Technology Industries of Finland Position and Suggestions to the ESP Regulation

TIF supports the Commission’s aim to modernise regulation of ecodesign requirements of products and set a legal framework for digital product passports, facilitating the combination of data with material flows. Our key messages are:
• The EU should be the global leader in setting standards together with industries for a circular, sustainable and responsible market economy. It is a great opportunity for advanced European companies to establish new markets.
• We need a single, sustainable market, based on harmonised requirements, effective enforcement and market surveillance.
• Practical challenges are sizeable, and industry needs to be closely involved when setting the harmonised standards and requirements to achieve proportionate and workable solutions.
• On digital product passports, we need a carefully balanced approach to data. By adjusting access and usage rights based on true needs of different players, we can maintain protection of trade secrets and have the data needed for new business models of circular economy.
• Setting up the arrangements for digital product passports is a highly complicated task. The system needs to be built gradually on sound general principles that consider the potential implications to the companies.

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