Ambitious rules for product sustainability: this sums up what HOP hopes to achieve at European level. To this end, HOP is counting on the implementation of the European Ecodesign for Sustainable Products Regulation (EPSR) and on the decisions taken at the Ecodesign Forum.
Coming into force in July 2024, it aims to set out broad guidelines on product sustainability for all Member States of the European Union and to level the playing field for those placing products on the European market. The previous version of this legislation applied only to around ten products: washing machines, tumble dryers, dishwashers, fridges, televisions, welding machines, vacuum cleaners, servers, telephones and tablets. The new text, however, is set to cover all products placed on the market, with the exception of foodstuffs, military products, medicines and vehicles.
An ‘ecodesign forum’: what is it?
To have a tangible impact, this text must be adapted for each individual product. These are known as delegated acts. They must be adopted to define the eco-design requirements for these products in greater detail. The ‘work plan’ to be drawn up by the Commission in the coming weeks will be decisive, as it will set out the framework for the work over the coming years and thus the deadlines and priorities regarding the products concerned.
To this end, the European Commission is convening stakeholders as part of a “forum”. These consultation meetings bring together various stakeholders. The forum will comprise NGOs (17 % of the total number of participants), representatives from academia (3 %) and, above all, trade associations and businesses (78 %).
To restore the balance of power, this is a crucial moment to send out strong advocacy messages so that regulations are not left at the mercy of industry.
HOP’s application to take part in this ecodesign forum has been accepted
HOP’s demands on this occasion centre on two key points:
- To continue to emphasise that there can be no reliable repairability index without criteria relating to the price of spare parts.
To this end, HOP and the other members of the Right to Repair coalition are proposing an ambitious framework to regulate spare parts prices and thus incorporate this criterion into the European index. Under this framework, every manufacturer should display spare part prices on their website and commit to not increasing these prices. This would put an end to the volatility of spare part prices – the main factor behind the European Commission’s reluctance to apply this criterion in the index.
HOP and the other members of the coalition have also jointly published a document co-signed by numerous stakeholders (manufacturers, distributors, designers, repairers, remanufacturers, rental companies and insurers). It proposes concrete solutions to put an end to spare part prices that render products economically irreparable. As a reminder, according to the French Agency for Ecological Transition (Ademe), the cost of repairing a product must not exceed 33 per cent of the price of a new product if the consumer is to opt for repair.
- Call for ambitious, cross-cutting eco-design requirements for all electrical and electronic products
- Ensure the availability of spare parts and software updates for everyone for a sufficient period of time
- Prohibit serialisation practices that create a barrier to reparability and refurbishment
- Make the European Repairability Index a tool that rewards market operators who are genuinely committed to sustainability. To this end, HOP calls for the European Index not to award points to market operators who merely comply with European regulations.
