Circular Economy requirements in Ecodesign

This graph illustrates the evolution in the number of product groups which are regulated by EU legislation (right axis), and the number of requirements for these product groups  in six key categories of Circular Economy (CE) product requirements(right axis) , from 2008 to 2023 and documented in Barkhausen et al. (2022). These categories include Durability, Reusability/Repairability, Recycling, Hazardous Chemicals/Dangerous Substances, Resource Efficiency, and Critical Sourcing. Additionally, the number of product groups regulated over time is also depicted.

The number of product groups regulated rose rapidly from 2008 to 2020, plateauing around 2020–2023 at 28 groups (examples of product groups include electronic displays and televisions, fluorescent lamps, household refrigeration, household dishwashers and washing machines, water pumps, vacuum cleaners, laptops, smartphones, heaters, and coolers). This significant growth reflects the increasing scope of the EU’s regulatory framework, expanding to cover more product categories, thus promoting circularity in a wider range of products. The category durability had a stable growth until 2020, then a noticeable decline and plateau from 2020 onward. This can be explained by a strong focus on ‘reduce’ (included in ‘durability’) due to three lightning requirements which were replaced in 2020 by a single overarching lighting regulation. The other categories all had an increase over time, whether it be less pronounced (hazardous chemicals/dangerous substances, resource efficiency, critical sourcing), a steep but steady increase (recycling), or a steady increase followed by a steep rise in 2020 (reusability/recyclability). Furthermore, the number of requirements from the category for reusability/repairability has overtaken others, potentially reflecting increased EU emphasis on extending product lifetimes to enhance circularity and a strong recent regulatory focus on promoting products that are repairable or reusable. This focus was mainly put on household refrigerating appliances, household dishwashers, household washing machines, and welding equipment.

This metric signals progress toward CE ambitions. While Reusability/Repairability and Recycling are making headway, categories like Resource Efficiency and Critical Sourcing remain lagging. Given the EU's goals for full circularity, more focus and innovation are needed in these areas to balance the framework. Ideally, the final state would show all categories at much higher levels, particularly Critical Sourcing and Resource Efficiency, which would need to rise sharply to ensure sustainable material management across sectors. The number of product groups regulated appears to have plateaued, suggesting regulatory saturation unless the scope is expanded further. The Ecodesign for Sustainable Product Regulation adopted in June 2024 develops a framework for future requirements on non-electronical products such as textiles, footwear, and construction materials, and it introduces the concept of a Digital Product Passport. Therefore, it is expected that more requirements will be introduced on a broader range of products and all the lines in the graph are expected to increase.

Regulatory shifts, changing market demands, and technological advancements (e.g., in repairability) are likely driving the recent rise in certain categories. The EU's increasing focus on reducing e-waste and extending product lifecycles (e.g., through Right to Repair laws) has shifted the regulatory emphasis toward Reusability/Repairability since 2020.