single phase transformers We request evidence on the decision not to address the minimum performance for single phase transformers which are specifically mentioned in the Review Clause for the current regulation. Finally, we note some proposed improvements. We welcome that the general exemptions to the scope for ‘disproportionate costs’ and ‘technically infeasible’ in Article 1 have been swept away but the gaps noted above allow scope for much improvement. We back progress to define retrofit, repair and refurbish. We suggest replacing “increase significantly the energy performance” with “increasing the efficiency of the transformer” to avoid potential loopholes due to the wording. We welcome the much-improved detail on correction factors for special windings with more restricted allowances for many types; and the marginally more strict requirements for dry type with Um <36kV and for liquid immersed >100MVA (Tier 2). And we strongly support the addition of options to reinforce market surveillance verification of transformers (e.g. witness testing of FATs).
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Response to Regulatory measure on the review of energy labelling for household washing machines and washer-driers

19 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations and particularly the new energy efficiency formulas, which are less linear and steep with capacity, thus avoiding the current encouragement to ever larger capacities. We also welcome the provisions to avoid programmes with too stretched durations, with a preference for the cap on duration in Ecodesign over indication on the energy label. With regard to resource efficiency, the proposals to make repair and recycling of washing machines easier have been substantially weakened compared to previous versions of the texts, and, consequently, we urge decision-makers to increase the regulation ambition. - Stretch the energy label scales The proposed energy labelling scales have small class widths, especially in the top classes. This jeopardises the possibility of the labels to last for at least 10 years and makes it too easy to jump one class up through limited product adjustment or using tolerances. We call for stretching the scales to a more adequate level, with truly challenging A and B classes. - Improve the duplication of programmes clause We fully support restricting the use of programme names such as normal/daily/standard/regular, but recommend reintroducing the wording from the previous regulatory draft, mentioning also the use of the term cotton. - Improve the label design The label designs and descriptions are missing the grey F and G classes that should apply after April 2024. We strongly advise to remove the circle with the word “eco 40-60°”, since we doubt that its meaning will be understood, and we see a very significant risk that consumers believe it certifies the product is in some way “eco-friendly”. We regret that no icons have been envisaged that could help consumers buy more durable, reparable products, such as the free warranty period offered by the manufacturer or spare parts availability - Lower delay start allowance and better regulation of networked modes The power limit for the delay start condition has been set to much too high a value (6 W) and should be limited at 1 W or less. In addition, the provisions on networked standby should allow the user to deactivate networked connections. - Strongly reinforce provisions on resource efficiency Spare parts should be available during the average product lifetime, i.e. 12 years. They spare should not be restricted to professional repairers but should be open to retailers, repairers and consumers. The list of spare parts should be extended to include batteries. A maximum delivery time of one week should be specified. Further, we call on the reintroduction of the unrestricted access to appliance repair and maintenance information to independent operators, supported by an explanatory section to the definition of “independent operator” as in the Regulation EC715/2007 on the availability of vehicle repair and maintenance information. Finally, while the previous drafts foresaw an easy access to a list of key parts for repair, the latest Commission proposals only foresee that dismantling shall be facilitated to extract the list of materials and components referred to in Annex VII of the WEEE Directive. This is a big step backwards in terms of reparability of products, and we call on the reintroduction of the previous provision. Our detailed comments are available through this link: https://www.coolproducts.eu/s/Final-recommendations-on-Washing-Machines-Nov-2018.pdf
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Response to Review of ecodesign requirements for household washing machines and washer-driers

19 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations and particularly the new energy efficiency formulas, which are less linear and steep with capacity, thus avoiding the current encouragement to ever larger capacities. We also welcome the provisions to avoid programmes with too stretched durations, with a preference for the cap on duration in Ecodesign over indication on the energy label. With regard to resource efficiency, the proposals to make repair and recycling of washing machines easier have been substantially weakened compared to previous versions of the texts, and, consequently, we urge decision-makers to increase the regulation ambition. - Stretch the energy label scales The proposed energy labelling scales have small class widths, especially in the top classes. This jeopardises the possibility of the labels to last for at least 10 years and makes it too easy to jump one class up through limited product adjustment or using tolerances. We call for stretching the scales to a more adequate level, with truly challenging A and B classes. - Improve the duplication of programmes clause We fully support restricting the use of programme names such as normal/daily/standard/regular, but recommend reintroducing the wording from the previous regulatory draft, mentioning also the use of the term cotton. - Improve the label design The label designs and descriptions are missing the grey F and G classes that should apply after April 2024. We strongly advise to remove the circle with the word “eco 40-60°”, since we doubt that its meaning will be understood, and we see a very significant risk that consumers believe it certifies the product is in some way “eco-friendly”. We regret that no icons have been envisaged that could help consumers buy more durable, reparable products, such as the free warranty period offered by the manufacturer or spare parts availability - Lower delay start allowance and better regulation of networked modes The power limit for the delay start condition has been set to much too high a value (6 W) and should be limited at 1 W or less. In addition, the provisions on networked standby should allow the user to deactivate networked connections. - Strongly reinforce provisions on resource efficiency Spare parts should be available during the average product lifetime, i.e. 12 years. They spare should not be restricted to professional repairers but should be open to retailers, repairers and consumers. The list of spare parts should be extended to include batteries. A maximum delivery time of one week should be specified. Further, we call on the reintroduction of the unrestricted access to appliance repair and maintenance information to independent operators, supported by an explanatory section to the definition of “independent operator” as in the Regulation EC715/2007 on the availability of vehicle repair and maintenance information. Finally, while the previous drafts foresaw an easy access to a list of key parts for repair, the latest Commission proposals only foresee that dismantling shall be facilitated to extract the list of materials and components referred to in Annex VII of the WEEE Directive. This is a big step backwards in terms of reparability of products, and we call on the reintroduction of the previous provision. Our detailed comments are available through this link: https://www.coolproducts.eu/s/Final-recommendations-on-Washing-Machines-Nov-2018.pdf
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Response to Ecodesign requirements for external power supplies

