Following the second stakeholder consultation meeting on 23 June 2022, the environmental stakeholders hereby submit their views on the draft JRC Technical Report on the Review of the Methodology for Ecodesign of Energy-related Products (MEErP). We appreciate the work undertaken by the JRC to refine the methodology to examine the wider resource efficiency impacts of energy-related products and to facilitate the shift toward more durable, reparable, and circular products. In particular, we support the following aspects:
• Improvements in packaging and distribution aspects
• New datasets to enable modelling of packaging, distribution, maintenance and repair separately
• New capabilities to account for direct emissions in manufacturing/assembly and use phases
• Ability to include consumable impacts during the use phase
• Improvements to the tables of upgradability and reparability levels