The Association of Medical Device Reprocessors (AMDR) appreciates the
Commission’s efforts to promote a cleaner and more competitive Europe. We
welcome the opportunity to provide feedback to the Inception Impact Assessment
on the Sustainable Products Initiative.
– AMDR strongly agrees with the Commission’s aim to widen the scope of the
existing EcoDesign Directive beyond energy related products.
– We urge the Commission to include health care products and consumers
within the scope of work when addressing the Sustainable Products Initiative.
We look forward to the adoption of overarching product sustainability
principles and hope they can be applied to health care products
– We further hope the Commission’s efforts will create manufacturer incentives
in the health and medical markets to make products used in hospitals and
surgical centers more sustainable, including incentivizing and brining
awareness to medical device remanufacturing. We encourage the
Commission’s consideration of tools to make producers responsible for
providing more circular products and intervention efforts aimed at preventing

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