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European Remanufacturing Council

ERC

The promotion of remanufacturing and refurbishment as an essential element of industrial policy that defends the EU Single Market.

Lobbying Activity

Response to Circular Economy Act

4 Nov 2025

Since 2015, the remanufacturing and refurbishment sector of the circular economy has enjoyed a period of strong growth, even if some of the product sectors within it have experienced a slower pace of unit growth or even decline (e.g., automotive aftermarket parts, printer cartridges and passenger vehicle tyres). Despite the overall increase in remanufacturing / refurbishment, this remains a fragile activity, representing only 2% or 3% of the equivalent manufacturing activity. This strong growth is due to the attention paid to the topic of sustainability and improved resource efficiency in Europe. Younger customers are now more inclined to search for and buy refurbished and remanufactured products as part of their desire to reduce their environmental impact. Equally, many businesses and public sector organisations are specifying a range of sustainable products, from office furniture to equipment that is owned then leased by third parties. These specialist third parties often extend the life of used products by remanufacturing them for reuse by other customers. The development of many reuse platforms, such as eBay, Vinted, Backmarket, has accelerated market demand. Equally, we have noted that the growth in the (physical) asset management sector appears to promote growth in remanufacturing. Overall, the World Bank expects to see 100 billion in sales of remanufactured products by 2030. We congratulate EU policymakers for their constructive actions to date: investment of more than 100 million in industrial R&D for remanufacture over the past three years through the Horizon programme; numerous free trade agreements which include clauses to enable trade in used products and remanufactured products; the development of the worlds first typology to guide investors; the development of new standards for remanufacture through CENELEC; the work on ecodesign under ESPR; green public procurement advice for the public sector; and the framework for extended producer responsibility programmes. All of these, and other work programme items, have prepared the ground in which remanufacturing and refurbishment have been able to grow. A Circular Economy Act could assist this growth trend. We are confident that businesses will respond by supplying additional remanufactured and refurbished products. We recommend that the following be included in the Circular Economy Act to promote remanufacturing: 1. Use the advantage of the single market to simplify, unify, digitise and scale-up existing and new Extended Producer Responsibility (EPR) programmes. The advantage of EPR programmes is that they consolidate used products and provide reliable data and financial resources to enable investors (and original equipment manufacturers) to investigate investment in value retention processes such as remanufacture. 2. Reform EPR regulations where possible to enable them to use reverse logistics, thereby allowing used products to be collected in a form suitable for reuse and ensure that they are not merely collected to be smashed for material recycling. To improve the efficiency of critical raw material use, it is generally far more effective to keep a product or component in use for longer before eventually directing it to material recycling. 3. Promote an EU wide repairability score for certain categories of new product. Higher-scoring new products attract independent remanufacturing specialists who demonstrate the economic viability of taking the used product as feedstock. 4. Procurement. The excellent work undertaken on GPP (Green Public Procurement) to promote procurement of circular economy products has only sporadically been responsible for increasing demand for remanufactured products. Members report that this may be because the GPP recommendations must first overcome fear of complication and legal challenge as well as inertia in public sector procurement processes. We simply encourage you to persevere. 5. Carbon Accounting (and pricing signal
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Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Meeting with Aurel Ciobanu-Dordea (Director Environment)

12 Jun 2025 · Exchange of views on the ecodesign requirements for printers and cartridges currently under impact assessment

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

12 Jun 2025 · Discussion on the potential of remanufacturing for Europe’s circularity objectives

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

The European Remanufacturing Council represents companies that take-back used products for disassembly within an industrial process, replacing all worn and damaged parts before testing and returning the products to customers, as new, often with an equivalent guarantee. The sector has sales of approximately 30 billion in Europe and we aim to grow this to 100 billion by 2030. Even at 100 billion, remanufacturing, refurbishment, reconditioning and overhaul and maintenance activities represent less than 3% of the maximum technical limit on these value retention processes. We support the intention of the ESPR, building as it does on the success of the previous Ecodesign regulations for electrical products. When considering how to increase remanufacturing in electrical products as well as some of the priority new products, we recommend taking account of the framework of regulations and ecodesign protocols that developed in two sectors. The first, aircraft and truck tyres where a high level of safety, traceability and durability required extensive changes. The second is medical devices where refurbishment activities are regulated for traceability and quality control. We support efforts to improve repairability generally as this tends to increase opportunities for industrial-scale remanufacture. We caution against the assumption that lightweighting is an effective horizontal ecodesign measure for non mobile products. Too often, lightweighting has meant the substitution of durable materials such as steel with lightweight materials that fail prematurely and lead to the disposal of the product. We endorse proposals to include network equipment and software as early priority products and proposals to require companies to adopt standard methodologies such as PEF (Product Environmental Footprints). We support the Ecodesign and Energy Labelling Working Plan 2022-24 and recognise that the ESPR is just one aspect of a very broad push to steer away from the catastrophic failure of policy makers to address the environmental damage caused by shorter product life cycles followed by destruction, sometimes designed to satisfy higher material recycling targets. We will be glad to recommend site visits to plants that currently remanufacture industrial and consumer products as exemplars of how future factories need to be designed. We look forward to the outcome of the Imaging Equipment and Cartridges Ecodesign regulations later in 2023 as a benchmark for what may be possible under the enhanced ESPR. And to encourage everyone that changing the rules and conditions of a market can rapidly improve sustainable outcomes we would point to the unwelcome supply chain disruption of 2020-23. During this time, remanufacturers were in great demand, driven by powerful competitive forces. Change happened very quickly.
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Response to Measures addressing the environmental impact of imaging equipment including consumables

