SUMMARY

• The European Commission has opened a consultation on potential ecodesign requirements for iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR). Members can find the questionnaire attached.
• Iron and steel intermediary products were mentioned in the 1st ESPR working plan. Initially, the initiative appeared to focus mainly on iron and steel as intermediate products; from ongoing discussions within the Ecodesign Forum, however, we understand that the scope of the future Delegated Act remains under assessment and no policy decisions have yet been taken.
• FESI is therefore assessing whether future requirements could have implications for downstream operators placing products on the EU market, including sporting goods, apparel and footwear products containing iron or steel components.

MORE INFORMATION

According to the consultation material, the Commission is considering possible requirements on iron and steel products, including:

• Information requirements on the carbon footprint, recycled content and recyclability of iron and steel products;
• Performance requirements potentially based on carbon footprint information;
• Digital Product Passport requirements for actors involved in the supply chain.

The Delegated Act may be relevant for the sporting goods industry if requirements were to extend, directly or indirectly, to economic operators placing the final products on the market. Potential examples could include ski boots, ski poles, skis, climbing carabiners and anchors, as well as apparel and footwear trims such as zippers, eyelets or other metallic components.

At this stage, FESI considers that, rather than a response to the full questionnaire (primarily made of questions that are not directly relevant to the textile and sporting goods industries), a more targeted contribution could be considered, focusing on the need to avoid extending the scope of the future Delegated Act to downstream products already covered, or expected to be covered, by their own product-specific ESPR Delegated Acts, including the future Textile Delegated Act.

Such a contribution could stress the importance of avoiding duplicative requirements, unnecessary administrative burden and inconsistencies between different ESPR product-specific measures. FESI is also exploring the possibility of coordinating with other associations to support a common approach on this issue.

NEXT STEPS

FESI is actively monitoring the file and assessing whether to contribute to the consultation. We are also actively engaging with the Commission to clarify some matters, such as the concept of "steel-rich" products expressed in the questionnaire.

Members are invited to share any questions on the matter, so that we may relay them to the Commission where possible. In this context, we would welcome input from Members on convincing arguments and practical examples supporting the exclusion of downstream products and actors from the scope. This could include, for instance, examples of products where iron or steel components represent only a limited or ancillary part of the final product, cases where additional information or traceability requirements would create disproportionate administrative burden, or situations where overlapping requirements under different ESPR Delegated Acts or other EU legislation could lead to duplication, inconsistency or legal uncertainty.

Members are kindly invited to share their input, so that EOG and FESI can assess whether to contribute to the consultation and, where appropriate, coordinate with other industry associations.

katy.stevens@europeanoutdoorgroup.com

‍