Recently adopted by the European Union, the eco-design regulation aims to transform our way of producing and consuming. Given the ambition of this vast project, the regulation could not be simple. It combines directly applicable measures and a framework for drafting additional acts, known as “delegated” acts, by the Commission. If you are new to this topic, you will find here the main measures of the act and its scope.
Main Measures
In my opinion, the regulation can be summarized in four key points:
- Eco-design Standards: The regulation delegates to the European Commission the power to draft eco-design standards through a mechanism of delegated acts. These standards can impact 20 seperate parameters, creating obligations for manufacturers, distributors, importers, and resellers. The Commission published the timeline and the products concerned for the next 5 years on April 16, 2025.
- Digital Product Passport (DPP): The DPP is an information file related to a specific product which will be easily and immediately accessible via a machine-readable ‘data carrier’, such as a QR code or barcode. The DPP will provide information on certain key parameters: compliance documentation, user manuals, usage instructions…
- Regulation of Unsold Goods: The regulation prohibits the destruction of unsold goods in the fashion industry (clothing, shoes, hats), unless they present a hygiene or environmental risk. In all other sectors, economic operators disposing of their unsold products will have to publish information on their unsold stocks from July 19, 2025.
- Green Public Procurement: The regulation imposes several restrictions on public procurement for products affected by eco-design or services using these products. They will have to comply with minimum requirements defined by the Commission’s delegated acts, give environmental considerations an importance of 15% to 30% in their weighted scoring of offers, and award at least 50% of public contracts to the most sustainable products.
Scope
The eco-design standards and the DPP have very broad scope. In theory, all products can be affected (with the exception of food products, certain vehicles, plants, animals, and products of human origin such as hair).
In conclusion, this ambitious project is confronted to the enormity of the task. In practice, the Commission will only publish a work program every 5 years. The 2025 – 2030 plan concerns 22 products, which is derisory. Either this regulation is a success and we will have to speed our pace, or this regulation will be just a failed attempt to better manage our consumption. Nevertheless, some GEM appliances are among these 22 products. Our industry will therefore be at the heart of the experiment conducted by this regulation over the next 5 years.
Will we transform this drive to better manage the impact of our overconsumption into success, or will it end up in the wastebin of overambition ?
Emmanuel Benoit, CEO of Agoragroup