- The scope of the Ecodesign Working Plan 2016-2019 is too limited to be a strong driver for wholesale change in behaviour through the supply chains of goods and services at a pace that would reflect the ambition of the Circular Economy Action Plan.
- The ecodesign of goods and services needs to go beyond just energy considerations. Although these are important, there is a need to have a focus on the full lifecycle of products, including their durability, ease of maintenance and repair, potential for sharing and digitisation, reuse, upgradeability, recyclability and actual uptake after use in the form of secondary materials in products entering the market.
- Ecodesign needs to incorporate the principles of the circular economy, in the context of digitisation, sharing and the functional economy, in order to have consistency across the various strategies that are intended to deliver a new economic model.
- The component parts of a product should be easily recoverable for reuse and/or remanufacture and drive the creation of a strong secondary raw materials market.
- Labelling requirements can drive improved ecodesign strategies and help consumers in decision making, thus becoming a driver for behavioural change. Labelling should include a life expectancy of a product, and/or its important components.
- The EESC reiterates it support for the use of Extended Producer Responsibility as a tool to promote the transition to circular economy business models, and emphasises that this too can play a role in the promotion of ecodesign.