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First ESPR working plan kick-starts a more sustainable EU single market

The European Commission’s first Working Plan for implementing the Ecodesign for Sustainable Products Regulation (ESPR) has been published. It confirms the list of priority products this policy will tackle first to improve their sustainability – with almost all products on the EU market due to be covered eventually. The list includes textile apparel, furniture, mattresses, tyres, iron and steel, and aluminium.
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The Ecodesign for Sustainable Products Regulation (ESPR) is a major piece of legislation that will benefit consumers of almost all products put on the EU single market, by ensuring sustainable design from the outset. This includes energy-intensive products like iron and steel, making it a key part of realising the EU’s Clean Industrial Deal. After its adoption in 2024, the ESPR is now being implemented in stages.

The first ESPR Working Plan confirms the list of products and horizontal measures that will be tackled first. These products have the highest environmental impact and potential for improvement, so it is right they will be dealt with first, ECOS says. However, the list of priority products is shorter than what was initially promised in the ESPR.

The priority product groups

  • Textile apparel. This environmentally impactful sector is rightfully in the spotlight. ECOS wants to see performance requirements that ensure textiles are of high quality, more durable, reusable, repairable, and non-toxic. The ESPR must now help to eliminate negative environmental impacts throughout textile value chains.
  • Furniture and mattresses. The move towards more sustainable materials is urgent. These products are often already quite durable, but they can be difficult to repair – and when they reach the end of their life, they are not always recyclable. Ecodesign can help to advance the use of innovative materials, eliminating hazardous chemicals (such as flame retardants).
  • Tyres. EU legislation already addresses microplastic pollution from tyres in some ways, but much more is needed – and the ESPR can help to fill the gaps. ECOS wants tyres to be more durable, reusable, non-toxic, and meet ambitious recycled content targets.
  • Iron and steel. As the first energy-intensive intermediate products to be covered under the ESPR, the European Commission must be ambitious and set the bar high. The industry needs a comprehensive set of policy measures to ensure an internationally competitive and climate-neutral steel production with quality jobs in Europe.
  • Aluminium.

The priority horizontal measures

  • Horizontal repairability measures. Horizontal repairability measures for energy-related products are included, signalling EU support for more repairable products. There are many common features that make a horizontal approach possible and necessary (as well as faster), according to ECOS.
  • Recycled content and recyclability of electrical and electronic equipment. It is encouraging that horizontal measures on recyclability and recycled content are prioritised, but any recycled content calculations must be done right – with traceability clauses included.

What is missing from the first Working Plan?

Sectors not mentioned above are not included in the first Working Plan, and so will not have sustainability or information requirements to adhere to until much later – 2030 at the very earliest.

While this was expected for most sectors, there are some with significant environmental impacts large enough to have been included in the first Working Plan. This plan can make a lot of progress, but there are some missed opportunities, says ECOS. For example:

  • Footwear: Footwear production is responsible for at least a fifth of the greenhouse gas emissions and a third of the resource use and water pollution of the entire textile and footwear industry. It is nonetheless encouraging that a study will be commissioned to evaluate the potential to improve the environmental sustainability of footwear.
  • Plastics and polymers and chemicals: Plastics in products have a huge impact on human health and the environment and improving this sector would have downstream effects on other products. However, it is positive that the Commission will launch a study later this year to analyse these complex sectors for future delegated acts.
Source: ECOS

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