Common rules promoting the repair of goods

Decathlon welcomes the proposal on Common Rules Promoting the Repair of Goods. We fully support the European Commission in its bid to put forward solutions to ensure that products sold on the European market adhere to increasingly rigorous sustainability criteria. In particular, Decathlon supports the introduction of a consumer right to repair, to allow consumers to use goods for a longer time.

Right to Repair Europe welcomes the Commissions proposal for a directive on Common Rules Promoting the Repair of Goods, and this opportunity to provide feedback on the proposal. Although this proposals intent to grant Europeans a right to repair their products is a step in the right direction, the policy options outlined in the proposal do not grant a universal right to repair.

Independent Retail Europe welcomes the proposal on a Directive for common rules on repair and reuse. Indeed, since consumers are more and more eager to consume in more sustainable ways, retailers see new business opportunities in providing repair services. Independent retailers are aware of their linking role between manufacturers and consumers by giving valuable customer advice.

Japan Business Council in Europe (JBCE) welcomes and strongly supports the European Commissions Proposal for a Directive on common rules promoting the repair of goods. We believe that the proposal creates a proportionate framework ensuring that consumers have access to safe and high-quality repair.

Sonae is a multinational corporation that manages a large portfolio of retail, financial ser-vices, technology, fashion, wood-based panels, shopping centres and telecommunications businesses, creating value across various geographic areas.

EUREFAS, the European refurbishment association, expresses appreciation for the European Commission's proposal for a Directive to promote the repair of goods. While acknowledging the importance of a consumer framework, EUREFAS emphasizes that it must be complemented by ecodesign legislation that prioritizes repair and reuse.

MEDEF supports the European Commission’s initiative to introduce measures to facilitate access to repair for consumers. These proposals complement the French initiatives that have already been introduced since 2020, and in particular the ‘repair fund’ under LOI No 2020-105 of 10 February 2020 on combating waste and the circular economy (Article 62).

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Orgalim represents Europes technology industries, providing innovative technology solutions which are underpinning the twin green and digital transitions and can unlock a greener, healthier and more prosperous future for the European Union and its citizens.

EASRA experts would like to thank the European Commission for having taken into consideration the position that Danish Dansk Bilbranche Rad DBR and French Fédération Nationale de l'Automobile FNA independent repairers organizations had presented in March 2022 in response to the previous Consultation on general provisions relating mainly to electronic products; the hereafter claims were upheld: -To promote repair -To…

ETSA, the European Textile Service Association, represents and works on behalf of the textile services industry, which provides laundering and rental services for reusable textile products such as workwear, linen, and uniforms, while also representing textile manufacturers, machineries and detergents.

With currently more than 21 million members, ADAC e.V. is the largest automobile club in Europe and the second largest in the world. The four letters in its name stand for an association which offers its members assistance, protection and advice around the clock and is a powerful stakeholder on all mobility issues.

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In order to help build a circular economy and more sustainable consumption, EMISA wishes to highlight the importance of industrial sectors and the effects of the ongoing process of digitalisation in the context of repair and reuse of goods.

The Japanese electric and electronic industrial associations JEMA, JEITA, CIAJ and JBMIA (JP4EE) welcomes this opportunity to offer feedback concerning the European Commissions proposal for a "DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on common rules promoting the repair of goods and amending Regulation (EU) 2017/2394, Directives (EU) 2019/771 and (EU) 2020/1828".

BEUC welcomes the proposal for a Directive on common rules promoting the repair of goods (COM(2023)155). However, in our view the proposed measures will be insufficient to ensure that a proper right to repair is introduced for the European consumers. Several improvements are still needed (for additional details please see the attached document).

The TÜV Association welcomes the EU Commissions proposal on common rules promoting the repair of goods. The Right to Repair will make it easier and more cost-effective for consumers to repair goods rather than have them replaced. In addition, increased demand will boost the repair sector while creating incentives for manufacturers and sellers to develop more sustainable business models.

Bitkom e.V. is the German Digital Association and represents more than 2000 member companies from the digital economy. Bitkom members employ more than 2 million employees in Germany. Members include more than 1000 medium-sized businesses, more than 500 start-ups and almost all global players. Thank you for the opportunity to comment and our detailed feedback can be found in the attached file.

