2022/0095(COD) · In Force
363 submissions from 306 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 390 submissions on this file. Shown here: the 363 from organizations. Not shown: 14 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 13 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
275 submissions from industry — companies and their trade associations — against 54 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 5.1 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 22 Jun 2022 — it ran from 3 Apr 2022.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 25 of 363 submissions.
Response Free ICT Europe to the ESPR consultation Free ICT EUROPE welcomes the transformation of the current Ecodesign Framework Directive into a new Ecodesign for Sustainable Products Regulation. We think it clearly reflects the ambition of the EU to make sustainable products the norm and shaping condition for different market operators.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Re:NewCell AB (publ) (“Renewcell”) was founded in 2012 by researchers at KTH in Stockholm. It is a multiple prize-winning sustaintech company based in Sweden. The vision of Renewcell is to inspire an Industriell Evolution for a sustainable world by producing high quality materials from recycled textiles.
Filed in Swedish · English published by the European Commission
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The European Phenolic Foam Association (EPRA) fully supports the broad objectives of the Eco-Design for Sustainable Products Regulation (ESPR), but is concerned that the inclusion of the full list of Substances of Concern from the outset could put the regulation out of step with the implementation of the Chemical Strategy for Sustainability (CSS) and potentially force substitutions which are neither sustainable nor…
EC2022 is a French non-partisan group, created in March 2021, of more than 250 experts with the aim of facilitating the networking of circular economy actors, putting the circular economy at the heart of the public debate and becoming a privileged interlocutor for public decision-makers on this topic. The collective has already worked on 5 main measures to make the whole economy circular.
Filed in French · English published by the European Commission
The BMW Group is already the first German car manufacturer to firmly anchor the 1.5 degree path of the Paris Climate Agreement in its business strategy and to become climate neutral by 2050. As part of its holistic sustainability strategy, BMW Group intends to offer cars with the best competitive environmental footprint to its customers.
Filed in German · English published by the European Commission
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maki Consulting welcomes the comprehensive legislation with its expansion to non energy-related products, its many options for measures to be selected and tailored for the specific product group (while considering the individual product’s characteristics).
EuRIC strongly welcomes the publication of the proposal for a Regulation on Ecodesign for Sustainable products (2022/0095 (COD)) accompanied by the Communication on making sustainable products the norm (COM (2022) 140 final). Eco-design for recycling is a pre-condition to move towards a more circular economy.
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The European Footwear Confederation (CEC) welcomes the main concepts of the EC proposal for a review of Eco-design Directive and their integration in the EU Strategy for Sustainable Textiles. We recognise the capacity of the proposal to ensure a sustainable future for our industry, a priority for our members, by establishing requirements and criteria for a greener production, limiting the proliferation of alleged…
Decarbonized heating is a priority for the European Union And has already been reflected in the RePowerEU strategy. This is crucial to protect human health (reduction of air pollution in many EU regions) and climate.
Generation Climate Europe welcomes the Commission’s proposal for an Ecodesign for Sustainable Products Regulation (ESPR) replacing the current Ecodesign Directive. We consider that, overall, its level of comprehensiveness and ambition are the necessary ones that are needed in light of the need to build more circular and sustainable economic systems.
Independent Retail Europe members believe that the new process to determine ecodesign requirements truly has the potential to change the way products will be consumed in future and that retail will play a pivotal role in this transition to greener products. Retailers’ in-store advisors and experts provide an essential added value to consumers, as they: 1.
Hydro welcomes the European Commission’s proposed Regulation for Ecodesign for Sustainable Products as an important step forward to drive demand for low-carbon and circular products. We, therefore, welcome legislation that empowers consumers to make sustainable choices in their daily lives and legislation that promotes the increased collection of used materials for recycling by improving and making available…
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Repair&Share welcomes the revision of the Ecodesign Directive through the Sustainable Products Initiative (SPI) as a major opportunity to enhance product sustainability. We believe this regulation has the potential to improve the way products are designed on the EU market, and can help us get closer to a Right to Repair in Europe.
ITI - the Information Technology Industry Council is the premier global advocate for technology, representing the world’s most innovative companies from technology, hardware, software, services, and related industries. We appreciate the opportunity to provide comments to the Proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products (ESPR).
Sympatex fully supports EU policy to regulate that design for circularity becomes the norm for new products in order to ensure that waste is avoided at the end of life and material ressources are used in the most economic way.
Bitkom welcomes the European Commission's intention to work towards products that are as sustainable, environmentally conscious and circular as possible. With the revision of the existing ecodesign directive, the European Commission is taking an important step towards a sustainable and climate-neutral Europe. Please find attached our feedback on the Ecodesign for Sustainable Products Regulation Proposal (ESPR).
European Commission DG ENV - Unit B1 DG GROW - Unit C1 DG ENER - Unit C4 Brussels, 22 June 2022 EPF and EPLF Feedback on the Proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products The European Panel Federation (EPF) and the European Producers of Laminate Flooring association (EPLF) welcome the opportunity to provide feedback on the Proposal for a Regulation…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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FSB supports the objective of the proposed Regulation to foster greater product sustainability and circularity, and agrees that a Regulation is the most effective means of ensuring greater harmonisation and levelling the playing field for businesses operating within the Single Market.
Response to European Commission Proposal 'Regulation of the Ecodesign on sustainable products' - Digital Product Passports This response to COM (2022) 142 final 2022/0095 (COD) is being submitted by Circle Economy (Amsterdam, the Netherlands.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
SSAB COMMENTS ON THE ECODESIGN REQUIREMENTS FOR SUSTAINABLE PRODUCTS SSAB welcomes the European Commission’s work on the proposal to set Ecodesign requirements for sustainable products (ERSP) and that steel products might be among the first group of products to be regulated. This will promote sustainable innovations, encourage investments in related technology and level the playing field in the steel sector.
We support the overall vision set by the European Union to reach climate neutrality and optimise the use of our resources. C&A has a long been committed to offer more sustainable products at affordable prices. • C&A is committed to offer more sustainable products at affordable prices and has set ambitious targets to create truly circular fashion.
We welcome the plan to make products placed on the EU market more sustainable. More specifically, the aim is to improve the durability and reliability of products, their reusability, upgradability, repairability, maintenance and overhaul. For this purpose, future ecodesign requirements should include performance requirements and information requirements. However, the latter are largely limited to indicators.
Filed in German · English published by the European Commission
The European Ventilation Industry Association (EVIA) support the need to keep legislation up-to-date and in line with the latest technological developments. In that light, we appreciate the European Commission’s proposals for an Ecodesign for Sustainable Products Regulation (ESPR).
Naturvernforbundet | Mariboes gate 8 |0183 Oslo [email removed] Telefon [phone removed] Org nr.: 938 418 837 Bank: 7874.05.56001 European Commission Oslo, 22.06.2022 Input to the public consultation on the European Commission proposal for the Sustainable products initiative We refer to the European Commission’s consultation on the Sustainable product initiative (SPI) and appreciate the opportunity to give our…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FIGIEFA (the European federation and political representative in Brussels of the independent wholesalers and retailers of automotive replacement parts and their associated repair chains) welcomes the objectives of the new EU Commission proposal for a Regulation setting ecodesign requirements for sustainable products which will contribute to reduce the negative life-cycle environmental and social impacts of products…
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HOP welcomes this proposal from the European Commission. However, we consider the ambition of the text needs to be increased on certain points in order to achieve its objectives. Ban specific and harmful practices in horizontal provisions : Some of the practices added in the Annex to Directive 2005/29/CE in the recent Empowering the consumer proposal should be included under the ecodesign framework and banned for…
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SolarPower Europe supports the regulatory proposal’s objective to extend the scope of Ecodesign beyond energy-related projects. As already pointed out in our feedback during the previous phases of this legislative initiative, we believe that broadening the scope of sustainability policies to additional sectors of the economy will strengthen EU efforts to reach climate neutrality and achieve the objectives laid out…
In line with the comments received from the European chemical industry represented by Cefic, welcomes the European Commission’s proposal for an Ecodesign Regulation for sustainable products and supports the overall objectives of this ambitious initiative. A proper implementation of the ESPR is an opportunity for industry to take an active role in the transition of the European market towards sustainable products.
Filed in Spanish · English published by the European Commission
Right to Repair Europe’s reaction to ESPR Right to Repair Europe is enthusiastic about the publication of the Ecodesign for Sustainable Products Regulation (ESPR) which has the potential to improve the way products on the EU market are designed and serviced. This regulation could mean a leap towards achieving a European right to repair.
Refashion welcomes the publication of the proposal for a Regulation establishing Ecodesign requirements for sustainable products (ESPR). In particular, Refashion supports the extension of the previous Directive’s scope to key sets of products, such as textiles.
ANIMA Confindustria Meccanica Varia is Italian industrial Organisation that represents companies operating in the mechanical engineering sector. ANIMA Confindustria Meccanica supports the Regulation on Ecodesign for Sustainable Products and, in the paper attached, would like to share some considerations on the implementation of this piece of legislation.
The WKÖ supports and commits to the objective of climate neutrality by 2050. A concrete set of measures is now needed to support a sustainable, green transition in the EU in line with a new growth strategy. The WKÖ advocates legislation that meets the requirements of effective climate protection while being practicable and compatible with economic prosperity.
Filed in German · English published by the European Commission
ECOS is a strong supporter of the European Commission’s efforts to make sustainable products the norm, and has long been calling for the extension of ecodesign requirements to all products. While our overall position on the proposal is detailed in the attached paper, we would like to focus here on the impact assessment accompanying the proposal: • Ecodesign criteria.
EPEE, representing the Refrigeration, Air-Conditioning and Heat-Pump (RACHP) industry, welcomes the European Commission’s proposal for a new Ecodesign for Sustainable Products Regulation as an ambitious piece of legislation.
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IFF supports the regulation objective of improving the sustainability of products and wishes to bring the Commission’s attention on a number of elements in the draft that IFF believes require further consideration and refinement. Article 2. The proposal defines product groups through the lens of purpose, functional properties, and consumer perception of goods.
Hydrogen Europe welcomed the high ambition of the Commission’s Fit for 55 package, and calls on the European Parliament and the Council to keep those objectives. In order to achieve those overarching goals however, we need to push for a regulatory framework that incentivises the shift towards more sustainable and low-carbon solutions, while promoting “carbon content as the new currency”.
We share the aims of the Green Deal and fully support the European Commission’s drive to offer solutions so that products sold on the European market respect strict sustainability criteria. A’re profitable of implementing new circular economy initiatives and incurred consumers to use their products for longer. At Decathlon, A're special keen to support the introduction of a proposed eco-design regulation.
Filed in French · English published by the European Commission
Consejo Intertextil Español view for the initiative: Ecodesign for Sustainable Products Regulation (ESPR) proposal. Consejo Intertextil Español, follows the roadmap on the ESPR published by the European Commission.
Please find attached the EHI position paper on the Commission proposal for a regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC. About EHI, the Association of the European Heating Industry: EHI represents 90% of the European market for heat and hot water generation, heating controls and heat emitters, 75% of the hydronic heat pump…
Members of Classifieds Marketplaces Europe (CME) operate online marketplaces across 17 European countries where we empower our users to reduce their purchase of new products by promoting circular consumption choices. By selling their pre-owned goods, our users play an active role in enabling the circular transition.
FEAD fully supports the Commission’s Sustainable Products Initiative and its main objectives of reducing the negative life cycle environmental impacts of products, and the improvement of the internal market through a harmonised ecodesign approach.
Consumption Research Norway (SIFO) would like to thank the European Commission for the opportunity to give feedback on the Ecodesign for Sustainable Products Regulation proposal. Our feedback concerns textiles that are very complex products, socially, aesthetically, functionally, and technically. The main problem lies in overproduction, and therefore setting requirements for eco-design can have unintended effects.
As an organisation representing over 35,000 businesses in the digital sector, DIGITALEUROPE and its members have been at the forefront of the transition of the digital industry towards more responsible and sustainable models for some years now.
