Orgalime comments on draft EuP Methodology Study

Published: 21 October 2005

Policies & Issues: Environment

At present, VHK is carrying out a study on an EuP methodology on behalf of DG Enterprise & Industry.  The stated aim of the study is "to contribute to the creation of a methodology allowing to evaluate whether and to which extent various energy using products fulfil certain criteria (listed in atricle 15 of the directive) that make them eligible for implementing measures under the Eco Design of EuP Directive 2005/32/EC".

In principle, Orgalime supports the development of such a methodology in the interest of more legal certainty and consistency.  Nevertheless, we believe that in order to enable the effective and correct use of the EuP methodology, a number of essential improvements are necessary since the present draft final report includes significant uncertainties.  In some areas, the present draft final report also seems to predict certain steps and to go beyond its stated aim.

We provide more details on the areas where we see that these concerns are particular evident in this position paper. Detailed information on the VHK study is available at www.eupproject.org.

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]