Six Steps to a Circular Economy
2. Product Design as an Anchor of the Circular Economy The design of products must meet many market requirements. These include product safety, functionality (e.g. stability and flexibility), hygiene regulations and marketability, etc. (so-called "design for performance"). At the same time, product design, jointly with the available technologies, determines whether products and materials can be used for as long as possible, can be reused ore have to be discarded. Thus, product design is a decisive element to keep materials and products at the end of their service life in as many cycles as possible with little or no loss of quality. In its 2020 NCEAP, the EU Commission has therefore declared sustainable product design to be a focus of its future policy within the framework of a "Sustainable Product Initiative (SPI)". On the one hand, the scope of the Ecodesign Directive will be extended beyond energy-related products and, on the other hand, sectoral strategies and specifications for a sustainable product policy will be developed. The SPI focuses on the goal of increasing the circularity of products (durability, reusability, reparability, recyclability, etc.). The Ecodesign Directive has worked well in the past as a requirement framework for increasing the energy efficiency of energy-related products. Here "tailor-made" requirements have been implemented for the product groups affected to date. Therefore, the new legislative initiative should make use of the regulatory system of the Ecodesign Directive in order to improve it in line with the requirements of a circular economy. To this end, the scope and regulatory system of the Directive, which have so far focused on energy consumption, must be adapted accordingly. New requirements for "Design for Circularity" within the framework of the Ecodesign Directive should also, as has been the case to date, be developed with the consultation of the industry sectors and companies concerned, and justified by considering the ecological impacts throughout the entire product life cycle. At the same time, the EU Commission has already begun to make product design the focus of regulation in sectoral legal acts. Examples of this are the EU Battery Regulation draft or the work on the amendment of the EU Packaging Directive. In the case of these and other projects of central importance to the economy, it will be important, as with the extension of the Ecodesign Directive, to establish product design requirements together with the economic players involved. These are to be defined in the light of the state of the art and its progress, thus innovations in materials, manufacturing, processing and recycling technologies and in the repair and collection infrastructure harmonise with the product design requirements. Overall, it is of high importance that the EU initiative on sustainable product policy and the parallelly running European chemicals strategy for sustainability do not create new contradictions or duplicate regulations in requirements for the design of products and their safety and the substances used. Claim: The German government should advocate the product-specific consideration of "design for circularity" criteria such as durability, reusability, reparability, recyclability, etc. within the framework of the EU's sustainable product and materials policy. Possible conflicts of objectives arising in this context, e.g. with the "design for performance" of products, must be resolved in the sense of a holistic "design for sustainability" in a circular economy. Only through uniform rules in the EU internal market and uniform enforcement and market surveillance, such criteria may become effective for a large number of products. In addition, it must be ensured that imports from third countries can only enter the EU internal market if the requirements are met, to avoid competitive disadvantages for European companies. For those product groups that do not fall within the scope of the Ecodesign Directive in the future, specific regulations must be used or created with regard to their sustainable product design. Besides others,
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