Study on Socioeconomic Impacts of Increased Reparability

Orgalime appreciates the possibility to comment on the draft report on the socioeconomic and environmental impacts of increased reparability of products in the European Union ('the draft Report'), as currently carried out by BIO Deloitte, ICF-GHK and SERI on behalf of the European Commission.  The main objective of this report is to present cases studies with reparability requirements relevant for domestic washing machines, domestic dishwashers, vacuum cleaners and coffee machines. It describes a ‘business-as-usual’ scenario concerning the number of repairs, which is compared to 11 ‘alternative scenarios’.  In the annex, we provide comments on each of these alternative scenarios. 

In general, we take positive note of the appropriate differentiation made between consumer and industrial products.  Indeed, 80% of Orgalime´s membership in terms of turnover relates to capital goods and durable consumer goods that, more often than not are in a world leadership position at the level of productivity, in material technology, energy efficiency or other resource efficiency technologies. It is of course essential to recognise the inherent differences between consumer products and capital goods in terms of overall purpose, reliability, safety, durability or maintenance requirements.  Regarding repair, the draft report correctly states that industrial products are often subject to individual contracts with provisions on repair and maintenance.

Nevertheless, there are also a number of areas where we see the need for improvement in the draft report. Most importantly, we find that it looks at reparability too narrowly, in particular without applying a proper life-cycle impact analysis. Focusing only on the waste phase hinders innovation and risks shifting burden to other life-cycle phases. It follows that we do not find the results of this draft report suitable for being used for other product groups. Indeed, only a product-group specific case-by-case impact assessment can determine the feasibility of new requirements.