Circular Economy Action Plan 2.0

VCI position on the EU's Circular Economy Action Plan



Zirkuläre Wirtschaft

VCI position on the EU's Circular Economy Action Plan


27 July 2020 | Position


The VCI has drawn up a position paper on the “Action Plan for the Circular Economy - for a Clean and Competitive Europe”. The position paper evaluates the seven fields of action of the action plan in detail. Because the industry is affected by a large part of the ambitious EU plan.

 The VCI has developed a position on the EU's Circular Economy Action Plan. - Image: © ferkelragga/
The VCI has developed a position on the EU's Circular Economy Action Plan. - Image: © ferkelragga/

On 11 March 2020, the European Commission presented a new circular economy action plan within the European Green Deal. This is the continuation of the first action plan of 2015, the measures of which have been implemented according to the Commission.

The objectives of the new action plan focus on a cross-sectoral decoupling of economic growth from resource use while ensuring long-term competitiveness. In order to enable the implementation of the “regenerative growth model”, which is pursued specifically for the said purpose, the Commission sets out a number of key tools with which the given aims are to be achieved. A central tool is to be a new framework for sustainable products where emphasis is given on reducing material consumption in design and a consistent circular management of products. Such potential savings in primary raw materials are intended to stimulate economic growth and to protect against fluctuating raw material prices, so that climate neutrality to 2050 can be reached, as aspired in the European Green Deal and laid down in the proposal for a regulation on the European Climate Law. Sustainability should become the norm for products, services and in finance. Waste prevention, recovery and producer responsibility are further central aspects of the action plan. Overall, the share of materials with a circular-oriented use is to double in the next 10 years. Where the circular economy is concerned, the Commission sees Europe in a global leadership role in the long term.

The action plan comprises seven fields of action from which a total of 35 measures – such as initiatives, legislative measures, reviews and tightening of existing legislation, proposals for legal frameworks, targets, regulatory measures and much more – are derived. These measures are to be implemented within the next three years. Large parts of them directly impact the chemical industry.

In addition to general comments, the full position of the German chemical industry on the “New Action Plan for the Circular Economy - For a Cleaner and More Competitive Europe”PDF | 239 kB | Version as of: 12 August 2020 the seven fields of action under the new action plan are addressed below, following the structure of the Commission Communication.

Core messages from the German chemical industry:

  • Sustainability should be examined across the entire life cycle: This means that a holistic approach must be taken. Recyclability of materials cannot be an end in itself. Therefore, one should speak of “Design for Sustainability” instead of “Design for Recycling”.
  • Waste, especially plastic waste, is a valuable resource. Beside mechanical recycling methods, there should be an open mind for chemical recycling options – in particular for kinds of waste that cannot be recycled as yet.
  • Strengthening the EU internal market for secondary raw materials through market-based rather than regulatory incentives. Prescribing blanket input quotas for recyclates for all plastics is not effective. Furthermore, there should be EU-wide minimum standards for secondary raw materials.
  • It is essential to avoid double regulation and inconsistencies with existing legislation, and existing legislation must be applied consistently throughout Europe.
  • A diversified raw material base consisting of all available resources must be maintained now and in the future to safeguard raw material supplies and competitiveness.


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