Reuse and Recycling European Union Social Enterprises
RREUSE
RREUSE is the European network of social environmental enterprises working on reuse, repair and recycling, representing approximately 110,000 workers and over 150,000 volunteers.
Lobbying Activity
Meeting with Rasmus Nordqvist (Member of the European Parliament)
28 Nov 2025 · Webinar on reuse
RREUSE Urges EU to Unlock Funding for Social Enterprises
15 Oct 2025
Message — RREUSE calls for an Action Plan to simplify complex funding rules for social enterprises. They also recommend a job guarantee scheme and more support for non-formal repair skills training.123
Why — Better funding rules would ensure the survival of social enterprises and their missions.4
Impact — Vulnerable workers lose specific opportunities to gain valuable skills in the circular economy.5
Response to General revision of the General Block Exemption Regulation
3 Oct 2025
The General Block Exemption Regulation (GBER) is crucial for channelling public aid to social enterprises fostering inclusive employment and training in reuse, repair, and recycling sectors. However, the social economy ecosystem, as the European Commission acknowledges, suffers from severe underfunding. Evidence from the French Court of Auditors (2025, attached) further attests to the insufficient public funding levels for the social economy. In 2024, only 7% of total public aid to enterprises was allocated, despite the social economy contributing to 13.7% of private employment creation in France. As such, only 4% of social economy entities received subsidies. The limited state aid in France, a country with some of the strongest EU social economy frameworks, raises grave concerns about the situation in other Member States, especially those with weaker frameworks. Furthermore, RREUSE and its reuse social enterprise members have been sounding the alarm about the ongoing crisis in the second-hand textile ecosystem, which is exacerbated by low investments into the reuse infrastructure in Europe, among other factors. This highlights a need for the GBER reform to bring substantial improvements. Our recommendations aim to refine existing provisions, enabling more targeted support that matches current realities. KEY PROPOSALS FOR THE GBER REFORM: - Extended Support Schemes for Recruitment Aid: We suggest increasing the maximum support duration for recruiting disadvantaged workers to 24 months, and 36 months for severely disadvantaged workers. For older workers, we recommend removing fixed time periods entirely due to their unique challenges to re-enter the labour market. - Broadened Definition of "Disadvantaged Worker": We propose broadening the "disadvantaged worker" definition to include refugees, individuals facing employment barriers due to family reunification, prisoners and ex-convicts, victims of (domestic) violence, people with addiction problems, and LGBTIQ+ workers experiencing systemic disadvantage. We also suggest extending the youth age range from 15-24 to 15-30 to ensure support reaches all those in need. - Increased Fund Coverage for Training: To promote comprehensive training for underrepresented groups, we propose increasing aid intensity to 100% for SMEs training people with disabilities or disadvantaged workers. For larger entities, we recommend an 80% maximum aid intensity for similar training. - Flexible Fund Coverage for Wage Subsidies: We propose a higher aid intensity of up to 75% for severely disadvantaged workers in social economy enterprises to reflect their additional social inclusion costs, while maintaining the 50% baseline for disadvantaged workers and 75% for those with disabilities. - Enhanced Fund Coverage for Assistance Costs: We propose a 75% aid intensity for assistance costs supporting (severely) disadvantaged workers. This covers enhanced supervision, workplace adjustments, and should better target transition support to the mainstream labour market. - Explicit Reference to Reuse Aid: To strengthen legal clarity around aid for reuse, especially for intact products like textiles, electronics, and furniture, we recommend explicitly referencing reuse in the key circular economy dispositions of Article 47. - Clear Definition of Social Enterprise: For clarity and consistent application, we propose adding definitions of social economy and social enterprise to the Regulation, based on Council Recommendation (C/2023/1344), as already integrated into the Waste Framework Directive and European Social Fund Plus Regulation. Our questionnaire responses are specifically designed to elaborate on how the suggestions for the General Block Exemption Regulation can be put into practice. Our primary goal is to demonstrate concrete methods and strategies that will ensure more effective, simple, and comprehensive support for the social economy in the circular economy sector within the GBER framework.
Read full responseMeeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)
29 Sept 2025 · Advancing Sustainable Resource Management with the Circular Economy Act
Response to The new Action Plan on the implementation of the European Pillar of Social Rights
8 Sept 2025
As the EUs largest network of reuse, repair, and recycling social enterprises, RREUSE advocates to ensure the Social Pillar effectively supports inclusive, equitable, and decent employment, access to lifelong learning, and actors whose raison dêtre is to advance social inclusion missions. Since 2021, the Pillar Action Plan has positively strengthened its monitoring process with the adoption of key and enforceable 2030 social headline targets. Such targets can deepen the Pillar's implementation and support the enforcement of its initiatives when adequately monitored. The Action Plan also helped increase visibility and facilitate the implementation of key sub-strategies, notably the Social Economy Action Plan. However, the Social Pillar mustn't remain siloed. While the current Pillar offers high-level social policy recommendations, there is a larger scope to enforce social considerations across legislation, for instance, in environmental legislation, where eco-social innovation across Europe warrants better support. A stronger integration into the European Semester and Country-Specific Recommendations would also further encourage active engagement in the joint effort to implement the Pillar, helping address specific national gaps. RREUSE has the following recommendations for a bold future Social Pillar Action Plan, which can benefit reuse, repair, and recycling social enterprises and their target groups: 1. POLICY INTEGRATION ACROSS DOMAINS Ensure the Pillar Action Plan promotes targeted social economy provisions across critical policy domains, such as environmental, procurement, and competition laws. Align social and green criteria more closely, especially in public procurement. The ongoing review of regulations presents an opportunity to implement integrated socially responsible and green procurement practices. 2. LEGAL AND REGULATORY CLARITY Improve the application of state aid rules, particularly those concerning Services of General Economic Interest (SGEI), to better support social economy actors and their services. Address underutilisation by national authorities and clarify legal ambiguities that exclude service providers linking social inclusion with environmental activities. Uptake Enrico Lettas proposed Action Plan for High-Quality SGIs, which aligns with green ambitions and fosters social services across the EU. 3. EMPLOYMENT AND SOCIAL INCLUSION Create an EU Job Guarantee scheme involving social economy actors and civil society. This would significantly contribute to achieving the 2030 social headline targets, including the one on poverty alleviation that is currently lagging. Strengthen collaboration between the Social Economy Action Plan and upcoming flagship initiatives, such as the EU Anti-Poverty Strategy and the Quality Jobs Roadmap. 4. FUNDING AND STRATEGIC SUPPORT Ensure sufficient funding for the Pillar Action Plan and its strategies, reflected in the upcoming Multiannual Financial Framework (MFF). This financial commitment is essential to support key social policy priorities and enable effective implementation, at a time when other policy priorities risk cutting social spending. 5. GUIDING PRINCIPLES AND STRATEGIC ALIGNMENT Uphold and integrate core Social Pillar principles in future initiatives, especially those relevant to a socially equitable green transition. These include: [Principle 1] Education, training, and lifelong learning; [Principle 3] Equal Opportunities; [Principle 4] Active support to employment; [Principle 17] Inclusion of people with disabilities; [Principle 20] Access to essential services. Additional measures are detailed in the attached document, co-authored by the Social Platform, of which RREUSE is a member and a contributor to the report.
Read full responseRREUSE urges EU to tighten ban on destroying clothes
8 Aug 2025
Topic — EU consultation on defining exceptions to the ban on destroying unsold footwear and apparel.
Message — The organization demands the Commission tighten proposed exemptions to prevent loopholes for wasteful business practices. They specifically oppose allowing destruction based on expired licensing agreements or the presence of brand logos.12
Why — This would prevent social enterprises from being overwhelmed by the costs and logistics of managing overproduced clothing.34
Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)
23 Jul 2025
As the EUs largest network of reuse, repair, and recycling social enterprises, RREUSE welcomes the Commission's initiative to simplify, update, and clarify the SGEI Decision. The 2011 Decision has been crucial in acknowledging our members work integration and social inclusion services for underrepresented groups, which necessitate increased funding due to their public mission, limited or non-profitability models, and higher upfront costs. Despite their potential, the SGEI Decision remains significantly underutilised as a source of support for social economy actors, as highlighted by a growing body of research, including the 2023 EU Commission study on State aid for social enterprises. This underutilisation is confirmed by our network members, who point to several obstacles: restrictive interpretations of SGEI rules, a lack of legal clarity, and limited understanding of social economy entities among authorities. These challenges, as affirmed by the C/2023/1344 Council Recommendation, hinder the full growth and recognition of the social economy. The EU Recommendation also advises Member States to explore how higher SGEI thresholds could better support these services by social economy entities (18 § b & c). The SGEI Decision should update its text to build on the EU Social Economy Action Plans objectives and urgently clarify to Member States that SGEI entrustment to social economy service providers is encouraged and essential to meet the Decision's objectives. Given the excessive reliance on de minimis rules and the underfunding of essential social services throughout Europe, it is also paramount to state that the SGEI Decision is the default Member State instrument financing the social services falling under the Decisions Art. 2 § c. Moreover, some members have been denied SGEI social service financing due to the ecological component in their social service provision. This is despite the inherent link between their environmental and social services: their reuse and repair initiatives are the very tools used to deliver work integration services for individuals facing labour market barriers, provide work-based training, and develop social inclusion activities. Furthermore, their social economy status also obliges them to reinvest any profit back into their social and circular economy missions, underscoring their public mission-driven models, which require adequate recognition and differentiation from for-profit providers. The current revision should thus update Art. 2 § c to reflect the diversity of social service providers across the EU, including those active in solidarity-based reuse, repair, and recycling waste management activities. There should be no ambiguity as to whether public compensation for social service providers is possible when it simultaneously advances essential environmental services, particularly when delivered by limited or non-profit socially driven entities. Such recognition is also warranted as circularity becomes more central to EU policy. It would help clarify the growing consensus that EU state aid rules must reflect modern policy priorities of the Circular Economy Act, Social Economy Action Plan and broader Pillar of Social Rights, and not disrupt social service provisions in key EU circular sectors with high social employment potential. RREUSE sees great potential in the current revision to remedy the ambiguity and litigation risks associated with public compensation granted to social economy entities. This is not just an opportunity to unlock the full potential of mission-driven services that connect environmental ambition with social inclusion on the ground, but also to simplify the implementation of SGEI rules within their intended scope.
