LegalVideo Games Europe
Video Games Europe: Contribution on Ecodesign for Sustainable Products
1 May 20236 pages~20 min full read
The European video game industry, comprising 5,000 studios and 98,000 employees, generated a €23.3 billion turnover in 2021 while serving over 135 million players.
See it on page 6The industry argues against uniform horizontal ecodesign regulations, asserting that the functional and technical diversity of ICT devices like consoles, PCs, and smartphones makes a one-size-fits-all approach impractical.
See it on page 1Existing frameworks, such as the Games Console Voluntary Agreement and the UNEP-facilitated Playing for the Planet Alliance, already address resource efficiency, recyclability, and out-of-warranty repair provisions.
See it on page 2Mandatory standardization of components or material limits could stifle innovation, restrict creative freedom for developers, and negatively impact spill-over benefits in fields like AI and healthcare.
See it on page 4The sector warns that new horizontal rules risk creating legal uncertainty, as durability, labeling, and repair requirements are already governed by the EU Sales of Goods Directive (2021) and the Right-to-Repair proposal.
See it on page 6Sharing repair information must include safeguards for intellectual property and consumer safety, particularly regarding proprietary diagnostic tools and trusted-platform modules.
See it on page 5The submission aims to shape the European Commission’s new ecodesign priorities by presenting the video‑games sector’s perspective on durability, repairability and the risks of imposing uniform horizontal requirements across ICT products. It argues that the industry already contributes to the EU green transition through initiatives such as the UNEP‑facilitated Playing for the Planet Alliance and the Games Console Voluntary Agreement, which embed resource‑efficiency, recyclability and out‑of‑warranty repair provisions for consoles. The sector stresses that any additional measures should build on these existing frameworks rather than create overlapping regulations.
Key observations highlight the diversity of ICT devices—consoles, PCs, laptops, tablets, smartphones, TVs and printers—and note that their functional and technical differences make a one‑size‑fits‑all approach impractical. Standardising components or limiting material counts, the response warns, could curb innovation, diminish spill‑over benefits to fields such as healthcare and AI, and restrict creative freedom for developers. It also stresses the need for safeguards protecting intellectual‑property rights and consumer safety when sharing repair information, given the reliance on proprietary diagnostic tools and trusted‑platform modules.
The commentary points out that durability, labelling and repair‑information requirements are already covered by the EU Sales of Goods Directive (2021) and the forthcoming Right‑to‑Repair proposal, and that new horizontal rules could generate legal uncertainty. The sector’s scope encompasses the European market, representing roughly 5,000 studios, over 98 000 employees and a 2021 turnover of €23.3 billion, serving more than 135 million players across 18 countries. The response, submitted in May 2023, draws on existing voluntary agreements and industry data rather than a formal survey.
