SMEs and standards key to making sustainable products the norm in the EU

On 30 March, the European Commission presented a package of initiatives to ensure that all products placed on the EU market become more sustainable. The package included a new proposed Regulation on ecodesign requirements for sustainable products. This proposal extends the scope of the current Ecodesign Directive beyond energy-related products to all products, with a few exceptions, such as food, animal feed or medicinal products. The aim is to ensure that products generally become more resource- and energy-efficient, durable, reliable, reusable, upgradable and reparable, as well as easier to maintain, refurbish and recycle. The proposal also introduces the Digital Product Passport (DPP). The DPP aims at enabling access to, and the sharing of, product-related information between the different actors in the value chain, which is essential to achieving a circular economy via an increase in the reparability, durability and recyclability of products. An important aspect to highlight is that the Regulation just provides a general framework to set product-related ecodesign and information requirements. The concrete DPP ecodesign and information requirements and content will be decided on specific product Regulations (delegated acts) that will be developed at a later stage. SBS supports this approach in principle, since not all criteria and requirements will be equally relevant to all products. It is important to carefully assess the practical application, relevance and feasibility of the requirements and criteria per product category.

The future Ecodesign Regulation will have a significant impact on SMEs. If your company produces goods such as textiles, furniture, mattresses, electronics, iron, steel or aluminium (some of the products likely to be regulated first) you will be affected by the introduction of the DPP and new European measures aimed at ensuring the production of more durable, repairable, reusable and recyclable products. This will create some challenges and, in all likelihood, generate additional costs for SMEs operating in these areas. The new legislation will, however, bring about new business opportunities and stimulate innovation. Requirements on reparability, for example, will expand the repair market, increasing business opportunities for local SMEs.

The proposals will rely heavily on standards for their implementation. European harmonised standards will be necessary to support the roll-out of the DPP and to provide the methods to measure and assess whether products comply with ecodesign requirements. In addition to standards in support of existing Regulations on different product groups under the current Ecodesign Directive, there are already a series of horizontal standards and ongoing standardisation work at the European and international levels that will be of relevance for the forthcoming Regulation. This is the case of the EN 45550 to EN 45560 series of standards developed under the CEN-CLC TC 10 on material efficiency, the work of ISO/TC 323/WG 5 on the product circularity datasheet or ISO/IEC JTC 1/SC 31 on automatic identification. SMEs make up the majority of companies in Europe. Therefore, to ensure the successful implementation of the Commission proposals, it is also essential to involve SMEs in the development of those standards through organisations such as SBS. If SMEs are not involved, we may end up with standards that do not meet their needs or even place disproportionate burdens on them. It is important to avoid a proliferation of standards and to build on what already exists whenever possible.

The challenges, opportunities and role of standards in relation to the Commission proposals was the main subject discussed during the SBS Annual Conference “SMEs setting the standard for sustainable products – Drivers and challenges” that took place on 15 June. The conference featured different panels focusing on the DPP and on textiles and construction. The package of proposals included the EU Strategy for Sustainable and Circular Textiles and the revision of the Construction Products Regulation in addition to the Ecodesign Regulation. Through the examples of these two product groups, which have a significant impact on the environment, panellists highlighted some barriers arising from the Commission’s proposals that may hamper SMEs’ growth in these sectors. Speakers stressed the need for harmonisation and a coherent set of safety-focused regulations and standards, and environmental and other requirements that can be easily implemented by SMEs.

In the panel dedicated to the DPP, speakers agreed it would be necessary to find a balance between sharing information and protecting sensitive data to ensure this information is accessible in a user-friendly format, and that data disclosure and reporting will not place unnecessary burdens on SMEs.

SBS is currently preparing a position paper on the proposed Regulation on ecodesign requirements for sustainable products, which will consider all the points covered above. Moreover, SBS will also stress the need to ensure the effective participation of SMEs in the future Ecodesign Forum that will be consulted on priorities and future delegated acts, and in the development of the standards that will support them by providing financial support for the participation of SMEs and their representatives. This should be in addition to the SME support measures already foreseen in the proposal.

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