Ref. Ares(2023)3183409 - 05/05/2023
Today, there is no clear, standardized way to define and verify lifespan. For this reason, it is premature to consider a
legal obligation to communicate the lifespan of product. Our recommendation is to first identify the key areas and
products that would benefit from such requirement, and thereafter work on a standardized definition and comparable
measurements. Only then, we can truly evaluate the pros and cons of such requirement.
SPARE PARTS
Spare parts availability is a key enabler for repair and refurbishment. As a retailer that offers a complete home furnishing
range of nearly 10,000 products, we understand how complex a spare parts offer approach for our range is. It is a fine
balance between 1) making spare parts available; 2) providing them in a reasonably short timeframe; 3) avoiding over-
part range can be very costly and of little value if the produced spare parts are not used. In our view, the time frame for
spare parts availability should be adaptable to ensure it creates the most value, taking into account the demand trends
over an extended period of time (years).
Our recommendation is to define a common framework, accompanied by specific product-related rules. For
example, considering the fol owing parameters on a general level:
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Maximum lead-time of parts to customers in a market
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Minimum time-period of availability of parts
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Principles defining what is a suitable spare part offer for customers (e.g. do it yourself principle) and what are crucial
parts for maintaining the product function
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Accompanied with product level requirements.
It is also important to consider the terms for access to spare parts based on concrete cases, addressing safety and liability
questions. We secure access to spare parts for repair, limiting this offer to what can be done by the customer on their
own. As of today, we do not ensure access to parts that may lead to unsafe exchange by customers or require specific
technical equipment or skil s.
RESTRICTING AND COMMUNICATING CHEMICAL CONTENT
Harmful substances pose a true chal enge in the transformation toward securing circular raw materials and products.
IKEA is supporting restrictions and/or bans to limit use of problematic substances on an EU-level. Restricting
hazardous substances is the best way to ensure safety and circularity of products and materials. However, it is important
to take into consideration the essential use of some substances in certain materials and application,
IKEA is also supporting the regulatory movement towards more legal requirements on information about chemicals
used in the supply chain. We want to be transparent about the use of chemical in our products. At the same time, we
believe this information should be understandable and relevant for customers. It is important to comprehend how
difficulty the long ingredient lists wil be for customers to understand (for example ingredient lists currently available for
cosmetics). The magnitude of the work needed for al actors in the supply chain to accomplish a ful disclosure of the
ingredients list is vast. For this reason, we recommend a stepwise approach, where the initial focus shall be on the
information that is of greatest importance.
The customer access to information is also important to consider. The information should be available electronical y,
enabling companies to keep the information up to date.
IDENTIFYING AND COMMUNICATING MATERIALS
Traceability of materials supports overall circular ambitions and recyclability. It is important however to first have a
common global identification of materials. This is to a certain extent missing today, and it is a precondition for building
a systemic support, for al actors in the supply chain to input data under a common identification. It is equal y important
to have clear common definitions for different waste streams supporting companies in correctly claiming, for
example, a recovered, recycled, reused material. When communicating material lists, it is also important to consider that
in certain cases, information on material and substances ingredients are protected by disclosure agreements. A certain
degree of flexibility wil be necessary, to recognize the needs of responsible sourcing and local availability of materials.
Pos t on on the EU
Group 7 June 2021
3
CARBON FOOTPRINT & ENVIRONMENTAL PERFORMANCE
We support efforts aimed at enabling and encouraging companies to communicate about the environmental
performance of their products. For a framework to work, it should be based on common measurement methodologies
(product-specific) and the availability of an extensive data set. Time will be needed to build these pre-conditions. Our
recommendation is to fol ow a stepwise approach, where priority should be given to the creation of product category
rules to calculate carbon footprint, starting with the product groups with the highest potential of impact. This wil
create a good basis for substantiating voluntary claims. At the same time, we encourage the European Commission to
assess what triggers consumers behaviors and to what extent information on carbon footprint wil support consumers
informed choices. Only as a second step, when the readiness of the methodology and data are more mature and the
value of that information is assessed, it could be considered as a mandatory information requirement.
DUE DILIGENCE REQUIREMENTS AND CONNECTION WITH CORPORATE SOCIAL RESPONSIBILITY
Due diligence can make a significant difference for people and planet by helping businesses embed sustainability into
their governance and decision making. We support wel -designed, harmonized legislation across the EU on human rights
and environmental due diligence. In the interest of developing a regulatory framework that is effective, efficient, and
feasible, we urge the Commission to streamline due diligence requirements from the perspective of the entire value
chain rather than at product level. Such an approach, as suggested in the Sustainable Corporate Governance
initiative, would require businesses to identify and mitigate human rights and environmental risks from all aspects of
the value chain (aligned with the existing UN Guiding Principles and OECD Guidelines), from raw material through
product to the home. Understanding the risks from a holistic view enables businesses to then act accordingly as the risk
applies to products, services, or operations. To effectively meet due diligence information sharing requirements at the
be col ected properly or thoroughly, customers risk receiving inaccurate, inadequate, or misleading information and the
information alone does not necessarily improve the lives of people and the environment in the value chains. We urge
these discussions to be taken within the Sustainable Corporate Governance initiative.
For more information:
About IKEA
IKEA offers wel -designed, functional and affordable, high-quality home furnishing, produced with care for people and
the environment. There are several companies with different owners, working under the IKEA Brand, al sharing the same
vision: to create a better everyday life for the many people. IKEA was founded in Sweden in 1943.
About the IKEA franchise system
The IKEA retail business is operated through a franchise system with franchisees that are authorised to market and sel
the IKEA product range within specified geographical territories. Inter IKEA Systems B.V. is the owner of the IKEA Concept
and worldwide IKEA franchisor, who also assigns different IKEA companies to develop the product range, supply products
and deliver communication solutions. Today, 12 different groups of companies have the right to own and operate IKEA
sales channels under franchise agreements with Inter IKEA Systems B.V.
About Ingka Group
Ingka Group (Ingka Holding B.V. and its control ed entities) is one of 12 different groups of companies that own and
operate IKEA retail under franchise agreements with Inter IKEA Systems B.V. Ingka Group has three business areas: IKEA
Retail, Ingka Investments and Ingka Centres. Ingka Group is a strategic partner in the IKEA franchise system, operating
378 IKEA stores in 31 countries. These IKEA stores had 706 mil ion visits during FY20 and 3.6 bil ion visits to www.IKEA.com.
Ingka Group operates business under the IKEA vision to create a better everyday life for the many people by offering a
wide range of wel -designed, functional home furnishing products at prices so low that as many people as possible can
afford it.
Pos t on on the EU
Group 7 June 2021
3
