Saatja: Mihkel Krusberg <
[email protected]>
Saadetud: 07.04.2021 14:13
Adressaat: <
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[email protected]>;
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Koopia: Annaliisa Jäme <
[email protected]>; Evelin Kuuse <
[email protected]>;
Sigrid Soomlais <
[email protected]>
Teema: FW: Kiri huvigruppidele: Kestliku tootepoliitika avalik konsultatsioon
Manused: image002.jpg; SPI_public_consultation_19_03_2021_EN.PDF
Hea koostööpartner!
Ringmajanduse praktikas rakendamiseks on võtmetähtsusega 2021 lõpus avaldatav EL kestliku
toote poliitika algatus, mille eesmärk on võimaldada juba toodete kavandamisel lähtumist
kliimaneutraalse, ressursitõhusa ja ringmajandusliku lähenemise EL ülestest põhimõtetest. Selle
täpsete elementide jaoks küsib Euroopa Komisjon avaliku konsultatsiooni küsimustiku
(https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12567-Sustainable-
Products-Initiative) kaudu huvitatud osapooltelt arvamusi 09. juuniks. Plaanime esitada
Keskkonnaministeeriumi ning Majandus- ja Kommunikatsiooniministeeriumi eestvedamisel Eesti
koondvastuse küsimustikule.
Algatuse fookusvaldkondadeks on elektroonika, IKT, tekstiilid, mööbel ja kõrge mõjuga
vahetooted nagu teras, tsement ja kemikaalid (rõhutatud on, et toit ja sööt ei ole kindlasti
fookuses). Meetmetes keskendutakse teiste kõrval näiteks toodete kasutajatele pakutava toote
eluiga või parandatavust puudutava informatsiooni nõuete sisustamisele ja digitaalse tootepassi
loomisele.
Küsimustikus tuleb hinnata ringmajanduse väljakutseid, hinnata erinevate meetmete (toodete
kestlikuma disaini võimalused - küsimustikus punkt 2A, informatsiooni kättesaadavus ja digitaalne
tootepass – 2B, müümata tooted – 2C, ringsed ärimudelid – 2D, ringsuse saavutamine – 2E, 2F)
asjakohasust kestliku toote kui normi tekitamisel ning vastava turu tekitamise tagamise võimalusi.
Kuna erinevaid võimalusi kestliku toote poliitika arendamiseks on palju, siis ootame, et
tooksite oma sisendis välja kõige olulisemad aspektid/meetmed, mis Teie hinnangul kõige
paremini toimiksid ja soovitud eesmärke saavutada aitaksid ning võimalusel tooksite ka oma
valdkonna raames välja ideid, teile teadaolevaid parimaid praktikaid või näiteid.
Küsimustiku inglise keelne versioon on leitav manusest. Oma eelistused, tähelepanekud ja
märkused selle kohta palume saata hiljemalt 07.05 aadressile
[email protected].
Lisaks plaanime 28.04 pärastlõunal tutvustada avalikku konsultatsiooni sisu ja korraldada
huvitatud osapooltega ka arutelu. Selleks saadame õige pea ka eraldi meili.
Lugupidamisega
Mihkel Krusberg
Nõunik | Keskkonnakorralduse osakond
Adviser | Environmental Management Department
+372 626 0752|+ 372 56 933 822|
[email protected]|http://www.envir.ee/
Keskkonnaministeerium | Ministry of the Environment of Estonia | Narva mnt 7a, 15172 Tallinn, Eesti
Public Consultation on the Sustainable
Products Initiative
Fields marked with * are mandatory.
Introduction
Developing a Sustainable Products Policy Initiative as a key part of the Circular Economy Action Plan for a
cleaner and more competitive Europe (CEAP)[1] is one of the main flagships of the European Green Deal[2] and
a pillar of the New Industrial Strategy for Europe[3]. This legislative initiative will aim to make products fit for a
climate neutral, resource efficient and circular economy, reduce waste and ensure that the performance of
frontrunners in sustainability progressively becomes the norm.
As announced in the new CEAP, the core of the Sustainable Product legislative Initiative will widen the scope of
the Ecodesign Directive[4] beyond energy-related products so as to make it applicable to the broadest possible
range of products (including services where appropriate) and make it deliver on circularity.
