Swedish Enterprise’s position on broadening the scope of the Ecodesign Directive 

It is important that the development of product policy takes place at EU level. National policies and regulations for circular economy run the risk of creating barriers to the EU internal market and to circular flows between countries and thereby also hamper product development. A well-functioning internal market is a prerequisite for the success of the circular economy in the EU.

Properly drafted, the Sustainable Products Initiative (SPI) and a broadening of the Ecodesign Directive may be relevant and appropriate tools for promoting the development of more sustainable products.

In our position paper, we comment on the work of the European Commission and present the following ten main messages:

1. 1.
   Retain key elements of the Ecodesign Directive when its scope is broadened
2. 2.
   Review the appropriateness of drafting one or more directives and safeguard transparent processes
3. 3.
   Ensure systematic and transparent selection process for inclusion of new products in the Ecodesign Directive
4. 4.
   Mandate the standardisation organisations to further develop sustainability principles into horizontal and product specific  
5. 5.
   Ensure that drafting of product requirements incorporates common set methodologies and consultation with business
6. 6.
   Safeguard and develop standards as tools for verification and for enabling continuous technical development and innovation
7. 7.
   Carefully co-ordinate the Directive with other Green Deal initiatives
8. 8.
   Allow various methods for verifying fulfilment of requirements and refrain from introducing a general demand for third-party verification
9. 9.
   Increase efforts to monitor implementation of legislation to ensure a level playing field
10. 10.
    Improve and strengthen market surveillance across the Union