DIGITALEUROPE position paper on ESPR Trialogues negotiations

On 30th August, the co-legislators convened for the first Trialogue on the Ecodesign for Sustainable Products Regulation, which aims to improve the environmental sustainability and circularity of all products placed on the EU market, including electric and electronics products.

DIGITALEUROPE welcomes the overall legislation’s objectives and the importance of accelerating the green transition via more sustainable products. DIGITALEUROPE is pleased to see the positive improvements suggested by co-legislators, notably on Digital Product Passport’s confidentiality, access rights and granularity. DIGITALEUROPE is also pleased to see suggestions by the European Parliament to mandate manufacturers to present information in a digital format (via Art. 21 paragraph 7 a (new)). DIGITALEUROPE reiterates strong support to the use of digital formats (e.g. QR codes) as the default option for instructions, compliance information, product information etc.

However, DIGITALEUROPE is concerned about the approach taken by co-legislators within some articles, notably on Ecodesign Forum, Performance & Information Requirements in the eco-design delegated acts, Substances of Concern, Digital Product Passport, Unsold Goods, Digital Label, Market Surveillance.
DIGITALEUROPE is particularly concerned about the direction of work taken by co-legislators on:

• Substances of Concern, which raises concerns due to its expansion compared to the original definition suggested by the European Commission.
• Digital Product Passport, where the suggestion of a central registry raises very practical questions on how to ensure the original decentralised approach suggested by the European Commission.
• Unsold Goods, where suggestions by the European Parliament have been, in our opinion, disproportionate given the complexity and diversity of the products that could be considered to fall under the consumer EEE market segment.

To conclude, DIGITALEUROPE reiterates that the ESPR is a product-related legislation, which should be aimed at improving products’ environmental impact via better product eco-design, with a focused and precise mechanism for setting product specific and impact assessed environmental requirements.