Rare earth elements content disclosure in consumer goods

The February 10, 2020 law on fighting wastefulness and on the circular economy (n°2020-105) aims to enhance transparency and promote environmentally responsible consumer choices by providing detailed product information. It includes a provision requiring the disclosure of precious metals and rare earths content present in consumer goods. This rule applies to vehicles and electronic goods and will progressively come into force from 2023 to 2025. This legal obligation is codified in article L.541-9-1 of the Environment Code, and implementation rules can be found in section VIII of article R. 541-221 in the same code.
It specifies the following:
1. Repairability and Durability Information: For certain electrical and electronic equipment, a repairability index (or a durability index from 1 January 2024) is displayed, indicating how easily the product can be repaired.
2. Recyclability: This concept is defined by criteria including effective collection, sorting, absence of elements that impede recycling, and the ability to recycle more than 50% of the material by mass. Products meeting these criteria are labeled as "mostly recyclable" or "entirely recyclable."
3. Presence of Precious Metals: Products containing more than 1 milligram of gold, silver, platinum, or palladium must be labeled with the quantity of each metal.
4. Presence of Rare Earth Elements: Similar to precious metals, products containing rare earth elements above a certain threshold must be labeled with the specific quantity.

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