June 21st, 2022
Our Comments on the Proposal for a Regulation establishing a framework for setting
ecodesign requirements for sustainable products and repealing Directive 2009/125/EC
Dear Sirs,
The Japan Machinery Center for Trade and Investment (“JMC”) is a non-profit organization withthe character of a public-interest corporation. It was established in December 1952 in accordance with
the Japanese Export and Import Trade Law under the authorization of the Minister of Economy, Tradeand Industry of Japan. The objective of the JMC is to engage in activities that enhance the common
benefit of member companies and promote the sound development of international trade andinvestment by the machinery industry. JMC comprises member companies engaged in machinery andsystems-related exports and foreign investments such as machinery manufacturers, trading houses andengineering companies. At present, the total number of JMC member companies is about 240.
Our committee handles environmental and product safety issues regarding products for tradeand is strongly concerned with overseas environment- and product safety-related regulations onproducts. From this standpoint, we would like to send our comment on the Proposal for a
Regulation establishing a framework for setting ecodesign requirements for sustainable products andrepealing Directive 2009/125/EC.
If you have any questions, please feel free to contact our secretariat (Mr. Chiaki Morikawa, E-mail:morikawa@jmcti.or.jp)).
Sincerely yours,

Yasuhiko Kanno
Chairman
Environment Law Committee

Rm. 401, Kikai Shinko Bldg., 3-5-8 Shiba-koen Minato-ku, Tokyo 105-0011, Japan
Tel : 81-3-3431-9230 , Fax : 81-3-3436-6455
E-mail : morikawa@jmcti.or.jp
URL : https://www.jmcti.or.jp

JMC comments on the Proposal for a Regulation establishing a framework for setting
ecodesign requirements for sustainable products and repealing Directive 2009/125/EC

Our industries welcome the European Commission’s Proposal for a Regulation establishing a frameworkfor setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC as a key
measure to further standardization of the way resources are used throughout the economy and society and toprevent differing legislation amongst Member States.
We would like to make the following comment in order to ensure that the implementation will be workable,
proportionate and will contribute to a circular economy.
1. Concerns over adding requirements for chemical substances to the Ecodesign Regulation, etc. foreach product group
Careful consideration should be given as to whether it is appropriate to add requirements for chemical
substances to the Ecodesign Regulation for each product group. Duplication with existing legislation should
be avoided to maintain legal validity and consistency.
Please bear in mind, for example, that ecodesign requirements for electronic displays include a ban on specificchemical substances that have caused terrible confusion for our supply chain. Such requirements should beregulated in the applicable chemical legislation. For electrical and electronic equipment, restrictions on
hazardous substances should be made in the RoHS Directive.

2. Request that the conformity assessment scheme is Module A for machinery, electrical/electronicproducts
We would like to request that the self-declaration system under Module A is to be maintained andestablished for the conformity assessment scheme under the CE marking system, including the newrequirements stipulated in Article 1.
For complex products such as machinery and electrical/electronic products covered by Module A in theexisting conformity assessment scheme of the CE marking system, proving conformity throughthird-party conformity assessment requires an enormous amount of work and cost and is not consideredfeasible from an operational point of view.

23. Information requirements accompanied with product should be in the company webpage
The information provided for in Article 7(2) and Article 21(7) should preferably be provided via
a website. It is considered a more sustainable means of ensuring rapid updating of information
as required and is more convenient and reliable to access to update rather than information accompaniedwith products.

4. Avoidance of the overlapping of existing legislation and regulations
While we understand the purpose of introducing the Product Passport of Article 8, duplicativerequirements with other EU legislation requiring disclosure of information should be avoided. Thisduplication would increase the burden on manufacturers.

5. Exemption from disclosure requirements for "presence of substance of concern"
The “presence of substances of concern” in Article 5(1)(g), which is required to be disclosed inArticle 7, “the information requirements”, should be SVHCs in the REACH regulation. While,the Waste Framework Directive (EU) 2018/851 requires this SVHC to be disclosed in the SCIPDATA BASE. Therefore, the requirements of this Article 5(1)(g) should exclude products,components, and intermediate products, as defined in Article 2, in order to avoid duplication withexisting legislation.

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