The Regulation for setting ecodesign requirements for sustainable products and the Directive as regards empowering consumers for the green transition are the two essential components of the circular economy package. Despite the basically to be endorsed thrust, from AK’s point of view, some passages of the Commission proposals require improvement and concretisation respectively.

Sustainable products

The proposal for ecodesign regulation provides for extending the scope to all physical products. This is a positive step from AK’s point of view as not only energy-related, but in many cases also other products are a major burden on the environment and as a result have to be included, such as furniture, building materials or sports equipment/goods. Furthermore, ecodesign does no longer exclusively focus on improving energy efficiency, but also on other product requirements; sustainability or repairability are coming to the fore. Apart from these performance-related requirements sufficient information must also be made available to consumers to enable them to make a knowledge-based and sustainable purchase decision. In this context, AK demands binding rules as regards the visibility of information on respective products and product packaging to ensure that essential product information is not hidden and well visible prior to a purchase. However, all these points refer to general rules; there are currently no concrete characteristics for certain products, which makes a final assessment not yet possible. To realise social sustainability, AK also supports the introduction of a product passport with target group specific information, as well as the approach of banning the destruction of unsold goods.

Empowering consumers

In its second proposal within the scope of the package on empowering consumers, the Commission proposes to expand information obligations. From AK‘s point of view, these represent a useful tool to create incentives for companies to provide durability guarantees. Mandatory information also about the fact that a company has not given any durability guarantees increases the visibility of the products of those manufacturers who have made such a promise. At the same time, consumers will be able to make better comparisons between products. Against this background, limiting these negative information obligations to energy-using equipment has to be rejected.

The proposal also includes a ban on generally worded environmental or green statements. However, these should not only refer to statements in text form but also to other forms of communication. To ensure effective protection against unfair trade practices, the ban should be extended to general statements on social impact (e.g. “fairly made”) as in this area the risk of deception is similarly high.

Circular economy package alone not sufficient

On their own, the legal acts, introduced within the scope of the circular economy package, are not sufficient to achieve a green and just transition. Hence, a parallel amendment of other, thematically related EU regulations is therefore deemed necessary. These include among other the Directive on certain aspects concerning contracts for the sale of goods and the Directive on representative actions for the protection of the collective interests of consumers to guarantee warranty claims on the one hand and to give consumer organisations the opportunity to bring action on the other. In this context, AK demands the creation of a more sustainable European warranty law, which provides for minimum product life cycles and long-term software updates.

Further information:

AK EUROPA Position Paper: Circular Economy Package – Making sustainable products the norm

AK EUROPA: New circular economy package to facilitate informed purchase decisions

AK EUROPA: AK consumer study proves great interest in sustainability