EGMF comments on the ‘Sustainable consumption of goods – promoting repair and reuse’ Initiative public consultation

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.