Own-Initiative Report by Rapporteur Ries on Ecodesign Implementation: key points of the European industry affected by the Ecodesign Directive today

The Environment Committee of the European Parliament is in the process of preparing an own-initiative report on the implementation of the Ecodesign Directive. As the voice of the European industry affected by the Directive in its entirety today, Orgalime has provided a number of key comments and recommendations:

• As the Ecodesign Directive provides the EU harmonised framework for setting ecodesign requirements on energy-related products, it secures the functioning of the EU Internal Market for these products. Upholding the Ecodesign Directive as the environmental product policy tool for the sector in scope today is essential from this point of view.
• Europe’s manufacturing strength lies in quality, performance, skills and innovation rather than low-cost or low-value products. This is why our industry has been supportive of the Ecodesign Directive from the outset, and a reliable partner throughout the implementation process to date.
• We believe the given criteria of “minimising life cycle impacts”, “based on scientific evidence”, “at least life cycle costs” and “setting measurable, enforceable requirements case by case” in “big savings areas” have been the recipe for success and credibility. These should continue to apply for the further implementation on any product parameter.
• We support improving market surveillance in line with the proposed market surveillance/goods package, as this can support manufacturers’ investments and compliance efforts with ecodesign measures.
• It would be helpful to strengthen the decision-making process and adopt implementing measures individually as soon as the respective preparatory work is completed. We view the Ecodesign Consultation Forum as an example of Better Regulation: it plays an essential role in bringing together regulators, industry and other stakeholders into the decision-making process to build consensus and credibility in a transparent and inclusive manner.
• Better consistency of legislative instruments should be pursued: the trend of duplication of product requirements in different pieces of EU and national legislation negatively impacts the functioning of the Internal Market and the realisation of environmental objectives. We believe that incorporating the ecolabel criteria as benchmarks in ecodesign would be counterproductive and remove the rewarding effect of the ecolabel. Moreover, sufficient room and flexibility for further innovation should remain in place at the top end.
• If the scope of the existing Ecodesign Directive were to be extended beyond energy-related products, the existing framework of the Ecodesign Directive must be maintained for these products to guarantee legal certainty, investment certainty, and confidence and trust in the market in the ongoing implementation.

Download the position paper to read our comments in full.