Viscom : achieves annual forecast for 2020 in difficult market environment






Brussels, 8 June 2021

Orgalim position on the Sustainable Products Initiative

Contents

Executive Summary………………………………………………………………………………………………………………………………….

2

Challenges to make products sustainable ……………………………………………………………………………………………..

5

1.1.

Market-related statements explaining why products sold in the EU are not more sustainable ………………..

5

1.2.

Policy-related statements explaining why products sold in the EU are not more sustainable ………………….

6

Measures to make sustainable products the norm ………………………………………………………………………………….

7

2.1.

Design for sustainability – sustainability requirements for products ……………………………………………………

7

2.2.

Responsibility for information, including Digital Product Passport(s)………………………………………………..

11

2.2.1.

Key principles for successful Digital Product Passport(s) ………………………………………………………….

11

2.2.2.

Opportunities of Digital Product Passport(s) ………………………………………………………………………….

12

2.2.3.

Challenges of Digital Product Passport(s)………………………………………………………………………………

13

2.2.4.

Content of Digital Product Passport(s) ………………………………………………………………………………….

14

2.2.5.

Digital aspects of Digital Product Passport(s) …………………………………………………………………………

20

2.3.

Avoidance of destruction of goods………………………………………………………………………………………………

21

2.4.

Circular business models ……………………………………………………………………………………………………………

21

2.5.

Ecodesign ……………………………………………………………………………………………………………………………….

22

2.6.

Incentives for circularity …………………………………………………………………………………………………………….

23

Compliance with, and enforcement of, sustainability requirements for products ………………………………………

26

2

Executive Summary

Orgalim represents Europe’s technology industries, providing innovative technology solutions which are underpinning the twin green and digital transitions and can unlock a greener, healthier and more prosperous future for the European Union and its citizens. Our industries welcome the European Commission’s Sustainable Products Initiative as a key measure to further optimise the way resources are used throughout the economy and society. Our industries stand ready to continue providing innovative, cutting-edge technology solutions and sustainable products and to continuously improving the performance and overall sustainability of products, striving for excellence and ensuring that consumers, businesses and the environment benefit from competing, innovative, cutting-edge technology solutions. For our industries, high product quality is a core competitive argument and this goes hand in hand with sustainability, as for example durability is one of the main objectives of the Sustainable Products Initiative.

The Sustainable Products Initiative (SPI) is an important opportunity for a win-win situation for the environment and the economy, and applying digital solutions for product information, such as Digital Product Passports (DPP), could have benefits for some end-users such as consumers as well as for our industries – provided that they are properly designed according to the key principles below:

  • To secure the functioning of the Single Market – one of the EU’s success stories and major achievements – requirements must be harmonised at EU level. “The stronger the EU Single Market, the better for the circular economy” should be a guiding principle for future action. We are concerned about different national provisions and mandatory requirements on products not aligned with the EU requirements.
  • An impact assessment must always be conducted to ensure that their implementation will be workable, proportionate and will contribute to a circular economy. There must be proven environmental benefits that exceed the costs to industry.
  • Ensuring effective enforcement and market surveillance will be of the utmost importance for the success of the application of the SPI and DPP and will be even more necessary in the future to ensure a level playing field.
  • New requirements for products must follow the New Legislative Framework (NLF) including the application of the CE marking and declaration of conformity. Product requirements must be based on applicable internal market regulations, to ensure a level playing field and to adjust relevant provisions to specifically solve uncertainties related to definitions, requirements and responsibilities of the different actors.
  • Requirements must be based on scientific assessment methods through recognised European or ISO /IEC/ITU international standards and must be reliable and verifiable. Standardisation bodies and global standards should be used in the design of the SPI and DPP requirements.
  • The “SMERC” principle must be applied:
    • Specific – requirements must be considered on a product group-specific basis. Even within the same product group and within individual categories of equipment in our sector, the products and their environmental impact differ significantly, especially depending on ambient and operating conditions.
    • Measurability – the parameters must be clearly determined and measurement methods must be accurately defined.
    • Enforceability – it must be possible to verify and enforce requirements through market surveillance.
    • Relevance – new parameters and corresponding requirements must be relevant for the environment, the users and applicable even within the specific life cycle phase(s). There must be evidence of clear and significant potential for improvement.
    • Competitiveness – there must be no significant negative impact on the industry’s competitiveness and the competition must be fair.
  • We support information at product level when it is possible and relevant.
  • The industry should be involved as early and as fully as possible in the development of the SPI and the DPP. The sector know-how is extremely important.
  • The burden put on companies must be proportionate. Additional requirements should be kept as minimal as possible and must be manageable and affordable for SMEs.
  • Information should respect confidentiality related to protectable trade secrets and secure IP protection.
  • There is no one-size-fits-allapproach. SPI requirements and DPP must be established on a sector-by-sectorand product-by-productbasis, taking into account the differences in products (and differences between business-to-consumer B2C and business-to-business B2B products) and the information that is relevant to them. It is very difficult to respond to the Commission SPI public consultation questionnaire because the

3

answers to the questions depend very much on the types of products. Differentiating consumer (B2C) and professional (B2B) products in the context of material efficiency is crucial. Incentive structures, customer behaviour, customer relations, pricing, material composition and market dynamics distinguish both sectors. To carry forward the success of the SPI, a case-by-case assessment remains of high importance.

