POSITION | SUSTAINABILITY | STANDARDIZATION
ISO/TC 323 Circular Economy
Mirror international standardization strategically for the promotion of a holistic Circular Economy
July 13, 2023
The role of standardization in the Circular Economy
In the transformation to a circular economy, thinking across industry and state boundaries is central. The circular economy only works if market participants cooperate and knowledge is transferred. Planning security for circular products and processes as well as reliable quality standards that guarantee product safety are essential. The industrial shift to more circular business models is a complex process in which companies can currently rely on different terminology and basic principles of circular economy and only a few standardized indicator systems to support measurement and evaluation.
The drafting and further development of norms and standards is therefore central to meeting these requirements. In addition, there are established structures at national, European and international level for the processes of standardization, through which industrial activities can be influenced.
In order to develop a solid and harmonized standards structure that supports the goals of the Green Deal, the Circular Economy Action Plan (CEAP) and German industry, a reliable and progressive structure is needed to guarantee the transfer performance of international to European standardization –and vice versa.
Current developments in international standardization
Currently, technical and strategic standards are being developed and refined in various bodies at all three levels – national, European and international – in particular to accelerate the transformation of more circular products and services and to lower market access barriers.
With five working groups, ISO/TC 323 Circular Economy at international level is one of the most ambitious projects in the committee landscape as far as horizontal standardization is concerned. Here, fundamental topics such as the compilation of a product circularity data sheet or the breakdown of terminologies and principles as well as indicator systems of a circular economy are to be implemented.
The initiation and rationale behind the TC is fundamentally welcome, as there is a lack of cross-industry consensual definitions, and conceptual ambiguities of Circular Economy principles and definitions prevail even in academic discourse.
Unfortunately, the work in the various working groups of the TC is characterized in part by major discrepancies in content and a need for harmonization Particularly with regard to the goal of standardizing a holistic definition of the Circular Economy concept that goes beyond the concept of waste, undesirable developments can be observed. The fact that fundamental and horizontal ideas are being standardized at the international level, which are in contrast to the interpretation of German industry and the
regulatory framework at the EU level, must be recognized and strategically prevented at all costs. There must be no contradiction between ISO, EN and DIN standards.
In order to absorb this development for the European single market in the EU, with particular reference to the ongoing regulatory processes under CEAP, we see the establishment of a mirror body at EU level as strategically extremely important. However, we see room for improvement in the proposal of the Swedish Institute for Standards (SIS).
ISO TC 323: Status quo
The Technical Committee (TC) was established in 2018 on the initiative of the French standardization organization Association francaise de normalisation (AFNOR) to support standardization in the field of Circular Economy, linked to the goals of the UN Sustainable Development Goals (SDGs).
ISO/TC 323 Circular Economy: Structure
There are 76 active members, of which 19 members can be assigned to the European continent.
The work is divided into five Working Groups (WG),
1. ISO/TC 323/WG 1 - Terminology, principles, frameworks and management system standard
2. ISO/TC 323/WG 2 - Practical approaches to develop and implement Circular Economy
3. ISO/TC 323/WG 3 - Measuring and assessing circularity
4. ISO/TC 323/WG 4 - Circular Economy in practice: experience feedback
5. ISO/TC 323/WG 5 - Product circularity data sheet
Currently, there are draft standards in draft status from three working groups,
▪ ISO/DIS 59004 Terminology, Principles and Guidance for Implementation
▪ ISO/DIS 59010 Guidance on the transition of business models and value networks
▪ ISO/DIS 59020 Measuring and assessing circularity
Until the end of August there is the possibility to reject or accept the drafts, but major changes in content are no longer expected.
ISO/TC 323 - Circular economy
Critical evaluation of the contents from the WGs in ISO/TC 323
▪ The ambition level is very low
▪ No holistic interpretation in definitions of principles Points such as service life extension, design, upstream innovation are not taken into account in the definition of Circular Economy.
