13.10.2017   

EN

Official Journal of the European Union

C 345/97

Rapporteur:

Cillian LOHAN

1.1.

The scope of the Ecodesign Working Plan 2016-2019 is too limited to be a strong driver for wholesale change in behaviour through the supply chains of goods and services at a pace that would reflect the ambition of the Circular Economy Action Plan.

1.2.

The ecodesign of goods and services needs to go beyond just energy considerations. Although these are important, there is a need to have a focus on the full lifecycle of products, including their durability, ease of maintenance and repair, potential for sharing and digitisation, reuse, upgradeability, recyclability and actual uptake after use in the form of secondary materials in products entering the market.

1.3.

Ecodesign needs to incorporate the principles of the circular economy, in the context of digitisation, sharing and the functional economy, in order to have consistency across the various strategies that are intended to deliver a new economic model.

1.4.

The component parts of a product should be easily recoverable for reuse and/or remanufacture and drive the creation of a strong secondary raw materials market.

1.5.

Labelling requirements can drive improved ecodesign strategies and help consumers in decision making, thus becoming a driver for behavioural change. Labelling should include a life expectancy of a product, and/or its important components.

1.6.

The EESC reiterates it support for the use of Extended Producer Responsibility as a tool to promote the transition to circular economy business models, and emphasises that this too can play a role in the promotion of ecodesign.

2.1.

The Ecodesign Working Plan 2016-2019 contributes to the Commission’s new initiative on the Circular Economy. The overarching goal is to promote a transition to a circular economic model that takes into consideration the whole lifecycle of products and their materials.

2.2.

It follows on from previous Ecodesign Working Plans for the periods 2009-2011 and 2012-2014. Its legislative context is that of both the framework Directive 2009/125/EC Ecodesign and the framework Directive 2010/30/EC Energy Labelling. Regular Working Plans are foreseen in Article 16(1) of the Ecodesign Directive.

2.3.

It is envisioned as a means of strengthening Europe’s competitiveness and promoting economic growth while boosting job creation.

2.4.

There was some expectation that any review of the Ecodesign Directive or update of the Working Plan would result in a broadening of the scope of the previous ecodesign initiatives.

3.1.

The Ecodesign and Energy Labelling legislative framework is identified as having a dual purpose (1). The first is to ensure that via ecodesign progressively more efficient products are permitted on the EU’s market. The second is focussed on empowering and encouraging consumers to buy the most efficient products through energy labelling.

3.2.

The current Working Plan sets out the implementing measures adopted, including 28 Ecodesign Regulations, 16 energy Labelling Delegated Regulations, and three recognised Voluntary Agreements.

3.3.

Other areas of work include the ecodesign measure for air heating and cooling products which will take the form of a regulation, and a series of amendments to regulations to improve product testing and reduce the scope for cheating through ecodesign and energy labelling. These initiatives are complementary to this working plan, and are referenced but not specifically contained within it.

3.4.

The assessment and presentation of existing and ongoing work is focussed on energy labelling and achieving an element of ecodesign only in the context of efficiency of performance.

3.5.

New product groups have been added to the list of product groupings that are the focus of existing legislation or reviews. These are:

4.1.

Ecodesign can contribute to the decoupling of economic growth from resource consumption through a decreased use of materials and energy, higher recycling rates and reduced waste generation (2). The power of a circular economy model is that the creation of economic prosperity, social benefits and environmental gains go hand in hand. Ecodesign can be an important driver for social sustainability.

4.2.

Although the Ecodesign Directive has been used to improve the energy efficiency of products, it could also be used more intensively to stimulate circular product design, for example by ruling out design strategies that hinder the repair or exchange of faulty parts (3).

4.3.

