Position and recommendations on the proposed Ecodesign for Sustainable Products Regulation

Our lobbying partner Orgalim welcomes the Ecodesign for Sustainable Products Regulation as a key measure to further optimise the way resources are used as well as bringing new business opportunities.

However, there are certain concerns on how it will work in practice:

  • Protection of confidential business data, data within the scope of the Digital Product Passport and interplay with other legislation
  • Duplication of efforts and double regulation, in particular for chemicals
  • Implementation with a disproportionate impact on the competitiveness of economic actors (third party verification, regulation of components and non-enforceable requirements


You can read the full position and recommendations below.



In March 2022, the European Commission proposed a new Ecodesign for Sustainable Products Regulation (ESPR) with the objective of making sustainable products the norm. The new ESPR Proposal builds on the existing Ecodesign Directive but is wider in scope –moving beyond energy-related products and impacting the entire supply chain.

The biggest change is probably the new Digital Product Passport (DPP), which will provide data on a product along its value chain.



Proposal for Ecodesign for Sustainable Products Regulation and Annexes

Orgalim Policy Exchange on the new ESPR Proposal

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