Read full responseResponse to Quality Jobs Roadmap
23 Jul 2025
As the EUs largest network of reuse, repair, and recycling social enterprises, RREUSE welcomes the proposed Quality Jobs Roadmap. The initiative is essential to ensuring competitiveness puts people first, supporting the meaningful employment offered by mission-driven actors such as social economy entities. The Roadmaps success is arguably interlinked with that of the Social Economy Action Plan and the upcoming Circular Economy Act, as part of the EUs strategy for sustainable competitiveness and inclusive growth. Many reuse, repair, and recycling social enterprises already deliver on the Roadmaps envisioned Pillars: DECENT WORKING CONDITIONS. Our social enterprises create quality employment and skill development opportunities for underrepresented groups through prioritising reuse and repair activities. Their commitment is also reflected in their engagement with trade unions. For example, our Flemish member HERW!N recently signed a tripartite agreement harmonising social security contributions across sheltered work enterprises. This enabled investments in working conditions and labour agreements, generating more social and circular economy jobs. ACCESS TO TRAINING. Circular social enterprises provide skill-building pathways, particularly for people at risk of poverty or social exclusion, especially via on-the-job training opportunities in key green skills such as repair. Our attached 2023 report offers numerous case studies of their up- and reskilling initiatives. FAIR JOB TRANSITIONS. Social enterprises foster transferable skills and build interpersonal, digital, and confidence-based competencies essential for future employment or education. Their work integration contracts offer tailored support to help participants build experience and social mobility. Despite these successes, gaps remain in promoting quality jobs equitably across the EU. We recommend the Roadmap pushes for robust social conditionalities into core economic and environmental policies, such as public procurement, state aid, and the circular economy. While the Social Economy Action Plan marks progress, social economy entities still lack integration in these frameworks, despite their expertise in a human-centred economy. The Roadmap should therefore actively include them and echo the SEAP objectives to adopt/adapt national social economy strategies. There is also a greater scope to expand universal access to training. The Roadmap should ensure skill development policies, including those from the Union of Skills, better serve underrepresented groups who face barriers to formal educational opportunities due to cost, geography, or caregiving responsibilities. Social economy and circular economy policies must be better aligned with skills initiatives to reach these groups. Finally, more can be done to support transitions from protected to mainstream labour markets after workers participate in social economy employment programs. Our "BuySocCirc" SMP project highlights that inclusive employment quota laws from Croatia and Italy led to increased integration for workers with disabilities, broader workforce diversity, and strengthened B2B collaboration. The Roadmap should encourage Member States to adopt similar inclusive policies so that quality jobs are truly accessible to all. By championing inclusive employment and skill-building pathways, the Quality Jobs Roadmap should help ensure competitiveness is built on a socially just and resilient workforce.
Read full responseResponse to Mid-Term Review: Social Economy Action Plan
2 Jul 2025
The 2021 Action Plan underscores the importance for both targeted interventions and an integrated approach across policies to raise the recognition and visibility of the European social economy. As the largest EU network of reuse, repair, and recycling social enterprises, RREUSE sees the 2023 Council Recommendation on developing social economy framework conditions as one of the most significant SEAP achievements so far. Besides acting as an important catalyst for national SE strategies, the first EU social economy legal act set a key precedent for future policies to capture the dual social and circular mission of reuse and repair social enterprises. Project funding has facilitated additional achievements, including opportunities to foster mutually beneficial private-sector partnerships and to digitise solidarity-based reuse operations. Commission-backed EU-level reports, including one on state aid for social enterprises' inclusive recruitment, have also provided significant evidence of key gaps impeding their full development. Social enterprises active in the circular economy arguably operate in a different scenario since the Plan adoption in 2021. The midterm review marks a timely moment to adjust initiatives in response to three evolving developments: First, solidarity-based reuse operations are today experiencing a dire textile crisis caused by market oversaturation, rising operational costs, and the influx of low-quality items. As the largest product stream, textiles are crucial for revenues to sustain their social missions. Without swift interventions, the second-hand textile ecosystem risks collapsing, threatening reuse social enterprises and inclusive employment. Second, budget cuts further contribute to an uncertain economic outlook, risking derailing vital public funding to cover expenses such as those for the employment and support of underrepresented groups. Lastly, digitalisation continues to gain prominence as a process to generate higher social and environmental impact and ensure relevance as consumer habits change. Members have estimated that 60-70% of all sales will be exclusively online in the next few years, underscoring the need for the social economys goods and services to have a web presence. Members also stressed the need to support the replication of eco-social innovations across the EU through new projects. Examples include supporting social enterprises capacity in preserving raw materials lifespan, or their role as inclusive green skills providers. There is also a larger scope to support skills development by linking social economy support with initiatives that promote the acquisition of circular skills. In addition, the SEAP can play a more enhanced role in guiding national authorities to make better use of state aid and public procurement rules. Namely, some members have lamented that circular activities carried by social enterprises meant they were ineligible for SGEI state aid support. This is despite the fact that their environmental services are inherently connected to the provision of social services, and deserve greater recognition. Future reports and guidelines could highlight societal benefits when social economy actors are recipients of such rules, address restrictive interpretations and simplify processes. Finally, the SEAP should invest in EU-wide awareness campaigns, drawing on best practices such as Belgium's "Acteurs de léconomie sociale"- a Wallonian government-funded, stakeholder-led initiative with strong replication potential. These steps are instrumental in positioning the Social Economy Action Plan as a driver to a circular, inclusive, and socially focused economy. Future SEAP initiatives should build on the current level of ambition and establish a lasting vision beyond 2030.
Read full responseMeeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and European Environmental Bureau and
30 Jun 2025 · Simplification agenda, EPR and waste prevention in WEEE
Meeting with Aurel Ciobanu-Dordea (Director Environment)
11 Jun 2025 · Exchange of views on Circular Economy Act
Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and European Environmental Bureau and Environmental Coalition on Standards
12 May 2025 · Circular Economy
Meeting with Jessika Roswall (Commissioner) and
23 Apr 2025 · Waste Framework Directive (WFD) and extended producer responsibility (EPR) for textiles, Ecodesign for Sustainable Product Regulation (ESPR), Circular Economy Act
Meeting with Brando Benifei (Member of the European Parliament) and European farmers
7 Apr 2025 · Amendments to the public procurement INI Report
Meeting with David Cormand (Member of the European Parliament, Rapporteur)
20 Mar 2025 · New legislative framework
Meeting with Regina Doherty (Member of the European Parliament, Shadow rapporteur for opinion) and EUROPEAN TRADE UNION CONFEDERATION and
18 Mar 2025 · Public Procurement
Response to Evaluation of the Public Procurement Directives
21 Feb 2025
Social enterprises active in reuse, repair, and recycling are key partners for contracting authorities as they contribute to local and socially inclusive green employment through their circular economy waste management activities. Reusing can carry a high job creation potential, higher than recycling, and significantly lowers the environmental impact of items. For example, RREUSE estimates that social enterprises can create 70 local jobs per 1,000 tonnes of items collected with a view of being reused. Social enterprises are also vital in upskilling workers, especially underrepresented groups, by fostering circular, digital, and interpersonal skills. WRAP also found that doubling the lifespan of clothes reduces CO2 emissions from the fashion industry by 44%. However, as Enrico Letta's Single Market report attests, public procurement can play a larger role in supporting social enterprises: - LOWEST-PRICE PREDOMINANCE: Despite the 2014 Directives Art. 70 introduction of voluntary social and environmental considerations, the predominance of the lowest price as the sole criterion systematically excludes social enterprises from competing, as their social and green activities entails higher upfront costs than mainstream businesses. This undermines the potential for public procurement to create public value and restrains entry for SMEs offering socially and environmentally innovative solutions. The Best Price-Quality Ratio criteria should be the default evaluating option for services for the person and the environment. - GREEN AND SOCIAL CONSIDERATIONS ARE SCARCE OR IN SILOS: Since 2014, social circular enterprises lament an increasing danger of losing access to municipalities waste streams due to the novel interest of large businesses in the circular economy. A lack of comprehensive frameworks across the EU that value both social and environmental criteria is one of the obstacles to a level playing field for social enterprises. The Directive hasnt led to much-hoped procurement strategies that match the EU's resilient and fair transition goals through mandatory social and circular criteria tied to enforceable targets (e.g. total work hours for the employment of marginalised groups, rates of reused products in procuring specific items, etc.). - BETTER SCOPE FOR TRANSPOSING AND REINFORCING RESERVED CONTRACTS: We observed a lack of public authorities awareness that the 2014 Directives Art. 20 foresees dispositions to guarantee work integration activities. A better transposition and enforcement of Art. 20 is crucial to guarantee the work of social inclusion actors. Contracting authorities should also be acquainted with social economy concepts. The Spanish RRP presented an encouraging example by mandating 50% of public tenders for the collection, transport, and treatment of key second-hand products to social enterprises under the 2022 Law on Waste and Contaminated Soil for the Circular Economy. - COMPLEXITY OF PROCEDURES: The complexity, length, and scale of procurement processes are challenging for social enterprises with limited resources and experience. Minimum turnover threshold requirements are often out of reach, resulting in a vicious cycle of exclusion from procurement opportunities. Social enterprises may be even subject to extra data and management demands than other SMEs due to a lack of familiarity with their models and the reuse sector. The Directive should better help simplify procurement procedures by reducing administrative burdens, dividing large contracts into smaller lots, and leveraging the role of procurement facilitators to bridge capacity gaps and enable all SMEs to compete. See attached our 2024 research outlining best practices, challenges, and recommendations for better GPP and SRPP across Europe.
