The world certainly has more than enough products available to consumers. These days, shopping centres, not to mention the internet, are full of shops selling plastic trinkets and mostly synthetic textiles. Is this sensible? Wouldn’t it be smarter to stop the manufacture of non-sustainable products and invest in sustainable commodities that are essential in our day-to-day lives? With its Ecodesign for Sustainable Products Regulation (ESPR), the European Commission aims to make sustainable products the norm on the EU markets. To truly make this goal a reality, the finalised regulation must recognise the importance of sustainable, renewable materials in circular economy.  

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The goal of the ESPR is to reduce the general environmental and climate impacts of products while reinforcing the free movement and internal market of goods in the EU. It will replace the current Ecodesign Directive and will primarily apply to all products, with the exception of a few categories, such as food. Moving forward, ecodesign requirements will be set on each step of the product’s life cycle, which is extremely commendable. The proposal includes a long list of ecodesign criteria, including reusability, repairability, energy and resource efficiency, recycled content, carbon and environmental footprint. However, one key criterion is missing: renewability. It is important to include renewability in the list of ecodesign criteria and recognise the potential of biobased products in carbon neutrality efforts.  

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The regulation must be in line with the goals of circular economy and promote the market of renewable products

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The fact that renewability is not listed in the criteria means that the proposal does not optimally support the realisation of the goals of circular economy. These goals include mitigating climate change and minimising emissions, waste and the loss of biodiversity. The design and manufacture of products in line with the goals of circular economy is based on using materials and products in as valuable a form as possible for as long as is possible. Circular economy avoids using non-renewable resources and promotes the use of renewable resources.

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The regulation also sets the requirements for a Digital Product Passport. This means product information provided in a digital format and attached to the product in a QR code, for example. It is likely that the required information will include, for example, the origins of the raw materials and components and instructions for repairing or recycling the product. Existing environmental labels, certificates, and life cycle analysis and product environmental footprint methodology could be utilised to communicate the environmental impacts.  The development and information requirements of Digital Product Passports must support circular economy, ensure high-quality information, be comparable and protect confidential information.

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Parliament voting for the regulation in July

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The European Parliament will vote on the ESPR in its plenary session on 12 July. Various committees of the Parliament have discussed renewability to various extents. The opinion of the Committee on Environment, Public Health and Food Safety (ENVI) takes renewability into account, but not in the ecodesign criteria. The Council of the European Union has recognised the importance of renewability to some extent. It is important that renewability will be included as an ecodesign criterion in the Parliament’s plenary session or in the trilogue phase at the latest when the European Parliament, the Council of the European Union and the European Commission that issued the proposal discuss the final wording of the regulation.

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If the importance of renewable materials is ignored, it will be impossible to produce an authentic image of the environmental and climate impacts of the product’s entire life cycle or promote the reduction of fossil raw materials. Replacing fossil raw materials with renewable ones is in line with circular economy, and the ESPR should also support this goal.

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