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The European Commission DG GROW (Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs) has entered into a contract with VITO, Viegand Maagøe, VHK and Fraunhofer ISI on an Ecodesign preparatory study for product specific measures on scarce, environmentally relevant and critical raw materials and on recycled content.

Political context

Highlights of the political context regarding product policy relevant for this study are:


The Ecodesign Directive requires product manufacturers to improve the environmental performance of their products by meeting minimum energy efficiency requirements, as well as other environmental requirements such as water consumption, emission levels or minimum durability of certain components. The Energy Labelling Regulation complements Ecodesign by enabling end-users to identify the better-performing products, via the well-known A-G labelling grading.

The Circular Economy Action Plan targets how products are designed, promotes circular economy processes, encourages sustainable consumption, and aims to ensure that waste is prevented, and the resources used are kept in the EU economy for as long as possible. It announces a sustainable product policy legislative initiative to make products fit for a climate neutral, resource efficient and circular economy, reduce waste and ensure that the performance of frontrunners in sustainability progressively becomes the norm.


The aim of the SPI (Sustainable Products Initiative) is to revise the Ecodesign Directive to set out the EU policy framework necessary to achieve the circular economy objectives. A proposal for Ecodesign for Sustainable Products Regulation was published by the Commission on 30 March 2022.

The Preparatory study for the Ecodesign and Energy Labelling Working Plan 2020-2024 (carried out by Viegand Maagøe, VHK and Oeko-institut) recommended after detailed analyses of a broad range of product groups and horizontal initiatives among others to include in the Ecodesign and Energy Labelling Working Plan two horizontal initiatives, namely post-consumer recycled content and scarce and critical raw materials. Alone implementation of measures for recycled content was assessed in having a very high saving potential, estimated at 160 PJ.

In May 2022, the Commission published the Ecodesign and Energy Labelling Working Plan 2022-2024 and, in addition to product specific priorities, recycled content and scarce, environmentally relevant and critical raw materials  were included.

The Working Plan emphasises the following focus points as background for selecting recycled content and scarce, environmentally relevant and critical raw materials as important horizontal aspects:

  • They are a continuation of prior circular economy measures in the Ecodesign work for energy-related product, especially the measures adopted in 2019 and they should contribute to the transition to the ESPR (Ecodesign for Sustainable Products Regulation).

  • Horizontal standards on material efficiency aspects for energy-related products under Mandate 543 are now in place, which can be the basis for developing product specific material efficiency standards for energy-related products.

  • The Methodology of Ecodesign for Energy-related Products (MEErP) under revision is expected to introduce a more systematic way of covering circular economy aspects for studies on specific product groups.

The Working Plan states that the Commission will assess the possibility and appropriateness of establishing product-specific requirements on recycled content and scarce, environmentally relevant and critical raw materials for energy related products, where dedicated preparatory studies will be needed to help identifying the product categories that are most relevant for potential regulatory approaches. The current study is the first step for implementing this part of the Working Plan.

The purpose and objectives of the study are:


  • The purpose is to conduct an Ecodesign preparatory study on potential product-specific requirements on recycled content and on scarce, environmentally relevant and critical raw materials, and to propose possible implementing measures under the Ecodesign and Energy Labelling Regulatory Framework.

  • The study objectives are:

    • investigating in more detail the materials and the products that could be subject to these requirements;

    • investigating the technical, economic, environmental, market and societal impacts of these potential requirements; and

    • providing the elements needed for the identification of policy options in the subsequent impact assessment.


If, on the basis of the study findings, the Commission finds it appropriate to develop an implementing measure under the Ecodesign Directive and/or the Energy Labelling Regulation, working documents will be drafted.


Two phases to be carried out: 

  • Phase 1: Prioritization of materials and product groups 

  • Phase 2: Execution of the preparatory study 


Phase 1 is a scoping phase aiming at identifying products and materials to be proposed for the detailed studies in phase 2. 

Phase 2 contains 5 mini Ecodesign studies focusing on recycled content and on scarce, environmentally relevant and critical raw materials for the products and materials selected in Phase 1. The studies will be based on the revised MEErP (Methodology of Ecodesign for Energy-related Products) and revised EcoReport Tool. For relevant measures draft working documents will be pepared. 

Stakeholder consultation will take place in both Phase 1 and 2. Please register here for receiving updates and invitation for stakeholder meetings.


Main milestones relevant for the stakeholders are:

  • 19 October 2023 10:00-12:30: Online stakeholder meeting, register here:

    • Presentation of aim and methodology of the study

    • Preliminary considerations on products and materials

    • Input from stakeholders

  • July 2024: Second stakeholder consultation meeting

    • Presentation and consultation on draft Phase 1 report

    • Presentation of approaches for Phase 2

    • Input from stakeholders

  • October 2024: Third stakeholder consultation meeting

    • Presentation and consultation on draft Phase 2 report

    • Input from stakeholders

  • Beginning 2025: Publication of final Phase 1 and 2 reports and end of study

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