Orgalim comments on the Commission Discussion Paper about the first ESPR and Energy Labelling Working Plan

To build on the success of the existing Ecodesign Directive and ensure that the new Ecodesign for Sustainable Products Regulation (ESPR) will be successful and will not undermine the competitiveness of our industries, we recommend that the following key principles are respected when developing new ESPR requirements for products:

• The implementation should start small and simple.
• New ecodesign requirements must always follow the EU Better Regulation principles, the New Legislative Framework (NLF) and be based on scientific assessment methods through recognised standards.
• Costs for the industry must be proportionate. There must be fair competition and a level playing ensured by robust market surveillance and effective enforcement.
• Requirements should be harmonised at EU level, technology-neutral, set product-by-product and consistent across different legislations.
• The scope of the ESPR delegated acts should be limited to the product properties that are the most decisive to the environmental performance of a product/product group and trade-offs must be analysed.
• The industry should be involved in the whole process as early and as fully as possible.
• Economic operators should be given sufficient time to prepare for the implementation of new ESPR. requirements. Companies, and in particular SMEs, should be supported to comply with requirements.
• Third party verification should be used only if the nature, the type and the degree of the risks entailed to the product justify it. For Substances of Concern, implementation should be done case-by-case.
• Testing after repair which is needed for most products should be taken into account.
• Life cycle assessment methods and requirements, especially when working across sectors d materials, need to be aligned acrosss and with already existing approaches. 

The proposed horizontal ecodesign requirements require early warning and a clear-cut description of scope for companies, in particular for SMEs, to be able to implement in time. We would welcome a description of how horizontal requirements would work in practice. Contradictions between horizontal delegated acts and product-specific delegated acts must be avoided, as well as double-regulation.

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