The European Commission has published the final report of Eunomia’s Study to Support Preparation of the Commission’s Guidance for Extended Producer Responsibility Schemes and their Recommendations for Guidance. Eunomia have retained their proposed criteria of disassembly, repair and upgrade; spare parts availability; durability and warranty period; recycled content; and hazardous substances, but have now added ecolabels; information for repairers and recyclers; and battery life.
Needless to say, APPLiA is reiterating the objections and concerns that they submitted on the draft report.
AMDEA and the JTA have been separately commenting on Eunomia’s very similar report to Defra. We have already challenged the assumption that moulded parts can be replaced by 3D printed parts; pointed out the dearth of technology to assess recycled content and extract critical raw materials; and underlined the futility of trying to itemise hazardous substances to be avoided when the ECHA updates its list every six months. And let’s not even start on why a commercial guarantee will never align directly with the lifetime of a product.