Executive Summary and Recommendations

The Sustainable Consumption of Goods Initiative (SCGI) covers the development of a European
Commission proposal to amend the Sales of Goods Directive (EU) 2019/771 with right-to-repair
requirements. The undersigned associations welcome the feedback opportunity for this initiative.
Nonetheless, the undersigned associations would like to offer recommendations, further explained
in this paper, in order to optimise the efficiency of the SCGI in relation to other EU policies.

Recommendations

1) HVACR equipment is long-lasting and repairable
2) Avoid overlaps with existing legislation, e.g., the Ecodesign Directive
3) Product-specific requirements for HVACR equipment under the Ecodesign Directive
4) Include importance of training and certification