Response to the Public Consultation on New Product Priorities for the Ecodesign of Sustainable Products Regulation (ESPR)
Posted on Monday 24 April 2023
Municipal Waste Europe responds to the Commission's Public Consultation on New Product Priorities for the Ecodesign of Sustainable Products Regulation (ESPR). We welcome the preliminary list of products for which the European Commission intends to prioritise action under the scope of the ESPR, including energy-related products, by setting ecodesign requirements in secondary legislation. However, we understand the list is given by Article 5 and Annex I of the proposed ESPR. Moreover, we suggest taking a balanced, integrated approach encompassing all of the parameters mentioned in the questionnaire rather than prioritising work on only the 3 ‘most important’ aspects as it is requested in the questionnaire. It is not reasonable to give priority to certain criteria over others when all criteria need to be met to fulfill the purpose of the regulation. (The whole purpose of the ESPR is jeopardized if one must remove characteristics -product aspects or parameters- that should not be prioritized as the European Commission asks the respondents in the Public Consultation.) For example, presence and release of substances of concern (as defined in Article 1 (28) of the proposed ESPR) should be always considered. Our full response...