COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS On making sustainable products the norm
Date: 2022-03-30
Institutions: Directorate-General for Environment, European Commission
Subjects: carbon neutrality, circular economy, consumer protection, energy consumption, energy efficiency, environmental impact, international cooperation, producer's liability, recycled product, sustainable product

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.3.2022  COM(2022) 140 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS On making sustainable products the norm  
 
 
1. 

INTRODUCTION 

The  collision  of  major  crises  and  economic  shocks  in  recent  years  has  impacted  every 
part of the EU’s economy and society. The latest and starkest in this series – the ruthless 
and unprovoked invasion of Ukraine by Russia  – is different in nature to the pandemic 
and  recovery  or  the  evermore  urgent  need  to  respond  to  the  climate  and  biodiversity 
crises.  The  geopolitical  situation  it  has  led  to  puts  a  renewed  strain  on  people  and 
businesses  in  Europe  and  beyond,  at  times  when  the  European  Union,  Ukraine  and  the 
world at large were looking forward to building back better.  

But  these  crises  also  have  much  in  common,  and  force  us  to  question  assumptions,  to 
rethink  our  economic  model  and  to  work  on  redesigning  our  energy  system.  We  have 
again been confronted with our own dependencies and with the vulnerabilities these can 
lead  to  in  terms  of  security  of  supply,  financial  strain  on  households  and  shocks  for 
businesses whose daily operations and long-term survival are at risk. 

This points to the need to look at how we can increase the well-being of our citizens and 
ensure sustainable growth through using better the resources and the materials that make 
up  the  products  we  use  every  day,  as  well  as  improving  the  products  themselves.  By 
making products consume less energy, by using them more efficiently and for longer, by 
relying on recycled materials  instead of primary  raw materials,  and by spreading front-
runner  circular  economic  models  we  can  decouple  our  economic  growth  from  natural 
resource use and environmental degradation. By promoting a harmonised approach at EU 
level,  we  can  boost  competitiveness,  create  new  business  opportunities  and  jobs,  foster 
the  greening  of  the  single  market  in  line  with  the  sustainable  growth  agenda  of  the 
European  Green  Deal1,  enable  consumers  to  save  on  costs,  and  make  the EU  economy 
more resilient to disruptions in integrated global value chains. Moreover, it will make a 
decisive contribution to achieving climate neutrality by 2050, to halting biodiversity loss 
and to achieving our zero-pollution ambition.  

While  progress  has  been  made  in  recent  years,  the  environmental  impacts  of 
consumption  are  still  pushing  us  outside  the  safe  operating  space  for  humanity,  as  we 
exceed planetary boundaries in several ways in the EU2. Globally, half of all greenhouse 
gas  emissions  and  90%  of  biodiversity  loss  are  caused  by  extracting  and  processing 
primary raw materials3, while the still prevailing linear take → make → dispose model of 
our  economy  leads  to  significant  waste  of  resources.  For  the  EU  to  succeed  in  the 
transition to a resource-efficient, climate-neutral and pollution-free circular economy and 
reduce  its  energy  and  resource  dependencies,  we  urgently  need  a  new  approach  to  the 
way  we  design,  make  and  use  products.  The  EU  will  promote  this  approach  also 
internationally, thus strengthening the sustainability and resilience of global value chains.   

Today’s  package  of  interlinked  initiatives  on  sustainable  products,  presented  in  this 
Communication, aims to bring this new approach significantly closer to reality, building 
on  what  has  already  been  done.  The  EU  already  sets  minimum  environmental 
requirements for certain products or sectors, such as energy-related products, packaging 

1 COM(2019) 640 final 
2  Sala,  S  et  al.  (2020).  Environmental  sustainability  of  European  production  and  consumption  assessed 
against planetary boundaries. Journal of environmental management, 269, 110686 
3  UN  International  Resources  Panel  Global  Outlook  2019  –  Natural  Resources  for  the  Future  we  Want. 
https://www.resourcepanel.org/reports/global-resources-outlook  

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and  chemicals.  These  requirements  have  helped  to  substantially  reduce  the  EU’s 
environmental  and  climate  footprint,  including  energy  consumption.  For  instance,  the 
cumulative  effect  of  current  EU  rules  on  ecodesign  and  energy  labelling  means  a  10% 
lower  annual  energy  consumption  by  the  products  in  scope,  comparable  to  the  energy 
consumption of Poland4, reducing our dependence on fossil fuels, including from Russia. 
However, the existing rules cover only a limited share of the goods marketed in the EU 
and  do  not  systematically  encourage  circularity,  nor  tackle  many  of  the  ways  in  which 
products impact the climate and the environment throughout their lifecycle. Also, there is 
still significant potential to lower the energy use of energy-related products. 

This is why the proposal for a Regulation on Ecodesign for Sustainable Products5 is at 
the  heart  of  today’s  package.  As  product  design  dictates  up  to  80%  of  its  life-cycle 
environmental  impact6,  the  proposal  extends  the  scope  of  the  Ecodesign  framework  to 
cover  the  broadest  possible  range  of  products.  It  foresees  setting  minimum  criteria  not 
only  for  energy  efficiency  but  also  for  circularity  and  an  overall  reduction  of  the 
environmental  and  climate  footprint  of  products.  Until  the  new  framework  enters  into 
force,  the  existing  Ecodesign  Directive  will  continue  to  drive  improvements  in  energy 
efficiency and circularity. To that end, the Commission is adopting together with the new 
proposal an Ecodesign and Energy Labelling Working Plan  2022-2024 to cover new 
energy-related  products  and  update  and  increase  the  ambition  for  products  that  are 
already regulated.  

