The EU Commission presented a legislative package at the end of March 2002, which shall provide consumers with better product information enabling them to make more environmentally friendly purchase decisions. A further proposal shall follow in autumn 2022, aimed at product reparability and reuse. Regarding the Commission’s consultation, AK stated that longer product sustainability is a top priority and consumers’ views have to be strengthened.

Promoting product sustainability

From AK’s point of view it has to be ensured that products last longer and will not wear out prematurely; this would remove the necessity of repair and any practical and legal problems resulting from it. It is therefore of great importance to extent the legal warranty period. Currently, a warranty period of two years is standard, independent of the product life cycle. This should be extended to at least five years, in particular for long lasting products.

Software updates are of vital importance, in particular for smart products (e.g. the ability to use mobile phones longer). The two-year period for updating products with digital elements is far too short and forces customers to invest in new devices even though their old ones could otherwise be used without problems.

Right to choose between repair and replacement

From AK’s point of view, consumers’ legal rights to choose between repair and replacement should be retained rather than determining repair as the primary measure to be taken for consumers in case of a warranty claim. Compared to repair, replacement obligations represent the greater incentive for companies to make consumer goods more sustainable. If a product is taken back because no replacement is available, labelling it “refurbished” should be mandatory before it is sold again. It is also significant that consumers do currently not get any information on durability or reparability. Important information, for example in form of a product passport, can support consumers in making environmentally and employee-friendly purchase decisions.

Repair market must not become a monopoly

AK warns against letting the repair market become a monopoly, where only one body can repair a product. This would have a negative impact on the price development of repairs. Hence, a promotion of independent repair services of the socioeconomic sector is urgently required in AK’s opinion, as this would have a positive effect on the local labour market. The right to repair must already be established at the production process, whereby the environmental product design acts as the regulating factor. Therefore, manufacturers should be encouraged to make their products fundamentally more sustainable. For example, a modular design could provide for individual damaged components to be exchanged or updated to match the latest technical standard without replacing the entire device or appliance. Of importance in this connection is also the standardisation of product parts and interfaces of important modules, which at best should be available from several providers, following for example the EU-wide harmonisation of chargers, which just entered the final negotiating phase.

Further information:

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

AK EUROPA: AK consumer study proves great interest in sustainability

AK EUROPA Position Paper: New Circular Economy Action Plan: For a cleaner and more competitive Europe

AK Wien: Study on sustainable consumption (German Only)

European Commission: Sustainable consumption von goods – promoting repair and reuse