Project Description: Supporting regulators in overseeing eco-innovative business practices that reduce waste and extend product life.
Within the framework of the circular economy circular, business models are promoted. These models aim to extend the lifetime of products and prolong the use of materials. It concerns products or materials which are being reused or further used for a another, new purpose (extended use). Prior to reuse or extended use they may be repaired, refurbished or remanufactured.
Circular business models aim - in accordance with the waste hierarchy - to prevent that products or materials are discarded and become waste. However in practise questions may arise whether indeed a substance or object is discarded or not.
Topics which in practise lead to questions:
- distinction between reuse and repair, refurbishment or remanufacturing
- distinction between reuse and preparing for reuse; what repairs are still accepted under reuse?
- meaning of ‘extended’ use, distinction with reuse (reuse: same purpose; extended use often not the same purpose); what requirements should extended use meet?
- distinction between reuse/extended use and by-product
- reuse: when is a material suitable for direct reuse for the original intended purpose? what conditions or criteria has the product to fulfil? the same characteristics of the virgin product?
- the need of certification after the step of repairing, refurbishing or remanufacturing in order to establish that the product may be considered as new good,
- the need of a system to grant a guarantee for the repaired product (especially for EEE)
- used component brokers have to be certified and even remanufacturers to ensure the logistic reman chain is not used to cheat EU waste legislation.
- authorising a preparation for reuse activity: can this be done through a simplified procedure? is the final product a sort of an EoW or something different?
- intention to discard; the intention of the holder of the material (is it a burden or not?), example used clothes
- temporal storage
- second hand clothes, second hand furniture or other donated goods: should be used for the same purpose? Furniture as fuel is waste? Second hand clothes which are collected for chemical recycling waste?
The aim of this sub-project of the WMCE Umbrella Project is to prepeare a guidance for environmental authorities in regulating in navigating the complex issues surrounding the concepts of discard, reuse, and extended use within the context of the circular economy. As new business models emerge that prioritize sustainability and resource efficiency, it becomes increasingly important to clearly define when a material is considered waste and when it remains a product for continued use.
The guidance will provide clarity on the distinctions between reuse, extended use, and preparing for reuse, along with practical tools and examples to support consistent decision-making. It will also offer recommendations for assessing whether a material or product has been discarded, including conditions that must be met, the roles of self-assessment versus prior approval, and the use of supporting tools such as declaratory opinions.
In addition, the document will address practical aspects relevant to inspections—such as temporal storage and certification requirements for repair operations—and propose inspection tools to assist regulators in the field.
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