Compare organizations

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”.

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.

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.

APPLiA (Home Appliance Europe) believes that GPSD has been working reasonably well over those almost 20 years and does not require major revision. However, considering time and efforts already invested in possible review, Option 0 ’Status quo’ is probably not realistic anymore.

Brussels Consulting Kft. submits the following concerning the Commission’s draft: • Overall, we support Commission’s proposal and we believe that the proposed (new) requirements are appropriate. • We recognise similar high-level requirements in existing US law, and we suggest that the Commission took a look at them if hadn’t already (e.g. Consumer Product Safety Improvement Act).

This document is focusing only on key aspects. APPLiA is happy to contribute to the legislative process with further details at a later stage. 1 - Improved coherence with New Legislative Framework The GPSR is thought as a “safety net” to Union harmonised legislation, therefore coherence with the New Legislative Framework (NLF) is of utmost importance.