Activities & Papers

EUREFAS strategic priority: Securing European sourcing while ensuring compliance of imports for a transitional period

EUREFAS envisions a European refurbishment ecosystem that is both sustainable and self-sufficient, grounded in fair competition, consumer trust, and legal clarity. Our strategic ambition is to strengthen circular loops within the EU so that, over time, refurbishment increasingly relies on products sourced and processed within Europe. EUREFAS’ ultimate hope is a self-sufficient refurbishment ecosystem within the Union. Currently, reliance on non-EU sourcing exposes the sector to geopolitical volatility and undermines competitiveness: establishing a domestically-sourced supply chain is our most critical priority.

To achieve this, EUREFAS calls for a robust legislative framework and political support to :

• Foster and scale buy-back and collection of devices aimed for refurbishment from consumers, companies, waste management organisations and public institutions;
• Legally secure EU sourcing by ensuring that products destined for refurbishment are not subject to the same requirements as new products, nor burdened by prohibitive administrative hurdles that exist today.

In the meantime, EUREFAS recognises that imports currently remain essential to meet consumer demand for affordable, high-quality refurbished devices and to ensure sufficient supply for the European market. To bridge the current supply gap, EUREFAS advocates for practical, proportionate, transitional compliance pathways for imported second-hand products. The objective is not to liberalise imports, but to facilitate a compliant and responsible trade framework to support the long-term growth of a European circular economy. These measures should remain transitional, serving our ultimate goal: an EU refurbishment market built on local sourcing, trusted processes, and resilient value chains.

To align copyright levies with today’s digital economy and the EU’s sustainability goals, we urge policymakers to exempt refurbished products from copyright levies.

This exemption must be implemented immediately as a high priority for the refurbishment sector. It is essential to:

• Promote a circular economy by making refurbished devices a more attractive and viable option for consumers by erasing any unnecessary cost.
• Reduce market barriers for refurbishers by eliminating administrative burdens and inconsistencies.
• Ensure fair competition between refurbishers and manufacturers of new devices.

If the European Commission considers a broader reform of the copyright levy system, EUREFAS stands ready to provide expertise and input to help develop a future-proof framework that supports both rights holders and sustainability.

EUREFAS, the European Refurbishment Association, welcomes the European Commission’s initiative to revise the current public procurement framework. We believe that public procurement must evolve from a simple administrative task into a powerful lever for industrial sovereignty and circular resilience. EUREFAS advocates for a framework that systematically prioritizes the preservation of resource value through reuse and refurbishment through the following measures.

EUREFAS, The European Refurbishment Association, welcomes the arrival of a Circular Economy Act as a crucial tool for creating market demand for secondary materials and establishing a single market for waste, key elements in advancing the circular economy.

However, we wish to alert the Commission to a critical oversight: the first policy objectives fail to adequately address one essential pillar of circularity, product lifespan extension through reuse, such as refurbishment, of electric and electronic equipment (EEE). Focusing solely on recycling is not enough to make the EU economy truly competitive and a global circular leader because:

• In many sectors, secondary raw materials will only benefit the manufacturing of new products outside the EU - such as EEE (smartphones, laptops, TVs, etc.);
• Complete and clean recovery of raw materials, especially strategic ones, from ICT products during recycling is rarely achievable;
• Improving the collection and recycling rates of e-waste without reuse targets is insufficient: take-back schemes for reuse are much more attractive for consumers than just giving used devices for recycling.

It is therefore essential that the CEA helps create sufficient supply and demand for refurbished products and a true single market for second-hand products before they become waste. It would fulfil all the CEA’s objectives:

• Improve competitiveness: each product refurbished in the EU replaces a new ICT product manufactured outside our borders, relocating economic value and supporting local jobs creation and reindustrialisation;
• Reduce EU dependency on imported raw materials, as fostering reuse lowers the need for new products that are not fully recyclable;
• Improve e-waste collection and recycling rates: The priority for reuse is not competitive with recycling goals but complements them by enhancing the attractiveness of professional collection channels, thereby ensuring that non-reusable e-waste is reliably routed to recycling.The more refurbishers buy used products or e-waste from end-users, the more attractive collection becomes, and the more likely e-waste will remain within professional channels and be passed to recyclers each time reuse is not possible.
• Reduce carbon footprint: refurbishment avoids the environmental impact of new manufacturing and achieves a significantly lower carbon footprint (e.g., 84–88% reduction for a smartphone per year of use).
• Preserve purchasing power: refurbished ICT products are on average significantly less expensive than new ones which offer quality alternatives at a lower price point, thereby benefiting EU consumers.

