The EF methodology should be used as an underlying approach in supporting product policies, rather
than a policy in itself.

Potential benefits of using the EF method in product policy:
EUROFER sees the need for a coherent product policy framework that supports a circular economy and sustainability, giving full recognition to materials at the design stage that are fit for circularity and support sustainable outcomes. We see a lifecycle approach in product policy as the only way to achieve this, and the EF method could provide the coherence if it is used in existing product policies that focus on different lifecycle stages e.g. design, production, use or end of life.

We believe the greatest benefit of PEF can be achieved when applied in end-product applications, rather than in the supply chain of semi-finished products. This is because the product design stage, including the materials used and other product design choices, has the greatest potential to improve environmental performance of a product, and in particular the degree of circularity achieved during the waste management of products at end-of-life.