Sustainable Products Initiative
Position paper accompanying input of the European furniture industries to open public consultation

Sustainable Products Initiative European furniture industry insights Position paper accompanying input to open public consultation

 

June 2021

The European furniture industries embrace EU circularity objectives1 and welcome the opportunity to provide comments on the open public consultation feeding into the upcoming Sustainable ProductsInitiative (SPI), building on the views of the industry provided to the roadmap consultation in November 2020.

General recommendations to policymakers

 

  1. Take a holistic approach in the development of new legislation, avoid addressing the same issues with several initiatives and contradictions between existing and upcoming legislation and tools. It is important that legislators work with a clear scope and do not ’reinvent the wheel’.

  2. Establish harmonised legislation at EU level, with harmonised definitions and ways of reporting (e.g., harmonised rules are needed at EU level for recycling symbols and sorting instructions). Avoid that Member States adopt differing legislation on the circular economy. As an example, uniform Extended Producer Responsibility schemes are needed in the Member States, as differing schemes would lead to unnecessary additional administrative and logistical expenses, but also to costs that do not add any value to the Circular Economy.

  3. Involve and consult standardisation bodies in the process, as well as the industry for sectorrelated expertise and recommendations. Work on circular economy is ongoing both at CEN (CEN TC 207 - Furniture) and at ISO (ISO / TC 323) level and best practices exist in the industry. Technical specifications and how these should be verified should be set in standards. The standardisation work is well established within the EU and must continue playing an important role in the implementation of future legislation.

  4. Consider a value chain and ecosystem approach. The success of the furniture industry in transitioning to a more circular economy also depends on suppliers of components and materials, on consumer mindsets and behaviour, as well as on players involved in distribution and waste management, including new service providers that will appear on the market.

  5. Consider the complexity of not only the furniture value chain, but also of the product itself. The furniture product range is very varied, ranging from chairs and seats, cabinets, kitchens, bedding, office furniture, project furniture, etc., and many different materials are used in furniture production (e.g. wood, plastics, textile, steel, glass, composites, foam).

  6. With this complexity in mind, consider that only general design principles should be established as part of ‘effect goals’3 at EU level, instead of binding rules. The technical solutions should be entrusted to the industry in collaboration with relevant stakeholders. Setting binding rules at EU level per product, detailing what rules producers are obliged to follow and requirements for technology development will be to the detriment of the industry. 

  7. Consider the two different distribution systems in the furniture market (B2B and B2C), where the B2C distribution system has by far the larger market share in terms of turnover and quantity of furniture in the total market. The B2C means that the end customer has a contractual relationship with the furniture retailer and not with the furniture manufacturer, therefore the furniture manufacturer usually does not have direct contact to the customer. Companies in B2B operate under completely different conditions than those under B2C, both in terms of possible (circular) business models and competitive conditions. These complexities of the furniture industry (in addition to the complexity of the product range and materials) must be considered when setting rules in many areas (e.g. warranties, take-back systems, or reverse logistics specialized in furniture, a necessary system capability to enable processes in the context of refurbishment and remanufacturing).

  8. With this complexity in mind, allow companies to adopt the circular business models that work best for them, as this is mainly market driven. SPI and circularity policies should only set the overall goals and consider that some business models will not work for certain product groups.

  9. Consider the complexity of value chains and of the sector when developing the product passports. Although these tools have a large potential to drive circularity, they should be based on existing legislation and schemes and must not become an administrative burden. Product passports should have a pragmatic approach and only provide information that is important and useful for the intended receiver or target operation. Consider making a differentiation between compulsory and voluntary information.

  10. Grant flexibility to the sector’s companies to adapt to new requirements during a reasonable transition period as well as to find the technical solutions for established policy goals and their own way to contribute to circularity. There is no one-size-fits-all solution. Ensure that no additional and unreasonable administrative burden is placed on the industry, which is mainly composed of SMEs and microenterprises. Companies' sustainability agendas are largely market-driven and not primarily by legislation, therefore legislation should be applied with caution and only in the case of market failures. The desire to operate in a responsible way is a main driver, too.

  11. Apart from granting a reasonable transition period to the industry, incentivize demand for circular products, both from public institutions and consumers, and reward companies that invest in circularity. Price remains a main driver for consumer choice. As such, pricing differences between products should be levelled.

  12. Put in place research and innovation funds to drive a systemic shift toward a circular economy. Large-scale studies, supported by the European Institutions, would support the purpose of building more knowledge on the circular economy.

  13. Ensure that products imported from third countries comply with the same rules that are applicable to EU manufacturers and put in place adequate market surveillance and enforcement efforts. Products produced in the EU are regularly more expensive and it is difficult to compete against countries with lower labour costs.

  14.  Labels and green claims should be voluntary. Avoid putting additional labels on the market and consider that labels are primarily used at the purchasing time, therefore they are not a tool for long-lasting information relevant for the purposes of the circular economy. We urge policymakers to adopt a constructive approach towards developing an EU methodology to quantify environmental impacts, where the industry is involved in the development of a sector-specific solution for the furniture sector.

  15. Consider the global aspect when creating and implementing circular economy rules, and the fact that the furniture industry is highly export oriented.