Read full responseMeeting with Emmanuelle Maire (Head of Unit Environment)
30 Jan 2025 · Discussion of the critical situation the textile reuse sector in Europe is faced with.
Meeting with David Cormand (Member of the European Parliament)
5 Nov 2024 · Circular Economy Action Plan
Response to ESF+ mid-term evaluation
6 Feb 2024
The European Social Fund+ is a key funding instrument for re-use and repair social enterprises in Europe. On the ground, it supports the RREUSE networks social enterprises in their missions of combating poverty and promoting social inclusion, employment and skills development in the circular economy. Thanks to ESF+, social enterprises like R.U.S.Z. (Austria) set up vocational training for mechatronic engineers who had not completed their primary education. Solidança (Spain) launched a 12-month labour insertion and training programme targeting women suffering from domestic violence and the transgender community. The Employment and Social Innovation strand (EaSI) of ESF+ also plays a foundational role in networks like RREUSE. EaSI enables RREUSE to create indispensable fora to discuss and promote social innovation, policy interventions, and gather data on behalf of its 35 members across 31 countries. In turn, RREUSE supports the EC in implementing key initiatives such as the Social Economy and Circular Economy Action Plans, the Social Pillar, and the 2030 Headline Targets. Amid the mid-term evaluation, RREUSE wishes for ESF+ to build upon its good track record. However, it notes the following recommendations for better social enterprise support: ADDRESS SOCIAL ENTERPRISES' OBSTACLES IN ACCESSING FUNDING FOR BOTH SOCIAL AND ENVIRONMENTAL GOALS. The EU Social Economy Action Plan reports the social economys need to access funds for environmental goals (p.17). As key experts in putting people first in the re-use, repair, and recycling sectors, members note ESF+ should invest in areas such as green jobs adaptation for marginalised groups and align with circular economy objectives. GUARANTEE A FLEXIBLE APPROACH FOR SOCIAL ENTERPRISES TO MEET TARGET GROUP'S NEEDS. The work integration workers within social enterprises come from different backgrounds at risk of social exclusion, with needs that can be difficult to predict. Members stressed ESF+ should have more flexible criteria allowing support for broader target groups. SAFEGUARD SOCIAL ECONOMY'S ACCESS TO EU FUNDING. Social enterprises of the circular economy compete with the private sectors increased interest in circular activities. As their core mission is to pursue social and environmental goals and reinvest any profit into its missions, RREUSE joins other EU networks in calling to earmark at least 10% of relevant EU funding such as ESF+ to ensure a level playing field and long-term support for social economy enterprises. RAISE AWARENESS OF FUNDING OPPORTUNITIES. European networks play a crucial role in knowledge transfer to national social economy actors, including available EU funding opportunities. However, members noted a lack of transparency on ESF+ funding allocation at the national level. The EC's new Social Economy Gateway is a positive step forward for awareness raising that should only be strengthened with more national framework information. BETTER SUPPORT INCLUSIVE SKILLS OPPORTUNITIES. Despite skills being a major ESF+ priority, re-use and repair social enterprises find challenges in accessing support for work-based approaches to circular training. Future skills investments should better recognise informal and non-formal training, which is often more accessible for target groups than formal education opportunities. RREUSE is an independent non-profit organisation representing social enterprises active in the field of re-use, repair and recycling, with 32 members across Europe and the USA. Our main vision is for Europe to support the role of social enterprise in a circular economy, providing meaningful work and training opportunities to thousands of vulnerable members. RREUSEs primary mission is to help tackle poverty, social exclusion and a throwaway culture by promoting policies, best practices and partnerships that support the social enterprises working in environmental services for local and inclusive job creation.
Read full responseResponse to 2014-2020 Ex post evaluation of ESF and YEI
8 Jan 2024
The European Social Fund has been an invaluable tool to guarantee social economy enterprises work for inclusive jobs and training in the circular economy. RREUSE members who were ESF beneficiaries for the 2014-2020 period (e.g. national networks Re-use Austria and AERESS in Spain) addressed the following ESF thematic objectives: promotion of sustainable, quality employment (8), promotion of social inclusion, combating poverty, and discrimination (9), and improving skills and supporting the development of education and training systems (10). Overall, members acknowledge the crucial ESF support for fairer job opportunities and living standards for over 110,000 workers - of which several in work integration programmes - in more than 1,100 social enterprises of the wide RREUSE Network. ESF joins other European Social Fund Plus initiatives - including EaSI - representing a lifeline for social enterprises and their European and national networks crucial role in coordinating, collecting data, and ensuring representation on the policy-making stage. RREUSE encourages ESF to build upon its good track record. However, it notes the following recommendations for better social enterprise support: 1. ADDRESS SOCIAL ENTERPRISES' OBSTACLES IN ACCESSING BOTH SOCIAL AND ENVIRONMENTAL FUNDING OPPORTUNITIES. The EC 2021 Social Economy Action Plan attests social economys need to access funding opportunities for environmental goals (p.17). RREUSE members noted there is a higher scope for ESF to invest in areas such as green jobs adaptation for marginalised groups. As key experts in integrating a human-centered approach in the re-use, repair, and recycling sectors, they emphasise the need to direct social innovation support in the circular economy and align ESF with national circular strategies. 2. GUARANTEE A FLEXIBLE APPROACH FOR SOCIAL ENTERPRISES TO MEET TARGET GROUP'S NEEDS. The work integration workers within social enterprises come from different backgrounds at risk of social exclusion, with needs that can be difficult to predict. Members stressed ESF should have more flexible criteria to reinforce social enterprises expertise in offering tailor-made opportunities to their target groups and offer higher social innovation support. 3. SAFEGUARD SOCIAL ECONOMY's ACCESS TO EU FUNDING. Social enterprises of the circular economy find it increasingly hard to compete with the private sectors increased interest in circular actions. As their core mission is to pursue social and environmental goals and reinvest any profit into their activities, earmarking relevant funding would help ensure a level playing field. RREUSE joins other EU networks in calling to earmark at least 10% of relevant EU funding for social enterprises and other social economy actors in streams such as ESF+, Life, Horizon, and the ERDF. 4. RAISE AWARENESS OF FUNDING OPPORTUNITIES. European networks play a crucial role in knowledge transfer to national social economy actors, including what concerns EU funding opportunities. However, some members stress the limited information on national authorities EU fund management. The EC new Social Economy Gateway is a positive step forward for awareness raising and transparency that should only be strengthened with more national framework information. RREUSE is an independent non-profit organisation representing social enterprises active in the field of re-use, repair and recycling, with 32 members across Europe and the USA. Our main vision is for Europe to support the role of social enterprise in a circular economy, providing meaningful work and training opportunities to thousands of vulnerable members. RREUSEs primary mission is to help tackle poverty, social exclusion and a throwaway culture by promoting policies, best practices and partnerships that support the social enterprises working in environmental services l for local and inclusive job creation.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
21 Nov 2023
PLEASE REFER TO THE ATTACHED DOCUMENT TO ACCESS THE COMPLETE FEEDBACK RREUSE supports the proposed revision of the Waste Framework Directive, recognizing its significance in acknowledging the pivotal role of social enterprises in promoting textile re-use. Social enterprises are key enablers of the transitioning to a circular and sustainable textile value chain, all the while creating local jobs and fostering inclusion for people distanced from the labour market. Nonetheless, further clarification and improvements on certain aspects of the legislation are needed to increase both effectiveness and ambition, especially on provisions linked to upcoming EPR schemes on textiles. Firstly, the text tends to refer to social enterprises as "non-waste operators," despite their accreditation as waste operators. More clarity on this point is needed to create legal certainty for social enterprises involved in textile waste collection and management within EPR schemes. Furthermore, the proposal should provide more guidance about needed the involvement of social enterprises in the decision-making procedures of the EPR schemes. The introduction to the proposal emphasizes the importance of involving social enterprises in the governance of EPR schemes, but this is not reflected in any provision within the legal text, representing a missed opportunity to realise higher environmental and social benefits through the establishment of EPRs for textiles. The EPR fee is also a crucial tool for providing the necessary incentives for a more sustainable textile value chain, but it can also be employed to foster the inclusion of vulnerable people through employment in social enterprises involved in the textile re-use, repair and recycling of textiles. To this end, a portion of the EPR fee should be earmarked to fund training and inclusion activities carried out by social enterprises, on the model of the French "Solidarity Re-use Fund". On the environmental side, strong eco-modulation is a prerequisite to encourage the manufacturing more circular and sustainable textiles. However, the proposal currently excludes certain products from the scope of eco-modulation, thus distortingincentives for circularity, including for product categories with significant sustainability challenges such as footwear and leather. RREUSE believes that all products in the scope of the EPR should also be in the scope of eco-modulation to ensure that the right incentives are in place to design more circular textile products to facilitate collection and management in the context of EPR schemes. Furthermore, encouraging competition between PROs should be avoided to prevent races to the bottom lowering environmental standards, including by reducing the amount of EPR fees. The absence of quantitative targets for prevention and (preparation for) re-use is unfortunately a glaring omission that overlooks the EPs call for such targets, which are already in place in several Member States. Therefore, RREUSE continues to advocate for the establishment of such targets to drive investments and collaboration to increase the circularity of textiles. In conclusion, RREUSE sincerely welcomes this revision of the Waste Framework Directive, but also highlights areas for improvement and anticipates fruitful collaboration with policymakers and stakeholders interested in fostering higher environmental and social responsibility in the circular textile value chain.
Read full responseResponse to Revision of EU rules on textile labelling
26 Sept 2023
RREUSE, the European network of social enterprises active in repair, re-use and recycling, welcomes the intention to review the Textiles Labelling Regulation as an opportunity to ease textile waste management and extend textile products lifetime. Improving rules on fibre composition determination and providing more reliable information to sorters will facilitate the sorting process. The revision should address the issues that affect social enterprises involved in textile sorting and undermine the re-use sectors growth: the high proportion of missing labels, the unreliability of fibre identification rules, the lack of harmonised sizes. At the sorting point, many garment labels are unreadable or missing (62% of EU citizens are estimated to cut their garment labels). Introducing a digital label could be an effective option to deal with this issue, under two conditions: consumers cannot easily remove the label, and the related equipment costs do not burden sorters. Social enterprises should receive financial and operational support through investments in digital and physical infrastructure and training for employees. Additionally, the technology should be interoperable and open-source to keep costs down. 41% of labels indicate the wrong fibre composition: fibre identification rules need to be revised to ensure the labels match the fibre composition. This is essential to facilitate textile waste management, especially in view of the upcoming mandatory separate collection and the resulting increase in collection volumes. Although better fibre identification rules are a prerequisite to automatic sorting and recycling processes development, the revision should, in line with the waste hierarchy, prioritise waste prevention and re-use while ensuring that automated and manual sorting are complementary. Additionally, the revision should introduce a European standardisation of clothing sizes. These should be based on an objective measurement that avoids the usage of terms that can feel discriminatory (S, M, L). Standardised sizes would facilitate the purchase of second-hand clothes and limit the practice of purchasing several sizes of the same items online. It has been estimated that 70% of EU citizens follow care instructions and 86% consider that the label should provide more information on the environmental and social impact of clothing products. The TLR revision could be an opportunity to support the second-hand sector and sustainable consumption behaviours by providing consumers with reliable information on their products circularity performance, and origin, and by supporting upcycling initiatives. The revision should empower consumers to adopt circular behaviour. We encourage the EC to introduce circularity parameters aligned with the waste hierarchy. This should include durability guarantees, as well as repair and end-of-life instructions. The label should also indicate the garments production date and its expected lifetime to track the products durability. Here, we recommend providing information on the expected number of washes after washes after which the product begins to show noticeable wear and tear. The EC should ensure that the introduction of a digital label will be coherent with the DPP, especially with regard to the introduction of sustainability and durability parameters. We encourage the introduction of a single data carrier. Made in claims are misleading. Production stages take place in various countries, but this is not reflected by the current origin labelling. The revision should develop clear criteria for origin claims and require that labels disclose all the countries the product has been through in its production journey. The revision should maintain the exemption from labelling requirements for upcycled products to protect social enterprises. Multiple components used in upcycled pieces and the lack of knowledge about their fibre composition make it very difficult to meet the labelling requirements.