▪ No guidance for circularity
▪ Concepts are in part only of little help when transferred to company and product level
Possible negative effects
▪ Discrepancy with goals of Green Deal and CEAP due to varying interpretation of Circular Economy concept.
▪ Increasing fragmentation of the EU internal market in Circular Economy standardization.
▪ Linear concepts are declared as Circular Economy without the necessary transformation process
▪ Problem of availability of critical raw materials in the EU is insufficiently addressed
▪ In particular, the principles of established environmental management systems such as ISO 14001 et.al. are insufficiently used for the evaluation of options for action
Plea for a purposeful European reflection
With a mirroring of ISO/TC 323 Circular Economy at European level, the negative effects mentioned can be absorbed. In particular, the option of European annexes makes it possible to adapt the forthcoming international standards to the needs of the European internal market.1
We call for the European mirroring of ISO/TC 323 for the following reasons,
▪ Fundamental issues of the Circular Economy are defined, which have implications for all industries and elementary components of the transformations, e. g. measurability and definitions of Circular Economy and management systems
▪ In legislative projects relevant to industry, such as the Ecodesign Regulation (ESPR), the Green Claims Directive, the Critical Raw Materials Act and the Digital Product Passport, ISO TC323 standards are used, especially in the area of definitions. Without European adaptation, there is a risk here that these will not be compatible with the main objectives of the legislative projects.
Via the secretariat mandate and/or a convenor nominated by DIN in a European CEN mirror committee for ISO/TC323, Germany would gain other possibilities of influence and would have the possibility to actively moderate and also control the work in the mirror committee.
We also call for mirroring via DIN and DKE in a joint standardization mirror committee at German level to ensure the common holistic interpretation of Circular Economy at EU level and to respond to the partly fragmented interpretation within the EU.
Evaluation of the SIS proposal of a "CEN/TC Circular Economy"
Furthermore, we take a critical view of the submitted proposal of SIS for a new CEN/TC Circular Economy (28-04-2023).
Here, the proposed CEN/TC structure misses an opportunity to address horizontal Circular Economy standardization holistically at the European level, as electrotechnical standardization is insufficiently integrated in the current proposal. The proposal also excludes the area of eco-design.
The topics from ISO TC/323 can only be dealt with in a holistic and targeted manner in a joint committee from CEN and CENELEC (JTC) – thus with the involvement of the electrotechnical industry. This is also a sensible combination with regard to the extended product inclusion under the ESPR
Eco-design is an essential element of the Circular Economy and the current legislative processes on ESPR may amount to a future standardization mandate.
Therefore, we also propose the adaptation of the Swedish proposal to include the topic of ecodesign in the scope of a new (J)TC Circular Economy and to integrate the existing CEN-CLC/JTC 10 Material efficiency aspects for products in scope of Ecodesign legislation as a subcommittee of a (J)TC Circular Economy. So that the existing committees can be efficiently supplemented at European level.
Since the proposed TC Circular Economy, even under a preferred JTC structure, is a pan-European effort to advance Circular Economy standardization, this should also be reflected in the leadership of the (J)TC. Finally, to avoid repeating similar dynamics as in ISO/TC 323 Circular Economy, we propose a co-leadership of the new (J)TC. Furthermore, this would reduce the expected high workload for the leadership. A co-chair together with the Secretariat would allow three NCs to organize the work in an outstanding way and demonstrate a common European understanding of the Circular Economy. Furthermore, this would also take into account the fact that a Joint TC consists of both CEN and CENELEC experts.
Here we call for the German NC to co-chair.
Imprint
Federation of German Industries (BDI)
Breite Straße 29, 10178 Berlin, Germany
www.bdi.eu
T: +49 30 2028-0
Lobby registration number: R000534
Editorial office
Ms. Annika Stuckenhoff
Project Officer BDI Circular Economy Initiative
T: +49 30 20281585
a.stuckenhoff@ice.bdi.eu
BDI document number: D1802