6 Nov 2018

We support the revision of the External Power Supplies regulation, in particular the extension of the scope to multi-voltage EPS. We regret that the proposal has not been made more ambitious, notably in terms of resource efficiency, as described below. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. Wireless chargers have not been integrated in the scope. We believe it is essential to consider this rapidly emerging category and potentially significant new source for energy waste. Inefficient design can have a resource efficiency impact in terms of adverse thermal effects (overheating) that can cause device malfunction or damage. Cheap inefficient wireless chargers on the EU market could reduce mobile phone lifetimes, as well as having poor lifetimes themselves. We call on the Commission to issue a standardisation request as soon as possible to define testing approaches for these products. We also ask for the integration of an early-revision clause, to be able to regulate these within a few years’ time. We regret that a 10%-load active efficiency requirement is not included in the proposal and think that an information requirement is a minimum and essential to be able to address this in the next revision. We also regret that this regulation has not been better integrated to the Circular Economy strategy of the European Union. In particular, we believe that this regulation should include a requirement for the EPS to be reparable with widely available tools, so that independent repairers would be able to repair an EPS rather than having to discard it as WEEE. We also think that the European institutions should play an active role in promoting the interoperability of supplies and EPS/chargers. It is clear that standardising and reducing the quantity of EPS and chargers in use would have a positive impact on material efficiency, reducing EPS electronic waste potentially by up to 500 000 tons, as well as extending lifetime, enhancing reliability and decreasing weight by up to 30. Moreover, this would potentially have a significant impact on embedded energy, corresponding to a non-negligible fraction of the energy that can be saved during the use stage. Additionally, this should contribute to cost savings for consumers, reducing the need to buy a new EPS each time a small ICT device is acquired. This revision is therefore a perfect opportunity that should be grasped.
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Response to Review of ecodesign requirements for household dishwashers

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission but call on the European institutions to reinforce several of the provisions in discussion. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. Energy efficiency We are concerned about the lack of ambition put forward on the energy efficiency aspects. On Ecodesign, the proposed first tier sets the efficiency levels as already in place today, meaning that no improvement will be actually implemented until Tier 2 in 2024. Although we support the inclusion of a Tier 2, the proposal for 2024 has been set at a very unambitious level. Tier 2 deviates from the least life cycle cost principle of the Ecodesign Directive, and cannot be accepted. The level of Tier 2 needs to be set at an adequate level, corresponding to at least class D of the new label (EEI of 50). Moreover, classes of the energy label have been relaxed, making it easier to climb out of the red bottom classes. This is regrettable, and a threat to the longevity of the new label. Besides, the proposed scale risks contravening with Labelling Regulation 2017/1369 which states that Class A should be empty and the BAT situated in Class B. As a matter of fact, the A class may not be empty from the start since heat pump dishwashers mentioned in the benchmarks may already be in A. Finally, we are convinced that the test method used for the declaration of the Energy Label should be representative of real-life use as much as possible. The appropriate scenario would include testing different programmes or a combination of programmes and functions, selected on the basis of consumer habits, instead of continuing using the eco programme for the labelling purposes as proposed. Resource efficiency We strongly support the measures addressing material efficiency and urge the European institutions to maintain ambition on this important issue. Some requirements seem to have been relaxed as the process progresses, which is not acceptable. We call on the below changes to the proposal: - Strengthen the availability of spare parts provision Availability of spare parts is a key material efficiency consideration, and we strongly support the inclusion of a minimum period of spare part availability, however this needs to be improved as follows: All spare parts should be available during the average product lifetime, i.e. 12 years. As a minimum, these should be available for 10 years, in line with the Austrian standard ONR 192102. Spare parts access should not be restricted to professional repairers but should be for retailers, repairers and consumers. The list of spare parts should be extended to include batteries, as the ability to remove these once no longer holding charge is key to the potential for products to be repaired. A maximum delivery time of one week for spare parts should also be specified. - Reintroduce the unrestricted access to repair and maintenance information We are disappointed to note the barriers now put in place to access repair and maintenance information. We call on the European institutions to reintroduce the “unrestricted access to appliance repair and maintenance information to independent operators”. - Target non-destructive disassembly Finally, it is essential that the ease of access to key components targets non-destructive disassembly for the purpose of repair, rather than dismantling only for material recovery.
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Response to Review of energy labelling for household dishwashers

