The Ecodesign for Sustainable Products Regulation proposal, as put forward by the European Commission, seeks to reduce the environmental impact of products throughout their life cycle, improve the functioning of the internal market, and stimulate both supply and demand for sustainable goods. It plays a critical role in advancing the EU’s transition toward a circular economy.

CME welcomes the objectives of the ESPR, particularly its focus on products entering the EU market for the first time. At the same time, we stress the importance of fully accounting for the realities of second-hand trade and online classifieds marketplaces, which are driven largely by consumer-to-consumer transactions and local circular consumption practices. Maintaining this balance is crucial to avoid inadvertently creating barriers for reuse and resale activities, which already make a significant contribution to circularity in Europe.

To achieve this, CME recommends that co-legislators prioritise:

  • Target products that are made available on the EU market for the first time
  • Exclude C2C (but not B2C) transactions from the scope
  • Ensure a harmonized legal framework, including consistent definitions, for online marketplaces and traders
  • Clarify the scope with regards to second-hand products
  • Align the Digital Product Passport with the specificities of second-hand trade to promote the circular economy
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Last modified: 3 March 2026