- Welcomes the harmonised proposals under the Circular Economy Action Plan and, in this opinion, specifically supports efforts to make products more sustainable. At the same time, it notes that the proposed new Ecodesign Regulation is still vague for the most part, because of the large number of delegated acts.
- It proposes faster and more ambitious implementation, but draws particular attention to the fact that the circular economy approach can only succeed if all economic operators – producers, consumers and workers – and authorities are properly involved and informed.
- Welcomes the new elements of the Regulation, such as the extended scope, the new ecodesign requirements (durability, repairability, recycling, environmental impact, CO2 emissions, etc.) and the information requirements of the digital product passport and labels, emphasising the importance of correct and relevant information, especially for consumers.
- Supports the ban on destroying unsold goods – understood as new, returned or repairable goods. It also welcomes the fact that, together with the circular package, the Regulation tackles existing issues, such as greenwashing and obsolescence.
- Promotes the Ecodesign Forum, a supporting body with a number of tasks relating to implementation. All stakeholders and civil society representatives, including social partners, should be given the opportunity to put forward ideas and suggestions to improve the process.
- Recognises the challenges facing producers and businesses, especially SMEs, but unnecessary red tape should be avoided. It also sees an opportunity to create a new European production standard – Made in Europe – with sustainable product standards.
- Underlines that the tools for the declaration of conformity and self-regulation provide scope for entrepreneurship.
- Regrettably notes that the Regulation overlooks the social dimension. A reference to the Commission's proposed Directive on Corporate Sustainability Due Diligence seems insufficient.