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Deutsche Industrie- und Handelskammer Vorschläge der Europäischen Kommission zum Anspruch auf Reparatur (Right to Repair) A. Das Wichtigste in Kürze Es ist positiv, dass mehr auf Freiwilligkeit gesetzt wird als im Entwurf von letztem Jahr. Es gibt dennoch einige Punkte, bei denen nachgebessert werden sollte.

Lenovo is a leading global technology company that designs and manufactures innovative personal computers, mobile devices, and data center solutions. As a company deeply committed to sustainability, Lenovo is fully supportive of the objectives and goals of the proposal for a Directive on common rules promoting the repair of goods.

The Directive will have positive effects on repairers, a sector mostly composed of SMEs. Independent repairers have the right expertise, experience, and the necessary tools to offer high-quality repair services. The Directive rightly proposes that repairers should have access to spare parts and technical documentation. However, the Directive will certainly have an impact on retailers and manufacturers.

The Federation of German Consumer Organisations (vzbv) welcomes the European Commission’s goal to improve the reparability of defective products in order to enable consumers to use their products for longer. However, the proposed measures are not sufficient to provide consumers with uncomplicated, almost and, above, all, economic access to repair.

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Refurbed, the fastest-growing marketplace for refurbished products in the DACH region and leading marketplace in Ireland, Sweden and Denmark, welcomes the opportunity to provide feedback on the long-awaited Right to Repair proposal. We aim to make the refurbed idea known throughout Europe and contribute to a more sustainable world.

The European Commission's proposal to promote the repair of goods is practical, proportionate and ambitious. It can help achieve sustainable consumption by increasing the repair and reuse of viable defective goods while securing high skilled jobs.

Logitech welcomes the European Commissions initiative to facilitate and make the repair of goods more cost-effective for consumers. We welcome the EUs efforts to further incentivize the demand for repair and boost circular business models. The Right to Repair obligations should be interpreted under durable and sustainable product design principles.

Back Market, a specialized marketplace for refurbished electrical and electronic products, collaborates with more than 1000 European repairers and refurbishers, offering valuable expertise in the professional second-hand sector.

Please find attached the Position Paper 28/23 of the German Bar Association (in German) on the proposal of the European Commission to promote the repair and reuse of goods. The German Bar Association (DAV) welcomes the objectives of the draft Directive without reservation. Who thinks that the intended priority of repair over replacement within the statutory warranty (Article 12) has to be clarified.

Filed in German · English published by the European Commission

Please find attached our response to the consultation. LKQ Europe, a subsidiary of LKQ Corporation is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe. It currently employs approximately 26,000 people with a network of more than 1,000 branches and approximately $5.7 billion in revenue in 2022.

UL Solutions welcomes the European Commissions intention to reduce waste and achieve a high level of consumer and environmental protection through the right to repair and reuse legislative proposal. A global safety science leader, UL Solutions helps companies to demonstrate safety, enhance sustainability, strengthen security, deliver quality, manage risk and achieve regulatory compliance.

The Federation of Finnish Enterprises (FFE) supports the reasons and objectives of this proposal promoting repair of goods, green transition and sustainable consumption. Consumption causes negative environmental and climate effects. These effects should be reduced by supporting various operating models of circular economy and by offering repair services and used goods to consumers.

The proposed Right to Repair Directive creates a positive new framework to enable more European consumers to access high-quality, safe repairs. Our members perform millions of repairs annually. Their repair facilities across Europe help promote sustainable consumption, reduce ICT products environmental impact, deliver real consumer benefits, and create high-skilled jobs.

APPLiA welcomes the publication of both Commission initiatives to promote repair and to substantiate green claims. The two texts bring stakeholders the complete picture of proposed requirements in the area of environmental and consumer protection together with the initiatives on ESPR and empowering consumers.

Gigaset Communications GmbH, Europe’s largest DECT telephone manufacturer, welcomes the EU’s basic idea of repair. For several years, Gigaset has been offering repairs to our smartphone and DECT device customers in some areas. However, from this experience, we also know about the limitations and difficulties of this project.

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The AVES Association supports the initiative of the European Commission to support the sustainable consumption of goods and the adoption of additional measures within the EU Action Plan for the circular economy.