Ecodesign delivers product-service systems and products made with fewer resources, using recycled and renewable resources and avoiding hazardous materials, as well as utilising components that are longer lasting and easier to maintain, repair, upgrade and recycle. Two approaches can be distinguished: product redesign based on incremental improvements to existing products and new product design which seeks to develop new resource-efficient products that can be repaired, upgraded and recycled (4). The implementation of the Ecodesign directive has mostly pushed the first incremental approach to date, but it should now step up the application of the second approach, in conjunction with the development of revised, appropriate labelling, and via support from the European standardisation organisations’ ongoing work in these areas.

4.4.

A major element of circular design is that a product can become a service with a shift in emphasis from ownership to usership, from selling a product to performance based contracting, e.g. Product-Service System (PSS) and Service-Level Agreements (SLAs).

4.5.

In the agricultural and food production sector, it should be noted that sustainable food production systems, such as in particular organic ones, are both examples of circularity and ecodesign.

4.6.

The recently launched joint initiative between the EESC and the European Commission on establishing a multistakeholder European Circular Economy Stakeholder Platform can facilitate the mapping of best practices in the field, and identify policy barriers to transition to ecodesign.

5.1.1.

The ecodesign of goods and services needs to go beyond just energy considerations. Although these are important there is a need to have a focus on the full lifecycle of products, including their durability, ease of maintenance and repair, potential for sharing and digitisation, reuse, upgradeability, recyclability and actual uptake after use in the form of secondary materials in products entering the market. Ecodesign needs to be part of an integrated approach, where both energy efficiency and performance of products is considered in conjunction and on equal footing with efficiency and performance in terms of use of resources and materials.

5.1.2.

The current Working Plan acknowledges the limitations of focussing primarily on energy performance. The need for a more comprehensive ecodesign strategy is clear for both consistency and clarity. The Ecodesign Directive itself is not limited to the energy performance of energy-related products but also addresses the wider scope of the material parts of such products, and the wider impact and costs of a lack of resource efficiency.

5.1.3.

The principles of the circular economy require goods and services that are durable, reusable, repairable and recyclable. Ecodesign needs to incorporate these principles, in the context of digitisation, sharing (5) and the functional (6) economy, in order to have consistency across the various strategies that are intended to deliver a new economic model (7). The risks associated with the current inconsistency can lead to uncertainty for the business sector, which in turn inhibits innovation or investment in business models that are based on a more comprehensive circular economy model. It will also lead to developments aiming for resource efficiency at the cost of excessive energy use and vice versa. The ongoing and future selection of products, which has so far been based on energy inefficiency, should be extended with products and services with a high resource inefficiency.

5.1.4.

A strong secondary raw materials market is essential for the development of a circular economy. Ecodesign should be contributing to the design of products and services that allows for the separation of component parts of a product. That is, the component parts of a product should be easily recoverable for reuse and/or remanufacture. Design should allow for this recovery of secondary raw materials to supply clean and high quality materials to the market.

5.1.5.

The use of design as a driver for a strong secondary raw materials market needs to occur in the context of the importance of durability and modularity in design also.

5.2.1.

A range of strategies should be used to change consumer behaviour. Labelling alone will not be sufficient to achieve widescale behavioural change. Previous EESC opinions have already specified the need for using economic instruments (8), product lifespan labelling (9) and behavioural economics (10) (in particular nudge thinking (11)) as part of a toolkit for achieving the transition.

5.2.2.

The requirement of behavioural change is not limited to consumers and end users. The business sector needs support through incentives and certainty on policy direction in order to encourage change. This will be especially crucial in the SME sector, where training and support tools can boost the understanding and application of the principles of ecodesign, and ensure that any transition comes with reallocation of workers as appropriate to minimise displacement.

5.2.3.

The EESC reiterates its support for the use of Extended Producer Responsibility as a tool to promote the transition to circular economy business models, and emphasises that this too can play a role in the promotion of ecodesign.

5.2.4.

The EESC’s opinion dedicated to the Circular Economy Package (12) refers to the role of new ownership models, which would include leasing product services. This can also drive ecodesign as a commercial imperative, with benefits for both the environment and for society as a whole.

