What is it called?

The “European Green Deal” is the EU’s action plan to make the EU a sustainable, climate-neutral economic system by 2050. Whilst the Green Deal encompasses a wide range of policy areas, such as energy, agriculture, buildings, transport and pollution, and is very much part of a broad policy priority for the European Commission, there are certain aspects that have particular implications for product manufacturers. The wide-ranging measures in the plan aim to tackle areas including the circular economy and chemicals.

What is being proposed?

Since announcing the Green Deal in 2019, the European Commission has begun publishing various legislative initiatives to achieve its ambitious goals. For manufacturers and sellers of products, the circular economy action plan is amongst the most significant of these initiatives.

The Circular Economy Action Plan

The European Commission announced the adoption of its updated Circular Economy Action Plan on 11 March 2020. The Circular Economy Action Plan aims to disrupt the traditional economic model for products and to foster circular production to recapture the wasted value of products through a number of interrelated initiatives and targets relating to sustainability of products, the reduction of waste and developing the market for high quality secondary materials. If you manufacture or sell products, the changes may require you to take action in relation to product design, repairability, information provision and more.

Initiatives include:

  • Introducing the Sustainable Product Initiative (previously discussed on Productwise here), which aims to make products placed on the EU market more sustainable, durable, reusable, repairable, recyclable and energy efficient eg. through expanding the Ecodesign Directive beyond energy-related products.
  • Addressing the presence of hazardous chemicals in products and increasing the recycled content in products by reviewing waste electrical and electronic equipment recycling legislation and hazardous chemicals legislation (this forms part of the pollution initiative of the Green Deal).
  • Expected proposals for a new framework for batteries, which will aim to boost the growth of high performance batteries with the smallest possible environmental footprint.
  • The EU Strategy for Textiles, expected in2021, which is anticipated to outline the regulatory changes to come for the EU’s textile supply chain, boosting circular practices from design to end-of-life. Stricter rules are due to be proposed to address “greenwashing”.
  • Introducing new consumer measures such as new information requirements (e.g. labelling requirements for energy consuming products) and plans for restricting single use and planned or premature obsolescence and establishing a “Right to Repair”.

More details of the proposals can be found on our blog here. Key takeaways from our team’s recent webinar on the circular economy can also be found here.

EU Chemical Strategy for Sustainability

You may also need to consider the recently published European Chemical Strategy for Sustainability, which contains significant initiatives relating to:

  • Prohibitions on the “most harmful chemicals” across a broad range of sectors in many product safety regimes, including introducing new prohibitions in the GPSD and REACH;
  • Introduction of increased information requirements to be provided to consumers regarding chemical composition;
  • Legislative amendments to the existing chemicals framework in the EU, including REACH ;
  • Minimising the allowance of “substances of concern” in certain products; and
  • Assessing risk presented by chemicals more accurately by considering daily and multiple sources of exposure.

Who will it apply to?

The proposals under the EU Green Deal will affect a wide range of sectors from consumer products such as electronics, food and textiles to automobile and construction industries. All businesses that sell or intend to sell products into the EU, will need to be prepared to adapt and respond to the new and increased regulation relating to product design, reduction of waste and carbon emission measures.

Why does it matter?

The Green Deal and the measures that will be brought in, such as those relating to the circular economy action plan are wide ranging. Given the substantial market transformation that the Green Deal promises – for example with requirements to enhance sustainability that will touch every stage of the product lifecycle – manufacturers, sellers, and others in the supply chain should continue to track these emerging legal requirements in order to review their practices and ensure compliance.

Where can I find it?

The European Commission’s communication on the Green Deal can be found here.

You can find more detail about the Green Deal here:

Sustainable Products Initiative: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12567-Sustainable-Products-Initiative

Posted by Carol Holley

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