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European Furniture Industries Confederation

EFIC

The European Furniture Industries Confederation represents furniture manufacturers to ensure favorable policy conditions within the European Union.

Lobbying Activity

European furniture industry calls for harmonised circular economy rules

6 Nov 2025
Topic — This consultation explores legislation to promote sustainable production and circular economic business models.
Message — EFIC requests unified EU rules to prevent a patchwork of national requirements. They want mandatory wood reuse priorities to prevent diversion into energy production. The industry also seeks centralized registration to simplify producer responsibility compliance.123
Why — These measures would reduce administrative burdens and secure wood supplies for manufacturers.45
Impact — Biomass energy producers lose access to wood waste diverted to furniture reuse.6
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Furniture industry urges digital instructions and standardisation reform

3 Sept 2025
Topic — New European rules to align product legislation with the digital age and specifications.
Message — EFIC recommends including the General Product Safety Regulation in the Omnibus IV package. This would allow manufacturers to provide digital assembly instructions instead of paper versions. They also warn that common specifications risk creating redundant and untransparent parallel structures.123
Why — Digitalisation reduces administrative burdens and environmental impact for small furniture manufacturers.45
Impact — European and international businesses lose competitiveness due to technical trade barriers.67
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Furniture Industry Urges CBAM Extension to Steel Products

26 Aug 2025
Topic — The Commission is consulting on extending carbon border taxes to downstream industrial products.
Message — The confederation requests adding metal furniture fittings and high-metal content seating to the regulation. They seek to close loopholes where finished imports currently escape the carbon border tax.12
Why — This expansion would level the playing field by removing the current import cost advantage.3
Impact — Non-EU manufacturers would lose their current exemption from paying carbon taxes on finished goods.4
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Response to EU label on product durability and EU notice on consumers’ legal guarantee rights

28 Jul 2025

The European Furniture sector follows closely initiatives under the European Green Deal aimed at making circular economy the norm and promotes circular design principles and business models based on repair, reuse, refurbishment and remanufacturing. We welcome the opportunity to provide comments to the proposed harmonised label and notice that will be set up in the framework of Directive 2024/825 on Empowering consumers for the green transition. Kindly find attached comments for your consideration.
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European furniture industry urges flexibility in reporting unsold products

10 Jul 2025
Topic — The consultation details how companies must disclose information on discarded unsold consumer products.
Message — EFIC requests flexibility to use estimates when data on discarded products is unavailable. They also call for removing third-party verification requirements to avoid heavy financial burdens.12
Why — Removing verification requirements would save furniture manufacturers from significant and disproportionate administrative costs.3
Impact — Market surveillance authorities lose data precision because companies would be allowed to use estimates.4
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Response to European Affordable Housing Plan

3 Jun 2025

EFIC welcomes the opportunity to contribute to the Commissions public consultation on European affordable housing plan. An affordable home not only meets the basic need for living in sheltered surroundings but also ensures social peace in society. However, the increasing lack of affordable housing in many European countries leads to rising rents, reduces disposable income, divides society, and strengthens political extremities. Please find below some considerations and proposals. - Impacts The above-mentioned issue leads to massive economic downturns and jeopardizes jobs across the entire value chain of construction and housing. According to a DIW, a well-known German consulting company, approximately two million employees and a turnover of around 200 billion euros are directly affected only in Germany. Indirectly, up to four million jobs are at stake. Few industries are as closely connected to everyday life as the furniture industry. The declining of new housing construction burdens the entire value chainfrom building materials, craftsmanship, services, mechanical engineering to furniture, electrical appliances, sanitary objects, and the related trade structures. - Necessary Measures Besides the undisputed need to increase public defense spending, the current political debate emphasizes a significant investment requirement in functioning and modern infrastructure. Beyond bridges, roads, and railways, we believe that an adequate supply of affordable housing also defines infrastructure in Europe. Therefore, specific actions need to be urgently defined and implemented in the very near future. This is also necessary because the creation of a special budget for defense and infrastructure has already impacted bond markets and increased real estate loan costs. - Our Proposals It is obvious that the current shortage of affordable housing cannot be resolved solely through simplification or acceleration of standards and procedures throughout the building process. Additional financial resources and measures are required. We propose: Short-term reduction of construction ancillary costs through a (temporary) reduction or halving of the real estate transfer tax. Bundling of currently fragmented funding programs for building. Introducing targeted and time-limited programs for new buildings. Providing special loans for owners to compensate for the frequent lack of equity capital.
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Furniture industry urges EU to scrap national regulatory barriers