Read full responseResponse to Mid-term evaluation of the LIFE programme 2021-2027
15 Sept 2023
As the only EU programme dedicated to environmental and climate actions, RREUSE believes the LIFE Programme should further reinforce the EU objectives of a socially fair and just green transition. The RREUSE network of social enterprises active in re-use, repair, and recycling activities are an example of actors advancing an inclusive and climate-resilient circular economy. They offer job and training opportunities for vulnerable groups in their green skills workshops, second-hand stores and re-use and repair centers. RREUSE estimates that, on average, a social enterprise creates 70 jobs per 1,000 tonnes collected for its re-use activities, prompting social innovative solutions to tackle unemployment and environmental degradation (https://rreuse.org/job-creation-by-social-enterprises-in-the-re-use-sector/). However, RREUSE highlights the following considerations for the mid-term evaluation of the LIFE Programme: - Social enterprises of the circular economy find obstacles in accessing funding addressing both environmental and social objectives. The Commissions 2021 Communication launching the EU Action Plan on the Social Economy also highlights this issue. The Communication states [social enterprises and other social economy actors] report the need for support to identify and adopt greener practices, build capacity and knowledge, including funding opportunities for environmental goals (p.17). Similarly, RREUSE members stress the need for EU funding streams like the Life Programme to better align with national social and circular economy strategies. The LIFEs sub-programme Circular economy and quality of life should thus ensure support for social and environmental actors like social economy enterprises and help integrate socio-economic considerations into environmental policies and funding. - RREUSE calls for safeguarding access to funding for social economy actors. Alongside other European social economy networks, it proposes to allocate 10% of every relevant fund to social enterprises and other social economy actors across programmes which address circular economy and social inclusion goals such as LIFE, Horizon 2020, Just Transition Fund, Cohesion funds, and European Regional Development Fund. In the current context of rising costs of living and other socio-economic disruptions by the Covid 19 pandemic, the ongoing mid-term revision of the MFF should serve as an opportunity to mobilise the EU Budget for a more Social Europe, including on environmental issues. The 2021 Special Eurobarometer also reveals that nine in ten Europeans (88%) consider a social Europe to be important to them personally (https://europa.eu/eurobarometer/surveys/detail/2266). Thus, funds with a robust green dimension like the Life Programme should play a greater role in supporting an inclusive circular economy. RREUSE is an independent non-profit organisation representing social enterprises active in the field of re-use, repair and recycling, with 32 members across Europe and the USA. Our main vision is for Europe to support the role of social enterprise in a circular economy, providing meaningful work opportunities to thousands of vulnerable members of our community through innovative economic, social and environmentally beneficial activities. RREUSEs primary mission is to help tackle poverty, social exclusion and a throwaway culture by promoting policies, best practices and partnerships that support the professionalism and development of social enterprises working in environmental services with high potential for local and inclusive job creation, notably re-use and repair.
Read full responseMeeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur for opinion)
7 Sept 2023 · Kreislaufwirtschaft für Textilien & internat. Handel (faiwertung)
Response to European Critical Raw Materials Act
30 Jun 2023
RREUSE calls for a Critical Raw Materials Regulation that is based on circular principles and promotes both sufficiency and resource efficiency. This can be achieved by adopting the following circular strategies, in order of importance: - Rethink and reduce: lower the demand for CRMs by promoting systemic change; - Circular design, repair, and re-use: extend the life of products to keep CRMs in use for longer; - Collect and recycle: focus on the separate collection, re-use, and treatment of CRMs, and invest in high-quality recycling to bring them back into circulation. We urge the European Parliament and Council of the EU to link the text of the Critical Raw Materials Act to an EU wide material footprint reduction target, to focus on waste prevention rather than recycling, and to enhance recycled content. The CRM Regulation should focus on the re-use and recovery of secondary raw materials from products and components, while ensuring that CRM value chains meet strict environmental and social requirements. This will ensure the energy transition is climate-proof, material efficient, and socially just. Please find the full position in the paper attached.
Read full responseRREUSE urges EU to prioritize reuse in 2040 climate target
22 Jun 2023
Message — RREUSE advocates for climate targets to prioritize waste prevention and reuse activities over recycling. They propose integrating waste prevention programmes into national climate plans and prioritizing product lifetime extension.123
Why — This shift would boost economic opportunities and job growth for circular social enterprises.4
Impact — Primary resource extractors lose as the economy transitions away from processing natural materials.5
Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and
21 Jun 2023 · Stakeholder meeting on WFD revision
Meeting with Delara Burkhardt (Member of the European Parliament)
15 Jun 2023 · Textiles
Response to Ecodesign for Sustainable Products - Product priorities
11 May 2023
RREUSE welcomes the possibility to give feedback on new product priorities under the upcoming Ecodesign for Sustainable Products Regulation. As an organisation that promotes the reuse and repair of products, we believe that mandatory eco-design requirements can play a key role in reducing waste and minimizing the environmental impact of products throughout their life cycle, while also creating major savings for European households. The recognition of furniture and textiles as the most important priorities for end-use products in the JRC study accompanying the consultation is particularly important for our sector as these are two categories of products with a high reusability potential that can be unlocked through ambitious eco-design legislation, resulting in a positive impact on the environment and significant opportunities for the creation of green and local jobs. However, it is crucial that ICT products are not excluded from the list of priorities to avoid the risk of a big subset of products not being slipping through the cracks between the old working plan and the new one under the ESPR. This would be an enormous missed opportunity to advance regulation for a key value chain that is seeing a proliferation of completely unregulated products with very limited reparability and durability, which are responsible for negative environmental impacts across their whole lifecycle. Furthermore, the lack of regulation represents an important stumbling block for the future of the EUs strategic autonomy due to the inefficient resource management of the Critical Raw Materials contained in such products. Therefore, RREUSE calls on the Commission to prioritise textiles, furniture and ICT products due to their high reusability potential and introduce ambitious mandatory requirements improving durability and reparability of these product categories, involving social enterprises in the consultation process due to their long-lasting expertise in the sector. Please find attached our detailed position.
Read full responseResponse to State aid – revision of rules on exemptions for small compensations to services of general economic interest
9 Jan 2023
RREUSE, the International network representing social enterprises active in re-use, repair and recycling, welcomes the call for evidence on reviewing rules on the Services of general economic interest (SGEI) de minims Regulation. RREUSE and its members call on the European Commission to increase the amount of the SGEI de minimis ceiling, among other things, in light of the current inflation period since the regulation's entry into force more than 10 years prior. Thus, RREUSE joins partners organisations' call for the increase of the threshold further to EUR 800.000 over any period of three fiscal years. Services of general economic interest (SGEI) are often offered by undertakings such as social circular enterprises that act as resilient actors and frontline responders to the different health and socio-economic crises affecting the Union, including the current challenges brought by the cost-of-living crisis and the COVID 19 pandemic. In line with the overarching objectives of the EU Action Plan on the Social Economy (SEAP), a higher and more appropriate ceiling would allow Member States to enjoy better room for manoeuvre to tackle these challenges by supporting the ecosystem. Furthermore, as highlighted by RREUSE during the related call for evidence in July 2022, RREUSE also proposes increasing the de minimis ceiling for up to EUR 1 Million over a period of three fiscal years for those undertakings which, according to their limited profitability nature, reinvest most of their profits and created surplus to carry out their activities for the collective and general interest. At the same time, RREUSE believes that the effective implementation of the (SGEI) de minimis rules must be guaranteed by accompanying capacity-building measures provided to local and regional authorities to navigate such rules characterised by a high level of complexity, and, notably, on raising awareness on their application to support social enterprises and other social economy actors in their activities for social inclusion, inclusive circular transition, and so forth. In line with the initiatives under the EU Social Economy Action Plans, such measures would guarantee a more coherent financial framework adapted to the needs of social economy actors, recognising their vital contributions in responding to the needs of vulnerable citizens and ensuring their upscaling.
Read full responseResponse to European Year of Skills 2023
14 Dec 2022
RREUSE greatly welcomes the Commissions proposal for the 2023 European Year of Skills which also acknowledges the social economys decisive role as a proponent of a socially fair and inclusive twin transition including in the field of upskilling and reskilling. Social enterprises active in re-use, preparation for re-use, and recycling activities such as those of the RREUSE network are historical contributors to key circular activities, providing training and employment opportunities to underprivileged individuals with a low skills baseline. These opportunities allow for acquiring valuable manual skills crucial for an inclusive green transition, some of which are now in scarcity. These include identification, first quality checks, sorting when receiving goods, and dismantling, repairing, and functionality checks during the restoration process. Equally, social enterprises are also active in the digital transition. RREUSE highlights its members promote innovative digital tools in e-commerce, traceability and reporting software. Finally, a key component of work integration programmes and training at social enterprises is to improve psychosocial skills like self-motivation, problem-solving, and teamwork. Such skills are not only necessary for future job prospects but form the basis to develop well-being and facilitate lifelong learning. While the contribution of social circular enterprises in the field of skills is remarkable, RREUSE stresses the momentum brought by the Year of Skills should be capitalised on to strengthen financial and legislative support to their social and circular innovations in the area. The current lack of data on green and digital skills runs counter to the even development of the ecosystem, which might struggle to efficiently communicate its impact, share best practices among the community or attract investors. More opportunities for collective engagement, including with the private sector, are needed alongside funding opportunities for social and environmental goals. To foster a mindset of inclusive upskilling and reskilling, RREUSE calls for the Year of Skills agenda to be comprehensive of the following actions: - Raising awareness on available European and national funding opportunities to support the upskilling and reskilling work of social economy actors, including under the EU Skills Agenda and Transition Pathway for the Social Economy. - Designing ad hoc events for social economy actors in the area of skills across the EU. Such events can include networking sessions with philanthropies, microfinance investors, and national authorities, aimed at enhancing the visibility of the ecosystem, mutual learning, and sharing of best innovative social and circular practices. Some of the content could touch upon engagements with the private sector in the area of skills or strengthening the role of facilitators to ease access to procurement opportunities. - Addressing the lack of data on skills, which is particularly pressing in regard to skills necessary for a circular economy. The upcoming single-entry point website, the EU Social Economy Gateway, as part of the Action Plan on the Social Economy, should facilitate the dissemination of relevant publications from social economy networks and institutions. The future RREUSE 2023 report on circular skills can provide additional evidence-based data on the contribution social enterprises provide. - Fostering the development and recognition of training and skills qualifications, with more harmonising rules. This is crucially needed to accelerate and professionalise circular skills development and, therefore, prevent a skills gap that could potentially slow down the transition to a circular economy. - Promoting initiatives to adapt academic curricula to reflect green social entrepreneurship concepts, including social economy business models addressing re-use employment potential in the circular economy, climate change, and other environment-related issues.
