Orgalime position paper on the draft SRM guidelines under the Ecodesign Directive

Orgalime supports Self-Regulatory Measures (SRM) as an effective tool to promote ecodesign in a cost-effective way. Not only SRMs can achieve similar and/or better targets than regulations but they allow industry to maintain flexibility in the design of products and to find the optimal balance between environmental impact, safety and performance. SRMs also allow the development of new technologies which may be hindered by legal requirements, or which would require specific exemptions/exclusions to be granted thus delaying the time to market.

For these reasons, Orgalime welcomes the support provided by the European Commission (EC) to SRMs and the intention to harmonsze and align SRMs and reporting obligations. Nonetheless, Orgalime believes that the present version of the Commission Guidelines, as presented during the Consultation Forum meeting on 12 June 2014, despite the improvements compared to previous versions, still contains elements, which may significantly increase the burden on existing SRMs and discourage other industrial sectors from promoting new SRMs.