31 Jan 2025
Topic — This consultation seeks to further develop the single market for companies and citizens.
Message — EFIC requests harmonised rules to prevent market fragmentation and reduce administrative burdens on small businesses. They want standardisation to be the backbone of EU rules to ensure competitiveness.12
Why — Uniform rules would reduce production costs by eliminating the need for separate national production lines.34
Impact — National authorities would lose the power to maintain stricter domestic environmental or safety regulations.5
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Confederation of European Paper Industries and

4 Jun 2024 · Discussion on implementation of the EU Deforestation regulation

EFIC urges harmonized rules to reduce furniture industry reporting burdens

1 Dec 2023
Topic — The initiative aims to reduce business reporting requirements by 25% across the EU.
Message — EFIC calls for harmonized European standards for product safety and packaging to replace diverse national rules. They advocate for a centralised EU-registry for waste reporting and longer preparation periods for new regulations.123
Why — Simplified rules would reduce expenses and administrative hurdles for furniture companies trading across borders.4
Impact — Environmental monitoring transparency could decline if geolocation reporting is waived for low-risk regions.5
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EFIC Urges Regulatory Alignment for Green Claims

20 Jul 2023
Topic — This consultation addresses new rules for substantiating environmental claims and labels.
Message — EFIC recommends aligning definitions across EU legislation to ensure a level playing field. They request clearer guidance on scientific evidence and third-party verifier liability. The industry also seeks guaranteed mutual recognition of certificates by national authorities.123
Why — Decreasing legal uncertainties would help companies avoid the risk of not communicating environmental results.45
Impact — Establishing new private schemes would be prohibited unless they provide specific added value.67
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

EFIC, the European Furniture Industries Confederation, is pleased to contribute to this consultation on first priorities under the ESPR. EFIC represents over 70% of the total turnover of the European Furniture Industries, a sector employing 1 million people in about 120.000 enterprises across the EU and generating a turnover of over 100 billion Euros. EFIC is composed of 17 national associations, one individual company member and several clusters. Further information: https://www.efic.eu/ Furniture is well suited for a circular economy and there is potential to drive it further in the industry. There are indeed some opportunities in being identified as a product for potential first action under the ESPR, such as 1) harmonisation and closing regulatory gaps and 2) increased circularity and material efficiency. However, the ESPR focuses on products and a combination of different tools and other legislation is needed to fully close the loop and enable a real transition to the circular economy. While we agree that prioritising furniture is reasonable considering the market size, volumes produced and the potential for a circular economy, in Annex I we are providing comments on JRC findings that in our view do not represent the furniture industry correctly and/or are not substantiated enough. The furniture industry consists largely of SMEs & microenterprises, therefore the performance and information requirements should be manageable for all companies. The furniture range is very diversified, with many furniture types and materials used. Therefore, it would be difficult to have ecodesign requirements applying on a general (horizontal?) level to all products. We believe that some sort of categorisation would be needed within the delegated act, most probably in furniture subgroups. Some requirements may be applicable to many types of furniture whereas others are material-specific or product type-specific. Considering this, the delegated act must allow for a diversity of relevant requirements where the focus should be on the impact objective to be achieved in terms of reduced ecological and climate footprint. Requirements should be set having a holistic approach and from a lifecycle perspective. Any requirement set should not have a negative effect on other important ecodesign criteria or be in contradiction. EFIC experts will be glad to assist and provide sector-specific expertise in all stages (Ecodesign Forum, preparatory study, impact assessment, etc.). Consider also that standardisation committee CEN TC 207 (Furniture) and its WG 10 (Requirements and tools for furniture circularity) has started developing standards for product aspects under article 5 of the ESPR. These standards should be used as a basis or considered in parallel for the development of a delegated act for furniture, and whenever relevant be harmonised at EU level for presumption of conformity. Please see further insights of the furniture industry in the attached position paper (also submitted as an attachment accompanying the consultation questionnaire).
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European furniture industry urges inclusion of new products