To  support  this,  targeted  sectoral  initiatives  --  the  EU  Strategy  for  Sustainable  and 
Circular  Textiles7  and  the  revision  of  the  Construction  Products  Regulation8  --  are 
presented as part of the package to address these two priority product groups that have a 
significant  impact  on  the  environment  and  climate.  To  ensure  that  consumers  remain 
active proponents of the transition, the Commission is also tabling a legislative proposal 
in  the  Green  Transition9 
targeted 
introduces 
to  Empower  Consumers 
amendments to ensure the necessary ‘greening’ of horizontal EU consumer law.  

that 

By bringing a common approach to products in the EU, our proposals will help to create 
a  level  playing  field  for  companies  operating  in  the  single  market  and  make  the  EU  a 
standard-setter  in  the  area  of  sustainable  products.  In  order  to  ensure  that  the  shift  to 
more sustainable products rolls out in a way that alleviates the costs and challenges of the 
transition, the selection of product groups and the setting of product-specific rules will be 
subject to long-term planning in an inclusive co-creation process, as well as to rigorous 
impact  assessments,  including  as  regards  affordability  for  consumers,  impacts  on 
competitiveness and administrative burden.  

Several  Member  States  have  already  started  to  set  environmental  sustainability 
requirements on products10 on their own and citizens are increasingly asking them to go 
further  and  faster.  This  risks  fragmenting  the  single  market  through  diverging  national 
rules, complicating and increasing the costs of doing business. Harmonised EU rules will 

4 Compared to ‘business as usual scenario’, where no ecodesign rules would be in place. Ecodesign Impact 
Accounting Overview Report 2020 
5 COM(2022) 142 
6 https://op.europa.eu/en/publication-detail/-/publication/4d42d597-4f92-4498-8e1d-857cc157e6db  
7 COM(2022) 141 
8 COM(2022) 144 
9 COM(2022) 143 
10 Please see Annex 7 of SWD(2022) 82 

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avoid  such  market  distortions,  considerably  scale  the  market  for  environmentally 
sustainable  products  and  ultimately  reduce  compliance  costs  and  administrative  burden 
for businesses operating across the EU.  

There are also many other cost saving opportunities for businesses, given the increasing 
scarcity of primary natural resources, challenges in the supply of raw materials and their 
price volatility. By re-designing business models, production processes and products, by 
making  products  last  longer  or  optimising  their  use,  and  by  participating  in  a  well-
functioning market for secondary raw materials, businesses can significantly reduce their 
costs  for  materials,  energy  and  waste  management  and  improve  their  resilience.  Social 
economy organisations have played a pioneering role in shaping and expanding circular 
economy  activities,  such  as  electronics  and  textile  recycling,  reusable  consumer  goods, 
repair  and  remanufacturing  activities.11  New  digital  solutions,  too,  open  up  huge 
opportunities to re-design business models for energy efficiency, circularity and broader 
environmental sustainability.  

Front-runner  companies  in  several  industrial  ecosystems  have  already  embraced  this 
transition.  

A  clear  and  harmonised  regulatory  framework  on  product  environmental  sustainability 
will provide the conditions for this approach to become mainstream and drive companies 
that buy and sell on EU markets to innovate and invest in circular business models and 
the products of tomorrow. 

All  this  would  significantly  extend  the  range  of  environmentally  sustainable  products 
available  to  EU  consumers  and  make  these  the  mainstream  option.  Today  the  market 
share of such products is still limited, also affecting their availability and affordability to 
consumers. But the EU’s experience has already shown that ecodesign, when scaled up, 
does  bring  notable  cost  savings.  In  2021  alone,  existing  ecodesign  requirements  for 
energy-related  products  saved  consumers  EUR 120  billion,  even  if  counting  in  the 
acquisition costs12. Many more savings could be unlocked if we remedy the problem that 
consumers are confronted with products that have a short lifespan and cannot be repaired, 
or  have  insufficient  access  to  circular  business  models.  Combining  this  with  the  right 
consumer  information  and  ensuring  protection  against  green-washing,  the  EU  would 
meaningfully  empower  its  consumers  for  the  green  transition  and  make  sustainable 
products the norm, inspiring the rest of the world to follow.  

11  OECD  policy  brief  on  Making  the  most  of  the  social  economy’s  contribution  to  the  circular  economy 
https://op.europa.eu/en/publication-detail/-/publication/be4e83a2-735a-11ec-9136-

(2022), 
01aa75ed71a1/language-en  

12 Ecodesign and Energy Labelling Working Plan 2022-2024 

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Overview of initiatives in the Circular Economy package 

2.  OUR AMBITION: MAKING SUSTAINABLE PRODUCTS THE NORM 

Designing more sustainable, circular and energy performing products 

The  proposed  Ecodesign  for  Sustainable  Products  Regulation  (ESPR)  is  the 
cornerstone  of  the  Commission’s  approach  to  more  environmentally  sustainable  and 
circular products. It establishes the framework for setting ecodesign requirements for 
specific product categories to significantly improve their circularity, energy performance 
and  other  environmental  sustainability  aspects.  It  builds  on  the  proven  effectiveness  of 
the Ecodesign Directive in relation to energy-related products and will enable minimum 
ecodesign  and  information  requirements  to  be  set  for  almost  all  categories  of  physical 
goods placed on the EU market13. For groups of products that share sufficient common 
characteristics, horizontal rules can be set. 

