RREUSE response to the consultation on an EU Sustainable Product Initiative

As the network of social enterprises active in re-use, repair and recycling, RREUSE is expecting the implementation of the SPI with anticipation. We believe that developing resource efficiency requirements for products through ecodesign will be a milestone in the development of products that are fit for a circular economy. To ensure that products still hold value when reaching the second-hand market, the first step is to make them durable and repairable.

However, RREUSE would like to raise the Commission’s attention towards the risks of developing solutions wherein independent operators and consumers are excluded from the process. The social impact of developing a circular economy can only be positive if all actors work in a symbiotic way.

RREUSE would, therefore, like to make the following recommendations:

• Ensure that new circular business models truly implement the waste hierarchy and do not encourage the development of repair/maintenance monopolies by producers/importers
• Develop the product passport with relevant maintenance and repair information, making it available on the product itself to ensure the information is available on the second-hand market
• Ensure that the product passport not only contains information on how the product should be recycled at the end of life, but also on how the product can be repaired/reused
• Lower the cost of repair/re-use (eg. through the use of repair vouchers or lower VAT) while driving up the price of new products
• Lower the price of spare parts or make producers/importers commit to maximum prices for the spare parts that are associated to their products (and make that information accessible on the product passport)
• Develop minimum average lifetimes, determined by categories of products, that, if not respected by producers/importers, will result in sanctions
• Tax the advertisement of new products

Picture credit © Cooperativa Sociale Insieme