Welcome to the June edition of the Circular Digest.
We've surpassed 200 subscribers! I'm delighted that so many of you are using Circular Digest as the go-to monthly briefing to redesign systems, reduce risk and drive real impact.
This month I'm also excited to bring you our first ever guest deep dive written by Dr. Tom VΓΆge on how EPR can be harmonised across waste streams. Read on below. β¬οΈ
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Innovation: Novelis has successfully, for the first time, powered its aluminium recycling plant with hydrogen. Substituting natural gas with hydrogen could reduce carbon emissions by up to 90%. A gamechanger in decarbonising aluminium recycling!
Policy: From 1st June 2025, single-use vapes have been banned in the UK. With multiplying environmental, social and health benefits, this policy will reduce resource use and GHG emissions, increase circularity and improve the health of the population.
Policy: At the 3rd UN Oceans Conference in Nice, almost 100 countries from all regions reaffirmed their commitment to an ambitious Global Plastics Treaty. This included commitments to reduce overproduction and consumption, address problematic products and chemicals of concern, champion ecodesign, finance measures to address plastic pollution in the Global South AND voting by majority when consensus isn't possible. Could this be the move that agrees a Treaty in August?!
Strategy: Chanel has launched Nevold ("never old"), a new circularity platform focused on integrating recycled fibres into its luxury designs. Chanel is pivoting strategically by openly acknowledging it canβt reach its circular goals alone. Nevold invites partnerships across the entire textiles value chain to position Chanel not just as a designer, but as a convener. This is a rare example of a luxury brand making circularity a systemic strategy, not a siloed initiative. One to watch.
Finance: NBIM, Norway's sovereign wealth fund, which manages β¬1.5 trillion in assets, isn't shying away from requiring ambitious ESG requirements from their holdings. While the Omnibus regulation is reducing the scope and ambition of the European Sustainability Reporting Standards (ESRS), we're seeing financial institutions step up.
Policy: Oman has commissioned the MENA region's first Circularity Gap Report. This first-of-its-kind initiative aims to advance sustainable resource use and build a roadmap for a circular economy in line with Oman Vision 2040.
Community: The Circular Economy Network is a platform to connect, inspire and promote the circular economy across Australia and Aotearoa New Zealand. Each week they feature circular champions - businesses, organisations, startups, groups and individuals who are actively engaging in circular economy principles and disrupting the linear economy and practitioners- professionals working in the circular economy space. Check them out to connect and collaborate.
Action This
To increase circularity, prioritize materials by conducting a double materiality assessment. This will enable you to identify and rank materials for circularity initiatives by rigorously evaluating both their environmental impact (e.g., impacts on nature, waste generation, GHG emissions) and financial implications. Consider key criteria such as tonnages used, evolving regulatory requirements, stakeholder demands, and supply chain resilience to build a robust, data-driven strategy for enhanced environmental performance and business value.
Harmonising EPR Policies Across Waste Streams: Towards a Coherent EU Circular Economy Framework
Written Dr. Tom Voege, Director Public Policy at GRS Service
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As the European Union (EU) deepens its commitment to a circular economy, Extended Producer Responsibility (EPR) is emerging as a cornerstone of waste management policy. EPR makes producers financially and operationally responsible for the end-of-life management of their products, incentivising eco-design, material efficiency, and increased recycling. However, the current patchwork of EPR schemes across waste streams (e.g. batteries, electronics, packaging, textiles, etc.) presents challenges to coherence, transparency, and efficiency. Harmonising EPR policies across waste streams is not only desirable, but also increasingly necessary.
The Case for Harmonisation
The rationale for EPR is well established. By shifting the burden of waste management from public authorities to producers, EPR can reduce environmental impacts, promote innovation in product design, and create level playing fields. Yet the way EPR is implemented varies significantly between sectors and Member States.
