The last 23rd April the European Commission approved the publication of a Regulation establishing a framework for setting ecodesign requirements for sustainable products. In this paper we want to report a summary on the major changes and obligations for the manufacturer.
First of all, the regulation shall apply to any products that is placed on the European market or put into service, including components and intermediate products. These goods to be placed on the market must comply with some sustainable requirements. Some of these requirements are “horizontal”, which means that they are applicable to all products, such as:
- Durability
- Reliability
- Reusability
- Reparability
- Upgradability
- Possibility of maintenance
- Presence of substance of concern
- Water, energy and resource use
- Recycled content
- Environmental impacts …
Moreover, for each product category the European Union will publish Delegated Act with some specific requirements. For example, there will be the delegated Act for furniture, textile, varnishes, polymers and metals.
Requirements could request to comply with a certain performance or could be of information. Anyway, to be put on the market the product must have a Product Digital Passport, on a European digital platform, with at least this information:
- Unique product identifier
- Global trade identification number
- Contact information of the manufacturer with unique operator identifier
- Compliance documentation and information required under this Regulation or pother Union law applicable to the product, such as the declaration of conformity, technical documentation or conformity certificates
- User’s manual, instruction, warnings or safety information…
Other contents will be specified with the Delegated Acts.
So, what will be the obligation for the manufacturer or first importers?
- Ensure that products have been design and manufactured in accordance with the eco design requirements
- Ensure that products are accompanied by the information and a product passport is available (including a backup copy)
- Before placing a product on the market carry out the conformity assessment and draw up the required technical documentation
- Draw up the EU declaration of conformity and affix the CE mark.
It is important to remark that exist the presumption of conformity in case the product will be design and manufactured in accordance with harmonized standards.
The Regulation will come into force soon, but the implementation will be from 2027/28. The next step will be the publication of the first Delegated Acts which will cover furniture, textile, plastic and metals.
Finally, the Regulation provides for an obligation to document unsold goods and prohibits their destruction. Small and medium-sized enterprises are currently exempt from the obligations of this article of the Regulation.
For info:Matilde Ceschia
+39 0432 747241
ceschia@catas.com