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UNIFAB is the French association for the promotion and protection of intellectual property rights (IPRs). Today, UNIFAB represents more than 200 French and International companies as well as professional federations; it serves as unique guardian of IP rights (IPRs) of its members, and a platform for discussions on this important topic.

One of our major concerns relates to the policy options presented, since they will most likely encourage manufacturers to “close” the repair market to independent actors and user repair. In order for product life extension to remain effective, timely and affordable, the repair market should be open and competitive.

EuCER Council position on the promotion of repair and reuse The European Consumer Electronics Retail Council (EuCER) is an AISBL representing the major European Retail Groups and Chains active in the sale of Technical Consumer Goods.

APPLiA welcomes the Commission’s initiative on sustainable consumption of goods – promoting repair and reuse. It fits with the circular culture our industry is promoting and allows considering together aspects such as consumer rights, consumer and product safety, waste, sustainable behaviours and the creation of skilled jobs.

Since 2015, the Round Table on Repair e.V. brings together organisations active in the fields of crafts, environmental and consumer protection, science, advice and voluntary repair. The Association, together with its partners at national and European level, is committed to a universal right to repair.

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Vehicles are designed and equipped with very advanced technology in order to last in time for many years (in average 13 years). Vehicles are already reliable and durable products which provide value for money to consumers and prevent the overuse of resources and waste.

Right to Repair (R2R) Europe welcomes the Commission’s initiative to directly address repair and reuse in the context of sustainable consumption of goods. Considering that e-waste is one of the fastest growing waste streams in the world, and that the amount of household appliances failing within 5 years of purchase is skyrocketing, this is an area that requires urgent and focused policy attention.

Opinion of the Cradle to Cradle NGO’s Product-as-a-Service Alliance We, the Cradle to Cradle NGO’s Product-as-a-Service Alliance, support the European Commission’s initiative to promote the sustainable consumption of goods and take complementary measures under the EU Circular Economy Action Plan.

Filed in German · English published by the European Commission

A very important initiative because I work in refrigeration and bait on the market are now considered to be disposable because of the price of high parts and the price of appliances too low compared to the viable labour prices for a repair company. There is an urgent need to force manufacturers to return to fundamentals that have been removed for 10 years.

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ISFE represents the video games industry in Europe and is based in Brussels, Belgium. Our membership comprises of national trade associations in 15 countries across Europe which represent in turn thousands of developers and publishers in the member states.

The Free Software Foundation Europe is a charity that empowers users to control technology. For a more sustainable consumption of good, promoting repair and reuse we developed the following policy recommendation: • End-users should have the right to freely choose operating systems and software running on their devices; • End-users should have the right to freely choose between service providers to connect their…

Belron® is the world’s leading vehicle glass repair, replacement, and recalibration service provider, operating in over 25 countries in Europe with brands such as Carglass®, Autoglass® and Safelite®. Belron's feedback on the consultation is contained in it's attached submission.

Key messages EuroCommerce supports the establishment of a culture of repair and reuse in Europe Make the right to repair the most economically feasible, sustainable and attractive option to consumers, retailers, repair service providers and producers.

A large part of the professional federations that are members of CPME and their SMEs are committed to a circular economy, more respectful of resources and concerned with tackling the fight against global warming.

ECOS, welcomes the Commission’s initiative to directly address repair and reuse in the context of sustainable consumption of goods. Considering that e-waste is one of the fastest growing waste streams in the world, and that the amount of household appliances failing within 5 years of purchase is skyrocketing, this is an area that requires urgent and focused policy attention.

The Coalition Classifieds Marketplaces Europe (“Coalition”) is a group of EU headquartered companies, including Adevinta, OLX Group, and Schibsted, operating online classifieds platforms that connect buyers and sellers to safely, easily, and conveniently exchange goods and services in their local communities. From furniture to fashion, from cars to collectibles, from real estate to jobs.

The European Network for Social Integration Enterprises, ENSIE, represents the interests of national and regional networks of ‘Work Integration Social Enterprises’ (WISEs) striving for more inclusive and integrated forms of employment at European level.

Niaga® welcomes the EU’s initiative to promote repair and reuse. We support high ambitions and mainstreaming repair and reuse in the EU, which is essential to transition to a climate-neutral and resource-efficient CE where materials keep their value.

