EN   EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, 30.3.2022  
SWD(2022) 83 final  
 
COMMISSION STAFF WORKING DOCUMENT  
 
EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT  
 
Accompanying the document  
Proposal for a Regulation of the European Parliament and of the Council  
establishing a framework for setting ecodesign requirements for sustainable products 
and repealing Directive 2009/125/EC  
{COM(2022)  142 final}  - {SEC(2022)  165 final}  - {SWD(2022)  81 final}  -
 {SWD(2022)  82 final}   
 
1 Executive Summary Sheet  
Impact assessment on  the Sustainable Products Initiative  
A. Need for action  
Why ? What is the problem being addressed?  
The main problem  is that consumption and production are not sustainable and not adequately addressed by 
existing EU product and internal market rules, leading to increasingly divergent national rules on the 
sustainability of products .  
Sub-problem 1 : Product design does not sufficiently take into account environmental impacts over the life cycle, 
including circularity aspects . As a result, p roducts are being replaced frequently,  involving significant energy and 
resource use in order to produce and dist ribute new products and dispose of old ones.  
Sub-problem 2 : It is still  too difficult for economic operators and citizens to make sustainable choices in relation 
to products given that relevant information and affordable options to do so are lacking . This leads to missed 
opportunities for sustainability and for value -retaining operations, limited demand for secondary materials  and 
obstacle s to the adoption of circular business models . 
Sub-problem 3 : Sub-optimal application of the current Ecodesign legislation . Although the Ecodesign Directive 
has generally been successful , its full potential is not systematically realised . Its scope is currently limited to 
energy -related products while other products also generate significant environmental impacts . Significant delays 
in the adoption of new product regulations  and lack of compliance are other key issue s that need to be  
addressed . 
What is this initiative expected to achieve?  
The general objective is to reduce the negative life -cycle environmental and social impacts of products and 
improve the functioning of the internal market . The specific objectives are:  
1. To improve products sustainability  
2. Better access to sustainabili ty information along the supply chain  
3. To incentivise more sustainable products and business models to improve value retention  
4. To improve application of the sustainable product legislative framework  
What is the value added of action at the EU level?   
In order to ensure a harmonised and well -functioning internal market across all Member States , and therefore a 
level playing field for economic operators  operating on the internal market , it is essential to put in place a 
common set of rules, which include product requirements and the obligation to provide reliable information to 
end-users. Without an EU -level initiative and its effective application, the problems assessed in this impact 
assessment will not be fully and consistently addressed  across the EU. National initiatives  (some of which are 
already underway) , while bringing certain benefits at national level, will inevitably further fragment the internal 
market and render consumer choices more complicated.  
B. Solutions  
What legislative and non -legislative policy options have been considered? Is there a preferred 
choice or not? Why?   
A range of sub-options is considered for 6 main options  and compared against the baseline (Option 1). The  
options  relate to : 
 Extension of the product scope of Ecodesign legislation (Option 2)  
 Extension of sustainability requirements for products (Option 3)  
 Sustainability information for consumers and business -to-business (Option 4)  
 Reward more sustaina ble products through incentives (Option 5)  
 Measures for circular economy and value retention (Option 6)  
 Strengthened application of the Ecodesign framework (Option 7)  
The preferred combina tion involves action on each option, including expanding the scope of Ecodesign to a 
wide range of products such as textiles , furniture  and high impact intermedia te products ; significantly 
strengthening its sustainability requirements ; introduc ing new information requirements for products , including 
the establishment of a  Digital Product Passport . Other actions include incentives by public authorities for 
sustainable product s and measures to prevent the destruction of  unsold consumer goods . Various measure s to 
strengthen the application  of Ecodesign rules are also foreseen .  
What are different stakeholders' views? Who supports which option?   
Most stakeholders advocated for a comprehensive scope for the SPI framework that includes a wide range of  
products and  takes a  whole life  cycle (LCA ) approach.  Support for an extension of the scope of Ecodesign is 
 
