SUMMARY

The JRC has published a report outlining the methodology for identifying, tracking, and preparing restrictions on Substances of Concern (SoCs) in products under the Ecodesign for Sustainable Products Regulation (ESPR). Members can find the report attached.

MORE DETAILS

The report proposes a methodology for defining and tracking Substances of Concern (SoCs) in products under the ESPR, as well as for assessing and preparing potential restriction measures for substances that affect specific product aspects. It also explores how information requirements could support the tracking of SoCs throughout a product’s life cycle, while aiming to avoid overlaps with existing EU chemicals legislation such as REACH.

The report is structured into sections:

• ‍Section A provides a method for gathering preliminary data and for screening substances that remain in the product or are used or emitted along the life cycle of the product, prioritising information on substances remaining in the product;‍
• Section B describes a method to identify substances of concern, as defined in ESPR Article 2(27), while providing additional guidance and a discussion on thresholds, exemptions and deadlines for the entry into application of the requirements being proposed;‍
• Section C proposes a method to develop performance requirements on substances in products or in their life cycle, which may take the form of specific bans, restrictions or other limitations in the conditions of use of substances that negatively affect the product aspects; ‍
• Section D provides an overview of the means to collect information on substances in products, such as the Digital Product Passport, and discusses appropriate verification mechanisms for the information and performance requirements in relation to substances.
• Finally, the report includes a case study of particular relevance, conducted on apparel textile (clothing) products, in its Annex (VI).

The work forms part of ongoing efforts to develop a comprehensive methodology to support the setting of requirements under the Ecodesign for Sustainable Products Regulation (ESPR).

In light of the ongoing consultations on the third milestone report of the Apparel and Textiles Preparatory Study, FESI sought clarification from the JRC. The JRC confirmed that the methodology described in the report has been used in the preparation of the Textiles Preparatory Study, and that the publication will therefore be relevant to this work.

The European Commission is expected to collect feedback on the various JRC methodology reports, including this one on SoCs. However, structured feedback is not expected to begin until September 2026, meaning the current priority should remain on providing input to the third milestone report.

The report also includes a case study on apparel textiles (Annex VI). According to the JRC, the approach illustrated in this case study is expected to be used, where possible, in future preparatory studies supporting ESPR delegated acts. This may be particularly relevant given the assumptions underlying the methodology and the level of stakeholder engagement anticipated in its application.

FESI will continue to follow the developments of the different JRC methodology reports for the ESPR, and aim to collect all relevant information for its members.