The Commission committed to consider such amendments to the Ecodesign Directive, and, where appropriate,
complementary legislative proposals, to regulate the following sustainability aspects: product durability,
reusability, upgradability and reparability; the presence of hazardous chemicals in products; energy and resource
efficiency; recycled content in products; remanufacturing and high-quality recycling; carbon and environmental
footprints; restrictions to single-use and premature obsolescence; a ban on the destruction of unsold durable
goods; circular business models; digitalisation of product information and ways to reward the most sustainable
products.
It will also strengthen information requirements and establish a digital product passport that gathers data on a
product along its value chain, among other things on environmental characteristics, repair and upgrade
instructions, presence of hazardous chemicals, reusability, recycled material content, recycling, and correct
disposal and waste stream information, so as to enable consumers and businesses to understand the
composition and properties of products, and enable compliance authorities to better fulfil their duties.
Priority products under the Sustainable Product Policy legislative initiative identified in the CEAP are electronics,
ICT, textiles, furniture and high-impact intermediary products such as steel, cement and chemicals. (The
initiative will not cover food and feed products.) Further product groups are to be identified based on their
environmental impact and circularity potential. The Commission will also seek to increase the effectiveness of
the current Ecodesign framework for energy-related products, including through the Ecodesign and Energy
Labelling Working Plan 2020-2024.
The Sustainable Product legislative Initiative aims primarily at advancing sustainability at the design phase. As
laid down in the Circular Economy Action Plan, it is part of a broader framework, which includes initiatives on
empowering consumers and public buyers and promoting circularity in production processes.
1
Further background can be found in the Inception Impact Assessment on the Sustainable Products Initiative,
which was published by the Commission in 2020[5].
The aim of this public consultation is to gather opinions and evidence from the public and relevant stakeholders
on the main policy options for the legislative initiative.
The questionnaire is divided into four sections:
First section: Introduction
Second section: “About you” questions
Third section: Main consultation questions:
Challenges to making products sustainable
Measures to make sustainable products the norm
Design for sustainability - sustainability requirements for products
Responsibility for information, including Digital Product Passport(s)
Avoidance of destruction of goods
Circular business models
Incentives for circularity
Compliance with and enforcement of sustainability requirements for products
Fourth section: Optional additional comments
[1] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2020:98:FIN
[2] https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1588580774040&uri=CELEX:52019DC0640
[3] https://ec.europa.eu/commission/presscorner/detail/en/ip_20_416
[4] https://ec.europa.eu/growth/industry/sustainability/product-policy-and-ecodesign
[5] https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12567-Sustainable-Products-Initiative
About you
* Language of my contribution
Bulgarian
Croatian
Czech
Danish
Dutch
English
Estonian
Finnish
French
German
Greek
Hungarian
2
Irish
Italian
Latvian
Lithuanian
Maltese
Polish
Portuguese
Romanian
Slovak
Slovenian
Spanish
Swedish
* I am giving my contribution as
Academic/research institution
Business association
Company/business organisation
Consumer organisation
EU citizen
Environmental organisation
Non-EU citizen
Non-governmental organisation (NGO)
Public authority
Trade union
Other
Please specify your sector:
Agriculture, forestry and fishing
Apparel and footwear
Chemicals and chemical products
Construction
Electrical equipment
Computers, electronic and optical products
Food and beverages
Materials (e.g. metals, plastics, paper)
3
Retail & wholesale trade
Banking
Insurance, reinsurance and pension funding
Accommodation and food service activities
Other
Please specify:
200 character(s) maximum
Please specify the type of product your organisation produces or represents:
Intermediate product (e.g. ingredient or component for a final product)
Final product (used as it is)
Both intermediate and final products
Other (e.g. services):
Please indicate the level of market(s) you are active on:
Local market
Regional market
EU market
Non-EU market
Worldwide market
Not applicable
* First name
* Surname
* Email (this won't be published)
* Scope
International
Local
4
National
Regional
* Level of governance
Local Authority
Local Agency
* Level of governance
Parliament
Authority
Agency
* Organisation name
255 character(s) maximum
* Organisation size
Micro (1 to 9 employees)
Small (10 to 49 employees)
Medium (50 to 249 employees)
Large (250 or more)
Transparency register number
255 character(s) maximum
Check if your organisation is on the transparency register. It's a voluntary database for organisations seeking to
influence EU decision-making.
