Sustainable consumption of goods – promoting repair and reuse

Unsustainable consumption of goods, leading to a growing amount of waste, is one of the main causes of negative impacts on the global environment. The new consumer agenda and the circular economy action plan aim at promoting repair and encouraging more sustainable products. The European Parliament called on the Commission to make it easier for consumers and businesses to make sustainable choices, to establish a consumer right to repair and to amend the Sale of Goods Directive (‘the Directive’). The Council welcomed the initiative on the ‘right to repair’ with the aim to promote more systematic repairs, including beyond the liability period , and at a reasonable cost.

This initiative will lead to a proposal on the right to repair. It will produce synergies with other initiatives such as those on sustainable products, circular electronics and the empowering consumers in the green transition, as well as with product-specific Ecodesign implementing regulations

 

Commission is currently preparing its impact assessment.

 

Commission’s policy options

Option 1) Low intervention – voluntary commitments: encourage businesses to commit voluntarily to repairing goods with a significant negative impact on the environment and promote the purchase of second-hand and refurbished goods.

Option 2) Moderate intervention:

Sub-options 2A) Extend the legal guarantee period: (i) for new goods that consumers choose to repair instead of replacing them; and/or (ii) for second-hand and/or refurbished goods (amendments to the Directive).

Sub-options 2B) Make repair the preferred remedy when repair is less expensive than or as expensive as replacement (amendment to the Directive); oblige producers or sellers to repair goods beyond the legal guarantee period for a reasonable price (new right to repair within the Directive or a separate instrument).

Option 3) High intervention:

Sub-option 3A) Limit consumers’ choice of remedies by prioritising repair over replacement (amendment to the Directive); Oblige producers or sellers to repair goods beyond the legal guarantee period, in some cases for free (new right to repair within the Directive or a separate instrument).

Sub-option 3B) Extend the legal guarantee period beyond the current minimum period of 2 years (amendment to the Directive).

Sub-option 3C) Enable the seller to replace defective products with refurbished goods and not new ones (amendment to the Directive). In addition, the Commission welcomes views on the need for, and design of, additional legislative and non-legislative measures to promote sustainable use of goods, which could influence the current relationship between consumers and businesses, with the aim of extending the useful life of goods.

 

Commission’s call for evidence of an impact assessment – 11/01/2022 – 05/04/2022

 

CECRA’s contribution  

Vehicles are designed and equipped with very advanced technology in order to last in time for many years (in average 13 years). Vehicles are already reliable and durable products which provide value for money to consumers and prevent the overuse of resources and waste. Furthermore, vehicles are already today – in contrast to disposable products - open to any kind of repair, upgrade, disassemble and – finally – recycling. However, vehicles, composed of a collection of complex components, have each of which its own lifespan and longevity characteristics, depending particularly on the type of components (e.g. brakes) and the kind of use (e.g. kilometers travelled, maintenance, driver behaviour etc.). These external influences are not predictable but have a major impact on the lifetime of components and the vehicle in itself. Keeping all these factors in mind, we consider that the ‘reasonable’ guarantee period, set at 2-year, already offers encompassing all relevant defects and therefore offers a good solution as it ensures high levels of sustainable consumption while keeping the burden for the industry at a reasonable level. Automotive manufactures are accountable for the products they produce and the guarantee – all related costs - they offer for these products. However, in practice, automotive authorised repairers report they are not fully reimbursed by their manufacturers for doing these repairs under the guarantee period. Through the guarantee period offered when buying a car, the automotive sales and repair sector esteems that the automotive industry, as a whole, already offers a sustainable format of repair and maintenance for its products and we do not see any need to introduce additional rules. Nevertheless, CECRA supports the general principle. It therefore supports the voluntary commitments (1st policy option proposed by the Commission), which would encourage businesses to commit voluntarily to repairing goods with a significant negative impact on the environment and promote the purchase of second-hand and refurbished goods which could encourage more sustainable behaviour. Please read the attached document for our full feedback.