As announced in its Circular Economy Action Plan (CEAP) almost two years ago (in March 2020), the European Commission aims to make products fit for a climate-neutral, resource-efficient and circular economy through a Sustainable Products Initiative (SPI). The SPI will serve as the main instrument in a renewed European approach towards product policy. Due to its broad scope and huge impact on many sectors, Dr2 Consultants guides you through the main issues companies will have to contend with when the SPI is published, its relationship to other policies as well as further opportunities to engage with policymakers.
The European Parliament, in its Non-Legislative Own-Initiative Report on the Circular Economy Action Plan from February 2021, emphasizes the need to turn the linear “take-make-dispose” economy to a truly circular economy. It also underlines the frontrunner role it expects European companies to play in a global market. The SPI thus also presents plenty of opportunities for innovative players in the circular economy.
Sustainable Products Initiative: a broad review of the Ecodesign Directive
The Sustainable Products Initiative will revise the Ecodesign Directive (2009) and make products placed on the EU market more sustainable. The SPI is expected to move beyond the narrow scope of the Ecodesign Directive – exclusively aimed at products, such as household appliances, information and communication technologies or engineering – and to set sustainability criteria based on harmonized indicators and life-cycle assessments, such as environmental footprints, to the broadest range of products such as:
- Electronics & ICT equipment;
- Steel, cement & chemicals.
Taking into account the broadening of the scope, the European Parliament in its Non-Legislative Own-Initiative Report on the Circular Economy Action Plan similarly actively calls for the establishment of common life cycle assessment methodologies and improved data collection. Such methodologies need to take into account the full life cycle of a product, from-cradle-to grave, and the impact of sourcing semi-finished products, spare parts and by-products throughout the value chain. The close involvement of stakeholders in defining these methodologies in an open, transparent, and science-based process is crucial. Here the European Parliament explicitly opens the door for input by relevant stakeholders.
The broad review of the Ecodesign Directive also means that the Sustainable Products Initiative will be developed in close coordination with other initiatives announced in the CEAP, in particular the initiative on empowering consumers for the green transition and the initiative on the substantiation of environmental claims, both of which are expected to be announced in the second quarter of 2021.
Widened scope brings opportunities and threats
On a general level, the Sustainable Products Initiative is expected to set sustainability principles and specific requirements linked to environmental aspects of products. However, producers of priority product groups such as electronics, ICT and textiles as well as furniture and high impact intermediate products such as steel, cement and chemicals will be made responsible for providing more circular products and intervening before products can become waste (for example providing products as a service, providing repair service or ensuring spare parts availability). The impact of such far-reaching principles on producers cannot be underestimated and Dr2 Consultants can support your organization in identifying the specific aspects within the Sustainable Products Initiative which are expected to affect your business. You can learn more about our sustainability sector here.
On another note, the Commission is determined to set EU rules for mandatory sustainability labelling and/or disclosure of information to market actors along value chains in the form of a digital product passport. Such passports will foster the availability of data related to product’s content and carbon footprint and recyclability. The exact scope of such a digital passport will of course have to be determined in close cooperation with the industry, which is why Dr2 Consultants highly advises companies to actively engage with policymakers.
When it comes to a ‘right to repair’, the European Commission will most likely take heed of the encouraging language of the European Parliament in its Non-Legislative Own-Initiative Report on the Circular Economy Action Plan. Producers, not only of electronic products, will need to be able to provide free-of-charge access to necessary repair and maintenance information, including information on spare parts and software updates, to all market participants.
Finally, the Sustainable Products Initiative is most definitely expected to set more elaborate rules on the inclusion of recycled content in products, for example in packaging. In doing so, the Commission also wants to ensure that hazardous substances in production processes are tracked more thoroughly. The impact of more stringent rules can of course not be underestimated, with a potential impact on the whole packaging and recycling sector.
Legislative proposal to be published shortly
Having run a public consultation from 17 March to 9 June 2021, the Commission is expected to publish a proposal on the Sustainable Products Initiative on 30 March 2022.
Dr2 Consultants’ expertise in this area means that our international team can support you not only in engaging with policymakers during, but also after, this public consultation process. Companies should also already keep an eye out on the position of the European Parliament and Council of the EU on this topic, as evidenced by their own reports on the Circular Economy Action Plan.
Feel free to get in touch with us for more information.