Eurospace welcomes product-specific approach of new EU ecodesign framework proposal – strategic role and specificities of space products highlighted

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20 June 2022 – Today, Eurospace has submitted a joint European Space Sector feedback on the European Commission Proposal of 30 March 2022 for a Regulation of the European Parliament and of the Council establishing a framework for setting ecodesign requirements for sustainable products – Ecodesign for Sustainable Products Regulation (“ESPR”). The proposal is part of the Commission’s Sustainable Products Initiative (“SPI”); see COM SPI website.

The European Space Sector recognises and is working proactively to reduce the environmental impact of space activities, for example as part of the EcoDesign branch of the ESA Clean Space Office, which includes work on space-specific adaptations to the life cycle assessment (LCA) approach.

In its detailed feedback paper (MPTB-ES-PO-0105; available here), the group welcomes and supports the overall objectives and product-specific framework approach of the ESPR Proposal, as well as the explicit acknowledgment in recital (16) of the ESPR Proposal of key specificities of space products with regard to any ecodesign requirements:

“Similarly, the space industry is strategic for Europe and for its technological non-dependence. As space technologies operate in extreme conditions, any ecodesign requirements for space products should balance sustainability considerations with resilience and expected performance.”

The Eurospace paper points out that space products have additional important characteristics that should also be taken into account for the implementation of the new Ecodesign for Sustainable Products Regulation, once adopted.

Based on these specificities the paper concludes that space products should have a rather low priority for setting ecodesign requirements.

If any ecodesign requirements or a Digital Product Passport were considered for space products, these should be underpinned by in-depth and detailed impact assessments, fully exploring the possibilities of specific provisions/exemptions in the Regulation; in particular “performance requirements” may not be necessary.

In relation to the broad definition of “substance of concern” in the Regulation proposal additional complexities due to reporting discrepancies as compared to REACH Article 33 and WFD/SCIP are feared; a full alignment of SPI provisions with the REACH Candidate List is therefore advocated.

More generally, there is a need – as also acknowledged in the ESPR Proposal – to prevent duplication and ensure clarity as regards the interface between ESPR and REACH rules governing chemicals, including chemical substances in products.

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The present feedback has been prepared with the support of the CSS Space Focus Group, a 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). It follows on the Eurospace contribution of 9 June 2021 to the Commission’s Public Consultation on the SPI (MPTB-ES-PO-0078; available here).

Eurospace, as part of the CSS Space Focus Group, now aims to continue following the legislative process on the adoption of the ESPR Proposal in the European Parliament and in the Council, providing further input as appropriate.

Contacts:

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