Position Paper on the EU Commission's proposal for a new Ecodesign Regulation

The TÜV Association welcomes the proposal for an Ecodesign Regulation submitted by the EU Commission in order to increase the ecological sustainability of products over their entire life cycle. The TÜV Association believes, however, that there is a need for improvement in some sections.

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The Ecodesign Directive 2009/125/EC has already been able to continuously reduce negative environmental impacts of energy-related products, while ensuring a level playing field for companies in the EU Single Market.

The EU Commission's proposal now goes further in this direction by significantly broadening the scope of the ecodesign requirements on the one hand and introducing new requirements on the other. The requirements comprise, for instance durability and reliability, reusability, repairability, ease of repair and maintenance, the absence of substances of concern, energy and resource efficiency and recycled content. Setting these requirements will help to increase the lifetime of products, reduce their carbon and environmental footprint, thus making them more sustainable and enabling a true circular economy.

Apart from setting out ambitious requirements, it is crucial to ensure their consistent and effective compliance. Independent conformity assessments are a powerful tool and should be made mandatory in the Ecodesign Regulation. By independently testing or certifying products before they are placed on the market, their conformity with the legal requirements can be ensured in a reliable manner. At the same time, non-compliant products can be prevented from being manufactured and thus resources can be saved. In addition, independent verification strengthens transparency and thus consumer confidence in the reliability of manufacturers' product claims, for example with regard to sustainable production and the absence of hazardous substances. Finally, market surveillance authorities, which often have limited resources, are relieved considerably as non-compliant products are not even placed on the market. Thus, the precautionary principle is consistently taken into account through independent third-party assessment with regard to central ecological product requirements.

The Central Demands refer to:

  1. Conformity assessment (Articles 4, 36 and Annex IV)
  2. New ecodesign requirement (Article 5)
  3. Digital Product Passport (Article 7-13)
  4. Standardization
  5. Self-regulation (Article 18, Annex VII)
  6. Presumption of conformity of certificates offered on a voluntary basis (Article 34)

Download the extensive Position Paper

EU Commission proposal for a new Ecodesign Regulation COM(2022) 142