DIGITALEUROPE Circular Economy position

General comments and principles

DIGITALEUROPE welcomes the opportunity to contribute to the public consultation on the circular economy. We have structured our response along the broad lines of the consultation, highlighting the areas that are of particular importance to support the further development of the circular economy in the electronics sector.

The Circular Economy is composed of different building blocks, each of which needs to be promoted in coherence with the overall concept. DIGITALEUROPE therefore urges the Commission to build any regulatory or policy measure driving the circular economy on a set of coherent principles including:

1. The Life Cycle Thinking Principle. Environmental considerations should be integrated at the stage of product design with the aim of reducing all relevant potential environmental impacts over its entire life cycle. At times products are maximizing trade offs (energy use during life versus resource used versus recyclability), the holistic approach should take precedence over measures addressing only an individual element. Consequences from acting on a specific part of the product lifecycle over the overall system should be systematically assessed to avoid rebound effects and maximise environmental benefits.

2. Balancing of Different Aspects Principle. Balance environmental aspects, such as emission, resource, and potential toxicity aspects, between themselves as well as with other aspects, such as economic, technical and safety aspects.

3. Responsibility Principle. Attribute responsibilities to those actors in the product life cycle that can be held accountable for the results.

4. Data Collection on all WEEE flows Principle: capturing data on the circular economy properly is essential for achieving circular economy’s goals. E.g. in order to measure the collection rate on WEEE correctly it is vital that Member States collect data on all flows of properly treated WEEE.

5. Competition Principle. Allow market forces to drive competition in a technology neutral, level playing field, and avoid the creation of monopolies. Circular economy features should not stifle innovation capacities of the industry. Develop guidance to facilitate collaboration without breaching competition rules.

6. Global Harmonisation Principle. Foster global harmonisation of environmental policies for products to avoid barriers to trade. A closed EU circular economy is undesirable as EU is part of a global economy.

The circular economy is already a reality in the electronics sector in the B2B space, but also trade-in solutions and authorised repair networks are emerging; Important for its functioning is the “repaired as produced principle” for spare parts. To promote the development of these circular economy elements we suggest building on current measures and developing new ideas to keep materials in circulation where it makes sense economically, environmentally and socially.

Also, information technology has the potential to contribute to a circular economy via for example sharing platforms, 3D printing or subscription services. Europe should make use of these new technologies and business models to maximize resource use. In terms of the scope of the circular economy package, the focus should be on those value chains with the greatest resource consumption in order to contribute significantly to Europe’s sustainability. We suggest improving the process for a few selected products not regulated under RoHS & WEEE before rolling it out to a wider industry. Office and consumer electronic equipment such as desktops, laptops and printers are already regulated under RoHS, WEEE, Reach, ErP regulation. No need for further regulation as existing regulation has already maximized environmental parameters to a large extent, particularly when compared to other less regulated sectors.

Furthermore, DIGITALEUROPE has already expressed its members’ concerns about the definition of resource efficiency indicators, as part of the 2012 European Commission consultation. We would like to reiterate here that an EU resource productivity target as lead indicator (measured as GDP divided by domestic material consumption) has a number of limitations, in that it does not account for the efficiency footprint of a material used outside the EU. It also risks sending the wrong signal if it is based on the assumption that imported goods have identical impacts to equivalent products manufactured within the EU. Equally important, general targets that do not take in account technical feasibility and industry specificities may not be enforceable.

Finally, capturing data on circular economy properly is also essential for achieving circular economy’s goals. E.g. in order to measure the collection rate on WEEE correctly it has to be ensured that Member States collect these data on all flows of properly treated WEEE. Currently in most Member States the collection rate based on official data of WEEE separately collected by systems set up by producers is on average one third of electronic and electrical equipment sold. With the increasing value of WEEE, linked to the increasing raw material prices over the last five years, we are witnessing more and more WEEE collected and recycled by actors operating outside of the Producer controlled systems. These so called “complementary WEEE flows” are being collected by an array of actors, operating from small-scale door-to-door collectors to large-scale scrap dealers and recyclers. Research in several Member States has revealed that in addition to this one third managed by producer take back systems, on average, a further one third is also collected and treated by recyclers. So, in fact at least two thirds of the WEEE is being treated by recyclers.