The European Commission is seeking feedback on its proposed Sustainable Products Initiative, which aims to set environmental and circularity requirements for a broad range of physical products to make the EU regulatory framework fit for a sustainable future. This consultation seeks views on the identification of new products and horizontal measures not covered by existing legislation, the order of priority in which these should be tackled, and the relevant aspects to tackle. The consultation will inform the first working plan once the framework legislation is in place. The Commission aims to ensure that products placed on the EU market become increasingly sustainable, reducing environmental impacts across their life cycles and improving the functioning of the EU's internal market. This consultation is part of the preparatory work needed to identify what the ESPR's first priorities should be.
In this article, we discuss the importance of two ICT product groups, network equipment and software, and why they should be a priority for selection in the new EU ICT Aftermarket. Network equipment is crucial to our ICT infrastructure and has a strong circular impact, making it a good candidate for achieving decoupling of economic development from environmental harm. However, the networking market is one of the least open markets, with minimal product information about energy consumption, requiring a need for regulation. Including networking in the ESPR is a pathway towards developing circular economy practice at scale within enterprise IT.
Software is becoming more and more decisive in the life-cycle of hardware, as they provide the digital key. The impact of forced upgrading creates a huge waste stream of equipment that is working fine, and the dependency on large tech corporations is increasing. The ESPR should prioritize software as a product group and enable longer product lifetimes, which will result in greater EU digital sovereignty and a stronger and more inclusive technology industry.
The ESPR can increase the sustainable impact of these products, reduce e-waste, and support European organizations deploying, trading, and servicing them. However, current constraints for circularity include firmware updates not being available, license restrictions, and lack of support/maintenance by independent companies. To achieve the goal of a circular economy, the ESPR needs to regulate these constraints and promote an open system of circular economy that is not controlled by non-EU manufacturers.
Network equipment and software are two vital product groups for the EU ICT Aftermarket. Prioritizing them in the ESPR can support the circular economy and increase EU digital sovereignty. By regulating current constraints and promoting an open system, the ESPR can ensure that these product groups have a sustainable impact and reduce e-waste.
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Being an organisation that is active in the EU ICT Aftermarket, we are pleased to share our views on new ESPR products to be selected.
We strongly call for two ICT product groups to be selected as a priority, as they are vital for our ICT infrastructure and have a strong Circular Impact. They represent a significant opportunity to address a also currently a competitive imbalance in the EU Technology Sector. In addition, a change to the rules will support an increased EU digital sovereignty. Network Equipment, Crucial in Connectivity & the Circular Economy
Selecting enterprise Network/Telco Equipment for the ESPR is a logical step because it is a core element the ICT infrastructure we all depend on. After Servers, Networking hardware is the group of products that comprises the highest hardware investment by the private and public sectors. Digital Telecom equipment is increasingly a part of the overall Networking estate and widening the effects. These products have a useful life of 15 to 20 years, providing a wealth of options for reuse. Research organisations report new sales continue to be increasing for this product category, making it a good candidate to achieve Decoupling of economic development from environmental harm.
Networking equipment seems to be one of the least open markets, hardly publicly available data on the number of products placed on the market, and there is minimal product information about energy consumption. This, combined with some policies set by manufacturers, suggests a real need to regulate the market. The Circular Economy should be an open system and not a sum of (non-EU) manufacturer-controlled eco-systems. Including networking within ESPR is a pathway towards developing circular economy practice at scale within Enterprise IT.
The ESPR would increase the sustainable impact of these products, reducing e-Waste as well as supporting the European organisations deploying, trading and servicing them. Key Current Constraints for Circularity: Firmware updates not available,
1. Firmware updates are not available: require an expensive OEM contract
2. Licenses restrictions can make the product becomes obsolete.
3. It is not always possible to acquire a license for a used product when traded on the open market. This causes that the Product cannot be reused and becomes e-Waste
4. Support/Maintenance - systems cannot be maintained/repaired by independent companies: unfair competition until the hardware is no longer supported by manufacturers
6. Hardware transfers are allowed within the EU, though it might require a signed transfer agreement from the party who originally purchased the product and therefore contrary to the free movement of goods.
7. The number of years for support/updates is not matching the technical life. Independent providers are the experts in resale, reuse, upgrading and keeping systems running for a longer time. There are many local SMEâs in all member states that provide these services, and who are the key contributors for the Circular Economy.
Software, a black box that should not be a blind spot
Software needs to be an ESPR priority product group: becoming more and more a decisive element in the life-cycle of hardware, as they provide the digital key. The impact of forced upgrading (end of support) to new versions creates a huge waste stream of equipment that is working technically fine.
The dependency from on large Tech corporations is becoming more and more visible. Software is invisible but should still be seen as an asset that can be managed according to circular principles. The ECJ has already caused Software to be seen as an asset, allowing resale just like a regular product that we own. The ESPR should do the same thing.
Software spend is a large portion of overall ICT spending, and the market has a significant effect on consumers, businesses and the public sector. Hence, the scope should include products for the B2B as well as the consumer market.
Doing so will support longer product lifetimes, and enable European SMEs to provide services that are able to compete with global corporations. This will result also into a greater EU digital sovereignty through a stronger and more inclusive technology industry.