* Country of origin
Please add your country of origin, or that of your organisation.
Afghanistan Djibouti Libya Saint Martin
Åland Islands Dominica Liechtenstein Saint Pierre
and Miquelon
Albania Dominican Lithuania Saint Vincent
Republic and the
Grenadines
Algeria Ecuador Luxembourg Samoa
5
American Egypt Macau San Marino
Samoa
Andorra El Salvador Madagascar São Tomé and
Príncipe
Angola Equatorial Malawi Saudi Arabia
Guinea
Anguilla Eritrea Malaysia Senegal
Antarctica Estonia Maldives Serbia
Antigua and Eswatini Mali Seychelles
Barbuda
Argentina Ethiopia Malta Sierra Leone
Armenia Falkland Islands Marshall Singapore
Islands
Aruba Faroe Islands Martinique Sint Maarten
Australia Fiji Mauritania Slovakia
Austria Finland Mauritius Slovenia
Azerbaijan France Mayotte Solomon
Islands
Bahamas French Guiana Mexico Somalia
Bahrain French Micronesia South Africa
Polynesia
Bangladesh French Moldova South Georgia
Southern and and the South
Antarctic Lands Sandwich
Islands
Barbados Gabon Monaco South Korea
Belarus Georgia Mongolia South Sudan
Belgium Germany Montenegro Spain
Belize Ghana Montserrat Sri Lanka
Benin Gibraltar Morocco Sudan
Bermuda Greece Mozambique Suriname
Bhutan Greenland Myanmar Svalbard and
/Burma Jan Mayen
Bolivia Grenada Namibia Sweden
Guadeloupe Nauru Switzerland
6
Bonaire Saint
Eustatius and
Saba
Bosnia and Guam Nepal Syria
Herzegovina
Botswana Guatemala Netherlands Taiwan
Bouvet Island Guernsey New Caledonia Tajikistan
Brazil Guinea New Zealand Tanzania
British Indian Guinea-Bissau Nicaragua Thailand
Ocean Territory
British Virgin Guyana Niger The Gambia
Islands
Brunei Haiti Nigeria Timor-Leste
Bulgaria Heard Island Niue Togo
and McDonald
Islands
Burkina Faso Honduras Norfolk Island Tokelau
Burundi Hong Kong Northern Tonga
Mariana Islands
Cambodia Hungary North Korea Trinidad and
Tobago
Cameroon Iceland North Tunisia
Macedonia
Canada India Norway Turkey
Cape Verde Indonesia Oman Turkmenistan
Cayman Islands Iran Pakistan Turks and
Caicos Islands
Central African Iraq Palau Tuvalu
Republic
Chad Ireland Palestine Uganda
Chile Isle of Man Panama Ukraine
China Israel Papua New United Arab
Guinea Emirates
Christmas Italy Paraguay United
Island Kingdom
7
Clipperton Jamaica Peru United States
Cocos (Keeling) Japan Philippines United States
Islands Minor Outlying
Islands
Colombia Jersey Pitcairn Islands Uruguay
Comoros Jordan Poland US Virgin
Islands
Congo Kazakhstan Portugal Uzbekistan
Cook Islands Kenya Puerto Rico Vanuatu
Costa Rica Kiribati Qatar Vatican City
Côte d’Ivoire Kosovo Réunion Venezuela
Croatia Kuwait Romania Vietnam
Cuba Kyrgyzstan Russia Wallis and
Futuna
Curaçao Laos Rwanda Western
Sahara
Cyprus Latvia Saint Yemen
Barthélemy
Czechia Lebanon Saint Helena Zambia
Ascension and
Tristan da
Cunha
Democratic Lesotho Saint Kitts and Zimbabwe
Republic of the Nevis
Congo
Denmark Liberia Saint Lucia
The Commission will publish all contributions to this public consultation. You can choose whether you
would prefer to have your details published or to remain anonymous when your contribution is published. Fo
r the purpose of transparency, the type of respondent (for example, ‘business association,
‘consumer association’, ‘EU citizen’) country of origin, organisation name and size, and its
transparency register number, are always published. Your e-mail address will never be published.
