Discussion paper: The role of the Product Environmental Footprints Classes of performance in the Ecodesign for Sustainable Products Regulation

A well-functioning green market entails the presence of mechanisms that create a market pull after products with a good environmental performance combined with a regulatory push to ensure that the worst performing products are excluded from the market. The EU energy label in combination with the Ecodesign Directive have successfully managed to provide such mechanisms (energy labelling and minimum performance requirements).

The aim of this discussion paper has been to examine how the PEF-method can support the classes of performance within the ESPR, and which circular aspects need additional assessment methods. This includes discussion of the opportunities for using the PEF method to establish classes of performance as well as the limitations that influence the relevance and applicability of the PEF method within the ESPR.

This paper concludes that the PEF method only to a limited extend provide the needed framework to support the classes of performance in the ESPR, and only if PEFCRs are in place the product group under consideration. PEF is an environmental assessment method with a core focus on environmental emissions and resource consumption. The PEF method can therefore only cover the product parameters related to the environmental impacts of a product. However, the ESPR aims at making ecodesign requirements to improve the environmental performance of products related to parameters that amongst other are core to circularity such as durability, reparability, and reusability. These product parameters are however either not covered or they are covered indirectly in the assessment, but then not communicated or visible to the consumer. Therefore, the PEF method cannot stand alone as the methodological framework for the classes of performance in the ESPR.