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14 June 2021

Position paper - Preparatory study for the Ecodesign and Energy Labelling Working Plan 2020-2024

This paper has been prepared by the Environmental Committee, and outlines the opinion of EUnited Cleaning in relation to the European Commission’s preparatory study for the Ecodesign and Energy Labelling Working Plan 2020-2024. The paper is available to sector members and discusses the expansion of existing requirements, the inclusion of new requirements, and the legal verifiability of market surveillance authorities in relation to three key areas of focus relevant to this preparatory study: lightweight design, recycling content, and ecological profile.


Concerning lightweight design, this paper emphasizes the motivation amongst producers of electronic and electrical (E&E) devices to design lightweight products. Both the benefits of such a design, as well as the potential negative impact on the quality of products as a result of this design, are discussed.


For recycling content, the paper discusses in detail some of the problems currently faced by manufactures who aim to increase the use of recycling plastics for technical plastic components or devices. SMEs need to be aware of the large variety of technical requirements of E&E plastics when they recycle plastics from similar products. Manufacturers should also be aware that the price of recycling plastic depends on the type of plastic and on the tests for meeting hazardous substances. It is therefore not a given that recycling plastic is always cheaper compared to virgin plastic.


Members can contact Frederik King ( to request copies of this position paper or for any related questions.



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