Ecommerce Europe contributed to the public consultation on the sustainable consumption of goods and the promotion of reuse and repair.
We believe that re-thinking the way we produce and consume products represents a crucial driver for the transition to a circular economy. Achieving long-lasting changes will require the contribution of all actors, as well as ambitious policy changes.
In our opinion, the initiative, as it is approached in the public consultation, does not sufficiently address the scale and complexity of the question of promoting repair and reuse. We are concerned that the current approach focuses exclusively on the tools (a “Right to Repair” for consumers), rather than on the objectives of the initiative. We encourage the European Commission to adopt a clear and holistic plan that can create real changes in the way we produce and consume products in the EU.
We believe an initiative on promoting repair and reuse should pursue two complementary objectives, developed further in our position paper:
Firstly, the development of a full-fledged European market for repair services and for second-hand, repaired and refurbished products. Our priority should be ensuring better design, facilitating repair and access to spare parts, as well as ensuring the growth of both the repair services market and the second-hand and refurbished products markets in the EU. These steps represent pre-conditions to the second objective, as well as to some of the measures envisaged by the European Commission.
Secondly, a long-lasting shift towards repair and reuse. We recommend focusing on the objective of fostering affordable, sustainable, quality repair services and balanced responsibility throughout the supply chain, rather than focusing on a single angle, such as consumer policy. We do, however, continue to advocate for maximum harmonisation of consumer law in the EU to create legal certainty for consumers and businesses, notably in the second-hand and refurbishing market.
For more information, you can consult our position paper.