These  ecodesign  requirements  will  be  tailored  to  the  particular  characteristics  of  the 
product  groups  concerned.  Their  identification  and  development  will  factor-in  the 
potential for improvement and relative effectiveness in delivering increased resource and 
energy  efficiency,  enabling  longer  product  life  and  maximising  the  value  embedded  in 
materials,  reducing  pollution  and  the  overall  impact  of  products  on  climate  and  the 

13 With some notable exceptions, such as food and feed as defined in the General Food Law (Regulation 
EC No 178/2002). 

4 

 
 
 
 
                                                 
environment. The ecodesign requirements will, as appropriate for the product categories 
to be regulated, cover: 

  product  durability,  reliability,  reusability,  upgradability,  reparability,  ease  of 

maintenance and refurbishment; 

 

restrictions  on  the  presence  of  substances  that  inhibit  the  circularity  of  products 
and materials; 

  energy use or energy efficiency of products;  

 

resource use or resource efficiency of products; 

  minimum recycled content in products;  

  ease of disassembly,  remanufacturing and recycling of products and materials; 

 

life-cycle  environmental  impact  of  products,  including  their  carbon  and 
environmental footprints;  

  preventing and reducing waste, including packaging waste.  

Helping businesses and consumers to make more informed choices  

In addition to setting requirements on how products should be made, the  Ecodesign for 
Sustainable  Products  Regulation  (ESPR)  is  also  a  framework  to  set  requirements  to 
provide information on the environmental sustainability of products. Depending on 
the  product  concerned,  this  can  include  information  on  energy  use,  recycled  content, 
presence of substances of concern, durability, reparability, including a reparability score, 
spare part availability and recyclability.  

Digital  product  passports  will  be  the  norm  for  all  products  regulated  under  the 
ESPR,  enabling  products  to  be  tagged,  identified  and  linked  to  data  relevant  to  their 
circularity  and  sustainability.  Pioneering  this  approach  for  environmental  sustainability 
data can also pave the way for wider voluntary data sharing, going beyond the products 
and  requirements  regulated  under  the  ESPR.  Moreover,  product  passports  may  be  used 
for  information  on  other  sustainability  aspects  applicable  to  the  relevant  product  group 
pursuant to other Union legislation. 

Structuring information on the environmental sustainability of products and transmitting 
it by means of digital product passports will help businesses along the value chain, from 
manufacturers,  importers  and  distributors  to  dealers,  repairers,  remanufacturers  and 
recyclers, to access information that is valuable in their work to improve environmental 
performance,  prolong  product  lifetime,  boost  efficiency  and  the  use  of  secondary  raw 
materials,  thus  lowering  the  need  for  primary  natural  resources,  saving  costs  and 
reducing strategic dependencies. This will also help track the presence of substances of 
concern  throughout  the  life  cycle  of  materials  and  products,  following  through  on 
commitments made in the Chemicals Strategy for Sustainability14 and contributing to the 
EU’s aim to achieve zero pollution. Digital product passports can also enable consumers 
to  make  more  informed  choices,  improve  transparency  for  public  interest  organisations 
and help national authorities in their enforcement and surveillance work.  

14 COM(2020) 667 final 

5 

 
 
 
                                                 
The  ESPR  will  also  enable  the  EU  to  set  labelling  requirements,  for  example  on  the 
reparability of products. The new EU Energy Labels will incorporate circularity aspects, 
such as a repair score, by means of supplementary information.  For other products, the 
new  ESPR  label  will  provide  such  information.  Some  products  may  bear  both  the  EU 
Energy Label and an ESPR label, in case there is evidence that this will be more effective 
for  consumers  and  less  burdensome  for  industries.  As  demonstrated  by  the  EU  Energy 
Label15,  mandatory  provision  of  key  information  at  the  moment  of  purchase  can  be  an 
effective  way  to  inform  about  relevant  aspects  of  the  environmental  performance  of 
products, particularly when it allows an easy comparison of products in a given category.    

In parallel to and in synergy with developing product-specific rules under the ESPR, the 
Commission  will  work  on  reviewing  or  setting  new  product-specific  criteria  under  the 
EU  Ecolabel.  This  is  a  well-known  and  trusted  label  that  has  recognised  and  certified 
products with a high environmental performance for 30 years across the EU. 

Putting a stop to the destruction of unsold consumer goods 

The proposed ESPR includes measures to prevent and stop the destruction of unsold 
consumer goods. As a first step, large businesses that discard unsold products will have 
to  disclose  the  amount  of  products  they  discard  per  year,  provide  reasons  for  the 
discarded  volumes  and  information  on  the  volume  of  discarded  products  sent  out  for 
reuse, remanufacturing, recycling, energy recovery and disposal operations, in line with 
the waste hierarchy. The regulation will also provide the possibility to ban the destruction 
of unsold products entirely, depending on the product categories to be regulated.   

