00:00 – Greetings & Introduction to today’s topic: EU Ecodesign Regulation.

02:26 – Why is product design important?

Manufacturers and product designers need to consider the product lifecycle and what happens to it at the end of its useful life in the design itself. Products will need to be at least 80% recyclable and should be designed to be disassembled so they can be recycled easily. Manufacturers of products that currently don’t comply will need to show that efforts have been made to make the products more sustainable, they cannot just keep importing with no changes.

08:07 – The role of ‘Repairability’ and ‘Maintainability.’

Consumers will need to be given access to spare parts and repair shops will need to be provided with instructions by the manufacturer about how to repair and maintain products. This helps reduce waste by increasing product lifetimes. Modern mobile phones are not made to be repaired or maintained, and that will need to change. This is connected to the ‘Right To Repair’ movement.

10:12 – The need to document your approach.

Initially, the ESPR will have general rules and specifics will follow. Importers should refer to them and document a risk analysis for different alternatives along with costs, why a particular approach was chosen, etc.

12:03 – How product designs will need to change according to the EU ESPR proposal [quotes].

Durability, impact on the environment, and enforcement are 3 key topics coming from the proposal.

All of the requirements of the regulation will affect your product design: design for reliability, recyclability, sustainability, durability, reusability, upgradability, and lower carbon footprint will all need to go into your design risk assessment.

Accelerated life testing will become the norm to test durability and reliability, and its data will be in the technical file attached to the product passport.

18:38 – Addressing ‘Greenwashing.’

Any green claims will need to be proved explicitly. So when new products are designed, the ability to show why it is ‘green’ must be considered. This will apply to all markets, too, so not importing into Europe doesn’t excuse you from being concerned about this, as the USA, for example, is making moves in this direction, too.

20:47 – Postmarket surveillance.

The amount of data required to be collected once the product is being sold to be compliant with ESPR is the same as for the EUMDR (medical devices regulation)…in other words, it’s a lot. This includes logs of complaints and known issues about durability, ease of repair, reliability, recycling, disposal, etc, that will be regularly-reviewed quarterly.

The product label must include a ‘unique identification number’ that is given by the certification body if a product complies and is provided to the European commission – without this, the products may not be sold in Europe.

25:01 – Calculating energy consumption throughout the product lifecycle.

ESPR requires more action in addition to a product lifecycle assessment to assure that the product and manufacturer reduce greenhouse gas emissions. ISO 14040 and 14064 standards detail how to reduce these. Your technical documentation will need to calculate and state how much energy and waste is required to produce and dispose of each product.

30:11 – Supply chain information will be transparent – suppliers who are more sustainable will be preferred.

The corporate due diligence regulation requires importers to know who their suppliers for materials and components are and what their environmental and safety impact is. If your supplier has a very poor environmental record or sells unsafe products which break quickly, buying from them without researching their impact and sustainability will be a bad idea. Your supply chain information will be made widely available to inspectors and consumers in your product passport as required by the ESPR. Therefore, consumers will be empowered to reject products that haven’t been made sustainably and the authorities can prosecute companies who import products made by suppliers who breach the corporate due diligence regulation.

34:37 – The example of garments and their supply chain.

Garments don’t have a CE mark. But now the label will have to feature product passport info as a QR code or barcode that can be scanned by consumers. It will provide a serial number that can be searched online in the EU database and bring up a product description if it is real.

The buyer/importer will need to know ALL parts of the supply chain – who supplies the cotton, where it is made into yarn and dyed, textile manufacturer, cut and sew factory, etc. Data on process steps will be in the technical file and made available to the EU commission.

37:58 – Detailed traceability & visibility over the supply chain – requirements.

If you do not know your supply chain information or your supplier will not provide the information to you, you will not be able to work with that supplier any longer, or at least sell the product in Europe any longer, as you would be breaking the law by not disclosing the information. 

You’ll need full supply chain information and environmental impacts for at least three tiers of suppliers per material and component, such as the mine where a particular mineral was extracted, plating companies, assemblers, etc.

A higher priority for transparency is on materials that make up more of the BOM and/or are known to have a great environmental impact.

43:18 – ESPR will evolve over time and cause headaches for importers…

It will be enforced for 8 years after the product has been put on the market and it will be connected to social compliance requirements, including health and safety, such as from pollution, as well as environmental impact. Over time more requirements will be clarified and added. 

46:23 – The key data you need to start collecting NOW.

Request suppliers for data on the energy required to make a product, waste generated, toxicity, and carbon footprint now. If they cannot or will not supply it, consider finding new suppliers ASAP. 

48:13 – Will ESPR negatively impact SMEs more than large businesses?

SMEs are concerned, but the EU commission has consulted businesses of different sizes, trade unions, environmental groups, etc, since 2016 and found that the regulation will not have a negative impact on SMEs. The problem for SMEs comes if suppliers abroad, such as in China, will not provide information. The EU commission doesn’t see that as their problem. The EU commission usually won’t be swayed by protests once they have decided on a course of action.

52:36 – You have been warned!

Importers cannot ignore this regulation. If a product doesn’t have a passport it will not be permitted entry to the EU.