A Strategic Approach to Recycled Content in Home Appliances

APPLiA, representing the home appliance industry in Europe, advocates for the increased and effective use of recycled materials where it is both feasible and environmentally beneficial. As an industry committed to the circular economy, we see the value in secondary raw materials. However, we urge a cautious, considered, and evidence-based approach to the potential introduction of mandatory recycled content targets. Such requirements necessitate careful, product-specific evaluation within established frameworks like the Ecodesign for Sustainable Products Regulation (ESPR), underpinned by thorough, independent impact assessments. It is crucial to recognise that circular design often entails a trade-off between multiple sustainability objectives, such as high energy efficiency and recyclability, and there is rarely a single, universally optimal sustainable design solution.

Key Challenges in Using Recycled Content in Home Appliances

The integration of recycled content into home appliances presents a complex set of challenges that must be thoroughly understood and addressed to ensure that policy measures are effective and do not lead to unintended negative consequences.

1. Limitations of "One-Size-Fits-All" Mandates and General Supply Issues

2. Specific Challenges Associated with Recycled Plastics

3. Considerations for Recycled Metals

4. The Evolving Nature of Products and Recycling Streams

APPLiA’s Recommendations for Effective and Pragmatic Recycled Content Policies

To ensure that policies on recycled content are practical, contribute positively to the circular economy, and support continued innovation in the home appliance sector, APPLiA proposes the following key considerations:

1. Mandatory recycled content targets or minimum requirements should be approached with significant caution

2. Prioritising Quality as the Cornerstone for Secondary Raw Material Uptake

3. Ensuring Coherent and Complementary Policy Design

4. Creating an Enabling Environment for a Global Circular Economy

Comments to the Ecodesign study 

APPLiA also provided written comments to the “Ecodesign preparatory study for product specific measures on scarce, environmentally relevant and critical raw materials and on recycled content - Study Report Phase 2”. Further additional comments were submitted here.

Conclusion

APPLiA and its members are committed to advancing the goals of the circular economy and enhancing the sustainability of home appliances. We believe that increasing the use of recycled content is an important part of this journey. However, success hinges on a pragmatic, holistic, and quality-focused approach. Policies must be carefully designed, integrated with existing frameworks like ESPR, based on thorough impact assessments, and supportive of robust quality standards, global markets, and continuous innovation. By working collaboratively, policymakers and industry can develop effective strategies that genuinely enhance the circularity of materials in the home appliance sector while upholding product performance, safety, and consumer trust.

For the full context and recommendations, read the full document below.