Lobbies are divided on product policy, ENDS has reported, referring to the highly anticipated release of a revised legislative package on Circular Economy.
Many trade associations support industry-led initiatives, which although admittedly express the need for a circular economy, are wary of adding stricter requirements on products, waste, and production processes. In addition to this, a true circular economy will promote an extended lifetime of many products, and a more services-oriented economy, which might lead to fewer products released on the market.
ECOS argues for the establishment of Ecodesign product-specific regulatory requirements for both energy and – in due course- non-energy related products, including material efficiency aspects. The development of a set of harmonised measurement and testing methods (both horizontal and product specific), would provide the necessary foundation in order to assess and implement the aforementioned requirements, notably on increased durability, reusability, reparability, and recyclability.
In our response to the public consultation of the Circular Economy, ECOS stresses the positive role of harmonised standards, which can create the necessary conditions for a true circular economy. We highlighted areas which deserve closer attention, namely:
- Regulatory gaps in product policies to tackle material efficiency, durability, reparability/re-usability and end-of-life requirements (e.g. ensuring traceability of products, especially for hazardous chemicals and nanomaterials) for both energy and non-energy related products;
- Closer management of the supply chain and material flows in the production, consumption and post-consumption phases to promote the use of renewable raw material with reduced environmental impacts as well as markets for secondary raw materials;
- Lack of harmonised standards to guarantee the quality of recycled materials and to avoid toxic legacies through contaminated materials;
- Focus on packaging materials to avoid single-use and improve sustainability, compostability, and biodegradability of packaging in general and of plastic and multi-material packaging in particular.
ECOS’ views take a similar tone to other environmental organisations, such as the European Environmental Bureau (EEB). With such different priorities seen between environmental NGOs and that of industry associations, it becomes important to not lose sight of what is meant by a true circular economy, namely, closing the material loop and enhancing the re-use, repair, refurbishment, and recycling of existing materials and products.
Read ECOS contribution to the public consultation here.