Everything you need to know about the EU’s upcoming Sustainable Product Initiative

The Sustainable Product Initiative is coming – and it’s set to change everything for companies placing products on the EU market. The initiative will transform every aspect of designing, producing, and selling products and aims to make sure that sustainable products become the norm on the EU market. This will also allow the EU to meet its climate goals. Upholding the principles of the 2020 European Green Deal and Circular Economy Action Plan, the new policy aims to make products durable and repairable while also reducing waste and harmful chemicals. 

So what does this mean for companies? It means you need to prepare for major changes at all stages of your workflow. You’ll need to rethink product design, incorporating longevity from the start. The initiative will overhaul traditional business models, by incentivizing new circular business models like product-as-a-service.

Businesses should also prepare for new ways of measuring and labelling sustainability and consider how they can ensure their employees have the skills necessary to implement these changes. In short: the Sustainable Product Policy Initiative affects everything from design, production, marketing, and aftersales to workforce management. 

Clearly, businesses will need to stay on top of the changes and be ready to put them into action. But as the initiative hasn’t yet been finalized, you can also take a more active role by participating in EU consultations to have your say on what the final legislation should look like. 

Want someone with deep experience and connections in the EU to help guide your sustainability strategy? Get in touch! 

Timeline and Key Players


Here’s the thing: there’s a time crunch on getting involved. The European Commission ran an Impact Inception Assessment last year to get opinions on its roadmap for the initiative. Now, the Commission has just opened a 12-week consultation period, deadline June 9th  during which stakeholders can give more detailed feedback on what they need from the legislation.

You can answer the consultation on the European Commission’s Have Your Say website. We expect more workshops to be organized by the Commission to gather more input from companies and other interested parties. The plan is for the final policy to be published, along with other key initiatives that form part of the Circular Economy Action Plan, by the end of 2021. 

Companies looking to take part in the consultation will need to plan now and get their position papers prepared. But in addition to preparing for external policy engagements, businesses should also kickstart their internal plans for how they intend to comply with the legislation.  The policy will regulate product design at the earliest stage, which means companies need to start thinking about how to incorporate sustainability such as durability and recyclability into their development processes for products they plan to release in the next 2-3 years.  

Making contacts

You should also start connecting with the key players in the initiative. The European Commission is responsible for drafting the policy and running the consultation processes, with DG GROW, DG ENV, and DG ENER taking the lead. 

Once this upcoming 12-week consultation closes, the Commission will draft the legislation, which they’ll pass over to the Council and Parliament who have the final say in amending and approving the initiative. For a step-by-step breakdown of how to engage with each of the EU decision-making institutions, check out our article on the topic.

What you need to know about the EU’s Sustainable Product Initiative 

Expanded scope 

The EU’s Sustainable Product Initiative expands the product scope of the 2009 Ecodesign Directive – so it’s no surprise that eco-design is at the core of the policy. The Ecodesign Directive limited its focus to sustainability within energy-related products, while this new initiative extends to all kinds of products: textiles, electronics, furniture, steel, chemicals, and more. The Sustainable Product Initiative applies to any company placing products on the European market, not just European companies

Connects with other policies

Legislation for the Sustainable Product Initiative draws on several other legislative proposals as part of the Circular Economy Action Plan. These include policies for empowering consumers and for substantiating green claims, which are already in progress and should be finalized at the end of 2021.

The initiative will also be connected to proposals for policy on the right to repair, industry emissions, and industry-led certification. These policies apply to all product types – but if you want an overview of the upcoming textile-specific strategy, take a look at our article.

Overarching sustainability principles 

The main principle of the Sustainable Product Initiative is to only allow sustainable products to be produced, advertised, and sold in the EU market. It sets out concrete product requirements that span all dimensions of sustainability, with circular product design at its core. The idea is to intervene before products become waste – but the initiative will also include waste and recycling policy. 

 The key areas are: 

  •     Sustainable  product design 
  •     Circular product-as-a-service models
  •     Tracing products across the life cycle 

 Ban the destruction of unsold durable goods

  •     Waste and circular resource flows

Key pillars of the Sustainable Product Initiative

Sustainable product design 

The EU is pushing companies to ensure their products have inbuilt longevity rather than inbuilt obsolescence. This will mean designing for purpose and manufacturing robust products that can be reused, upgraded, and repaired. The EU Commission is also looking into increasing recycled material content, as well as reducing carbon and environmental footprint at product level.  

Circular product-as-a-service models

The Sustainable Product Initiative aims to make business models circular, ending the culture of throwaway products and incentivizing consumers to repair and reuse the items they buy. Companies will need to switch to product-as-a-service models, where customers buy the full service and experience of using the product. This will likely include after-services like repair, as well as an increase in rental reuse. 

Tracing products across the life cycle

The ability to track products across the full value chain is a key aspect of the Sustainable Product Initiative. The initiative calls for companies to implement life cycle analysis (LCA) methodologies that trace the environmental impact and production process of products from raw material right through to the end of their life cycle, so someone looking to recycle a garment, for instance, would be able to tell exactly which chemicals had been used throughout.

The initiative wants to strengthen information requirements through tools like digital product passports. This will make companies accountable for demonstrating their commitment to sustainability at every stage of the product’s life. The scope defined in the ongoing consultation is very broad and includes repair and upgrade instructions, the presence of hazardous chemicals, reusability, recycled material content, recycling, correct disposal and waste stream information. 

Destruction of unsold goods 

The EU initiative follows the approach several Member States have taken over the past few months, by banning the destruction of unsold goods to limit overproduction. Several criteria are on the table to define the scope of this ban and to decrease the number of unsold goods on the EU market.   

Waste and circular resource flows

To encourage circular resource flows, the Sustainable Product Initiative will need to set out clear criteria for waste shipment, classification, and definition. The policy will also minimize waste by banning companies from destroying overstock or unsold goods. 

Organizations will also need to increase the amount of recycled content in their products and engage in remanufacturing practices. 

Getting ready for the Sustainable Product Initiative 

The Sustainable Product Initiative, alongside key proposals for empowering consumers and substantiating green claims, will shake up every stage of the product life cycle. Sustainable design isn’t just required of energy-related products anymore – this will affect every company that sells products within the EU.  

Companies need to prepare for big changes and get their sustainability strategy in place. The initiative calls for major moves towards robust, circular product design; life cycle traceability; measurable sustainability labelling, and regulation of waste and circular resources. 

As well as getting prepared, make sure you get your voice heard. The EU’s 12-week consultation process on the Sustainable Product Initiative has just opened, and stakeholders should take the opportunity to share their opinions and shape the final policy. It’s time for companies to lead the way on sustainable and circular production. 

At Ohana, we guide companies on designing and implementing sustainability strategies that comply with EU policy like the Sustainable Product Initiative. With deep experience and EU connections, we also help companies to engage with EU decision-makers to get their voice heard in shaping legislation. We can support you in preparing your organization to be truly sustainable – get in touch!

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