Opt in to select the privacy option that best suits you. Privacy options default based on the type of
respondent selected
* Contribution publication privacy settings
The Commission will publish the responses to this public consultation. You can choose whether you would like
your details to be made public or to remain anonymous.
8
Anonymous
The type of respondent that you responded to this consultation as, your
country of origin and your contribution will be published as received. Your
name will not be published. Please do not include any personal data in the
contribution itself.
Public
Your name, the type of respondent that you responded to this consultation
as, your country of origin and your contribution will be published.
* Contribution publication privacy settings
The Commission will publish the responses to this public consultation. You can choose whether you would like
your details to be made public or to remain anonymous.
Anonymous
Only organisation details are published: The type of respondent that you
responded to this consultation as, the name of the organisation on whose
behalf you reply as well as its transparency number, its size, its country of
origin and your contribution will be published as received. Your name will not
be published. Please do not include any personal data in the contribution
itself if you want to remain anonymous.
Public
Organisation details and respondent details are published: The type of
respondent that you responded to this consultation as, the name of the
organisation on whose behalf you reply as well as its transparency number,
its size, its country of origin and your contribution will be published. Your
name will also be published.
I agree with the personal data protection provisions
Main questions
1. Challenges to making products sustainable
1.A To what extent do you agree that the following market-related statements
explain why products sold in the EU are not more sustainable?
I do
not
Agree Neutral Disagree know /
9
Strongly Strongly no
agree disagree opinion
a. Economic actors do not have
adequate and reliable
information on the sustainability
of products
b. Products such as electronics
become obsolete quickly
because of technological
innovations
c. Some products are designed
for shorter term use due to
changing fashion trends
d. Many products are not
designed to be easily repaired or
upgraded
e. Some products are designed
to break down after a certain
amount of time (planned
obsolescence)
f. Materials used in products are
more and more complex and
difficult to recycle
g. Products do not sufficiently
cover the costs of the harm that
their production and use cause
to the environment
h. More sustainable products are
often too expensive for
households with lower incomes
i. The cost of repairing a product
is too high, in comparison with
buying a brand new product
j. For electronics, as well as for
fashion products, there are not
enough places where products
can be repaired
k. The quality of second hand
goods cannot be guaranteed or
is difficult to assess
1.B To what extent do you agree that the following policy-related statements
explain why products sold in the EU are not more sustainable?
10
I do
Strongly Strongly not
Agree Neutral Disagree
agree disagree know /
no
opinion
a. There is no harmonized set of
requirements to foster the
sustainable design of products
placed on the EU market
b. There is no harmonized set of
requirements to foster the
sustainability of services
provided in the EU
c. Voluntary approaches, such
as labelling, do not provide
sufficient incentives for
businesses to offer more
sustainable products
d. Diverging national rules and
lack of a harmonized set of EU
rules discourage large
businesses, which operate
across various EU Member
States, from offering more
sustainable products
e. There are insufficient
incentives to reward products
based on their different
sustainability performances
1.C Other relevant market or policy-related challenges to making products more
sustainable in the EU (please specify) and/or other comments you may have:
500 character(s) maximum
2. Measures to make sustainable products the norm
2.A Design for sustainability - sustainability requirements for products
As set out in the CEAP, the Commission intends to set product design rules and
general product requirements to foster the overall sustainability of products in the
EU. Among other aspects, these rules should cover:
11
improving product durability, reusability, upgradability and reparability,
addressing the presence of hazardous chemicals in products, and increasing
their energy and resource efficiency;
increasing recycled content in products, while ensuring their performance and
safety;
enabling remanufacturing and high-quality recycling;
reducing carbon and environmental footprints;
restricting single-use and countering premature obsolescence.
In your view, how effective would the following measures be in achieving these
objectives? Please rate the choices below from 1 to 5, with 1 denoting low
preference and 5 high preference.
