ECOS took part in two public consultations launched by the European Commission in relation to the Circular Economy, focusing respectively on Product Environmental Footprinting (PEF) and EU product policy tools.
These consultations were inititiated as part of the EC 2015 Circular Economy Action Plan, with a view to develop a more coherent policy framework which would streamline policies applying to products placed on the EU market and promote circularity principles.
In our contributions we stressed several blind spots in the PEF methodology. We warned against its potential use for communication to consumers, which would be at the expense of well-established and third-party verified labels such as the EU Ecolabel.
In relation to EU product policies, we highlighted the importance of the early stages of a product’s life cycle with a focus on product design and chemicals. Instead of the current focus on the end-of-life to recycle products, we recommend that more emphasis is placed on product design so as to make them longer-lasting, reusable, repairable, and taking into account green chemistry principles.