The increasing consideration of environmental criteria in business activity makes eco-design one of the keys to achieving more sustainable business models. By enacting the ‘AGEC’ law (anti-waste and for a circular economy) of February 2020, France has already put in place a series of measures to promote more sustainable products, as stated in Article 67, which provides for the placing on the market of a proportion…
Filed in French · English published by the European Commission
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At its heart, the revision of the Directive 2009/125/EC on Ecodesign requirements for energy-related products to become a Regulation of the Ecodesign on sustainable products (ESPR), entails sustainability requirements as one of the means to achieve the European Green Deal and Circular Economy Action Plan.
Position Paper Ecodesign for Sustainable Products Regulation Publication date: 22 June 2022 The steel industry welcomes the release of the recently proposed Ecodesign for Sustainable Products Regulation (ESPR) by the European Commission.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Adolf Würth GmbH & Co. KG (AWKG) supports the objectives of the European Union’s proposal for the Ecodesign Directive for the Sustainable Products Regulation. In doing so, Adolf Würth GmbH & Co. KG endeavours to manage sustainably, for example by developing innovative products.
Filed in German · English published by the European Commission
Have Your Say, SPI 2022 Norwegian Environment Agency, 22 June 2022 Norway is highly supportive of the Sustainable Products Initiative (SPI) as a key factor driving the transition to a more circular economy and thereby reducing the climate and environmental footprint of products. This ambitious endeavour will also support our national transition as Norway has a high consumption rate based on imported products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ECI welcomes the European Commission’s ambition for a sustainable product policy framework. The EC proposal on Eco-design for Sustainable Products Regulation (ESPR) has great potential in driving product design towards more sustainability. However, to deliver on the ambition of reducing the negative life-cycle environmental impact of products on the EU market, the following considerations should be made: 1.
In principle, the Finnish forest industry supports the initiative’s good ambition of sustainable products. An effective transition to a bio-based circular economy requiring sustainable products to become the norm. The ESPR is a broad and ambitious framework law that all products produced by the Finnish forest industry.
Filed in Finnish · English published by the European Commission
EURATEX supports the efforts of the European Commission to improve the sustainability of products that circulate in the European internal market through the Ecodesign Requirements for Sustainable Products Regulation proposal. However, there are critical points that require attention and revision for the regulation to be workable in the textiles industry.
This document contains Swedish Enterprise’s initial comments on the Sustainable Product Initiative and the Ecodesign requirements for sustainable products regulation (ESPR) presented on March 30 by the European Commission. Confederation of Swedish Enterprise is Sweden’s largest business federation, representing 60 000 member companies in all sectors with almost 2 million employees.
CO2 Value Europe is the European Association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030 and 2050, and for the development of the CCU industry. We represent more than 70 stakeholders along the entire CCU value chain. We commend the publication of the Sustainable Products Initiative.
Corbion welcomes the Commission’s initiatives to address unnecessary adverse environmental impacts of products placed on the EU market, while harmonizing industry requirements. The objectives set in the COM proposal for the Ecodesign for sustainable products Regulation (ESPR) are core to Corbion’s priorities of sustainability, circularity, and resource efficiency.
In line with the EU Green Deal and the Circular Economy Action Plan, we as HUGO BOSS aim to contribute to continuously lowering the environmental impact of our business activities. We are convinced that the future of business will be a circular system, where products are made to last, and made from safe input that can be recycled and predominately derive from and can stay in closed loops.
Confederation of Danish Industry supports the proposed Ecodesign for Sustainable Products Regulation (ESPR). Overall, we find that the proposal if implemented according to the good intentions will strengthen the Single Market, push for more circular products in the EU and create more transparency in the value chain.
Huawei welcomes the opportunity to provide feedback on the European Commission’s proposal for a Regulation of the European Parliament and of the Council establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive, a crucial proposal which will make products in the EU single market more sustainable, and to promote the EU to fulfil Green Deal ambitions.
Eingabe BUND eV zur „Sustainable products initiative“ 22.06.2022 Als Umweltverband beschäftigt sich der BUND neben Umweltschutz auch mit Verbraucher*innenschutz. Mit der ToxFox App, welche Schadstoffe in Produkten (Kosmetik und REACH Art.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
TUSIAD - Turkish Industry & Business Association perceives Green Deal as a model of economic growth focusing on fair and inclusive development for all. In this respect, Paris Agreement and European Green Deal are among our strategic priorities. Since its inception in 1995, EU – Türkiye Customs Union has been mutually beneficial for EU and Turkish companies.
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The main objectives of this regulation are to reduce the negative life cycle environmental impacts of products and improve the functioning of the internal market. ANSOL supports that goal and wants to highlight specific necessary regulations to reduce the negative life cycle environmental impacts of electronic products in particular: As outlined in Article 5.1, ecodesign requirements shall be established to improve…
ABB welcomes the European Commission’s proposal for the draft Ecodesign for Sustainable Products Regulation (ESPR) launched as part of the broader Sustainable Product Initiative on 30 March 2022. Building on the success of the existing EU Ecodesign framework, the proposal has the potential to substantially boost new circular business models across the EU, support further development of sustainable products and…
The European Infrared Heating Alliance (EIHA) supports the need to keep legislation updated and in line with the latest technological developments. In that light, we appreciate the European Commission’s proposals for an Ecodesign for Sustainable Products Regulation (ESPR).
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The European Power Tool Association represents 25 European power tool manufacturers, who are committed to the highest possible standards of quality and safety for their tools, and who invest considerably to find resource-efficient and customer-friendly solutions.
ACCREDIA, the Italian single accreditation body, has made some comments on the text of the Regulation, which we hope will be taken into account in order to make any clarifications or amendments to the Regulation that are deemed necessary in order to achieve its objectives.
Filed in Italian · English published by the European Commission
ETSA’s feedback to the European Commission on establishing a framework for setting eco-design requirements for sustainable products We at ETSA, the European Textile Service Association wholly support the European Commission’s framework in establishing eco-design requirements for sustainable products.
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EGMF is the European federation representing major garden, landscaping, forestry and turf equipment manufacturers. Through its 30 European corporate members and 7 National Associations, EGMF represents 18 million units placed on the European market and its members employ over 120,000 people in the EU.
H&M Group welcomes the European Commission’s proposal for a Regulation on Ecodesign for Sustainable Products and the development of product specific requirements. In our view, this will provide the needed granularity to drive change towards more circular, durable, and recyclable products and as such is a major milestone in the EU’s transition towards a circular economy.
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circular.fashion supports the Sustainable Product Initiative and the proposed regulation as a solid basis for the circular economy in Europe to evolve. We appreciate the opportunity to give feedback and suggest for the further process of defining more in-detail regulations to also consider the two following aspects: 1. in point (31), QR codes and watermarks are suggested as data carriers.
With the attached paper we take the opportunity to comment on the draft Ecodesign Regulation (COM(2022) 142 final) published by the European Commission on 30 March 2022 as part of its Sustainable Product Initiative (SPI). We welcome that the EU Commission continues to pursue the ecodesign approach.
Citeo, the French company in charge of Extended Producer Responsibility (EPR) for household packaging and graphic papers, would like to share its views on the proposal for a regulation on ecodesign for sustainable products presented by the European Commission on 30 March 2022, as part of the Sustainable Product Initiative, the Circular Economy Action Plan and the European Green Deal.
The Polish Union of the Cosmetics Industry supports the objectives of the Green Deal and the European Commission's proposal for a Regulation on Ecodesign for Sustainable Products (ESPR). Cosmetic products are outside the scope of the ESPR in the first step.
EHPA would like to thank the European Commission for the opportunity given to send feedback on the Commission proposal. General remarks Overall, when discussing about the Ecodesign for Sustainable Products Regulation and its requirements, it is important to keep in mind the following: - EHPA would like to recall the importance of a product group specific approach to take into account the specificities of the heat…
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Eurogypsum, the European federation of national associations of producers of gypsum products (such as plaster and plasterboard), welcomes the Sustainable Products Initiative (SPI) and its core objective of making products placed on the EU market more sustainable.
The European furniture industry is following closely Green Deal initiatives aimed at making circular economy the norm, such as the Sustainable Products Initiative (SPI). As such, building on the EFIC position on the SPI of June 2021, we welcome the possibility to provide our views on the Ecodesign for Sustainable Products Regulation (ESPR) proposal. Please find attached our input.
The chemical industry contributes to the sustainability and climate goals of the EU with innovative products and processes and has been working successfully for years to avoid possible impacts on the environment and health. We therefore welcome the extension of the ecodesign criteria to include all aspects of the circular economy.
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PVthin – the international trade body promoting thin-film photovoltaic (PV) technologies – supports the regulatory proposal’s objective to extend the scope of Ecodesign beyond energy-related projects. PVthin, having closely followed the ongoing work by the Commission to define Ecodesign requirements for PV modules, inverters, and systems, looks forward to seeing Ecodesign gain ambition.
The Electric Underfloor Heating Alliance (EUHA) supports the need to keep legislation updated and in line with the latest technological developments. In that light, we appreciate the European Commission’s proposals for an Ecodesign for Sustainable Products Regulation (ESPR).
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Mengend Nederland (MNL) are the downstream users of chemicals in the Netherlands; a collaboration between trade associations NVZ (detergents, disinfectants), NCV (cosmetics), NAV (aerosols), VLK (adhesives, sealants) and VVVF (paints, inks). MNL supports the goal of ESPR: giving sustainable products a better business case and introducing a digital product passport.
21 June 2022 [email removed] [phone removed] Position and recommendations on the proposed Ecodesign for Sustainable Products Regulation, ESPR Teknikföretagen (the Association of Swedish Engineering Industries) is the primary representative for Swedish industry. In total, our 4 300 member companies constitute one third of Sweden’s exports.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DUH welcomes the EU’s intention to make sustainable products the norm as part of the Sustainable Products Initiative and the Ecodesign for Sustainable Products Regulation (ESPR). To ensure that the initiative meets its objectives with respect to specific product groups, we would like to comment on general requirements, specific articles of the regulatory proposal and finally important eco design rules regarding…
Dear Members of the European Commission, We are pleased to respond to your proposal for “establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC”.
EUROPUR welcomes the European Commission’s initiative to further instate a circular economy in Europe and – as a sectoral trade association representing part of the plastics family – generally supports the proposed Regulation. Please find contribution from the European flexible polyurethane industry.
The VELUX Group welcomes the EU Commission's proposal on Ecodesign for Sustainable Products Regulation (ESPR) and supports the broader scope, moving away from a one-sided focus on energy efficiency to also factor in resource efficiency in a life cycle perspective.
Paris, le 22 juin 2022 Position du MEDEF relative au projet de règlement sur l’éco-conception des produits durable Une conception durable et harmonisée des produits, associée à une information qui permet d’éclairer le consommateur dans ses choix doit permettre de concourir à l’atteinte des objectifs de neutralité carbone et plus généralement à la réduction des impacts des produits et de la consommation sur…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The steel industry welcomes the draft regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC. The ambitious legislative package has the potential to improve the overall sustainability of products and create incentives for more sustainable products and business models.
Filed in German · English published by the European Commission
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We, APICER, the Portuguese Ceramic and Domestic Glass Industries Association welcome the publication of this regulation and the objectives it sets out, namely to reduce the negative environmental impacts of products throughout their life cycle and to improve the internal market by creating a level playing field - "This Regulation shall establish harmonized requirements where existing legislation does not…
CRNI welcomes the revision of the Ecodesign Directive through the Sustainable Products Initiative (SPI) as a major opportunity to enhance product sustainability and to pave the way for a transition towards sustainability within European markets.
Cefic welcomes the European Commission proposal on the Ecodesign for Sustainable Products Regulation and supports the overall objectives of this ambitious initiative. Well implemented, the ESPR is an opportunity for industry to take an active role in the European market transition towards sustainable products.
The Japan Business Council in Europe (JBCE) welcomes this opportunity to provide feedback on the Commission's proposal for the Ecodesign for Sustainable Products Regulation (ESPR). JBCE is a cross-sectoral association of companies with Japanese parentage. We support the EU’s ambition to make sustainable products the norm in the EU and we firmly believe JBCE can contribute to this through the ESPR.