Read full responseResponse to Evaluation of the 2012 Directive on waste from electrical and electronic equipment
2 Nov 2022
RREUSE welcomes the possibility to provide input for the evaluation of the WEEE Directive. The WEEE Directive has been an important first step towards increasing the circularity of electronics, but the directive must be updated to reflect increasing quantity of electronic waste and improved by focusing on ensuring correct implementation across member states and on some key aspects. Firstly, EPRs tend to favour material recycling over reuse and preparation for reuse, resulting in suboptimal environmental benefits and less job creation potential, while also directly contradicting the waste hierarchy and the aims of the Directive. The most effective way to solve this issue is to set quantitative reuse and preparation for re-use targets to ensure that incentives are aligned with the waste hierarchy. Eco-modulation of the EPR fee should also be designed to encourage re-use and preparation for re-use before recycling. It is also important that EPR schemes established under the Directive are compliant with the minimum requirements set in Art. 8a of the WFD to ensure the involvement of all stakeholders in the development, governance and functioning of these schemes. Waste prevention aspects should also be addressed by ensuring high ambition in relevant product legislation such as Ecodesign and Right to Repair. Secondly, collection should be improved with a view of safeguarding the reusability of goods, preventing damaging potentially reusable items. Relevant stakeholders, including social enterprises, should be consulted on what technical aspects of separate collection of WEEE should be enhanced in a future revision. Thirdly, accredited operators should be granted access to the waste stream in accordance with Art. 6 of the Directive, which is often not the case, especially regarding takeback schemes operated by distributors who tend to have the highest quality of WEEE and thus the highest reuse potential. Finally, there are also legal barriers hampering the reusability of WEEE. The most important one is the lack of a clear end-of-waste criteria for WEEE that has been prepared for reuse. Accredited operators should be allowed to declare whether an item has reached its end-of-waste status after passing a rigorous examination procedure, similar to what is prescribed by the Austrian end-of-waste criteria. Therefore, a potential revision of the WEEE directive should be conducive to the correct application of the waste hierarchy by: - Setting up a quantitative target for preparation for re-use, separate from recycling Improving separate collection with a view of facilitating preparation for re-use by using standard EN50614 as a baseline to integrate relevant provisions in EU legislation - Ensuring that the implementation of EPR schemes is conducive to the directives aims by guaranteeing the involvement of all stakeholders and aligning economic incentives with the waste hierarchy - Granting access to the waste stream for accredited reuse operators and supporting the establishment of national reuse networks - Considering waste prevention aspects by strengthening the durability and reparability of EEEs in other relevant EU legislation - Establishing clear guidelines to determine the end-of-waste status of WEEEs that have been prepared for re-use Please see the attached document for more detailed feedback.
Read full responseResponse to Strengthening social dialogue
19 Oct 2022
As the international network of reuse, repairing and recycling social enterprises promoting the social and circular economies, the RREUSE network has a long tradition of contributing to the implementation of the principles of the Pillar, including the following:
- Education, training, and lifelong learning (1),
- Equal opportunities (3),
- Active support to employment (4),
- Inclusion of People with Disabilities (17).
Additionally, circular social enterprises and other social economy actors are central actors in the proximity economy, contributing to local green job creation and strengthening social cohesion in the communities where they reside. In this regard, the national networks of social enterprises play a crucial role to ensure social dialogue with national administrations, making sure they are aware of key features and challenges of local actors and that national policy frameworks are adapted to their needs.
RREUSE welcomes the upcoming initiative for a well-functioning Pillar. However, social dialogue at the European level is stronger if the one at the national level is first properly supported. The EC Communication and proposal for a Council Recommendation stemming from this initiative should then encourage the Member States to increase support towards national networks of social enterprises for better social dialogue, in line with the goals of the 2023 Council Recommendation for Framework Conditions under the Social Economy Action Plan. In fact, national networks of social enterprises often rely on funds coming from project-based activities and lack a funding mechanism to sustainably provide resources to engage with national administrations and in turn represent the interests of local and regional actors. Therefore, RREUSE believes operational funding - whether in the shape of successful programmes such EaSi or co-financed by ESF+ in cooperation with relevant ministries - should be stressed to provide a steady contribution to reinforcing their capacity to partake in social dialogue at the national level and fostering the implementation of the principles of the Pillar.
Taking into consideration the variety and contextual specificities of activities associated with reuse, social enterprises of the RREUSE network create between 20 and 140 jobs per 1,000 tonnes collected with a view of being reused. This on average translates to a social enterprise creating 70 jobs per the same amount collected. Equally, circular social enterprises provide green skills and lifelong learning opportunities for low-skilled underprivileged categories, such as in sorting, collecting, as well as restoration skills, including extending the life cycle of products via repairing. While their contribution to implementing the Pillar is noteworthy, sustainable access to funds is key to upscale their impact.
In addition to funding, RREUSE believes the EC should encourage the Member States to further strengthen social dialogue by ensuring the involvement of social partners when designing and implementing the National Reform Programmes NRPs of the European Semester (ES). The ES can be an important instrument to monitor the measures provided in support of the actors contributing to the implementation of the Pillar and, in this context, to support the ecosystem via measures that mainstream further links between the social and circular economies in their NRPs. Equally, encouraging that environmental, social, and economic dimensions underpin the NRPs in terms of short-term and long-term policy goals is key to achieving the objectives of the Pillar in line with the goals of a green transition that leaves no one behind.
Read full responseResponse to Developing social economy framework conditions
29 Sept 2022
RREUSE welcomes the initiative and calls on the Commission to ensure the Council Recommendation sends a clear message to Member States to promote a better national framework in support of the actors of the social economy, including social enterprises active in reuse, repairing, and recycling waste management activities. RREUSE highlights that, taking into consideration the different contexts of activities associated with reuse, its members can create on average 70 jobs for 1,000 tonnes of goods collected with a view of being reused, rising to 140 per 1,000 tonnes depending on the nature of the product (RREUSE report on job creation attached). Additionally, as of 2019, the social enterprises under the RREUSE network extended the lifespan of 214.500 tonnes of products, compensating for the average CO2 emissions of approximately 107.107 EU citizens.
While there is striking evidence of the transversal contribution of social enterprises, the support towards the sector - be it legislative or financial - vastly differs across Member States, impeding access to upscaling opportunities and increased societal impact. As a result, social enterprises struggle to access funding at the national level or, paradoxically, to be officially recognised by authorities if their target group extend to more categories of vulnerable persons, or yet, fall under the same taxation regimes as for-profit companies despite their core social and environmental mission and limited profitability.
RREUSE believes the Council recommendation should give an unambiguous impetus to Member States to design targeted national strategies for social economy actors. It is today more relevant than ever as social enterprises provide resilient solutions to the multiple crises affecting the Union by putting people first. As such, environmental policy design should be intrinsic to a social dimension, for instance, by introducing targets for local employment creation. Especially, RREUSE calls on the EC to ensure the proposal stresses the urgency of setting up single entry-point mechanisms within national administrations to ensure dialogue with social economy stakeholders, increased transparency, and promote the opportunities under the Social Economy Action Plan and relevant frameworks, such as joint-actions with circular policy files.
In light of the updated EU VAT Directive and the new social and environmental clauses therein laying out new grounds for reductions, the Council recommendation must also encourage Member states to adopt more favourable taxation in support of social economy actors as contributors to social cohesion and environmental protection. Furthermore, national public procurement rules should make social and green criteria mandatory whenever possible to push forward an inclusive green transition. Equally, social entrepreneurship should be promoted, for instance via R&D, to support the inclusive circular innovations of social enterprises as well as partnerships with municipalities and mainstream businesses.
Finally, social enterprises active in the circular economy require flexible labour market policies to accommodate the evolving scenarios deriving from circular business models. As such, more synergies between labour market integration policies and support for social enterprises are needed to allow them upscaling, for instance, by allowing better wage subsidy schemes for the people they work with or sustained flexibility to innovate for better environmental outcomes.
The EC's proposal for a Council Recommendation should ensure EU countries effectively implement the goals and initiatives of the Social Economy Action Plan at the national and local levels while mainstreaming the social economy within the circular and other policy areas mentioned above. RREUSE calls on the EC to ensure the proposal is unequivocal on the urgency to set better national frameworks for the even and successful implementation of the Social Economy Action Plan across the EU.
Read full responseResponse to Review of the de minimis aid Regulation
22 Jul 2022
RREUSE, in accordance with ENSIE, proposes adding another exception to Article 1 of the De Minimis Regulation 1407/2013/EU:
“aid granted to work integration social enterprises (defined as sheltered workshops and economic operators whose main aim is the social and professional integration of disabled or disadvantaged persons or may provide for such contracts to be performed in the context of sheltered employment programmes, provided that at least 30 % of the employees of those workshops, economic operators or programmes are people with disabilities or disadvantaged workers according to the articles 2 and 20 of the EU Public Procurement Directive 2014/24).
In this framework, the total amount of de minimis aid granted by a Member State must be proportional to the size of the social enterprise: a percentage in relation to the number of workers in the enterprise with a minimum ceiling of EUR 200 000 and a maximum ceiling of EUR 1 million over a period of three fiscal years.”
With this proposal, RREUSE joins partner organizations’ call to advocate for the development of the job creation potential brought by work integration social enterprises. In fact, the more jobs are created by social enterprises, the higher the amount of de minimis aid that should be allowed in order to increase their social impact (and consequently, to increase the environmental and circular impact of social enterprises involved in reuse, repair, and recycling such as those that form the RREUSE network).
RREUSE believes that “the imposition'' of the same ceiling scheme as the one applicable to mainstream businesses is a discouraging approach that does not take into consideration the nature of limited profitability of the non-profit entities and the distribution of the created surplus towards actors other than shareholders that characterize the scope of economic activity of work integration social enterprises. In addition, the current ceiling scheme does not take into account the local/national dimension of their economic activities which does not provide the same risks of distorting the functioning of the internal market. Knowing that their economic activities remain at a national if not at a local level, the potential competitive advantage caused by the suggested new de minimis aid scheme would not have a significant impact at the EU level and on other businesses operating a comparable economic activity. For instance, some members estimate that creating a new refurbishing workshop alone can have a current cost much higher than EUR 200 000, while typically representing a local activity.
Thus, the EU must not penalise medium and large work integration social enterprises whose true nature is to fulfill inclusive and fair objectives with their activities, for instance, by creating green jobs for vulnerable categories of people for the sake of an inclusive circular transition. A different and proportional approach, as advanced by RREUSE and partner organizations such as ENSIE, would appear more fit for the reality of non-mainstream European undertakings such as social enterprises.