20 Feb 2023

We favour Option 4 and propose a 'landing zone' on which to develop improved environmental outcomes in this highly competitive - and slowly declining market. The European Remanufacturing Council represents businesses that remanufacture and refurbish used products in many sectors but including imaging equipment and cartridges. We represent Original Equipment Manufacturers (OEM) that take back their own cartridges for remanufacture (Lexmark and Brother) as well as independents (ETIRA members) and G.I.T. who use the OEM ink cartridges (and equipment) as their feedstock (cores) for both remanufacture and refilling. The landing zone we have in mind for the consumables (cartridges) is to borrow from the Bosch remanufacturing model for diesel injectors. Bosch approve and license independent remanufacturers to receive (millions) of diesel injectors, Bosch receives a fee and ensures the highest standards and traceability are maintained. We do not propose this as the only option since in this competitive market, several business models are already established. Regulation may, for instance, require those placing cartridges on the single market to either 1. Take back their own cartridges for remanufacture (Lexmark and Brother model). 2. Have in place a system for third parties to do so (Independents model) 3. Use a fill-at-home technology (Epson) or 4. Take back for material recycling (HP) - on the understanding that any energy labelling system will reflect the difference between (1-3) and option (4). This landing zone for discussion might offer, subject to competition and free trade considerations, offer a common advantage to both OEMs and independents. Both groups agree they wish to see the reduction in sales of imported 'clones' i.e. low-price cartridges designed for a single use and reported to be filled, in some cases, with non-compliant toners. These cartridges are winning market share but are designed not to opened for reuse. For imaging equipment, the inclusion of a standard impression counter (similar to a km counter in a vehicle) would aid improved valuation in reuse markets and could enable a minimum use guarantee (instead of or in addition to number of years) in the B2C market. Proposals 1 to 5 appear reasonable at this stage and we confirm that we will continue to contribute to future the Technical Working Group on these topics. In the meantime, we recommend a close examination of the business models operated by those companies that take back both equipment and cartridges for remanufacture into products that become 'better than new' because of their 70% resource savings over an equivalent new product.
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

Aligning Member State interpretation and adoption of the Directive, improving its enforcement, standardising the metrics and definitions are all necessary improvements but they will not be sufficient. Not sufficient because the almost total loss of critical raw materials (CRMs) used in many categories of electronic and some electrical devices that become WEEE is now recognised as having consequences for EU economic security. The 2020 EU study "Critical Raw Materials for Strategic Technologies and Sectors in the EU" provides evidence enough but the urgent shift toward investment in more renewable energy (RePowerEU) since February 2022, implies a renewed focus on asking why we accept the near total loss of CRMs within the WEEE management system. Work by T U Delft is especially noteworthy in this regard. A significant, yet uncertain, quantity of CRMs are required during the manufacture of many categories of electrical and electronic devices. At the end of the useful working life of a device, if collected, the used products are typically fragmentized for material recycling. Meeting the recycling targets is an aim but during the process the effective capture rate for CRMs is Zero. There is for the most part no reason to change since only tiny quantities of CRMs, with an economic value of a few euro cents per device, are used to provide the functionality required. The CRMs are then largely mixed into the melted ferrous and non ferrous streams from which it is practically impossible to recover them. Where they become less accessible than they were in the earths crust, their brief period of usefulness within a device is followed by an accelerated entropy. An alternative approach would be to extend the useful working life of the devices and/or their components. Some products have already implemented systems to achieve this outcome. Aircraft and truck tyres for example, where there is a clear economic driver to do so, but systems of site registration and tyre identification for quality control had to be implemented and agreed through international standards. Trade association ETRMA can provide details of how this was achieved. The WEEE Directive may not, by itself, be an appropriate instrument with which to achieve an outcome in which many more electrical and electronic products have an extended working life through processes such as remanufacture and refurbishment. But as presently framed, the WEEE Directive is not aligning with other instruments in preparation to address the need to make better use of the CRMs in these devices. The single most useful reform would be to adopt a combined recycling and remanufacturing target. Others have argued for separate targets, we disagree. By combining the targets, manufacturers can choose to what extent remanufacturing is achievable for their product category. The certified tonnage of products remanufactured would be counted as equivalent to 5 times the material tonnage collected for recycling. Policy makers would subsequently have the option of changing this ratio to suit future circumstances. We are optimistic about the forthcoming regulatory changes to implement the Circular Economy Action Plan. Equally, we are optimistic about the direction of the proposed Critical Raw Materials Act. The Revised Blue Guide (2022) and developing rules from EFRAG on company reporting for sustainability are equally helpful for those companies involved in remanufacture and refurbishment. We will be glad to work with your technical consultants to expand on our brief contribution here and to direct them to leading companies that are already active in the 30 billion remanufacturing sector in Europe. Our member companies represent many product sectors, mostly for industrial, commercial and health uses but also some consumer-facing products such as imaging equipment and cartridges, personal IT and medical devices. The Conseil europeen de remanufacture is grateful for this opportunity to contribute.
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Response to Promoting sustainability in consumer after-sales