3 May 2023
Topic — Defining technical screening criteria for activities contributing to the EU's circular economy taxonomy.
Message — EFIC requests that new furniture designed for longevity be considered a sustainable circular economy activity. They also propose aligning definitions with the Ecodesign for Sustainable Products Regulation.12
Why — The inclusion would help furniture manufacturers attract green capital and ensure a level playing field.34
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Response to Strengthening social dialogue

19 Oct 2022

The Sectoral social dialogue for furniture is an efficient platform, successful in conducting dialogue and debating with Trade Unions in a constructive atmosphere on relevant subjects, and in presenting the issues affecting the labour market and labour conditions in the sector. Many issues are on the Social Dialogue furniture work programme 2020-2024, including industry policy, circular economy & non-toxic environment, skills & education, health and safety. However, on certain occasions, Social Partners face challenges and limitations. EFIC would like to reiterate its position from the consultation of Social Partners on the review of the EU SSD of 16 July 2021. Please find it attached.
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Response to Enabling factors for digital education

16 Sept 2022

EFIC welcomes the possibility to provide feedback on the Commission initiative on ‘’Digital education - enabling factors for success’’. Please find attached our input.
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Response to Sustainable Products Initiative

22 Jun 2022

The European furniture industry is following closely Green Deal initiatives aimed at making circular economy the norm, such as the Sustainable Products Initiative (SPI). As such, building on the EFIC position on the SPI of June 2021, we welcome the possibility to provide our views on the Ecodesign for Sustainable Products Regulation (ESPR) proposal. Please find attached our input.
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Response to Review of the general product safety directive

4 Oct 2021

Please see attached the views of the European Furniture Industries Confederation.
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Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis), Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis) and

17 Sept 2021 · Upcoming Russian export ban on logs

Response to Revision of the Machinery Directive

19 Jul 2021

EFIC, the European Furniture Industries Confederation, welcomes the possibility to provide feedback on the draft Machinery Regulation. Please find attached our input.
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Response to RoHS deleting exemptions for mercury in double-capped linear fluorescent lamps for general lighting purposes

16 Jul 2021

EFIC is the European Furniture Industries Confederation. EFIC notes with surprise that the European Commission proposes in the present draft not to extend the RoHS exemptions for double capped linear fluorescent lamps for general lighting purposes 2(a)(1) - 2 (a)(5). EFIC has also noted that in the framework of the EU Ecodesign Regulation (EU) 2019/2020 for light sources and separate ballasts regarding the future availability of exactly these product types, it has already been decided by the EU Member States and the European Commission that some of these product types must be maintained on the EU market. In Annex II, Table 1 of the (EU) 2019/ 2020, a corresponding timetable for the phase-out of other types has been set. EFIC fundamentally welcomes the transformation of the economy in terms of sustainability, the responsible use of resources and the reduction of pollutants and proactively accompanies the transformation both when it comes to products and production. In companies in the furniture sector, the conversion from fluorescent tube technology to LED technology is already underway and will continue to be implemented step by step. This is despite the fact that, depending on the application (ballast used and switching cycles), current lamps achieve a service life of up to 80,000 hours compared to 18,000 hours for standard versions, and these long service lives have also been proven by measurements. In contrast, corresponding information regarding the service life of light-emitting diode products is often only based on extrapolations (forecasts) and not on measurements (proof). It must also be taken into account that so-called "plug & play replacement tubes with LED technology" are by far not as energy-efficient as appropriately matched complete LED systems. The energetically sensible replacement with the latter units is therefore much more complex and thus also more time- and cost-intensive.   Therefore, these retrofitting measures are usually measures that are planned and implemented in the course of investment plans and also the practical implementation spread over several years. In this respect, EFIC calls on the EU Commission to provide for a correspondingly practical deadline regulation in which this conversion is possible both organisationally (> in many cases the conversion is only possible during a shutdown) and economically (> investment volume). From EFIC's point of view, this is even more important given the context of the coronavirus pandemic and the burdens that companies have faced as a result. EFIC therefore calls on the European Commission to extend the timetable of the exemptions in the present draft directive to the exemptions provided for in the Ecodesign Regulation for lamps - widely used in companies for workplace lighting - and to set a clear timetable for the future of each product type in the sense of planning security. After the adoption of a corresponding delegated directive to amend RoHS Annex III, EFIC believes that a publication would be desirable that shows for each product type which phase-out periods ultimately apply on the basis of which regulations, so that in addition to planning certainty, there is also legal certainty for the coming years. Contact: info@efic.eu
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Response to Micro-credentials

