Promising:

• Although primarily a supply-side tool, eco-design focusing on, for instance, durability, repairability and recyclability of products may have an impact on the level of material consumption, so long as this results in an actual replacement of/prolonging buying a new product. We therefore very much welcome the Commission's continued focus on eco-design aspects as part of its sustainable product policy legislative initiative and in sector- and material-specific initiatives put forward (see below). It is particularly promising to see the suggested widening of the Ecodesign Directive beyond energyrelated products. There has long been a policy gap in terms of eco-design requirements of products that are not energy related.
• Lack of transparency is a significant barrier to circular economy approaches, in particular those involving material streams where legacy substances2 are an issue for value retention and reuse (such as plastics and textilesxii). We therefore welcome the Commission's initiative to establish a common European Dataspace for Smart Circular Applications with data on value chains and product information. This is in line with the Think 2030 recommendations calling for the establishment of a centralised system for environmental product information in the EU to support industry and regional initiatives in the transition towards circularityxiii.
• We also welcome the acknowledgement of mobilising the potential of digitalisation, such as digital product passports, as they might help foster harmonised implementation approaches across Member Statesxiv, support private sector front-runners and enable various stakeholders to establish a better and more reliable understanding of the links between choice and impact. Supporting product-level information exchange and transparency might also help provide for overall tracking of consumption and environmental footprint indicators (see further points in relation to "Monitoring progress", below).
• It is promising that the Commission will consider introducing mandatory requirements to increase the sustainability of goods as well as services. Adopting minimum requirements on for instance material or resource efficiency of products placed on the EU market could be one effective approach. For instance, as energy efficiency of products covered by the Ecodesign Directive has improved thanks to existing rules and standards, the relative significance of other environmental impacts of these products has increased and therefore ought to be addressedxv. A recent IEEP think piece on greening the EU Industrial Strategy provides further insights on role of resource efficiency in this regardxvi.

Potential issues:

• While it is encouraging that the Commission will consider widening the Ecodesign Directive beyond energy-related products, it is important to recognise that it needs to be accompanied by the development of standards and testing methods to support harmonised verification of new requirements.
• We encourage the Commission to clarify how support for the development of a European Dataspace for Smart Circular Applications will be provided, e.g. through the Communication on the SME strategy for a sustainable and digital Europe. While the SME Strategy elaborates support for SMEs to better access and make use of already available data sets, the gathering, processing and reporting on product/ value chainspecific data envisaged in the CEAP can be both difficult and costly for individual firms, and sometimes relevant metrics are missing altogetherxvii.

• Legislative proposal empowering consumers in the green transition
• Legislative and non legislative measures establishing a new "right to repair"
• Legislative proposal on substantiating green claims

Promising:

• We welcome the initiatives to put forward a legislative proposal on information to consumers on product lifespans, availability of repair services, spare parts and repair manuals, and the establishment of a new Right-to-Repair. Planned obsolescence is prevalent and it is increasingly (often intentionally) difficult to repair for instance ICT products and small electronic devices. The effective lifetime of many consumer products is shrinkingxviii. This development is wholly incompatible with the ambition to ensure an EU economy within the planet's boundariesxix.
• We also welcome the initiative to put forward a legislative proposal on substantiating green claims. There is currently a high volume of different green claims on the EU market with and without independent verification, creating confusion and possibly eroding consumer confidence in the legitimacy of the claims. The lack of coordination, credibility and comparability between green claims is an issue for advancing a more circular economy within the boundaries of the planet (e.g. to be able to trace materials in recycled products) as well as for people's safety when it comes to potentially toxic chemicals in products, for instance.
• Reliable and transparent information - as opposed to 'greenwashing' - could meanwhile support the growing interest among investors and shareholders to channel funds toward more sustainable, low-impact solutions, for instance by forming the basis for standards and labels for green financial products. The Commission's continued commitment to developing EU Ecolabel criteria for financial products is therefore welcome.
• We welcome the Commission's commitment to include, more systematically, incentives in the labelling criteria that encourage companies to develop products that are more durable and easier to recycle.

Potential issues:

• So far, keeping citizens' responsible for delivering more sustainable consumption through our choices as consumers has had limited impact. Despite many years of relying on information-based policy tools, such as labels and awareness-raising, Europeans' consumption patterns have remained relatively unchanged^xx.
• In fact, there is limited evidence to suggest that improved information about products' environmental impacts, such as eco-labels, result in real-life changes in purchasing behaviour because of various rebound effects, subconscious routines and habits, etc.3 ; let alone at the scale required. Our choices as consumers (be them household, private sector or public) remain largely driven by price and convenience^xxi. It is also problematic to place the responsibility for the transformational shift required on citizens' role as consumers, while market and societal levers remain set on encouraging increased levels of material consumption.

Promising:

• We very much welcome this initiative which is in line with the 2018 Think 2030 recommendations, urging the Commission to "Expand circular and green procurement guidelines to more sectors/ product groups and gradually transform guidelines into mandatory requirements"xxii. Given the size of public procurement in the EU economy4 , public procurement criteria can be an effective instrument in bringing about wider change in the market by creating demand and acceptability for more circular products, and business models, which, at scale, may contribute to reducing the EU's material consumption.
• It is meanwhile an important message that the Commission is ready to move from voluntary guidelines to mandatory criteria. This may have impacts also on the penetration of existing voluntary criteria.
• One current barrier to implementation of circular procurement criteria specifically is a lack of knowledge and expertise to do so5 . It is therefore positive to see the Commission's commitment to continue to support capacity building through, for instance, the proposed "Public Buyers for Climate and Environment" initiative.

Potential issues:

• It remains to be seen what criteria and targets will be prioritised. Importantly, procurement criteria should cover high-volume products and include more than energy efficiency, such as, for instance, level of reusability or other measures to reflect product longevity.