On June 14, 2021, the European Environmental Bureau (EEB), a network of environmental citizens’ organizations, released a set of policy briefs and a discussion paper with recommendations for the European Commission’s Sustainable Products Initiative (SPI). The discussion paper outlines EEB’s position on what the SPI should cover. Primarily, it recommends that the SPI should “target all products on the European market, with specific measures targeting at least the strategic sectors defined in the circular economy action plan” such as packaging, chemicals, and plastics. And while “the new policy should build on existing policy instruments,” the EEB believes that for the SPI to be successful it needs to encompass more than existing policies.

The paper provides ideas for strengthening various policies across different product groups, horizontal legislation, or levels in the value chain, vertical legislation. Horizontal restrictions could include: considering voluntary industry agreements as complementary to regulation as opposed to regulatory substitution, implementing extended producer responsibility policies (FPF reported), and making low-impact public procurement the default. While vertical restrictions are more specific, like minimizing substances of concern in “products for which usage increases the risk of contamination such as food contact materials.”

The policy brief Integrating the Toxic-Free Environment Goal into Product Policy uses the guiding principles of the EU Chemicals Strategy for Sustainability (FPF reported) to draw the central legislative components that EEB believes would “ensure hazardous substances are avoided and substituted with safe alternatives.” These components, EEB writes, could be part of a new SPI framework or amendments to existing legislation. The key recommendations are to (i) restrict substances of concern horizontally except when necessary, (ii) clearly define specific product legislation timelines, (iii) create a transparent assessment for deciding when exceptions are necessary, and (iv) define requirements for manufacturers to report when they are using an exception. A second EEB policy brief on “due diligence” identifies measures to increase transparency in product value chains.


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EEB (June 14, 2021) “Making sustainable products the norm.”

EEB (June 14, 2021) “Integrating the toxic-free environment goal into product policy – policy briefing.”

EEB (June 14, 2021) “Due diligence in EU product rules – Policy Briefing.”