How to get a say before the rules for your products are written

The short answer

The requirements for most product groups are not written yet, which is the reason so much of this estate says nothing is settled. The corollary gets almost no attention: a rule that has not been written is a rule somebody is still writing.

The framework requires the Commission to take into account the views of the Ecodesign Forum and of the Member States expert group, and to carry out an impact assessment, before adopting a delegated act. Around that statutory requirement sit four practical routes with real procedures and real addresses.

They are documented on five different Commission websites. We could not find one page, at the Commission or anywhere else, that assembles them. That is what this page is.

Only the last of those shows you the actual text. Only the first three let you say anything before it exists.

The Forum, which is open now

The framework establishes an Ecodesign Forum as an expert group with balanced participation from Member State experts and from all parties with an interest in the product group in question, and lists its contributions: preparing ecodesign requirements, preparing working plans, examining the effectiveness of market surveillance mechanisms, assessing self-regulation measures, and assessing the prohibition on destroying unsold consumer products.

The detail is not in the framework. The framework gives the Forum four lines. Everything operational is in the Commission decision that set it up, Decision C(2024) 7356 of 24 October 2024, and in the Forum's entry on the Commission's register of expert groups, published in November 2024 and last updated in June 2026.

Three things from that entry are worth knowing before applying.

It is a continuously open call. The application form is live and headed as such, which we confirmed at the form itself in August 2026. There is no deadline to miss. A first call carried a closing date in December 2024 and the standing arrangement replaced it.

Membership has a shape. The decision caps membership and spreads it deliberately across Member State authorities, industry, small and craft enterprises, trade unions, retailers, consumer and environmental organisations and researchers. Terms run for five years and renew automatically unless the Commission decides otherwise. So a seat is a long commitment rather than a one off submission.

What you file is published. The transparency provisions require agendas, minutes and participants' submissions to be made available on the register. That is a feature rather than a risk if you have thought about what you are filing, and a risk if you have not.

The application is a twelve page form covering classification, selection criteria, professional contact details, supporting documents and data protection. It is not a mailing list sign up. The Forum's first meeting, in February 2025, ran with close to 130 members and covered the draft working plan priorities including textiles, furniture, steel, aluminium and tyres.

The preparatory study, which is where the evidence comes from

Before an act is drafted, the Commission's research service runs a preparatory study for the product group. This is the least visible route and the earliest.

Registration has two stages. You complete a registration form and select the specific product group. After scientific approval you get access to the study platform using an EU Login account, requesting either a new account or a match to an existing one. The published instructions are explicit that an EU Login account has to exist first and that the account type has to be requested correctly or the registration cannot proceed.

What the pages do not say is what registration actually gets you: whether it is a mailing list, meeting access, draft documents or a right to comment, and what the rules are on publishing your name and your comments. That is a gap in the Commission's own documentation rather than in our reading of it, and how we type a question in that state is set out separately.

What is visible is the output. Stakeholder meeting presentations are published, and so are named industry submissions. One published submission to the iron and steel study proposes what the digital product passport for that group should contain. Whatever happens to that proposal, it is on the record, under its author's name, inside the study that feeds the act. That is the proof this route is real.

The group you cannot join

The Member States expert group is a subgroup of the Forum composed of experts designated by Member States. It contributes to preparing ecodesign requirements, assessing self-regulation measures, exchanging information on compliance and setting priorities on unsold consumer products.

A business cannot apply to it. The route in is your own national authority, which is a slower and more political path than the other three and is also the one most likely to be neglected. Our advice is to test it first if you already sit inside a strong national trade association, because the association is likely to hold the contact and the standing that make the approach land. That is practical advice rather than a measured finding. We found no published assessment comparing the effectiveness of the four routes, and it gets the least attention of the four in published guidance.

The window on the draft

Once a draft exists it is published for feedback on the Commission's own portal. The Commission's guidance on delegated and implementing acts describes a four week feedback period as the norm, with exceptions where there is urgency or where stakeholders have already contributed, and says that an explanatory memorandum accompanying the adopted act summarises the feedback received and how it was used.

The most useful thing here is a worked example, because it shows what the process actually looks like end to end rather than what the guidance says it should.

