On July 18, 2024, the Ecodesign for Sustainable Products Regulation (ESPR) became effective as a new piece of EU legislation, approximately seven months after it had been provisionally agreed by the European Commission.

The legislation sets out a new framework that will eventually be completed by a variety of regulatory requirements that will propel European industry further forward in achieving the EU’s Green Deal objectives. Almost all industry segments are covered by the framework and the chemicals sector is among them.

About the ESPR Framework

The ESPR framework legislation will slowly be implemented over time. It replaces the Ecodesign Directive 2009/125/EC and sets out the ecodesign requirements for almost all tangible consumer goods (excluding foods for human consumption and animal feeds). The framework will seek to do the following:

• Improve product durability, reusability, upgradability and repairability
• Make products more energy and resource-efficient
• Address the presence of substances that inhibit circularity
• Increase recycled content
• Make products easier to remanufacture and recycle
• Set rules on carbon and environmental footprints
• Improve the availability of information on product sustainability

Where there are broad similarities in product groups, this should allow for across-the-board regulation. This is the hook that will probably hang the ink sector up with the paint and coatings sector as a matter of close similarity (formulation-based; raw materials intensive), since inks have not been explicitly mentioned in the information released on the legislation.

Further to paints and coatings and the wider chemical sector being prioritized, the legislation will also impact ink-consuming sectors such as ICT (information and communications technology), electronics, packaging and textiles. Digital printing is playing an increasing role in packaging and textile printing and I’ll return to that later.

Implementation

Implementation of the framework is imminent and will start with a prioritization exercise that will be followed by the establishment of a working plan for the products, and their required measures and timescales in which those affected will have to comply.

This should be followed by the drawing up of product rules, taking into account planning, impact assessments and consultation with stakeholders. An Ecodesign Forum will be established in order to accomplish this. The setting up of the Ecodesign Forum was imminent at the time of writing this article, with a first meeting of the forum due to take place in Q4 2024.

Suppliers Outside the EU

The ESPR framework will apply to all products placed in EU markets, not necessarily those just produced within the EU. Suppliers from so-called third countries will be expected to demonstrate an interesting in making their products more sustainably and responsibly within the guidelines of what the framework sets out.

The EU expects to support those countries or the business in those third countries in order to understand what impacts its requirements will have locally.

Fleshing Out Digital Product Passports (PPDs)

Digital product passports (henceforth PPDs, as the EU refers to them) were originally targeted for consumer goods by the end of this year, but this has now been deferred. Their future adoption and mandatory use across all 27 EU countries is now expected between 2026 and 2030.

There has been a relentless targeting of high-environmental-impact products since this idea was conceived, so some industry sectors are being prioritized for that reason. Paints and coatings (and probably inks as similar products) are among them once more.

A PPD will be a collection of product-related data with pre-defined scope and agreed data management and access rights conveyed through a unique identifier. PPDs are being implemented to:

• Enhance sustainable production
• Lengthen product lifetimes and optimize product use and re-use
• Inform customers in making sustainable purchases
• Facilitate the growth of the circular economy
• Support authorities in compliance verification

The EU has now released more information on what the PPDs should include with a view to achieving these objectives. The data elements are set out below, although some products may not need all of them:

• A unique product identifier (UID)
• A global trade identification number as provided for in standard ISO/IEC or equivalent of products or their parts
• A TARIC code and any other relevant commodity codes
• Compliance documentation, including declaration of conformity, technical documentation, and conformity certificates
• Requirements related to any substances of concern
• User manuals, instructions, warnings, or safety information

Relevant information will also be required on the following topics:

• Importers, operators and manufacturers
• Unique facility identifiers
• Installation, maintenance and repair guides so that long-term durability is achieved, thereby reducing environmental impact
• How to dispose of (or return) the product at the end of a product’s serviceable life
• Dismantling, recycling and disposal at the end of a product’s serviceable life
• Product handling by those other than the manufacturer
• Other relevant information that may influence the way the product is handled by parties other than the manufacturer.

New Report on Digital Printing Highlights EU Greenness

With mentions of the remainder of the decade up until 2030, the overarching prominence of future EU greenness and the shift to digital technologies, a new report on the digital printing sector published over the summer also embodies these factors where the ink industry is concerned.

The new title, Digital Printing Market Size, Share & Trends Analysis Report… 2024-2030, from Grand View Research concludes that the global digital printing market size was estimated at US$38.07 billion in 2023 and should grow at a CAGR of 6.2% from 2024 to 2030. Digital printing encompasses techniques such as inkjet and laser printing, which are widely used for producing documents, marketing materials, and packaging.

The European printing sector is being driven rapidly down this path by the emphasis on sustainability and environmental accountability. The digital printing route, with its superior eco-footprint, is being seen as increasingly more desirable than the more traditional technologies that are associated with greater use of harmful chemicals. This shift aligns with the EU’s stringent environmental regulations and growing consumer preference for eco-friendly products and practices.

Pointedly mentioned for being outside the EU, the report also highlights developments within the UK digital print sector. The UK is reportedly flourishing through its extensive creative industries such as publishing, design and fashion and has embraced digital printing in a big way to embark on product differentiation. The flexibility of the digital process has meant that brands and designers have been able to work with new concepts, as well as produce limited-edition and bespoke products for niche markets and their customers.

The relative importance of these industry segments to the global digital print sector is summarized in the pie chart above.

Some End-User Notes and a Return to ESPR

The packaging sector is by far the largest when it comes to digital printing and accounts for nearly 52% of demand. Much of this is being driven by the e-commerce segment. Textile applications, on the other hand, are being inspired by fast fashion because digital printing offers a much quicker turnaround and is easier to set up. Relatively rapid production decreases time-to-market and allows producers to maintain a competitive edge.

However, fast fashion is within the sights of the EU and its ESPR legislation, because it plans to hold companies and retailers responsible in what amounts to a “name and shame” approach to the destroying or destruction of unsold goods and fast fashion is one of the areas where this happens.

Companies and retailers would be required to post details of the disposals of unsold goods on their websites. Caveat emptor will then take on a whole new perspective when it comes to ethical purchasing and corporate responsibility for the increasingly eco-conscious consumer.