Executive Summary

Furniture is well suited for a circular economy and there is potential to drive it further in the industry. There are indeed some opportunities in being identified as a product for potential first action under the ESPR, such as 1) harmonisation and closing regulatory gaps and 2) increased circularity and material efficiency. However, the ESPR focuses on products and a combination of different tools and other legislation is needed to fully close the loop and enable a real transition to the circular economy. While we agree that prioritising furniture is reasonable considering the market size, volumes produced and the potential for a circular economy, in Annex I we are providing comments on JRC findings that in our view do not represent the furniture industry correctly and/or are not substantiated enough.

The furniture industry consists largely of SMEs & microenterprises, therefore the performance and information requirements should be manageable for all companies. The furniture range is very diversified, with many furniture types and materials used. Therefore, it would be difficult to have ecodesign requirements applying on a general (horizontal?) level to all products. We believe that some sort of categorisation would be needed within the delegated act, most probably in furniture subgroups. Some requirements may be applicable to many types of furniture whereas others are material-specific or product type-specific. Considering this, the delegated act must allow for a diversity of relevant requirements where the focus should be on the impact objective to be achieved in terms of reduced ecological and climate footprint. Requirements should be set having a holistic approach and from a lifecycle perspective. Any requirement set should not have a negative effect on other important ecodesign criteria or be in contradiction.

EFIC experts will be glad to assist and provide sector-specific expertise in all stages (Ecodesign Forum, preparatory study, impact assessment, etc.). Consider also that standardisation committee CEN TC 207 (Furniture) and its WG 10 (Requirements and tools for furniture circularity) has started developing standards for product aspects under article 5 of the ESPR. These standards should be used as a basis or considered in parallel for the development of a delegated act for furniture, and whenever relevant be harmonised at EU level for presumption of conformity.