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The European Commission has recently announced two guiding principles for EU product policy: First, product policy shall ensure that the performance of front-runner products in terms of sustainability becomes the norm, and second, the effectiveness of the current Ecodesign legislative framework is going to be significantly improved. Within this paper, already existing front-runner approaches and recent and ongoing product policy-making processes were reviewed. Based on the results, an EU front-runner approach is outlined. The presented approach (i) refers to performance levels of the best products already available on the market, (ii) aggregates information in existing databases, and (iii) works semi-automated. Together, all three attributes have a high potential to facilitate and accelerate the specification of appropriate minimum requirements for products at the EU level. This way, EU policymakers can deliver on the core objectives of the Ecodesign legislative framework much better. The basic mechanism and its legal entrenchment of the approach are illustrated for the energy efficiency of energy-related products. In addition, the Front-Runner Approach can be applied to any product group in the scope of the upcoming Ecodesign for Sustainable Products Regulation and to a wide range of product-related minimum requirements, such as durability, reparability, or recycled content. The study’s objective is to suggest a tailor-made and dynamic approach to keep the EU product legislation up to date using innovative technology based on the investigation of current regulations and identify the gap. Experiences from three international case studies suggest that a front-runner approach to setting energy-performance standards can drive innovation and reduce energy consumption via promoting energy-efficient products; transparency about available products is one of the key factors and can be established by a database. The EU front-runner approach comprises extending the existing energy label database (or making use of the digital product passport) and introducing a legislative procedure that triggers changes in the energy efficiency requirements in the specific EU regulations if the database shows that a certain threshold value is reached. Challenges such as limited EU staff capacities and opportunities such as increased dynamic are discussed.
In 2020, the European Commission has announced to propose a Sustainable Product Policy for the EU which shall ensure that the performance of front-runners in sustainability progressively becomes the norm. In addition, the European Commission has re-emphasised the necessity to significantly improve the effectiveness of the current Ecodesign framework for energy-related products.
With this paper, we present an initial outline of a policy approach which we call the “EU frontrunner approach”. The approach aims at installing a regulatory framework which enables a semi-automated, progressive adaptation of ecodesign minimum requirements for products. It builds on performance levels of the best products available on the market by aggregating information in a database.
The “front-runner approach” could first be applied to progressively adapt product-related minimum energy-efficiency requirements. This way it would serve as a starting point to introduce this conceptto the EU policy arena.
While the approach can be applied for energy efficiency, it is neither limited to energy-related products nor to energy-related requirements. It can be applied to the wide range of nonenergy related products within the scope of the upcoming Ecodesign for Sustainable Products Regulation (ESPR) as well as to non-energy-related requirements, such as minimum requirements for durability, reparability, recyclability and recycled content.
Improving the energy efficiency of products was identified as the most important short-term opportunity to decrease energy consumption and therefore CO2-emission worldwide. More efficient products are created due to technical innovation. Restricting market access to efficient products only and making the most efficient products stand out by energy labelling are legislative approaches to encourage this development. Market surveillance authorities’ checks are fundamental to protect the consumer from wrongly declared goods on the market and ensure fair competition between manufacturers. However, the activities of market surveillance authorities are limited by their financial resources. Testing all product efficiency parameters in an accredited laboratory is very time consuming and cost intensive. In this article, a theoretical concept is presented which can be used to develop screening tests enabling market surveillance authorities to perform product tests with less financial resources. The concept identifies components which lead to non-compliance or make a product less energy efficient with minimum effort. The principle is based on a combination of random product tests, disassembling specific products and comparing components. This represents a new approach in product testing procedures beyond the current market surveillance activities. The concept is being tested within a research project funded by the German government.
Smart Products Enable Smart Regulations—Optimal Durability Requirements Facilitated by the IoT
(2021)
The challenges and opportunities linked with IoT have been intensively discussed in recent years. The connectivity of things over their entire life cycle and the smart properties associated with it provide new functionalities and unprecedented availability of (usage) data. This offers huge opportunities for manufacturers, service providers, users, and also policymakers. The latter May impact policy areas such as the regulations on resource and materials efficiency under the Ecodesign Directive 2009/125/EC. With the general approach as it is practiced today, legal requirements are usually set for entire product groups without considering the products individually, including user behavior and environmental conditions. The increasing number of smart products and the growing availability of product data are sparking a discussion on whether these requirements could be more product and application-specific. This paper presents a method for calculating the economically and ecologically optimal durability of a product. It allows determining the point in time when a product should be replaced by combining consumer data with product design data. This novel Approach could contribute to making product regulation more flexible and possibly more efficient. In this context, fundamental challenges associated with smart products in policymaking are also discussed.
