Towards an EU Product Policy Framework contributing to the Circular Economy

To whom it might concern In view of a policy framework, and especially regarding circular economy, a holistic approach it is crucial. It is beyond controversy that minimizing climate change, ozone depletion, acidification, eutrophication, resource use and others are important contributions on the way to circular economy.

Detailhandel Nederland, the Dutch Retail Association, represents the collective social and economic interests of Dutch retailers. The Association welcomes the opportunity to comment on the Commission’s Roadmap 'Towards an EU Product Policy Framework contributing to the Circular Economy'.

ChemSec welcomes the work the Commission is conducting on Circular Economy. However, we sense through the number of consultations and events that the important perspective of the progressive down stream users as well as the recyclers have not been given the appropriate space. Increasingly, downstream users are realising that hazardous substances mean exposing customers to a risk.

FEVE welcomes the opportunity to comment on the Commission’s Roadmap on an EU Product Policy Framework contributing to the Circular Economy. We would like to highlight the specificity of food products and food packaging in the context of product policy. As fast-moving consumer goods, food & food packaging products are a very relevant category for the Commission’s further work on EU product policy.

We agree with the feedback by the European Environmental Bureau, which they have handed it (EEB proposals for a more coherent EU Product Policy Framework contributing to the Circular Economy). We have a few additions as that we have encountered as part of our campaigns, notably our campaign to increase circularity of the carpet sector.

The European steel industry welcomes the development of a coherent product policy framework that supports a circular economy and sustainability, giving full recognition to materials fit for circularity and supporting sustainable outcomes. We are at a critical stage in which EU product policy can be shaped to fully support the development of a more Circular Economy.

We support the circular economy concept aiming at the use of much more circular products, to identify those products which could be reused, repaired and recycled. It is especially important to extend EU regulation to these products, due to the increasing amount of waste produced in the EU, such as waste tyres. Reuse of tyre rubber as raw material could be a good method to reduce the amount of waste.

Consultation on a Roadmap towards an EU Product Policy Framework - input from the Swedish Government Offices • Sweden supports the ambition from the Commission to develop an EU Product Policy Framework and the aim to address that many products in use today are not designed or produced with circularity in mind. This concept was introduced already in the Communication with an Action Plan for a Circular Economy.

FoodDrinkEurope represents Europe’s food and drink industry, Europe’s largest manufacturing sector in terms of turnover, employment and value added. Firstly in is relevant to highlight that Food and drink products are already covered or have been recently assessed under a large number of European Policies cited in the roadmap: • Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF)…

Contribution agreed between ACCREDIA-L’ Ente Italiano UNI-Ente Italian accreditation and standardisation The new EU Circular Economy will encourage productions that minimise the consumption of resources by reducing waste and environmental impact. Promote a radical rethink of production systems, by design, which will require a long-term commitment.

Filed in Italian · English published by the European Commission

The European non-ferrous metals industry is a key materials supplier and recycler of valuable metals from cars, buildings, packaging, e-waste, batteries and other applications. We support fully support the transition to a true circular economy. We believe that a coherent EU Product Policy Framework will be integral to improving product design, manufacturing, use and end-of-life treatment.

Conversion to circular economy must be triggered by a demand for recyclable materials from the market e.g. stimulation of public procurement and consumer interests. Evidence for circular economy should be targeted by e.g. recycled materials presents in consumer products. One goal should be high material quality in recycling though stronger standardization and certification schemes. The Commission should e.g.

Product Environmental Footprint (PEF) The pulp and paper sector has been deeply involved in the development of category rules for Intermediate Paper Products. The methodology is very time and resource consuming. Furthermore, some parts of the methodology as defined in the guide, have shown not to be robust, mature and scientifically grounded. It is valid for the eco/human toxicity and land use impact categories.

FEAD welcomes the publication of the EC Roadmap "Towards an EU Product Policy Framework". The private waste and resources management industry would like to stress the following points: • We need to focus more on the very first step in the value chain and intensify our cooperation with designers and manufacturers to ensure that products are designed to prevent waste and to be easily reused, dismantled and recycled.

First and preliminary Belgian comments on the roadmap « Towards an EU Product Policy Framework contributing to the Circular Economy": • The initiative should not only analyse the soundness and completeness ‘in abstracto’ of existing EU product policy but should analyse it in relation to the actual impact of this current policy on macro indicators of European sustainability (GES, annual energy consumption, annual…

The Commission intends to emphasise circular economy aspects, such as reparability, durability, upgradability or recyclability in the EU Product Policy framework in the context of the EU Circular Economy agenda.

APPLiA, representing the home appliance industry, takes this opportunity to give some initial comments from the perspective of our sector in relation to the EU product policy framework contributing to a circular economy. Please find this attached. Thank you.