Comments on Document “Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC) 1. In article 43 paragraph 6 the wording “take as a basis” is unclear regarding the resources a conformity assessment body is allowed to use from its parent or sister companies.
Confindustria Toscana Nord, follows with particular attention the roadmap on the 'Sustainable Product Initiative' published by the European Commission. In fact, the Prato area is home to the largest textile cluster in Italy and Europe, which has been based on a circular business model for centuries.
IFOAM Organics Europe welcomes the opportunity to provide feedback on the proposal for a regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC, as part of the Sustainable products initiative. Please find in the attached file our suggestions in reaction to the proposed regulation.
LKAB initial comments on the Ecodesign Requirements for Sustainable Products LKAB is a sustainable frontrunner in Europe’s iron and steel value chain Luossavaara-Kiirunavaara AB (LKAB) is an international high-tech mining and mineral group of iron ore in Sweden for the global steel market. More than 80% of the iron ore produced in Europe comes from LKAB’s mines.
The proposal for a new Ecodesign for Sustainable Products Regulation (ESPR) seeks to create a Single Market for sustainable products and improve access to sustainability information through the Digital Product Passport (DPP). The Regulation will only be successful if it ensures full harmonisation across Member States and drives competitiveness for European industry.
FNADE’s Feedback on regulation of the European Parliament and of the Council establishing a framework for setting Ecodesign requirements for Sustainable Products and repealing Directive 2009/125/EC June, 22 2022 FNADE, the French waste management and environmental services association, welcomes the proposal for Sustainable products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eurovent supports the Ecodesign Regulation for Sustainable Products proposal. Product sustainability must be addressed in harmonised way across the EU to ensure the free movement of products within the Single Market. For the new Ecodesign framework to be as successful as possible while stimulating innovation and preserving the competitiveness of European industry, Eurovent makes the following recommendations: 1.
Japanese 4EE industrial association’s (JP4EE) Comments and proposal: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC 22nd June, 2022 Japanese 4EE Industry associations; JEITA (Japan Electronics & Information Technology Industries Association) CIAJ (Communications and…
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BEUC and ANEC very much welcome the proposed Ecodesign for Sustainable Products Regulation. Along with the other important proposals included in the Circular Economy Package, it is a step in the right direction to bring more sustainable products to consumers and make a change in the way we design, produce, and consume products, to reduce their negative environment impact and enable the EU to meet its ambitious…
Climate Action Network (CAN) Europe is Europe's leading NGO coalition fighting dangerous climate change. With over 185 member organisations from 38 European countries, representing over 1.700 NGOs and more than 47 million citizens, CAN Europe promotes sustainable climate, energy and development policies throughout Europe.
Federchimica recognises the overall objectives of the European Commission proposal on the Ecodesign for Sustainable Products Regulation (ESPR) and believes that the Regulation will have a significant impact on its members as producers of chemicals (substances and mixtures).
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EUROPEN, the European Organization for Packaging and the Environment, supports the overall objectives of the European Commission’s Ecodesign for Sustainable Products Regulation (ESPR) proposal to reduce the negative life cycle environmental impacts of products and improve the functioning of the internal market.
Tarkett, a global leader in innovative and sustainable solutions for flooring, welcomes the European Commission’s proposal on Ecodesign for Sustainable Products Regulation (ESPR), aiming at creating an EU-wide Single Market for sustainable products across the European Union, while improving transparency through the Digital Product Passport.
The Offshore Wind Foundations Alliance (OWFA) is a coalition of five European companies producing offshore wind foundations: Bladt Industries A/S (Denmark), EEW Special Pipe Constructions GmbH (Germany), SIF Netherlands BV (the Netherlands), Smulders Projects Belgium (Belgium), and Steelwind Nordenham GmbH (Germany).
Autodesk, one of the global leaders in design and make technologies, welcomes the European Commission’s proposal for Ecodesign for Sustainable Products Regulation (ESPR) and the opportunity to share its views on it (see attached document for full comment). The potential of digital transformation for the reduction of the negative environmental impacts of product manufacturing remains under-exploited in the EU today.
Feedback on ‘Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC’ By way of some information in relation to our business, Tokyo Electron Limited (“TEL”) is a global company with operations all over the world, including the European Union.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Please find enclosed the feedback of EPPA, the European PVC Profiles and related Building Products Association representing the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of €4 billion with profile systems and building products.
The Policy Hub – Circularity for Apparel and Footwear, uniting more than 700 brands, retailers, manufacturers, and other stakeholders within the industry, and representing more than 50% of the apparel and footwear sector, welcomes the European authorities' efforts to reduce the environmental impact of products placed on the EU’s market.
At Clean Clothes Campaign – an international network of over 230 NGOs and trade unions focused on workers’ rights in the garment industry – we strongly believe that traceability and transparency are indispensable tools to ensure that products produced worldwide and consumed on the EU market are made in a sustainable way, with respect for human rights, labour rights and the environment.
IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.
ISOPA, the Association of Diisocyanates and Polyols Producers, shares the vision of a Circular Economy and is committed to the Chemicals Strategy for Sustainability. We welcome the opportunity to provide comments feeding into the upcoming Ecodesign Sustainable Products Regulation (ESPR), formerly known as the Sustainable Products Initiative (SPI).
The Verband der Mineralfarbenindustrie e.V. (VdMi) welcomes the EU Commission's efforts to strengthen the circular economy through the Ecodesign Regulation for Sustainable Products (ESPR), which is part of the 2020 Circular Economy Action Plan, as part of the Green Deal.
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The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) deeply appreciate European Commission’s effort taken for an Ecodesign for Sustainable Products Regulation (ESPR), and welcomes this opportunity to feedback regarding the proposal for the ESPR. Executive Summary 1.
EUREFAS - the European Refurbishment Association welcomes the proposal of Ecodesign for Sustainable Products setting up ambitious principles of durability, reusability and reparability at the design and manufacturing stages, in order to implement the green transition.
Textile Exchange welcomes the European Commission’s proposal for a Regulation on Ecodesign for Sustainable Products (ESPR) and Digital Product Passport (DPP) and appreciates the opportunity to provide feedback on the proposal. Textile Exchange fully supports the ambitions of the European Commission to regulate the design of products to improve their sustainability.
We welcome the European Commission’s proposal for a Regulation establishing a framework for setting eco-design requirements for sustainable products. We support the EU’s goal for manufacturers to design longer-lived products and to incentivise consumers to move away from the traditional linear model by transitioning to more durable, reusable, repairable, and recyclable products.
Logitech sees the Commission’s proposal for Ecodesign for Sustainable Products Regulation (the Ecodesign Regulation) as an excellent starting point for creating a global sustainability standard, while giving consumers the information on the sustainability implications of products.
European Bioplastics (EUBP) welcomes the initiatives taken at Commission level to address unnecessary adverse environmental impacts of products placed on the EU market, while harmonising industry requirements. The objectives set in the COM proposal for the Ecodesign for sustainable products Regulation (ESPR) are core to EUBP’s priorities of sustainability, circularity, and resource efficiency.
In light of Amazon’s strong commitment to our customers and sustainability practices, we welcome efforts to make products increasingly recyclable, restrict single-use, and counter premature obsolescence. Setting up a framework for ecodesign requirements, an EU Digital Product Passport, and introducing restrictions on unsold consumer goods under the new European Commission’s proposal for an Ecodesign for Sustainable…
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The International Wool Textile Organisation (IWTO), representing the global wool textile industry, welcomes the European Commission’s proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products, the Ecodesign for Sustainable Products Regulation (ESPR).
Please see attached comments of ACT | The App Association (Transparency Reg. # 7202951387754) on the European Commission’s proposal for a regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC.
Pyrowave is a pioneer in the electrification of chemical processes based on low carbon footprint microwaves. Pyrowave is also a Canadian leader in the plastics circular economy and chemical recycling to regenerate post-consumer and post-industrial plastics into new plastics, reclaiming these resources’ full value.
The European aluminium industry welcomes the Commission’s proposal for the ESPR and considers it as an important foundational framework which can ensure coherency and complementarity with all relevant policy areas. Such an approach would allow for a smooth and accelerated transition to a resource-efficient, low-carbon and circular economy which can realise the EU’s Green Deal ’s sustainability objectives.
EUROBAT welcomes the already-tabled Ecodesign for Sustainable Products Regulation and re-confirms its full support for the creation of a fully-decarbonised economy by 2050. It is important to further optimise products and create a circular economy ecosystem through more efficient common standards that will help to reach the environmental objectives. We commend the replacement of the former Ecodesign Directive…
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The textile district of Prato welcomes the proposal on the “Sustainable Product Initiative” of the European Commission. As a matter of fact, the district of Prato is the largest textile cluster in Italy and Europe, whose production has been using circular business models for centuries. Circular practices from Prato are a good practice that can be taken as a model for Europe at large.
The Forest Stewardship Council (FSC), the pioneer of forest certification with nearly +50 million hectares of certified forests in Europe, supports the EU Commission objective of improving the overall sustainability and circularity aspects of products. In the attached document we have elaborated five recommendations, backed by evidence, aiming at further strengthening the proposal: 1.
The Austrian Federal Ministry of Climate Action welcomes the proposal for establishing a framework for setting ecodesign requirements for sustainable products (ESPR) and would like to express its comments in the attached document. This document reflects the first assessment by the Austrian Federal Ministry of Climate Action.
• UNIFE - the association of the European rail supply industry - welcomes the opportunity to provide a feedback on the proposal for a regulation establishing a framework for setting eco-design requirements for sustainable products and repealing Directive 2009/125/EC.
VdL-Stellungnahme zum Entwurf der Ökodesign-Verordnung für nachhaltige Produkte vom 30. März 2022 Die Europäische Kommission schlägt vor, die derzeitige Ökodesign-Richtlinie auf nicht energieverbrauchsrelevante Produkte auszudehnen und dort Anforderungen festzulegen, bei denen bestehende Rechtsvorschriften Aspekte der ökologischen Nachhaltigkeit nicht oder nur unzureichend berücksichtigen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Brüssel, 21. Juni 2022 Deutscher Industrie- und Handelskammertag Konsultation der EU-Kommission zum Vorschlag für eine Verordnung zur Schaffung eines Rahmens für die Festlegung von Ökodesign-Anforderungen für nachhaltige Produkte und zur Aufhebung der Richtlinie 2009/125/EG Wir bedanken uns für die Gelegenheit zur Stellungnahme zu dem o. g. Entwurf.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CEPE welcomes the opportunity to comment on the adopted Ecodesign for Sustainable Product Regulation (ESPR) proposal. CEPE finds the following elements to be critical for its industry sectors. • CEPE finds the ESPR proposal a tool for ensuring a level-playing field for certain product categories.
The European Commission published on 31 March 2022 a proposal for a Regulation on Ecodesign for Sustainable Products (the Regulation). The proposal addresses product design, which determines up to 80% of a product's lifecycle environmental impact.
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We support the goal of the Sustainable Product Initiative and the European Green Deal striving towards a circular economy. We welcome that the Commission’s legislative proposal is in the form of a regulation, as this provides increased harmonisation in the EU single market. The efficient functioning of the single market is vital to business and the development of the circular economy.
MedTech Europe is the European trade association for the medical technology industry, including diagnostics, medical devices, and digital health. MedTech Europe supports the ambition towards more sustainable products in the European Union and circular business models.
We support the goal of the Sustainable Product Initiative and the European Green Deal striving towards a circular economy. We welcome that the Commission’s legislative proposal is in the form of a regulation, as this provides increased harmonisation in the EU single market. The efficient functioning of the single market is vital to business and the development of the circular economy.
The TÜV Association welcomes the EU Commission’s proposal for a new Ecodesign Regulation within the framework of the Sustainable Product Initiative (SPI) in order to increase the environmental sustainability of products over their entire life cycle. Apart from setting out ambitious requirements, it is crucial to ensure their consistent and effective compliance.
