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ESPR deal: End of take-make-waste economy impossible without recycling of unsold goods

05 December 2023

Yesterday, EU negotiators reached a provisional agreement on the Ecodesign for Sustainable Products Regulation, a key part of Europe’s strategy to foster a circular economy. This regulation aims to make products more durable, reusable, upgradable, reparable, recyclable, and easier to maintain. It targets a range of products including textiles and footwear and intermediate products.

EuRIC, the voice of Europe’s recycling industries, welcomes the agreement, which incorporated most of the recycling industries’ main points, such as the compliance of online marketplaces with EU legislation, the requirement for transparency in reporting the destruction of unsold goods, and the introduction of the “Digital Product Passport”.

However, we regret the fact that the imposed direct ban on the destruction of unsold textiles and footwear fails to consider the role of recycling. Ending the take-make-waste cycle (linear economy model) is a significant step towards circularity but is impossible without recycling operations. To equate recycling with destruction contradicts the very objectives of the Circular Economy Action Plan. The path to circularity should be defined by recycling operations, providing a second life to materials. Recycling is not destruction, but a resource recovery process, crucial for extending the lifecycle of materials. Therefore, we strongly urge lawmakers to correct this miscalculated oversight and include recycling as a possibility to treat unsold goods, whenever reuse is not possible.

Regarding motor vehicles, although they are excluded from the provisional agreement’s scope, their ecodesign provisions will be addressed in other legislation, such as the Regulation on circularity requirements for vehicle design and on management of End-of-Life Vehicles. In this context, EuRIC highlights the necessity for powerful drivers such as targeted design for dismantling or recycled content targets for plastics and beyond plastics to enhance re-use and pull the demand for circular and low-carbon materials use into new cars.

We now call on lawmakers to recognise recycling as key pillar of the circular economy in the upcoming regulatory framework, explicitly acknowledging its role as a recovery operation, especially for unsold textiles and footwear.