SIRMELEC, representing the professional electrical equipment maintenance companies in France (trainer and rotating machines), wishes to give its views on the levers to be mobilised to encourage longer use of professional electrical equipment. Its proposals are set out in the attached contribution in the fields of taxation, eco-design criteria, regulatory framework and vocational training.

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Generation Climate Europe is a coalition of youth-led networks focusing on environmental and climate issues. At GCE, we fight for a system that respects human rights and the planet, that includes the youth voice and acknowledges our common responsibility.

The European Remanufacturing Council represents companies that extend the life of products through industrial-scale processes of remanufacture and refurbishment. 90% of the €30 billion European sales in the sector are in B2B with only 10% in B2C. Expanding the expertise in B2B toward B2C products is going to be necessary for a more circular economy.

With more than 875 000 members and funders, NABU, founded in 1899, is the oldest and largest environmental association in Germany. NABU welcomes the initiative on “Sustainable consumption of goods and the promotion of repair and reuse”.

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We share the objectives of the Green Deal and fully support the European Commission in its bid to put forward solutions to ensure that products sold on the European market adhere to increasingly rigorous sustainability criteria. We are positive about implementing new circular economy initiatives and the encouragement of consumers to use goods for a longer time.

FairTEC contribution to the initiative itself. — We subscribe to educational transparency on the social and environmental impact and impact of the electronic industry. Specifically, we propose, on the one hand, to raise awareness about the impact of production and, on the other hand, to encourage moderate use of a smartphone.

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DIGITALEUROPE believes that consumers should be entitled to high-quality repairs that are safe, secure and reliable. Our members already treat repair, refurbishment and remanufacturing as part of their everyday business practice, performing millions of repairs annually.

Dear Sir or Madam, at the European Commission We are answering the following consultation on the Sustainable Consumption of goods, promoting reuse and repair, on behalf of ETSA and the greater textile services industry.

SINTEF would like to provide the following comments to the proposed amendment to the Sales of Goods Directive. We believe the following measures will be key to promoting sustainable consumption of goods: 1. Incentivize new products that make it easier for the consumer to repair common faults with provided spare parts and repair instructions, standardized design of components. 2.

The Fédération Internationale des Véhicules Anciens defines a historic vehicle as a mechanically propelled road vehicle which is at least 30 years old; which is preserved and maintained in a historically correct condition; which is not used as a means of daily transport and which is therefore a part of our technical and cultural heritage.

FIGIEFA welcomes the objectives of the new ‘Right to Repair’ Initiative of the EU Commission, which will contribute to promote more accessible, green and affordable repair services to the benefit of all European consumers.

Of the policy options outlined, Option 1 is voluntary and therefore low-level commitments are unlikely to provide a real solution to the problem outlined. Based on the above, we support option 2/moderate intervention.

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IKEA welcomes the EU Commission’s efforts to enable and accelerate the adoption of the circular economy principles by creating policy and regulatory pre-conditions. Reuse and repair are of paramount importance to prolonging product and material life, addressing one of the most problematic climate impact areas.

Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission’s initiative to promote more sustainable use of goods throughout their useful life through reuse and repair. Crucially, this initiative cannot be achieved without also addressing consumption of healthcare products.

The Association of Medical Device Reprocessors, representing the regulated, commercial medical device reprocessing and remanufacturing industry, respectfully submits the attached comments promoting reuse and repair for "single-use" medical devices.

The Information Technology Industry Council (ITI) welcomes the opportunity to respond to the “Sustainable consumption of goods – promoting repair and reuse” initiative public consultation from the European Commission. ITI represents 80 of the world’s leading information and communications technology (ICT) companies from all corners of the technology sector.

The European furniture industries promote the transition to a circular economy and sustainable consumption and welcome the opportunity to provide comments on the open public consultation on Sustainable consumption of goods – promoting the right to repair and reuse. Kindly find in the attached our general considerations. European Furniture Industries Confederation

The National Network of Usato Operators (UN Network) is the trade association of reuse operators in Italy and employs more than 13.000 people. In order to promote the reuse and repair of goods, it is crucial to build on the existing reuse and repair sectors, without favouring particular groups or frames, and taking note of the large numbers guaranteed by these sectors despite their fragmented and often ineffective…

Filed in Italian · English published by the European Commission

For me the right to repair should be effective as long as product is expected to last. So for example 10 - 15 years for a mattress, 20 years or 400.000 kilometers for a car, 15- 20 years for a washing machine, etc. The manufacturer should make sure that all parts last that long and/or can be replaced with spares during that time.

