​​The EU has unveiled its master plan to move beyond the ‘throwaway economy’ today. Despite the absence of targets to reduce the impact of our consumption, the strategy is a once-in-a-generation opportunity to transform the way we manufacture and use our products in a way that benefits people and the planet.

The European Commission’s Circular Economy Action Plan (CEAP) is the most ambitious and comprehensive proposal ever put forward to reduce the environmental and climate impact of our products and economic activities.

The EU has a political responsibility to reduce resource use as well as the carbon emissions and other environmental impacts resulting from wasteful production and consumption patterns, said the European Environmental Bureau (EEB).

The strategy outlines the need for a truly responsible value chain, from product design and manufacturing to reducing toxicity and cutting waste. It also specifically addresses some of the product groups with the largest environmental footprints, including textiles, electronics, batteries, construction, packaging, and although less prominently also furniture and automotives. 

Proposed measures aim at making sustainable products the norm and fighting premature obsolescence. For example, minimum repairability requirements aimed at facilitating the disassembly of smartphones will considerably extend their lifespans.

The EU also wants to set a food waste reduction target and promises to end over-packaging as well as microplastic pollution.

While praising the strategy, and despite the introduction of a goal to double the share of secondary materials in the economy by 2030 (circular material use rate), the EEB regrets that no target was set for reducing resource use and its impacts in absolute terms. Waste prevention targets for businesses and industries are also missing.

Stephane Arditi, the EEB Policy Manager for the Circular Economy, said: 

“The Circular Economy Action Plan can be a turning point for sustainability and climate action in Europe, which will hopefully inspire the rest of the world. It shows that the systemic change the people and the planet need is within reach.

Now the EU institutions and governments need to turn these promises into laws to ensure the absolute reduction in carbon emissions and resource use.

We only have one planet and yet we consume resources as if we had three. It’s time to do more with less.

On the missed opportunity of having a target for resource use and waste generation, Arditi said:

“The proposal ticks almost all boxes, but does not explicitly target Europe’s over-consumption of resources. Without binding EU-wide targets, governments risk losing momentum and neglecting the fundamental objective of reducing our consumption footprint.

Last week, the EEB criticized the European Commission for publishing a far less ambitious proposal to reach net-zero carbon emissions by 2050.

 

Area of focus The Commission’s proposal The EEB’s comment The EEB’s assessment
Resource reduction target Advancing towards keeping resource consumption within planetary boundaries

Reducing Europe’s consumption footprint and double its circular material use rate in the coming decade

Developing indicators on resource use, including consumption and material footprints

While it acknowledges the need to decouple growth from resource use, keep consumption within planetary boundaries and develop indicators in these areas, a clear initiative which would start a political process to establish targets and related impacts in absolute terms is clearly missing. As in other areas such as energy efficiency and GHG emissions, clear targets to reduce our dependence on and reverse our unsustainable relationship with resources are urgently needed. See our position paper on a the need for a headline target and our report on debunking decoupling.

It is regrettable that there are no provisions to restrict unsustainable mining practices in or outside the EU, notably deep-sea mining. See Seas At Risk’s position on natural resources.

 

 

Product policy

Proposing a sustainable product policy initiative to ensure that performance of front-runners in sustainability becomes progressively the norm for all products and services placed on the EU market Product policy has a central prominence in the text. The EEB welcomes the long-awaited integrated product policy that through “horizontal measures” will ensure that products placed on the EU market are sustainable, including through broadening the application of eco-design style requirements. The timeline of this work will be critical so we welcome efforts to increase the effectiveness of the Ecodesign framework. We also stress the importance which a digital product passport could play in supporting this overall framework. See our position paper on product policy and campaign website Coolproducts.
 Empowering consumers

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Right to Repair

Strengthening consumer protection against greenwashing and premature obsolescence

Enabling information on products lifespan and reparability

Establishing a new “Right to Repair”

Minimum mandatory green public procurement (GPP) criteria and targets

Eight in 10 Europeans think manufacturers should be required to make it easier to repair electronic devices or replace parts. Nine out of 10 would like to see information on the expected life of products. The European Commission’s proposal is moving in this direction. See the Right to Repair Europe reaction.

Also, six out of 10 consumers struggle to understand which products are truly green. Citizens must be able to be guided by reliable labels, such as the EU Ecolabel. In this context, we applaud initiatives setting minimum requirements for sustainability labels/logos and requiring companies to substantiate green claims.

We welcome efforts to make Green Public Procurement (GPP) the default approach, as public authorities should lead by example. Initial sectors to phase in mandatory GPP could be textiles, food, construction and electronics.

