Towards an EU Product Policy framework contributing to the Circular Economy

APPLiA Home Appliance Europe supports the European Commission’s work to examine options and actions for a more coherent product policy framework of the different strands of work related to circular economy, while preserving the single market, competition and innovation.

As it is not possible to provide full answers to the online survey, we have outlined below some more general comments to complement APPLiA’s response to the European Commission’s public consultation on “Towards an EU Product Policy Framework contributing to the Circular Economy.” We look forward to cooperating further with the European Commission as it develops its ideas and activities in this field.

Key Messages  

  • APPLiA supports initiatives and policy that contribute to a more successful circular economy that brings together all societal actors. APPLiA believes that sharing best practices and using market-based incentives should be prioritised to drive a circular culture.
  • While we agree the EU should set rules for products on the European market to limit their impact on the environment, product characteristics should only be regulated by law if there is actual evidence of a need for regulation with relevant requirements that can be measured accurately and reliably. Market surveillance must have the sufficient means to ensure fair competition and guarantee a high degree of legal certainty and level playing field for all actors.
  • European household manufacturers are increasingly subject to a conflicting regulatory landscape. Policymakers can pursue various routes to move towards a more circular economy but need to consider the consequences of their choices, and the trade-offs these inevitably yield.
  • APPLiA firmly believes that product legislation should follow the Better Regulation agenda to ensure coherence and legal certainty. Where necessary, all future legislation should be based on the New Legislative Framework. Any assessment method used as the basis for legislation should correspond to real-life conditions of use.

Download our Position Paper