Read full responseResponse to Sustainable Products Initiative
17 Jun 2022
RREUSE welcomes the revision of the Ecodesign Directive through the Sustainable Products Initiative (SPI) as a major opportunity to enhance product sustainability and to pave the way for a transition towards sustainability within European markets. We strongly defend the need to take eco-design seriously across all products placed on the European market. In this regard, the SPI should keep an inclusive vision of the products to tackle and include not only energy using and related products but also broader categories of products such as textiles and furniture.
We particularly recognize and appreciate the following initiative’s outcomes: implementing eco-design and information requirements to improve products’ sustainability, promoting the right to repair, and exploring new circular business models.
However, the initiative should introduce strong and clear targets in order to be effective. Action on eco-design must be combined with enhancing options for re-use and repair that ultimately lead to reduced consumption of products and materials. Eco-design alone will not solve our unsustainable consumption levels. This is why both the information and eco-design requirements should lead not only to a more sustainable production of goods, but to a concrete phase-out of unsustainable products.
Therefore, we would like to address several elements that seem to be lacking in the actual regulation but are necessary to adopt ambitious policies. In this regard, RREUSE’s call to the Commission will focus on the following elements:
- Ensure a proper and inclusive implementation of information requirement with a strong assessment of the information provided;
- Deploy inclusive and convenient eco-design requirement, including fit-for-repair criteria;
- Tackle and reduce the overall production;
- Implement measures to foster the repair and re-use sector.
Read full responseMeeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders) and European Environmental Bureau and
22 Mar 2022 · Corporate Sustainability Due Diligence
Response to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
Even though updated not so long ago, the revision of the Waste Framework Directive is highly welcome as the strategy devised in the new Circular Economy Action Plan requires a shift to a better implementation of the waste hierarchy. Indeed, the current waste prevention and preparing for re-use provisions are not concrete enough to lead Member States towards an absolute decrease in waste generation.
With the recent publication of a Social Economy Action Plan and a clear reference to the link between a social and a circular economy, reopening the revision of the WFD is also a great opportunity to reinforce the role that social economy enterprises have in the collection and treatment of waste.
To improve the management of waste in the EU, both socially and environmentally speaking, RREUSE advises the Commission to make the following amendments to the WFD:
• Targets on waste prevention must be devised in absolute terms, not in relative percentages. Therefore, RREUSE supports Zero Waste Europe's call for replacing the WFD 10% landfill target with 120 kilograms of residual waste per year per capita by 2030. On top of that, the Commission must accelerate the development of re-use and/or preparing for re-use targets at EU level. At the moment, the WFD only contains promises from the Commission to look into the feasibility of setting such targets by 2025. There is no doubt now that these targets are feasible as many examples (in Flanders, Spain and soon in France and Wallonia) already exist and have positive impacts.
• Every waste collection model (e.g. door-to-door collection, civic amenity sites, deposit-refund schemes, etc.) must be designed to collect re-usable waste separately. Therefore, article 11.1§1 WFD on facilitating access to the waste stream for preparing for re-use and repair networks shall be expanded. It should include concrete minimum requirements on how waste collection models must be set up to make the separate collection of re-useable items happen at the earliest stage possible, hence safeguarding their re-usability.
• Support for re-use and preparing for re-use networks to set up alternative collection models for re-usable products. Partnerships between local authorities/producer responsibility organisations and social economy enterprises for the collection of re-usable products are essential to achieve that objective. Re-use operators, especially if they are social economy enterprises and participating in the inclusion of disadvantaged groups on the job market, should not have to pay to deposit donation containers. They should actually be remunerated for participating in the achievement of EU's waste prevention targets and allowed to install containers in diverse public spaces (city halls, supermarkets, administration offices, private offices, etc.).
• Reinforce minimum requirements for Extended Producer Responsibility. Producer Responsibility Organisations must also reach concrete waste prevention and re-use targets. For more information on this topic, please refer to the following position paper: https://bit.ly/3LO1Gsq
• Support EU citizens to help them find out where and how to discard their unwanted yet re-usable items appropriately. Financing the development of mapping applications can be helpful in that regard.
• Prevent the use of counter-productive collection models. The rewarding schemes developed by certain operators (mainly retailers) to collect waste items must be supervised to ensure they do not encourage the consumption of new items (Ex: Textiles retailers giving €5 vouchers for new clothes to clients bringing back waste textiles). If discarders are rewarded, they should be paid cash, not with vouchers. It must also be clear that retailers participating in the collection of waste also have to respect re-use targets and implement the waste hierarchy.
Read full responseMeeting with Virginijus Sinkevičius (Commissioner) and
10 Jan 2022 · To discuss the role of social value in the circular economy and the contribution of the social economy to sustainable growth and jobs creation, including in local communities
Response to Social and labour aspects of the climate transition
18 Nov 2021
RREUSE is a network of social enterprises active in re-use, repair and recycling. In 2019, social enterprises federated by RREUSE generated between 20 and 140 jobs per 1,000 tonnes of products handled and valorised for re-use oriented activities, with the majority creating between 40 and 100 jobs per 1,000 tonnes. They have also extended the lifespan of 214.500 tonnes of products, counterbalancing the average CO2 emissions of approximately 107.100 EU citizens in 2019 (calculated via AERESS's CO2 calculator and in relation to Eurostat's
greenhouse gas emissions per capita). Given that RREUSE represents 105.000 employees, volunteers and trainees, it is evident that RREUSE achieved carbon neutrality by offsetting the average CO2 footprint of all individuals engaged in its activities.
The transition towards climate neutrality will result in the necessary disappearance of certain industrial activities. History shows that these transitions often result in long-term unemployment for people whose skills become obsolete. It will be of paramount importance to use the new Social Climate Fund to not only cover the surging costs of energy but also to finance training opportunities for people who lose their jobs during this energy transition. Social enterprises active in re-use, repair and recycling can be valuable partners for the development of training programs and for giving job opportunities to those who might be left behind. Reinforcing the link between the Fit for 55 package and other broad policy packages such as the Circular Economy Action Plan or the forthcoming Social Economy Action Plan is, therefore, necessary. To adopt an even more holistic approach, switching from a theoretically unlimited growth to a well-being society would also solve some of the social issues that might result from the green transition.
Concerning the prime objectives of the Social Climate Fund, which is to "finance temporary direct income support for vulnerable households" and "to support measures and investments that reduce emissions in road transport and buildings sectors", social enterprises can also be reliable partners. A perfect example is Herw!n who developed the "Energy Cutters" project to teach vulnerable households to save energy and reduce their energy bills, hence turning the energy transition into an economic opportunity rather than an additional financial pressure. However, RREUSE insists that the energy transition should not be used as an excuse to replace so-called "energy-guzzling" products if it is not demonstrated that replacing functional but less energy-efficient products with new ones (deemed as more energy efficient) is actually helping households to save money. The price of new products and the resources and energy needed to build them often counterbalance the positive effects of their energy efficiency. The green transition should not be reduced to the energy bill received at the end of the month as energy is also used for the manufacturing of new products. Instead, extending the lifetime of products through re-use and repair activities should be viewed as one of the most efficient tools of the transition towards a fair and green transition, especially when these activities are conducted by social enterprises providing meaningful, formative, local and green jobs to disadvantaged groups.
In the attached document, you will find more information on job creation in the social re-use sector.
Read full responseMeeting with Alice Kuhnke (Member of the European Parliament) and European Environmental Bureau
12 Jul 2021 · Civil Society Shadow Strategy for Fair and Sustainable Textiles (staff level)
Response to Ecodesign and energy labelling working plan 2020-2024
28 May 2021
The ecodesign and energy labelling policies have enabled achieving a quarter of the EU’s emission reduction targets to date and nearly half of the EU’s 2020 energy savings. These policies have the potential to significantly contribute to the Green Deal, bringing important GHG emission reductions but only if they are used to their full capability and level of ambition. This is currently not the case: chronic delays are hampering the successful implementation of this policy, as highlighted by the European Court of Auditors in January 2020 and evidenced by the timing for the adoption of this Working Plan. The plan is supposed to cover the period 2020-2024 but it will probably not be adopted before the end of 2021, with a two-year delay. The measures included in the previous Working Plan (2016-2019) are also delayed, and not a single new implementing measure has been adopted since the Von der Leyen Commission took office 1.5 years ago. Such delays are unacceptable, the Commission should urgently prioritise this file within its services and dedicate adequate human resources to the development of product measures.
The climate and environmental emergency must mean that all potential energy, CO2 emission and material savings are reaped as early as possible. The prioritisation exercise between the introduction of new regulations and the reviews of existing regulation proposed in the roadmap is therefore not acceptable and not justifiable by the lack of resources within the Commission to correctly implement the policy. Timely revision of existing regulations is responsibility of the legislator, and so is to assess the adequacy of setting new legal requirements for other products in view of achieving the climate objectives the Commission has committed to.
The Working Plan should also clearly set out the timetable for each measure: the current lack of clear timing and prioritisation has led to a substantial accumulation of draft measures that have not been presented or concluded and have significantly stymied the achievement of product policy objectives to date.
Regarding the preparatory study for the Working Plan 2020-2024 in particular, we strongly recommend to only consider science-based and objective evidence in the selection process leading to the establishment of a shortlist. The proposed shortlist was developed ‘in a dialogue/in agreement with the European Commission’ (Task 4 report). While we understand the need for some pragmatism, political aspects should not be considered at this preparatory stage; we insist on the importance of transparency and objectivity being main drivers for the technical assessment of the product selection.
Looking at the savings potential and the expected development of certain products and technologies, we propose an alternative shortlist, keeping the majority of the products selected by the study team but introducing four crucial product groups that have been discarded despite their environmental relevance: base stations, electric vehicles chargers, universal batteries and heaters for outdoor spaces. Find the reasoning and full alternative shortlist proposal in the position paper attached.
Furthermore, we strongly believe that the Working Plan should foresee the development of horizontal material efficiency requirements for a broader set of energy-related products. This should lead to the introduction of repairability requirements for an enlarged set of household electrical appliances, by means of an overarching regulation similarly to the existing one on standby energy consumption – in line with the Commission’s ambition to progressively make sustainable products the norm and the forthcoming Sustainable Products Initiative.
Finally, the Working Plan should aim at reinforcing market surveillance to ensure the forecasted savings are achieved. The possibility to extend the use of the EPREL database to products without an energy label could be explored should it prove to facilitate the work of MSAs.
Read full responseMeeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)
5 May 2021 · Implementation of the EU Circular Economy Action Plan, including its social dimension
Response to Social Economy Action Plan
23 Apr 2021
RREUSE contributions to the SEAP Roadmap: Achieving a fair and inclusive circular transition through the EU Social Economy Action Plan
COVID-19 pandemic has further exacerbated the existing inequalities and barriers for achieving social Europe.