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission but call on the European institutions to reinforce several of the provisions in discussion. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. Energy efficiency We are concerned about the lack of ambition put forward on the energy efficiency aspects. On Ecodesign, the proposed first tier sets the efficiency levels as already in place today, meaning that no improvement will be actually implemented until Tier 2 in 2024. Although we support the inclusion of a Tier 2, the proposal for 2024 has been set at a very unambitious level. Tier 2 deviates from the least life cycle cost principle of the Ecodesign Directive, and cannot be accepted. The level of Tier 2 needs to be set at an adequate level, corresponding to at least class D of the new label (EEI of 50). Moreover, classes of the energy label have been relaxed, making it easier to climb out of the red bottom classes. This is regrettable, and a threat to the longevity of the new label. Besides, the proposed scale risks contravening with Labelling Regulation 2017/1369 which states that Class A should be empty and the BAT situated in Class B. As a matter of fact, the A class may not be empty from the start since heat pump dishwashers mentioned in the benchmarks may already be in A. Finally, we are convinced that the test method used for the declaration of the Energy Label should be representative of real-life use as much as possible. The appropriate scenario would include testing different programmes or a combination of programmes and functions, selected on the basis of consumer habits, instead of continuing using the eco programme for the labelling purposes as proposed. Resource efficiency We strongly support the measures addressing material efficiency and urge the European institutions to maintain ambition on this important issue. Some requirements seem to have been relaxed as the process progresses, which is not acceptable. We call on the below changes to the proposal: - Strengthen the availability of spare parts provision Availability of spare parts is a key material efficiency consideration, and we strongly support the inclusion of a minimum period of spare part availability, however this needs to be improved as follows: All spare parts should be available during the average product lifetime, i.e. 12 years. As a minimum, these should be available for 10 years, in line with the Austrian standard ONR 192102. Spare parts access should not be restricted to professional repairers but should be for retailers, repairers and consumers. The list of spare parts should be extended to include batteries, as the ability to remove these once no longer holding charge is key to the potential for products to be repaired. A maximum delivery time of one week for spare parts should also be specified. - Reintroduce the unrestricted access to repair and maintenance information We are disappointed to note the barriers now put in place to access repair and maintenance information. We call on the European institutions to reintroduce the “unrestricted access to appliance repair and maintenance information to independent operators”. - Target non-destructive disassembly Finally, it is essential that the ease of access to key components targets non-destructive disassembly for the purpose of repair, rather than dismantling only for material recovery.
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Response to Ecodesign requirements for electronic displays and televisions

6 Nov 2018

The Commission proposal brings various improvements, such as the extension of the scope to displays, a revised scale with classes A and B empty to drive innovation, a double scale, which gives the right amount of attention to the High Dynamic Range (HDR) feature, stricter standby requirements, etc. We also have a number of suggestions on how to improve the text further. Note that most of our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Extend the regulation scope We call on the European institutions to remove several exemptions from the scope, notably the exemption for electronic displays where the main function of the display is status display or control or function activation, the exemption for digital photo frames, and the numerous exemptions for signage displays. Moreover, in the previous drafts, electronic displays integrated into other products were made easily accessible to facilitate their dismantling, which is not the case anymore. We urge the European institutions to reintroduce this provision. - Finetune the proposed Energy Label The Energy Label should contain indication of the annual energy consumption, in a prominent position, to be consistent with the new Energy Labelling Framework Regulation. We have doubts regarding the proposed External Power Supplies (EPS) icon in terms of comprehensibility and influence on purchasing decisions. Other options could be added, such as the time during which spare parts will be made available by the manufacturer. - Reinforce the clause on software updates We strongly support the requirement that the power demand of the product will not increase after a software or firmware update when measured with the same test standard originally used for the declaration of conformity. However, the exception that this is allowed with the “explicit consent of the end-user” significantly weakens this requirement. In the STEP report, an increase in energy consumption of 31% to 37% was observed after software updates for three of the seven television models tested. We believe that prior to being asked to provide consent, the user shall be notified of a possible increase of energy use and in which circumstance or functionality that increase will occur before starting the update. The user should have right to refuse an update. Furthermore, in the event that the user disables energy saving functionality (either directly or indirectly, for example via a change in picture settings), the user shall be informed of the resultant increase in energy usage, and it shall be possible for them to re-enable this functionality without a factory reset. - Reinforce the resource efficiency provisions by targeting easier repair Ease of access should target non-destructive disassembly rather than dismantling only. The European Commission has put forward innovative provisions to facilitate the repair of several domestic appliances as part of the Package of measures to be adopted by the end of the year and we disagree with the idea that TVs and displays should be under a different regime. Moreover, on dismantling, the reference to WEEE results in key display parts not being addressed (e.g. PMMA boards and internal power supplies) and some display technologies neither (e.g. OLED). - Limit the use of halogenated flame retardants We firmly believe that the use of halogenated flame retardants should not be permitted in the enclosure and stand of electronic displays, as proposed in the July 2018 draft from the European Commission. We strongly disagree with the idea that this should be kept for another policy discussion. The negative impact of using halogenated flame retardants in televisions and displays does not need to be proven anymore and it needs to be urgently addressed, for the European institutions to be coherent with their Circular Economy and Plastics agendas.
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Response to Energy labelling for electronic displays