European Organisation of the Sawmill Industry: Who We Are The European Organization of the Sawmill Industry (EOS) is a Brussels-based non-profit association representing the interests of the European sawmilling sector on European and International level.

An ambitious EU Product Policy Framework contributing to the Circular Economy should take place in the context of an articulated European Strategy for a non-toxic environment, which is one of the deliverables the European Commission is committed to under the 7th Environment Action Programme. In HEAL's new, regulations for new products need to be strengthened, in particular through better implementation of REACH.

ACEA, the European Automobile Manufacturers' Association welcomes the opportunity to comment on the Commission Roadmap “Towards an EU Product Policy Framework contributing to the Circular Economy”. Particularly, ACEA members would like to reflect on the problem this initiative aims to tackle. Please find ACEA feedback enclosed.

Preliminary comments: We are all sensible to reducing consumption in the printing industry. Printer manufacturers have focused on launching products with a lower consumption energy. In this sense the progress has been fantastic. But it is difficult to see a similar progress in reducing the actual waste generated via the printing process.

ECOS welcomes the European Commission’s ongoing efforts to develop an EU circular economy. We strongly encourage the EU to ensure that the circular economy respects planetary boundaries and fair share of use and access to resources, and avoids and minimises negative impacts of resource use including biodiversity loss, climate change, pollution, and reduced/impaired human health.

ESPP (European Sustainable Phosphorus Platform) considers as positive this initiative and supports EU action in favour of the Circular Economy, for which policy at the European level is important to ensure a dynamic and operational single market and to remove barriers for recycled nutrient products, for recycling technologies and for recyclable waste/secondary raw materials.

We welcome this initiative and roadmap. With this comment we want to highlight some important aspects that should not be underestimated. 1. The importance of having a circular resource management perspective Managing the use and impacts of resources in our society - such as primary resources, secondary resources (waste), energy, and renewable materials - needs to be approached from a broad systems perspective.

- All across Europe, consumers are getting a bad deal: too many new products don’t last as long as they should. The average life of washing machines before replacement in 2000 was ten years, while in 2010 the average life was only seven years(1). On top of this being a waste of money for the consumer, it is also a huge waste of resources and a large source of carbon emissions.

- ‘Products & services’ are the entry point for material loops: 80% of environmental impacts are determined at design stage and if injecting single use & toxic materials through products we spoil the whole potential for circularity. It is no brainer that products and services need to be better designed for circularity. It’s impossible to make a good recipe with rotten ingredients.

In our assessment, an initiative to review the substance and completeness of existing EU policy and regulatory instruments and regulations, including the work undertaken as part of the follow-up to the re-update of the EU Ecolabel and its link to the work on product policy, is much needed.

Filed in Polish · English published by the European Commission

- ‘Products & services’ are the entry point for material loops: 80% of environmental impacts are determined at design stage and if injecting single use & toxic materials through products we spoil the whole potential for circularity. It is no brainer that products and services need to be better designed for circularity. It’s impossible to make a good recipe with rotten ingredients.

FEEDBACK FROM EUROPEAN BOATING INDUSTRY The European Boating Industry (EBI) salutes the Commission’s initiative to work on an EU Product Policy Framework contributing to the Circular Economy. Such coherent and unique policy will greatly improve the sustainability of our society and economy.

Products and services must be designed from the start to enhance circularity. It's the design stage that counts the most when creating the environmental impact, and it is at that stage that most of the effort must be done to improve European policy on circularity.

- ‘Products & services’ are the entry point for material loops: 80% of environmental impacts are determined at design stage and if injecting single use & toxic materials through products we spoil the whole potential for circularity. It is no brainer that products and services need to be better designed for circularity. It’s impossible to make a good recipe with rotten ingredients.

The economic system and its environment are changing continuously. Against this background, the regulatory framework for the European Single Market – a key factor for European integration, must regularly be put to the test. In this sense the Federation of TÜV (VdTÜV) welcomes the European Commission's plan for an initiative „Towards an EU Product Policy Framework contributing to the Circular Economy“.

Considering the use of materials remanufacturing is one of the most preferable alternatives because the geometrical form of the product is retained and its associated economic value is preserved. The DKWU Networks main concern in regard to remanufacturing are imaging devices (Printers, Multi Functional Printers (MFPs), Copiers and Fax machines) as well as their consumables (cartridges, drum units, etc.).

The Recycling of end of life tyres is important as the quantity of old tyres in the EU reaches 2 mio tons per annum. Recycling technology and a full scale of products made from end of life tyre rubber has been existing for decades. Yet, lawmakers in the EU and especially in Germany are starting to ban tyre rubber as raw material for many products due to it's pah-content.