Promoting and procuring more sustainable products  

While  the  performance  and  information  requirements  on  product  ecodesign  will  enable 
businesses and consumers to choose more environmentally sustainable products, there is 
a  greater  role  that  Member  State’s  incentives  and  public  procurement  can  play.  The 
Commission  has  already  developed  several  green  public  procurement  criteria,  but  their 
impact remains limited as their use is currently voluntary. Therefore, the ESPR aims to 
leverage  the  weight  of  public  spending  to  boost  demand  for  more  environmentally 
sustainable  products  by  setting  mandatory  criteria  for  the  public  procurement  of 
these products, drawing where appropriate on existing voluntary criteria. This means that 
contracting authorities would  be required to  use  green  procurement criteria  to  purchase 
specific groups of products. In addition, incentives provided by Member States can be 
leveraged  through  environmental  sustainability  requirements  on  the  products  those 
incentives concern.  

3.  A CROSS-SECTORAL APPROACH TO SUSTAINABLE PRODUCTS 

The  ESPR  is  designed  to  be  coherent  and  aligned  with  existing  and  future  sectoral 
legislation and policies. Once its framework is in place, the product requirements will be 
rolled  out  following  multiannual  working  plans.  This  will  enable  the  Commission  to 
make a careful assessment of where regulatory action is most needed.  

Where environmental sustainability requirements are already set at a satisfactory level in 
EU legislation, the ESPR will not come into play. Conversely, where these requirements 

15 Regulation (EU) 2017/1369 

6 

 
 
                                                 
are  lacking,  but  the  circularity,  energy  and  resource  efficiency  potential,  as  well  as  the 
potential  to  reduce  overall  climate  and  environmental  impacts  are  high  and  warrant 
action,  the  ESPR  would  step  in.  Measures  under  the  ESPR  will  be  accompanied  by 
dedicated  impact  assessments,  to  ensure  proportionality,  due  consideration  of  the 
international  dimension  and  the  impact  on  third  countries,  as  well  as  consistency  with 
other EU legislation.  

Three different situations can illustrate how the proposed ESPR is designed to work with 
sectoral legislative and policy initiatives to accelerate the green transition.   

Creating new EU product-specific rules: the example of textiles 

For  products  where  there  is  no  specific  EU  law  setting  mandatory  requirements  on 
environmental  sustainability,  the  ESPR  will  be the  legal  framework  under  which  to  set 
EU rules. This is the case for textiles and footwear. While these products are currently 
subject  to  certain  product  requirements,  for  instance  concerning  chemicals16  and 
labelling17,  there  are  no  specific  requirements  governing  circularity,  e.g.  durability, 
reparability, recyclability and recycled content.  

Following  the  adoption  and  entry  into  force  of  the  ESPR,  and  subject  to  impact 
assessment,  this  regulatory  gap  will  be  filled  through  secondary  legislation  setting 
ecodesign performance requirements for textile products, information requirements and a 
Digital  Product  Passport.  Targeted  changes  to  textiles  labelling  will  also  be  considered 
under the Textiles Labelling Regulation18. Beyond textiles and following the same logic, 
other priority products will be identified in the first ESPR working plan (see Section 4). 

In addition, the EU strategy for sustainable and circular textiles that the Commission 
is adopting as part of this package presents a comprehensive set of actions that go beyond 
the ESPR. The aim is to transform this sector and change not only textile design but also 
boost  circular  business  models  and  reduce  textile  waste,  in  line  with  and  in  full 
consideration of the need to ensure consumer affordability and business competitiveness. 
It  also  marks  the  launch  of  the  co-creation  process  of  the  transition  pathway  of  the 
textiles industrial ecosystem. 

Complementing  existing  product-specific  EU  rules:  the  example  of  construction 
products, batteries, packaging and chemicals  

Given the wide scope of the ESPR, some products covered by it will also be subject to 
separate product-specific legislation. For these products, as a general principle the ESPR 
will only intervene when the environmental sustainability dimensions of those products 
cannot be fully and appropriately addressed by other instruments. This would make EU 
rules on specific products more coherent and avoid placing an administrative burden on 
businesses  to  meet  requirements  laid  down  in  different  EU  pieces  of  legislation. 
However,  following  the  necessary  consultations  and  impact  assessments,  specific 
circumstances  may  justify  taking  targeted  action  also  under  the  ESPR.  This  may  make 
sense when the product is part of another product (e.g. batteries), closely linked to it (e.g. 

16 Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), 
1907/2006 of 18 December 2006 and Directive on the Restriction of Hazardous Substances in Electrical 
and Electronic Equipment (RoHS) 2011/65/EU of 8 June 2011. 
17 Regulation (EU) No 1007/2011  
18 Regulation (EU) No 1007/2011 

7 

 
 
                                                 
packaging),  or  when  environmental  sustainability  requirements  for  a  group  of  products 
are laid down. 