6 Nov 2018

The Commission proposal brings various improvements, such as the extension of the scope to displays, a revised scale with classes A and B empty to drive innovation, a double scale, which gives the right amount of attention to the High Dynamic Range (HDR) feature, stricter standby requirements, etc. We also have a number of suggestions on how to improve the text further. Note that most of our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Extend the regulation scope We call on the European institutions to remove several exemptions from the scope, notably the exemption for electronic displays where the main function of the display is status display or control or function activation, the exemption for digital photo frames, and the numerous exemptions for signage displays. Moreover, in the previous drafts, electronic displays integrated into other products were made easily accessible to facilitate their dismantling, which is not the case anymore. We urge the European institutions to reintroduce this provision. - Finetune the proposed Energy Label The Energy Label should contain indication of the annual energy consumption, in a prominent position, to be consistent with the new Energy Labelling Framework Regulation. We have doubts regarding the proposed External Power Supplies (EPS) icon in terms of comprehensibility and influence on purchasing decisions. Other options could be added, such as the time during which spare parts will be made available by the manufacturer. - Reinforce the clause on software updates We strongly support the requirement that the power demand of the product will not increase after a software or firmware update when measured with the same test standard originally used for the declaration of conformity. However, the exception that this is allowed with the “explicit consent of the end-user” significantly weakens this requirement. In the STEP report, an increase in energy consumption of 31% to 37% was observed after software updates for three of the seven television models tested. We believe that prior to being asked to provide consent, the user shall be notified of a possible increase of energy use and in which circumstance or functionality that increase will occur before starting the update. The user should have right to refuse an update. Furthermore, in the event that the user disables energy saving functionality (either directly or indirectly, for example via a change in picture settings), the user shall be informed of the resultant increase in energy usage, and it shall be possible for them to re-enable this functionality without a factory reset. - Reinforce the resource efficiency provisions by targeting easier repair Ease of access should target non-destructive disassembly rather than dismantling only. The European Commission has put forward innovative provisions to facilitate the repair of several domestic appliances as part of the Package of measures to be adopted by the end of the year and we disagree with the idea that TVs and displays should be under a different regime. Moreover, on dismantling, the reference to WEEE results in key display parts not being addressed (e.g. PMMA boards and internal power supplies) and some display technologies neither (e.g. OLED). - Limit the use of halogenated flame retardants We firmly believe that the use of halogenated flame retardants should not be permitted in the enclosure and stand of electronic displays, as proposed in the July 2018 draft from the European Commission. We strongly disagree with the idea that this should be kept for another policy discussion. The negative impact of using halogenated flame retardants in televisions and displays does not need to be proven anymore and it needs to be urgently addressed, for the European institutions to be coherent with their Circular Economy and Plastics agendas.
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Response to Review of ecodesign requirements for household cold appliances

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission. We also listed below recommendations on how to further improve the proposals. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Accelerate implementation of requirements We regret the one-year delay on all application dates compared to the previous drafts. Everything should be done to respect the Energy Labelling Regulation 2017/1369, which foresees that new labels are displayed in shops by end 2019. - Finetune the scope We welcome the definition of the scope, especially the reinstatement of wine coolers and minibars with glass doors. We still see a risk of potential gaps in the combined scopes of these regulations and that for professional and commercial appliances. - Simplify the Energy Efficiency Index Formula We regret that the formula for the energy efficiency index has not been simplified and streamlined. We firmly believe there are too many correction factors and bonuses. The ‘built-in factor’ should especially be removed. We also consider that thee frost-free correction factor is too generous and should not exceed 5%. - Design of the Label We believe that only one indicator should be kept for the storage volume of all compartments together. We regret that no icons that could help consumers buy more durable, reparable products have been envisaged. Moreover, the call from many stakeholders for starting without grey classes from the beginning (meaning changing the F and G boundaries) should be considered. - Strongly reinforce provisions on resource efficiency We support requirements looking at facilitating fridges’ repair and recycling. The proposal in discussion remains very shy compared to what is proposed for dishwashers and washing machines and we call for an alignment on these. This would mean enlarging the provision on the ease of disassembly, allowing the easy access to ann exhaustive list of key components for repair. The availability of spare parts should be extended so that all spare parts important for repair are available during the average product lifetime or for 10 years minimum. We also consider that that the maximum delivery time for spare parts should be reduced. And finally, we believe that a clause on “unrestricted access to repair and maintenance information” should be included.
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Response to Review of energy labelling for household cold appliances

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission. We also listed below recommendations on how to further improve the proposals. Note that our comments refer to the Interservice Consultation drafts and could need to be amended in the coming weeks depending on the importance of changes in the new versions submitted to WTO. - Accelerate implementation of requirements We regret the one-year delay on all application dates compared to the previous drafts. Everything should be done to respect the Energy Labelling Regulation 2017/1369, which foresees that new labels are displayed in shops by end 2019. - Finetune the scope We welcome the definition of the scope, especially the reinstatement of wine coolers and minibars with glass doors. We still see a risk of potential gaps in the combined scopes of these regulations and that for professional and commercial appliances. - Simplify the Energy Efficiency Index Formula We regret that the formula for the energy efficiency index has not been simplified and streamlined. We firmly believe there are too many correction factors and bonuses. The ‘built-in factor’ should especially be removed. We also consider that thee frost-free correction factor is too generous and should not exceed 5%. - Design of the Label We believe that only one indicator should be kept for the storage volume of all compartments together. We regret that no icons that could help consumers buy more durable, reparable products have been envisaged. Moreover, the call from many stakeholders for starting without grey classes from the beginning (meaning changing the F and G boundaries) should be considered. - Strongly reinforce provisions on resource efficiency We support requirements looking at facilitating fridges’ repair and recycling. The proposal in discussion remains very shy compared to what is proposed for dishwashers and washing machines and we call for an alignment on these. This would mean enlarging the provision on the ease of disassembly, allowing the easy access to ann exhaustive list of key components for repair. The availability of spare parts should be extended so that all spare parts important for repair are available during the average product lifetime or for 10 years minimum. We also consider that that the maximum delivery time for spare parts should be reduced. And finally, we believe that a clause on “unrestricted access to repair and maintenance information” should be included.
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Response to Review of ecodesign requirements for lighting products