Clariant welcomes the European Commission proposal on the Ecodesign for Sustainable Products Regulation and supports the overall objectives of this ambitious initiative. We are convinced that sustainable products can bring a decisive contribution in achieving the EU’s flagship goals established under the Green Deal program, in particular in terms of safe and sustainable by design chemicals, low-carbon and circular…
Eurocolour welcomes the EU Commission's efforts to strengthen the circular economy through the Ecodesign Regulation for Sustainable Products (ESPR), which is part of the 2020 Circular Economy Action Plan, as part of the Green Deal. Nevertheless, when considering sustainability criteria, the product and its use within the framework of the entire life cycle must be kept in mind, i.e.
We support the proposal for a regulation. We consider the digital passport of the product to be of great interest. In particular, information should be easily understood by consumers, the information should be comparable to the list of ingredients of a product or a safety fiche of a chemical. The information should incorporate sustainability indicators so that the buyer can compare and choose responsibly.
Filed in Spanish · English published by the European Commission
EuroWindoor appreciates the opportunity to give feedback to the ESPR consultation und supports the aim of making sustainable products the norm while at the same time strengthening a level playing field with a fair and smooth functioning internal market.
Ecopreneur.eu - The European Sustainable Business Federation - highly welcomes the European Commission’s proposal for a European Sustainable Product Initiative (SPI) including an Ecodesign for Sustainable Products Regulation (ESPR) and a Digital Product Passport (DPP).
Aerospace and Defence Industries Associations of Europe (ASD) is the voice of the European Aeronautics, Space, Defence and Security Industries, representing over 3,000 companies and actively supporting the competitive development of the sector in Europe and worldwide. Our members produce very complex systems, like aircraft, complex weapon systems, launch vehicles and satellites, to name a few.
Cerame-Unie, the European Ceramic Industry Association, welcomes the objectives of the European Commission for a climate neutral, resource efficient and circular economy. Cerame-Unie thanks the European Commission for the opportunity to partake in the public consultation and set out the industry’s view in respect of the proposal for the Ecodesign for Sustainable Products Regulation (ESPR).
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Comments on Document „Proposal for a Regulation of the European Parliament and of the Council establishing a framework for setting eco-design requirements for sustainable products and repealing Directive 2009/125/EB” 2022/0095 (COD) 1.
Finnwatch welcomes the initiative to establish a framework for setting ecodesign requirements for sustainable products. Current level of consumption in the European Union is utterly unsustainable and in direct contradiction with the EU goals of stopping climate change and the loss of biodiversity.
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We, the Bundesverband Digitale Sicherheit e.V., have the goal of increasing digital security in our society. One of the ways we want to achieve this goal is by ensuring that every EU citizen has access to an electronic device. To ensure that this remains up to date (and therefore secure), we welcome the Sustainable products initiative.
We agree with the ultimate scope for setting ecodesign requirements about sustainable products but, at the same time, we would like to share our opinions regarding some parts deemed as critical. In the following senteces, you can find a summary of what we have written in the attached file.
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LKQ Europe, a subsidiary of LKQ Corporation, with its head office in Zug, Switzerland, is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe. It currently employs approximately 26,000 people with a network of more than 1,000 branches and approximately $6.1 billion in revenue in 2021.
JMC comments on the Proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC We would like to make the following comment in order to ensure that the implementation will be workable, proportionate and will contribute to a circular economy. 1.
PRE welcomes the publication of the proposal for a Regulation establishing ecodesign requirements for sustainable products (ESPR) and repealing Directive 2009/125/EC, as an opportunity to foster product sustainability in the EU, in the context of the EU Green Deal and the Circular Economy Action Plan. Please find attached our position paper on the EC proposal.
We believe that these are key considerations for all "intermediate products" (eg. cement & steel): 1) Introduce mandatory Ecodesign Requirements on information and performance for all relevant performance and lifecycle parameters, communicated via a robust, accessible, and harmonised B2B Digital Product Passport (DPP) system; underpinned by a 'nodata, no-market' principle and a clear legal framework for the…
We welcome and support the overall objectives and product-specific framework approach of the ESPR Proposal, as well as the explicit acknowledgment in recital (16) of the ESPR Proposal of key specificities of space products with regard to any ecodesign requirements.
TIF supports the Commission’s aim to modernise regulation of ecodesign requirements of products and set a legal framework for digital product passports, facilitating the combination of data with material flows. Our key messages are: The EU should be the global leader in setting standards together with industries for a sustainable and responsible market economy.
Response to the Public Consultation of the Ecodesign for Sustainable Products Regulation BASF supports the overall objectives of the European Commission’s proposal on the Ecodesign for Sustainable Products Regulation (ESPR).
IDunion Comment to Proposal for Ecodesign for Sustainable Products Regulation As IDunion consortium partners we highly appreciate the conclusions made and efforts done regarding the upcoming digital product passport regulation.
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The main objectives of this regulation are to reduce the negative life cycle environmental impacts of products and improve the functioning of the internal market. The Free Software Foundation Europe supports that goal and wants to highlight specific necessary regulations to reduce the negative life cycle environmental impacts of electronic products in particular: As outlined in Articel 5.1, ecodesign requirements…
In general, HKI supports the Ecodesign instrument which already delivered for EU consumers, industry and the planet by taking due consideration of all aspects of the life cycle of the product, setting measurable and enforceable requirements and based on the proportionality principle. It is the impetus to develop standardized methods that enable appliances and machines to be better compared.
EXPRA calls for regulatory consistency across Circular Economy legislations Input to call for feedback on the Ecodesign for Sustainable Products Regulation (2022/0095(COD)) EXPRA backs the ambitions set by the European Commission’s Proposal for an Ecodesign for Sustainable Products Regulation (ESPR).
FENA, representing the European furniture retail sector, supports the EU's ambitious sustainability goals. On 30 March 2022, the European Commission presented its strategy and concrete proposals to strengthen the circular economy. According to these, sustainable products are to become the norm in Europe. Furniture is also in the foreground, as it has a strong impact on the environment.
BSEF, The International Bromine Council, attaches the enclosed position paper on the EU Regulation on Eco-design for Sustainable Products. A summary of the key messages are as follows; • Develop a new methodology for the ESPR • Put in place a representative Eco-design Forum • Avoid duplication of existing chemical regulation for substances • Promote scientific-based Green Public Procurement criteria Thank you in…
Euralarm, the European association representing the electronic fire safety and security industry, welcomes the opportunity provided by the European Commission to give feedback on the proposal for ESPR. We generally support the proposal but also wishes to raise some comments, concerns and proposals. Orgalim’s position paper on this same initiative provides general considerations that Euralarm supports.
[See industriAll Europe's complete feedback in attachment] Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europe’s industrial workforce at European Level.
COTANCE, the representative body of the European Leather-Making Industry, welcomes this opportunity to give its feedback to the Commission Ecodesign proposal. Leather is the material that results from the recycling of hides & skins which arise as a residue (ABP) during slaughter of animals for human consumption. It is a perfect example of the circular economy.
Back Market welcomes the European Commission's proposal on ESPR. However, we fear some of its provisions may threaten the viability of the second-hand market, and that of refurbishment in particular. Indeed, the current definition of refurbishment proposed by ESPR does not matches the characteristics of this practice.
RREUSE welcomes the revision of the Ecodesign Directive through the Sustainable Products Initiative (SPI) as a major opportunity to enhance product sustainability and to pave the way for a transition towards sustainability within European markets. We strongly defend the need to take eco-design seriously across all products placed on the European market.
For full details, see our attached paper The EEB welcomes the transformation of the current Ecodesign Framework Directive into a new Ecodesign for Sustainable Products Regulation. We think it clearly reflects the ambition of the EU to make sustainable products the norm (we think this should be more explicitely reflected in the article 1 on subject matter and scope, in the proposal of the EU Commission).
WEEE AUDITS Ref. Ares(2022)4469588 - 17/06/2022 Dokument: Dokument ID: Datum: PM – Comments on the EcoDesign Regulation WA-332-2022 2022-06-17 PM – Comments on the EcoDesign Regulation Author: Lennart Ask WEEE AUDITS welcomes the EcoDesign regulation but want to highlight some incorrect use of terminology, primarily related to the Waste Framework Directive.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Federation of Corrugated Board Manufacturers (FEFCO) welcomes the European Commission’s first package of the Circular Economy Action Plan 2.0. The proposal for a regulation on eco-design for sustainable products has the potential to significantly influence the environmental impact of products placed on the EU market.
CEMEP welcomes the draft Ecodesign for Sustainable Products Regulation (ESPR) as presented by the European Commission on 30 March 2022. CEMEP believes that the draft regulation will support further development of sustainable products and markets, and we strongly encourage a common European ap-proach to this important field.
Stockholm, 15. June 2022 Nordic Ecolabelling feedback on the EU Commissions proposal to extend the existing Ecodesign framework Thank you for the proposal to extend the existing Ecodesign framework and the possibility to give feedback.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
APPLiA is a Brussels-based trade association representing home appliance manufacturers in Europe. Our membership includes 24 Direct Members who are leading global companies in the sector, and 26 National Associations across Europe. The sector is an economic powerhouse, with an annual turnover of EUR 67 billion, over EUR 1.4 billion invested in R&D activities and nearly 1 million people involved.
refurbedTM is a marketplace for circular products. Our mission is to build the leading platform for sustainable products and services. refurbed provides : - Refurbished electronic devices, combining the quality and security of a new product with the sustainability and low price of a used one (40% cheaper, 70% less CO2, 12-month warranty).
Position of the Fédération de la Haute Couture et de la Mode on the Proposal for Ecodesign for Sustainable Products Regulation Founded in 1973, the Fédération de la Haute Couture et de la Mode (“the Federation”) represents over a hundred French and international brands and is the voice of the creative and high-end fashion industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
eHA’s Comments on the Sustainable Products Initiative – 13 June 2022 The electric Hand Dryers Association (eHA) highly welcomes the European Commission’s proposal for a Sustainable Products Policy Initiative (SPI). eHA is an international association comprising small and medium-sized electric hand dryer manufacturers, most of them European.
Orgalim represents Europe’s technology industries, providing innovative technology solutions which are underpinning the twin green and digital transitions and can unlock a greener, healthier and more prosperous future for the European Union and its citizens.
CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its national industry members. In the EU there are about 1000 companies, the majority of them being small and medium sized enterprises (SMEs), providing more than 150,000 direct/indirect jobs. Via the CONEBI’s national industry members, more than 600 small, medium and large companies are represented in CONEBI.
SGI welcomes the opportunity to provide comments on the proposal for an Ecodesign for Sustainable Products Regulation. SGI is a trade association representing IT wholesalers in France. Our members represent over 80% of the French IT wholesale market in value. Our member companies employ over 2.500 people in France.
The Roundtable for Reusable Containers Trays and Pallets (RCTP) is happy to submit feedback on the Ecodesign for Sustainable Product Regulation proposal. The RCTP supports the ambitions to make products in the EU market more sustainable, ensuring that waste generation is prevented and used resources are kept in the economy for as long as possible.
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TotalEnergies Corbion welcomes the “Ecodesign Requirements for Sustainable Products” Regulation, we believe it is important that a balanced and science based regulation (and subsequent measures) will help to set a level-playing field for European companies while achieving the overall goals set by the European Green Deal to reach a climate neutrality by 2050.
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This initiative aims to ensure that products placed on the EU market are more sustainable. We welcome this initiative because everything is not sustainable today. Only 2 examples will be mentioned. 1. Unsustainable obsolescence of ICT technologies.
Filed in Slovak · English published by the European Commission
Swedish Forest Industries Federation (SFIF) welcomes the European Commission’s ecodesign requirements for sustainable products as well as the establishment of overarching sustainability requirements. In the framework of the European Green Deal and the Circular Economy Action Plan, it is crucial to ensure that products placed on the European market contribute to reach the climate neutrality by 2050 objective.
Brussels, 1 June 2022 Subject: Ecodesign for Sustainable Products Regulation – EVA Comments Dear Sir/Madam, Thank you for the opportunity to comment on the proposed Ecodesign for Sustainable Products Regulation (ESPR). I am writing to you from the European Vending & Coffee Service Association (EVA) which represents the interests of the European-wide industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Sekab, a leading producer of bio-based chemicals, welcomes the European Commission’s Sustainable Products Initiative and its ambition to reduce the negative life cycle environmental impacts of products through an updated Eco-Design Directive. We are, however, concerned about the proposal to use the Product Environmental Footprint (PEF) methodology in the proposal under the eco-design requirements.
