Development of resource efficiency and waste management assessment methods to identify eco design requirements

Orgalime supports the general objectives of the EU’s Resource Efficiency policy and agrees that energy efficiency represents a priority topic, not only in the context of the EU’s energy and climate change policy, but also in that respect. 

We therefore also support that the Eco Design Directive in its ongoing implementation, has assessed and, where this has been identified as a significant factor, regulated on the parameters of a product’s energy and water consumption in the use phase, thereby already contributing to the EU’s resource efficiency policy objectives. 

Any further eco design parameter and methodology needs to be developed in full application of all criteria and procedural aspects of the Eco Design Directive. This is in our view not the case in the ongoing JRC study and its methodological approach. In particular, the methodological approach is not in line with article 15 of the Eco Design Directive and the requirement of demonstrating 'significant potential for improvement in terms of its environmental impact without entailing excessive costs'. 

The four resource efficiency parameters presented by JRC are in our view not promising in terms of significant environmental improvement potential from a life cycle perspective, while the proposed methodological approach ignores the existing MEErP methodology that has been particularly established for the implementation of the Eco Design Directive.