EFIC position on the proposal for an Ecodesign for Sustainable Products Regulation (ESPR)

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June 2022

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The European furniture industry is following closely Green Deal initiatives aimed at making circular economy the norm, such as the Sustainable Products Initiative (SPI). As such, building on the EFIC position on the SPI of June 2021, we welcome the possibility to provide our views on the Ecodesign for Sustainable Products Regulation (ESPR) proposal.

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Executive summary

 

1. The European furniture industry welcomes the ESPR, a key proposal to promote circularity. Furniture is well suited for a circular economy, a transition that is seen as an opportunity.

2. SMEs should be offered guidance and flexibility in adapting to a more circular economy and performance and information requirements should be reasonable and manageable.

3. The European Furniture Industries Confederation (EFIC) is keen to provide sector-specific expertise, as well as to have a seat in Ecodesign Forum; industry associations being a natural partner in such expert groups.

4. Create one EU circular economy and not 27 different ones. Harmonised legislation at EU level is needed to preserve the Single Market and ensure a level playing field. We welcome the internal market basis and article 3 of the ESPR.

5. Standardisation to be the backbone of harmonised legislation. Consultation with standardisation bodies is essential and existing standardisation work should be used as a basis for the ecodesign framework. Standardisation committee CEN/TC 207 and its WG 10 on Furniture Circularity is already working on circular design product parameters (dis/re-assembly requirements and evaluation methods - prEN 17902) and is ready to cooperate with policymakers.

6. We believe the Commission should generally refrain from issuing its own technical specifications and that an in-depth expertise and a flexible process are needed to take into account innovations on the market, in close dialogue with standardisation bodies and the industry concerned. Bottlenecks in standardisation should be addressed. EN standards should be the first choice and if not available, they should be developed.

7. Innovation should be promoted and technology / material / business model neutrality safeguarded, avoiding lock-in effects in product categories.

8. Ecodesign product and performance requirements: Consider the specificities and complexity of the furniture value chain (designs, products, materials used), ensure that the requirements contribute to effect goals and a truly sustainable development, and that they are of a general nature, relevant, appropriate and proportionate, considering the whole lifecycle of a product.

9. Ecodesign product and performance requirements: Consider that the methodology to assess or verify many of proposed ecodesign and performance requirements is being developed or no harmonised system exists.

10. Ecodesign product and performance requirements: Industry needs support to ensure compliance with the Regulation, such as for example with harmonised flammability requirements across EU to ensure toxic flame retardants are not used.

11. Ecodesign product and performance requirements: Minimum recycled content & durability: recycled content should not be an isolated sustainability criterion and the whole product and limitations should be considered. Recycled content should not have a negative effect on durability and the availability of recycled material and the technical possibility of replacing virgin with recycled material should be considered.

12. Ecodesign and performance requirements: renewable content should be considered as a criteria in Annex I as it contributes to moving away from fossil-based materials.

13. Clarification is needed on how the legislation affects existing products, including future performance and information requirements. Also, the Regulation focuses primarily on obligations of manufacturers and does not consider the responsibilities of other players in the value chain & the need for shared responsibility. The term manufacturer needs to be defined more clearly to avoid uneven competition between new products and repaired/remanufactured products. Also, the definitions of the different actors along value chain should be aligned in all EU legislation.

14. Information on the environmental sustainability of products: product passports should be workable, designed on need-to-know basis, with clear delimitation of liability of value chain partners in updating the passport (including those that extend the lifetime of furniture such as repairers, upgraders, refurbishers). Most information should be provided via the product passport as opposed to other means.

15. Information on the environmental sustainability of products: product passports should consider the complexities of furniture products and the furniture value and supply chain, not become an administrative burden and differentiate between compulsory and voluntary information.

16. Information on the environmental sustainability of products: product passports should be respectful of companies’ trade secrets. The Regulation in its current form does not seem to be compatible with the need to protect knowledge-based assets. Such protection is crucial for the competitiveness of European companies.

17. Information on the environmental sustainability of products: Provision on tracking and sharing information on substances of concern risks bringing huge burden on companies. We believe that substances of very high concern (SVHCs) should be prioritised. We are concerned of the broad definition of substances of concern (SoCs) and that no process is proposed for identifying substances that hinder recyclability. The selection criteria of substances inhibiting recycling should be clarified. There should be no duplication or inconsistencies with ongoing work on revising chemical legislation. The SoCs to be reported in the product passport must be defined based on the usefulness of the information they provide and selected with care.

18. We welcome mandatory Green Public Procurement as a tool to drive circularity forward.

19. We welcome increased market surveillance focus including on imported products, leading to increased level playing field.

20. Incentives (recital 86, article 57) should also include measures that stimulate the market for refurbishment or remanufacturing, not only newly produced products.

21. Clear definitions are needed (manufacturer, distributor, recycling, substances of concern, product group …).

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