Manufacturers and industries in the EU stand at the precipice of transformative change to how they design and support their products, and how they address the waste from their operations and product lifecycle. This stems from legislation known as Ecodesign for Sustainable Product Regulations (ESPR), which over the next few years will create durability, reparability, recyclability directives around 31 product types that are expected to have the largest net contribution to energy and material savings.

Taken all together, this is a series of policy initiatives aimed at reaching climate neutrality by 2050. The intent is to give electronics manufacturers guidelines and market incentives to review their design principles. These guidelines were set forth so that in the long term, electronic products would be manufactured using fewer resource and sustainable practices. The directive was updated and re-released in October 2012 to expand the scope beyond just electronic products. An updated and further expanded version is anticipated in 2023 for implementation starting as early as 2024.

Taken all together, this is a series of policy initiatives aimed at reaching climate neutrality by 2050. The intent is to give electronics manufacturers guidelines and market incentives to review their design principles and manufacture products using fewer resource and sustainable practices.

Changing how goods are manufactured and sold

There is an existing, thriving European internal market for a wide variety of goods. It is the EU policy to ensure that as ecodesign principles are applied, a robust market for sustainable goods will exist on a level playing field with existing products. This will require harmonized requirements for manufactured product. It is also noted that existing products may have safety, performance, reporting or supply chain restrictions. The intent of the ESPR regulations is not to re-write any existing statutory requirements.

To be effective, the ecodesign approach needs to be applied broadly and to prioritize action on those features that have the most detrimental environment effects. The main criteria include operational elements like durability, reusability, upgradability and reparability.

On the manufacturing side the issues encompass substances of concern, energy consumption and resource efficiency. Recycled content and re-manufacturability have been identified as having significant opportunities for improvement.

The EUGD plan intends to stimulate the market for climate neutral and sustainable products by promoting sustainable design, empowering consumers and promoting circularity in design and production. Perhaps one of the most challenging of the three aspects is the part about empowering customers. The proposed steps for consumer engagement include improving information on products at point of sale regarding durability and reparability. The aim is to help prevent greenwashing and premature obsolescence. Affected industries will need to perform Life Cycle Assessments (LCA) on their products which will require guidance on how to convey this information to users in a useful way.

Stakeholders weigh in

To better understand the impact, the European Commission performed a wide-ranging series of assessments. They approached stakeholders with educational workshops, convened public groups, met with small to medium enterprises, manufacturers and importers, and produced other targeted surveys over a period from late 2020 through mid-2021.

The commission found wide support for sustainability initiatives. In addition, the consensus was that the means for assessing progress should be based on a whole lifecycle analysis. This decision makes for considerable extra work with each new product release. Nonetheless, it was widely accepted as the best way to accurately assess progress. As a result, the current state of the EUGD initiative, as written, applies to a wide range of products with exceptions only for food, feed and medicinal products.

ESPR product priorities

As a result of that work, it was deemed necessary to set up an ecodesign forum to assist the commission in the development of a working plan and the preparation of ecodesign requirements. Another outgrowth of the commission’s work is the need for a digital medium to electronically register, process and share product-related information throughout the supply chain. This increases the transparency amongst all stakeholders. The form and content requirements have their own committee; however, the solution will need to address four main categories: traceability, product-related information, environmental issues and circularity assessment.

Candidate products for this first ESPR working plan are:

• Materials, such as iron, steel, aluminum and cement
• Chemicals and solutions, like detergents, paints and lubricants
• Consumer goods, like furniture, textiles or electronics
• Automotive parts; most notably tires
• Energy related products, although this remains somewhat ill-defined

A set of criteria which helps define a threshold for developing sustainability plans around product types. There are three basic criteria:

• The product (or product family) under review must be of sufficient volume to have a significant financial impact
• The product must have (by definition) significant environmental impact
• The product must present sufficient potential for improvement in its environmental impact at reasonable cost.

There are a number of sub-articles contained in this main article which take into account such “reasonableness factors” as life cycle of the product, existing environmental regulations, industry competitiveness and so on.

The intent is not to create market winners and losers by making implementation measures too onerous. At the same time implementation measures should move industries forward in terms of the circular economy and lessened environmental impact. It is foreseeable that several companies operating in similar (or horizontal) sectors could be in similar economic situations. They may all, therefore, benefit from a common implementation plan. With this thought in mind, the intent and challenge of the implementation plan is to provide guidelines for generic improvements available within the ecodesign framework.

