New Circular Economy Action Plan can combine ecologic and economic objectives

The EU Commission rightly notes that the multitude of issues associated with a circular economy increasingly requires a cross-cutting and interdisciplinary approach. It is essential that such complex challenges are analysed and evaluated at an early stage in dialogue with all actors along the value chains. Doing so, possible regulatory activities can be sensibly weighed and designed - and thus could actually be described as "sustainable".

Considering the background of many years of experience with the implementation of sustainability-related requirements, the electrical industry is willing to make a constructive and goal-oriented contribution to a sustainable competitive Europe and thus a sustainable circular economy. Our member companies are suppliers of innovative, energy and resource-saving product solutions that already contribute to the realisation of the circular economy in their field of application. Electrical products, that have reached the end of their life, we don’t see as waste, but as a recyclable source of resources.

This paper provides a first assessment of the most important discussion points from the perspective of the manufacturers of electrical products. These are for instance:

• Product requirements must always be considered product-specific and carefully checked
• Maintain RoHS as a separate law and apply a risk-based approach for regulating substances and product groups
• Regulate batteries exclusively within the Batteries directive
• No mandatory use of recycled plastics without prior development of product-specific standards for quality criteria
• No new data(bases) - first of all, existing data(bases) must be designed in a practical manner
• Regulate exports of waste – strengthen enforcement and the internal market 
• Exploiting the opportunities of digitalisation - expanding synergies with Circular Economy
• Maintaining the competitiveness of European products on the world market
• Identical transposition of European legislation on the level of member states
• Better enforcement of laws