This initiative has great implications for future technology innovation and lifecycle management. And this initiative have to think about the capabilities of future possible cases. We have attached our submission for your feedback, highlighting important aspects of interoperability of Decentralized Identifiers (DIDs).
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We "Europeans for Safe Connections" welcome updating Ecodesign Directive from 2009 because we ask for it in our Europeans citizens' initiative in the Proposal 14. https://signstop5g.eu/en/solutions/protection-of-our-environment/proposal-14 Wireless electronic devices are not included in the current Ecodesign Directive which requires that manufacturers of energy-using products will, at the design stage, be obliged to…
This inititaive has broad reach with respect to future capabilities for sustainbility and asset registration and lifecycle management. It is the Decentralized Identity Foundation's position (representing our 300 organzition members) to ensure that current state technology be identified within the initiative's scope, allowing for a more interoperable, verifiable and privacy preserving capability.
However, business models of circular economy and loop closure can only be functional if the products and services are designed to be circular, e.g. be modular, repairable, upgradable, easily disassembled and separated into different parts and materials, to facilitate the exchange of defective parts, to increase the service life of products in various ways.
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1. First, this document is not "designed". meaning very technical and not easily digestible by the normal EU citizens. There should be a short version with clear content. 2. I believe that all products coming on EU market (also the ones we import, not only create), must go through a process of validation if they are recyclable, not polluting during their manufacturing, use, recycling phase at minimum.
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Dear European Commission, Dear DGs, Dear Ladies/Gentlemen, After reading this Initiative as the Commission's work program, our Association will provide the following professional information to Ms Ursula von der Leyen, President of the European Commission, to Mr Frans Timmermans EVP., to the named Directorates-Generals. TITLE OF THE INITIATIVE Sustainable Products Initiative.
ZOE-Institute for future-fit economies strongly supports the Sustainable Product Policy Initiative (SPPI) and strongly supports initiatives aiming at changing consumption patterns. To achieve the bold aim of ensuring that “sustainable goods, services and busi-ness models become the norm” transformative changes are required that tilt the playing field.
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Cummins Inc. welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment for the Sustainable Products Initiative. Cummins shares the Commission’s goals of providing more sustainable products to consumers and reducing environmental impact; this is demonstrated through the company’s PLANET 2050 sustainability strategy, which sets quantifiable goals for reducing greenhouse gas…
We welcome the potentially far reaching and inspiring approach of a complete overhaul of the Ecodesign Directive, substantially deepening and broadening it. The Ecodesign Directive has very substantially helped to improve the environmental performance of a range of important energy-using (and to some extend energy-related) products on the EU market.
Free ICT Europe Foundation(FIE) is a not-for-profit foundation actively promoting the ICT Secondary Market within Europe. Our objective is to secure the right of ownership and the freedom for consumers and businesses alike to freely choose their providers to trade, maintain and repair hardware and software. Please find our input in the attached document.
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Saint-Gobain welcomes the European Commission’s Sustainable Product Policy Initiative: sustainable products are at the heart of Saint-Gobain, a multinational company that designs, manufactures and distributes construction products and services to improve our habitat and achieve sustainable buildings.
IPC represents the electronics manufacturing value chain including printed circuit board designers and fabricators, assembly companies, suppliers and original equipment manufacturers. The global membership includes more than 6,000 company sites of which over 900 are in Europe and includes both large companies and small and mid-sized enterprises.
Plastic Change Islands Brygge 39 2300 København S Denmark Ref. Ares(2020)6812901 - 16/11/2020 Plastic Change fully support the “The Circular Economy Action Plan” and welcomes the inception impact assessment and road map for the sustainable products initiative and to make sustainable products and services the norm.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Hydro is an aluminium producer, with activities in the entire value chain. We welcome the Sustainable Product Policy Initiative (SPPI) and strongly supports initiatives aiming at driving demand towards low-carbon and circular products. We support establishing sustainability principles and common criteria, as well as improve and make available reliable information on sustainability.
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TIE, Toy Industries of Europe, welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment for the Sustainable Products Initiative. TIE’s members are reputable toy manufacturers who prioritise toy safety.
Eurima welcomes the Commission’s intention to harmonize and set a baseline of principles for a market of sustainable products in Europe. We support the objectives of the Circular Economy Action Plan in this regard as it will contribute to a fairer market and allow for a better valorisation of the more sustainable products in the construction sector.
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Dear Sir or Madam, The Circular Economy Initiative Deutschland (CEID) was founded in 2019 on behalf of the German Federal Ministry of Education and Research (BMBF) to promote Germany's transformation into a circular economy.
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The Norwegian Environment Agency welcome the sustainable products initiative. In particular, we see the importance of ensuring that product design supports the goals of longer lifetime, easy repair, and high rate of recycling where the substances of concern are removed from the material cycle.
For 25 years, eBay has enabled millions of consumers and businesses to give a second life to goods. Whether through individuals selling items online that they no longer need, or by facilitating online access to spare parts for repair, eBay can be considered a key player in the circular economy.
November 2020 Grundfos input to roadmap and inception impact assessment sustainable products initiative Grundfos welcomes the inception impact assessment and road map for the sustainable products initiative. Grundfos fully support the “The Circular Economy Action Plan” and this initiative to make new products fit for a climate neutral, resource efficient and circular economy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The international high-tech mining and minerals group LKAB has the ambition to be one of the industry’s most innovative, resource-efficient and responsible companies and hopes that the SPI can help to make the performance of frontrunners in sustainability, progressively the norm – as the Circular Economy Action Plan has announced it should.
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Climate Leadership Coalition (CLC) is a non-profit organization committed to the pursuit of carbon-neutrality through the sustainable use of natural resources. During the first six years CLC has become the largest European climate business network when measured by the number of members.
We at DSM thank the European Commission for the chance to comment on the inception impact assessment of the Sustainable Products Initiative (SPI), which is an important next step to enhance Europe’s market for high-quality secondary raw materials and circular products. As the new Circular Economy Action Plan rightly points out, the performance of frontrunners must become the market benchmark and standard.
BIBM supports the objectives of the Sustainable Product Policy Initiative (SPPI) within the new Circular Economy Action Plan, one of the action plan’s most important initiative to shift towards a well-functioning European market for secondary raw materials and circular products.
FOUR PAWS feedback on the Sustainable Product Initiative’s Inception Impact Assessment FOUR PAWS / VIER PFOTEN welcomes the Commission’s intention to further develop the sustainable products policy and the opportunity to provide feedback to the Inception Impact Assessment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Rethink Plastic alliance welcomes the launch of the Sustainable Products Initiative (SPI) and its overarching objective to make sustainable products and services the norm. In order to achieve its overarching objective and meet the seriousness of current environmental challenges, the proposed product policy framework must be applied across all sectors of the economy in an integrated manner.
amfori, advocating for sustainable trade, welcomes a Sustainable Product Initiative (SPI) that will mainstream sustainable requirements in the EU market. Such an initiative can guide all companies towards their transition towards more circularity and provide a competitive advantage for frontrunners. Here are a few points to ensure that sustainability objectives are not diluted by administrative burden for companies.
Supporting Remanufacturing – Ref. Ares(2020)6810910 - 16/11/2020 the backbone of the Circular Economy Consultation Response to the Sustainable Products Initiative __________________________________________________________________________________ Thank you for the opportunity to comment on the Sustainable Products Initiative.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Fédération de la Haute Couture et de la Mode (“the Federation”) represents over a hundred French and international brands and is the voice of the creative and luxury fashion industry. Together with its expert task force, the Federation and its members fully adhere to the European Commission’s objectives for a more circular economy.
anois is a global design agency that specialise in design for sustainability, circularity and responsibility. This response is based on anois directors’ 50+ years working on design for sustainability, circularity and responsibility. Our director, Dr Frank O’Connor first called for a circular economy in Ireland in 1989.
The Austrian Federal Ministry of Climate Action welcomes the Sustainable Products Initiative and would like to express its comments, especially with regards to the widening of the eco-design directive, in the attached document. This document reflects the first assessment by the Austria Federal Ministry of Climate Action regarding the Inception Impact Assessment to a roadmap to a Sustainable Products Initiative.
Eurogypsum, the association representing the interests of the European industry extracting and processing gypsum, welcomes the inception impact assessment on a sustainable product policy. Gypsum is a cost-efficient, low carbon, sustainable mineral that has been used for centuries to produce construction materials such as plaster, stucco or plaster-based products.
SolarPower Europe response to Inception Impact Assessment on Sustainable Products Initiative SolarPower Europe supports the EU Commission’s effort in extending the scope of Ecodesign beyond energy related products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The video games sector shares the European Commission’s conviction that addressing climate change is one of the most critical challenges of the 21st century and welcomes the opportunity to contribute to the roadmap consultation on the sustainable products initiative.
PU Europe welcomes the opportunity to comment the roadmap on the “Sustainable Products” initiative and firmly believes that PU insulation products have a key role to play in a greener and more sustainable future. The views expressed below reuse and complement our submission to the “substantiating green claims” public consultation over the summer.
The European Union of Electrical Wholesalers (EUEW ) welcomes the opportunity to contribute its feedback to the consultation on the roadmap for the Sustainable Products Initiative (SPI). Electrification is the key measure to reduce CO2-emissions and build a more sustainable world.
16th November 2020 Position Paper The EU Sustainable Products Initiative (SPI) EDRA’s key messages on this issue are the following: 1. General remarks • Firstly, we would like to stress that we thoroughly support this initiative as we feel it is time for the EU to upgrade rules on product sustainability for the benefits of all.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Association of Medical Device Reprocessors (AMDR) appreciates the Commission’s efforts to promote a cleaner and more competitive Europe. We welcome the opportunity to provide feedback to the Inception Impact Assessment on the Sustainable Products Initiative. - AMDR strongly agrees with the Commission’s aim to widen the scope of the existing EcoDesign Directive beyond energy related products.
The EEB welcomes the initiative, a detailed draft position is included in the attached document. Here we outline the key messages: 'Make sustainable products the norm' represents the core objective of the initiative, implying transformative changes to the European market in order to address the reality that products and consumption drive environmental degradation.
Eurometaux, representing the European non-ferrous metals industry fully supports the transition to a true Circular Economy. Metals are present in various products, including those listed in the Action Plan as key value chains namely, electronics and ICT, batteries and vehicles, packaging, textiles, construction and buildings.
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)…
We thank the European Commission for the opportunity to provide comments to the inception Impact Assessment for the Sustainable Product Initiative. Teknikföretagen welcomes the EU Commission's action plan on circular economy and the initiative on Sustainable Product Initiative as it has the potential to facilitate a functioning market in Europe.
The Swedish Steel Producer's Association, Jernkontoret, welcomes the initiative taken by the EU Commission on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, as part of Circular Economy Action Plan. It is important that the three pillars of the sustainability are taken into account.
The European Bedding Industry welcomes the EU Product Policy Initiative and thanks the Commission for the opportunity to contribute. At the EU-28 level, 520 million mattresses are currently in-use and the stock is growing by 4.5 million units per year. 45.1 million new mattresses are sold annually, and 40.6 million units are disposed of annually. On average, 9 out of 10 units sold are to replace a used mattress.
CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment (IIA) on the Sustainable Products Initiative. The European Green Deal explicitly recognises the cement industry as essential to the EU economy as it supplies several key value chains.
EURATEX, the European Apparel and Textile Confederation welcomes and supports the roadmap on the Sustainable Product Initiative published by the European Commission. We are pleased to see that the European Commission is moving forward on this policy.
As a worldwide manufacturer and retailer, Decathlon is fully aware of its social and environmental responsibility. At Decathlon we strive for responsible growth that benefits both people and the planet, acting within a regenerative economy. This element is part of our corporate vision.
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The Corporate Leaders Group Europe, a leading cross-sectoral business voice convened across the EU in support of a climate neutral economy, welcomes the sustainable products initiative and the revision of the Ecodesign Directive, as we believe that the Commission should make its new sustainable product policy framework a priority legislative initiative and set ambitious environmental design parameters including on…
The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals.
