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ARTICLE24 November 2020

Inception Impact Assessment for Sustainable Product Initiative

The Confederation of Swedish Enterprise welcomes the EU Commission”s action plan on circular economy and the initiative on Sustainable Product Initiative. Swedish business community is already at the forefront of changing from a linear to a circular economy and wants to take a driving role in its development.

Photo: MostPhotos

Any new circular economy measure, especially in the area of product policy, must be accompanied by robust market surveillance and effective enforcement. We also want to highlight the importance of conducting ambitious impact assessments for the new policy suggestions ahead and thereby ensuring that new policy will strengthen European companies’ competitiveness on the global market. Overlapping regulations must be avoided. Policy objectives, policy choices and incentives across all policy areas need to be both clear and consistently implemented.

Circular design principles and requirements should be established, based on the life cycle analysis of the product category, to ensure that sub optimization will not be the case. The design of the sustainability principles will be of huge significance to the business sector”s work on product development. It is therefore crucial that these are discussed with the business community at an early stage.

The lack of harmonisation of labelling impedes the internal market and is administratively burdensome and costly for companies; particularly given the limited environmental benefit it delivers. Therefore, we urge the European Commission to use life cycle approaches to achieve the most uniform and relevant criteria within the EU, setting minimum quantifiable requirements in order to avoid greenwashing and to provide genuinely useful guidance to consumers on environmental information.

It is positive that the European Commission is proposing tools for sharing product information digitally, including a product passport. However, when developing a policy framework to ensure communication over the complete value chain it will need to be developed through a cross-industry dialogue with a strong focus on feasibility and effective implementation.

Green public procurement (GPP) can be a powerful driver for the transition to a carbon-neutral and circular economy in Europe, particularly if there are measures at EU level to facilitate the market for GPP across and between EU Member States. We support the suggestion by the European Commission to establish mandatory, EU-wide criteria for circular materials and products.

It is positive that the European Commission is planning measures for increasing recycling and promoting the market for recycled and recyclable materials. In this context, the Confederation of Swedish Enterprise wishes to clearly highlight the need for further revisions to the Waste Directive, for development of End-of-Waste criteria and criteria for by-products, the proposal to review the Waste Shipment Regulation and a risk-based approach concerning chemicals in recycled materials.

Cirkulär ekonomiKlimatHållbarhet
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Contact our EU-Office

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Rue du Luxembourg 3
BE-1000 Bruxelles Open map
Subscribe to our Swedish newsletter
Contact our EU-Office

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Rue du Luxembourg 3
BE-1000 Bruxelles Open map
Subscribe to our Swedish newsletter
Publisher and editor-in-chief Anna Dalqvist