APPLiA, representing the home appliance industry in Europe, advocates for improving recyclability where it is both feasible and environmentally beneficial. As an industry committed to the circular economy, we see the value in secondary raw materials and the recycling of our appliances. However, we urge a cautious, considered, and evidence-based approach to the potential introduction of mandatory recyclability 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.
As policymakers consider the introduction of mandatory recyclability indexes and other recyclability-focused policies, APPLiA urges a cautious, well-considered, and robustly evidence-based approach. In this paragraph, we outline the challenges encountered today by manufacturers of home appliances.
1. State-of-the-art technologies and recycling approaches today
2. Looking at current requirements when the market is still recycling appliances of the past
3. Disassembly and labelling are not the solution
To ensure that policies aimed at increasing recyclability are practical, genuinely contribute to a more circular economy, and continue to foster innovation within the home appliance sector, APPLiA proposes the following key considerations:
1. Promoting Material Composition over Disassembly and Labelling
2. Identifying Materials Positive and Negative for Recycling
3. Introduce Producer Responsibility on Recyclers for the Quality of their Products
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.
APPLiA and its members are deeply committed to the overarching goals of the circular economy and to continuously improving the sustainability of home appliances. Enhancing the recyclability of our products is a vital component of this commitment. However, achieving true circularity requires a pragmatic, holistic, and unwavering focus on material quality, taking into account the economic drivers and technological realities of current recycling infrastructure. We need carefully planned policies that work well with existing rules, like the ESPR, WEEE, REACH and RoHS. These policies should be based on strong research and support good quality for recycled materials, consider global markets, and encourage new ideas. By working together, policymakers and the appliance industry can create effective ways to recycle more materials. This will also make sure our appliances work well, are safe for people to use, and that customers can trust them.
For the full context and recommendations, read the full document below.
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