The European Union's strategy to accelerate its circular economy agenda is fundamentally tied to its ability to manage, save and recover valuable resources, particularly those found in used Electrical and Electronic Equipment (UEEE), fueling a local refurbishment market. While the Waste Shipment Regulation (WSR) is crucial for ensuring environmentally sound waste management, its potential application to UEEE can hinder the refurbishment sector. Given that refurbishment operates at the intra-EU level and requires supply flows from other Member States, applying burdensome rules such stifle this vital and environmentally responsible economic activity.

EUREFAS reiterates the need to clarify the grey regulatory zone that used electronics fall into. Without clarification of their status, UEEE risks falling under waste regulations, causing disproportionate administrative burden, higher costs, inconsistent interpretation among Member States, and reduced competitiveness for legitimate refurbishment businesses.

EUREFAS welcomes the Commission’s initiative to develop a new visual identity (ie. the guarantee notice and label) aimed at enhancing consumer awareness to support sustainable consumption and purchasing. As a sector we are dedicated to building consumer trust in refurbished products and we believe the availability of transparent, harmonised guarantee information is essential to empower consumers to make informed, responsible choices, especially in the growing market for second-life electronics.

However, we wish to underline an important concern: the increasing complexity of pre-contractual information obligations risks having the opposite effect (…).

To address this, we encourage the Commission to explore a simplified guarantee symbol like a clear, recognisable visual indicator that a product benefits from a legal or commercial durability guarantee.

As the association representing the refurbishment sector and being a key player in the circular economy by extending devices’ lifespan containing a majority of the materials listed in Annex I, EUREFAS would like to underline the importance of prioritizing reuse over recycling. To this day, reuse stands as the most effective and resource-efficient method to valorize those materials: While recycling aims to recover CRM from end-of-life products and waste streams, reuse already retains these materials in functional or reusable devices, avoiding the energy-intensive and resource-consuming process of extraction through recycling. In addition, through reuse, such as refurbishment, every device resold into the market reduces the need to manufacture a new product, thereby mitigating the demand for new raw material extraction and further recovery processes.

Before valorizing materials through extraction, EUREFAS calls for the valorization of the product as a whole through the following measures:

• Improve collection objectives and specific targets for reuse, distinguishing reuse from recycling in reporting obligations.
• Mandate sorting and prioritization for reuse in collection schemes, ensuring that every device suitable for reuse does not automatically end in recycling streams.
• Support the development and promotion of buy-back programs, enabling the retrieval of high-value devices and components suitable for reuse.

An effective CRM policy should thus be complementary to European and national policies promoting reuse first, followed by component salvaging and recycling only when reuse is no longer viable.

EUREFAS therefore encourages the Commission to recognize the role of reuse within CRM policymaking and to ensure that regulatory frameworks prioritize reuse.

EUREFAS – the European Refurbishment Association – welcomes the opportunity to provide high level comments on the draft Act.

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We therefore recommend that the Regulation should incentivise traders to avoid the destruction of unsold goods, particularly if they haven’t yet reached the status of “waste”. We strongly support the extension of the scope of the ban on the destruction of unsold goods to more product categories, including consumer electronics such as mobile phones, smartphones, laptops and computers.

We would like to see refurbishment recognised as a standalone activity, ranked higher than preparation for reuse and recycling in order to unlock access to untapped sources of supply. This would be one clear incentive for traders to turn to refurbishers to handle their goods instead of sending them to recycling or destruction, and contribute to the objectives of the circular economy.

EUREFAS broadly welcomes this draft Implementing Regulation as a necessary and well-structured step towards operationalising the Digital Product Passport framework. The registry architecture, the tiered access system, and the inclusion of value chain actors as legitimate DPP updaters reflect a sound understanding of how products circulate across the economy. We offer the following targeted recommendations to ensure the framework works effectively for the refurbishment and repair sector.