5 Apr 2022

The European Remanufacturing Council represents companies that extend the life of products through industrial-scale processes of remanufacture and refurbishment. 90% of the €30 billion European sales in the sector are in B2B with only 10% in B2C. Expanding the expertise in B2B toward B2C products is going to be necessary for a more circular economy. We are more than ready to contribute to the changed rules and incentives needed to accelerate this transition. In our response, we especially favour Option 3C. In many cases, OEM's smash new products for material recycling when they are returned by customers and retailers. By requiring OEMs (Original Equipment Manufacturers) to invest in processes to remanufacture (repair, test and guarantee at scale) the outcome will be this. The design and manufacture of more repairable products will become a matter of self-interest for an OEM and not, as it is now, an optional social gift.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

The European Remanufacturing Council represents organisations that remanufacture and refurbish products at an industrial scale in Europe. Sales in this sector are valued at approximately €30 billion annually. The sector is a key element of the circular economy as it extends the operational life of products and components. The majority (approximately 90%) of the products remanufactured are in the Business to Business (B2B) sector with only 10% in consumer products. Remanufacturing and refurbishment factories handle many different products, including components for passenger vehicles, trains, aircraft, buses, IT, telecoms and imaging equipment, devices and equipment from the medical, defence, construction and machine tools sectors. Within all these product categories, the electrical equipment is commonly remanufactured and refurbished. It is in the subcategory of electrical products with a longer life cycle (in excess of five years) that there have been negative implications from applying the RoHS Directive. We are supportive of the comments made by COCIR and the observations made by the Critical Raw Materials Alliance. At this stage, we prefer option two and have the following specific proposals: Reforming the provisions for spare parts. The RoHS Directive, first introduced in 2001, has made the use of some warehoused spare parts and some recovered spare parts so complicated that remanufacturing and refurbishment processes have ceased to be economically viable. This effect has been reported most recently by the medical equipment sector in particular, which has been subject to RoHS since 2014. To align RoHS with the Circular Economy, we would encourage the recovery of spare parts for reuse. The reuse could be for either in-situ repair or industrial-scale remanufacture to use in new equipment. Reflecting this, it would be better to designate the recovery of spare parts for reuse and remanufacture as a set rule instead of it being an exception under RoHS. We concur with COCIR in arguing for the following changes: • Exemptions 31a and 47 to be identified as fundamental principles of a circular economy and integrated into article 4.4. The ‘repaired as produced principle’ is reflected in the US standard for remanufacturing RIC- 001. We support the extension of this principle. • Extend article 4.5 to permit the reuse of parts recovered from used machines and subjected to remanufacturing processes in the manufacture of new devices. In most instances, the use of remanufactured components saves between 50% and 70% of CO2 emissions. For some components it also reduces the loss of critical raw materials when compared with practices in which components are placed into metal recycling processes from which the critical raw materials cannot be economically recovered. We are grateful for the opportunity to provide evidence to this consultation and will be glad to participate in further technical workshops on the issue.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

The European Remanufacturing Council welcomes the opportunity to comment on the ‘Evaluation of certain aspects of the New Legislative Framework (Decision No 768/2008/EC and Regulation (EC) No 765/2008) Please see the attached document for our full response.
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Response to Sustainable Products Initiative

16 Nov 2020

The European Remanufacturing Council welcomes the opportunity to provide feedback on the Sustainable Products Initiative. Please see the attached document for our full response.
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Response to A new Circular Economy Action Plan

20 Jan 2020

The European Remanufacturing Council is pleased to offer its comments on the New Circular Economy Action Plan Roadmap on behalf of its member organisations and companies.
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