The Eco-design Directive for sustainable products - are product owners ready?

The Eco-design Directive for sustainable products - are product owners ready?

March 2024

by Tim Hartley, Senior Consultant at 42T

The new eco-design regulation promises to be highly impactful for those manufacturing and designing goods sold within the EU. We discuss what you need to be aware of.

In an effort to promote environmental sustainability and combat climate change, the EU is proposing a new regulatory framework building on the 2009 Eco-design Directive that will have a far-reaching impacts on goods sold in Europe.

Eco design regulations

This article explores the key aspects of the proposed regulation from a product owners’ perspective which, if passed, will extend beyond energy-related products to encompass a wide range of goods placed on the EU market.

What are the big changes for product owners?

There are five key changes to the existing Eco-design Directive that will be likely to affect companies producing products in the EU going forward.

1.    Directive to regulation

While both directives and regulations are legal acts used to achieve the aims set out in the EU treaties, directives set out goals that must be achieved by all EU countries but leave it up to individual countries to decide how to achieve them. Regulations are binding legislative acts that must be applied in their entirety across the EU.

This is one of the big differences for the new Eco-design regulations, with the change aiming to create a more uniform set of standards so products can be compared and there will be less ambiguity for manufacturers.

2.    Expanding scope

The scope of the new proposed regulation is broad, encompassing all physical goods sold on the market, with only a few exclusions like food, feed, medicinal, and veterinary products. This expansion aims to create a comprehensive framework for enhancing the environmental performance of products across various sectors.

3.    Eco-design requirements

The regulation introduces two types of requirements: performance requirements and information requirements.

Performance standards encompass aspects like durability and ease of repair, while information requirements include details like substances of concern and materials comprising the product. These will be contained in the product passport. This is intended to give consumers clear information to compare products.

The performance requirements will be established for different product groups separately. The goals of these are to enhance product durability, reliability, reusability, upgradability, and reparability. Moreover, the focus is on reducing energy consumption, promoting energy efficiency, optimizing resource utilization, and minimizing environmental impacts.

To ensure a well-rounded perspective, an expert group comprising representatives from Member States and various stakeholders, including industry, retailers, and environmental organisations, will continue to influence the development of Eco-design requirements.

4.    Product passport

Each product group will require a product passport. This passport will contain product information, including performance and information requirements, traceability data, declarations of conformity, technical documentation, user manuals, and manufacturer details.

This is expected to take the form of an identifier on each product which can be used to reach the digital documentation for each product containing traceability information, instructions for end-of-life and other key information on the use and sustainability of the products. The exact information to be stored in this is as yet to be decided but forms a key part of the EU circular design strategy.

5.    Unsold goods

Companies discarding unsold products will be required to publish data on quantities, reasons for disposal, and efforts toward reuse, remanufacturing, recycling, energy recovery, and disposal.

This transparency measure would aim to discourage wasteful practices and improve accountability. The Commission would also be authorised to ban the destruction of environmentally impactful product groups.

Eco design regulations

Timelines to be aware of

The regulation was proposed in March 2022 and is currently going through the regulatory approval process. The exact timing of its implementation is uncertain, but many companies are already beginning to prepare for its effects.

In particular, there have been some products already identified for their environmental impacts which will be part of the first wave to come under the jurisdiction of this new regulation. This list includes textiles, furniture, mattresses, tyres, detergents, paints and lubricants.

This regulation is planned to be adapted with the changing conditions in the product market and as the 2050 deadline approaches. An evaluation of the regulation is scheduled eight years after its adoption, allowing for continuous improvement and adaptation.

Where to from here?

The new Eco-design regulation - if passed in its current form - promises to be highly influential for those manufacturing and designing goods sold within the EU. By promoting product performance and information transparency the regulation paves the way for a greener and more sustainable future.

We have the capability to support your teams with the changes that will be required. If you require a team of specialists to help move your product portfolio in line with new regulations and stay ahead of the market, capitalising on the opportunity this change may provide contact us at

With the likelihood of emerging requirements from different markets in multiple areas of legislation, we are uniquely positioned to assist. We routinely redesign and/or source materials for products and packaging to meet these challenges for our clients.

Tim Hartley | +44 (0)1480 302700 | LinkedIn: Tim

Tim Hartley is a consultant at 42 Technology with experience in conceptual design, development, testing and prototyping. He has worked on many different products from diverse industries. These range from surgical devices to food and beverage handling systems.  42T believes in drawing in knowledge from other sectors to achieve client goals.

At 42T we have a team of expert designers and engineers with a wealth of across different industries, from concept design to manufacturing line optimisation. 

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