Feedback: European Commission Circular Economy Act
The Finnish Association of Architects SAFA suggests the following changes to the Circular Economy Act:
Durability and lifecycle design should be promoted. A narrow focus on recycling combined with the free movement of waste materials across borders could lead to waste being shipped to the member state with the least strict regulation on waste handling. Instead, focus on the higher tiers of circularity by introducing EU-wide standards and regulations focused on durability, repairability, deconstructability, and adaptability to ensure long-lifespan products and construction works. This includes incentivizing ”design for multi-cycle use” to ensure efficient reusability and closed-loop recyclability. Standards ISO 20887:2023′ Sustainability in buildings and civil engineering works; Design for dismantling and adaptability; Principles, requirements and guidelines’ and ISO 59020:2024 ‘Circular economy — Measuring and assessing circularity performance’ provide good starting points. ISO 20887 is also referred to in the EU taxonomy 7.1 and 7.2, the uniform application of which would greatly benefit from EU-wide standards and metrics.
The use of secondary construction materials should be incentivized and standardized. Strong support for the development of technical standards for secondary construction materials and products should be provided (e.g., for testing, quality control, and functional equivalence). This ties in closely with the update of the Construction Product Regulation, although the transition period stretches until 2039. How to facilitate harmonized practices in the meantime, is an important consideration. It should also be noted, that this needs to be coordinated with the digital product passports to ensure that data is available over multiple use-cycles.
Circular business models and infrastructure for construction should be supported. The incentives for circular business models, such as leasing, remanufacturing, and product-as-a-service in the construction sector should be incentivised. This may include financial instruments, tax reductions for circular practices, and the development of supportive infrastructure for material reuse and recycling. Currently, linear practices are incentivized, which creates challenges for scaling circular initiatives.
Accountability for environmental costs should be enhanced. It should be mandated that virgin materials and high-carbon processes reflect their true environmental cost (e.g., through carbon pricing or resource taxation) to level the playing field for circular and renewable materials in construction. This will prevent circular construction practices from being undercut by cheaper linear options.
EU-wide coordination to avoid fragmentation should be facilitated. Fragmented regional rules should be avoided by creating unified, standardized indicators and criteria for circularity across the EU. Cross-border regulations for material recovery should be simplified and high recycling standards should be ensured to prevent exports to countries with low waste management standards.