In November, the Microbial Control Executive Council (MCEC) contributed to a public consultation launched by the European Commission on the so-called Sustainable Product Initiative.
This initiative will result in a legislative proposal that will revise the European Ecodesign Directive, and propose additional legislative measures to make products placed on the EU market more sustainable, i.e. more durable, reusable, repairable, recyclable, and energy efficient. Until now the legislation is limited to electronic products, but the initiative is expected to extend the scope of the directive to other types of products, such as information technology equipment, textiles, furniture and intermediate materials such as steel and cement. An emphasis on the presence of ‘harmful chemicals’ in these products has been announced in the communication of this legislative proposal.
MCEC contributed, in support of the European Commission’s policy goal to create a circular economy in Europe, focusing on enhanced reusability and recyclability of products. However, MCEC has stressed that references to ‘harmful chemicals’ should be clearly defined in the context of this initiative. It is the conviction of the microbial control industry that many chemicals can be effective because of their hazardous properties. This is particularly relevant for the necessary biocidal substances that support sustainability aspects of the manufacturing, use and consumption of the products covered by this policy initiative.
In addition, MCEC agrees with the European Commission that “improved durability and reparability of products is expected to boost jobs in the reuse and repair sectors, […]”*. But to achieve this objective, existing solutions for the durability of intermediate materials and products should not be hindered, including where microbial control technologies are essential for sustainable production.
Lastly, under the announced “measures on production processes, for example to facilitate recycled content or remanufacturing and to track the use of hazardous substances in such processes”*, MCEC has invited the European Commission to consider the extension of the scope of the Ecodesign Directive only through relevant consideration of the existing regulatory framework. MCEC has referred to the fact that human and environmental safety considerations of and from the use of biocidal substances are already addressed under the Biocidal Products Regulation (Regulation (EU) 528/2012).
Another public consultation on the initiative has been announced for Q1 2021 and MCEC continues to monitor the situation. The legislative proposal revising the Ecodesign Directive is expected for Q4 2021 according to the Commission 2021 Work Programme published in October 2020.