Institut Bauen und Umwelt e.V. (IBU) is one of Europe’s largest programme operators for environmental product declarations (EPDs) of construction products. With its around 170 member companies and around 50 member associations at German, European, and global levels it represents far more than 3’000 producers of construction products from all sectors and of all sizes. IBU fully supports the European Green Deal.
The members of the Closed Pallet Pooling Coalition (CPPC) – CHEP/IPP/LPR - welcome the opportunity to contribute to the Inception Impact Assessment on the Sustainable Products Initiative. The Coalition welcomes the European Commission’s ambition to propose – as mentioned in the Inception Impact Assessment - a sustainable product policy legislative initiative to make products fit for a climate neutral, resource…
The main goal of the circular economy should be supported, i.e. increasing the use of secondary raw materials, and thus reducing the amount of waste directed and deposited in landfills. Creating a catalog of critical secondary raw materials toi be considered that should be governed by other / separate rules than for waste in order to increase their use.
We agree with the goals of the sustainable product policy legislative initiative (SPPI), which aims to make products fit for a climate neutral, resource efficient and circular economy, to reduce waste, and to ensure that the performance of frontrunners in sustainability progressively becomes the norm. It is clear that our societies need better products.
Cosmetics Europe welcomes the opportunity to engage with the European Commission. We consider the following aspects are critical elements for the upcoming European Commission policy discussion on the Sustainable Products Policy Framework: • Overarching product sustainability principles should be clear, objective and adaptable to the wide variety of product categories.
European Organisation of the Sawmill Industry aisbl Feedback to the Sustainable Products Initiative Inception Impact Assessment EOS, the European association representing the interests of the European Sawmill Industry, hereby submits its comments on the Inception Impact Assessment of the Sustainable Products Initiative.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
European Aluminium represents the entire value chain of the aluminium industry in Europe. The European aluminium industry strongly supports initiatives aiming at developing more sustainable products. To do this in the most effective way and in line with better regulation principles, European Aluminium would like to make the following recommendations: 1.
ZERO WASTE EUROPE RESPONSE TO THE SUSTAINABLE PRODUCT INITIATIVE Zero Waste Europe (ZWE) welcomes the European Commission’s commitment to develop a Sustainable Product Initiative as part of the Circular Economy Action Plan (CEAP) and the opportunity to provide its recommendations in line with our vision to create a zero waste Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CEI-Bois We are a responsible Industry Feedback to the Sustainable Products Initiative Inception Impact Assessment 16 November 2020 CEI-Bois, the umbrella Confederation representing the European Woodworking Industry, wishes to submit its comments on the Inception Impact Assessment of the Sustainable Products Initiative.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Sustainable Products Initiative builds upon Circular Economy Action Plan and intends to extend the scope of the Ecodesign Directive. While not addressing directly the policy objective, the revision Methodology of Ecodesign of Energy Related Products (MEErP) is paving the way for the Sustainable Products Initiative and the Circular Economy by considering the inclusion of material efficiency and ecological profile…
Inception Impact Assessment for Sustainable Product Initiative We thank the European Commission for the opportunity to provide comments to the Inception Impact Assessment (IIA) on the Sustainable Product Initiative (SPI). The Confederation of Swedish Enterprise welcomes the European Commission's action plan on circular economy and the SPI.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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The TÜV-Association welcomes the Commissions initiative to develop an initiative for more sustainable products and would like to provide feedback on the following issues. Establishing and enforcing EU’s sustainability rules Currently, there is no comprehensive set of requirements for a more sustainable product policy within the EU. Existing instruments are either limited to certain resources (e.g.
The European Recycling Industries' Confederation (EuRIC), representing the interests of the European recycling industries, welcomes the Commission's ambitious Sustainable Products Legislative Initiative to connect the dots between the design and the end-of-life (EoL) phase of products, be them products having a short a long lifespan.
Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding the Commission’s Sustainable Products Initiative. JBCE supports the EU’s target to achieve climate neutrality by 2050 and JBCE has committed to the European Commission’s objective to ensure that products placed on the market contribute to the circular economy transition.
The European Green Deal and the New Circular Economy Action Plan have set out a historically ambitious agenda for environmental policy. DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver innovative products and services in a sustainable way.
We welcome the Sustainable Product Policy Initiative’s intention to assess the true environmental impact of products and correct existing market failures which do not take into account their externalities. The current EU policy framework needs to be amended to reflect the true cost of all products.
Position Paper 16 November 2020 Contribution to Roadmap on Sustainable Product Initiative Introduction The shift from a linear to a circular economy is both a challenge and an opportunity. Being in daily contact with consumers and handling millions of products per day, retailers and wholesalers have embarked on the challenge to shape this societal change.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
RREUSE welcomes the release of the “Sustainable Products Initiative” inception impact assessment. Ensuring durability, reusability and repairability is essential to improve the quality of products placed on the EU market and, in the long run, of second-hand products.
The Spanish Steel Association, UNESID, in representation of the Spanish Steel Industry welcomes the opportunity to give feedback on the Inception Impact Assessment of the Sustainable Products Initiative. The European Green Deal has defined ambitious aspirations that will entail a converging point in the European economic system.
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The views of the EU steel sector about the objectives, policy options and the likely impacts presented in the Roadmap can be summarised as follows. 1. Eco-Design – Circularity Requirements at the Design Stage - Eco-design can effectively act as instrument for plugging-in sustainability into products - The scope of Eco-design has to be widened - A set of minimum sustainability criteria should be defined and…
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CO2 Value Europe very much supports the EU’s goals to increase the circularity of the EU’s economy, while preserving its natural environment and supporting the contribution of the EU’s industry to achieve a climate-neutral continent. As a consequence, we welcome the Sustainable Products Initiative.
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The Eco-Design Directive can be a more powerful instrument in greening and creating a market for sustainable products. Its scope has to be widened in order to cover a larger number of products and to set minimum conditions for products sustainability (overarching principles).
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We thank the European Commission for the opportunity to provide comments to the IIA on SPI. We are a working group for the use of Circular Design as a tool to meet the challenges of a Climate neutral industry within the Swedish Government’s innovation partnership program.
Inception Impact Assessment for Sustainable Product Initiative We thank the European Commission for the opportunity for TEKO, the Textile and Clothing Industries` Association to provide comments to the IIA on SPI.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Reusable Packaging Europe (RPE) fully supports the European Commission in its ambition to widen the scope of the Eco-design Directive and promote sustainable packaging (design), and calls on the Commission to respect the respect the waste hierarchy in doing so, thus promoting reusable (transport) packaging.
Verband der deutschen Lackund Druckfarbenindustrie e.V. VdL-Position zur Initiative für nachhaltige Produkte Der Verband der deutschen Lack- und Druckfarbenindustrie e.V. (VdL) unterstützt jede sinnvolle und wirtschaftlich tragfähige Initiative zur Verbesserung der Nachhaltigkeit. Daher möchte der VdL die Gelegenheit wahrnehmen, Position zur Initiative für nachhaltige Produkte zu beziehen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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ArcelorMittal France, welcomes the initiative on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, once the three pillars of the sustainability are taken equally into account for controlling and removing, to the extent possible, trade-offs. It is also important to recognise that EU products policy will also have an impact on the economic aspects.
SSAB supports the objectives set out in the EU Green Deal. SSAB's plan is to convert to a fossil-free steelmaking process based on the hydrogen-based HYBRIT technology, developed by SSAB together with our partners (LKAB and Vattenfall) within the framework of the HYBRIT initiative. SSAB's ambition is to be the first to offer fossil-free steel to the market as early as 2026.
Orgalim, representing Europe's Technology Industries, welcomes the Commission’s sustainable product policy legislative initiative as a key measure to further optimise the way resources are used throughout the economy and society. Please find attached Orgalim views and recommendations on the Sustainable Products Initiative.
Comentários à consulta pública sobre a Avaliação de Impacto Inicial da Iniciativa Política em matéria de Produtos Sustentáveis As empresas consideram esta iniciativa como uma das iniciativas legislativas mais importantes do novo Plano de Ação para a Economia Circular, para promover um mercado operacional na Europa para matérias-primas secundárias e produtos circulares.
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission’s roadmap to make products on the European market more sustainable. We would like to take this opportunity to recommend embedding the following sustainability considerations into the Sustainable Product Initiative (please, see our detailed contribution in attachment): - Expand the scope of the Ecodesign Directive and sector…
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Fur Europe welcomes the inception impact assessment on the Sustainable Product Initiative (SPI). The European fur industry sees the SPI as a major opportunity to foster the shift of European businesses towards full circularity by removing present obstacles and fostering best practices and features of the industry.
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The VCI represents the politico-economic interests of around 1,700 German chemical companies and German subsidiaries of foreign businesses. In 2019 the German chemical industry realised sales of over 198 billion euros (equal to 1/3 of the European chemical industry) and employed around 464,000 staff.
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The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association, pinfa, www.pinfa.eu supports the objective of the Sustainable Products Initiative (SPI) to move forward product sustainability, circularity and energy and materials efficiency, including addressing chemicals.
The Forest Stewardship Council (FSC), the pioneer of forest certification with nearly 50 million of forest hectares certified in Europe, strives to support the EU Commission in making products more sustainable. In this framework, FSC recommends the following: 1. Design for renewables: incentivising renewables materials to decarbonize the economy. 2.
Hesus warmly welcomes the Sustainable Products Initiative and the Commission’s ambition to establish sustainability principles linked to environmental aspects. Yet, we regret that the Roadmap does not mention the construction and building sector, despite the fact that it is identified as one of the key product value chains in the New Circular Economy Action Plan (Section 3.6).
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YASKAWA Europe welcomes the European Commission’s new Sustainable Products Initiative and strongly encourages a common European approach to this important field. YASKAWA Europe is company of people pursuing their passion – driven by the vision of a smarter future with advanced technologies that save precious time and energy. For us, any given day is a new chance to make progress.
Euromines members are committed to facilitating and encouraging the promotion of safe use, recycling and disposal of products through an understanding of their life cycles. Primary production of metals and minerals, which remain abundant, will play an important role in delivering the European Green Deal and increased sustainable supply from European sources will be needed to make the sustainable transition: •…
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Legislative incentives for product-service systems as a holistic approach to product sustainability We, the Berlin regional group of the Cradle to Cradle NGO, support the Commission’s initiative. To increase the initiative’s potential impact, we would like to propose the creation of additional legislative measures.
The Fair Trade Advocacy Office (FTAO) welcomes the opportunity to participate in this public consultation. The FTAO speaks out on behalf of the Fair Trade Movement for Fair Trade and Trade Justice with the aim to improve the livelihoods of marginalised producers and workers in the South.
Assofibre CIRFS Italia, representing the man-made fibres producers within Federchimica (Italian Federation of the chemical industry), welcomes the opportunity to express some first considerations on the development of the Sustainable Products Initiative.
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The paper & board converters welcome the Sustainable Products Initiative of the European Commission aiming to establish sustainability principles and leading the way to a cleaner and more competitive Europe. The sustainable products policy could be a real driver for circularity starting from resource efficiency to the products’ end-of-life. Please see more detailed feedback in the attached document.
The Nappy Alliance welcomes the European Commission’s proposed new Sustainable Products initiative, and is grateful for this opportunity to provide feedback to the roadmap. The EU has long been a leader in sustainability and it is important that this trend continues.
The Belgian federal Public Service Environment supports the idea of a future legislative Sustainable Product initiative. However we beleive this initiative should be the core element of a broader overarching/umbrella framework. Our views regarding this aspect are developped in the attached document.
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Sympatex wholeheartedly welcomes the Sustainable Products Initiative of the European Commission, as it clearly focusses on making the EU economy “future-fit”. The Covid-19 crisis has slowed down an ever-accelerating process of economic growth that has started to threaten human survival not only in the long, but even in the short term.
EFPIA, the research-based pharmaceutical industry is supportive of the European Commission initiative to increase product sustainability as indicated in the roadmap for the Sustainable Products Initiative. We would like to contribute to the policy debate with recommendations that aim at safeguarding the future access to care for patients and at improving human health.