Reparability must be permitted by the provision of means to enable the products to be removed, but also for primary parts and wear and tear. Access to technologies, including softwares with impossibility of diagnosis, should be regulated, in particular where the owner does not have or make available a repair solution.

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FSB supports the objective of tackling the unsustainable consumption of goods and promoting greater repair and reuse. Small businesses are keenly aware of the need to act on climate change and are eager to contribute. Many are taking active steps towards greater sustainability, whether within their own business practices or in terms of the products and services they provide.

>>Challenges: GISAD welcomes the initiative to promote repair and reuse. An EU D-S to preserve democracy in the digital society must provide access for every citizen. However, many citizens do not have the financial means or still use an old, non-Internet enabled mobile phone only to make phone calls. This GISAD statement only refers to devices that are suitable for communicating via the internet.

The Sporting goods industry welcomes the opportunity to comment on the ‘Right To Repair initiative’. In the attached position paper you can see how our sector is building momentum to support the objectives of the EU Green Deal and has developed ambitious circular economy programs by improving new business models or investing in existing models including rental, resell and repairing.

ACR+ welcomes this initiative of the European Commission to encourage consumers to use goods for a longer time and to promote repaired, second-hand and refurbished goods. We would like to highlight some key points that have to be kept into consideration. Please find more clarification in our full feedback attached. Legal and economic instruments are needed both on demand and supply side: - Product policy.

In the position paper attached, you can find UNIZO’s view with regard to the impact assessment conducted by the European Commission on several policy options aiming at promoting repair and reuse with a view to enhancing the sustainable consumption of goods. UNIZO is an organization defending the interests of self-employed persons and SME’s in Belgium.

ECAR (the European Campaign for the Freedom of the Automotive Parts and Repair Market) fully supports the objectives of the new Right to Repair Initiative, which will contribute to promote more accessible and affordable repair services to the benefit of all European consumers.

CEFACD, representing domestic and local space heating manufacturers, appreciates the possibility to provide feedback to the European Commission's Sustainable Consumption of Goods Initiative (SCGI). Nonetheless, CEFACD would like to raise some concerns and offer recommendations in order to optimise the efficiency of the SCGI in relation to other policies that are also addressing material efficiency and…

EPEE, the voice of the refrigeration, air conditioning, and heat pump industries, appreciates the possibility to provide feedback to the European Commission's Sustainable Consumption of Goods Initiative (SCGI). Nonetheless, EPEE would like to raise some concerns and offer recommendations in order to optimise the efficiency of the SCGI in relation to other policies that are also addressing material efficiency and…

The European Infrared Heating Alliance (EIHA) appreciates the possibility to provide feedback to the European Commission's Sustainable Consumption of Goods Initiative (SCGI). Nonetheless, the EIHA would like to raise some concerns and offer recommendations in order to optimise the efficiency of the SCGI in relation to other policies that are also addressing material efficiency and sustainability.

EVIA welcomes the opportunity to provide feedback to the European Commission's Sustainable Consumption of Goods Initiative (SCGI). Nonetheless, we would like to raise our concerns and offer recommendations in order to optimise the efficiency of the SCGI in relation to other policies that are also addressing material efficiency and sustainability of goods.

In addition to the consultation questions, the North Netherlands provides the following information. As far as our region is concerned, it is very good to refer to producers, as we see in the regular surveys we carry out among their own residents (when it comes to reducing waste and separating waste), that users also consider producers primarily responsible for producing sound products and prefer to call them to do…

Filed in Dutch · English published by the European Commission

CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its national industry members. CONEBI welcomes the European Commission’s initiative ‘Sustainable consumption of goods – promoting repair and reuse’.

Dear Madam/Sir: Brussels Consulting Kft. and its clients believe that the “Sustainable consumption of goods” initiative and the right of consumers to repair are important steps for increasing the circularity of electronics and electronic equipments. We would like to point out that a key concept to bear in mind is that of the “smallest unit of practical repair”.

