Common position of the Council on a proposal for a framework directive for the setting of eco design requirements for energy using products (EUP)

Published: 17 December 2004

Policies & Issues: Environment

On 29 November 2004, the Council has adopted its common position on the eco design of energy using products directive (EUP) - an extremely sensitive issue for our industry.  When legislating in the field of environment product policy, it is all the more important that the Council has endorsed article 95 of the EC Treaty as the sole legal basis of the EUP proposal in order to facilitate a fully harmonised approach cross Europe.

Orgalime believes that the Council has shaped the EUP proposal in many areas of importance in a balanced and pragmatic manner (e.g.: introduction of a stakeholder forum and a working plan, clarifications introduced into annexes I and V, priority for alternative courses such as self regulation or the rejection of the top runner approach).

In some areas though, Orgalime feels that uncertainties remain and encourages the European Parliament to provide the necessary clarifications in its second reading.  These areas particularly concern the free movement of products for which no implementing measure was found necessary and for products below a sales volume of 200.000 units, the definition of the "manufacturer", the application of New Approach principles, certain aspects of article 12 and conformity assessment procedures.

References: COM/2003/0453 final

Related Position Papers

Green Transition: Joint Business statement on the Corporate Sustainability Due Diligence Directive (CS3D) [30 May 2023]

Green Transition: Joint Business Statement on the due diligence proposal (CS3D) [19 January 2023]

Environment: Orgalim preliminary key messages for the upcoming revision of the EU Waste Framework Directive Orgalim [11 August 2022]

Environment: Position and recommendations from Europe’s technology industries on the proposed Ecodesign for Sustainable Products Regulation [1 June 2022]

Environment: Orgalim position paper on the upcoming revision of the RoHS Directive [31 May 2022]

Environment: Orgalim position on the upcoming revision of the REACH Regulation [13 April 2022]

Environment: Orgalim Position Paper on the “right to repair” [5 April 2022]

Environment: Orgalim Position Paper on the restriction of PFAS [27 January 2022]

Environment: Orgalim Position Paper on the draft French Decree on consumer information for waste-generating products [21 December 2021]