I do
not
1 2 3 4 5 know/
no
opinion
a. Set binding rules detailing, at product group level, what
actions producers are obliged to take to improve their
products’ durability, reusability, upgradability and reparability
(for example, for electronic/ICT products, setting a minimum
number of cycles during which the battery must function
properly)
b. Require producers/importers to prove that the design of
their products respects the following prioritization: (first
preference) that the product is capable of being reused
/repaired/shared; (second preference) that the product is
capable of being remanufactured/refurbished/upgraded; (
third preference) that the product is capable of being
recycled
c. Require producers/importers to prove that they have
assessed possible causes of failures and addressed them,
with a view to optimising product durability
d. Require producers/importers to prioritise modular design
of their products, so as to facilitate repair, remanufacture,
upgrade and disassembly (for example, for ICT products,
batteries, screens and back covers should be removable in
less than a defined number of steps).
e. Require producers/importers to ensure information on
repairability is provided on or with a product
f. Require producers/importers to ensure information on
access to repair services is provided on or with a product
12
g. Require producers/importers to offer product guarantees,
which could include "commitment to free repair as first
remedy" in case of failures and a "commitment to upgrade
the product periodically”
h. Require producers/importers to display a repairability
score on their products, in line with harmonized
requirements at EU level, to facilitate comparison of product
repairability
i. Require producers/importers to establish a repair network
for their products
j. Require producers/importers to ensure information on a
product’s average expected lifespan is provided on or with a
product
k. Require producers/importers to ensure information on the
chemical content of a product is provided on or with a
product
l. Ban the use of a substance or substances in a given
product, should such substances be found to inhibit product
recyclability
m. Require producers/importers to publish information on
how they have prioritised materials that are safe and
sustainable-by-design, and have substituted chemicals of
concern with safer ones whenever possible
n. Require additional information to be made available on
material sources, e.g. content in the product of critical raw
materials and minerals from conflict-affected and high-risk
areas
13
2.B Responsibility for information, including Digital Product Passport
One of the options considered for a new Sustainable Products legislative Initiative
is the development of digital ‘product passport(s)’, which would provide producers
and other key supply chain actors, consumers and market surveillance authorities
with information relevant for ensuring the sustainable management of a product
(maintenance, repair, re-manufacturing, recycling, control of compliance, etc.).
2.B.1 In your opinion, what information should be collected as part of such a
digital ‘product passport’?
I do
not
Strongly Strongly
Agree Neutral Disagree know /
agree disagree
no
opinion
a. Economic actors at the origin
of information (Manufacturer
/Service provider/Retailer
/Distributor/Recycler/ Providers
of Repairability services)
b. List of materials and
substances present in the product
c. Quantities of materials and
substances present in the product
d. Recycled content of each
material present in the product
14
e. Presence in the product of
hazardous chemicals, and if so,
their location
f. List of legislation and
standards that the product
complies with, or the technical
specifications that it fulfils
g. Results of compliance tests
against legislations, standards or
technical specifications
h. Expected lifespan of the
product
i. Information relevant for testing,
disassembly, maintenance,
repair or reassembly (e.g. test
protocol, disassembly process
and instructions, etc.)
j. Information on safe use and
instructions, where applicable
k. Information relevant to re-
manufacture and spare parts (e.
g. CAD technical drawings, 3D-
printing files)
l. Information on Product
Environmental and/or carbon
footprint, or other relevant
sustainability characteristics
15
m. Social conditions along the
value chain (e.g. working and
pay conditions; respect of human
rights)
n. Information on the origin of
product components
o. Information on material
sources (e.g. conflict-free
materials, responsible mining
etc.)
p. Any possession of
sustainability labels, such as the
EU Ecolabel
q. Information on how the
product should be recycled and
/or handled at the end of life
16
2.B.2 In your view, what are the biggest challenges to ensuring a successful
establishment and implementation of digital product passport(s)? Please select
your top preferences from the list below.
at most 3 choice(s)
a. Managing confidential data (for example making sure that information is
only available to those entitled to access it)
b. Minimising administrative burden by re-using data already uploaded on
existing databases and ensuring their interoperability
c. Managing the complexity of products and value chains and the quantity of
data that is required to make such a passport effective
d. Minimising the costs and environmental impacts involved in setting up a
digital ‘product passport'
e. Ensuring the relevance and reliability of the information included in the
passport
2.C Avoidance of destruction of unsold durable goods
The Commission intends to ban the destruction of unsold durable goods (e.g. home
appliances, textiles, electronic equipment etc.)
