Position paper
Position on the ESPR proposal – 22 June 2022
Position paper
Position on the ESPR proposal – 22 June 2022 :


EPEE, representing the Refrigeration, Air-Conditioning and Heat-Pump (RACHP) industry, welcomes the European Commission’s proposal for a new Ecodesign for Sustainable Products Regulation as an ambitious piece of legislation.

The present position paper aims to highlight the loopholes where the draft regulation may fall short in the future implementation and provide an overview of the main recommendations in this respect:

  • Assess requirements on a product-by-product approach by applying the proportionality principle in setting product specific requirements and ensure these are measurable and verifiable.
  • Ensure a consistent approach with existing EU legislations by aligning definitions to avoid loopholes or overlap.
  • Consider the expertise of standardisation bodies and avoid the introduction of inconsistencies among the different policy areas and legislation.
  • Streamline information requirements and clarify the reference to the performance levels and the Digital Products Passport’s provisions.
  • Support e-labelling as a more sustainable alternative to providing physical paper-based
  • Assess the introduction of a performance label on case-by-case basis, to avoid an overlap with the products that are already in scope of the Energy Labelling Regulation.
  • Avoid one-size-fits-all and maintain specific considerations for ErP groups.
  • Consider the risks of disclosing competitively sensitive information on unsold goods.
  • Support market surveillance authorities by including customs into the surveillance systems and ensure unnecessary duplication of data.
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