ETRMA Feedback to the Inception Impact Assessment on the review of the Sustainable products initiative

The European Tyre & Rubber Manufacturers’ Association (ETRMA) believes that the EU’s Sustainable Product Policy (SPP) offers an excellent opportunity to capitalise on existing technologies, best practices and rules in the rubber and tyre sector, which could find wider implementation to serve the purposes of a circular economy.

In welcoming this EU’s initiative ETRMA strongly recommends to:

1. strike a balance among environmental, social - including safety - and economic objectives for products and services
2. make sure the SPP will be built on sector-by-sector robust assessments and approaches
3. have effective enforcement and market surveillance for existing and future rules
4. create incentives at points of sale and through green public procurement for products and services to create some congruity between the supply and the demand side along environmental and social objectives
5. assure homogeneity of the EU actions for both, rules and incentives
6. implement as much as possible proven, relevant international standards to achieve the EU SPP goals.

Please read more here about the “ETRMA Feedback to the Inception Impact Assessment on the review of the Sustainable products initiative”

• 20201105_FINAL_ETRMA-IIA_SPP (pdf)