18 Mar 2021

The EFIC input is attached in pdf format.
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Response to Review of the Community Designs Regulation

21 Dec 2020

You will find in attachment the input of the European Furniture Industries Confederation.
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Response to Initiative on adequate minimum wages

18 Dec 2020

The European Furniture Industries Confederation (EFIC) welcomes the opportunity to share views on the proposal for an EU Directive on adequate minimum wages in the EU launched under Art. 154 TFEU. EFIC reiterates that EU actions addressing minimum wages at EU level are not appropriate and that the EU, according to article 153(5) of the TFEU, explicitly and for good reasons lacks competence in the field of remuneration. Please see our complete feedback attached.
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Response to Sustainable Products Initiative

4 Nov 2020

EFIC, the European Furniture Industries Confederation, welcomes the opportunity to provide comments on the inception impact assessment of the upcoming Sustainable Products Initiative. Please see our main considerations below and detailed argumentation in the attached document. A) Need for harmonised circular economy rules at EU level, the involvement of standardisation bodies and harmonised implementation of rules in the EU and globally B) The complexity of furniture should be considered when widening the scope of the Ecodesign Directive and assessing the mix of complementary legislative measures & industry and standardisation bodies should be involved in the process. C) Digital product passports, if designed correctly, have a large potential to channel information among stakeholders. Information to consumers should be provided by various means and green claims should be voluntary. About EFIC: EFIC is the European Furniture Industries Confederation, representing over 70% of the total turnover of the European Furniture Industries, a sector employing 1 million people in about 120.000 enterprises across the EU and generating a turnover of 96 billion Euros. The EFIC membership is composed of 16 national federations and one individual company member: https://www.efic.eu/about-our-members
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Response to Energy labelling omnibus amendment of 2019 regulations

3 Nov 2020

In view of the two ongoing consultations updating EU ecodesign and energy labelling rules, the European Furniture Industries Confederation (EFIC) is hereby providing comments and suggestions to the text of the draft Regulations. Please find our considerations attached.
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Response to Ecodesign omnibus amendment of 2019 regulations

3 Nov 2020

In view of the two ongoing consultations updating EU ecodesign and energy labelling rules, the European Furniture Industries Confederation (EFIC) is hereby providing comments and suggestions to the text of the draft Regulations. Please find our considerations attached.
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Response to Persistent organic pollutants - annex I amendment

8 Sept 2020

Regulation (EU) 2019/1021 does not include a mandatory UTC limit value for Pentachlorophenol (PCP) in Annex I, Part A. As stated by the German Federal Environment Agency in a webinar on the POPs Regulation of 23 June 2020 this means that products with PCP values above the detection limit (>0.05 mg/kg) are currently not allowed to be placed on the market and that there is an urgent need to set a UTC for PCP and to re-establish legal clarity. In the view of EFIC, this legal situation is untenable because it is associated with high legal and financial risks, some of which threaten the existence of companies in the European furniture industry represented by EFIC. In this context, we support the draft delegated act introducing a UTC limit value of 5 mg/kg for PCP. On the basis of measurements carried out by our company members on PCP in particle boards, we see that the proposed limit value of 5mg/kg can be complied with. We also stress the urgency of bringing the delegated legal act into force within the shortest timeframe possible.
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Response to Review of the general product safety directive

1 Sept 2020

The General Product Safety Directive (GPSD) must be adapted to reflect developments in products and markets and to address challenges and shortcomings identified. In light of the review of the Directive, the European Furniture Industries Confederation believe that option 2 or 3 of the Inception Impact Assessment are preferable, consisting of a targeted revision of the Directive or the full revision and repeal of the Directive through the choice of a Regulation, respectively. Please see attached the European Furniture Industries views.
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Response to Empowering the consumer for the green transition

