Joint Industry Letter on the SPI Regulatory Approach

Our associations recognise the imperative of complementing the decarbonisation objectives under the European Green Deal (EGD) with efforts to improve the environmental sustainability of products. The Commission has indicated that it has been politically decided that the scope of the Ecodesign Directive is to be widened to include non-ErP, in addition to the ErP currently within the scope of the Directive. Should the Ecodesign methodology be applied to non-ErP products, we believe that the legislation should be sensitive to the differences between ErP and non-ErP products. We believe that a one-size-fits-all approach should not be the way forward.