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

Published: 16 January 2012

Policies & Issues: Environment

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.

Related Position Papers

Environment: Orgalim views and recommendations on the Sustainable Products Initiative [16 November 2020]

Environment: Orgalim position paper on the new Circular Economy Action Plan [15 October 2020]

Environment: Orgalim executive summary of the position paper on the new Circular Economy Action Plan [15 October 2020]

Environment: 40 industry organisations call for urgent actions to postpone the legal obligations to the ECHA SCIP database [21 September 2020]

Environment: Joint industry statement on the impact of restricting primary batteries in Europe [15 September 2020]

Environment: Orgalim calls for an impact assessment and a delay of implementation of ECHA SCIP database [30 June 2020]

Environment: Orgalim comments on the development of sustainability requirements for batteries under a New Regulatory Framework for Batteries [26 June 2020]

Environment: Wastewater matters too: Orgalim’s recommendations for the revision of the Urban Waste Water Treatment Directive [22 May 2020]

Environment: Think Blue: Orgalim recommendations for the improvement of the Water Framework Directive [22 May 2020]