ASERCOM, the Association of European Refrigeration Component Manufacturers, actively participates in the European Ecodesign Forum, a crucial initiative supporting the implementation of the new Ecodesign for Sustainable Products Regulation (ESPR). This regulation establishes a comprehensive framework for mandatory performance and information standards, ensuring more sustainable product design and fostering a stronger EU single market.
The European Commission established the Ecodesign Forum through Commission Decision (EU) 2024/2779 on 24 October 2024. The Forum serves as a platform for diverse stakeholders, including industry representatives, member state experts, civil society, and academia, to contribute to the formulation of ecodesign standards and ESPR working plans.
Following the latest discussions at the Forum, ASERCOM has identified several key areas of relevance for the HVACR industry:
Material Considerations:
Steel and aluminum are fundamental to HVACR manufacturing. Classifying these under the ESPR may create supply chain disadvantages for EU manufacturers. If intermediate products with high steel or aluminum content are imported at lower costs than those produced within the EU, domestic manufacturers could face competitiveness challenges. The European Commission acknowledged these concerns at the Forum and assured stakeholders that the impact of such market imbalances will be carefully considered.
Prevention of Unsold Consumer Product Destruction:
While the ESPR discourages the destruction of unsold consumer products, such as textiles, HVACR products fall outside this category, as they are classified as B2B products. The definition of consumer products aligns with the „Sale of Goods Directive,“ which specifies that a consumer is a natural person acting outside their trade, business, craft, or profession.
Repairability, Repairability Scores, and Recycled Content:
Repairability scores are part of forthcoming repairability requirements for selected product groups. These requirements, applicable under the horizontal act expected around 2026/27, will extend to all relevant products, with additional recycled content regulations anticipated by 2028. ASERCOM emphasized the critical need for material purity in components where refrigerants circulate, such as copper and steel. Additionally, ASERCOM considers hermetic products inherently non-repairable.
Digital Product Passport (DPP):
For products falling under the Energy Label Regulation, the existing Energy Label may suffice, potentially eliminating the need for an additional Digital Product Passport (DPP). ASERCOM will continue to monitor developments to ensure regulatory alignment and efficiency.
ASERCOM President Marco Masini comments: “The Ecodesign Forum is key to balancing sustainability with industrial competitiveness. Fair material classifications in ESPR are essential to prevent disadvantages for European manufacturers. We appreciate the Commission’s commitment to addressing these concerns. Furthermore, distinguishing HVACR products from consumer goods in the context of unsold product destruction is a crucial step. ASERCOM will continue to actively engage in this process to ensure balanced and practical regulations for the industry.“
ASERCOM remains advocating for policies that balance sustainability with business practicality, and supporting the HVACR industry through the evolving regulatory landscape.