1 Sept 2020

The European furniture industries embrace EU circularity objectives and are already transitioning to and promoting circular business models based on reuse, repair, refurbishment and remanufacturing of products. A true circular economy can only be achieved through collaboration and requires the involvement of many actors, including policy makers, industry, experts, academia and consumers. Without the involvement of consumers, who are becoming more and more demanding, closing the loop will not be possible. The active involvement of consumers will strengthen demand in developing green markets and the green transition will be accelerated. The European furniture industries welcome EU initiatives to empower consumers for the green transition and our industry is interested in a continued dialogue with the EU institutions on the matter. There is a need for a harmonised system at EU level to provide information to consumers on the environmental performance of products. In this context, we believe that option 2 of the inception impact assessment would be the policy option yielding the best results, as it would lead to a more uniform framework, more consistent enforcement by the Member States and Union wide-coordination and harmonisation. Please see attached the views of European furniture industry.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

The European furniture industries embrace EU circularity objectives and are already transitioning to and promoting circular business models based on reuse, repair, refurbishment and remanufacturing of products. A true circular economy can only be achieved through collaboration and requires the involvement of many actors, including policy makers, industry, experts, academia and consumers. Misleading claims on the environmental performance of products can be an obstacle to the development of a true circular economy and comparable and reliable data are needed in this context. When developing policy options to substantiate environmental claims, a number of aspects should be taken into account. See attached input for consideration. EFIC would welcome that the European Commission develops a uniform system to assess the sustainability of furniture, based on criteria that are tangible for the consumer and structured (with regard to the criteria and the corresponding requirements) in such a way that companies are motivated to start using it and can be guided through the transformation process by gradually adapting the criteria and requirements. EFIC and its experts are ready to support the Commission in developing such a system.
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Response to Intellectual Property Action Plan

14 Aug 2020

The European Furniture Industries Confederation welcomes the opportunity to provide comments to the consultation on the Intellectual Property Action Plan. Please see attached our comments.
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Response to Update of concentration limit values of persistent organic pollutants in waste

7 Aug 2020

The European furniture industries embrace the EU Green Deal and circularity objectives and are already transitioning to and promoting circular business models based on reuse, repair, refurbishment and remanufacturing of products. The material wood, which is used in furniture to a large extent alongside other materials, offers one of the most promising bases for success due to its CO2-storing properties. As such, the European furniture industry has a strong interest in the further development of furniture sustainability with a variety of materials used, the processes required for this, and supports corresponding efforts. The European furniture industries welcome initiatives to move towards a zero-pollution ambition for a toxic-free environment, helping to better protect citizens (workers, consumers) and the environment against hazardous chemicals and complementing efforts in the context of the Green Deal and Circular Economy. The announced waste legislation reforms are also welcome, including amending the annexes of the Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs). In this context, the European Furniture Industries Confederation (EFIC) would like to stress the points in the attached letter.
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Response to Trade policy review, including WTO reform initiative

14 Jul 2020

The European Furniture Industries Confederation (EFIC) welcomes the initiative of the European Commission to review the EU’s trade and investment policy and the opportunity to share views on the process. The European furniture industries are strongly oriented towards international trade, which must be open and rules-based. In 2018, the EU (plus Norway, Switzerland and Iceland) accounted for imports of furniture worth $64,059 million and exports worth US$ 63,377 million (data from CSIL World Furniture Outlook of July 2019). International trade creates business opportunities for EU furniture manufacturers and leads to increased competitiveness and the creation of jobs. Please see attached our confederation's input.
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Response to Chemicals strategy for sustainability

