SBS* welcomes the Commission’s proposal for a new Regulation on eco-design requirements for sustainable products and the measures aimed at SMEs it includes. According to SBS, the implementation of the proposal will heavily rely on delegated acts and European standards. Financial support will be needed to ensure the involvement of SMEs in the development of these standards and regulations, and to guarantee SME participation in the Ecodesign Forum.

On 30 March, the Commission issued its proposal for a new eco-design Regulation which includes a series of measures Member States and the Commission are required to take to help SMEs with the implementation of the future Regulation. Moreover, it proposes the creation of an Ecodesign Forum to provide advice to the Commission on the ecodesign working plan, in setting priority product groups and ecodesign requirements. 
 
Since SMEs represent most businesses in the EU, they will be key to the successful implementation of the proposal. Many SMEs traditionally operate at the local level in areas such as repairing, refurbishing and maintenance and will certainly benefit from business opportunities in these areas. Yet, they will also need to adapt to new requirements and cope with additional costs.
 
As stated in its position paper, SBS considers that the new Regulation and its delegated acts should provide a well-balanced approach that ensures implementation is workable, proportionate and shows evidence that the environmental benefits will exceed the costs. The Regulation should be accompanied by market instruments that support the uptake of sustainable products and by incentives facilitating the implementation of the Regulation among SMEs.

One of the main novelties of the proposal is the creation of a Digital Product Passport (DPP) to register, process and share product-related information amongst actors within the supply chain, authorities and consumers. The DPP will heavily rely on standards for its deployment. SBS stresses the need to involve SMEs in the development of these standards as well as in any pilot projects to develop DPP prototypes.

SBS supports the intention of the Commission to only apply the Regulation to products not covered by existing legislation or when legislation does not sufficiently address the sustainability of those products. It also agrees that ecodesign requirements should not have an impact on the functionality and safety of the products. For SMEs, it is indeed important to ensure the coherence between the future Regulation and its delegated acts and other pieces of legislation affecting a specific product.  

Commenting on the proposal, SBS Secretary General Maitane Olabarria said: “SBS welcomes the measures foreseen to ease the implementation of the future Regulation by SMEs. Nevertheless, SBS believes the Regulation should also provide a legal basis to provide adequate resources, including financial resources, for SMEs and SME representatives to participate in the Ecodesign Forum and relevant standardisation work.”
 
SBS position can be consulted via the following link.

* Small Business Standards (SBS) is a European non-profit association (aisbl) co-financed by the European Union and EFTA Member States. Its goal is to represent and defend small and medium-sized enterprises’ (SMEs) interests in the standardisation process at European and international levels