Video Games Europe contribution: Public Consultation on Product Priorities for Ecodesign

Video Games Europe shares the views of the European Commission that climate change is one of the most critical challenges of the 21st century. The video games sector is committed to contributing to the EU green transition, and launched in 2019 the UNEP-facilitated Playing for the Planet Alliance, encouraging studios and players across the globe to learn more about the impacts of climate change through in-game content. Our members also provide guidance to help studios reduce their environmental impact, and have developed internal training tools to explain global warming and its causes, lays out the stakes of inaction, and provides specific insights and advice to employees based on their role.

Video Games Europe welcomes the opportunity offered by the European Commission to contribute to the public consultation on the new product priorities for Ecodesign for Sustainable Products. Whilst video games products already fall under the scope of the current Ecodesign framework, and whilst this consultation is tailored for identifying new product categories for its application, Video Games Europe would like to share its observations on section III of the questionnaire, which specifically mentions ICT products as a category for potential horizontal measures under the new ESPR framework.

Executive Summary

The video games sector has taken numerous efforts to improve the durability and recyclability of its products
Video games console manufacturers strive to ensure that their products offer the highest quality and standards possible to ensure that players enjoy their video gaming experiences and that game developers release their games on platforms that are reliable. Durability is part of such quality standards. Durability and repairability has also been further facilitated through the adoption of the Games Consoles Voluntary Agreement, which includes requirements related to recyclability and repairability. New requirements should build upon such successful instruments, rather than adding new layers of regulations.

A careful consideration of the specificities of each product within a same category of products should be conducted before designing horizontal requirements
Video games consoles, PCs, Notebooks/Laptops, Slate Tablets, Smartphones, Mobile Phones, TVs or even printers are disparate products with significant functional differences. A phone and a video game console have fundamentally different applications and functionalities, the first being designed primarily to communicate, while the latter being primarily designed to play video games. Therefore, Video Games Europe encourages the Commission to conduct a careful assessment of such disparities before designing horizontal requirements, also to allow for better implementation of such requirements and to cater for the specificities of each sub-category of products.

On specific horizontal requirements suggested in the EC questionnaire
Video Games Europe is concerned that standardisation and limitation of usable components would stifle innovation in the sector. In addition, any new information requirements provided to independent repairers should not be detrimental to video games consoles manufacturers’ and video game developers’ IPs and to consumer safety. In both cases, the specificities of the sector must be adequately catered for in the design of ecodesign requirements.
Finally, certain requirements suggested by the questionnaire would potentially conflict with existing (Directive (EU) 2019/771) and forthcoming (‘Right to Repair’ proposal) EU legislation, leading to legal uncertainty rather harmonisation. Therefore, Video Games Europe suggests to not adopt such horizontal requirements.