2 strong, with general agreement that the  sectors  identified in the CEAP1 should be prioritised, and 
manufacturers/importers in particular expressing a preference for an approach that takes product specifi cities 
firmly into account. There is general agreement (including from m anufacturers/importers, SMEs, retailers and 
waste operators ) that lack of clear, comprehensive, binding legislation, as well as lack of trustworthy information 
are all presenting barri ers to greater availability of sustainable products, as is uneven enforcement of product 
sustainability requirements . Digital Product Passport s are generally supported by clear majorities across all 
stakeholder groups . A large majority of all stakeholders (including public authorities) expressed support for 
mandatory Green Public Procurement  and agree that more incentives are required to orient demand towards  
sustainable products . Stronger  enforcement and market surveillance activities (e.g. inspections or audits) are 
seen as necessary to accompany the implementation of the SPI . 
C. Impacts of the preferred option  
What are the benefits of the preferred option (if any, otherwise main ones)?  
Citizens will benefit from wider availability of more sustainable  products  and product -related  options (such as 
repair) . The worst performing products will gradually be removed from the market resulting in  benefits such as  
improved durability , reliability  and reparability  of products.  Requirements to ensure high -quality recycling of 
products and to increase their recycled content  will contribute to boosting supply of and demand for secondary 
raw materials.  Improved availability of information on the sustainability dimension of products should facilitate 
consumer choice and complement other EU level initiatives in this area2. Measures to orient public purchasing 
power  towards the most sustainable products, ensure value retention and foster  circular economy practices will 
help green the market. Overall, there will be significant greening of the market for products, with economic and 
social benefits. There will also be material environmental benefits, including a significant reduction of  GHG 
emissions .  
 
What are the c osts of the preferred option (if any, otherwise main ones) ? 
Due to the framework architecture foreseen for SPI, overall costs of the preferred options are challenging to 
identify precisely. While  there will be certain initial costs associated with establishing the framework and 
preparing SPI measures , the most significant are likely to be incurred only after these measures are laid down  
for priority products . Overall, this means costs  for economic actors involved in product manufacturing  are likely to 
increase , with some costs passed on to consumers. The experience of t he Ecodesign Directive  is, however, that 
increased costs are more than offset by financial savings for consumers  over the long term . Under SPI, there is 
also clear potentia l for benefits from life extension and improvements in the production process. Furthermore, 
production cost increases could also be offset by savings along the value chain for other businesses.  All SPI  
measures will be underpinned by impact assessments and consultation processes that examine the costs and 
benefits to ensure proportionality.   
What  are the impacts on SMEs and competitiveness?  
Businesses including SMEs will face additional costs that will be analysed in the context of future implementing 
measures , with possibilities for mitigation considered in the accompanying  impact assessments.  Any compliance 
costs will be proportionate, and  some may be passed on to consumers  (which in turn are expected to be offset 
over time as described above) . For businesses operating across EU borders , harmonised requirements at EU 
level are likely to reduce  overall compliance costs , given that they will replace  various  existing or planned 
requirements  at national level . There will also be direct benefits to  the competitiveness of  businesses, including 
from a  shift of activity from the processing of primary towards secondary raw  materials and from production of 
products to maintenance, reuse,  refurbishment , repair  and second -hand sales , which  is expected to b enefit 
SMEs significantly  because they a re more active in these sectors.  While SMEs have suggest ed that certain  
negative impacts may stem from some  of the main measures under the preferred policy options, many also 
believe that these can be offset and bring added value  over time  (e.g. due to reduced material expenditure; 
increased customer loyalty; better access to the market for greener products; reputational benefits etc .) 
Will there be significant impacts  on national budget s and administrations ? 
There will be administrative costs for Member States as a result of the preferred options, in particular a need for 
additional human resources . Overall, t hese are not expected to be significant compared to the economic , 
environmental , and social  benefits o f the options .  
                                                 
1 https://ec.europa.eu/environment/strategy/circular -economy -action -plan_en   
2 In particular, the Green Claims Initiative  and the initiative on Empowering Consumers for the Green 
Transition .  
 
3  
Will there be other significant impacts ? 
Requirements would apply in a non -discriminatory manner to European and non -European companies, thus 
ensuring a level playing field for sustainable products placed on  the EU market . The requirements would be 
consistent with the EU’s international trade obligations.  
D. Follow up  
When will the policy be reviewed?  
An evaluation of the SPI, eight years after its entry into force , will build upon product group -specific review 
studies and examine what is and is not working well .