EUREFAS OPEN LETTER ON CIRCULAR ECONOMY ACT AND THE ROLE OF REUSE AND REFURBISHMENT

Subject: EUREFAS OPEN LETTER ON CIRCULAR ECONOMY ACT AND THE ROLE OF REUSE AND REFURBISHMENT

We, the European Refurbishment Association (EUREFAS), call on the European Commission to ensure that the upcoming Circular Economy Act establishes reuse and refurbishment as the priority pillars of Europe's circular economy, as established by the waste treatment hierarchy.

The Circular Economy Act, expected in Q4 2026, is one of the most consequential pieces of industrial legislation of this Commission mandate. We welcome its ambition to accelerate Europe's transition away from linear models and to build a functioning single market for secondary materials. We share the Commission's concern that Europe's circularity rate has barely moved (growing from 10.7% to 11.8% over a decade) and that more decisive action is needed.

But we are concerned that, as currently framed, the Act risks repeating the fundamental mistake of its predecessors: treating the circular economy as synonymous with recycling, while leaving reuse and refurbishment — the highest-value options in the waste hierarchy — without the policy framework, the targets, or the incentives needed to scale.

Recycling is not enough

The waste hierarchy, enshrined in EU law since 2008, places prevention, reuse, and preparation for reuse above recycling. In practice, while some progress has been made, reuse and refurbishment still lack the binding targets, dedicated funding, and policy infrastructure that recycling has long benefited from.

The consequences are visible in the data. Europe generates 17.6 kg of e-waste per capita, the highest rate in the world. Smartphone collection rates for reuse stand at approximately 11-15% according to Eurostat numbers. Millions of devices that could be refurbished and sold to consumers at a fraction of the cost of a new device are instead shredded, with only a fraction of their embedded value recovered. This is not a circular economy. It is a recycling economy — and one that is failing even on its own terms.

Reuse and refurbishment are not niche activities. Europe's professional refurbishment sector employs tens of thousands of people, generates hundreds of millions of euros in economic activity, and delivers consumer products that save, per device, approximately 77 kg of CO₂, 243 kg of raw materials, and 76,000 litres of water compared to a new equivalent. This is the circular economy working at scale. The Commission's own Clean Industrial Deal explicitly champions European circular business models. The Circular Economy Act must back that ambition with concrete measures.

What the Act must include

We call on the Commission to ensure that the Circular Economy Act:

1. Establishes binding reuse and refurbishment targets alongside recycling targets. The Act should set measurable, time-bound targets for the collection, preparation for reuse, and professional refurbishment of electronics and other durable product categories. These targets must be tracked separately from recycling rates to ensure the waste hierarchy is applied in practice, not only on paper. This is necessary to eliminate the current incentive to prematurely channel reusable devices into waste treatment processes in order to artificially improve reported recycling performance statistics.

2. Designs collection schemes to systematically maximise reuse. The single biggest barrier to scaling professional refurbishment in Europe is the chronic undersupply of quality used devices available for processing. The Act should introduce fiscal instruments, tax incentives and bonuses for consumer trade-in, or EPR fee differentiation that rewards reuse over recycling, to effectively divert the flow of used products into professional reuse streams. Every device collected should be assessed for reusability by a qualified professional to assess reusability before any recycling decision, while public and private organisations should be mandated to return used devices to refurbishers.

3. Redefines and harmonises end-of-waste criteria for electronics across the single market. Under current EU law, the absence of clear and harmonised criteria means that used electronics risk being automatically classified as waste, leading to their premature recycling and the irreversible loss of reuse potential. This problem is compounded by regulatory fragmentation: a device crossing an EU border during the refurbishment process may legally be classified as waste in one member state and as a product in another, creating a structural barrier to building pan-European refurbishment supply chains. The Act should establish harmonised, clear, and operationally workable end-of-waste criteria for electronics destined for professional refurbishment, with reuse potential as the guiding principle.

4. Ensures EPR schemes fund the full waste hierarchy, including reuse. Extended Producer Responsibility schemes have become de facto funding mechanisms for recycling infrastructure. The Act should require that a portion of EPR contributions is directed toward collection for reuse, preparation for reuse, and professional refurbishment infrastructure. This would be consistent with the hierarchy that EU law already mandates but does not enforce.

The window is now

The Commission's legislative proposal is due in Q4 2026. The political and institutional window to shape its content is open today. Once the text is published, the scope for structural changes narrows dramatically. We urge the Commission to use the months ahead to engage with the reuse and refurbishment sector, incorporate its operational realities into the impact assessment, and publish a proposal that genuinely delivers on the promise of the waste hierarchy.

A Circular Economy Act that does not mention or promote reuse fails to incorporate the most essential components of a circular economy and misses a critical opportunity to contribute to building a more resilient and sovereign Europe.

We look forward to engaging with the Commission on this agenda and stand ready to contribute the operational expertise and evidence needed to get the framework right.

Yours sincerely,

Augustin Becquet

President of the European Refurbishment Association (EUREFAS)