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission, and particularly the phasing out of T8 lamps, the important product information that will be made accessible in the EU product database, and the revised verification tolerance levels. We also have the below recommendations on how to further improve the proposals. - Accelerate implementation of requirements We do not support the decision to delay the entry into force of the Regulations by a year, to 2021. The measures should take effect in 2020 as originally proposed in the November 2017 draft. We particularly oppose the nine-month transition period offered for relabelling products in shops until June 2022. It is much longer than is necessary and conflicts with Energy Labelling Regulation 2017/1369 which states that new labels should be displayed in shops by the end of 2019. - Expand the chromaticity boundaries defining “white light” We urge the European institutions to ensure that the light chromaticity boundaries defining the scope of coverage be expanded, so as not to create the risk of a loophole (i.e. products placed on the market which are just outside the white-light boundaries, that would still look like white light but would escape all requirements). - Set the L factor at 1.0 instead of 1.5 We warn about the too high “end-loss factor” L for LEDs in the formula for efficacy requirements. There will be hardly any impact on household products in the low and medium lumen ranges, where efficiency can be substantially improved. - Introduce a mid-term check in the new accelerated endurance testing proposal We welcome the new lifetime testing proposal, which combines endurance switching cycles with lumen maintenance. Since we believe that some of the poor-quality products will fail in the first few hundred hours of testing, and it is important that they can be quickly identified and subjected to timely sanctions, we suggest introducing a mid-term check during the test. - Raise ambition on product disassemblability The provision on the possibility to remove the light sources and control gears without mechanical damage by the end-user from any product containing them is too weak: dismantling (not disassembly) is now foreseen, and only for market surveillance purposes. This is a big step backwards and we call on the reintroduction of the initial proposal which was supported by several Member States in December 2017.
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Response to Review of energy labelling requirements for lighting products

6 Nov 2018

We would like to support the draft Ecodesign and Energy Labelling regulations proposed by the European Commission, and particularly the phasing out of T8 lamps, the important product information that will be made accessible in the EU product database, and the revised verification tolerance levels. We also have the below recommendations on how to further improve the proposals. - Accelerate implementation of requirements We do not support the decision to delay the entry into force of the Regulations by a year, to 2021. The measures should take effect in 2020 as originally proposed in the November 2017 draft. We particularly oppose the nine-month transition period offered for relabelling products in shops until June 2022. It is much longer than is necessary and conflicts with Energy Labelling Regulation 2017/1369 which states that new labels should be displayed in shops by the end of 2019. - Expand the chromaticity boundaries defining “white light” We urge the European institutions to ensure that the light chromaticity boundaries defining the scope of coverage be expanded, so as not to create the risk of a loophole (i.e. products placed on the market which are just outside the white-light boundaries, that would still look like white light but would escape all requirements). - Set the L factor at 1.0 instead of 1.5 We warn about the too high “end-loss factor” L for LEDs in the formula for efficacy requirements. There will be hardly any impact on household products in the low and medium lumen ranges, where efficiency can be substantially improved. - Introduce a mid-term check in the new accelerated endurance testing proposal We welcome the new lifetime testing proposal, which combines endurance switching cycles with lumen maintenance. Since we believe that some of the poor-quality products will fail in the first few hundred hours of testing, and it is important that they can be quickly identified and subjected to timely sanctions, we suggest introducing a mid-term check during the test. - Raise ambition on product disassemblability The provision on the possibility to remove the light sources and control gears without mechanical damage by the end-user from any product containing them is too weak: dismantling (not disassembly) is now foreseen, and only for market surveillance purposes. This is a big step backwards and we call on the reintroduction of the initial proposal which was supported by several Member States in December 2017.
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Response to Environmental impact of enterprise servers and data storage products

30 Jul 2018

ECOS, with the support of the Coolproducts campaign, would like to welcome the European Commission’s intention to regulate the design of enterprise servers and data storage products with a view of limiting their environmental impact. In particular, ECOS strongly supports the resource efficiency requirements put forward by the Commission to ensure the durability, reparability, reusability and upgradability of servers, as specified in the ambition of clauses 4) 8) and 9) of the draft regulation. ECOS is currently reviewing the newly published proposal and will put together some consolidated views by the end of September 2018.
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Response to Evaluation and potential revision of the EU tyre labelling scheme