EUREFAS brings together environmentally-focused stakeholders in high-tech and electronics refurbishment across Europe. It aims to support the development of a comprehensive European market for repair and refurbished goods, share expertise with public authorities and policymakers, and promote environmentally friendly and socially beneficial products by raising consumer awareness.

Refurbishment Sector Overview: Refurbished products, which are second-hand items collected, tested, and if needed repaired by professionals, are gaining traction in the EU. For instance, refurbished smartphones account for over 20% of sales in France and 10% in Germany. This sector is set to play a significant role in the future economy by offering sustainable, high-quality products at lower prices with reduced carbon footprints. It also presents opportunities for reindustrialisation, local job creation, strategic autonomy by reclaiming value from outsourced tech manufacturing, and reduced reliance on global raw materials.

The European refurbishment and second-hand markets face development barriers due to current Single market rules, which are tailored for new products. They do not provide a secure legal framework for professionals dealing with used products.

• Refurbishers can’t comply with any classic economic operator rules as they lack access to initial product documentation and relationships with original manufacturers or the previous consumer, complicating compliance with distributor or trader obligations
• Refurbishment is not clearly defined, and definition of substantial modification does not exclude refurbishment, which poses the risk to consider refurbishers as manufacturers.
• Second-hand products also cannot meet new product requirements due to wear and tear, outdated design regulations, and limited initial product information.

EUREFAS proposed solution:

• We call for a clear, cross-legislative definition of refurbishment, excluding it from substantial modification processes, which should be considered as remanufacturing.
• A specific legal regime for second-hand economic operators is needed, clarifying their liability and responsibilities. Refurbishers should be accountable for providing only publicly available product information, EU requirements on spare parts they have replaced, and eventually specific second-hand or refurbishment product requirements that could be set. They should not be considered manufacturers or liable for previous operators’ practices.

Simplifying Extended Producer Responsibility (EPR): EUREFAS advocates for a one-stop-shop EPR system to streamline registration and reporting across Member States, reducing administrative burdens, especially for SMEs. This system would allow a product to pay its EPR fee once, even if refurbished and sold multiple times within the Internal Market, fostering the reuse market’s growth.

EUREFAS appreciates the opportunity to contribute to the public consultation on expanding the Ecodesign and Energy Labelling Directive to cover a broader range of electronic displays, including small screens. The proposal to extend requirements beyond the current 100 cm² threshold to devices like small displays, video conferencing devices, and digital photo frames is a significant and necessary step.

As an association representing the refurbishment sector, EUREFAS supports this extension as it promotes durability, repairability, and reuse—key pillars of a circular economy. The inclusion of small screens will not only curb e-waste but also set a critical precedent for reparability and durability indexes in other product categories. This would help drive sustainable practices across the entire electronics industry.

Eurefas gathers the environment-focused players in high tech and electronics refurbishment throughout Europe. It aims at supporting the development of a fully fledged European market for repair and refurbished goods, sharing their expertise with public authorities and policy makers, and promoting environmentally friendly and socially beneficial products by raising consumers’ awareness.

We welcome the Commission’s ambition to provide a fair system for compensating people who suffer physical injury or damage to property due to defective products. We also applaud Europe’s aims to adapt this directive to new types of economic operators selling or dealing with second-hand products, such as refurbishers or remanufacturers.

EUREFAS – the European Refurbishment Association welcomes the proposal of ecodesign requirements for mobile phones, cordless phones and slate tablets setting up ambitious principles of durability, reusability and reparability at the design and manufacturing stages.

The text will be a powerful tool for improving those products’ circularity and environmental footprint, by:

• Defining professional repairers in a way covering both repair services and refurbishment to solve the common challenge they face regarding reparability;
• Aiming at opening the after sales market by making much needed spare parts and repair and maintenance information available, at a proportionate price and within decent delivery delays,
• Requiring transparency on spare parts pricing, which is critical to ending existing discriminatory practices,
• Improving design for easier disassembly and better reliability,
• Mandating software maintenance durability, which together with hardware, is the pillar for extending the lifespan of electronics.

However, we would like to raise some concerns about the negative impact of some key provisions for repair and refurbishment, which, contrary to its spirit, strongly risk hampering the text’s circularity ambitions.