Day of laba, Lithuania restricts the rights of waste managers in plastic waste recycling activities that produce plastic pellets from the recycled plastic itself. The Law on Waste Management and the Procedure for classifying production residues as by-products limit the possibility for waste processors to take advantage of the opportunity to consider inert materials generated during their activities as a by-product…

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Please find MWE's thoughts in the paper attached. Municipal Waste Europe is the European umbrella association representing public responsibility for waste. Our members are national public waste associations and similar national or regional associations or municipalities.

Before going into details, EHPA would like to stress that heating products are not the focus of this newly plan legislation because they are completely different products which we will further explain below. Furthermore, heat pumps are already performing well and an example when it comes to long-lasting products, availability of spare parts, repair and maintenance.

Position papier „ Right to repair “ FENA criticizes the right to repair of furniture Sustainability has long since ceased to be a buzzword and is being pursued vehemently by the EU Commission: Products should be manufactured in an environmentally friendly manner, be durable, (more easily) repairable and recycled at the end of their service life.

Ecopreneur.eu - the European Sustainable Business Federation - and its seven member organisations welcome the European Commission’s “Right to Repair” initiative aimed at extending the lifetime of consumer products through improved quality and ease of repair while promoting the purchase of second-hand and refurbished goods.

Summary - In this feedback to the public consultation for the Sustainable consumption of goods – promoting repair and reuse initiative (‘the initiative’), we argue that the Sale of Goods Directive (EU) 2019/771 should be amended (as soon as possible), so as to make consumer sales law more sustainable and circular.

ECC-Net gathered internally information on the transposition of Directive 2019/771 into national laws. Part of this survey was national rules, initiatives and info in relation to the right to repair, spare parts, right to reject etc.

The Polish Chamber of the Derivative Industry is strongly in favour of moving away from the placing on the market of single-use goods with a short foreseeable period of use. Our belief stems from years of observation of our own market and participation in international discussions on the risks posed by the saturation of markets with products of dubious quality, the main feature of which is their low price.

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At Aalborg University, we have in 2020, as part of a research project, carried out a survey among citizens in the Capital Region of Denmark about the citizens' experiences with repair needs and repair experiences. (Furthermore the survey covered purchase of new versus used products and the reasons behind). The survey report (in Danish) is attached.

The Repair Round Table and its members (repairers, repair initiatives, consumer protections, environmental associations) have been working since 2015 on what needs to be done to increase the number of repairs. On www.runder-tisch-reparatur.de you can find all policy papers, analyses, proposals and demands.

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• The German economy supports the objective of a circular economy in which products and feedstocks can be made more resource efficient. • However, legal extensions to guarantee rights such as a right to repair are criticised by large parts of the German economy. This is afraid of considerable logistical and financial burden.

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SEDIMA, a professional organisation, represents the companies distributing, repairing and renting green space maintenance equipment. The latter are concerned with the protection of the environment and wish, as longstanding actors involved in repair and reuse, to help combat the increase in waste. It is in this context that we send you our contribution in the attached document.

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We are the FairTEC collective! We are working together to propose credible and sustainable alternatives for digital sobriety. 7 European organisations make up the collective: Commown, Fairphone,/e/OS, Neibo, TeleCoop, Your Co-op Mobile, WEtell.

Filed in French · English published by the European Commission

Response to initiative 13150 We are FairTEC: We are a collective, offering credible and sustainable alternatives in the field of digital communication, in order to create a paradigm shift: Commown: A cooperative electronics rental service Fairphone: A Dutch social enterprise that manufacturers. /e/OS: An open-source operating system that respects end-user privacy. Neibo: A Belgian cooperative telecom.

Please find attached the full contribution. The Halte association with planned obsolescence works in France for durable and repairable products through awareness-raising, advocacy and legal action. In 2020 it published a White Paper on the subject.

Filed in French · English published by the European Commission

I think the promotion of repair and reuse is a great initiative. People WANT to buy reliable products with long lives, it is the sellers who force people to buy poor quality products in order to sell more. Even without any incentive, I believe the establishment of a classification of products as "repairable" with a score like the energy efficiency score would already be highly beneficial to European citizens, who…

Reuse and sustainability are very important for Adolf Würth GmbH & Co. KG, while Würth meets the highest quality requirements. Therefore, we are of the opinion in principle that both manufacturers and distributors should offer repairs within the legal guarantee period. This service is already provided at Würth. It is important for us that repairs should not be equated with the purchase of a product.

