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The European Green Deal – the first policy strategy put forward by the new European Commission (EC) that took office in December 2019 – is a sweeping plan that aims to reconcile the economy with the planet. Among its other objectives, the Green Deal sets a goal of achieving climate neutrality in Europe by 2050.
The Circular Economy Action Plan, adopted by the EC on March 11, 2020, is one of the flagship initiatives of this effort and will be at the heart of many European policy discussions for months to come. The plan is not legally binding, but it presents a set of 35 measures to be considered from 2020 to 2023 to ensure a cleaner and more competitive Europe. These measures, both legislative and non-legislative, will cover the entire lifecycle of products, ranging from design, production, and consumption to making sure resources are kept in the economy for as long as possible. The plan aims to make sustainable products the new norm in the EU and to make Europe the leader of such efforts at the global level. It calls for this to happen through “co-creation” involving industry, consumers, and civil society organizations.
The Circular Economy Action Plan asserts that up to 80 percent of the environmental impact of a product is determined during its design phase, and therefore the current linear model of “take-make-use-dispose” needs to change. To tackle this challenge, a Sustainable Product Policy Framework will be proposed to make products future-proof, climate-neutral and resource-efficient. The Ecodesign Directive, an existing EU law regulating energy- and resource-efficiency, will be extended beyond energy-related products, and the methodology behind it will be subject to a review. The Framework will be complemented, where necessary and appropriate, with sustainability principles to address aspects such as product durability, reusability, upgradability, and repairability, as well as chemical composition and overall carbon and environmental footprint. To grasp the benefits that digitization makes possible, a to-be-established digital product passport would bring together existing and new databases containing product information covering the entire product life-cycle.
Although the Circular Economy Action Plan covers several product value chains, electronics and ICT are top concerns because they represent some of the fastest-growing waste streams in the EU, with current annual growth rates of 2 percent. A Circular Electronics Initiative will focus on regulatory measures to promote longer product lifetimes, with a primary focus on mobile phones, tablets, and laptops, and bringing those under the Ecodesign Directive.
Consumers will play a crucial role in the transition; their choice of products and consumption patterns affect the entire economy. Consumers need to receive trustworthy information about their products, including aspects such as lifespan, repair options, manuals, and availability of spare parts. These policies will be part of a new initiative called Right-to-Repair, which could affect electronics product design, manufacturing, and service delivery, including requiring spare parts and repair manuals to be available to third-party professional repairers.
When it comes to chemicals, the European Commission is planning to present a new methodology and approach towards regulating hazardous chemicals under the upcoming Chemicals Strategy for Sustainability, which is expected to be finalized in October 2020. The strategy will mark a new phase in the long-running interface between product, chemicals and waste, seeking to balance what are often seen as conflicting interests: on one hand, improving recycling and uptake of secondary materials, and on the other hand, substituting for substances of concern.
Although there are already efforts in place to promote a toxics-free environment by adopting substitutes for hazardous substances, the safety of secondary materials can be still compromised. The EC will therefore work on methodologies to minimize the presence of substances of concern in recycled materials and develop harmonized systems to track those substances across the supply chain. As of January 2021, companies supplying articles containing substances of very high concern (SVHCs) will need to submit information on these articles to the European Chemicals Agency (ECHA) via the SCIP database. There also are indications in the Circular Economy Action Plan that the Commission is looking into extending the current scope from SVHCs to substances of concern (SoC), despite the lack of a clear definition of the latter.
At the same time, the EC is set to review the current Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS) by 2021.
The upcoming months will present several opportunities for engaging with EU institutions and stakeholders in shaping all these initiatives. IPC, which is uniquely positioned to represent the entire electronics supply chain, is working on two research reports on traceability of substances and lifecycle analysis, and the association will continue to engage directly in these policy discussions. IPC members with relevant information and opinions should contact Alison James, IPC Senior Director for Europe, or Kelly Scanlon, IPC Director, EHS Policy and Research.
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