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Position Paper — Circular Economy Act

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The circular economy (CE) offers significant social, economic, and environmental benefits, which are widely recognised in the EU. However, implementation remains slow. While policies are robust, scaling remains sluggish, and progress is lagging the EU’s ambition of doubling circularity up to 24% by 2030. This slow uptake reflects the reality that transitioning to a circular economy requires further support for changes in production, governance, regulation, and consumption patterns.

Greenovate! Europe (G!E) welcomes the vision and work of the European Commission for the Circular Economy Act (CEA), and is ready to make recommendations, drawing on evidence from its diverse participation in Horizon Europe projects and the expertise of G!E Members across Europe.

This paper sets out three interlocking priorities for the forthcoming CEA: valorising the circular bioeconomy, using public procurement as a strategic lever, and de-risking sustainable circular business models.

In particular, G!E highlights the following overarching recommendations:

  • Recognise secondary bio-based materials, such as recovered nutrients, biowaste and organic residues, and industrial biogenic side streams from forestry and agricultural as strategic circular resources rather than waste
  • Remove regulatory barriers that block circular bioeconomy innovation, including biowaste’s legal “waste” status, restrictive Animal By-Product rules, and EU Taxonomy criteria that currently unlock finance only for composting and anaerobic digestion.
  • Make circular public procurement a genuine lever, not only a legal option, through common EU circular procurement criteria, higher SMEs access, and digital reporting standards, so the EU’s estimated €2 trillion in annual public spending can systematically favour circular solutions.
  • De-risk sustainable circular business models by mandating targeted financial instruments, such as state-backed guarantees, transition vouchers and blended finance, for commercial scale-up, and by establishing regulatory sandboxes with common EU-wide validation criteria.

Download the position paper here.

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