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Towards an EU Product Policy Framework contributing to the Circular Economy

Environment

This initiative will examine options and actions for a more coherent policy framework of the different strands of work of EU product policy in their contribution to the circular economy. Product policy has an important role in the transition to the circular economy and is part of the implementation of the Circular Economy Action Plan adopted by the Commission in 2015 (COM(2015)614 final).

Links

Public consultation

ID: 1740

Lobbying Activity

30 responses

Environmental groups demand integrated EU product policy for circular economy

European Environmental Bureau, 31 May 2018

The organization calls for harmonized circular economy criteria across all EU product policy instruments, from minimum Ecodesign requirements to eco-labelling. They want joint preparatory studies covering the same metrics and performance levels for different instruments. They propose extending Ecodesign approaches to non-energy products and creating an EU-wide digital product information system.
This would mainstream circular economy principles across all product regulations and procurement decisions.
Manufacturers in low-cost countries lose if products are designed for durability rather than quick replacement.

Auto industry opposes one-size-fits-all EU circular economy product rules

Association des Constructeurs Européens d'Automobiles, 3 Jun 2018

ACEA demands a sector-specific approach for vehicles, arguing they should be regulated as complete products within dedicated frameworks rather than as collections of parts. They oppose design-for-recycling requirements as obsolete given modern sorting technologies.
This would preserve their existing regulatory framework and avoid new design requirements.
Environmental advocates lose stronger circular economy standards across product categories.

Consultation response

The European Steel Association, 4 Jun 2018

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…

Consultation response

Orgalim – Europe's Technology Industries, 4 Jun 2018

Please see attached Orgalime Position Paper: "Roadmap For EU Product Policy - Creating a Market for Circularity" (4 June 2018)

Consultation response

FoodDrinkEurope, 4 Jun 2018

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…

Consultation response

EUROMETAUX, 4 Jun 2018

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…

Consultation response

Swedish Forest Industries Federation, 4 Jun 2018

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…

Consultation response

SUEZ Group, 4 Jun 2018

Please find attached SUEZ's answer to the Roadmap "Towards an EU Product Policy Framework contributing to the Circular Economy"

Consultation response

APPLiA (Home Appliance Europe), 4 Jun 2018

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.

Consultation response

Zero Waste Europe, 1 Jun 2018

Please find attached ZWE's response to the consultation

Consultation response

Environmental Coalition on Standards, 1 Jun 2018

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…

Consultation response

Plastics Recyclers Europe, 1 Jun 2018

Plastics Recyclers Europe' feedback can be found in the enclosed file.

Consultation response

European Boating Industry, 28 May 2018

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.…

Consultation response

Health & Environment Alliance, 4 Jun 2018

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…

Consultation response

Deutscher Naturschutzring, Dachverband der deutschen Natur-, Tier- und Umweltschutzverbände (DNR) e.V., 29 May 2018

- ‘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…

Consultation response

MOL Hungarian Oil and Gas Company, 4 Jun 2018

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…

Consultation response

FEAD, 4 Jun 2018

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…

Consultation response

ROCKWOOL A/S, 4 Jun 2018

Please see feedback in attached Word file and embedded PDF.

Consultation response

European Container Glass Federation, 4 Jun 2018

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…

Consultation response

TÜV-Verband e. V., 24 May 2018

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…

Consultation response

European Partnership for Energy and the Environment, 4 Jun 2018

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. EPEE, representing the heat pump, cooling and refrigeration industry, welcomes the…

Consultation response

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 24 May 2018

- ‘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…

Consultation response

European Organisation of the Sawmill industry, 4 Jun 2018

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. Through its Member Federations and…

Consultation response

Stichting Changing Markets, 4 Jun 2018

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…

Consultation response

Deutsche Kartuschen Wiederaufbereitungs-Unternehmen, 8 May 2018

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…

Consultation response

REGUPOL Germany GmbH Co KG, 8 May 2018

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…

Consultation response

Verein für Konsumenteninformation, 4 Jun 2018

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…

Consultation response

Detailhandel Nederland, 4 Jun 2018

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'. The…

Consultation response

European Sustainable Phosphorus Platform, 1 Jun 2018

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…

Consultation response

L'ENTE ITALIANO DI ACCREDITAMENTO, 4 Jun 2018

Contributo concordato tra ACCREDIA-L'Ente Italiano di Accreditamento e UNI-Ente Italiano di Normazione I nuovi indirizzi UE sull’economia circolare incentiveranno le produzioni che minimizzano i consumi di risorse riducendo rifiuti e impatto ambientale. Promuoveranno un radicale ripensamento…