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6. Intelligent Use of Data and Consistent Requirements for Circular Economies

in particular using recycled materials, or from renewable raw materials. In addition, § 45 covers products that are characterised by durability, ease of repair, reusability and recyclability.

As part of its "Green Deal", the European Commission plans to propose binding minimum criteria and targets for green public procurement in sector-specific legislation.

Claim:

The German Government should ensure that the provisions in the Closed Cycle Management and Waste Act adopted in the last legislative period generate a real impact, unlike in the past. To this end, the awarding bodies should be further supported, e.g. by means of target-oriented general administrative regulations and competence centres. At the European level, the German government should advocate manageable and unambiguous regulations on GPP in the context of the Green Deal that comply with public procurement law and encourage the tendering of climate-friendly circular economy products and services. To this end, it will also be necessary to ensure that the products and services to be procured are also identifiable as such for the procuring entities.

6. Intelligent Use of Data and Consistent Requirements for Circular Economies

The material composition of products and waste plays an important role in the success of the circular economy. Sincein particular durable goods only reach the end of their life and the subsequent recycling stage after years or decades, there may be little or no information available on their material composition. Thus, in the future, intelligent digital systems for information on substances in products should be established that actually offer added value for the industrial management of efficient value-added cycles. Knowledge of the presence of "substances of very high concern" in products in accordance with chemicals legislation (REACH) and the appropriate, risk-based handling of these in production and recycling processes are also central to market approval and acceptance by consumers. However, the goal of a "zero pollution ambition" formulated by the EU Commission as part of the "Green Deal" must also be questioned in this context, since many substances perceived as "pollution" are natural components of the environment. Therefore, there is a need for a realistic, practice-oriented assessment of the real risks of substances used in product and material cycles, based on the principle of proportionality.

Claim:

The German Government should work to ensure that the interfaces between product, substance and waste law are coordinated in such a way that companies gain legal certainty in closing material cycles and that there are no contradictory regulations. In addition, new ordinances, guidelines and regulations for the end of waste status and for by-products should also be considered.

Scientific risk assessment must be retained as a core element of chemicals management. At EU level, there must be a focus on coherence between the ambitions to further develop the Circular Economy and the Sustainable Chemicals Strategy.

Digital information systems, such as the announced digital product passport of the EU Commission, which are to provide the necessary data for closed product and material cycles, are to be developed together with the circles involved. This is particularly important against the background of preventing future initiatives

that are not target-oriented and cost-intensive, such as the implementation of the so-called SCIP database (pursuant to Article 9(1)(i) of the Waste Framework Directive).

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