2.C.1 In your view, are there categories of products that should be excluded from
this ban?
a. Defective goods
b. Goods not complying with relevant legislation
c. Highly inefficient products
d. Defunct accessories/spare parts of products no longer on the market
e. Counterfeit products
f. Products that pose a health or safety risk
g. Products that are not usable after a certain date
2.C.2 What additional measures should be taken to decrease the amount of unsold
goods in the EU, thereby complementing this ban?
at most 4 choice(s)
a. Selling damaged products at a discounted price
b. Fostering donation schemes
c. Fostering reconditioning and remanufacturing schemes
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d. Fostering a producer ‘duty of care’, whereby producers take measures to
ensure that products are not damaged during distribution, transport or
storage
e. Fostering greater transparency by producers regarding their product
return rates and unsold goods policies
f. Boosting more sustainable business models such as on-demand
production
2.D Circular business models
2.D.1 Circular business model types
2.D.1.a The ways in which businesses operate strongly influence how products are
produced and consumed. The table below presents several (non-exhaustive)
categories of circular business models, together with a brief description of them.
How effective do you think these models can be in terms of encouraging more
sustainable production and consumption patterns? Please rate from 1 to 5, with 1
denoting low impact and 5 high impact.
I do
not
1 2 3 4 5 know /
no
opinion
a. Product-service systems (i.e. users do not buy the
product from manufacturers/owners but rather the service
associated with the product, e.g. car leasing. This means
that the manufacturer/owner is responsible for repairing and
maintaining the product, thus incentivizing better reparability
and potentially longer lifespan of the product)
b. Collaborative and sharing economy (i.e. where sharing of
products replaces purchasing, e.g. for power tools or other
products that consumers use only occasionally. As a result,
less resources are used to satisfy the same needs)
c. Reverse logistics (i.e. where the reverse transport of
products, from consumer to producer, is arranged in view of
repair or reuse. e.g. beer bottles or old phones)
d. On-demand production (i.e. where the production of
goods occurs only for those customers expressly requesting
them, thus preventing overproduction and waste)
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2.D.1.b Other relevant circular business models not included in the list above
(please specify):
500 character(s) maximum
2.D.2 Challenges
What in your view are the main barriers to successful deployment of more circular
business models in the EU? Please rate from 1 to 5, with 1 denoting low
importance and 5 high importance?
I do
not
1 2 3 4 5 know /
no
opinion
a. The profitability of these business models is not viewed
as sufficient, or is viewed as too high-risk
b. The initial investment costs and financial capital required
to establish such business models are too high
c. Banks and investors are often unwilling to provide the
credit and funding necessary to initially establish these
business models
d. There is a lack of demonstrable success stories or large-
scale projects demonstrating the business case for such
business models
e. There is a lack of tools and methods to measure (long-
term) benefits of circularity for businesses, including the
financial benefits
f. There is insufficient proof of adequate consumer demand
for these business models
g. Consumer awareness of and responsiveness to these
business models are insufficient
h. There is a lack of training for entrepreneurs/potential
entrepreneurs in how circular business models operate
i. There is a lack of the technical skills necessary to perform
the functions required by these business models (repair;
maintenance etc.)
j. These business models are more difficult for SMEs to
adopt, e.g. given the initial investment costs
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k. A clear regulatory framework to support such business
models is missing
2.D.3 Enabling circular business models
Taking as examples the models mentioned above, how in your view can the EU
best enable or regulate circular business models?