RREUSE welcomes the European Commission’s timely roadmap proposal to develop a favourable policy environment for social economy actors, including social enterprises and calls for an ambitious Social Economy Action Plan (SEAP) that would provide a policy toolbox enabling a green, fair and circular transition in the post-COVID economic recovery.
The SEAP’s effectiveness relies on the intrinsic link between the social and circular economies, creating opportunities for new partnerships between social enterprises and the public and private sectors along different value chains. Social enterprises — operators in the social economy whose primary objective is to have a social, societal or environmental impact over profit — should be at the Action Plan’s epicentre. Their transversal nature ideally posits them to deliver crosscutting social, circular and digital objectives, paving the way for a future economy that works for people and the environment. In order to establish a sustainable EU socio-economic environment and maximise the SEAP’s potential, RREUSE seeks to put forward the following recommendations on four priority areas:
1. Mainstream the social economy within circular policies and beyond
2. Recognise the real value of social enterprises active in the circular economy
3. Improve access to funding for social enterprises
4. Acknowledge social enterprises’ role in skilling and upskilling to meet changing market needs.
These recommendations are further elaborated in our policy paper, which has been published on 12 March (please find in the attachment file):
In addition, alongside our policy paper, we would like to emphasise two other aspects fundamental for the Social Economy Action Plans implementation:
Monitoring: the implementation of the SEAP action should be underpinned by an effective monitoring method to track the progress of developing the social economy across the EU. In addition, an enhanced dialogue between social enterprises and other social economy actors and the public institutions at the national and the European level should be the cornerstone of this.
Ensuring quality jobs and well-being in the social economy: Social enterprises active in the circular economy offer an untapped job creation potential and inclusion opportunities for the vulnerable groups. Please find our briefing on jobs which was published on 13 April, as an additional contribution to the social economy roadmap (please find in the attachment file). However, RREUSE believes that it is fundamental to ensure that jobs created in the social and circular economy intersections are quality jobs that adhere to well-being economy principles such as good working conditions, training possibilities and safety at work. We believe these conditions can be further strengthened through increased research in this sector, such measures as public social procurement and enhanced social dialogue.
Read full responseResponse to EU strategy for sustainable textiles
2 Feb 2021
Over half of RREUSE’s 27 members work with used textiles, garment, leather and footwear (TGLF), collectively managing 257 000 tonnes across Europe annually. Thus, the “EU Strategy for Textiles” is highly anticipated by the EU re-use sector and RREUSE welcomes the release of its roadmap. Undoubtedly, this initiative will also please the 75% of EU citizens who view sustainability as very or extremely important when buying fashion.
RREUSE and the 60+ signatories of the “Fair and Sustainable Textiles, European civil society strategy for sustainable TGLF” are happy to see the document mentioned in the roadmap. RREUSE is also grateful for the acknowledgement of the impact that COVID-19 had on the trade of second-hand TGLF.
Nonetheless, RREUSE would like to take this opportunity to raise the following points:
1. Give priority to prevention and preparing for re-use
RREUSE feels that the roadmap focuses too much on developing the textiles recycling sector. For instance, the objective of this strategy is said to address “structural weaknesses regarding textile waste collection, sorting and recycling in the Member States”. What about tackling overconsumption or supporting repair and re-use activities?
Buying a used TGLF item instead of a new one reduces its carbon footprint by 82 %. Reducing the impact of the TGLF industry simply by making fast fashion recyclable will not suffice. There is a pressing need for ecodesign policies to focus on making TGLF products more durable and repairable, as well as for sustainable investments to finance re-use activities.
Fortunately, the roadmap states that the waste hierarchy will be considered when studying the role of EPR. Whether linked to EPR schemes or not, concrete targets prioritising re-use over recycling must be developed, preferably in coordination with employment targets valorising the role of social economy actors.
2. Protect re-use operators of the social economy
It is encouraging to see that the “environmental and social impact” of the EU textiles sector will be addressed, especially if this goal is applied to the production of new TGLF as well as the management of used TGLF. Protecting the role of social economy enterprises in that sector is essential to support the integration of disadvantaged groups on the job market. This will be a particularly welcome step in the context of the COVID-19 crisis recovery.
Collection, sorting and sales of second-hand TGLF can locally create 20 jobs per 1,000 tonnes of used clothes and shoes. Developing partnerships along the TGLF value chain together with social enterprises would maximise sustainable production and consumption (e.g. reward systems for companies who partner with re-use/upcycling initiatives to use waste fabrics and materials).
An impact assessment should also be carried out regarding separate collection obligations for TGLF under the Waste Framework Directive, taking into account the associated environmental, social and economic impacts on used-textile management operators.
3. Voluntary approaches and new business models are not enough
The strategy described in the roadmap is not solid enough to encourage the EU TGLF sector to move towards a circular economy. Incentivising new business models such as ‘product as a service’, for which the sustainability still needs to be demonstrated, or promoting the use of voluntary labelling will fall short in making the sale of low-quality products less profitable. The battle against fast fashion will not be won by giving consumers more choice or information.
Ecodesign measures must make textile products more durable and repairable, advertisement should be limited, the destruction or premature recycling of unsold and returned goods should be banned and floor prices for some emblematic items must be developed to internalise the environmental and social externalities caused by the production of TGLF products.
Please find attached a PDF with the same text with references.
Read full responseResponse to Environmental impact of mobile phones and tablets - Energy Labelling
27 Jan 2021
RREUSE welcomes this opportunity to comment on the roadmap to "Designing mobile phones and tablets to be sustainable".
RREUSE joins its voice to those of ECOS, IFixIt, the EEB, the Right to Repair Campaign and the Cool Products campaign to support the idea that mobile phones and tablets should be designed to be durable, repairable and upgradeable in order to properly fit into a circular economy.
RREUSE strongly encourages the Commission to ensure that eco-design measures will permit the widest possible range of stakeholders to repair these products. Consumers, or at least professional repairers (who include independent repairers, not only repairers authorised by manufacturers), must be able to repair tablets and mobile phones with commonly available tools and have access to repair manuals and spare parts.
RREUSE also suggests that clear and enforceable measures (such as stiff fines and bans) are developed to prevent producers/retailers/distributors to put non-compliant appliances on the market.
Beyond these two points, RREUSE also supports the content of the paper developed by ECOS and its partners (attached).
Read full responseMeeting with Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit), Santina Bertulessi (Cabinet of Commissioner Nicolas Schmit) and
17 Dec 2020 · Next Generation EU and RRF/European action plan of social economy/The social consequence of the Covid crisis
Response to Sustainable Products Initiative
16 Nov 2020
RREUSE welcomes the release of the “Sustainable Products Initiative” inception impact assessment. Ensuring durability, reusability and repairability is essential to improve the quality of products placed on the EU market and, in the long run, of second-hand products. The Commission’s ambition to implement a strategy reinforcing ecodesign resource-efficiency requirements for electronics and widening the scope of the ecodesign regulation to other types of products was particularly called for by re-use operators. This initiative is also highly anticipated by consumers who, in the aftermath of Covid-19, wish to possess goods on which they can rely in times of crisis.
RREUSE would, however, like to benefit from this opportunity to make the following remarks:
• Improving the status of re-use and repair markets is one of the objectives of this initiative. It is therefore essential to see strong and concrete fiscal measures being developed to incentivise consumers to repair their products or buy second-hand before purchasing new products. These fiscal measures could be based on the repairability and durability labelling that will be developed in the framework of the initiative on “Empowering the consumer for the green transition”.
• “Internalising product-related externalities” is a worthy goal. Details on how this will be implemented should follow, but RREUSE would recommend avoiding EPR-like systems where producers retain too much control over how externalities are internalised. The polluter-pays principle should not be confused with a right to pollute, as is often the case: Externalities should be avoided before being internalised. Product-as-services models should not be considered as forms of internalisation of product-related externalities as the resource efficiency of these models still needs to be demonstrated.
• On "establishing EU rules for setting mandatory minimum sustainability requirements on public procurement of products", RREUSE asks the Commission to understand the concept of sustainability as including the three environmental, social and economic pillars, for example through facilitating access to public tenders for social economy enterprises.
• To complement the waste hierarchy, the Commission must develop the concept of a product hierarchy: 1. Avoid purchase; 2. Repair; 3. Buy second-hand; 4. Buy new and sustainable. This could be established in the framework of the development of mandatory minimum sustainability requirements on public procurement of products.
• Measures to ban the destruction of unsold durable goods sound well-meaning but will do little to limit overproduction if not accompanied by fiscal measures discouraging the overstock of products. If simply donated, unsold goods might even become a management burden that will backfire on charities and go against the philosophy of selling second-hand products.
Read full responseMeeting with Nicolas Schmit (Commissioner) and
30 Oct 2020 · Pact for Skills Roundtable on proximity and social economy.
Meeting with Agnieszka Skonieczna (Cabinet of Commissioner Thierry Breton) and Social Economy Europe and
30 Oct 2020 · Pact for Skills: Proximity and social economy roundtable
Response to Empowering the consumer for the green transition
1 Sept 2020
RREUSE welcomes the release of the inception impact assessment “Empowering the consumer for the green transition”. Tackling greenwashing and premature obsolescence is essential to improve the quality of products placed on the EU market and, in the long run, of second-hand products. This initiative is also highly anticipated by consumers who, in the aftermath of Covid-19, wish to possess durable and repairable goods on which they can rely in times of crisis. However, RREUSE insists that access to information will not suffice in tackling overconsumption. Tools to simply remove unsustainable products from the EU market will also have to be developed. This will hopefully take place through the “Legislative proposal for a sustainable product policy initiative” also suggested by the Circular Economy Action Plan.
The following points consist of recommendations on how to empower consumers, as well as independent repairers, refurbishers, second-hand operators and repair cafés:
• RREUSE strongly encourages the Commission to focus on the suggested Option 2 and create a new stand-alone consumer protection instrument that will guarantee access to information at the point of sale and ultimately define and prohibit greenwashing and early product failure.
• To facilitate access for everyone (including independent repairers, refurbishers, second-hand operators and repair cafés), information on product sustainability should be attached to products themselves and not to packaging.
• Having access to information will encourage consumers to buy more sustainable products, but might also encourage them to replace already functioning products or products that could be repaired with new ones. Information on product sustainability should go hand in hand with information on the impact of buying new and advantages to maintain, repair or buy used products.
• Product-as-services models should also be covered by sustainability information in order to promote models which are based on durable products and maintenance instead of those based on regular replacement and unnecessary upgrades.
