Anne Claire Rasselet

On 21 April 2022, EGMF issued a position paper on the ‘Sustainable consumption of goods – promoting repair and reuse’ initiative, currently under development by the European Commission and expected to be adopted in Q3 2022.

This position paper aims to provide additional comments on several aspects and potential measures that were outlined in the Commission’s public consultation questionnaire, to which EGMF responded.

These are our key messages:

• The new ‘right to repair’ and its financial impacts need to be clearly defined, underlining that B2C and B2B should be regulated in specific ways.
• The economic and environmental dynamics of companies’ operations and the products they use need to be considered when analysing measures like extended legal guarantees and mandatory repairs in order to avoid extending the use of inefficient products and maintenance negligence.
• ‘Second-hand’ and ‘refurbished’ goods need precise definitions, and any measures must not ignore the various issues related to potential purchasing incentives, and the responsibility for performance and risk evaluations.
• We raise caution about incentivising repair by independent repairers, specifically when it comes to electrical and electronic equipment, and highlight the risks of data sharing with external entities. We also stress on the necessity to raise awareness on the importance of maintenance to ensure the safety and optimum lifetime of all products.

Find more details and examples in our position paper here .

EGMF, and 16 fellow European industry associations, welcome the European Commission’s initiative for a European standardisation strategy that aims to support the digital transformation and the green transition. Standards are at the core of the EU Single Market and the New Legislative Framework for products, and key to the EU’s economic integration that is imperative in today’s geopolitical context.

We support the ambition to take a more proactive approach towards strategy setting for standards. The proposed actions should consolidate the strengths of the existing system and consequently preserve the inclusive and successful market-driven nature of the standardisation processes.

Based on the observations of industry leaders and experts active in standardisation, we urge policy-makers to consider the following elements when implementing the strategy and remain available for a constructive dialogue on how the EU can lead in standardisation.

Together we set out our recommendations.

Download our joint industry statement.

The NRMM Stage V FAQ has been updated by the ITF NRMM group (which EGMF is part of) to reflect recent amendments to the Regulation (EU) 2016/1628, namely the Regulations (EU) 2020/1040 and (EU) 2021/1068 which were published to cover transitional provisions in order to address the impact of the COVID-19 crisis on machines and their transition engines in specific power categories.

Some additional questions and answers have been added to clarify specific scenarios: for instance, the time limit for the sale of machine if the latter are in stock and have an engine of an emission stage prior to Stage V installed; or whether an engine or a machine is considered as placed on the market in two cases (the engine or a machine is at a distributor within the EU, or if there is an engine within the premises of an OEM within the EU). Additionally, the ITF NRMM drafted two new sections related to the acceptance of equivalent engine emission type-approvals, and also the impact of Brexit on NRMM engines and machines.

Consult the document here.

Several types of outdoor power equipment are impacted by the Directive 2011/65/EU, the so-called RoHS 2 Directive. Therefore, EGMF submitted on 14 March its comments on the RoHS revision inception impact assessment roadmap. The purpose of this roadmap is to provide an initial non-exhaustive list of possible options identified by the European Commission regarding the review of the RoHS Directive, which is scheduled for Q4 2022.

EGMF paper aims to share our key observations and asks regarding the revision of the RoHS Directive:

• The Directive has been effective, has prevented the multiplication of legislation restricting use of hazardous substances at national level and possible inconsistencies and has played a positive role at international level.
• However, the Directive still needs to be improved, especially the lengthy and inefficient process to renew exemptions, resulting in uncertainties for manufacturers.
• As regards the RoHS revision roadmap, EGMF supports a combination of options 2 and 3, namely ‘Simplify and clarify the RoHS Directive by introducing and revising legislative measures’ and ‘Transform the RoHS Directive into a regulation’. However, we oppose to options 4 and 5 that aim to repeal the RoHS Directive and incorporate its provisions into the REACH Regulation and/or the upcoming Sustainable Products Initiative.

To consult the document click here

EGMF, together with 24 associations representing key European industry stakeholders, urge the EU institutions to continue to make EU trade agreements a priority, opening new markets for trade and investment.

More concretely, we first call on the EU to ensure that Free Trade Agreements enter into force as soon as possible after negotiations are concluded. In addition, we support an expansive EU bilateral trade agenda to remain competitive at international level.

Our joint statement has been published on the occasion of the French Presidency conference on trade policy & European strategic autonomy.

Read the full statement here.