The draft delegated act on exemptions to the prohibition on destroying unsold apparel and footwear was published for feedback on the Commission's portal. Checked at the initiative page in August 2026:

• The feedback period ran from 30 June 2025 to 11 August 2025, midnight Brussels time. That is roughly six weeks, longer than the four week norm, which is worth knowing before planning around four.
• Sixty nine pieces of feedback were received.
• Each is published with the contributor's name and category. The three most recent visible on the page were a university, a national public authority and a business association.
• The draft was a fourteen page document. The adopted act, in February 2026, ran to thirteen pages.
• The initiative page links the Ecodesign Forum's own register entry, which is the two routes joining up on the Commission's own page.

Sixty nine is a small number. It is small enough that a considered submission from a business that actually makes the goods is unlikely to be lost in a crowd, and that is the honest argument for filing one.

What this is not

Three cautions, because a page like this can read as an invitation to overinvest.

Treat all of it as external communication. Whether any of these routes counts as lobbying for the purposes of your own internal rules, your national transparency regime or a client's code of conduct is a question for whoever answers that question at your business, and the answer is not the same everywhere. What is not in doubt is that Forum membership and published submissions are public acts attached to your name, and are not a form somebody fills in.

Influence is not a result. Nothing here entitles anybody to an outcome. The Commission is required to take views into account, which is not the same as being required to act on them.

And none of it changes what is currently required of you, which is a much shorter list and is set out at what already applies to a clothing brand today. Every date in this area, including for the act in the worked example above, is kept on the status record rather than asserted here.

What to do now

1. Decide whether your product group's study has started. If it has, registering is the cheapest thing on this page and the earliest point of entry.
2. Decide whether a Forum seat is worth five years. The term renews automatically. It is a standing commitment, not a submission, and the honest answer for most businesses is that a trade association seat serves them better than their own.
3. Find out who covers this at your national authority. It is the only route a business has to the Member States expert group, and identifying the right person is usually a single email.
4. Set a watch on the feedback portal for your product group. The window is weeks, not months, and the draft is the only artefact in this process that shows you actual text.
5. Work out your position before you need it. The questions an act has to answer are already knowable, and the two that decide who may read and who may write your product data are set out at what a delegated act will actually decide about your products. What you would actually be arguing about, attribute by attribute, is the set we track. A business that has not formed a view will not form one in six weeks.
6. Write for the record. What you file through the Forum and through the feedback portal is published under your name and will be readable long after the act is adopted. The study route's publication rules are the gap noted above, so ask before you assume either way.

Sources

• Ecodesign for Sustainable Products Regulation (EU) 2024/1781, consolidated text
  Relevant provisions reviewed

  Article 4, for the duty to take the Forum's and the expert group's views into account and to carry out an impact assessment, and Articles 19 and 20 for what each body is and what it contributes.

  View official source

• Commission Decision setting up the group of experts on ecodesign for sustainable products and energy labelling, the Ecodesign Forum
  Reviewed in full

  Read in a browser in August 2026, because the register is a script driven application that returns nothing to ordinary retrieval. The creating decision, the mission, the tasks including assisting in the preparation of delegated acts, the publication date and the last update.

  View official source

• Register of Commission expert groups, entry for the Ecodesign Forum, and the application form
  Reviewed in full

  Read in a browser in August 2026. That the call is headed as continuously open, and the twelve page structure of the application.

  View official source

• Have your say, exemptions to prohibiting the destruction of unsold apparel and footwear, initiative 14591
  Reviewed in full

  Read in a browser in August 2026. The feedback period, the count of sixty nine, that feedback is published with contributor name and category, the draft and adopted document lengths, and the link to the Forum's register entry.

  View official source

• Preparatory studies, stakeholder registration
  Reviewed in full

  The four week feedback norm, its exceptions, and the explanatory memorandum recording how feedback was used.

  View official source

• Implementing and delegated acts, law making process
  Relevant provisions reviewed

  The two stage registration, the EU Login and platform account requirement, and the published condition that the account type must be requested correctly. Also used for one absence: the page does not state what registration gets you.

  View official source