For the sake of readability:

• Eurefas’ comments refer to the Smartphones section of Annex 1 & 2, but they also apply to the other products addressed.
• As Eurefas is the European refurbishers association, we only address provisions impacting professional repairers, and not end users.
• A modified version of the regulation, including our suggestions, is attached to this paper as an annex

The current initiative is a true opportunity to address major bottlenecks our sector is facing by growing access to used products to either refurbish, if in enough good shape, or “salvage” for spare parts. The point here would be to grow European supply for products and spare parts to be refurbished by market players such as our members, hence boosting the extension of the lifespan of products to the maximum, creating obvious environmental benefits.

With this objective in mind, we strongly recommend the Commission to work both on improving waste collection, and making sure recycling comes at the very end of a waste treatment process.

How?

• Prioritize reuse
• Extend the polluter pays principle to targeted responsibilities on the extension of products life
• Streamline the EPR system by uniformizing it across the EU

EUREFAS – the European Refurbishment Association welcomes the proposal of Ecodesign for Sustainable Products setting up ambitious principles of durability, reusability and reparability at the design and manufacturing stages, in order to implement the green transition. New sustainable products are however not the sole solution in this view: Second-hand and refurbished products have appeared as a remedy to limit the need for new products. EUREFAS welcomes the fact that this emerging market and its new economic operators such as refurbishers are now acknowledged.

However, EUREFAS would like to raise some concerns about how refurbishment is addressed in the regulation and how a digital product passport can benefit the sector.

EUREFAS – the European refurbishment association – welcomes this initiative which ensures consumers will have more reliable information on product’s reparability, durability and the way it is promoted. (…)

Indeed, having more reliable information on how a product can be reused is beneficial for consumers as they will be able to resell it more easily.

However, we feel the proposal does not appropriately address the specificities of the second-hand market and some provisions could be strengthened in order to be more precise and binding. We outline below key recommendations to ensure that the initiative delivers on its promises. 

As such, we fully support the EU “Sustainable consumption of goods” initiative because it promotes repair and reuse. As the European economy is still mainly linear and more efforts are needed to make a more circular consumption the preferred default option for consumers, we recommend the Commission to go further than “voluntary commitments” (option 1 in the consultation). In order to achieve a real paradigm shift, the support of the Commission needs to be decisive and should:

• Ensure a level playing field with manufacturers
• Foster strong and high-quality networks of independent repairers close to end-users.
• Make it easier for consumers to get their products repaired and encourage them to be true players in the circular economy transition.

In practical terms, these three main lines of action have to apply during the product’s lifespan: at the time of purchase, within the legal warranty period, and above all beyond it. Eurefas strongly believes in creating a dedicated right to repair, not exclusively related to the revision of the Sales of Good Directive, which is too much focused on the legal warranty period.

Gathering the environment-focused players in high tech and electronics refurbishment throughout Europe, EUREFAS aims at strengthening collaboration between European professional stakeholders, sharing their expertise with public authorities and administration, promoting environmentally virtuous and socially benefic products by raising consumers’ awareness.

As such, we thus fully support the Circular Economy Action plan (CEAP) objectives: making sustainable products the norm in the EU market – empowering consumers by providing them more information on environmental characteristics and to encourage sustainable choices, to take action in the high tech sector for a longer products’ lifespan and improving waste treatment.

How can the CEAP actually support this sector?

• Providing a common and harmonized definition of refurbishment.
• Helping and supporting refurbishment processes by encouraging collection schemes and respecting waste treatment hierarchy
• Securing a level playing field with manufacturers / Enjoining manufacturers to play a fair game
• Giving customers a Right to repair and nudging them into making truly sustainable choices

The European Refurbishment Association – EUREFAS – welcomes Apple’s latest announcement giving access to spare parts and repair schemes for customers among their “Self Service Repair” program. This announcement sends a general message for more responsible habits toward reparation, encouraged by the first stakeholder in the consumption chain – manufacturers and original equipment manufacturers (OEMs).. As 77% of Europeans are more likely to repair their products instead of buying new ones1, reparation and re-employment schemes must be encouraged and facilitated by OEMs at the very beginning. Among the upcoming legislations, it also shows that even the biggest manufacturers such as Apple have heard this message and that those efforts were possible.

But progress is still to be made and this announcement raises three questions among European Union (EU) refurbishers:

1. On a spare part’s full and real availability with affordable prices
2. We should avoid any practices aimed to protect spare parts monopoly
3. Including refurbishers in the reparation scheme