The New EU Circular Economy Action Plan by Schuttelaar & Partners

By Schuttelaar & Partners

On 11th of March 2020, the European Commission released its new Circular Economy Action Plan (CEAP) in support of the European Green Deal. CEAP sets out ambitious goals for the European economy and invites businesses to work together with EU policy makers to create a framework for sustainable products. Based on the former Action Plan for a Circular Economy put forward by the Juncker Commission, and the report on its implementation, this new document sets out a strategy for the EU to transition to a Circular Economy.

Highlighting the need for better management of natural resources and to reduce waste and so to tackle the globally rising environmental impacts of human activities, this plan puts forward circularity as a reshaping of Europe’s consumption patterns rather than simply a “tool” to incentivise change – as this was the case in the 2015 Action Plan.





Building on the work already undertaken in the transition towards a more circular European economy, the CEAP sets out objectives in product design, production and consumption. It also highlights the sectors which are critical for this transition as Key Product Value Chains: electronics, batteries, plastics, textiles, packaging, food and construction. In contrast to the former Action Plan, which was largely based on sector-specific incentives with very little regulation, the CEAP is regulatory-based with a number of major new regulations in the pipeline along with amendments of existing directives to include stricter targets and actions.  

The Construction sector is addressed in the CEAP mainly with a planned revision of the Construction Product Regulation, setting minimum targets for recycled content requirements for certain products. Furthermore, a revision of material recovery targets set in EU legislation for construction and demolition waste and its material-specific fractions is also planned. Other incentive-based measures will aim at reducing soil sealing and integrating life cycle assessments in public procurement.

Some cross-cutting measures that concern all sectors will also be implemented. The aim of these measures is to integrate sustainability and circularity throughout the whole European economy. In addition to incentives for business-led initiatives to develop environmental accounting and integrate sustainability into business strategies, regulatory measures such as the review of the non-financial disclosure directive are also planned along with additional measures aimed at tightening the requirements for public funding, adding circularity and sustainability criteria for the obtaining of funds.

To learn more about upcoming European regulation and our EU policy monitoring service, please contact:

Bea Rofagha, Senior Advisor at

Schuttelaar & Partners


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