Although construction products are in the scope of the ESPR, given the need to manage 
the close links between their environmental and structural performance, including health 
and safety, it is justified to lay down environmental sustainability requirements under the 
revised  Construction  Products  Regulation  that  is  adopted  as  part  of  this  sustainable 
products  package.  However,  in  the  case  of  energy-related  construction  products, 
sustainability  aspects  will  be  primarily  dealt  with  under  the  ESPR,  as  they  are  already 
regulated under the existing Ecodesign Directive. Still, the revised Construction Products 
Regulation may intervene in a complementary manner, where needed. The two proposed 
Regulations  include  provisions  to  maintain  close  legal  alignment  as  the  rules  are 
developed and implemented. 

The  sustainability  requirements  for  batteries  will  primarily  be  dealt  with  under  the 
proposed batteries regulation19. If the need arises to set additional specific sustainability 
requirements,  for  instance  for  specific  applications  of  batteries  in  other  products,  the 
ESPR could cover complementary aspects.  

Concerning  packaging,  the  essential  requirements  for  packaging  allowed  on  the  EU 
market  are  laid  down  in  the  Packaging  and  Packaging  Waste  Directive20  (PPWD), 
currently under revision. However, as packaging varies greatly depending on the product 
category, it should be one of the key aspects to cover when developing product-specific 
ESPR rules. This must complement, with more targeted rules, the essential requirements 
laid down in the PPWD.  

Regarding chemicals, the ESPR’s area of competence is clearly defined: it will be able to 
take  action  to  restrict  the  presence  of  chemicals  in  products  for  reasons  linked  to 
improving  the  product’s  environmental  performance  along  its  life  cycle.  This  can 
complement existing law governing chemicals, such as REACH21, the primary focus of 
which is ensuring chemical safety, or RoHS22, which covers only electrical and electronic 
equipment.  

New  EU  rules  under  the  current  Ecodesign  Directive:  the  example  of  consumer 
electronics   

Electronics is our fastest growing waste stream. Users are frustrated at how quickly their 
devices break, become obsolete, cannot be updated or repaired. Moreover, in the EU we 
recover only few of the components or materials, including critical ones23, that could be 
used again for making new products. In this context, the Commission is working on new 
ecodesign  measures for  smartphones, tablets  and laptops,  to  be adopted  as  identified in 
the working plan under the existing Ecodesign Directive. In addition to energy efficiency 
and already before the new ESPR will replace the existing framework, the measures will 
cover other key aspects  of ecodesign for circularity, notably durability,  reparability and 

19 COM(2020) 798 final  
20 Directive 94/62/EC 
21 Regulation 1907/2006 and Directive 2011/65/EU.  
22 Directive 2011/65/EU 
23 Critical Raw Materials (CRMs) are those of high importance to the EU economy and with high risk 
associated with their supply. See also: https://op.europa.eu/en/publication-detail/-/publication/d1be1b43-
e18f-11e8-b690-01aa75ed71a1  

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recyclability.  In  the  same  context,  the  ecodesign  rules  for  external  power  supplies  are 
being  revised, mainly  in view of interoperability and circular economy  requirements to 
complement  the  recent  Common  Charger  initiative  adopted  as  a  revision  of  the  Radio 
Equipment Directive24.  

In  addition  to  developing ecodesign requirements, the Commission  has also  launched a 
review of EU rules restricting the use of hazardous substances in electrical and electronic 
equipment, i.e. the RoHS Directive25 with the aim of ensuring that it meets its objectives 
in  the  most  effective  and  efficient  way26.  The  Commission  is  also  exploring  options  to 
incentivise  the  take-back  and  return  of  small  electronics  such  as  old  mobile  phones, 
tablets  and  chargers  stored  at  home.  The  objective  is  to  extend  lifetimes  and  improve 
collection of those products, thereby also boosting circular business models.   

4.  THE ECODESIGN METHOD: PLANNING, CONSULTATION, CO-CREATION  

The  EU’s  ecodesign  and  energy  labelling  policies  are  already  highly  effective  in 
delivering energy efficiency. They generate savings for consumers lower our dependency 
on  fossil  energy  imports  and  reduce  emissions  reductions.  Over  the  last  decade,  rules 
have  been  set  for  around  30  energy-related  product  groups27.  Careful  targeting  through 
the  adoption  of  multiannual  working  plans  has  been  central  to  ensuring  clear 
prioritisation,  effectiveness  and  efficiency  under  the  Ecodesign  Directive.  This  will 
continue under the ESPR, based on a sound and robust approach for identifying priority 
products.  

In order to  ensure a smooth transition to the ESPR framework, the  new ecodesign and 
energy  labelling  working  plan  for  2022-2024  is  adopted  as  part  of  this  package.  It 
ensures  that,  until  the  new  ESPR  framework  enters  into  force,  work  under  the  current 
Ecodesign  Directive  can  continue  at  pace,  bringing  further  reductions  in  energy  use  as 
well  as  material  consumption  from  energy-related  products.  Additional  products 
identified,  such  as  low  temperature  emitters,  offer  energy-saving  potential  representing 
billions  of  euro  in  reduced  consumer  expenditure.  Importantly,  the  new  working  plan 
ensures that circularity aspects are increasingly addressed to the extent feasible under the 
current legal framework.  