Please select the business model(s) for which you wish to provide a response, then
indicate your preferences from the list(s) of options that appear:
1. Product-service systems
2. Collaborative and sharing economy
3. Reverse logistics
4. On-demand production
2.D.3.a Product-service systems: please select your top preferences (max 5)
from the list below
at most 5 choice(s)
a. Provide guidelines on the various EU funding instruments, opportunities
and support mechanisms available to foster the creation of circular business
models
b. Strengthen maintenance and repair obligations for producers (such as on
the ease of separating product parts; the availability of spare parts etc.) to
encourage the adoption of these business models
c. Foster increased collaboration amongst the circular business community
and facilitate exchange of best practice/‘lessons learnt’
d. Develop tools and methods to better measure the (long-term) benefits and
financial viability of circular business models
e. Investigate the feasibility of harmonization at EU level of the certification
of competence for professional repairers and other professionals involved in
circular businesses
f. Require large producers, who offer repair and other services ‘in-house’, to
provide repair training programmes to independents, as well as training
certification
g. Set EU level targets related to adoption rates for circular business model
h. Disseminate information on cost effectiveness of such models
i. Introduce obligatory take-back schemes, to ensure products at end of life
are less likely to become waste and can e.g. be reused or remanufactured
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j. Facilitate market access for circular innovations by decreasing
administrative burden for new circular business models, e.g. by speeding up
approval procedures for novel products and application to existing funding
schemes, where appropriate
k. Prioritize circularity as a criteria or as part of a reward system in use of
public finances, e.g. by giving priority to circular business models in
financing schemes and in formulation of public tenders
l. Introduce a circularity certification/label/scoring system to promote circular
business models
2.D.3.b Collaborative and sharing economy: please select your top preferences
(max 5) from the list below
at most 5 choice(s)
a. Provide guidelines on the various EU funding instruments, opportunities
and support mechanisms available to foster the creation of circular business
models
b. Strengthen maintenance and repair obligations for producers (such as on
the ease of separating product parts; the availability of spare parts etc.) to
encourage the adoption of these business models
c. Foster increased collaboration amongst the circular business community
and facilitate exchange of best practice/‘lessons learnt’
d. Develop tools and methods to better measure the (long-term) benefits and
financial viability of circular business models
e. Investigate the feasibility of harmonization at EU level of the certification
of competence for professional repairers and other professionals involved in
circular businesses
f. Require large producers, who offer repair and other services ‘in-house’, to
provide repair training programmes to independents, as well as training
certification
g. Set EU level targets related to adoption rates for circular business model
h. Disseminate information on cost effectiveness of such models
i. Introduce obligatory take-back schemes, to ensure products at end of life
are less likely to become waste and can e.g. be reused or remanufactured
j. Facilitate market access for circular innovations by decreasing
administrative burden for new circular business models, e.g. by speeding up
approval procedures for novel products and application to existing funding
schemes, where appropriate
21
k. Prioritize circularity as a criteria or as part of a reward system in use of
public finances, e.g. by giving priority to circular business models in
financing schemes and in formulation of public tenders
l. Introduce a circularity certification/label/scoring system to promote circular
business models
2.D.3.c Reverse logistics: please select your top preferences (max 5) from the list
below
at most 5 choice(s)
a. Provide guidelines on the various EU funding instruments, opportunities
and support mechanisms available to foster the creation of circular business
models
b. Strengthen maintenance and repair obligations for producers (such as on
the ease of separating product parts; the availability of spare parts etc.) to
encourage the adoption of these business models
c. Foster increased collaboration amongst the circular business community
and facilitate exchange of best practice/‘lessons learnt’
d. Develop tools and methods to better measure the (long-term) benefits and
financial viability of circular business models
e. Investigate the feasibility of harmonization at EU level of the certification
of competence for professional repairers and other professionals involved in
circular businesses
f. Require large producers, who offer repair and other services ‘in-house’, to
provide repair training programmes to independents, as well as training
certification
g. Set EU level targets related to adoption rates for circular business model
h. Disseminate information on cost effectiveness of such models
i. Introduce obligatory take-back schemes, to ensure products at end of life
are less likely to become waste and can e.g. be reused or remanufactured
j. Facilitate market access for circular innovations by decreasing
administrative burden for new circular business models, e.g. by speeding up
approval procedures for novel products and application to existing funding
schemes, where appropriate
k. Prioritize circularity as a criteria or as part of a reward system in use of