18 Jun 2020

Short version below. Longer version attached. The European furniture industries embrace EU circularity objectives and are already transitioning to and promoting circular business models based on reuse, repair, refurbishment and remanufacturing of products. The transition to circularity requires addressing certain challenges already from the production phase. Furniture producers believe in the principles of a circular design, requiring, among others, the responsible use of chemicals of concerns such as hazardous substances. 1. Eliminating toxic substances from design phase It is imperative that toxic substances are removed from the manufacturing cycle from the production phase. This will help to support a cleaner circular economy by enabling more products and materials to be safely reused, repaired, remanufactured or recycled. 2. Holistic approach on circular economy & resource efficiency vs. chemical content • Aligning circular and chemical legislation is key to avoid that they are in contradiction. The current conflict between so-called non-toxic products and the resource-efficient circular economy needs to be addressed. • It is crucial that a coordinated approach is taken at EU level with regard to the classification of hazardous substances and the interface between product, chemical and waste legislation, to avoid that decisions taken at substance level can potentially threaten the circular economy and in particular the recycling of products. • Until the industry has fully transformed from a linear to circular economy there will be a need for transitional regulations based on risk assessment for different product categories to avoid a situation in which reuse and recycling of materials is hampered. A risk-based assessment would be key and the preferred option to address chemical content without hampering circular operations. 3. Traceability of chemicals a. Addressing the interface between product, chemical and waste legislation is of utmost importance. Furniture producers are confronted many times with a lack of information on chemicals from suppliers & stringent Regulations, impacting the traceability of chemicals in products and undermining the future treatment of the material, circular loops and waste disposal. It is imperative to develop intelligent and innovative methodologies to minimise the presence of substances posing problems to health or the environment in recycled materials and to develop practical systems to track information on substances throughout the value chain. b. Enhancing the EU market for secondary raw materials is key to increase the competitiveness of recycled materials and their safety. 4. Evaluating efficacy and safety of chemicals a. Efficacy and safety of chemicals and products should be evaluated throughout the whole lifecycle of products and total value chain, from material sourcing, design, production, distribution, reuse, refurbishment, remanufacturing to recycling. b. Grouping of substances as opposed to the substance-by-substance approach would speed up regulatory action as ECHA has recently found without diminishing the positive impact of a specific assessment. One particular example which would benefit from a grouping approach are toxic flame retardants, 5. Level playing field and equal treatment / market surveillance Third country producers placing products on the EU market must adhere to the same rules as EU producers, to avoid that EU measures promoting circularity and European producers efforts are counteracted by imports of unsustainably produced / non-circular products entering the EU market (especially relevant is compliance with REACH and CLP and the use and tracking of substances of concern). 6. The case of flame retardant free furniture The Alliance for Flame Retardant Free Furniture launched by the European Furniture Industries advocates for the removal of toxic flame retardants from furniture, chemicals that counteract EU circularity objectives.
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Response to Action Plan on the Customs Union

21 Apr 2020

The European Furniture industries are strongly oriented towards international trade. In 2018, the EU (plus Norway, Switzerland and Iceland) accounted for imports of furniture worth $64,059 million (data from CSIL World Furniture Outlook of July 2019). While the European Furniture Industries advocate for free international trade and the removal of trade barriers, trade must be rules-based. As such, imported goods from all over the world should be subject to the same rules as EU products, including those purchased online. Compliance of non-EU products needs to be enforceable and controllable by customs authorities. European furniture products are produced taking into consideration the highest social, safety and environmental standards and they are appreciated and recognised worldwide because of their quality. European furniture manufacturers are also setting the trends for furniture design at global level. Furthermore, our companies are embracing high environmental and sustainability standards, are constantly looking into new business models that promote circular loops such as reuse, remanufacturing, refurbishment and recycling and are actively engaging in the transition to the circular economy, aiming at increasing the lifetime of products through a circular design, the use of more sustainable materials and the reduction of chemicals in the manufacturing cycle. The European furniture industries are facing challenges due to the rising imports of non-compliant products from third countries. Recommendations to protect the competitiveness of European producers: • Custom control effectiveness and risk analysis is key to fight illegitimate trade and to ensure that safe and compliant products enter the EU market. With an appropriate balance between trade facilitation and control, Member States must strengthen their control actions at the EU borders. For this purpose, a consistent and harmonised implementation of the Customs Union rules rules by all Member States is crucial. The same rules and controls must apply to products purchased via e-commerce. • Protection of Intellectual Property Rights must be strongly enforced. Our competitiveness strongly depends on the protection of products with high intangible contents, such us brands, patents, design and copyright as the only effective tool against counterfeiting. • Third country producers placing products on the EU market must provide proof of environmental responsibility, to avoid that EU measures promoting circularity and European producers efforts are counteracted by imports of unsustainably produced / non-circular products entering the EU market (especially relevant is compliance with REACH and CLP and the use and tracking of substances of concern). It is crucial that third country producers importing products in the EU abide by all upcoming EU rules related to circularity (including sustainable product design, information to consumers, etc.). These steps are crucial if the EU is indeed to become a trendsetter at global level when it comes to the transition to a circular economy.
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Response to Illegal logging – evaluation of EU rules (fitness check)

