The Environmental Coalition on Standards (ECOS), and the European Environmental Bureau (EEB), thank the European Commission for their efforts so far in evaluating the existing CPR, and developing a range of interesting ideas for the forthcoming proposal. Regrettably however, our understanding is that this lengthy process will conclude with a legislative proposal that will fall short. While relevant information and product requirements aligned with the Sustainable Products Initiative, assessment, and controls on environmental impacts will be omitted from the CPR revision legislative proposal now being finalised. This is the last chance to revise the CPR for this decade of decarbonisation. Our organisations strongly believe the legislative proposal for revision of the CPR must include EU-level requirements across three key pillars as described below:
- Performance: A basis for EU legislative product requirements that can establish maximum carbon footprint and environmental impact values, circularity requirements, and functional performance requirements for each product groups, set by regulators, and not pseudo-regulated by industry through standards.
- Information: Structured legislative product information requirements within the CPR itself to require communication of full lifecycle information that is intelligible, open access, and comparable using PEF as a common guiding basis for data quality and lifecycle assessment.
- Governance and implementation: Legislative provisions for developing implementing legislation that formalise a clear governance framework to support development of the requirements outlined above through implementing measures per product group (e.g., one for structural products, and one for insulation products).
Access the letter here.