Sustainability is a topic that’s very important to us at HD, it underpins the acceptance criteria for the projects that we work on, and it’s interwoven into the process of how we design products.

It’s common for people to state that the world is not doing enough to fight climate change, specifically from a materialistic output point of view, and while this is true, there are incredibly powerful systems already in place to limit our wastefulness and pollution output onto the Earth.

Currently, the EU are seen to be leading the march towards a greener, brighter and healthier future for the Earth, and not only have current plans in place, but future goals in small but meaningful transitional legislation-driven steppingstones, to minimise humanities pollutive nature.

The world of regulation and compliance can be a confusing and daunting landscape, particularly for new legislation for a rapidly growing and emerging market. It can seem that there are ‘traps’ for those not aware. This article proposes to shed light on what legislation there already is regarding sustainability and, what the future holds.

Legislation, Directives, Regulation & Standards

Firstly, we’d like to clarify some terms, as they’re used throughout this article. (All terms refer to EU definitions).

Legislation firstly sets out Primary Legislation, essentially the ground rules for all EU action, then Secondary Legislation comes into play, including Regulations and Directives proposed by a Legislative Body.

Directives are Legislative Acts that sets out a goal that all EU countries must achieve, however it’s up to the individual counties to devise their own laws on how to reach these goals.

Regulation is a subset of a particular Legislation, typically describing a more specific requirement. These are binding legislative acts, applied across the entire EU,

Standards are agreed principles or criteria, sometimes in the form of advice/guidance, however, sometimes are absolute requirements that must be met, in order to be compliant.



Repairability, reusability and upgradability

EN45554 is a new and very important design standard that is a major step towards better designed products. This standard assists design teams to design products that fit extremely well into a Circular Economy. Philips are leading the way regarding this approach and are releasing new products with this mindset at the foundation of their design principles.


Environmental Standards

ISO14000 family contains a whole host of standards to assist with the development of sustainable products, processes and practices. There is also a growing trend for companies to become 14001 certified, alongside typical 9001 certification.


Medical Devices

Medical devices are tightly controlled and are ultimately governed by their efficacy and safety. Environmental concern is unfortunately, secondary. However, legislation has changed and is set to continue changing for the better to introduce new regulations that allow for improvement in the sustainability of medical devices.


Pharmaceutical Packaging



The Directive 2011/65/EU on Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS2) aims to reduce the levels of lead, cadmium, mercury, hexavalant chromium, polybrominated biphenyl (pbb) and polybrominated diphenyl ether (PBDE) flame retardants in products. RoSH2 is a CE Mark Directive.


The European Batteries Directive

The Directive 2006/66/EC on Batteries and Accumulators and Waste Batteries and Accumulators (known as the Batteries Directive) regulating the manufacturing and disposal of batteries and accumulators in the EU to protect human health and the environment from hazardous substances such as mercury and cadmium.

The Batteries Directive prohibits the marketing of batteries containing some hazardous substances, defines measures to establish schemes aiming at high level of collection and recycling, and fixes targets for collection and recycling activities. The Directive also sets out provisions on labelling of batteries and their removability from equipment.

It also aims to improve the environmental performance of all operators involved in the life cycle of batteries and accumulators, e.g. producers, distributors and end-users and, in particular, those operators directly involved in the treatment and recycling of waste batteries and accumulators.



The Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulates the registration, evaluation, authorisation and restriction of chemical substances in the EU market.

REACH aims to improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances.

REACH is a global directive. In contrast, RoHS2 is a specific directive focused on the restriction of certain hazardous substances in waste electrical and electronic equipment.



The goal of the WEEE Directive is to minimize the impact of electrical and electronic goods on the environment by increasing the reuse and the recycling and reducing the amount of waste of electrical and electrical equipment going to the landfill.


Waste Packaging Directive

The Directive 94/62/EC on Packaging and Packaging Waste requires manufacturers to prevent the formation of packaging waste, to ensure that the weight and volume of packaging placed on the market is limited to the minimum and to develop packaging reuse systems to reduce their impact on the environment (restriction of the presence of certain heavy metals in packaging).


Paints Directive

Directive 1999/13/EC aims to prevent the negative environmental effects of emissions of volatile organic compounds (VOC) from decorative paints and vehicle refinishing products.

Potential Future



PVC is an incredibly useful material that’s used all over the world, from window frames to blood bags to waste pipes, etc. However, PVC poses some real concerns regarding it’s toxicity. Research studies have found that upon product end of life, PVC leaches toxic chemicals into soils, contaminating ground, water and air. Some EU countries have either banned PVC from certain products, or banned it entirely. We foresee PVC to become a material that is to undergo tighter regulation in the future.