In parallel, the Commission intends to start work under the proposed ESPR to cover new 
products  and  new  parameters.  It  aims  to  propose  product-specific  measures  without 
delay, as soon as the new framework is in place. To ensure the right priorities are set in a 
transparent  and inclusive way, it will launch  a public consultation on the categories of 
products  to  be  selected  under  the  first  Ecodesign  for  Sustainable  Products 
Regulation  working  plan  by  the  end  of  2022.  A  preliminary  assessment  made  by  the 
Commission has identified that product categories such as textiles, furniture, mattresses, 
tyres,  detergents,  paints,  lubricants,  as  well  as  iron,  steel  and  aluminium  have  high 

24 COM(2021) 547 final 
25 Directive 2011/65/EU 
26 European Green Deal: Commission seeks views on reviewing rules on hazardous substances in electrical 
and  electronic  equipment,  https://ec.europa.eu/environment/news/european-green-deal-commission-seeks-
views-reviewing-rules-hazardous-substances-electrical-and-2022-03-10_en  
27 In 2020, it is estimated that some 3 billion products subject to Ecodesign and/or Energy Labelling 
measures were sold in the EU. This includes some 1.5 billion light sources, 880 million electronics, 350 
million tyres and 240 million other products. 

9 

 
 
                                                 
environmental impact and potential for improvement, and are thus suitable candidates for 
the first working plan.  

The  success  of  the  Ecodesign  Directive  to  date  owes  much  to  the  input  from  all  key 
players, contributing in an inclusive, open and transparent way. The ESPR will build 
on this co-creation approach, from drawing up a working plan and prioritising products, 
to  assessing  and  developing  all  new  product  requirements.  The  Ecodesign  Forum, 
building on the existing Consultation Forum under the Ecodesign Directive28, will remain 
the platform for targeted exchanges across stakeholder groups and at all key phases of the 
process, and thus bring industry, national-level and enforcement authorities to the table. 
Consultation  processes and thorough impact  assessments  will precede and underpin the 
development and adoption of product requirements. 

New  ESPR  rules  must  be  underpinned  by  sound  methodological  approaches,  so  that 
environmental  and  climate  impacts  of  products  can  be  effectively  addressed  through 
requirements  on  the  key  aspects  laid  down  in  the  ESPR.  Given  the  potential  range  of 
products  under  the  future  framework,  it  will  be  essential  to  choose  and  adapt  the  most 
suitable methodology, depending on the product or group of products in question and the 
environmental or circularity aspect targeted. This approach will build on the experience 
gained under the  current  Ecodesign Directive, which will continue to  be upgraded, and 
on  the  Product  Environmental  Footprint  method  where  appropriate.  As  a  priority,  the 
Commission will develop new methodologies to underpin the additional circularity 
aspects  brought  under  the  ESPR,  including  e.g.  durability,  reparability  and  recycled 
content  related  methodologies,  also  taking  into  account  research  results  of  projects 
funded by the Horizon Europe Programme.  

5.  CIRCULAR BUSINESS MODELS  

In addition to making sustainable products the norm, we must also increasingly invest in 
and  incentivise  the  uptake  of  circular  business  models.  These  include  product-as-a-
service  models,  peer-to-peer  sharing  and  reverse  logistics,  on-demand  manufacturing, 
reuse and repair services, to name a few. This is necessary to decrease overall demand for 
energy and resources, and decouple growth from primary resource use.  

Circular business models are designed to create and capture value while helping optimise 
and limit resource use. This means not only regulatory product-specific requirements but 
also the right market signals for circular business models to give producers an incentive 
to design products better, extend products’ lifetime and retain their value during and after 
use. For instance, by selling products as a service (illustrated by the well-known example 
of  selling  light,  not  light  bulbs29)  the  economic  logic  shifts  and  profits  are  no  longer 
dependent on the volume of products sold.  Instead, it becomes profitable to ensure that 
the products provided as a service are durable and repairable, as the ownership remains 
with the business and the need to buy new products is a business cost.  

Today, it is still challenging for circular business models to take off and scale up. Product 
requirements  under  the  ESPR  will  stimulate  the  uptake  of  such  models,  as  developing 

28 https://ec.europa.eu/transparency/expert-groups-register/screen/expert-
groups/consult?do=groupDetail.groupDetail&groupID=3609  
29 https://ellenmacarthurfoundation.org/circular-examples/why-buy-light-bulbs-when-you-can-buy-light-
signify 

10 

 
 
                                                 
circular activities depends to a large extent on  the physical design features of products, 
and on access to relevant data. Also digital product passports and smart use of digitally 
enabled  innovation  constitute  critical  enablers  to  move  to  circular  business  models. 
However, better product design and information alone will not be enough to trigger a full 
shift  in  business  approaches.  There  is  a  clear  need  to  identify  bottlenecks,  identify 
effective means to boost the uptake of circular business models, ensure their profitability, 
make  them  increasingly  attractive  to  consumers,  exchange  best  practices,  and  provide 
tailored advice for new and existing businesses to switch to circular business models.  

To  that  end,  the  Commission  wants  to  bring  different  stakeholders  together  in  the  new 
European Circular Business Hub. The Hub will support the uptake of circular business 
models,  channel  information  and  services  including  awareness  raising,  cooperation, 
training and exchanges of best practices. It will build upon the expertise and service offer 
of existing EU actions, notably the European Circular Economy Stakeholder Platform30, 
Enterprise Europe Network Sustainability Advisors31 and the network of European green 
tech clusters32. 

