Eurospace calls on the Commission to narrow down product priorities for its Sustainable Products Initiative, focusing more on consumer products

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23 May 2023 – On May 11th, Eurospace has submitted a joint European Space Sector feedback in response to the European Commission Call for Evidence on “New product priorities for Ecodesign for Sustainable Products” (link to initiative).

The Commission’s recent proposal on Ecodesign for Sustainable Products of 30 March 2022 (link to proposal package) aims to make products sold in the EU subject to performance and information-related requirements, to ensure greater sustainability.

With the present Call for Evidence the Commission has sought views on the categories of new products and measures to address first. This includes many products that are used in the European Space Sector today, such as ceramic products, lubricants, paints and varnishes, iron and steel, non-ferrous metals, aluminium, chemicals, plastics and polymers, or glass.

In our position paper (here) and questionnaire response (here) we have emphasized some key messages:

  1. We welcome the initial focus on simpler products, excluding very complex objects such as electronics but also excluding products manufactured in the European space industry.
  2. We are concerned about a possible upstream impact, due to the high number of products considered as a first priority. We are concerned that regulating all these products in a similar timeframe could cause widespread and unforeseen obsolescence cases for materials and processes for space production. Therefore, a further shortlisting of prioritised products is required, excluding notably technical ceramics for aerospace industries, non-consumer lubricants and chemicals.
  3. We call for an explicit prioritisation of consumer products, with a clear legal definition of “consumer”, excluding professionals and industrial use; at least, these different product groups should be clearly distinguished by customer group.
  4. The horizontal measures currently envisaged (durability, recyclability, post-consumer recycled content) are not relevant nor appropriate to set for products designed to be sent into space. With regard to recital (16) of the Commission’s ESPR proposal of 30 March 2022, space use shall not have any limitation in material selection driven by substances impacting recyclability. This should be taken into account when defining the scope of ecodesign requirements for relevant upstream products, as part of horizontal or other measures.

The present feedback has been prepared with the support of the CSS Space Focus Group under the Materials and Processes Technology Board of the European Space Components Coordination (ESCC MPTB), which is a partnership between the European Space Agency (ESA), national space agencies, and space industry represented by ASD-Eurospace.

This feedback follows on a number of previous Eurospace contributions since 2021 on the Commission’s Sustainable Products and Ecodesign initiatives, being priority files for our sector.

Contacts:

  • Secretariat: Pierre Lionnet, Research and Managing Director, ASD-EUROSPACE, pierre.lionnet@eurospace.org, +33-(0)1 44 42 00 70
  • Regulatory expert: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., tim.becker@reachlaw.fi; +358 (0)40 773 8143