Submission to the DETE & the DECC on the European Commission’s Proposal for a Regulation on Ecodesign for Sustainable Products

IMA has called for a whole of government, integrated approach to policy to bring together all stakeholders and relevant government departments across the ecosystem with assessments to identify strengths and weaknesses. 

Key concerns are: 

• Protection of confidential business data, data within the scope of the Digital Product Passport and interplay with other legislation
• Duplication of efforts and overlaps in regulation, in particular for substances of very high concern (SVHCs);
• Implementation with a disproportionate impact on the competitiveness of economic actors (third party verification, regulation of components and non-enforceable requirements)