public finances, e.g. by giving priority to circular business models in
financing schemes and in formulation of public tenders
22
l. Introduce a circularity certification/label/scoring system to promote circular
business models
2.D.3.d On-demand production: please select your top preferences (max 5) from
the list below
at most 5 choice(s)
a. Provide guidelines on the various EU funding instruments, opportunities
and support mechanisms available to foster the creation of circular business
models
b. Strengthen maintenance and repair obligations for producers (such as on
the ease of separating product parts; the availability of spare parts etc.) to
encourage the adoption of these business models
c. Foster increased collaboration amongst the circular business community
and facilitate exchange of best practice/‘lessons learnt’
d. Develop tools and methods to better measure the (long-term) benefits and
financial viability of circular business models
e. Investigate the feasibility of harmonization at EU level of the certification
of competence for professional repairers and other professionals involved in
circular businesses
f. Require large producers, who offer repair and other services ‘in-house’, to
provide repair training programmes to independents, as well as training
certification
g. Set EU level targets related to adoption rates for circular business model
h. Disseminate information on cost effectiveness of such models
i. Introduce obligatory take-back schemes, to ensure products at end of life
are less likely to become waste and can e.g. be reused or remanufactured
j. Facilitate market access for circular innovations by decreasing
administrative burden for new circular business models, e.g. by speeding up
approval procedures for novel products and application to existing funding
schemes, where appropriate
k. Prioritize circularity as a criteria or as part of a reward system in use of
public finances, e.g. by giving priority to circular business models in
financing schemes and in formulation of public tenders
l. Introduce a circularity certification/label/scoring system to promote circular
business models
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2.E Incentives for circularity
Regulatory, market and reputational incentives are necessary to encourage more
sustainable production and consumption patterns. The Commission is examining
what the most effective measures in this respect are, and how products can be
rewarded based on their sustainability performance.
In your view, how important are the following measures? Please rate the choices
below from 1 to 5, with 1 denoting low preference and 5 high preference.
I do
not
1 2 3 4 5 know /
no
opinion
a. Modulation of fees on the sustainability of products under
Extended Producer Responsibility schemes (e.g. producers
who place products that are more easily recyclable on the
EU market pay reduced fees)
b. Recognizing voluntary commitments by producers to
increase the sustainability of their products
c. Making better use of standardisation to promote
sustainability
d. Increasing transparency on the performance of products
as regards sustainability, for instance by identifying different
levels of sustainability performance at EU level
e. Better use and promotion of voluntary sustainability
labels, such as the EU Ecolabel
f. Improving access to finance for the production and
consumption of more sustainable products
g. Developing and implementing mandatory Green Public
Procurement criteria and targets
2.F Measures to make sustainable products the norm: other comments
Other comments you may have relating to any of the sections covered in ‘Question
2 – Measures to make sustainable products the norm’:
500 character(s) maximum
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3. Compliance with and enforcement of sustainability requirements for
products
3.A Compliance with requirements and enforcement of sustainable product policy
are crucial for achieving results. Enforcement can be carried out via market
surveillance within the EU Single Market and via customs checks at its borders.
Market surveillance is the responsibility of the Member States and was the object of
the recently revised Regulation (EU) 2019/1020 of 20 June 2019 on market
surveillance and compliance of products. How do you think the European
Commission could contribute further to this dimension? Please rate from 1 to 5
each action presented in the table, with 1 denoting low importance and 5 high
importance.
I do
not
1 2 3 4 5 know /
no
opinion
a. Set verification targets for the products deemed most
likely to be non-compliant (e.g. electronic gadgets)
b. Support Member States in the distribution of surveillance
tasks per product category (e.g. Member State A
responsible for construction materials; Member State B for
heating & cooling equipment etc.)
c. Require third-party certification or inspection to simplify
the work of Member State enforcement authorities
d. Accompanying measures from the European Commission
to Member States (e.g. guidance, support etc.)
e. Create a central reporting point/website to enable
consumers to provide feedback on products that do not
meet their sustainability requirements
3.B According to your experience with the Ecodesign Directive (if any), are there
any market surveillance issues related to the current Directive that you think need
to be considered in a future Ecodesign legislation?
500 character(s) maximum
Optional additional comments
25
If you wish to add further information, comments or suggestions (relevant to the
scope of this Public Consultation), please do so here:
2000 character(s) maximum
If you wish to upload a supporting file, please do so here
Only files of the type pdf,txt,doc,docx,odt,rtf are allowed
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