• Beyond information on product sustainability, clarity is needed on consumer’s prerogatives within legal and commercial warranties, especially concerning the time during which the burden of proof lies on the manufacturer.
• In order to allow owners of second-hand products to use them, legal and commercial warranties should be attached to products, not to buyers.
• When products fail within their warranty period, they must be repaired, or replaced by equivalent second-hand products. Extending warranty periods will be at the benefit of consumers, but should not encourage early replacement with new products.
• RREUSE welcomes the reference to the “Analysis and development of a scoring system for repair and upgrade of products” drafted by the JRC. It is essential that information on product sustainability includes a repair scoring system and clear information on access to repair manuals, availability and delivery time of spare parts, as well as on the possibility to repair the product yourself or with the help of independent repairers.
• Bearing in mind that such practices should simply be banned, if a product can only be repaired by operators authorised by manufacturers, this should be displayed negatively on the information on product’s sustainability (e.g. “The repair of this product is restricted to the manufacturer’s repair services” on a red background).
• Free access to repair manuals for independent repairers, refurbishing operators, consumers and repair cafés is always a good idea. The easier access to repair information is, the safer the repair operation will be.
• Consumers, repairers, refurbishers and repair cafés should have access to software updates during the whole expected lifetime of a product.
Read full responseResponse to Farm to Fork Strategy
19 Mar 2020
The Role of the Social Enterprise in the Farm to Fork Strategy. RREUSE is a network of Social Enterprises active in re-use and recycling.
The 850 Social Enterprises federated by RREUSE's 26 members provide work opportunities for 95,000 employees, volunteers and trainees. Traditionally, RREUSE members worked with food waste in the form of community composting facilities.
Increasingly, social enterprises are tackling food waste by using and distributing surplus foods in diverse ways. Communities can be directly supported, benefitting from employment and social inclusion opportunities that such initiatives provide. With the review of the WFD, comes opportunities to share best practices locally and internationally. For inspiration on what can be achieved, RREUSE highlights a few examples to encourage further collaboration amongst social enterprises, municipalities and businesses in the fight to reduce waste, including food waste.
RREUSE members: A snapshot of examples from social enterprises active in food waste
1) RREUSE member HERW!N 3 (Collective of social and circular entrepreneurs in Flanders) helps the Flemish region of Belgium reach its food waste prevention target with the Foodsavers project. With three objectives including ‘Climate, Social Employment and Poverty Reduction,’ Foodsavers is a distribution platform that recovers and redistributes surplus foods across Flanders. Almost 200 social organisations are involved in the Foodsavers programme, collectively working on the Flemish roadmap (2015-2020) to reduce food waste by 15%. Figures from 2018 highlight the demand for the project, with 55 disadvantaged workers employed and a growing network of 191 social organisations involved in the donation process. Over 920 tonnes of surplus food was redistributed in 2018, offsetting more than 2,300 tonnes of CO2. In full partnership with the City of Ghent since March 2017, Foodsavers is a success story and template for how city governments can support initiatives locally and regionally.
2) The social enterprise FoodCloud, a member of Community Reuse Network Ireland, one of RREUSE members, is an example of building partnerships on the ground, nationally and internationally. Founded in 2014, FoodCloud has changed the way businesses interact with food waste. Using an app that connects businesses with surplus foods to charities using foods, FoodCloud offers a user-friendly platform to make food donation straightforward. To date, FoodCloud has helped over 9,100 charitable groups get surplus food in Ireland and the UK, equivalent to 50 million meals that have gone to people and not to waste. This amount has saved charities €66.1 million which is measurable to 22,000 tonnes of food.
3) Established by the NYC Department of Sanitation in 2016, donateNYC (U.S.A), a member of RREUSE, plays a vital role in New York City’s re-use scene. With 52,254 tonnes of material diverted from landfill in 2018 and food accounting for 52% of its impact contribution, donateNYC’s partners rescued 5,415 items (32,014 tonnes) of food and beverages alone. 6 The latest donateNYC app counts 300 registered organisations (donors and recipients) and covers about 1,000 locations throughout NYC. By prioritising connections by type of food needed and then by distance, this donation portal benefits social enterprises in receiving and redistributing food on the go. With 4.5 tonnes of food diverted from landfill since March 2019, the portal also encourages small donations which other food rescue organisations in the city are unable to handle.
With a growing spotlight in recent years on social enterprises with a flair for technology to reduce food waste, RREUSE advocates for the support of enterprises that’s impact intersects environmental and social dimensions. Many avenues can be used effectively to tackle food waste, with social enterprises and community led initiatives being one example of the building blocks to achieve global goals.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
RREUSE is an international network representing social enterprises active in re-use, repair and recycling. RREUSE members currently divert around 1 million tonnes of goods and materials on an annual basis from landfill through re-use, repair and recycling, generating a combined turnover of 1,2 billion EUR . In 2018, RREUSE members active in re-use extended the lifespan of 214 500 tonnes of products, counterbalancing the average CO2 emissions of approximately 108 000 EU citizens . Environmental services, including those of re-use and repair, enabled 850 social enterprises federated by RREUSE’s wider network to fulfil their social mission, which for the most part includes the provision of work opportunities, training and support services for disadvantaged individuals. There are approximately 95,000 employees, volunteers and trainees engaged in the activities of RREUSE’s 27 members spanning 25 European countries and the USA.
RREUSE welcomes the roadmap on a New Circular Economy Action Plan and supports the idea that, to speed up the transition, we must take into account impacts associated with “the lifecycle of products”. The strengthening of circular economy related policies is very much needed to change our consumption patterns, create local jobs and achieve the objectives set out by the European Green Deal. While the roadmap identifies a number of solutions to help drive the European economy towards circularity, RREUSE would like, in the document attached, to highlight some shortcomings and suggest policies to ensure the New Circular Economy Action Plan not only saves more resources but also creates a significant number of jobs, especially for those in need.
Read full responseResponse to Sustainability requirements for batteries
6 Feb 2019
Dear members of the European Commission,
RREUSE, the network of European social economy enterprises active in re-use, repair and recycling, welcomes your commitment to take action towards an improvement of the sustainability requirements linked to batteries placed on the European market. This will be a necessary step to ensure that every product containing a battery can be easily repaired and re-used, providing benefits in terms of preservation of the environment, climate change mitigation and social impact.
Please find attached our feedback.
Best regards,
RREUSE team
Read full responseResponse to Review of ecodesign requirements for household cold appliances
13 Feb 2018
RREUSE supports the attached statement co-signed with ECOS, the EEB, CoolProducts, TopTen and IFixit in particular concerning resource efficiency requirements for household cold appliances.
In addition, to support the idea that the repairability of household cold appliances is necessary to save both energy and resources, RREUSE asked to his membership to share data related to the second-hand market of domestic refrigeration. Three social enterprises including two in Belgium and one in Italy, as well as a network of re-use centres in Spain, answered to RREUSE with the following information:
• How old are the second-hand domestic refrigeration products?
In Belgium and Italy, the average age of second-hand household cold appliances sold by RREUSE members is varying from an operator to another, ranging from 4 to 9 years.
In Spain, the re-use centre network has difficulties to estimate the age of the appliances received from households. However, and thanks to the EPR scheme put in place in Spain, some of their members have contracts with manufacturers allowing them to have access to products returned within the guaranty period. They estimate that the age of the appliances received through this system is around 2 years.
• Are new fridges really more energy efficient than second-hand appliances?
RREUSE members find no significant differences between the fridges currently put on the market and those which are showcased in their re-use shops when it comes to compare their energy efficiency. Most of the appliances that they collect are rated between A and A+++, B being the less energy efficient that they are collecting.
However, the Italian operator noticed that it was a trend in the Italian households to replace their appliances for energy efficiency reasons. This explanation was given to justify the very early replacement (before 7 years of use) of totally functioning fridges which did not have a significantly different energy efficiency when compared to new appliances.
• Should the forecast about the improving energy efficiency of domestic refrigeration products be a reason to forget about resource efficiency requirements?
RREUSE understands that for appliances which were placed on the market before the enforcement of the Commission regulation n°643/2009, replacement can be justified. Anyway, the demand for such products being very low, re-use operators tend to let those old appliances be recycled. However, with a lack of accurate life cycle assessment for each appliance, there is a threat that a communication focused on energy efficiency could result in premature replacements of still functioning and energy efficient appliances as it is the case in Italy. This could have an overall negative impact on the environment if we take into account the energy and the resources used for their manufacturing.
The RREUSE network believes that the replaceability of domestic refrigeration products’ spare parts and their repairability could, in the future, allow for their upgrading towards better energy efficiency. This is why we welcome the possibility to change the door gaskets proposed by the Commission since it can help improve the energy efficiency of older products by maximising their insulation, even though we think that more spare parts could respect the same requirement.
Resource efficiency requirements are often described as being hindrances to innovation while we see them as drivers for innovation for the benefit of consumers and the environment. Resource and energy efficiency requirements should be considered as complementary and not opposed. Repairability, durability, upgradability and modularity are criteria that we think should be the next innovation targets of manufacturers of Electrical and Electronic Equipment.
Read full responseResponse to Review of ecodesign requirements for household dishwashers
13 Feb 2018
RREUSE supports the attached statement co-signed with ECOS, the EEB, CoolProducts, TopTen and IFixit in particular concerning resource efficiency requirements for household dishwashers:
We are pleased to note and strongly support all the measures outlined in the Working Document that address material efficiency considerations (dismantling, spare part availability and repairability) under Annex I. In particular for dishwashers, where there is a trend towards reduction in product lifetimes, lifetime extension via improved repair has proven benefits, and the Ecodesign regulation is the key legislative tool to address this. The opportunity should be seized to strengthen certain aspects even further (…).
Read full responseResponse to Review of ecodesign requirements for household washing machines and washer-driers
13 Feb 2018
RREUSE would like to support the attached statement co-signed co-signed with ECOS, the EEB, CoolProducts, TopTen and IFixit in particular concerning resource efficiency requirements for household washing machines and washer-driers:
We strongly support the measures that address material efficiency considerations (dismantling, spare part availability and repairability) under Annex I. We support the proposal for the additional generic Ecodesign requirements on repair and end-of-life aspects. In particular for washing machines, where there is a trend toward reduction in product lifetimes, lifetime extension via improved repair has proven benefits, and Ecodesign regulation is the key legislative tool to address this. The opportunity should be seized to strengthen certain aspects even further (…).
Read full responseMeeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)
2 Aug 2017 · introduction to the organisation and main issues it tackles related to the circular economy, in particular ecodesign and waste
Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen)
24 Nov 2015 · circular economy
Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)
15 Apr 2015 · Circular Economy
Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)
15 Apr 2015 · Circular Economy