Environment: Orgalim position on the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024

Published: 2 June 2021

Policies & Issues: Environment

To carry forward the success of the Ecodesign Directive, we recommend that the following key principles are respected when developing new sustainability requirements for products:

  • An impact assessment must always be conducted;

  • Effective enforcement and market surveillance must be secured to ensure a level playing field;

  • New requirements for products must follow the New Legislative Framework;

  • Ecodesign requirements must continue to be addressed on a product-by-product basis. There is no one-size-fits-all solution due to the huge variety of products, different types of uses of the products, etc;

  • The industry should be involved as early and as fully as possible in the process;

  • The “SMERC" principle must be applied: requirements must be Specific, Measurable, Enforceable, Relevant and not harm the industry’s Competitiveness;

  • Requirements must be based on scientific assessment methods through recognised European or ISO /IEC/ITU international standards;

  • Double regulation both at horizontal and product levels must be avoided;

  • Product requirements should be technology-neutral.


As to the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024:

  • Lightweighting of products is one of the best options for effective design strategy regarding material efficiency. However, there are several limitations to lightweight design.

  • We support the good intention of recycled content but we have several concerns and recommendations. As long as the price of primary raw materials is significantly lower and the quality and quantities higher than that of secondary materials, we oppose a mandatory use of recycled content in products because there is no market incentive for their use. Recycled content should only focus on a few materials in the products.

  • As to the proposed ecological profile, data used to measure against this ecological profile must be harmonised at EU level, comparable, available, updated, verifiable and enforceable. Data may vary by product or by sector. There are still open questions about how this will work in practice. We agree that applying Annex I gives the possibility of a more flexible treatment.

  • Regarding durability, we support the principle of countering “planned obsolescence” on the condition that “planned obsolescence” is defined and that EU standards and guidelines are applied. The durability of a product is a complex concept. Increased product durability means conflicts with other aspects of the product. There is currently no methodology available that would allow a reliable assessment of the durability of products.

  • As to firmware and software, double regulation must be avoided, the definition of a software clarified, and the responsibilities of the different actors addressed.


We recommend only having information requirements for recycling activities concerning scarce materials and critical raw materials, and double regulation must be avoided.


To read our recommendations in full, please download the document above.


Stéphanie Mittelham
Manager - Green Transition

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