  • Requirements should be technology-neutral to ensure a variety of technology options applicable to sustainable design requirements and choices related to material efficiency.
  • Requirements should not hinder the development of new innovations, business models and products. Decisions on technology development, product design and technical requirements must be left to the manufacturers who are the technical experts.
  • The EU should support European companies to put in place theses new SPI and DPP measures as well as the EU Member States who will control these measures.
  • We strongly oppose third-party certification or inspection. Self-assessmentis just as valid a procedure and offers the same level of safety benefits as any conformity assessment procedure supported by a third-party(e.g. notified body). Furthermore, it would be unacceptable for industries to be required to bear the costs of third- party certification or inspection because Member States lack the capacity and resources to undertake sufficient market surveillance and enforcement activities.

We have the following additional recommendations on the proposed Digital Product Passport(s) (DPP):

  • DPP should be designed to support circular economy principles.
  • DPP should be properly designed by policymakers together with the industry given its considerable knowledge and expertise about information in value chains, existing systems and what is required for a product passport to work in practice.
  • We have a general concern about the protection of confidential data/information. It is of the utmost importance to ensure the confidentiality and protection of companies’ know-howand trade secrets.
  • Information on product characteristics must be meaningful, easy to understand, reliable, comparable, verifiable and have an improvement potential from a sustainability perspective. The quality of data is important and data has to be of added value. The recent ‘bad example’ of the ECHA SCIP database must not be replicated.
  • As to the scope of DPP, we recommend to start with a small number of products and simple criteria based on data already available rather than with a wide scope and complex criteria. We very much welcome the intention of the Commission to start with a limited number of prototype projects. It is important for DPP to be tested in smaller fields of application before its use becomes more widespread.
  • The information content in the passports should be limited to regulatory requirements because is it impossible for companies to obtain non-mandatory information from their global and complex supply chains.
  • Consistency and alignment with existing requirements under other EU laws (e.g. REACH Regulation, ECHA SCIP database, etc) is needed to avoid the duplication of efforts in providing information. The passports must be linked to – and ideally extract data from or replace – existing databases and avoid duplications and overlaps causing business an unnecessary administrative burden.
  • There must be clear responsibilities for all actors (e.g. suppliers, manufacturers, retailers, repairers, recyclers) providing data, accessing and sharing information from the DPP.
  • DPP requirements must be verifiable and enforceable to guarantee a level playing field.
  • The appropriate and reasonable level of detail of information needs to be determined.
  • We welcome that for specific value chains or specific product groups, stakeholders will be invited to identify relevant data and agree on access.
  • We also welcome that the DPP is expected to be a decentralised system linked with the European Dataspace for Smart Circular Applications, importance of quality of data, etc. But it is important that the information / data required will be standardised in a harmonised EU format set by the Commission.
  • The DPP should be similar to the EU Product Database for Energy Labelling (EPREL) database where some information can only be accessed by the authorities and is subject to higher security safeguards.
  • Our general position on the proposed content of the DPP is as follows (see related explanations on pages 14 to 20), noting that it will depend on the type of products that will be within the scope of the passport as well as on how these proposed requirements will be formulated in details:
    • We agree with the following proposals:
      • List of legislation and standards that the product complies with, or the technical specifications that it fulfils
      • Information on safe use and instructions, where applicable

4

  • We are neutral on the following proposals:
    • Information relevant for testing, disassembly, maintenance, repair or reassembly
    • Information on Product Environmental and/or carbon footprint, or other relevant sustainability characteristics
    • Any possession of sustainability labels, such as the EU Ecolabel
    • Information on how the product should be recycled and /or handled at the end of life
  • We disagree with the following proposals:
    • Economic actors at the origin of information
    • Recycled content of each material present in the product
    • Results of compliance tests against legislations, standards or technical specifications
    • Expected lifespan of the product
  • We strongly disagree with the following proposals
    • List of materials and substances present in the product
    • Quantities of materials and substances present in the product
    • Presence in the product of hazardous chemicals, and if so, their location
    • Information relevant to remanufacture and spare parts (e.g. CAD technical drawings, 3Dprinting files)
    • Information on the origin of product components
    • Information on material sources (e.g. conflict-free materials, responsible mining etc.)

As to circular business models:

  • Policymakers should not develop business models. They need to focus on the promotion of business models that are decreasing the environmental footprint.
    Policymakers should accommodate both existing and new business models in terms of placing products on the market and in terms of service activities.
  • A level playing field must be secured. Manufacturers want to see that, if they are following rules on circularity, there should be an incentive for people to choose these products. Otherwise, less reputable manufacturers may not follow the rules.
  • We strongly support the circular business model of product-servicesystems.