5.3.1.

Most of the Ecodesign and Energy Labelling implementing measures have review clauses which are due in the coming years. These will specifically examine the resource efficiency, repairability, recyclability and durability of products.

5.3.2.

The EESC highlights the importance of applying these principles to the ongoing studies of the existing product list, and not only to the new product groups that are to be included in this Working Plan.

5.3.3.

Applying these principles should not only be externalised to the reviews, but also should now be integrated into the Ecodesign Working Plan.

5.4.1.

The EESC notes that the current Ecodesign Working Plan was revisited in the light of the Circular Economy Action Plan. However, the consultation with the Consultation Forum regarding the draft Ecodesign Working Plan proposals, as required by Article 18 of the Ecodesign Directive, was held at the end of October 2015. This was before the launch of the Circular Economy Action Plan.

5.4.2.

The Consultation Forum should take note of the official position taken by the organised civil society through the work done at the EESC.

5.4.3.

ICT products are included in the Working Plan solely as a ‘separate track’ group due to the complications and difficulties associated with fast moving products, and the uncertainty of future market developments. It is noted that labelling for these products typically takes too long to develop (on average 4 years) and that voluntary agreements are not delivering environmental, economic and social gains with sufficient rigour and speed.

5.4.4.

The separate treatment of ICT products within the Working Plan is significant. Specific clear direction and ambition needs to be set for this sector in order to drive innovation in ecodesign of these products. Applying ecodesign to mobile phones for example, could make mobile phones the ambassadors for ecodesign, using a communications device to communicate to a wide audience the practicalities of ecodesign and the consequences and benefits to them of it.

5.4.5.

The EU-US Energy Star Agreement is due to expire in 2018. This sets the same voluntary efficiency requirements for office equipment in both jurisdictions. There may be risks associated with the extension of this agreement given the new political dynamics in the USA. The review should consider the competitive advantages of a strong support for ecodesign for business in Europe. The EU has an opportunity to be a world leader in this field. The importance of reciprocity and international agreements should not be underestimated in achieving the mainstreaming of ecodesign.

5.4.6.

There is an expressed indication that a more comprehensive section on the contribution of ecodesign to the circular economy within the Plan will be developed. This recognition of the need to broaden the scope is welcome but needs to be accompanied by specific short delivery times.

5.4.7.

The development of a circular economy toolbox for ecodesign, such as the Circular Design Guide recently published by the Ellen MacArthur Foundation, can facilitate change but will need to have the support of strong appropriate legislation, backed up with background research, extensive stakeholder consultation and standardisation support. From both the consumer perspective and the business perspective, the product price and economic incentives will determine the uptake of such a toolbox. The polluter-pays principle can underpin best practice in this area.

5.4.8.

The challenges faced in terms of market surveillance and international cooperation should not be underestimated. The EESC notes that there is an increased need at Member State level for implementation and reporting through market surveillance, and that if this is not forthcoming, there may be the need for stronger surveillance mechanisms to be implemented at national level, coordinated either indirectly or directly via oversight at EU level. The utilisation of different surveillance or inspection mechanisms to those currently commonly used in ecodesign and energy labelling may also require consideration, in order to minimise the presence of ‘free-rider’ manufacturers and importers on the EU’s market, and to protect and reward the investments made by companies who are following good and transparent practices in ecodesign, labelling and provision of product information and declarations.

5.4.9.

Labelling is critical when it comes to consumers and transparency. However, labelling is not a cure-all, and may especially not be the most appropriate tool when dealing with business to business products/services. Labelling, where appropriate, should reflect life expectancy, and not just focus on energy performance. For example, a building may have a high rating due to its energy performance, but may also warrant greater recognition for the materials used in its construction. Or a large complex product (e.g. some heating, cooling or ventilation product system) may warrant further recognition for the materials used and also their repairability, replaceability, durability and recyclability.