Filed in German · English published by the European Commission

CE is a global topic and can (unfortunately) not be created/implemented in one continent, in silo. What the EC decides on, towards a greener/circular tech industry, will have an impact on other parts of the world. Some of those impact can be negative and if that is the case, and those parts of the world are also more vulnerable than (most) EU countries, the EC cold consider that impact.

As a TÜV association, we welcome a product policy that ambitiously promotes the transition from a linear economy to a circular economy. This includes the issue of the repair (ability) of products with the aim of significantly prolonging their useful life. The Sustainable Products (SPI) initiative should establish a right to reparability. The TÜV Association supports Option 3 taking into account all sub-options.

Filed in German · English published by the European Commission

The warranty period/should depend on the frequency of use of the product and on what it is done. I am referring mainly to the footwear and clothing sector. Footwear is particularly exposed to adverse external conditions. The soles are in contact with the ground, they wipe and users often use the same pair of shoes. Footwear made of natural leather is used differently from synthetic materials.

Filed in Polish · English published by the European Commission

• Prohibit planned obsolescence practices by using the definition that exists in French legislation: The practice of planned obsolescence, which is defined by the use of techniques, including software, whereby the person responsible for placing a product on the market is intended to deliberately reduce its lifespan, shall be prohibited.

Filed in French · English published by the European Commission

Clothes and shoes can be repaired: •if materials are available: Some 40 000 different products and 209 million garments are sold in Finland, making it impracticable to store fabrics and materials •Shoes and clothing sold in Finland are almost 100 % produced outside Finland and 95 % outside the EU. It is practically impossible to obtain or store fabrics and accessories for the repair of these products.

Filed in Finnish · English published by the European Commission

Good day, I represent a shoe manufacturer of the RYŁKO brand. We mainly produce leather shoes, of high quality, with an annual production of around. 700-800 thousand pairs of footwear. We are one of the best-recognised Polish footwear brands, all of our production takes place in Poland. Our shoes are known for high durability and have been used by customers for many years.

Filed in Polish · English published by the European Commission

Good day, I represent a shoe manufacturer of the RYŁKO brand. We mainly produce leather shoes, of high quality, with an annual production of around. 700-800 thousand pairs of footwear. We are one of the best-recognised Polish footwear brands, all of our production takes place in Poland. Our shoes are known for high durability and have been used by customers for many years.

Filed in Polish · English published by the European Commission

Good day, I represent a shoe manufacturer of the RYŁKO brand. We mainly produce leather shoes, of high quality, with an annual production of around. 700-800 thousand pairs of footwear. We are one of the best-recognised Polish footwear brands, all of our production takes place in Poland. Our shoes are known for high durability and have been used by customers for many years.

Filed in Polish · English published by the European Commission

The Federation of Norwegian Industries supports the introduction of a consumer right to repair. Such a "Right to Repair" for consumers must be accompanied by a right for sellers of a product to offer reparation of products within the legal liability period.

The Federation of Norwegian Industries supports the introduction of a consumer right to repair. Such a "Right to Repair" for consumers must be accompanied by a right for sellers of a product to offer reparation of products within the legal liability period.

The Federation of Norwegian Industries supports the introduction of a consumer right to repair. Such a "Right to Repair" for consumers must be accompanied by a right for sellers of a product to offer reparation of products within the legal liability period.

Many thanks for giving the Federation of Craft Businesses in the Automotive sector and in Mobility Services (FNA) the opportunity to answering the European Commission Consultation on the right to repair. The proposal for provisions on the right to repair, presented by the European Commission, is a response to the vote of the European Parliament of 25 November 2020 on the Resolution for a more sustainable single…

1. It should also be laid down, in the most lenient form of the manufacturer’s obligation, that repair and service documentation for technical products is available to consumers at a low level. 2. Manufacturers should be prohibited from designing the casing of a product in such a way that it can only be opened by destruction.

Filed in German · English published by the European Commission

1. It should also be laid down, in the most lenient form of the manufacturer’s obligation, that repair and service documentation for technical products is available to consumers at a low level. 2. Manufacturers should be prohibited from designing the casing of a product in such a way that it can only be opened by destruction.

