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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”.

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.

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).

Key messages According to SMEunited the proposal contains several provisions and approaches which are very positive, such as: - the need for uniform market surveillance in the EU, - the general approach to AI, - the formal recognition of the imbalance between the rules for physical stores and those for digital platforms.