Circular Economy Product Labels – will current EU harmonisation efforts reduce fragmentation on the Single Market?
Products on the European market are subject to multiple labelling requirements relating to the circular economy. Companies that want to sell their products in Europe must adapt to these requirements, in both national regulations and EU law. In this study, the National Board of Trade maps out these requirements and analyses if forthcoming EU legislation will reduce the fragmentation on the Single Market.
Companies selling their products in the EU must adapt to different labelling requirements. This could include making their packaging larger in order to accommodate all the required labels. They may also have to use different kinds of packaging for different markets, thereby losing out on economies of scale. Furthermore, they must collect the necessary data and information to label their product correctly. This can be both time-consuming and costly.
So, will forthcoming EU legislation make it easier or harder for companies to sell their products in the EU? Will it facilitate the shift towards a circular economy?
In this paper, we have analysed the proposals for the new Regulation on Packaging and Packaging Waste (PPWR), the Ecodesign for Sustainable Products Regulation (ESPR), the Green Claims Directive, the Battery Regulation and the European Critical Raw Materials Act (CRMA). These harmonisation efforts could contribute to reducing the regulatory burden of the different labelling requirements on European companies. However, challenges remain. Our analysis shows the need for adopting harmonising legislation as soon as possible as national requirements are continuously being drafted.
Legislative recommendations on labelling, facilitating the shift to a circular economy
In this PM, the National Board of Trade puts forward some recommendations that we believe could contribute to the shift to a circular economy while preserving the functioning of the Single Market, as well as global trade. The recommendations are directed to EU policy makers and policy makers in the Member States. Among them a call for the Commission and the member states to seek to align national and European labelling schemes with international standards.
The EU should also engage in the appropriate international fora to influence or promote new international standards in line with EU priorities in circular economy labelling. Another recommendation is that the member states should restrict national circular economy labelling requirements to only include labels necessary for the functioning of the extended producer responsibility (EPR) schemes that are in place.