28 Feb 2020

The European Furniture Industries Confederation (EFIC), welcomes EU initiatives aimed at strengthening the fight against illegal logging. Illegal logging is a pervasive problem of major international concern. Forests provide a broad variety of environmental, economic and social benefits essential for humankind, such as maintaining biodiversity and ecosystem functions and protecting the climate. Therefore, they must be well-preserved. While international trade of timber and timber products is a suitable source to cover the growing demand of raw material, legality and sustainability requirements have to be met, and Europe, as a global trading partner, should ensure the full implementation of existing instruments (EUTR & FLEGT Regulations). Regrettably, several wood-based products are not yet in the scope of the Regulation. In particular, extending the coverage to products under the NC Chapter 9401 (e.g. wooden seats) and 4421 (e.g. wooden coffins) would increase the coherence of the EUTR and its overall effectiveness, since other wooden furniture products are already included in the scope. As a consequence, while the first importer of timber (e.g. sawn wood) is under the obligation to implement a due diligence system, the same obligation does not fall on the trader of finished products such as seats, thus increasing the risk of importing illegally logged timber into the EU. EFIC sees the benefits of a wider application of the EUTR, including the following: a) companies would benefit from a higher level playing field among operators, preventing market distortion; b) an increased coherence of the EUTR and its overall effectiveness, since many wood furniture products are already included in the scope but some are still excluded; c) possibly support trans-border actions for confiscation, at least of the Member States’ competent authorities; d) the inclusion of finished products of higher value. Additionally, the experience shared by EFIC members demonstrates a lack of correct implementation of the existing EUTR rules. EFIC therefore calls on the European Commission to coordinate a more consistent enforcement of the EUTR. In particular, there is an urgent need to close existing gaps and harmonise rules. Actions proposed: 1. Define “Appropriate Due Diligence System”: Defining clear criteria for Member States for ‘good due diligence systems’ could remove a lot of the uncertainty. For example, some Member States accept credible certifications as an important part of the necessary due diligence system to fulfil the EUTR, while other Member States do not. In this regard, EFIC advises the European Commission to consider reputable international certification schemes promoting sustainable forestry, such as FSC and PEFC, to play a recognized role as a part of due diligence requirements of all Member States. This would provide a clearer compliance route and save resources, preventing excessive administrative burden for companies and the duplication of risk assessment obligations. If part of the process could be covered by recognised certifications aiming at simplifying the legal procedure, this process should be specified by the European Commission. 2. Align Enforcement Procedures: providing more concrete guidance could remove today’s uncertainties for both operators and authorities to demonstrate compliance. Guidance from the Commission could include a clear description for Member States on the level and depth of information required from operators to prove compliance, influence of credible certification as partial supporting evidence of compliance, and harmonized understanding of what authorities should seek from operators to demonstrate EUTR compliance. 3. Educate authorities to implement such a harmonized approach: operators will only benefit with a correct and uniform implementation of the EUTR.
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Response to A new Circular Economy Action Plan

