Author: Maria Negut, Head of EU Affairs at European Bioplastics e.V.

The long-awaited EC proposal for Ecodesign for Sustainable Products Regulation (ESPR) was finally published on 30 March 2022, building upon the “Ecodesign Directive”, which currently only covers energy-related products. Part of the Sustainable Products Initiative (SPI), the proposal for ecodesign is one in a series of ambitious Commission proposals aimed at bringing companies in line with the Green Deal ambitions and EU’s sustainability goals.

The framework will allow for the setting of a wide range of requirements, including on:

  • product durability, reusability, upgradability, and reparability
  • presence of substances that inhibit circularity
  • energy and resource efficiency
  • recycled content
  • remanufacturing and recycling
  • carbon and environmental footprints
  • information requirements, including a Digital Product Passport.

Based on the Regulation which provides a general framework for ecodesign requirements for products placed on the EU market, the Commission will adopt a series of delegated acts which will set criteria for different product groups – including plastics. While traditional circular economy principles focus on the end-of-life phase, the current proposal on ecodesign aims at building in sustainability throughout the entire product lifecycle, starting with the design phase.

The ESPR proposal will be the cornerstone of EU environmental policy and will have a major impact on product design and market access. Given its wide scope, some product categories will be subject to additional product-specific legislation which could create additional burden for companies operating on the EU market. Some concerns are notably linked to the use of Life-Cycle-Assessment (LCA) and Product Environmental Footprint (PEF) methods, and intellectual property rights of companies.

ESPR will also enable the EU to set labelling requirements. An ESPR label, for example, with mandatory provision of key information at the moment of purchase can be an effective way to inform about the environmental performance of products, particularly if it allows for an easy comparison between products in a given category. Nevertheless, comparison between products must be done in a cautious way, given the complexity of products included in the family of bioplastics and inconsistencies in how the LCA method can be interpreted. With PEF likely to become the new EU standard to evaluate green claims, it could unfairly compare bio-based plastics with conventional plastics, as proposed in the JRC LCA methodology for alternative feedstock for plastics production. Since the Commis