Bureau Veritas

Ecodesign 

Who does EcoDesign apply to and when?

Maybe you have heard of circular economy? Circular economy is not just about recycling materials and raw materials - ecodesign is the focal point of the circular economy.

Environmentally friendly design for sustainable products, also known as ecodesign, has a strengthened role in a new regulation. The aim is to improve the environmental profile of goods at EU's internal market. Negative environmental effects must be minimised throughout the product's life cycle, and raw materials and components are included in circular cycles. The regulation also stipulates that products must have a digital product passport stating mandatory criteria for green public procurement. The goal is, not least, to prevent the destruction of unsold products.

In the long term, almost all goods are covered, and the rules apply to the primary players in the market - i.e. manufacturers, importers and sales. Although the new rules will not come into force until 2027, it is recommended to start preparations now, as the requirements will be extensive and the transition periods short. Early intervention can give your business a competitive edge.

our advice to you - how to get started

Many areas can already be addressed now to be well-prepared and ensure that your goods can be sold on the internal market when the new rules come into force. Even though the deadlines are some way off, it is our experience that the transition requires time, and therefore we recommend that you start to:

  • getting familiar with key concepts: Concepts such as circularity, climate footprint, product environmental footprint, repairability, upgradeability, producer responsibility, digital product passport, recyclability and much more
  • collaborate across different functions within your company and along the supply chain, establishing a common understanding and an agile way of cooperating when the rules come into force.

You can embark on some of the more concrete activities:

  • Streamline data generation and management: This will be key, both within the company and in the supply chain. Efficient data generation and data management will no longer be a luxury, but a necessity. The requirements for the digital product passport and life cycle assessments require reliable, high-quality data to ensure useful outputs and mandatory transparency.
  • Identify substances of concern: The aim is to limit the use of substances of concern that may prevent recycling or have a negative impact on products’ sustainability. Look at the presence of substances of concern in sub-components, production processes or products. Establish methods to ensure traceability.
  • Take a holistic approach to product circularity and sustainability: examine the entire life cycle of products from the cradle to the grave, look at opportunities for redesign and replace virgin materials with recycled materials.
  • Consider recyclability: Is there a potential for recycling or perhaps directly reusing components, products as well as packaging? Which changes may be necessary?
  • Assess the role environmental standards and certification can play for your business.
  • Decide whether new initiatives and documentation can support green marketing and strengthen your market position.

ecodesign in brief

  • Background for Ecodesign

    As the world's population grows, economic prosperity increases, consumption intensifies, supply chains become longer, and environmental challenges become more complex.

    Historically, we have diluted, landfilled, filtered and set requirements for manufacturing companies' emissions when we had to deal with environmental problems. This approach works if there is a clear perpetrator. But it is challenged when the production is moved to third countries and supply chains become more non-transparent.

    Therefore, a more holistic approach is needed, focusing not only on the production itself, but also on the entire product life cycle. As the word ecodesign suggests, it is about reducing the environmental impact already in the design phase. This is done by designing products based on principles that both reduce the environmental footprint in the design, production and use phases and extend the product's lifespan - without compromising the product’s functionality.

    This means shifting the focus to:

    • Ecodesign where products are designed with recyclable materials, low energy and resource consumption and the possibility of repairing, upgrading or recycling the products.
    • Eco-labelling of the products, which informs consumers about a product's environmental impact through labelling and declarations.
    • Give producers greater responsibilities, for example for collecting, recycling and environmentally sound disposal of end-of-life products.
    • Change purchasing patterns, so both public and professional purchasers demand environmental considerations, and consumers are guided through information and labelling.
    • Set performance limits for products so that low-performance products can no longer be sold after a set date.

    The new ecodesign regulation takes all these aspects into account and integrates them in the legislation.

  • BASIC PRINCIPLES OF ECODESIGN

    Most companies will face the ecodesign mindset and the specific requirements, if they play a role in a product's life cycle from the cradle to the grave. This applies whether you are responsible for the product design or not.

    Eco-friendly products typically have the following characteristics:

    • Low resource and energy consumption
    • Long service life
    • Can be easily repaired and upgraded
    • Easy separation for recycling
    • Few harmful substances
    • High recyclability
    • High content of recycled materials
    • Low climate and environmental footprint throughout the life cycle.

    Several of these principles are already used in the regulation of electrical household appliances with requirements for both performance and labelling. Thus, consumers are able to make informed choices, for example through A-E labelling.

  • LEGISLATION REGARDING ECODESIGN

    Ecodesign is mentioned in several regulations. The new European Ecodesign Regulation is the most comprehensive to date, covering almost all physical products, apart from product categories such as feed, food and pharmaceuticals.

    The principles behind ecodesign are already mentioned in several regulations. The first wave in 2009 included energy-consuming and energy-related products such as domestic appliances and LED lighting.

    The product category: Construction products have a high environmental footprint, and the choices made during the construction of buildings are often permanent. Material choices and energy consumption have consequences for many years to come. That is why ecodesign principles are now also being integrated into the Construction Products Regulation.

    In the future, the ecodesign regulation will be the basic regulation for products within the EU. In Denmark, a national ecodesign product law was introduced in 2025, which clarifies responsibilities and implements parts of the European regulation.

    As the regulation concerns the European market, it is essential to ensure equal access to the market for all. Therefore, as with other product regulations, requirements are developed step by step and product group by product group. At the same time, cross-cutting requirements are introduced, such as digital product passports and score models for repairability. The rules are laid down in delegated acts, which also requires verifications.

    Ecodesign requirements are typically divided into the following tracks:

    Performance requirements:

    • Minimum and/or maximum values of a specific product parameter.
    • Requirements aimed at improving environmental performance, including: 
      -    repair score 
      -    durability score 
      -    climate/environmental footprint

    Information requirements:

    • Digital access to product-specific information
    • Information about reducing the environmental impact and improving the use phase
    • Information about end-of-life management and circularity
    • Performance classes specific for the product group.

    At the same time as increasing product requirements, market surveillance is also increased.

  • Ecodesign work plan

    This is a comprehensive area to regulate, which is why a work plan has been adopted for the period 2025-2030 that addresses products with the greatest improvement potential. The plan initially includes six end products, two intermediate products and the preparation of several cross-cutting requirements with a focus on the reparability, recycled content and recyclability of products. The plan can be expanded to include more product groups in connection with the mid-term evaluation.

    The specific product groups covered by the first work plan are iron, steel, aluminium, textiles (with a focus on clothing), furniture, tyres, cleaning products, paints, lubricants, chemicals, information and communication technology products and other electronics. Prior to the establishment of the rules for each product group, preparatory studies and impact assessments will be carried out for each product group. Specific delegated acts on product group-specific measures will apply within 18 months of the adoption of the delegated act.

    Certain elements of the plan are intended to act as catalysts which both strengthen consumer protection and stimulate demands for more sustainable products. These elements include, among other things, the digital product passport, clear and informative product labels, and green public procurement.

  • HOW THIS AFFECTS COMPANIES

    In practice, ecodesign will have an impact on many processes in companies and their value chains and business relations. First and foremost, the need to be able to document products and activities in one's own part of the value chain will increase. Companies, which market products, must ensure that they have the necessary documentation, and that the previous links in the chain have fulfilled their part of the responsibility.

can I get help?

At Bureau Veritas, we are ready to help you if you are not sure whether your products and your company are covered by the regulation. If you are looking for sparring on how your products can be compliant, you are also welcome to reach out to us. These could be concerning CBAM, LCA, EPDs, Product Environmental Footprint (PEF) and the EU Deforestation-free Products Regulation (EUDR).