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iFixit welcomes the Sustainable Products Initiative that aims to make sustainable goods, services and business models the norm. We strongly support reducing the environmental footprint of products on the EU market, introducing sustainability principles and extending product lifetimes with more durable and reparable products.
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The Ministry of Infrastructure and Water Management of the Netherlands strongly supports the Sustainable Products Initiative (SPI) and its goals to make sustainable goods, services and business models the norm on the EU market, and to make consumption patterns more sustainable. We call on the Commission to deliver SPI without delay.
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The testing, inspection and certification (TIC) sector welcomes the sustainable products’ initiative. TIC Council members provide services that help manufacturers assess the compliance of their products with all legislation, including on energy, resource efficiency, traceability, social compliance and safety.
MCEC supports the policy goal to create a circular economy in Europe, focusing on enhanced reusability and recyclability of products. However, we would like to stress that references to hazardous chemicals should be better defined in the initiative. Many chemicals need to have hazardous properties to ensure action efficacy.
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In order to combat the gradual increase in waste generated by human activities, action must be taken simultaneously on several fronts, in accordance with the waste hierarchy. Syctom supports the introduction of principles aimed at improving the durability, re-use and reparability of products while combating planned obsolescence and the unnecessary use of single-use products.
Filed in French · English published by the European Commission
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Kraiburg Austria, as a long-standing, well-established specialist in tyre retreading in Europe, warmly welcomes the projects presented in the Sustainable Products Initiative! We agree with the comments of various industry associations for tyre retreading, such as BIPAVER. we would also recommend that tyres be added as a further example alongside Electronics, ITC, Textiles... in ‘B.
Filed in German · English published by the European Commission
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Madam, Sirs, Brussels Consulting has several clients who are determined to be fully supportive of the overall objectives of the Commission’s circular economy initiative(s). The company and its clients continue to believe that one of major legacies of the von der Leyen Commission could be the achievements in this regard, though yet to come.
The European Panel Federation (EPF), warmly welcomes the Inception Impact Assessment on the Sustainable Products Initiative and the review of the Ecodesign Directive. The wood-based panels industry believes that this initiative will be a key element in implementing a coherent framework allowing for achieving the objectives of a resilient circular economy and climate neutrality while strengthening the role of…
November 13, 2020 Ref. Ares(2020)6694986 - 13/11/2020 LOBU DI-2019-19128 Ref.Ares (2020)4754440 European Commission Confederation of Danish Industry (DI) response to Sustainable Products Initiative DI is grateful for the opportunity to let our opinion be known on this inception impact assessment on the Sustainable Products Initiative.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Copper Institute (ECI) welcomes the EC's ambition for a sustainable product policy framework, to decouple economic growth from environmental & climate impacts. We believe a holistic, life-cycle management approach, from product design to efficient recycling, with reliable, relevant and verifiable environmental information, fulfilling appropriate product sustainability requirements, is the most viable…
We welcome the opportunity to provide feedback to the Commission’s Roadmap on the Sustainable Products Initiative. The European chemical industry is highly committed to bringing products to the market that are safe and have a low environmental impact, while maximising value for the consumers and the society. Innovation continues in search of more resource efficient and circular products.
COMMENTS 13 November 2020 INCEPTION IMPACT ASSESSMENT ON SUSTAINABLE PRODUCT POLICY INITIATIVE (SPPI) We thank the European Commission for the opportunity to provide comments on the inception impact assessment of the Sustainable Product Policy Initiative (SPPI).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Construction Products Europe shares the views of the EC about the need to build a fairer, greener and more digital Europe. Our industry worked during the last years to accomplish these goals under a European approach considering that the environmental performance of construction products only make sense in the context of the building or the construction works (the final "product").
FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Sustainable Products Initiative”. While this initiative is not directly focused on the products we are representing, we guess that its overarching sustainability principles will concern all sectors at a later stage and thus we would like to express a few remarks on it: - We need harmonized rules and a…
In order to speed up the ecological transition, the environmental impact of the use of products should be further reduced. This can be achieved by addressing businesses’ supply of more sustainable products and consumer demand. Linking the new Circular Economy Action Plan with the consultation on consumer autonomy in the green transition is a relevant approach.
Filed in French · English published by the European Commission
The Sustainable Products Initiative (SPI) offers the possibility to introduce effective, enforceable and holistic sustainability requirements for products in the EU. It is relevant for a wide variety of products, but particularly for emissions-intensive commodity products.
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Ecopreneur.eu, the sustainable business federation representing 3000 SMEs, welcomes the European Green Deal, the Circular Economy Action Plan and, as part of that, the Sustainable Products Initiative. We share their ambitious goals and advocate swift implementation. We also recommend additional measures because the combined policies are insufficient to meet the goals.
Swedish Forest Industries Federation (SFIF) welcomes the Commission’s action plan on circular economy and the Sustainable Product Initiative acknowledging the importance of ensuring the placement of more sustainable products on the Internal market to support Europe’s transition towards a more circular economy and achieve the goals set under the European Green Deal.
Avenue de Broqueville 12 1150 Brussels – Belgium [phone removed] [email removed] www.plasticsrecyclers.eu Thursday, 12 November 2020 Subject: Sustainable Products Initiative – Roadmap Consultation Inception Impact Assessment – Legislative Proposal Plastics Recyclers Europe (PRE) welcomes the initiative taken by the EU Commission to develop a policy framework on sustainable products to complement the Green Deal…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The German Electrical and Electronic Manufacturers' Association (ZVEI) supports key aspects of the EU Commission's Sustainable products initiative. Striving for sustainable products is rightly at the top of the political agenda. Please find our detailed comment in the attached file.
German Environment Agency 12. November 2020 German Environment Agency III 1.3 Wörlitzer Platz 1 D-06844 Dessau-Roßlau Germany Feedback to the Sustainable Products Initiative Disclaimer: Any views expressed are the views of the German Environment Agency and may not in any circumstances be regarded as stating an official position of the German Federal Ministry for the Environment (BMU) or the Federal Republic of…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s Sustainable Products Initiative and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. EAACA promotes the interests of producers of autoclaved aerated concrete (AAC) and their national associations across Europe.
FACE supports the EU Green Deal and warmly welcomes the Sustainable Products initiative. This proposal aligns with FACE green ambition by incentivizing businesses and industries to place more sustainable products on the EU market. Sustainability and the green transition have always been at the core of FACE’s advocacy.
Solvay welcomes the opportunity to provide feedback on the Commission’s Roadmap on Sustainable Products Initiative. The chemical industry is highly committed to bringing products to the market that are safe and have a low environmental impact, while maximising value for the consumers and the society. Innovation continues in search of more resource efficient and circular products.
Sustainable Product Policy – a necessity to fulfil Circular Economy Technology Industries of Finland welcomes the commissions initiative on Sustainable Product Policy. It is crucial for our industries that the sustainable product policy legislative initiative will provide a stable framework, while upholding the basic principle of technology neutrality which is a key enabler of ensuring a variety of technology…
Established in 1935, CINOA is the principal international confederation of Art & Antique dealer associations representing more than 5,000 dealer world-wide. Affiliated dealers, from 30 leading dealer associations, cover a wide array of specialties from antiquities to contemporary art. CINOA’s associate member, the International League of Antiquarian Booksellers (ILAB), represents an additional 22 associations.
The European Tyre & Rubber Manufacturers’ Association (ETRMA) and its members count around 4.300 companies in the EU, employing directly 360.000 people. ETRMA tyre company members represent 59% of the global tyre sales. We have strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres.
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EGMF - the European Garden Machinery Industry Federation - fully supports the European Commission’s ambition to realise a circular economy. The European garden and outdoor power equipment industry shares with households, municipalities, landscapers, greenkeepers, gardeners and farmers the responsibility for green area maintenance and food production.
APPLiA - Home Appliance Europe - welcomes the opportunity to comment on the EU Commission’s Sustainable Products Initiative. We support the work towards a more coherent EU policy framework for a circular economy, while preserving the single market, competition and innovation.
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BEUC and ANEC support the European Commission’s intention to set up an ambitious EU policy framework that would contribute to achieving climate neutrality by 2050 and agree on the crucial role of Ecodesign to make this happen. It is of foremost importance that sustainable products become the default choice for everyone, as to reduce the use of natural resources, prevent waste production and meet consumers’ needs.
VIPAL EUROPE AV. AMADO GRANELL MESADO 75 - 10 B, 46013 VALENCIA, SPAIN November 6th, 2020 Re: Feedback on the “Sustainable Products Initiative”, by the European Commission Vipal Europe is directly involved in the tyre business, more precisely, on supplying products for the repairing and retreading of tyres.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Ceegon fully supports the initiative to have more sustainable products in the EU. Device manufacturers should provide information about reliability and serviceability of the products sold within the EU; without this information, it may prove difficult even for conscious consumers, to make sustainable choices.
Osservazioni di Confcommercio – Imprese per l’Italia Valutazione d’impatto “Iniziativa per i prodotti sostenibili" Ares(2020)4754440 L'obiettivo generale dell'iniziativa è quello di allargare il campo di applicazione della direttiva ecodesign con particolare riferimento ai parametri dei prodotti inerenti la riciclabilità dei materiali, il rendimento energetico degli stessi e la tracciabilità attraverso passaporto…
Filed in Italian · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EFIC, the European Furniture Industries Confederation, welcomes the opportunity to provide comments on the inception impact assessment of the upcoming Sustainable Products Initiative. Please see our main considerations below and detailed argumentation in the attached document.
European Steel Association, EUROFER, welcomes the initiative on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, once the three pillars of the sustainability are taken equally into account for controlling and removing, to the extent possible, trade-offs.
We understand that at the heart of the Circular Economy Action Plan, the European Commission aims to develop a product policy framework based on sustainability. While AmCham members fully support and embrace the circular economy transition and are actively committed in closing the carbon loop, we wish to underline the need for maintaining the main principles of a legislative framework that is delivering already…
Amazon welcomes the Commission’s decision to assess options for strengthening the sustainability of EU product policy and facilitate the environmental performance of all products placed on the market in the EU. In so doing, we encourage the Commission to be mindful of the importance of an effective and flexible policy framework to facilitate and stimulate industry-led innovation for sustainability.
A.I.S.E. welcomes the objectives of the ‘Sustainable Products Initiative’. A holistic approach towards sustainability, incl. social, environmental and economic aspects should be taken, also using the potential of digitalisation. A.I.S.E.
Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to ensure a competitive, circular, sustainable and safe value chain for all products placed on the Union market. Please find attached the response of the Enel Group on the sustainable products initiative.
Member of European Chemical Industry Council CEFIC Warszawa, 02.11.2020 PIPC/422/2020 Komisja Europejska DG ENV, UNIT B1 DG GROW, UNIT C1 DG ENER, UNIT C4 Inicjatywa dotycząca zrównoważonych produktów W związku z trwającymi konsultacjami społecznymi Komisji Europejskiej odnośnie inicjatywy dotyczącej zrównoważonych produktów, Polska Izba Przemysłu Chemicznego chciałaby zwrócić uwagę na poniższe kwestie, istotne dla…
Filed in Polish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Austrian Federal Economic Chamber, Wiedner [address removed], Austria, is registered with the number 10405322962-08 in the Transparency Register of the European Parliament and the European Commission. Feedback on the Sustainable products initiative November 2, 2020 The Austrian Federal Economic Chamber is the legal representative of the entire Austrian business community and represents all Austrian companies –…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 2 Nov 2020 · source
BCSD Portugal’s Feedback on the ‘Sustainable Products Initiative’ Ref. Ares(2020)6262477 - 02/11/2020 Conselho Empresarial para o Desenvolvimento Sustentável (BCSD Portugal), a Portuguese private sector stakeholder, welcomes the opportunity to give inputs to the Sustainable Products Initiative.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
SUEZ welcomes the Impact Inception Assessment on the Sustainable Products initiative and considers it is necessary to reduce carbon emissions through circular designed products. The promotion of reuse and recycling and incorporation of recycled products is key to the transition to a low carbon and circular economy.
