European Refurbishment Association

EUREFAS (the European Refurbishment Association) welcomes the proposed Circular Economy Act as a way to stimulate demand for secondary materials and harmonize a single market for waste. However, it warns that the CEA overlooks a core pillar of circularity: product lifetime extension through reuse or repair of electrical and electronic equipment.

EUREFAS, the European Refurbishment Association, welcomes the European Commissions initiative to revise the current public procurement framework. We believe that public procurement must evolve from a simple administrative task into a powerful lever for industrial sovereignty and circular resilience.

EUREFAS broadly welcomes this draft Implementing Regulation as a necessary and well-structured step towards operationalising the Digital Product Passport framework. The registry architecture, the tiered access system, and the inclusion of value chain actors as legitimate DPP updaters reflect a sound understanding of how products circulate across the economy.

EUREFAS - the European Refurbishment Association - welcomes the opportunity to provide high level comments on the draft Act. Our association gathers actors of the refurbishment sector interested in ensuring long-term sustainability of the consumer electronics industry by allowing devices to get multiple use lives.

EUREFAS, the European Refurbishment Association, welcomes the Commissions initiative and strongly supports the objectives of the Critical Raw material Act Regulation 2024/1252. EUREFAS particularly endorses the recognition of the materials listed in Annex I as having high strategic potential in contributing to the EU's critical raw material (hereafter CRM) policies as outlined in Article 1 of the Regulation.