ECOS Discussion Paper: Ecodesign as Part of Circular Economy – Implications for Market Surveillance

Resource efficiency requirements have already been incorporated and/or will soon be integrated in a number of Ecodesign product-specific regulations. Consequently, ECOS would like to demonstrate that market surveillance of such requirements is as feasible as that of energy efficiency requirements and that suggestions to delay the introduction of resource efficiency requirements due to a perceived market surveillance obstacle are unfounded.

Increasing the durability, repairability and recyclability of products represents the next big step for Ecodesign and Energy Labelling, hence ECOS calls for the European Union to strengthen those requirements and address circularity in all future regulations while ensuring that requirements on products result in tangible environmental benefits.

Ambitious design requirements need to be supported by strong enforcement, which depend on the Member States’ effort dedicated to their market surveillance activities. While market surveillance authorities have limited resources, monitoring and verification approaches are improving and becoming better coordinated across the EU. Within its discussion paper, ECOS explores how resource efficiency aspects can be easily verified, often at low cost and with minimal training, while ensuring objectivity, consistency and repeatability.