SUSTAINABILITY EU POLICY RECYCLING REGULATION

Will the EU’s Sustainable Products Initiative get the balance right?

What is a “sustainable product”? Is it more sustainable to continue using my old washing machine or to buy a new, more energy efficient one? Are single use products always unsustainable? What criteria should I use to judge whether a product is sustainable or not? What measures can we take to promote sustainability in products?

The discussion on products and sustainability is not simply philosophical and detached from real life. It is an ongoing, highly relevant debate. Consumption patterns are changing, with an increasing number of products entering markets.

Today, consumers purchase products, but to what extent do they think about their use from a sustainability perspective? Long life, low maintenance, high efficiency, reliability, possibility to repair and reuse: some of us associate such aspects with products that we consider as sustainable.

However, consumers also put weight on other aspects such as design or functionality which they may consider to be more relevant. Manufacturers on the other hand, are increasingly producing products with a built-in obsolescence, that can neither be maintained nor repaired.

There is clearly a need to bring sustainability back into the minds of both consumers and industry, especially when considering consumer products. And some of these aspects will need to be formulated as requirements in legislation.

Sustainable Products Initiative

In March 2022, the European Commission published its Sustainable Products Initiative. The overall aim of the Commission proposal is to ensure that products placed on the EU market become more sustainable.

The expectation is that consumers, the environment and the climate will benefit from products that are more durable, reusable, repairable, recyclable, and energy efficient. The initiative is a key element in the European Commission´s Circular Economy Plan. A core deliverable is a revamped EU Ecodesign Directive introducing other related measures. The European Commission focuses on a range of product groups such as electronics and ICT, textiles, furniture, construction and buildings as well as intermediary products such as steel, cement and chemicals.

It is intended to assess and improve the product life cycle with respect to durability, reusability and reparability include improvement of the environmental and carbon footprint of products; increasing energy and resource efficiency; promotion of recycling to ensure that raw materials contained in products enter new life cycles and do not end up in landfills; and recycling to take place under highest environmental and worker´s protection measures.

We all can sign up to each of these points.

Metals in general and nickel more specifically tick many of the boxes that we expect to see in the Commission proposal. Using nickel leads to higher energy efficiency during use, reduces maintenance, prolongs lifetime, makes products more durable – and its high economic value ensures their recycling and prevents landfilling.

Assessing all these points in parallel, however, is complex and requires a tool that guides us towards making balanced decisions. The European Commission developed its Product Environmental Footprint (PEF) method.

Product Environmental Footprint

The Product Environmental Footprint method is mainly built on a globally agreed life cycle assessment standard from the International Standardization Organization (ISO) and allows comparison of products or services throughout the entire life cycle and assesses their environmental performance. It will guide us to the right decisions, to identify hot spots within a product life cycle where improvements can be made and will play a critical role in the sustainable products initiative.

But is the product environmental footprint method going to answer all questions and guide us to more sustainable products?

There are several points where more detailed consideration is required; where consequences along the entire life cycle and its environmental, economic and social implications have to be considered, and where political decisions will need to be taken.

address the presence of hazardous substances in products

As part of the sustainable products initiative, the European Commission plans to also “address the presence of hazardous substances in products”. But is this the right direction? Are bans of hazardous substances the right approach and will they make products more sustainable?

Let´s take the example of batteries: all modern battery technologies contain hazardous substances. We know that they play a critical role in electric vehicles and for the storage of renewable energy to achieve the climate change targets. Risk based approaches allow us to identify potential risks that might occur throughout the battery life– and to address them. Such approaches help us to take advantage of all the benefits that batteries bring during use, and on the other hand to manage the risks which might occur in other stages of the life cycle. It is not the presence of hazardous substances that needs to be tackled, but the risks associated with them.

It is not the presence of hazardous substances that needs to be tackled, but the risks associated with them.

What about recycling?

The idea of recycled content is also seriously considered. In principle, a mandatory share of recycled material in a product can help to promote its recycling at the end of life, reduce dependencies on raw materials imports, and improve the environmental and carbon footprint. But it is important to understand material characteristics, influencing parameters and what can be achieved. The longevity of products for instance is an important aspect and something which is aimed for in sustainability. If we look at nickel-containing stainless steel in buildings, we see many products still in use after 50 years, in some cases even more than 100 years – these materials are not yet available for recycling. Consequently, there is only a limited amount of nickel currently available to satisfy recycled content targets. There is however a high economic incentive to collect materials containing nickel at the end of life and to make them available for future life cycles.

 

Nickel-containing stainless steel in buildings are still in use after 50 years, in some cases even more than 100 years - The nickel-containing stainless steel forming the shining crown of the Chrysler building is still as pristine and beautiful as the day it was completed in 1930.
Nickel-containing stainless steel in buildings are still in use after 50 years, in some cases even more than 100 years - The nickel-containing stainless steel forming the shining crown of the Chrysler building is still as pristine and beautiful as the day it was completed in 1930.

The longevity of products is an important aspect and something which is aimed for in sustainability.

For other raw materials with a shorter lifetime or lower economic value, however, including requirements for recycled content might be more appropriate and help to achieve a higher product sustainability. The consumer has a critical role to play. The sustainable products initiative can only be successful if it involves consumers, informs them and targets their decision making. In many cases, the sustainability performance of products can be easily improved by increasing lifetime and ensuring recycling at the end of life.

Consumers have a role to play

Consumers decide whether a product should be replaced by a new one; whether a broken product shall be repaired and – if not reparable any longer – whether it is going to a recycling scheme.

Educating and sensitising consumers is important to ensure that sustainability is considered, and more sustainable products are purchased.

It will be interesting to see how the Sustainable Products Initiative will balance full life cycle thinking, political targets and consumer education and promote the use of more sustainable products. Only if the Commission package manages to find a balance between these elements, can we expect the Sustainable Products Initiative to be successful and to lead us to more sustainable products.

This article was first published on Euractiv, in February 2022 and edited in July 2022.

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