22.11.2022
EN
Official Journal of the European Union
C 443/127
Thinking in the material cycle shows the enormous need for change.
By way of example, higher recycling rates should go together with minimum quotas for use of recycled material, or the theoretical recyclability (3) of products should be consistent with the technical feasibility of recycling and the practical implementation of recycling measures.
In the plastics sector, for example, many changes are needed in design and production before secondary raw materials are treated differently from primary raw materials (4).
Recycling is also an opportunity for Europe.
For example, high-quality metallic minerals are imported as raw materials or products and then, after use, are disposed of or re-dispatched into the world almost for free; this particularly includes cars and electronic scrap.
These should be regarded as reusable materials and treated as such.
Dismantling, processing and recycling benefit the climate, but also create significant added value and jobs (5).
In all of this, it is also crucial to keep the economic, environmental and social balance in mind.
3.10.3.
The EESC welcomes the proposal to deal with unsold goods, but a more ambitious approach is possible.
The destruction of products that remain intact, including new, returned and repairable products, is undesirable for society because it is tantamount to wasting resources.
For the EESC, the Commission proposal to initially encourage only documentation by businesses while exempting small and medium-sized enterprises (SMEs) does not go far enough.
The mere possibility of effecting stronger measures through delegated acts casts doubt on whether the objectives will actually be achieved.
The EESC supports a ban on destroying unsold products, provided they are not dangerous.
Businesses and retail platforms should also be asked to work on business practices that significantly reduce the number of returned products and unsold stocks.
At the same time, consumers should be made aware of the environmental impact of returning goods.
3.11.
Economic aspects 3.11.1.
The EESC points out that the proposed Regulation is in principle welcome from the point of view of SMEs, but is also viewed with scepticism.
SMEs have only limited (human) resources at their disposal.
In particular, the support measures referred to in the Regulation should be geared to the needs and requirements of SMEs.
Furthermore, SMEs are having difficulties in accessing the required public procurement procedures.
Solutions should therefore be sought to enable them to participate in these procedures.
Finally, from an SME perspective, it is necessary to ensure complementarity between the sustainable product regulation and product-specific rules.
This is to avoid duplication of costs and administrative burden.
3.11.2.
Repairers have a key role in ensuring that products last.
It should therefore be made easier for repairers, socio-economic businesses specialising in re-use and civil society/local repair initiatives to take up their place in this circular model.
In Germany and Austria, for example, it has proven worthwhile for repair initiatives to take out repair insurance, which at the same time entitles them to carry out repairs.
3.12.
New circular business models (6) are identified as an important tool in the Communication.
These must be attractive, appealing and act as an incentive for businesses and consumers, and ensure decent working conditions.
Models of this kind already exist in practice, such as the sharing economy, product-as-a-service and pay-per-use.
The EESC suggests encouraging use of the existing best practice platforms and adapting them to the current challenges of the circular economy.
Currently listed examples include Baukarussell — materials are offered to new users following demolition or conversion works — and repair networks that bring together consumers and repairers.
However, it should be noted that many databases are not so attractive for contributors and users.
(3) (4) (5) (6)
Pomberger, R. (2020).
Über theoretische, praktische und reale Recyclingfähigkeit, https://doi.org/10.1007/s00506-020-00721-5, https://doi.org/10.1007/s00506-019-00648-6 Communication on A European Strategy for Plastics in a Circular Economy, COM(2018) 28 final.
OJ C 220, 9.6.2021, p. 118.
See INT/778 on Innovation as a driver of new business models (exploratory opinion) (OJ C 303, 19.8.2016, p. 28).