Joint industry paper on Enabling the Circular Economy - Ensuring a free flow for products for repair, remanufacturing and refurbishment

The associations supporting this position paper represent industries with strong business models in the circular economy: repair, remanufacturing and refurbishment. The medical devices refurbishment business alone is worth nearly €500 million p.a., the IT-Remanufacturing market in the EU generated revenues of about 6.9 billion $ in 2012.

Importantly, the repair, remanufacturing and refurbishment business is implemented by various industrial sectors and contributes significantly to the circular economy: the lifetime of products is prolonged, the environmental impacts of virgin production are displaced, resource efficiency is increased and reuse is facilitated. Waste is avoided, natural resources are saved and energy use is reduced.

In order to provide cost efficient repair, remanufacturing and refurbishment services, companies in the different sectors have established networks of service points and implemented a variety of collection strategies. This infrastructure is the backbone of the circular economy, giving products a new life.

Repair, remanufacturing and refurbishment operations are oftentimes centralized within or outside the EU to benefit from economies of scale and access to qualified technicians and high-tech equipment. Both centralized and de-centralized service models depend on the shipment of products and spare parts for repair, remanufacturing and used equipment. Millions of products are shipped every year for failure analysis, in-warranty and out-of-warranty repairs, for remanufacturing or refurbishing.

The associations supporting this position paper call upon the European institutions to facilitate the flows of the innermost loops of the circular economy. To this end, the undersigned associations recommend to:

1. Conceptualize the circular economy as a global flow of goods rather than as a European, closed economy. The circular remanufacturing economy is global and based on regionally clustered repair/remanufacturing facilities mirroring the global production chain.

2. Reduce administrative burden for shipments of products destined for failure analysis, repair, remanufacturing and refurbishment rather than increasing red tape.

3. Recognize legitimate business models by mirroring the Basel and WEEE 2 approaches in the Draft Correspondents’ Guidelines on the Waste Shipment Regulation currently under preparation.

4. Consult with stakeholders in defining key terms such as ‘warranty’, ‘professional use’ or signed declarations of functionality so that all products shipped for repair, refurbishment and remanufacturing are considered as ‘non-waste’ in alignment with WEEE and the Basel Convention Technical Guidelines.

5. Safeguard the existing exemptions for medical devices refurbishment.

Following our recommendations would ensure that the costs to repair, remanufacturing and refurbishment would be reduced. Shipment processes would be sped up. Ensuring the shipment of used EEE and spare parts will increase the live span of the related product thus contributing to the overarching objective of the circular economy.