The Consumer Products Sector and the EU's Circular Economy Policy for Products

An InfluenceMap Briefing

October 2022

An Analysis of the Consumer Products Sector's Engagement on the EU's Ecodesign for Sustainable Products Regulation

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InfluenceMap has undertaken analysis of European consumer products companies' and their industry associations' policy engagement on a key policy in the EU's Circular Economy Action Plan, the Ecodesign for Sustainable Products Regulation (ESPR).

The ESPR aims to make products placed on the EU market more sustainable and to align them with circular economy principles. The EU Commission's policy proposal sets an overarching framework for future sector-specific legislation to align products with the circular economy. The ESPR focuses on the plastics, chemicals, metals, digital and textiles sectors primarily, and in this analysis InfluenceMap focuses on the consumer product sector's engagement with the policy and the wider circular economy.

Only four of the 20 companies assessed engaged directly with the EU’s circular economy policy, the Ecodesign for Sustainable Products Regulation (ESPR). L'Oréal, Nestlé and Unilever engaged mostly positively on the ESPR. However, Henkel did not seem to support expanding the scope of the ESPR to non-energy related products.

Almost all companies communicated their efforts to implement circular economy practices in their operations. However, it appears that much of company focus on circularity remains on recycling, rather than elimination and transitioning to re-use.

Outside of the ESPR, around half of the companies covered in this briefing are engaged on the implementation of a circular economy in the EU, and have voiced positions on various national policies and high-level initiatives.

Despite broadly positive direct engagement on circular economy policy, the companies assessed retain memberships to powerful industry associations which are mostly engaging negatively on the EU's ESPR. The negative positioning of the associations assessed in this briefing, including the the European Chemical Industry Council (Cefic), BusinessEurope and EuroCommerce, likely outweighs the somewhat more positive influence of the companies on the ESPR. Companies' limited yet broadly supportive engagement with the ESPR indicates that they could be directing oppositional engagement through their industry associations.

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