Carbon Tax

The UK currently does not have a carbon tax. However, in many groups that we’re apart of, Carbon Tax is spoken about a lot, mostly not regarding whether it should be implemented, but how to implement it, and how the tax funds collected should be reinvested into the economy, and how high polluting critical services will be impacted.

There are various carbon-like taxes including fuel taxes and energy taxes, such as the fuel duty escalator and the Climate Change Levy. The UK was also a member of the European Union Emission Trading Scheme until it left the EU. It has since implemented its own carbon trading scheme.


Carbon Count

Restaurants at COP26 included carbon counts on their menus, alongside typical identifiers such as calorie count, vegan, vegetarian, gluten free, etc. to allow for users to make informed decisions upon purchase. Klimato’s carbon count system is a new system that is specifically addressing carbon counting for the food industry. We hope to see this system in more menus in the future.

We believe that this notation will become more apparent in the future, not only for menus, but for most food stuffs, and eventually spreading out into high volume/high impact products. There were historical systems such as carbon footprint calculators, for carbon counting, but it never hit mainstream. There are already existing systems that allow products to ‘wear badges of honour’ regarding their sustainability such as EU Ecolabel, but not a unified agreed system for true carbon counting. True carbon counting is difficult, and to do it accurately requires an in-depth investigation into the total supply chain, something that only a full Life Cycle Analysis can really calculate. Polestar have recently published their LCA of their latest electrical vehicle. There are however smaller and simpler systems (such as EI99) that are easy to implement throughout the design stage, in order to steer the development towards a more sustainable direction.


Circular Economy

This is probably the system that has the biggest impact regarding sustainability. This system is a mindset shift from a Take; Make; Waste system, that is driven from an imbalanced capitalistic society to a Circular System by eliminating waste and pollution, circulating products and materials, all whilst regenerating nature. To do this frameworks are set up encouraging innovative thinking and commercial partnership across all industries. The Ellen MacArthur Foundation is playing a big part in the push for the Circular Economy, by providing helpful toolkits for businesses, but also talking to politicians and governing bodies, like the EU and nation leaders, about the correct implementation of a CE future.

The EU are already putting measures in place to encourage CE systems through packaging, plastics or recycling systems.


Sustainable Development Goals

On a global level, all United Nation member states in 2015 adopted a 2030 Agenda for Sustainable Development. These include 17 sustainable development goals (SDGs) which call for urgent action by all countries. Most large organisations have systems in place to achieve these goals, such as Chiesi, Dell, GSK, Nestle, Sabic, Philips, etc. Forcing these giants into sustainable practices has not only yielded benefits environmentally, but socially and commercially. This global push has also opened up the gates for much smaller organisations who wished to do the right thing, but didn’t know where to start, what to do, or how it should be done.

In conclusion, it’s clear to see that there are plenty of existing and future legislation to limit our wasteful impact. There’s even a lot of very useful regulation regarding certain technical elements and even guidance documentation about how to effectively implement these changes.

However, as we are all aware, more still needs to be done, that’s why at HD we pay attention to not only current legislation, but keep our ear to the ground regarding future legislation, as the products designed today, need to be prepared for the world of tomorrow.

Designing for future legislation requires deep insight into market trends, technical capability and cutting edge technological innovations. This results in products that are designed 3-5-10 years ahead of the current market, meaning that should legislation come in that limits or even bans certain hazardous materials, or requires certain single material use, we would’ve already done so, meaning that there’s no future product recalls, or expensive retrospective redesign and potential for damage to your company reputation.


We’d very much like to hear what you say about sustainability. Do you think we’re doing enough? Do you think plastics are good or bad? What do you think we could do better at? Will the Circular Economy help? Please write to use and let us know!

If you would like to learn more about how we can help you with your NPD challenges, please get in touch.

William Morris - Senior Design Development Engineer & Business Development Manager at Haughton Design Will Morris 2 December 2021


Get in Touch with Will Morris

Senior Design Development Engineer & Business Development Manager

Will graduated from the University of Wolverhampton with a degree in Product Design. Prior to Haughton Design, Will worked for Renishaw, where he led the industrial design for the current and next generation metal Additive Manufacturing machines. Will has a strong interest in Design for Sustainability, and the Circular Economy, looking to reduce companies’ environmental impact and often teaches about design engineering at local STEM events. Outside of work, Will enjoys Formula 1, rugby and travelling with friends.

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