Comments on Ecodesign Working Plan 3 (2015-2017)

The Ecodesign Working Plan as foreseen in article 16 of the Ecodesign Directive generally represents an early warning tool for the affected industry and helps companies to prepare and plan ahead for the demanding implementation process of the Directive. 

Some 50 product groups have been identified as priority groups in the initial list of priority products of the Directive itself and the subsequent working plans 1 and 2. 

To date, work on about half of these product groups has been concluded, while the other half remains pending. There are actually still product groups from the very first priority list included in the initial 2005 Directive, which are not yet finalised; the same applies for product groups listed on Working Plans 1 and 2. In addition, where implementing measures have been adopted, reviews of more than 10 existing measures are underway due to specific review clauses in the legal text of these implementing measures. 

Instead, the success of the Ecodesign Directive should now be carried forward to the systems levels through the review of Directives 2012/27/EU (Energy Efficiency) and 2010/31 (Energy Performance of Buildings). The Industrial Emissions Directive (IED) would, in our view, also be a suitable tool for promoting the uptake of innovative technologies.