The EuCER Council significantly appreciates the opportunity given by the European Commission to express its position. 

The Council emphasises the following aspects:

• Preferred objectives to pursue should be to repair products always when possible and economically sustainable as well as to replace broken devices with second-hand or refurbished products when so desired by consumers. 

• In order to create a change of attitude by consumers it is will be essential to launch public communication campaigns focused on the benefits of repairing products and about the connected economic and environmental implications. 

• It has to be carefully considered the fact that the decision whether to replace or repair goods is mainly influenced by the cost and availability of spare parts, as well as the guidelines on repair to be provided by manufacturers, by the amount of time needed (labour costs in EU), and by the possible gap in efficiency (energy consumption etc.) between a new and a repaired device eco-designed several years before. We must remember that repair will not increase the energy efficiency of products but will simply return devices to their initial status.

• The mentioned purposes should be achieved at the EU level, with the scope of harmonising the related directives and guidelines. 

In order to properly set a strategy to achieve these goals, it is important to consider the relevant differences between the management of products covered or not by the legal guarantee.

The European institutions should focus on encouraging a fair and virtuous competition between manufacturers and retailers, with the purpose of incentivising the sellers to offer refurbished products rather than to recline on manufactures, who have no interest in putting repaired products on the market.

For instance, a reduced VAT rate for refurbished and repaired products and other tax incentives could create a very favourable environment and support investment in education for the employees.

A “race to the top” encouraging retailers to offer refurbished products, with the inclusion of a reasonable margin of profit, would, in these terms, be beneficial for consumers, businesses operating inside EU and, of course, the environment.

The full EuCER Council position is available below (in English, Italian, French and German).