OpenLobby.EU
Explore

SIRRMIET

SIRRMIET aims at representing the French refurbished and second-hand electronics industry at a national level, bringing together refurbishers and second-life electronics distributors of all sizes from across France.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

The SIRRMIET, representing Frances refurbishers and second-hand electronic distributors, welcomes the European Commissions ambition to accelerate circularity through the upcoming Circular Economy Act (CEA). Refurbishment is identified as a strategic pillar for achieving the EUs climate neutrality, resource independence, and competitiveness objectives. However, it remains underrepresented in current policy frameworks. The position paper attached calls for the CEA to explicitly recognise and integrate refurbishment as a key component of Europes circular economy strategy. Summary 1. Refurbishment as a Strategic Lever for Critical Raw Materials Refurbishment extends product lifespans, reduces demand for virgin materials, and supports the recovery of secondary critical raw materials, enhancing European sovereignty and supply security. The paper calls for: Formal inclusion of refurbishment in the CEAs scope and resource efficiency monitoring. Integration of reuse and refurbishment targets into secondary material markets. Support for a genuine single market for refurbished products across the EU. 2. Prioritising Refurbishment in the Waste Treatment Hierarchy Refurbishment implements the upper tiers of the waste hierarchy by preventing waste generation and cutting energy use by up to 80%. Yet, collection systems remain inadequate and often prioritise recycling. Recommendations include: Legal recognition of refurbishment as a priority treatment activity separate from waste regulation. Quantitative reuse targets alongside recycling goals. Mandatory professional sorting for reusability before recycling. Integration of reuse criteria into logistics and procurement contracts. Public awareness campaigns funded through EPR budgets. 3. Rebalancing Extended Producer Responsibility (EPR) EPR systems are currently recycling-centric, imposing disproportionate burdens on refurbishers. The SIRRMIET calls for: Recognition of refurbished products in environmental performance metrics. Creation of a centralised EPR One-Stop Shop platform to streamline compliance and improve data transparency. Exemption of second-hand products from EPR fees already applied to first sales. Revised governance ensuring co-decision rights for reuse actors. Financial contributions proportionate to lower environmental impacts. 4. Incentive Mechanisms to Strengthen the Sector The refurbishment industry faces fragile margins and high costs due to repair complexity, spare parts pricing, and double taxation. To enhance competitiveness and circular consumption, SIRRMIET proposes: Reduced VAT rates for refurbished goods. Exclusion from copyright levies to end double taxation. Investment incentives for refurbishment infrastructure. Inclusion of reuse criteria in public procurement. Support for training and certification in refurbishment professions. 5. Industrial Innovation and Regulatory Simplification To foster growth and innovation among SMEs and startups, the CEA should: Simplify administrative procedures and enable cross-border operation through mutual recognition of authorisations. Promote innovation in diagnostic, testing, and certification tools. Create streamlined approval processes for compliant operators. The full position paper is available in the attachments.
Read full response

Meeting with Alvydas Stancikas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

18 Sept 2025 · Meeting SMET (GROW.E4) and Sirrmiet

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

18 Sept 2025 · Concerns by the refurbishment sector with respect to the Union legislation on harmonised products

Response to Revision of the 'New Legislative Framework'

1 Sept 2025

SIRRMIET welcomes the opportunity to provide feedback to the call for evidence for the revision of the New Legislative Framework (NLF). Please find attached the full contribution to the revision of the NLF. Overall, SIRRMIET has identified four key areas for reform: 1. Introduction of a new economic operator category for refurbishers and repairers Refurbishers are often treated as if they were placing entirely new products on the market, despite the fact that they are reintroducing second-hand goods that have already been used by consumers. This creates a regulatory mismatch, as refurbishers are subjected to obligations they cannot meet (like CE marking or complying with the Common Charger Directive) because they do not have access to original design and manufacturing information. This legal uncertainty and the disproportionate requirements hinder the sector's growth. A new, distinct category would allow for tailored, proportionate obligations that reflect the refurbishers actual role, ensuring the NLF supports circular business models instead of penalising them. 2. Implementation of circular VAT for refurbished products The current VAT rules place refurbished products at a disadvantage by treating them like new goods, unlike second-hand sales which often enjoy VAT exemptions. This also allows for widespread VAT fraud, where fraudsters declare products from non-EU countries as intra-EU second-hand goods to exploit reduced rates. This harmful practice undercuts legitimate refurbishers. To combat this, SIRRMIET proposes leveraging EU initiatives like VAT in the Digital Age (or ViDA) could be leveraged to fight against tax fraud. This will help the sector grow further, thus overcoming the current situation where the online sale of second-hand products faces heightened risks of tax fraud both in relation to marginal VAT and to standard VAT. A reduced VAT rate for refurbished products would create a level playing field, support SMEs, and accelerate the adoption of circular goods. 3. Establishment of a harmonised EU label for refurbished products The lack of a unified label for refurbished goods across the EU leads to consumer confusion and erodes trust. SIRRMIET urges the NLF to provide a legal basis for the mutual recognition and scaling of existing national labels, such as France's "Label Reconditionné" (RecQ). RecQ is an independently audited, quality-focused label with strict criteria for data deletion, functional testing, and consumer transparency. By adopting proven national schemes like RecQ, the NLF could quickly build consumer confidence, streamline cross-border trade, and prevent greenwashing. 4. Inclusion of circularity and reuse in essential requirements The current NLF defines essential requirements around safety, health, and environmental protection, but remains silent on circular-economy objectives and the treatment of reconditioned products. This omission undermines the EUs broader ambitions to extend product lifespans, reduce waste, and foster sustainable growth. We urge the Commission, to explicitly embed circularity and reuse into the essential-requirements framework. By doing so, the NLF will catalyse design-for-repair, transparent product lifecycles, and open spare-parts markets, aligning regulatory incentives with the EUs Green Deal and Circular Economy Action Plan. We thank the European Commission for the opportunity to provide feedback on the revision of the NLF, which will be key for a strong, competitive, and more circular EU.
Read full response