We strongly support the Ecodesign instrument which has delivered for the consumer, the industry and the planet through its holistic approach of minimising life cycle impacts, based on scientific evidence, at the least life cycle cost – setting measurable, enforceable requirements case-by-case in big saving areas. We also support the Ecodesign Directive because it provides an EU harmonised framework in accordance with the New Legislative Framework for setting the Ecodesign requirements on energy related products, and as such ensures the functioning of the EU Internal Market for these products. Should the scope of the existing Ecodesign Directive be extended to non-energy related products:

  • We recommend maintaining the existing framework of the Ecodesign Directive for energy-related products to guarantee legal and investment certainty, confidence and trust in the market in the ongoing implementation.
  • Adding new products within the scope of Ecodesign should be proportionate and we defend the method of establishing implementing measures in the existing Ecodesign Directive as stipulated in its Article 15.

Regarding incentives:

  • We strongly support developing and implementing mandatory Green Public Procurement (GPP) criteria and targets, improving access to finance for the production and consumption of more sustainable products.
  • As regards Extended Producer Responsibility (EPR), EPR-related directives (such as the WEEE Directive) have certainly achieved positive results including increased collection volumes and improved recycling results and we recognise the role of producers in the proper collection and treatment of their end-of-life products. However, producers alone cannot achieve the entirety of the objectives and any extension of EPR’s obligations should be carefully analysed from that perspective. Successful EPR solutions depend not only on producers but also on the effective cooperation of several actors such as municipalities, retailers, consumers, waste companies, recyclers, and enforcement authorities. This is why we call for a true ‘shared responsibility’ approach: all actors involved in the collection and treatment of different waste streams, not only producers, need to respect the same obligations to achieve the collection and recycling targets of EPR-related directives.
  • We understand the reasoning behind the modulation of fees on the sustainability of products under EPR schemes but please consider the concerns mentioned in this document (on page 25) as we doubt it will work in practice for Waste Electrical and Electronic Equipment (WEEE) and it will have an impact on product design.

5

Challenges to make products sustainable

1.1. Market-related statements explaining why products sold in the EU are not more sustainable

  • We AGREE with the following statements:
    • “More sustainable products are often too expensive for households with lower incomes”. Sometimes sustainability costs more. The total cost of ownership (TCO) of such products needs to be considered as many sustainable product are less expensive in the long run. Some education for citizens and consumers on sustainable products and TCO is also needed.
    • “The quality of second hand goods cannot be guaranted or is difficult to assess”. It depends on the type of products (B2C or B2B products). We agree with respect to professional products due to safety reasons because for these products there are already systems in place to secure the safety of the second- hand products. Manufacturers are not responsible for the quality of second hand products. There are questions about the responsibility regarding the quality and safety of second hand products. We need to differentiate between products that are remanufactured/refurbished by the manufacturer or dealer and products sold second hand by consumers themselves. There are also questions over which standards would apply; those applicable when the product or equipment was first sold on the market or the newer/updated standards?
  • We are NEUTRAL on the following statements:
    • “Economic actors do not have adequate and reliable information on the sustainability of products” because we are questioning several terms. What are the definitions of “economic actors” (only consumers or also professionals)? What are the definitions of “information on the sustainability of products”? (this is too vague) and of “adequate and reliable” information?
    • “Products such as electronics become obsolete quickly because of technological innovations” due to the fact that our answer depends on the type of electronics and also on the use by consumers. There is an enormous difference here between B2C and B2B products. Also of importance are the definitions of “obsolete”, (what kind of obsolescence we are talking about?) and of “planned obsolescence”. Our industries strongly recommend to use EU standards and guidelines to define and measure these concepts.
    • “Many products are not designed to be easily repaired or upgraded”. What does “easily repaired or upgraded” mean? And specifically, what does “easily” mean?
    • “The cost of repairing a product is too high, in comparison with buying a brand new product“. Both depend again on the type of products (B2C or B2B products?). We agree for consumer products but not for professional products. Furthermore, there are differences regarding the costs of repairing professional versus consumer products. As safety comes first, professionals are the ones who repair B2B products. There are several reasons why products are not designed to be easily repaired or upgraded. When it comes to the question of new purchases or repairs, consumers often decide against a repair for economic reasons, even though it would make sense from an environmental perspective. The decisive factor here is not so much the absolute cost of repair, but the relationship between the purchase price and the cost of repair. In addition, it is not uncommon for some consumer appliances to be replaced by new ones, even though they still function perfectly.
  • We DISAGREE with the statement “Some products are designed to break down after a certain amount of time (planned obsolescence)” because this is not the case in our industries. European technology companies, nurturing a long-termreputation and credibility, simply avoid designing products of short durability. Planned ageing is not, and cannot be, a long-termsustainable business model.

This is an excerpt of the original content. To continue reading it, access the original document here.

Disclaimer

Orgalim – Europe’s Technology Industries published this content on 08 June 2021 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 08 June 2021 08:36:00 UTC.

Publicnow 2021

Leave a Reply

Your email address will not be published. Required fields are marked *