27 Jul 2018

ECOS, supported by other European environmental NGOs, welcomes the revision of the Energy Labelling for tyres. Several critical improvements are supported, such as the provisions to better display the label to end-users to help increase awareness and confidence in the label, the obligation to register tyre models in the EU product database, and the rescaling of the label. However, ECOS has a number of concerns regarding certain aspects of this legislative proposal: - We deeply regret that third-party certification/verification has been ruled out. It is only mentioned in the revision clause, which is insufficient. At present, there is no requirement for public authorities to ensure independent or third-party verification, and the label parameters are assessed by means of “self-declaration” by manufacturers, that is, without any form of third-party certification. As the rate of technical non-compliance seems to be significant, third party certification/verification would contribute to a level playing field much more than the current scheme. - It is suggested to move the label scale one class up at the top of the scale. We believe aiming for two classes would stimulate innovation and ensure that the new label remains valid for a decade or more. - The obligation to show the label to customers buying new cars sold with tyres is welcome in principle, although there is doubt about the actual impact of this provision if it comes alone. What happens if the customer sees that the tyres sold with the car have a poor energy class? Can he/she request the car dealer to provide the car with better alternatives? Will the dealer charge a dissuasive extra for this? This provision should be better framed and complemented so that the end-user can make an informed choice thanks to the label information. ECOS believes it should be mandatory for car dealers to only supply models with tyres of the top energy classes, or allow the end-user to freely choose the tyres at no extra cost. - New essential performance parameters that have been covered in the review study, such as abrasion (contributing to microplastics release) and mileage, have been dismissed because of the lack of agreed measurement methods. It is key that these methods are developed as soon as possible in order to remove this barrier. The Commission should now, at the very least, request that robust and representative methods are developed for these parameters. Considering that the standardisation community might not be interested in developing those without a request (or may even not have an interest in “widely accepting” methods that are available), such a Commission request would at least attempt to avoid facing exactly the same situation when a future review or revision takes place. We also think that to be coherent with the European Commission Strategy for Plastics in a Circular Economy, the Commission should issue a standardisation request on the measurement of abrasion and unintended release of microplastics without further delays. In fact, Europe contributes by 15.9% to global releases of primary microplastics to the world oceans, from which more than half (8.6%) come from tyre abrasion while driving and hence, it is an urgent issue to be tackled. - Regrettably, the proposal does not mention material and resource efficiency, although it is a top priority under the EU’s Circular Economy agenda. We firmly call for the revision clause to indicate the need to inform consumers about the material and resource efficiency of tyres, and the importance of assessing these parameters at least in view of the next review (through e.g. the development of a recyclability index for tyres that could be displayed on the label).
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

1 Jun 2018

ECOS welcomes the European Commission’s ongoing efforts to develop an EU circular economy. We strongly encourage the EU to ensure that the circular economy respects planetary boundaries and fair share of use and access to resources, and avoids and minimises negative impacts of resource use including biodiversity loss, climate change, pollution, and reduced/impaired human health. ECOS views the European Commission’s current work on EU product policy contributing to the circular economy as a continuum that began with its work on Integrated Product Policy (IPP) in the late 1990s. This work was then taken up again under the heading of Sustainable Consumption and Production and Sustainable Industrial Policy adopted in the mid-2000s. Despite this long-standing analysis and reflection on EU product policy, we regret that there has been little development on a more horizontal tool or approach to integrated, sustainable or even circular products. We therefore urge the European Commission to perform a gap analysis and to develop policy and legislative proposals to fill any gaps identified. While the focus on circularity is welcome, several other important aspects need to be addressed on the road to circularity, such as the environmental (and social) aspects of different materials including their production, sourcing, labelling, and ease of recycling, and listing of all chemicals in final products. Lifecycle thinking is a well-established and understood approach which also needs deeper integration into policy approaches. A circular economy also requires a horizontal sustainability approach to production and consumption, even if focused attention on a narrow range of products like energy-related products remains essential. Such a horizontal sustainability approach could be integrated into existing policy tools such as the General Product Safety Directive, which could be extended to address sustainability. The General Product Safety (and Sustainability) Directive could then be supported by vertical sectoral targeted actions addressing key product groups identified as having significant environmental impacts. Understanding the difficulty of introducing horizontal sustainability criteria across a large range of products, the extended GPSD could start by requiring information provision on sustainability-specific aspects of products (bill of materials, chemicals present in the final product, etc.). An EU product information tool could be created, which would gather data from tools such as the future Energy Labelling Regulation product database, and the Waste Framework Directive’s SVHC list. The extended GPSD’s sustainability information element would fit well within this information tool. In the context of the European Commission’s work on IPP, extensive studies were undertaken to identify products with significant environmental impacts. The EIPRO project resulted in 22 product groups being highlighted , and three functional areas of consumption identified as having most significant impacts. Food and drink, passenger transport, and housing were shown to represent 70-80% of environmental impacts of consumption and account for 60% of consumption expenditure. In other areas of private consumption, clothing was also highlighted as ranking highest amongst a wide range of products. The Commission’s roadmap document has also identified food and drinks, textiles, construction products/buildings, furniture, cosmetics as having high circularity potential. ECOS calls on the Commission to: • put into practice the many studies that have pointed to significant environmental impacts and potential for improvements • to build on experience from existing EU product policy tools to streamline criteria development processes • to integrate into future EU product policy tools and measures the experience from independent sustainability initiatives on products (from FSC and MSC to bio-based products sustainability tools and beyond).
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Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and

