16 December 2020

Sustainable Products Initiative: a strong tool for circularity only if ambitious requirements are enforced for all goods

We welcome the EU’s intention to make sustainable products and circular business models the norm as part of the upcoming Sustainable Products Initiative. To ensure this new legislation achieves its goals, we have sent detailed recommendations to the European Commission highlighting the need for removing unnecessary, inefficient, toxic, wasteful and polluting products from the EU market complemented with (and not driven by) better consumer information.

Without policy intervention, by 2050 the world population is expected to be consuming resources at a rate three times higher than the Earth can regenerate. Global consumption of materials such as biomass, fossil fuels, metals and minerals are expected to double by 2060, while annual waste generation is projected to increase by 70% by 2050.

Up to 80% of the environmental impacts of products are determined at the design phase, yet the linear pattern of ‘take-make-use-dispose’ does not provide producers with sufficient incentives to make their products more circular. Many products break down too quickly, cannot be easily reused, repaired or recycled, and many are made for a single use only.

The European Commission is currently working on its Sustainable Product Policy initiative (SPI), seeking to correct these market and regulatory failures. It will try to solve issues such as product-related flaws (including single-use products or devices with short lifespans), sustainability aspects (including energy efficiency and circularity) and the need for reliable information across value chains.

As part of the call for feedback by the Commission, we have submitted a position paper setting out detailed recommendations the EU should take onboard to make this initiative a true success:

  • Define and assess ambitious policy options. An ambitious set of legal requirements supported by appropriate technical standards should enhance the design and manufacturing phases of all products alike, and dramatically increase their potential to be reused, repaired and recycled, as well as improve the information to be conveyed to consumers and stakeholders across the value chain.
  • Enlarge the scope of the SPI to all key product groups: include sectors such as batteries, packaging and construction products to be coherent with the Circular Economy Action Plan and the key value chains it has identified.
  • Build on experience to expand ecodesign. We welcome the intention to broaden the scope of the Ecodesign Directive to cover a wide range of other sectors, but we call on the Commission to build on the lessons learnt in this process, and not to compromise on any of the elements that have proven so successful for energy-related products.
  • Ensure effective market surveillance through targeted measures to guarantee the full delivery of the expected environmental benefits.
  • Get the right measures…right. We support the set of principles and measures put forward by the Commission. However, we urge to include the absence of substances of concern as an overarching requirement into all sectors to be covered. In addition, it is fundamental to develop a robust methodology common to all sectors to quantify environmental impacts and identify priority actions across the entire product lifecycle so that worst performers can be directly identified. Furthermore, we believe that measures to address circularity should follow a real circular economy hierarchy where value retention is prioritised, and where prevention strategies to avoid material consumption in the first place are adequately valued.
Real circular economy hierarchy. Source: ECOS response to the inception impact assessment on the Sustainable Products Initiative


The Commission is expected to present a formal legislative proposal for a Sustainable Product Policy in the last quarter of 2021, as confirmed by President Ursula von der Leyen. Prior to that, a more formal public consultation is expected once it is established how the scope of the Ecodesign directive can be broadened towards a more generic ‘sustainable product policy directive’ that applies beyond energy related products.  

To read our feedback in detail, download our position paper.

ECOS is co-funded by the European Commission and EFTA

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