Eurovent Position Paper on Ecodesign Regulation for Sustainable Products EP

Eurovent supports the Ecodesign Regulation for Sustainable Products proposal. Product sustainability must be addressed in harmonised way across the EU to ensure the free movement of products within the Single Market. For the new Ecodesign framework to be as successful as possible while stimulating innovation and preserving the competitiveness of European industry, Eurovent makes the following recommendations:

1. Avoid overlaps and double regulation.
2. Specify requirements product group by product group.
3. Allow sufficient lead times and predictability before requirements come into force.
4. Ensure proper stakeholder consultation and evidence-based decision-making.
5. Use harmonised European standards rather than common specifications.
6. Avoid third-party conformity assessment if not strictly justified.
7. Implement the Digital Product Passport respecting proportionality.