13 Apr 2018 · Single use plastic

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Friends of the Earth Europe and

13 Apr 2018 · discussion on single-use plastics legislation

Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

ECOS welcomes this opportunity to provide feedback on the Commission’s plan to update its 2012 Bioeconomy Strategy. In the past years, ECOS actively participated in the development of European standards requested by the European Commission to support the Strategy and was heavily involved in technical discussions on circular economy, bioenergy and bioplastics. The Roadmap outlines eight areas of focus for a revised strategy, primarily supporting market expansion and economic innovations. In so doing, the economy element continues to take precedence over the bio element, despite the bio element being the basis of the economy element. We would prefer to see more focus, effort and resources applied to the understanding and resilience of land and sea ecosystems. Actions that improve early warning systems, and governance mechanisms to ensure that the EU’s demand for biological materials helps to bring the biodiversity loss back within planetary boundaries must be prioritized over indiscriminate increases in switches to bio-based product use. An example of such indiscriminate increase is the BBI JU’s target of achieving 30% bio-based products in the chemicals sector, based on little to no analysis of what this entails in terms of sourcing of biomass.Such unsubstantiated and little guided policy objectives cannot be supported given the state of over-consumption of natural resources that has existed for decades. Without a commitment backed up by policy objectives, the EU risks continuing to add to human activity that further destroys the natural resources our societies and economies depend on. Although the roadmap repeatedly refers to a ‘sustainable circular bioeconomy’, the bioeconomy as such is not necessarily sustainable or circular. The mere substitution of fossil resources by biomass does not guarantee that our economic model will turn into a sustainable circular one.To ensure that this is actually the case, the roadmap should include five currently missing aspects: • the finite character of natural resources requires first and foremost to dramatically reduce the pressure put on ecosystems through current consumption patterns. The existence of bio-based counterparts for various consumer goods should in no way undermine efforts to cut demand for new products; • biomass should be used following the cascading use principle (food/feed – bio-based products – bioenergy), and ensuring compliance with the waste hierarchy. Neither of these two concepts are mentioned in the roadmap; • fostering the bioeconomy will automatically increase the demand in biomass. Yet, the risks related to such increase (e.g. (indirect) land use change, soil erosion, biodiversity losses, water and energy use) are currently unknown. ECOS urges the Commission to allocate resources to investigate this issue. In the absence of solid data, the precautionary principle should be applied; • the environmental performance of bio-based products and bioenergy should be higher than that of the fossil counterpart it is meant to replace. The environmental performance assessment should take into consideration biomass production, biomass conversion, and end-of-life options and include a broad range of criteria such as GHG emissions, direct and indirect land-use change, energy use, water use, soil quality, etc. • it is essential that communication to consumers avoids green washing, be it false labelling or sustainability claims based on limited requirements. The strategy should ensure that consumers are better made aware of (i) bio-based content of products and bio-energy blends (very rarely being 100% for product labelled as ‘bio-based’); (ii) the value-added of these products over fossil-based ones; (iii) the difference between raw materials and products' functionality: bio-based products are not necessarily biodegradable and fossil-based products can be biodegradable. Further information can be found in the attached document.
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Response to Energy labelling requirements for computers and computer servers

20 Feb 2018

The inception impact assessment document provides a very good introduction to the topic, and we are very supportive of most of the statements made. The best policy option for consumers and the environment is indeed option 3. We would like to insist on three key points: 1/ Ecodesign requirements should be pursued, but thoroughly revised and reinforced to better reflect current technologies and practices. - Measuring computers in a more active state than idle would ensure that the requirements are closer to real life use and the potential savings really reaped. - Carefully designing requirements on standby modes, so that no ‘modern standby’ unduly escapes Ecodesign limits, is a critical aspect. - Most of the power allowances (for graphic adders, tuners, additional memory storage, etc.) should also be revisited and substantially adjusted, since there are technological solutions to avoid the energy use from these adders when they are not in operation. - The current exemption of requirements for high-end PCs needs to be deleted, because it creates a too high risk of free ride for configurations that then become more and more mainstream. In particular, powerful gaming computers should be covered (as game consoles are), since the saving potentials are massive for these types of products. - Durability, reusability, and recyclability requirements are also of paramount importance. For mobile products, the share of the production and end of life phases is dominant in their ecological life-cycle. Hence the need to tackle these issues that become increasingly significant for consumers. 2/ An Energy Label for computers will be a very welcome addition. It is obvious that most (private and professional) consumers do not have a clear idea of the energy use from computers, and the difference between models and configurations on the market. Only an energy label can fil this gap. The Label can be based on a similar methodology/measurement than Ecodesign. From our analysis, there is sufficient differentiation on the market to allow for a scale of 7 energy classes for desktops, and possibly slightly less (e.g. 5) for laptops. The label can also be used to display durability information. 3/ We agree that tablets could be removed from the scope of energy efficiency requirements and labelling (as they are intrinsically low consuming), however we are fully opposed to exempting them from durability requirements. Issues of poorly performing and changeable batteries, lack of recyclability, and rapid obsolescence are fully relevant for tablets and should be tackled.
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Response to Review of ecodesign requirements for computers and computer servers

