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Product policy is crucial for realising the circular economy., the European Sustainable Business Federation, has filed its response with position paper to the public consultation “Towards an EU Product Policy Framework contributing to the Circular Economy”. welcomes this consultation and urges the next European Commission to prioritise the circular economy in their work plan with a focus on product policy. Solving the huge waste problems for many products and materials, ranging from construction and plastics to food, textile and electronics, requires changes in EU regulation. For instance, the import of toys containing banned substances under a false CE label should be prevented. Moreover, current regulation does not foster circularity over the life cycle and fails to include citizens to create markets for circular products and services.

Most of all, the circularity needs to be reflected in the price of end products and in public procurement. therefore advocates strong price incentives through (a) harmonised implementation of eco-modulated fees in improved schemes for extended producer responsibility, (b) a tax shift from labour to consumption, and (c) opening up the VAT directive to allow member states to differentiate VAT rates on the basis of circularity and sustainability. This would turn the product’s price into a powerful label.

To ensure safe products, all recovered substances should in principle be registered under REACH and thereby achieve end-of-waste status. However, to avoid excessive costs and red tape, we favour to retain an exemption for goods with relatively small waste stream impacts.

Environmental and social labels are important to sustainable SMEs and pioneers in a range of sectors, giving them a competitive advantage. At the same time, the labeling system has many shortcomings, such as having too many labels, costs for SMEs, ignoring the latest innovations, and providing confusing information. advocates fostering digital information disclosure on all relevant product information throughout the lifecycle to increase the transparency – the lack of which which forms a major obstacle for circularity.

An added value of an improved Ecolabel could be to simplify the choice for conscious consumers by being a reliable “stamp” of sustainability. To improve the reliability of labels, advocates increased market surveillance of imported goods including certain random, unannounced checks in combination with high fines in case of transgressions. Click here to read more about’s position concerning substances of very high concern.

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