Our answer supports harmonised definitions of circular economy actors, such as repairers and refurbishers, provided they are inclusive and aligned with existing definitions under ecodesign legislation. We also support digital compliance information requirements for product manufacturers, including for products sold via e-commerce platforms, and call for increased market surveillance efforts. If digital compliance information is provided via the digital product passport (DPP), interoperability and accessibility will be crucial, particularly for repairers, refurbishers and end-of-life actors.
Aligning the NLF with the EU's circular economy objectives and realities requires a clear distinction among new products, substantially modified products, and repaired or refurbished products. Whereas new and substantially modified products should be subject to conformity assessment, safety and compliance requirements, repair and refurbishment should not be required to undergo processes and assessments aimed at new products. Similarly, repairers and refurbishers should not be subject to requirements intended for original manufacturers or remanufacturers, as these would otherwise significantly hinder circular business models in reuse, repair, and refurbishment, as well as social circular enterprises across Europe.
The revision of the NLF is an important opportunity to harmonise and provide clarity on definitions, improve digital compliance information and market surveillance on new and substantially modified products, and make sure actors in reuse, repair and refurbishment - including social enterprises - are recognised and supported as part of a competitive European circular economy.
Public consultation
