Responses to consultations Archives

Response to the consultation | Aligning climate and circular economy objectives through an enhanced CBAM

As the European Union seeks to meet both climate and circular economy goals while boosting its competitiveness, the extension of the Carbon Border Adjustment Mechanism (CBAM) presents a unique opportunity to introduce financial incentives that simultaneously address carbon leakage and drive the transition toward a truly circular economy.

While the European Commission is preparing a Circular Economy Act announced for Q4 2026, the ongoing CBAM review offers a strategic pathway to integrate these two policy frameworks through market-based mechanisms that internalise environmental externalities. The current fragmented approach to environmental policymaking has largely overlooked the impact of absolute levels of resource consumption on climate, an omission that is increasingly dangerous as we continue to overshoot planetary boundaries.

Available in English.

Response to the consultation | Single-use plastic beverage bottles – EU rules for calculating, verifying and reporting on recycled plastic content

Zero Waste Europe provided feedback to the European Commission’s consultation on the implementing decision defining the methodology for recycled content as part of the Single-Use Plastic Directive (SUPD). The latter is the first of this type and will create a blueprint for other legislative pieces introducing recycled content targets for plastic, including within the packaging, automobile, and textiles sectors.

For the methodology to be relevant to the transition to a circular economy, it must ensure a high level of transparency and traceability, reward efficient technologies, and safeguard against greenwashing.

Available in English.