Trends in Ecodesign Regulations: Effective Dates and Disclosure Requirements: Preparing for Future Regulations

Zeroboard Inc.
Taku Nozoko, General Manager of the Solutions Development Department, Sales Division

The EU's Ecodesign Regulation *1) (ESPR), issued on July 18, 2024, is a new regulation aimed at reducing the environmental impact of products and ensuring the free flow of sustainable products. In the future, it will apply to almost all products, and even consumer products such as apparel and cosmetics may be required to conduct environmental impact assessments based on Life Cycle Assessment (LCA) and calculate and disclose their product carbon footprint (CFP).
While these regulations stipulate penalties for violations, specific disclosure requirements and application dates will be determined gradually for each product through a "delegated law." Therefore, it is extremely important for companies to understand early on when and what kind of response their products will be required to take based on the upcoming schedule.
This column summarizes the following points:
・The latest trends in ESPR and an overview of the target products
• Disclosure requirements including CFP and LCA, and potential improvement requirements for each product.
• Product Category with high priority for the development of delegated legislation and publication schedule
Preparations that companies should start now, without waiting until 2026.
This is Contents that company representatives conducting business with the EU should be aware of as soon as possible.

For companies working to reduce the environmental impact of their products and Service
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LCA-based carbon footprint (CFP) calculation solutions. Support from our experts is also available.
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1. overview of Ecodesign Regulations *1

The Ecodesign Regulation came into effect on July 18, 2024.*1)The aim is to improve the environmental sustainability of products and reduce CO2 emission amount and environmental footprint throughout their entire lifecycle. Having been transformed from a "directive" to a "regulation," it now has the same legal force as national law in EU member states, and penalties for violations are also stipulated. Furthermore, it applies to almost all products, with the exception of some exemptions such as food and pharmaceuticals.

2. Disclosure items required by the Ecodesign Regulations *1

The disclosure items can be broadly divided into two types: those relating to the technical specifications of individual products, and those relating to environmental impacts that are evaluated and disclosed in accordance with LCA (Life Cycle Assessment). In particular, the carbon footprint (CFP) and microplastic emissions of products are included, and requirements such as upper and lower limits are expected to be Settings in future delegated laws for each product.

3. Anticipated disclosure items and improvement requirements for each product

A report by the Joint Research Centre for Europe (JRC) summarizes the disclosure items that may be required for each product. Apparel (textiles and footwear), cosmetics, tires, and detergents are likely to be required to disclose CFP (Certified Financial Plan), while furniture and absorbent hygiene products are expected to be required to disclose LCA (Life Cycle Assessment) related items as well. However, it should be noted that these are the JRC's views and not decisions made by the European Commission.

4. Schedule of requirements for Ecodesign Regulation *1

The product categories for which delegated legislation will be prioritized include 11 final products and 7 intermediate products. The specific application schedule will be announced in the "First Work Plan," which is scheduled to be adopted in the second quarter of 2025. However, current predictions suggest that delegated legislation for textiles, footwear, and steel will be published and issued sometime in 2026.

5. Conclusion

While some aspects of the specific requirements of the Ecodesign Regulation *1) are still undecided as they will be finalized in a future delegated law, it is essential to begin preparations for compliance even before the delegated law is issued in 2026. Without waiting for the details to be finalized, this document outlines directions for companies to begin preparing for disclosures such as CFPs immediately, taking into account current European regulations and existing guidelines (such as PEFCR).

Zeroboard, the provider of this document, offers consulting Service to support LCA (Life Cycle Assessment) implementation, as well as CFP (Certified Financial Planner) calculation and management tools.

For companies working to reduce the environmental impact of their products and Service
Zeroboard CFP
LCA-based carbon footprint (CFP) calculation solutions. Support from our experts is also available.
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*1)Source: European Union : EUR-Lex "Ecodesign Regulation": https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R1781&qid=1719580391746

*2)Source: "Ecodesign for Sustainable Products Regulation: Study on new product priorities" by JRC : https://publications.jrc.ec.europa.eu/repository/handle/JRC138903　

*3)Source:" DPP System Roadmap" by the "CIRPASS" Management Office V2.0 May 2024":https://cirpassproject.eu/wp-content/uploads/2024/05/D3.4_DPP_System_Roadmap_V2.pdf

*4)European Commission Products Bureau"Websites of various research groups of the European Commission":https://susproc.jrc.ec.europa.eu/product-bureau/product-groups