The Confederation of the European Paper Industry (Cepi) welcome the opportunity to comment on the EU Commission’s Sustainable Products initiative, acknowledging the importance of ensuring the placement of more sustainable products on the internal market to support Europe’s transition towards a more circular economy and achieve the goals set under the European Green Deal.
With the Green Deal, the European Commission has for the first time taken a holistic approach to tackling climate and environmental challenges in Europe. The VKU warmly welcomes the Commission’s position on the circular economy and the associated sustainable product policy initiative as a key element of the Green Deal.
Filed in German · English published by the European Commission
Feedback to the Sustainable Products Initiative FNADE, the French association of environmental services companies, welcomes the commission's new initiative on sustainable products, which will lead to implement a coherent policy framework both on product environmental footprint and on consumers information.
The Thuringia Ministry of the Environment, Energy and Nature Conservation (TMUEN) welcomes the “Sustainable Products Initiative” to extend the regulatory framework of the Eco-signage Directive beyond energy aspects.
Filed in German · English published by the European Commission
The German Steel Federation (WV Stahl) welcomes in principle the European Commission's proposal for a sustainable product policy. A product policy based on the three pillars of sustainability can make a significant contribution to achieving the EU's targets in terms of, for example, climate protection, the circular economy and resource efficiency.
ECO — Verband der Internetwirtschaft e.V. and the Alliance for Strengthening Digital Infrastructures in Germany, founded under the umbrella of eco, welcome the Commission’s evaluation of the Ecodesign Directive and would like to share its experience so far in the further consultation process.
Filed in German · English published by the European Commission
After reviewing the sustainable products initiative by the European Commission, the German Textile Cleaning Association wants to highlight the contribution of the textile services industry when it comes to sustainability and the circular economy of textiles. The initiative wants to make products placed on the EU market more sustainable.
· · filed 2 Nov 2020 · source
The European Data Centre Association (EUDCA) represents the European data centre operator community. EEE (Electrical and Electronic Equipment) technologies are critical to energy transition and decarbonisation of EU and global economy.
ChemSec supports the Commissions ambition to address the prerequisites of producing sustainable products, in line with the Green Deal, the Circular Economy Action Plan and the Chemical Strategy. ChemSec is positive towards widening of the ecodesign directive beyond energy related products and the establishment of overarching product sustainability principles.To achieve useful and relevant principles it is essential…
· · filed 2 Nov 2020 · source
EPPA, The European PVC Profiles and related Building Products Association represents the manufacturers of PVC window systems suppliers in Europe. Windows are long-life constructions products, thus EPPA is committed to ensure that the environment and the climate will benefit from windows placed on the market, bringing to the market products that are durable, recyclable and safe, while having a low environmental…
The Policy Hub welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment "Sustainable Products Initiative". The transition towards a circular economy in which materials can be used and reused at their highest potential, is one of the priorities of the apparel and footwear industry. For many leading companies, it is already a key pillar of their sustainability strategy.
The Industrial Minerals Association, IMA-Europe, and its members welcome the opportunity to share comments on the inception impact assessment of the SPPI. Minerals' unique properties provide specific functions in a myriad of products and processes.
Feedback to the Commission’s Inception Impact Assessment on the Sustainable Products Initiative Summary Covestro welcomes the Commission’s Sustainable Products Initiative and its ambitious aim to make products placed on the EU market more sustainable, reducing their environmental footprint over the complete life cycle, increasing their lifespan, reducing waste and improving use rates of recycled and circular…
PlasticsEurope is a leading European trade association, with centres in Brussels, Frankfurt, London, Madrid, Milan and Paris. We network with European and national plastics associations and have more than 100 member companies, who are responsible for producing more than 90% of all polymers across the 27 member states of the European Union, plus Norway, Switzerland, Turkey and UK.
FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative on sustainable products under the European Green Deal and the new Circular Economy Action Plan (CEAP).
Dear Madam or Sir, VACO, the association for the tyre and wheel industry in the Netherlands, is delighted about the European Commission’s initiative to extent the scope of the Ecodesign Directive. Extending the scope of the Ecodesign Directive to the broadest possible range of products, and beyond energy related products, is an important step in reaching the European Green Deal as well as the European Circular…
· · filed 30 Oct 2020 · source
We, ALPLA, as a rigid plastic packaging converter, are working on to produce more sustainable packaging. Therefore, we would appreciate EU rules considering carbon and environmental footprint of packaging through its whole life cycle. These criteria need to be equally if not more important than circularity of packaging (reusability, recyclability).
· · filed 30 Oct 2020 · source
● CONTRIBUTION OF THE SOCIAL GROUP ELEVEN TO THE PUBLIC CONSULTATION ON THE SUSTAINABLE PRODUCTS INITIATIVE. The ONCE Social Group is one of the world reference social organisations for people with disabilities and also one of the largest social economy groups.
Filed in Spanish · English published by the European Commission
On the pathway towards a low-emission European society in 2050 the shift toward sustainable products is key for ensuring a zero-carbon footprint of European citizens. While the “sustainable products initiative” primarily aims to revise the Ecodesign Directive and propose additional legislative measures, we would like to highlight the importance and consequences of such regulatory changes for a long term policy…
ANIRP´s Feedback to the “Sustainable Product Initiative” of the European Commission The ANIRP – Associação Nacional dos Industriais de Recauchutagem de Pneus (The Portuguese Retreading Industry Association) represents the interest of Tyre Retreader’s in Portugal and endorses the initiative of the EU in order to create and develop more sustainable goods, services and business models, reduce waste and stimulate…
Danfoss welcomes the consulation launched by the European Commission on a Sustainable products initiative. The Ecodesign Directive has served as a useful tool for increasing the energy efficiency for energy related products and this could be further developed to support material efficiency within a broad range of product groups. Please refer to the document attached for the full position of Danfoss. Thank you.
Founded in 1963, AIRP represents the tyre retreading industry in Italy. Among its objectives, it aims to foster and follow activities in defence of industry and members, to sponsor activities supporting and increasing the importance of the tyre retreading industry socially, technically and economically, to defend and represent legitimate business interests with authorities, boards, public and private institutions…
Non toxic material cycles are key to ensure a clean and sustainable circular economy to create confidence in secondary raw materials. This happens by implementing safe and sustainable by-design requirements, but also by taking into account a few principles at the recycling phases.
· · filed 30 Oct 2020 · source
The Sustainable Products Initiative is an important step on the way towards strengthening environmental, human and workers rights in global supply chains. The European Union is a big and developed market to ask supplying industries to deliver on much important ecological and social innovation in the delivery of their products.
· · filed 29 Oct 2020 · source
These are the comments from FIEC, European Construction Industry Federation, on the Road Map on the Sustainable Products Policy Legislative Initiative. First and foremost, this initiative must not duplicate or be incompatible with the Construction Products Regulation in particular, but also with other relevant existing legislation.
· · filed 29 Oct 2020 · source
Dear Sir/Madam, we very much welcome the roadmap you have drawn up for the Sustainable Product Policy Initiative. We consider it essential to further strengthen materials and resource efficiency in the field of ecodesign, thereby reducing the environmental footprint of products regulated under ecodesign in the medium term.
Filed in German · English published by the European Commission
Fecc supports Sustainable Products Initiative roadmap and the measures proposed to assess the presence of certain chemicals in products present in the EU market. In this context we would like to raise the following points on behalf of the European chemical distribution sector and in particular the many SMEs we represent: - The synergy between the Sustainable Products Initiative and the Chemical Strategy for…
The promotion of circular bioeconomy should be considered as a key element in the strategy aimed at making products placed on the EU market more sustainable. In fact, the circular bioeconomy is the economic sector that is based on the sustainable use of renewable resources for the development of applications that are (eco)designed not to integrally substitute all the fossil-based alternatives, but to be a solution…
As a global home-furnishing brand, IKEA has a big responsibility – and a big growth opportunity – to make a large-scale, positive impact on climate and resource use by adopting a circular business model. IKEA is committed to become a circular and climate positive business by 2030.
CAN Europe welcomes the Sustainable Products initiative, and considers it a further step towards filling a considerable and important gap in the EU policy framework addressing various aspects of environmental and social challenges – from the climate and biodiversity emergencies, to resource over-consumption, pollution and substances of concern.
· · filed 27 Oct 2020 · source
ANIMEE totally agrees with the CEMEP position to this consultation, dated 9th October (ANIMEE is the Portuguese member of CEMEP). Further, we want to add the following remarks: - The measures that are planned will make the products more expensive. It is essential to think about this aspect, since the first purchase may have a value so high that it will be inaccessible to many consumers.
We welcome the European Commission's initiative to extend the scope of the Ecodesign Directive to a wider range of products within the framework of the “European Green Deal”. We appreciate the attention given to the overall life-cycle of the products placed on the EU market, in order to achieve longer product lifetimes, increase circular material use rate, reduce waste and achieve higher recycling rates.
· · filed 21 Oct 2020 · source
The announced “sustainable product policy legislative initiative” should be used to enable the European Union's environmental product policy to be a unified whole, i.e. without the coexistence of duplicate and contradictory sets of rules for the same products. The envisaged fundamental sustainability principles should take into account all aspects of sustainability, i.e.
· · filed 19 Oct 2020 · source
Dear Madam or Sir, as a local market surveillance authority we appreciate the Sustainable Products Initiative of the EU to improve the life time of products and to reduce the carbon foot print. With the given responibility for Ecodesign and Energy Label we go to enforce this legislation as best we can.
Madam/Sir, We greatly appreciate the efforts of EU for introducing PEFCR which has the potential to significantly reducing the carbon foot print all across the world. I represent International Sericultural Commission, Bangalore, India which is an inter-governmental organization engaged for the development of sericulture and silk industry across the globe.
· · filed 12 Oct 2020 · source
The actions for reducing waste, CO2, energy and raw materials is not a responsibility of individual countries but a common topic of concern and improvement. Finnish Tyre Specialists, Autonrengasliitto r.y. (ARL) supports an initiative to include pneumatic tyres in the list of products of sustainable design, production, application and end of life strategy.
· · filed 12 Oct 2020 · source
BIPAVER (Bureau International Permanent des Associates de Vendeurs et Rechapeurs de pneumatiques, The European Retread Manufacturers Association) fully supports the initiative of the European Commission to increase sustainability of products in designs, production, application and end of life strategy.
The BRV Bundesverband Reifenhandel und Vulkaniseur-Handwerk e.V. (German Tyre Retail and Vulcanisation Trade Association) represents the interests of German retreaders and tire disposal companies in addition to the tire retail branch. We welcome the fact that the scope of application of the Ecodesign Directive is to be extended within the framework of the "European Green Deal".
CEMEP welcomes the initiative to further develop the sustainable products policy and strongly encourages a common European approach to this important field. The Ecodesign Directive has served as a useful tool for increasing energy efficiency for energy related products and this could be further developed to support material efficiency and other product groups as well, while it is in the same time also important to…
We welcome the Commission’s efforts to create incentives for more a sustainable Single Market. We are confident that a solution can be found that achieves greater sustainability without damaging the interests of consumers or businesses. In this context, we appreciate in particular the attention given to SMEs in the Inception Impact Assessment to the Initiative.
IALD Contribution to Sustainable product initiative October 2020 International Association of Lighting Designers | 440 N. Wells St., Ste 210 | Chicago, IL USA 60654 | [phone removed] | [email removed] IALD Europe | Avenue de Tervueren 188a, Postbox 4 | 1150 Brussels, Belgium | [phone removed] | [email removed] 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 3 Oct 2020 · source
The term sustainable is very vague. As a result, everything is advertised with sustainability. Often individual aspects of sustainability are picked out in advertising, but this leads to confusion among customers. "Bio-based" is perceived by customers as valuable and good, even if biomass base production destroys the rainforest.
· · filed 17 Sept 2020 · source
Dear European Commission, Dear Lady/Sir, INCEPTION IMPACT ASSESSMENT After read the Inception Impact Assessment, we will briefly explain our environmental management engineer proposal below. In order to create Sustainable Products, the first step in changing the product structure is to create an environmentally friendly production method.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.