New report calls for a replacement of European Waste Framework Directive for a materials-based one, to urgently alleviate the triple planetary crisis


27 Mar 2024


Eunomia’s latest report recommends replacement of Waste Framework Directive with a Materials Framework Directive, and establishment of EU level powers on environmental taxation.

27 March 2024, London – 17h00 / Brussels – 18h00

Eunomia Research and Consulting Ltd. has today published a report ‘Managing materials for 1.5oC: an EU regulatory framework for a low carbon material economy’. It presents a series of recommendations designed to enable Europe to prosper whilst reducing the pressure we place on the planet from our consumption of materials.

The report was funded by a consortium comprised of Handelens Miljøford, Minderoo Foundation, TOMRA, and Zero Waste Europe, all of whom have an active interest in questions relating to the way we can better manage materials to tackle environmental challenges.[1]

While decarbonisation of energy supply is crucial in tackling the climate crisis, the public and political discourse has to date largely ignored our consumption of materials. This must change. Extraction and processing of material resources account for over 55% of greenhouse gas emissions – more than 60 per cent if land use impacts are considered.[2]

More broadly the extraction, manufacture, transport, use, and disposal of materials is responsible for 90% of land-based biodiversity loss and water stress.[3] The extent and nature of our consumption of materials is at the heart of the triple planetary crisis – the crisis of climate change, the crisis of nature and biodiversity loss, and the crisis of pollution and waste.[4]

The proposed regulatory framework is based on a number of underpinning principles, full details are contained within the report:

  1. Leveraging the power of the Single Market.
  2. Minimising administrative burden for business through harmonisation.
  3. Engaging the digital transition.
  4. Levelling the playing field.
  5. Maximising use of economic instruments.
  6. Securing popular support for the broad framework of measures.
  7. Expanding the EU’s influence on global policy for managing materials and reducing greenhouse gas emissions.

The proposed regulatory framework builds on what is already in place or underway, makes connections between policy mechanisms where relevant, and presents a number of more innovative, novel approaches in various areas. A key theme is providing greater clarity and simplification for business through harmonisation across the EU, accompanied by a transfer of decision-making competences in certain areas away from individual Member States to the EU level.

The proposed regulatory framework encompasses:

  • Decarbonising materials production.
  • Product policy for a low carbon economy.
  • Maintaining material value at end of life.
  • Reducing overall material consumption.

The most politically challenging – but arguably also the most important – of the proposed measures is the greater application of environmental taxation at the EU level. To overcome these challenges this important shift will have to be undertaken creatively in ways that will need to directly benefit – and be seen to benefit – the majority of citizens. That is to say that the shift overall must have broad popular appeal.

Dr Chris Sherrington, Eunomia, Head of Environmental Policy & Economics said: ‘We recognise the political challenge of introducing the proposed measures – particularly the greater application of environmental taxation at the EU level. Accordingly, we argue that addressing the current levels of societal inequality is both an important end in itself, but also something that might reasonably be expected to ease the political challenge of introducing the policy measures needed to move towards a low carbon material economy.’

He goes on to add: ‘While not a panacea we suggest consideration be given to the direct redistribution to EU citizens of revenues from environmental taxation and other market-based instruments such as the EU-ETS and CBAM.’

Axel Darut, Minderoo Foundation, Public Affairs Associate said: ‘This report offers a systemic approach, with comprehensive toolkits and a range of measures – from ecodesign to end-of-life – to accelerate a sustainable and just transition to a circular economy. We hope it inspires policymakers and global leaders to shape circular economy policies that align with the Paris Agreement.’

Bilyana Ignatova, TOMRA, Vice President Public Affairs, Head of EU Policy said: ‘To transition to a world where waste is seen as a valuable resource, a revolution is necessary—a resource revolution. It’s time for the EU, a global leader in environmental policy, to align its framework legislation with this vision.’

Cecilie Lind, Handelens Miljøfond CEO, said: “Supporting the ‘Managing Materials for 1.5 degrees’ report aligns with Handelens Miljøfond’s mission to spearhead a shift towards a circular plastic economy. We’re investing in research that goes beyond highlighting problems, focusing instead on uncovering solutions that promote the reduction of plastic, reuse and recycling. This initiative reflects our belief in taking informed, practical steps to transform how plastic is managed, paving the way for sustainable industry practices.”

Aline Maigret, Zero Waste Europe, Head of Policy said: “Amidst the urgency to stay within a 1.5 degrees carbon budget, this new report underscores a pivotal shift in perspective: from a waste-focused policymaking we need to put strategic resource use at the heart of EU’s priorities. It suggests reimagining materials, offering pragmatic solutions that engage progressive businesses, and adapt to changing politics”.



[1] While these organisations have funded the work, it is an independent study with Eunomia having full editorial control. The views and recommendations presented in the report are thus Eunomia’s and do not necessarily reflect the views of the funders.

[2] United Nations Environment Programme (2024) Global Resources Outlook 2024: Bend the Trend – Pathways to a liveable planet as resource use spikes. International Resource Panel. Nairobi. Available at

[3] United Nations Environment Programme (2024) Global Resources Outlook 2024: Bend the Trend – Pathways to a liveable planet as resource use spikes. International Resource Panel. Nairobi. Available at

[4] UNEP (2020) The triple planetary crisis: Forging a new relationship between people and the earth. Statement prepared for delivery to the Sub-Committee, Committee of Permanent Representatives by H E Fernando Coimbra, Chair of the Committee of Permanent Representatives. Available at


For further information please contact [email protected] // (+44) (0)7912 672863

Eunomia Research and Consulting Ltd

Eunomia is an independent sustainability consultancy driven by a genuine passion to make a positive change to the clients we work with and the communities they operate in. We are driven by the power of Unwasted. At Eunomia, we’re social-environmental problem-solvers and researchers with a difference. Combining real world consulting experience and deep knowledge with an active role in policy, empowers us to provide pragmatic, science-led solutions that reduce human impact on the planet.  We are committed to finding solutions to better protect the planet, while supporting the wider aims and needs of our clients. For more information about Eunomia, please visit

Minderoo Foundation 

Established by Dr Andrew Forrest AO and Nicola Forrest AO in 2001, Minderoo Foundation is a proudly Australian philanthropy that fights for a fairer future. It takes on tough, persistent issues with the potential to drive massive change. One of its key programs is to stop plastic pollution by adopting a comprehensive life-cycle approach to plastic management.


TOMRA is a global impact leader in the resource revolution, creating and providing sensor-based solutions for optimal resource productivity. TOMRA was founded in 1972 on an innovation that began with the design, manufacture, and sale of reverse vending machines (RVMs) for the automated collection of used beverage containers. Today, TOMRA provides technology-led solutions that enable the growth of the circular economy with advanced collection and sorting systems that optimize resource recovery and minimize waste in the food, recycling, and mining industries.

Handelens Miljøfond (Norwegian Retailers’ Environment Fund)

Handelens Miljøfond is Norway’s largest private environmental fund, and Norway’s most important measure for complying with the EU Plastic Bags Directive. The fund supports national and international projects that reduce plastic pollution, increase plastic recycling, and reduce the consumption of plastic bags.

Zero Waste Europe

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards a better use of resources and elimination of waste in our society. We advocate for sustainable systems; for the redesign of our relationship with resources; and for a global shift towards environmental justice, accelerating a just transition towards zero waste for the benefit of people and the planet.