9 June 2021 – Today, Eurospace has submitted its response to the European Commission’s (EC) public consultation on the Sustainable Products Initiative (“SPI”). The initiative which will revise the Ecodesign Directive and propose additional legislative measures as appropriate, aims to make products placed on the EU market more sustainable; a related EC legislative proposal is planned for the fourth quarter of 2021 (see EC SPI website).
In its detailed contribution paper (available here), Eurospace recalls the existing EU provisions governing the reporting on Substances of Very High Concern (SVHC) in articles – Article 33(1) of the REACH Regulation and Article 9(1)(i) and (2) of the revised Waste Framework Directive (WFD) on the one hand, and existing exclusions for equipment sent into space in a number of EU product laws on the other hand. Eurospace stresses the need for full coherence with these provisions and advocates an alignment with the REACH Candidate List and the definition of SVHCs.
Specifically in relation to the SPI, ASD-Eurospace is calling on the EC to clarify the scope of the SPI for non-consumer products, and to confirm that the planned extension of the Ecodesign Directive does not concern equipment sent into space (Space Products), also because such products are not resulting in waste on Earth or on the EU territory and are no consumer products.
Furthermore, ASD-Eurospace requests a dedicated feasibility, usefulness and impact assessment to ensure that any new requirements that would apply such as the Digital Product Passport will collect relevant and proportionate information for operators at a reasonable cost and that it is critical to ensure the protection of confidential data.
Finally, Eurospace offers its availability to support the EC’s work on the Sustainable Products Initiative and the Digital Product Passport, should it be intended to extend beyond consumer products – which, as we understand, is not the case today.
The Eurospace response to the SPI public consultation is the second key deliverable prepared with the support of the CSS Space Focus Group, a new splinter group of 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 (see Eurospace News of 26 April 2021). Previously, Eurospace had already submitted related feedback to the EC on 1 June 2021 on its REACH Revision Roadmap (see Eurospace News of 1 June 2021).
- Group coordinator and REACH expert: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., email@example.com; +358 (0)40 773 8143
- Secretariat: Pierre Lionnet, Research and Managing Director, ASD-EUROSPACE, firstname.lastname@example.org, +33-(0)1 44 42 00 70