In  addition,  the  Commission  will  prepare  guidance  on  boosting  circular  business 
models  to  help  businesses,  Member  States  and  regions  take  action.  This  will  include 
guidance on directing investment  and funding and optimising local  resource stocks and 
flows,  with  a view to  creating  circular value and jobs. The Commission will also  issue 
guidance33 on how to support uptake and partnerships for the circular economy between 
social enterprises and other actors, including mainstream businesses.  

Moreover,  through  the  European  Skills  Agenda34,  the  Commission  is  supporting 
investments in skills indispensable for the development of a circular economy. Under the 
Pact for Skills35, the Commission is setting up large-scale partnerships bringing together 
training 
industry  representatives,  social  partners  and  vocational  education  and 
providers36.  

6.  EMPOWERING AND PROTECTING CONSUMERS 

Most  consumers  want  to  play  an  active  part  in  the  green  transition37.  The  ESPR  will 
support  consumers  in  the  green  transition.  It  will  ensure  products  meet  minimum 
requirements  for  environmental  performance,  and  provide  better  information,  labelling 
and  greater  access  to  spare  parts,  upgrades  and  repairs,  while  taking  into  account 
affordability,  boosting  consumer  convenience  and  giving  consumers  access  to  higher 
quality products.  

30 https://circulareconomy.europa.eu/platform/  
31 https://een.ec.europa.eu/  
32 https://resourceefficient.eu/en  
33As announced in the Social Economy Action Plan COM(2021) 778 
34 COM(2020) 274 final 
35 Pact for Skills - Employment, Social Affairs & Inclusion - European Commission (europa.eu) 

36Pacts  for  Skills  have  already  been  established  in  industrial  ecosystems  such  as  Construction, 
Microelectronics, and Textile, Clothing, Leather and Footwear. 
37 94% of Europeans say protecting the environment is important to them personally, and 68% regard their 
own  consumption  habits  as  adversely  affecting  the  environment.  Attitudes  of  Europeans  towards  the 
Environment - March 2020 - - Eurobarometer survey (europa.eu) 

11 

 
 
 
                                                 
But  it  is  also  necessary  to  ensure  better  information  at  the  point  of  sale  and  build 
consumer confidence in the claims that producers make on the environmental benefits of 
their  products  on  their  own  accord.  The  proposal  on  empowering  consumers  for  the 
green transition38 enables consumers to take informed purchasing decisions.  

The  proposal  will  introduce  targeted  amendments  to  horizontal  EU  consumer  law39  to 
ensure  that  consumers  are  provided  with  information  at  the  point  of  sale  about  a 
commercial  guarantee  of  product  durability,  as  well  as  information  relevant  for  repair 
(including  a  reparability  score,  whenever  this  is  available).  It  will  also  prohibit  traders 
from  making  certain  types  of  environmental  claims  deemed  to  be  misleading.  This 
includes  vague  environmental  claims  (e.g.  “green”,  “eco-friendly”,  “good  for  the 
environment”)  that  are  not  adequately  justified  and  verified  in  line  with  the  rules. 
Moreover,  the  proposal  will  ban  several  practices  associated  with  early  obsolescence, 
including planned obsolescence practices.  

In  addition,  the  Commission  is  working  on  proposing  more  specific  rules  on  green 
claims to boost reliability, comparability and verifiability, relying on the Product and 
Organisation  Environmental  Footprint  methods40  and  is  developing  an  initiative  for 
encouraging repairs of consumer goods (‘right to repair’), with adoption planned in 
autumn 2022.  This  initiative will complement ESPR and will contribute to  its practical 
effects  by  giving  consumers  the  possibility  to  use  their  purchased  products  longer  by 
giving them a right to have these products repaired.  

7.  LEADING  THE  SUSTAINABLE  AND  CIRCULAR  PRODUCTS  AND  BUSINESS  MODELS 

AGENDA AT GLOBAL LEVEL 

for 

track 

record  of  advocating 

sustainability  worldwide.  
The  EU  has  a 
Producers already meet EU rules  on  hazardous  substances,  ecodesign  and  energy 
labelling  when  placing  products  on  the  EU  market.  The  proposals  in  the  package  of 
initiatives  on sustainable products  will contribute to accelerating  implementation  of the 
for 
UN  2030  Agenda 
environmentally  sustainable  products,  the  EU  seeks  to  strengthen  the  sustainability  of 
global value chains and contribute to positive change in the partner countries, which will 
help in meeting several UN Sustainable Development Goals.   

for  Sustainable  Development.  By  expanding  markets 

However, EU action alone is not enough and cannot deliver alone the transition to more 
environmental sustainability and  circularity the world needs.  We need to work together 
with our partners by strengthening international cooperation and promoting our ambition 
worldwide.  The  EU  will  step  up  its  engagement  with  non-EU  countries,  at  global, 
regional  and  bilateral  level,  to  support  the  sustainability  transition,  and  to  facilitate 
compliance  with  the  new  rules,  especially  with  low-  and  middle-income  countries. 
Bilaterally, the EU will work in partnership with non-EU countries on capacity building, 
enhanced dialogue, technical cooperation, access to business support networks, access to 

38 COM(2022) 143 
39 Unfair commercial practices Directive 2005/29/EC and Consumer rights Directive 2011/83/EU 
40 Commission Recommendation (EU) 2021/2279 of 15 December 2021 on the use of the Environmental 
Footprint methods to measure and communicate the life cycle environmental performance of products and 
organisations, OJ L471/1 

12 

 
 
 
                                                 
finance  for  circular  economy  investments,  and  exchanging  best  practices  to  identify 
potential technical barriers and to promote joint initiatives. 