As the ESPR is moving forward to release the next edition, it will have an expanded scope of products to consider. Each product group that falls under ESPR will have its own Implementing Act, which is a set of laws that make compliance mandatory.

To prepare your company the first step is to understand which group a product will fall under and which laws are currently applicable and if any changes are contemplated. A good starting point for this information is the document Ecodesign and Energy Labelling Working Plan 2022-2024. Sections 2.3, 2.4, and 2.5 of this document list the various product families along with a summary of any findings and current status.

What is the Digital Product Passport?

Along with the upcoming release of new regulations, the Digital Product Passport (DPP) requirements move closer to reality. The EU is deploying a DPP focused on the three value chains of textiles, batteries and electronics. This pilot program should start in 2023. Eventually, it will migrate to all product families by 2030.

Depending on the information required for each of the product families, it could serve to provide transparency, boost buyer confidence, increase consumer trust, validate green claims, ensure compliance and potentially even ownership history. This effort will form the basis for system requirements including data and IT architecture.

The other part of this is the physical media being used to convey this information. There are several options including 2D bar codes, 3D bar codes, QR codes, RFID tags and more. This is a conversation EU industry associations are having currently with its member organizations.

LCAs

Remember that the environmental focus is a key part of the whole picture here and the focus for this measure is based on LCA. This is an in-depth analysis of your product “footprint” with regard to specific environmental factors. This could be greenhouse gas emissions, water consumption, consumption of energy from non-sustainable resources, and so on.

An LCA is usually done in four steps:

1. Define precisely what your goal is
2. Put together a lifecycle inventory – collect the data relevant to your goal at every step of the lifecycle
3. Summarize findings by adding up all of the impacts of interest as defined by a specified goal
4. Interpret the data in context. Ask if there are opportunities to reduce the environmental impact in some part of the lifecycle and if so, what are they?

A useful guideline and industry-standard source is ISO 14044:2006. In addition, an online search will uncover other sources, worksheets and templates designed to facilitate LCA development.

Opportunities to self-regulate

The directives that make up the requirements for the ESPR (reduced environmental footprint), CEAP (sustainable practices and recycling), and DPP (electronic tracking) must be monitored regularly in order to ensure compliance.

Companies within a particular industry group can petition to be self-regulatory, rather than being monitored directly by a governmental agency of the directive. Nonetheless, this self-regulatory body and policy must still contain all of the elements of the directive.

• Open to participation by any eligible third-party companies.
• Must deliver added value measured in terms of environmental improvement.
• Must represent a substantial majority of that economic sector.
• The objectives of the stakeholders of this group must be clear and stated with reference to an established baseline.
• Self-regulatory initiatives must be published on the internet and other public forums for comment.
• The monitoring plan must be detailed, transparent and objective.
• Self-regulation must be cost-effective relative to the objectives and other available policies.
• It must contain all of the policy objectives of the directive with regard to health, environment and quality of life.
• To maintain incentives, the self-regulation policies must be consistent with national policies and objectives.

Despite the administrative overhead of managing a self-regulation program, there are advantages. One of the primary benefits is that an industry sector is likely more time-efficient when it comes to implementing changes to design or processes. It is also likely to be more cost-effective to implement changes as some of the administrative burden is shared throughout the industry.

Final thoughts

The time horizon for achieving the climate-neutral objective is 2050, and the first directive toward this goal was released as a public document in 2009. This means that we are currently 1/3 of the way through the timeline. This just emphasizes how big and ambitious this task is. And we have to remember that when 2050 comes, whether we’ve met the goal or not, everything that we will have done at that point must continue. We need to get really good at reducing waste and pollutants. Our supply chain will look very different at that point. There will be people in the workforce who consider it normal to consider an LCA for product changes, and to choose materials that biodegrade, or that are re-useable because that’s just the way we care for the Earth. We will need to think and act differently about everything in the world today if we want a better tomorrow.

About the author

Scott Orlosky has an MS in Manufacturing and Control Theory from the University of California at Berkeley and has worked over 30 years designing, developing, marketing and selling sensors and actuators for industrial and commercial industries. He has written numerous articles and application notes for speed and position sensors used in industrial and hazardous area environments including an author credit in “Encoders for Dummies.” Scott authored an industrial newsletter for nearly 15 years and is also co-inventor on a number of patents involving design and manufacturing of inertial sensors.