Resource efficiency is a much discussed topic in terms of improving the sustainability of energy related and energy non-related products. Resource efficiency aspects such as the availability of spare parts, the ability to dismantle, etc. have been included in draft working documents in the revision of several already existing Ecodesign regulations as a first step. However, often these aspects are not consistent with the current technology and design of these products. A possible reason could be a lack of sufficient consultation or of a methodology which is sufficiently tailored for this topic. The established strategies and tools, used by policymakers, such as the Methodology for the Ecodesign of Energy-related Products (MEErP), do not seem to deal with these aspects appropriately. Draft requirements need to be very well developed before being discussed with member states and other related stakeholders, because including resource efficiency parameters could lead to additional, very wide-ranging effects on society. This topic cannot be covered well with legislative tools developed primarily for energy aspects. In this paper, a method is presented which can be used to combine products’ properties with crucial resource efficiency indicators. The method can be used to develop a set of draft legislative requirements and to pre-evaluate these requirements by target groups which would be affected by additional legal requirements. These include: market surveillance authorities, standardization organizations, manufacturers and their associations, environmental organizations and research facilities. The method incorporates stakeholders’ feedback to identify potential resource efficiency measures for materials and/or products, their impact on the European ecology, economy and society. Based on this it would help to develop legislative requirements which are feasible and desirable. The results can then be fed into the formal legislative process, probably speeding it up.
(i) Überblick zum aktuellen Stand der Normung und aktuellen Normungsvorhaben im Bereich Ökodesign.
(ii) Vorstellung des Forschungsprojektes (Steigerung der produktbezogenen Energie- und Ressourceneffizienz) vor allem in Hinblick auf Vorhaben die sich auf die Langlebigkeit, Reparierbarkeit und Recyclingfähigkeit.
Whilst the concept of ecodesign is intended to account for the environmental impacts of the product across its whole lifecycle, European ecodesign policy to date has been heavily focused upon energy efficiency in the use phase. The Ecodesign Directive and Energy Labelling Regulation have achieved substantial energy savings since their inception. For many products, the magnitude of savings available from further tightening existing energy efficiency requirements is now often outweighed by savings that can be achieved by material efficiency requirements. Further, there are some products such as smartphones for which there are limited gains to be made in energy efficiency but for material efficiency. In the Commission’s Circular Economy Action Plan from 2015, a new direction was defined for ecodesign policy, to systematically examine considerations such as reparability, durability, upgradability, recyclability, or the identification of certain materials or substances. The Commission consequently issued a standardisation request (M/543, 2015) to the European Standardization Organisations (CEN / CENELEC / ETSI) to develop generic/horizontal standards relevant to energy-related products that address these major aspects of material efficiency. In this study we evaluate the potential contribution of these new standards (with specific focus on the standards for repair, durability and recyclability) to future developments under the European Ecodesign Directive. Opportunities for the impact of these standards to be enhanced by future work are highlighted.
Improving the energy efficiency of products was identified as the most important short-term opportunity to decrease energy consumption and therefore CO2-emission worldwide. More efficient products are created due to technical innovation. Restricting market access to efficient products only and making the most efficient products stand out by energy labelling are legislative tools to encourage this development. Market surveillance authorities’ checks are fundamental to protect the consumer from wrongly declared goods on the market and ensure fair competition between manufacturers. However, the activities of market surveillance authorities are limited by their financial resources. Testing all product efficiency parameters in an accredited laboratory is very time consuming and cost intensive. In this study, a theoretical concept is presented which can be used to develop screening tests in order to perform product tests by market surveillance authorities with less financial resources. The method identifies components which lead to non-compliance or make a product less energy efficient with minimum effort. The concept is based on a combination of random product tests, dismantling specific products and comparing components. This represents a new approach in product testing procedures beyond the current market surveillance activities. The concept is being tested within a research project funded by the German government.