20 Jan 2020

The circularity of the European Union (EU) economy needs to be increased to preserve the environment and to achieve a climate-neutral continent, by stimulating markets for circular products and services. To this end, the use of resources needs to be optimised to reduce the environmental footprint of the EU economy and the generation of waste. In this context, the European furniture industry welcomes the roadmap on the new Circular Economy Action Plan, part of the European Green Deal, with a focus on initiatives along the lifecycle of products, sustainable product policies, measures to empower consumers, to reduce waste generation, to foster an integrated internal market for secondary raw materials, to tackle the skills needs for the transition to a circular economy and to support companies and SMEs via innovation and investment opportunities. The European furniture industry strongly supports the transition to a circular economy and is ready to be involved in making it a reality. A true circular economy can only be achieved through collaboration and requires the involvement of many actors, including policy makers, industry, experts, academia and consumers. Important to be kept in mind is that there is currently no roadmap to the transition to a circular economy. The furniture industry is however adapting gradually and changing business models, also taking into account the fact that consumers are more and more conscious of the environmental impact of the products they purchase and are becoming more demanding. Circularity is in its early days, much remains to move away from a linear economy, and changes will be seen in the medium/long-term. From a “circularity” point of view, furniture products are complex due to the wide range of materials used in their production (e.g. wood, plastics, textile, steel, glass, composites, foam). EFIC, the European Furniture Industries Confederation, has identified a number of challenges and opportunities linked to the transition to a circular economy, covering the different phases of furniture manufacturing, from the supply of materials to the end of life phase, and is hereby providing sector specific expertise for EU policies on circular economy affecting the furniture sector. The European furniture industries are ready to collaborate with EU institutions to create suitable tools for the sector, enabling the industry to move into the right direction in the transition to a circular economy. Please see attached some more in depth remarks of EFIC, concerning the need for harmonised circular economy rules, certain limits to EU regulatory action, the need for clear definitions and a common language, for a realistic transition, for investment support for companies, as well as for a continuous dialogue with stakeholders and academia. Further input can be found attached regarding value chains, the production phase, including our views regarding Ecodesign, the consumption phase and the waste management phase.
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Response to Review of energy labelling requirements for lighting products

5 Nov 2018

EFIC – the European Furniture Industries Confederation – represents the voice of the jointly united European furniture industries and its registered representative towards the European Institutions. EFIC members are the National federations of European furniture producers in 13-Member States and associated European furniture companies. EFIC represents more than the 70% of the total turnover of the furniture industries in Europe. Recognizing the objectives of the written stakeholders’ consultation and the possibility to submit observations by 6th November 2018, EFIC welcomes the possibility to comment on the proposal. Overall, EFIC welcomes the improvements made to the text. Particularly, EFIC acknowledges that some comments made on the former Energy Labelling Regulation have been considered in the new public proposals published on October 2018. The issues raised particularly concerned: (i) the definition of Containing product and (ii) the packaging informing about energy efficiency class, where there is now possibility to replace the text with a pictogram and also for the text to be displayed once for all light sources. Remaining issues of concern: • Impact Assessment It was produced between March and May 2018, but it has not been made public yet. As a consequence, there is no clear knowledge about the implication of the new regulation, for the obligations were not originally intended for furniture producers. Particularly, this is due to the fact that the furniture sector is not regulated by the framework Directive, but it has been involved in the Delegated Acts (in terms of producer of a containing product). At present, no clear estimation of the impact of the new rules on the furniture industry is known. Therefore, EFIC asks the European Commission to publish as soon as possible the results of its impact assessment. • Extension of obligations and EPREL database From the furniture industries’ side, there is particular concern for the potential extension of obligations originally intended for producers of lighting products, such as on information on performance and compliance, which furniture producers could not equally provide. A particular concern involves the EPREL database. EFIC understands that the EPREL timeline is currently under discussion and will be further clarified by an Implementing Act. However, EFIC wishes to bring to the attention of the European Commission the fact that nearly the totality of furniture companies are SMEs, with the largest share of micro-enterprises. When legally equalising furniture producers (intended as a producer of a containing product) to producers of light sources, the needed distinction should be made in terms of extended obligations. • New requirements EFIC also highlights the importance of ensuring the needed legal certainty to manufacturers: new requirements should only apply to products placed on the market after the entry into force of said requirements. • Timeline for entry into force As for the timeline, a longer timing for implementation would be needed, in order for companies to gain knowledge on how to reach the same quality and functionality of products while meeting the new requirements. In fact, there is a need for a transition period for all dealers to comply without too much rework of existing stock. In most cases, e.g. ecolabel, a transitional period of one year is granted if changes occur. A hypothetic transitional period would be 24 months from entry into force. Moreover, EFIC would like to bring attention to the fact that in some cases it might not be possible to recall furniture already placed on the market, e.g. furniture already in distribution shops. Please, find more information in the attached document.
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Response to Review of energy labelling requirements for lighting products

23 Feb 2018

Please find attached EFIC feedback on the review of ecodesign requirements for lighting products.
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Response to Review of ecodesign requirements for lighting products

23 Feb 2018

Please find attached EFIC feedback on the review of ecodesign requirements for lighting products.
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