Provide Input for the ESPR, list Networking & Software

Published on 
April 10, 2023
Jan Hoogstrate
Provide Input for the ESPR, list Networking & Software

IMPORTANT:Action to list Networking Equipment & Software on ESPR (Ecodesign) – deadline May 12, 2023!

Being part of the aftermarket industry we ask you all to respond!

The new extended EU Eco-design for Sustainable Products (ESPR) aims to make products sold in the EU more sustainable. The scope of the ESPR list is expanded to include non-electric products, and lessening the focus on energy requirements. This opens opportunities to address a family of comparable products.

The Commission seeks views on the categories of new products, so that it can set priorities. This consultation is open to all EU citizens, companies and organisations. We call on you to respond to this invitation and to make Networking Equipment and Software  priority product groups! This will enable us to address OEM policies around firmware, licenses and restrictions for the sale of refurbished hardware in the open market.

Your input is essential for us to better represent you and the ICT Aftermarket in Brussels. Steps to take to provide the Feedback:

• Click on "Give Feedback" & Register yourself : LINK

• Use/copy or edit the text below

• Options: file your feedback only to the EU, publicly visible at the website; can be without your name

• Deadline: 12 May 2023

Example text:


Dear Commission,

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 apriority, as they are vital for our ICT infrastructure and have a strong Circular Impact. They represent a significant opportunity to address 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 scope to include this is vital. These products have a useful life of 15 to20 years, providing a wealth of many options for reuse between organisations. 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.  There is hardly any 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 open the market to assessment and legislation. The Circular Economy should be an open system and not a sum of(non-EU) manufacturer-controlled eco-systems. Including Networking equipment 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 forCircularity:

1. Firmware updates are not available, this requires an expensive OEM contract.

2. Licenses can be required over and above those available with the product.  In many cases, they only have a limited lifetime once purchased.  The product becomes obsolete, not working, once the license cannot be renewed.

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 becomes e-Waste, as reuse policies demand a new license for the product to work.

4. Support/Maintenance - systems cannot be maintained/repaired byindependent companies.

5. Unfair competition until the hardware is no longer supported bymanufacturers.

6.  Hardware transfers are allowed within the EU, though it might require a signed transfer agreement from the party who originally purchased the product.  With  hardware brokerages and multiple resales between users, this kind of policy makes compliance virtually impossible for hardware resale in the EU, and is therefore contrary to the free movement of goods.

7. Extend the number of years for support/updates.

Independent providers are the experts in resale, reuse, upgrading and keeping systems running for a longer time. There are many local SME’s 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. Firmware and applications are becoming more and more a decisive element in the life-cycle of hardware, as they provide the digital key. The impact of forced upgrading to new versions (e.g. Microsoft withdrawing support for Windows) creates a huge waste stream of equipment that is working technically fine.

The dependency on large Tech corporations is becoming more and more visible. The EU copyright-based protection is 70 years, which allows vendors full control without setting limiting requirements. 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; opening up reuse, support and additional requirements.

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 SME’s 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.


As a representative of our market the Free ICT Europe Foundation is the organisation that can inform you more and will be available for more information and contributions.



Thank you for your support!

More News

Go to news page  


Go to podcasts page  

Get Involved

Are you an ICT Secondary Market provider?
Then please join our alliance, as we need your help to raise our voice.

FIE has become a serious partner in Brussels, please join the alliance, so that we can continue to expand our reach and gain more attention representing businesses like yours.


As a Foundation we are depending on the gifts we receive. Please consider to support us financially, your contribution is appreciated & needed!
Thank you in advance,


Subscribe to our newsletter so that we can share more about our activities and the issues our industry is facing. We also encourage other companies to share their story.