Filed in German · English published by the European Commission

These proposals are whole heartedly supported by myself as the founder of How To Basically which is a social enterprise dedicated to educating people on every day domestic jobs including repairing white goods, clothes, cars and bikes (together with using a power drill, decorating and gardening). We're based in England but I hold an Irish passport and aim to establish in all member states.

These proposals are whole heartedly supported by myself as the founder of How To Basically which is a social enterprise dedicated to educating people on every day domestic jobs including repairing white goods, clothes, cars and bikes (together with using a power drill, decorating and gardening). We're based in England but I hold an Irish passport and aim to establish in all member states.

These proposals are whole heartedly supported by myself as the founder of How To Basically which is a social enterprise dedicated to educating people on every day domestic jobs including repairing white goods, clothes, cars and bikes (together with using a power drill, decorating and gardening). We're based in England but I hold an Irish passport and aim to establish in all member states.

These proposals are whole heartedly supported by myself as the founder of How To Basically which is a social enterprise dedicated to educating people on every day domestic jobs including repairing white goods, clothes, cars and bikes (together with using a power drill, decorating and gardening). We're based in England but I hold an Irish passport and aim to establish in all member states.

These proposals are whole heartedly supported by myself as the founder of How To Basically which is a social enterprise dedicated to educating people on every day domestic jobs including repairing white goods, clothes, cars and bikes (together with using a power drill, decorating and gardening). We're based in England but I hold an Irish passport and aim to establish in all member states.

Great initiative Please consider to include the right of update firmware or software as part of the right to repair. A lot of hardware is useless in some time if the logic software that connect it to third party operating systems (android, iOS, Windows, Linux...) doesn't run because is not update to work with the last versions of the operating system in which relays a big part of the value of the hardware.

While the Initiative on the Sustainable Consumption of Goods – Promoting Repair and Reuse is hearti-ly welcomed, it should always take into account that the “consumption phase” is preceded by a selec-tion and purchase or borrowing phase which sets the frame for the consumption phase proper.

Dear Sir or Madam, first of all, we would like to thank you for the opportunity to issue an opinion on the EU initiative “Sustainable consumption of goods — promoting repair and reuse”. 1. General We disagree with the assumption that, in principle, companies have only a limited economic interest in producing or delivering environmentally sustainable goods.

Filed in German · English published by the European Commission

As one of the founders, in addition to the promoter and volunteer of RepairCafePerugia (we are now in 11 people), who has been disseminating good practice in Umbro and beyond for 5 years, I would like to highlight above all the lack of financial support for this type of activity, which will generate significant environmental, social, cultural, work and training benefits.

Filed in Italian · English published by the European Commission

Sustainable consumption and the circular economy express societal policy objectives, which deliver on individual and collective fundamental rights. The effective implementation of these green policy objectives in an efficient and participatory way requires the involvement of all parts of society, starting with professionalism in technology.

Filed in Italian · English published by the European Commission

The sale of second-hand textile goods (clothing, accessories, footwear) cannot include a legal guarantee period for manufacturing defects or preparation for re-use processes. The sale of second-hand textiles cannot render sellers liable for any defects which may exist at the time of delivery (sale of second-hand goods) or subsequently.

Filed in Spanish · English published by the European Commission

In our opinion the main points and arguments on repairability can be summarized as follows: • Repairability is product specific, and can even vary within a product category. no one-size-fits all approach. • Legal guarantee, minimum 2 years, only conformity, most defects occur within the first 6 months (71 %) and within the first year (87%) • Trader best to assess best remedy • Consumers usually want a replacement •…

We welcome the idea of Commission to promote sustainable products, otherwise we consider that the ideas of the Commission are contradictory. It is not clear why we have an idea of Commission in which we want to have durable products, in this sense it means that they rarely reach the repair and ideas in which the consumer is entitled to replace the defective product with a new one with the idea of repair his.

Manufacturers should provide instructions on how products are used sustainably (how to keep them longer, how to consume less energy, how to dispose of them safely, etc.), and, especially for repairable products, provide clear instructions and manuals to allow for repair by any competent person (e.g.

Filed in Italian · English published by the European Commission