EUREFAS’s Position Paper on the Review of the Ecodesign and Energy Labelling Requirements for Electronic Displays
Executive Summary
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’ Response to the EU Public Consultation on the Single Market Strategy
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 position paper on ecodesign requirements for mobile phones, cordless phones and slate tablets
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
EUREFAS FEEDBACK on Waste Framework Directive Revision
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 position paper on Ecodesign for Sustainable Products
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 position paper on Empowering consumers for the green transition initiative
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.
Right to repair : Our position paper on the EU initiative “Sustainable consumption of goods : promoting repair and reuse”
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.
Refurbishment to support the Green Deal and the Circular Economy Action Plan. For a greener and fair EU refurbishment market
Eurefas – The European Refurbishment association
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
Apple announces a Self Service Repair program Here’s what EU refurbishers have to say about it...
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