At  global  level,  the  EU  will  continue  to  pursue  the  circular  economy  agenda  in 
multilateral  fora,  in  the  G7  and  G20,  and  in  the  context  of  the  Global  Alliance  for 
Circular  Economy  and  Resource  Efficiency.  The  Commission  will  advocate  creating  a 
global  Sustainable  Consumption  and  Production  Forum  to  facilitate  a  broad 
discussion  between  countries  and  stakeholders  on  meeting  the  UN  Environment 
Assembly’s  recent  call  on  Member  States  ‘to  take  measures,  in  cooperation  with  the 
private  sector    to    enhance  the  design  of  products  taking  into  account  lifecycle 
assessments, to favour product lifetime extension, repair, re-use, and easier recycling in 
the  context  of  circular  economy  with  the  view  to  contributing  to  achieving  resource 
efficiency41’.  The  EU  will  continue  supporting  the  UN  and  other  relevant  global  and 
multilateral  initiatives  promoting  sustainable  production  and  consumption.  It  will  also 
support  and  help  disseminate  the  findings  of  the  work  carried  out  by  the  International 
Resource  Panel.  The  EU  will  cooperate  with  its  trading  partners  in  the  World  Trade 
Organisation, by sharing and discussing best practices on how to increase circularity in 
global value chains, in line with domestic and international law. 

Finally,  the  recent  Commission  proposal  on  corporate  sustainability  due  diligence42 
will  contribute  to  driving  sustainable  business  models  at  global  level.  The  proposal 
fosters the sustainability transition of companies across industry sectors by requiring that 
companies  address  and  account  for  adverse  impacts  on  the  environment  in  their  global 
value chains. Based on the proposed rules larger companies also need to have a plan to 
ensure that their business strategy is compatible with limiting global warming to 1.5 °C 
in line with the Paris Agreement. 

8.  CONCLUSION  

The  initiatives  on  sustainable  products  aim  to  ensure  that  by  2030  a  significant  part  of 
products  available  to  EU  consumers  will  be  designed  to  be  durable  and  energy-  and 
resource  efficient,  reparable,  recyclable,  and  with  preference  for  recycled  materials. 
Companies  from  all  over  the  world  will  be  able  to  compete  without  being  undercut  by 
companies that pass on costs to society and the environment. Consumers will also have 
access  to  the  information  they  need  to  make  more  sustainable  choices,  will  be  better 
protected against practices harmful to the green transition, and will be able to keep their 
products functioning for as long as possible, while companies will be able to access the 
data they need to ensure environmental sustainability and circularity of their products and 
business models. These actions are explicitly recommended by European citizens in the 
framework  of  the  Conference  on  the  Future  of  Europe,  who  have  called  for  stronger 
circular economy policies, including on combatting planned obsolescence and providing 
information on how to re-use and repair products. 

The  impact  of  today’s  package  of  initiatives  will  be  felt  gradually.  The  rules  of  some 
measures will be applicable upon entry into force; others will take time due to the legal 
framework  and  the  type  of  systemic  changes  they  will  instigate.  The  Ecodesign  for 
Sustainable  Products  Regulation  will  allow  for  a  multi-pronged  approach  to  product 

41 UNEA 5 resolution on Enhancing Circular Economy as a contribution to achieving sustainable 
consumption and production, adopted 5 March 2022, UNEP/EA5/L17/REV.1 
42 COM(2022) 71 final  

13 

 
 
                                                 
regulation  –  a  real  game  changer,  whose  momentum  will  build  over  time.  By  setting  a 
comprehensive cross-sectoral framework and by taking key steps such as the adoption of 
working  plans,  the  general  direction  and  objectives  will  be  clear  well  in  advance.  This 
will  give  time  for  companies  to  make  the  necessary  organisational  and  systemic 
preparations, even before detailed product rules are laid down.  

The proposals in this package are central to the European Green Deal. They will make a 
considerable  contribution  to  the  European  Union’s  environmental  and  climate  goals,  in 
particular  to  achieving  climate  neutrality  by  2050,  to  doubling  the  circularity  rate  of 
material use by 2030 and to achieving the European Union’s ambitious energy efficiency 
targets. They will also contribute to and benefit from the objectives of the 2030 Digital 
Decade,  the  New  Industrial  Strategy,  the  European  Pillar  of  Social  Rights  Action  Plan 
and the New European Bauhaus. 

The proposals in this package have the potential to  bring the EU significantly closer to 
reaching  the  UN’s  2030  Sustainable  Development  Goals,  provided  that  their  level  of 
ambition is maintained and they are swiftly and effectively implemented. 

The  Commission  therefore  calls  on  the  European  Parliament,  the  Council  and  all  other 
stakeholders  to  endorse  the  approach  and  ambitions  of  these  proposals  and  to  work 
towards their rapid adoption and implementation. 

14