 

 

 

 

 

 

 

 

 

 

 

 

Sectorial initiative

 

Electronics and ICT products (including smartphones) We welcome the promise for regulatory measures for smartphones, tablets and laptops under the Ecodesign Directive, as well as the right to software updates. See our report on the climate impact of ‘disposable’ smartphones. We also welcome the call for a common charger policy. However, the need to reduce the overall footprint from digital technology, data centres, and the Internet of Things are not addressed.
Batteries and vehicles A new regulation for batteries including sustainability requirements for design and sourcing, use of recycled content, and measures to improve collection, as well as the phase out of non-rechargeable batteries are welcome. Measures to improve tracking of performance and materials should be set to better inform the supply chain and end users. For vehicles, more emphasis should be put on durability and decontamination. We question the support for alternative fuels. See our views on End-of-life Vehicles and Batteries.
Plastic and packaging A new focus on reduction and reuse, restrictions on over-packaging and access to public drinking water, are all highly welcome. It is regrettable that the action plan on microplastics remains focused on quantifying the pollution. We are also very concerned about the risk of regrettable substitutions from conventional to bio-based, biodegradable and compostable plastics. See the Rethink Plastic Alliance’s reaction to the CEAP.
 Textiles The EU promises a comprehensive textile strategy including eco-design measures. This should make sure  textile products with the lowest environmental impact become the ‘default’. At the same time, labelling schemes, making producers responsible for the textiles they sell and the associated waste, will be vital to fostering business models based around reuse and repair. Visit our campaign website Wardrobe Change.
Construction The action plan rightly targets the construction sector that consumes half of our resources with a significant climate impact. It emphasizes the role of construction products, the LEVELs sustainability framework, recycled content, building durability and an information system (digital logbook). It hesitates on setting carbon reduction targets for the whole life of a building. This should be clearly applied to all new buildings and renovation work. Legal requirements for carbon neutral construction materials and buildings could act as a key driver for investments to decarbonise this energy intensive sector.
Food and nutrients It is encouraging that there will be binding targets on food waste reduction. We also welcome specific measures to reduce impacts associated with food distribution, packaging and consumption. The Integrated Nutrient Management must cover nutrients holistically (agriculture and forestry residues, waste, food loss, sewage and wastewater sludge) to cut pollution, GHG emissions and nutrient losses. We would have liked clearer links between CE and Agricultural policy, notably the reform of the CAP. We are concerned with the lack of clarity on priorities for the use of biomass and find it worrying that there is no reference to the Biodiversity Strategy.
 Waste prevention Waste prevention in food, packaging and other specific streams.

Significantly reduce waste generation” and halve the amount of residual (non-recycled) municipal waste by 2030.

Enhancing the implementation of extended producer responsibility schemes.

Harmonisation of separate waste collection systems.

Priority given to waste prevention over recycling is in line with the waste hierarchy. The objective to halve residual waste is good, but will not directly result in reduction of waste generation. That is why we welcome parallel objectives to set up overall waste reduction targets. We regret however that it’s not made clearer that commercial and industrial waste must also be reduced. Reuse and preparation for reuse targets have also not been mentioned.  We welcome the message to ban the destruction of unsold durable goods. See our 10 policy priorities to reduce waste.
 Taxes

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Economic instruments

Improving non-financial reporting with circularity data.

Reflecting circular economy objectives in the European Semester.

Taxing non-recycled plastic packaging waste.

Encouraging fiscal reform, including VAT reduction for repair.

Support for fiscal reform is welcome but remains non-committal. Economic instruments have potential to address unsustainable virgin resource extraction, address externalities, support secondary markets and deliver a tax shift from labour onto pollution and resource use. The plastics tax remains poorly designed and should instead address virgin plastics. We support the development of the taxonomy in the area of the circular economy, notably if unsustainable activities, such as incineration, will not be supported. The Commission must ensure strict standards for the EU Ecolabel for financial products. The reference to “beyond GDP” and measuring wellbeing is welcome, though falls short on questioning the continued focus of the strategy on growth.
 Global issues

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Trade

Promoting international cooperation on a “Safe Operating Space” and a Global Circular Economy alliance.

Revising the waste shipment regulation and restrict exports of waste

Free trade agreements should reflect circular economy objectives

Action in Europe alone will not address the global resource crisis, so a global outlook is needed. Revision of the waste shipment law and restrictions on waste exports are welcome. Yet, double standards must be addressed in other policy areas such as chemicals and product requirements. Likewise, a due diligence framework covering the full supply chain must be established. In general, a more comprehensive approach to assessing the consequences of Europe’s production and consumption in third countries is needed.
 Toxic-free environment Systematically considering chemicals within product policies

Focusing on the interface issue and address the presence of substances of concern in products

Developing methodologies to minimise the presence of toxic substances in recycled materials

Measures must prevent hazardous substances from ending up in recyclates. This requires a horizontal phase out of hazardous substances from consumer products. Information systems for substances of concern, as well as sorting and decontamination of recycled material are highly welcome. The upcoming concrete actions under the CEAP should now reinforce in a coherent way the chemicals strategy but not exclusively rely upon it to achieve a toxic-free environment. Some core issues of the interface between chemicals, products and waste are delegated to the chemical strategy suggesting this important area remains undeveloped. See our position paper on the interface communication.
 

 

Industrial strategy

 

 

Addressing intermediary products such as steel, cement and chemicals

Boosting uptake of secondary raw materials

Promoting circularity in industrial processes

This clearly reinforces the links between circular economy and climate policy. There is no way we can decarbonize our industry without circular economy. We also appreciate that circular economy efforts should now be taken in the NECP, providing they come on top of already existing national commitments. However, we regret that sustainable sourcing and the carbon neutrality of materials is not more clearly set as a future condition for market access. The directions set in the CEAP could help to rescue the Industrial Strategy that lacks substance and falls short of setting clear carbon reduction targets.

 

For more information:

Mauro Anastasio

mauro.anastasio@eeb.org

0032 2 274 10 87