Where to start addressing the EU’s upcoming ecodesign regulation

 

Ecodesign for Sustainable Products Regulation

The European Council recently finalised the Ecodesign for Sustainable Products Regulation (ESPR) to encourage businesses to contribute to a more circular economy. Anyone who will be impacted should consider kick-starting their preparation now, argues Lars Rensing, CEO of Protokol.

The mounting waste our society and businesses across sectors are contending with is well documented and widely acknowledged. In 2020 alone, 4.8 tonnes of waste was generated per EU inhabitant and approximately 32.2% of it was sent to landfill.

As a natural offshoot of its Circular Economy Action Plan (CEAP), the EU is introducing the Ecodesign for Sustainable Products Regulation (ESPR), a framework that will set the design requirements of products to ensure their sustainability.

The regulation will apply to select product groups that have been prioritised (seemingly due to the amount of waste they generate) including electronics, textiles, and batteries, and while most will be expected to comply by 2030, some (such as batteries) will be expected to comply sooner, by 2027.

Any business placing products within these groups in the EU market will need to comply. One of the requirements of the regulation is the implementation of Digital Product Passports (DPPs), which may be a new concept for some businesses but will be central to the success of the EU’s efforts.

What is a DPP and what does it have to do with sustainability?

digital product passport

For those who haven’t come across DPPs before, they are a tool used to collect and provide access to data about a product throughout its entire lifecycle.

They are typically used to host data about a product’s sustainability credentials, such as its composition, information on how to recycle or dispose of it sustainably, or the carbon footprint of that product.

This is what makes them the chosen tool to support the EU’s efforts and why they have been championing them for some time.

If we think of a sofa as an example, a DPP would be in the form of a data carrier such as a QR code or barcode placed somewhere on the item, and information about it would be accessed through a smartphone.

This information could include the carbon footprint of the production of that sofa (e.g. the raw materials used to create it), so consumers can use that information to make purchasing decisions, and even how to correctly dispose of the item once it comes to end-of-life so suitable parts of it have the opportunity to be recycled.

If we think of electronic items, they can often contain hazardous materials, such as lead or mercury, so giving consumers this information not only increases the opportunity for circularity but also reduces the environmental and potential risks or health impacts of incorrect disposal.

So what now? How do I prepare for the directive?

EU

While the regulation framework has just been finalised, at present, we are still waiting for some of the details of the directive to be outlined.

These will take the form of delegated acts which are expected to outline the exact requirements for product groups impacted, including what information will need to be available via the mandated DPPs.

With this in mind, businesses looking to prepare should today begin with an internal education initiative. This could be assigning one person or a group of people with the responsibility of researching and understanding as much information as is currently available about the directive at present.

From here the business will begin to see what aspects of the current set-up are likely to be impacted. Some of these will be fairly clear or possible to answer now even without the delegated acts.

For example, there will be a need to consider the logistics of implementing DPPs, understand as much as they can about DPPs or who could support implementation, and map out the supply chain to see where data may potentially need to be gathered.

sofa
If we think of a sofa as an example, a DPP would be in the form of a data carrier such as a QR code or barcode placed somewhere on the item.

Every organisation is going to be in a completely different shape, and compliance will take a different path, so understanding the starting point for your business specifically will be important, and set you up for the next stage of preparation.

From here the business will begin to see what aspects of the current set-up are likely to be impacted.

Once more information on the delegated acts becomes available, the business will be in a better starting position to craft a strategy knowing exactly where they need to source information within their supply chain, and where they will begin their DPP journey.

Those who seek out help from specialist DPP consultants from the outset and work with them to understand what compliance will look like for their organisation specifically, and even to support in the creation of their strategy will be a particularly confident position and beneficial starting point.

For the organisations that own the product groups that will be affected, it might seem like there is an onerous task ahead of them, but, just like for many companies that already have sustainability goals in place, it can be seen as a catalyst to support existing efforts.

To ensure that it doesn’t reach a pressure point, companies that know they will be impacted will do well to begin as much preparation as they can now. You’ve already made a great start by reading this article.

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