The EU Ecodesign regulation is coming!
The European Commission has been hard at work preparing the ambitious new EU Ecodesign regulation. It is currently (in June 2022) at the stage of a proposal and hasn’t been confirmed by the Council or voted into law by the Parliament yet, but it is already a well-advanced draft and it is not likely that very substantial changes will be made.
There is currently an Ecodesign Directive and an Energy Labelling Regulation, but their scope is going to be extended “beyond energy-related products so that it covers the broadest possible range of products and helps achieve a circular economy”.
If you regularly import products into the EU, you need to be ready to comply with the EU Ecodesign Regulation which requires you to document your environmental impact, and, ultimately, to manufacture more sustainable and traceable products by May 2024. Non-compliance is not an option, as you may be totally blocked from selling your product(s) on the EU market.
The challenges you face
You may not have visibility over your supply chain or have a complete list of its components & related suppliers. You may not have information about the environmental impact of your product along its full lifecycle. And, as result, you may be unable to take action to minimize your risks.
That’s where our team, who understands the challenges the Ecodesign regulation provides, can step in to study your key risks and give you solutions that can help you import products into the EU with peace of mind.
The regulation affects both your products and your supply chain.
It focuses on “product durability, reusability, upgradability and reparability, the presence of substances of concern in products, product energy and resource efficiency, the recycled content of products, product remanufacturing and high-quality recycling, and for reducing products’ carbon and environmental footprints”.
These requirements may well call for a change in materials, production processes, and even suppliers for many importers.
Your understanding of who supplies you and your suppliers needs to be relatively advanced, because the regulation will also ensure certain supply chain information, including the manufacturing facilities, is declared. Any eco-friendly claims you make will need to be reflected in the supply chain and will be verified using the submitted information. Consumers and market surveillance authorities will also be given access to this information which may guide their decisions.
👉 Learn more about the ESPR here: What is the EU Ecodesign for Sustainable Products Regulation?
We also created a 2-part podcast series on the topic:
Nearly all products sold in the EU, except for example food, feed, and drug products, will have to comply.
The EU Commission is targeting textile products and certain construction products first since they represent the “most significant impacts on the environment and climate”. We believe consumer electronics will be targeted shortly after that. Certain types of batteries are also regarded as a high priority.
At the same time, the requirements mentioned are going to come into effect quickly, for all products concerned.
You need to start collecting information about your supply chain and about the environmental impact of your products now.
Sofeast’s supply chain management team work with you to understand your product, its compliance risks, and assure that you follow the necessary actions to comply with the regulation and support you to build a more sustainable supply chain and products. We typically do the following:
- Initial desk analysis – research what products will be considered most risky and are most likely to be examined by market surveillance authorities and customs; what information is already available on all the topics covered by the regulation; what the major gaps are.
- On-site information gathering – at the key manufacturing facilities to assess who is in the supply chain and how sustainable they are. We will investigate, among others, what stages and steps go into making your products, where they’re truly made, whether sustainable and/or recyclable materials are used as claimed by suppliers, and whether manufacturing processes can be greener.
- Development of risk analysis and mitigation plans – based on your business and product, our experts create the plans to uncover your unique sustainability and compliance risks and how to reduce them. We will focus on the highest sources of risk. We will suggest an action plan that can be started quickly.
- Advice and support on the implementation of the plans – you’re not left alone to cope. Our team supports you to implement the risk mitigation plan/s and is on hand to answer questions and provide follow-up advice based on results throughout the process.
Some of these requirements may come into play sooner, but most products will have to comply by May 21st 2024.
It means now is the time to re-evaluate your product and supply chain-related risks, do a gap analysis, and have a plan. We have heard of some large retailers who started to require their direct suppliers to present a compliance plan!
Besides, the current EU commissioners are not known for their leniency. The EU Medical Device Regulation went into effect, despite the strong requests of most notified bodies who complained they, and most of their clients were not ready.
The Commission clearly states that “the enforcement of current Ecodesign rules is insufficient and uneven”, and they have been working on a scheme that will make the customs’ and market surveillance authorities’ jobs much easier. The products’ information will have to be marked on the products themselves (typically with a QR code), and the product information will be visible in a central registry — that will allow for a risk analysis that will orient what to control!
Product sustainability may also be connected to business tax (for instance, to discourage the disposal of unsold goods), so not taking steps to comply may be costly in the long term.
Your dedicated project manager will act as the go-between for you and our compliance and supply chain management specialists. All dialogue and written materials are in English and the reports and plans provided are yours to keep.
What does it cost?
Cost is highly dependent on your exact situation (complexity and number of products, locations of the key suppliers…) as it involves travel to suppliers and in-office work. As such, we need to give you a tailored proposal per project. Please request a consultation and quotation by clicking the button.