20 Feb 2018

The inception impact assessment document provides a very good introduction to the topic, and we are very supportive of most of the statements made. The best policy option for consumers and the environment is indeed option 3. We would like to insist on three key points: 1/ Ecodesign requirements should be pursued, but thoroughly revised and reinforced to better reflect current technologies and practices. - Measuring computers in a more active state than idle would ensure that the requirements are closer to real life use and the potential savings really reaped. - Carefully designing requirements on standby modes, so that no ‘modern standby’ unduly escapes Ecodesign limits, is a critical aspect. - Most of the power allowances (for graphic adders, tuners, additional memory storage, etc.) should also be revisited and substantially adjusted, since there are technological solutions to avoid the energy use from these adders when they are not in operation. - The current exemption of requirements for high-end PCs needs to be deleted, because it creates a too high risk of free ride for configurations that then become more and more mainstream. In particular, powerful gaming computers should be covered (as game consoles are), since the saving potentials are massive for these types of products. - Durability, reusability, and recyclability requirements are also of paramount importance. For mobile products, the share of the production and end of life phases is dominant in their ecological life-cycle. Hence the need to tackle these issues that become increasingly significant for consumers. 2/ An Energy Label for computers will be a very welcome addition. It is obvious that most (private and professional) consumers do not have a clear idea of the energy use from computers, and the difference between models and configurations on the market. Only an energy label can fil this gap. The Label can be based on a similar methodology/measurement than Ecodesign. From our analysis, there is sufficient differentiation on the market to allow for a scale of 7 energy classes for desktops, and possibly slightly less (e.g. 5) for laptops. The label can also be used to display durability information. 3/ We agree that tablets could be removed from the scope of energy efficiency requirements and labelling (as they are intrinsically low consuming), however we are fully opposed to exempting them from durability requirements. Issues of poorly performing and changeable batteries, lack of recyclability, and rapid obsolescence are fully relevant for tablets and should be tackled.
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Response to Review of ecodesign requirements for standby and off mode electric power consumption

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/f7YJpN We are in favour of Option 3 because Ecodesign & Energy Labelling requirements for standby and network standby help mitigate climate change and help EU citizens save on their bills. Our paper includes proposals on how to go further.
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Response to Review of energy labelling for household cold appliances

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/vtaonZ We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for domestic cold appliances help mitigate climate change and help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate these products in a Circular Economy, notably by introducing requirements on spare parts and recyclability. Our paper includes proposals on how to go further.
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Response to Review of ecodesign requirements for household cold appliances

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/vtaonZ We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for domestic cold appliances help mitigate climate change and help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate these products in a Circular Economy, notably by introducing requirements on spare parts and recyclability. Our paper includes proposals on how to go further.
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Response to Review of energy labelling requirements for lighting products

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/NSvjpG We are in favour of Option 5 because Ecodesign & Energy Labelling requirements for lighting help mitigate climate change and help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate lighting in a Circular Economy, notably by introducing requirements on the removability of light sources and control gears. In our paper, we have listed additional measures we think that the European Commission should be taking or maintaining to increase lighting lifetime.
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Response to Review of ecodesign requirements for lighting products

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/NSvjpG We are in favour of Option 5 because Ecodesign & Energy Labelling requirements for lighting help mitigate climate change and help EU citizens save on their bills, and we strongly support the efforts made by the Commission intention to better integrate lighting in a Circular Economy, notably by introducing requirements on the removability of light sources and control gears. In our paper, we have listed additional measures we think that the European Commission should be taking or maintaining to increase lighting lifetime. Our paper includes proposals on how to go further.
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Response to Review of energy labelling for household dishwashers

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/baHJFq We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household dishwashers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the proposed reparability and recyclability requirements. Our paper includes proposals on how to go further.
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Response to Review of ecodesign requirements for household dishwashers

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/baHJFq We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household dishwashers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the proposed reparability and recyclability requirements. Our paper includes proposals on how to go further.
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Response to Regulatory measure on the review of energy labelling for household washing machines and washer-driers

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/7XeaF8 We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household washing machines and washer driers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the proposed reparability and recyclability requirements. Our paper includes proposals on how to go further.
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Response to Review of ecodesign requirements for household washing machines and washer-driers

20 Feb 2018

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/7XeaF8 We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household washing machines and washer driers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the proposed reparability and recyclability requirements. Our paper includes proposals on how to go further.
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Meeting with Elżbieta Bieńkowska (Commissioner) and

30 Jan 2018 · Exchange of views regarding strategy on plastics

Response to Amendments of the Annexes to REACH for registration of nanomaterials

6 Nov 2017

ECOS considers the need for better, more and publicly available safety information central to the safe use and management of chemical substances, including nanomaterials. Nanotechnologies continue to evolve and there is a need to ensure that adequate scientific information is provided on existing and future nanomaterials (including 'active substances') BEFORE the substances are placed on the market. In attachment we provide our fuller response.
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Meeting with Frans Timmermans (First Vice-President) and European Environmental Bureau and

6 Nov 2017 · Discussion on EU Plastics Strategy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Friends of the Earth Europe and

26 Oct 2017 · Plastic strategy

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

10 Mar 2015 · Energy Union follow-up: Energy labelling