Some streams, like packaging, have well-established EPR systems governed by detailed EU directives. Others, such as textiles, are only now being integrated under mandatory EPR, with national systems still emerging. Batteries and Waste Electrical and Electronic Equipment (WEEE) follow their own sector-specific legislation, with separate requirements for collection, reporting, and eco-modulation.
This fragmentation leads to several issues:
Administrative complexity for producers, especially those operating in multiple markets or selling products that span several categories (e.g., smart textiles or e-bikes).
Inefficiencies in waste collection and treatment, with parallel systems for similar materials (e.g., plastics in packaging vs. plastics in electronics).
Inconsistent incentives for eco-design, due to divergent fee structures, reporting formats, and modulated fee schemes.
Missed opportunities for cross-sector innovation in reuse and recycling infrastructure.
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Towards a Common Framework
To address these challenges, the European Commission is exploring options to harmonise EPR schemes across waste streams. The Circular Economy Action Plan and upcoming Circular Economy Act highlight EPR as a key policy tool. The Digital Product Passport (DPP) will also play a central role, creating the infrastructure for coherent tracking and information sharing across value chains.
But what would harmonisation look like in practice?
Core principles and definitions: The EU could define a common set of EPR principles applicable across all streams. This would include harmonised definitions of producer responsibility, recyclability, reusability, and circularity metrics.
Standardised fee modulation criteria: Fee modulation, i.e. linking EPR contributions to the environmental performance of products, is a powerful incentive. A cross-stream framework for eco-modulation could ensure consistency and drive systemic design improvements across sectors.
Common reporting and data requirements: Producers currently face a labyrinth of reporting obligations. Unified digital reporting formats, ideally integrated into DPP systems, could streamline compliance, and improve data quality for policy evaluation.
Interoperable collection and treatment systems: Some materials, including plastics, textiles, metals, cut across product categories. Harmonising collection requirements and infrastructure investments can boost efficiency and enable more circular flows of materials.
Cross-sector governance and enforcement: EPR performance varies widely across Member States, partly due to differing national implementation and enforcement. EU-wide minimum requirements and a framework for compliance checks could close the gap.
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Challenges and Considerations
While harmonisation offers many benefits, it is not without challenges. Existing schemes have developed over years in response to sector-specific needs and political compromises. A β1-size-fits-allβ approach may risk diluting the effectiveness of tailored systems. There must also be room for innovation and flexibility at national level. Moreover, harmonisation efforts must consider the broader waste hierarchy. EPR is often criticised for focusing too much on recycling rather than waste prevention and reuse. A harmonised EPR framework must include strong incentives for upstream innovation, not only managing waste better, but creating less of it in the first place.
The Road Ahead
The European Commission is expected to issue further guidance on EPR harmonisation as part of its implementation of the Circular Economy Action Plan. Meanwhile, industry, Member States, and Producer Responsibility Organisations (PROs) are already working across borders and sectors to pilot joint solutions. For example, multi-stream PROs are increasingly active in aligning operational models, integrating digital reporting systems, and supporting the development of take-back schemes that cater to multiple product types. The emergence of digital tools, such as product passports, traceability platforms, and AI-driven material recovery, can further accelerate convergence.
Image credits: Marks & Spencer
Conclusion
Harmonising EPR policies across waste streams is a complex but necessary step toward a truly circular European economy. As product systems become more integrated and value chains more global, fragmented national or sectoral approaches are no longer fit for purpose. A coherent, harmonised EPR framework can reduce administrative burdens, drive innovation, and ensure that Europe makes the most of its material resources, while holding producers accountable for their environmental footprint. The transition will require bold policymaking, careful coordination, and open dialogue among all stakeholders.
But the prize is worth it: a system where products are designed with circularity in mind, resources are used efficiently, and waste is truly treated as a design flaw, not an inevitability.
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Dr. Tom VΓΆge is a leading expert in the areas of Circular Economy, Sustainability, and EPR Policy, and a sought after public speaker and author. He currently serves as Director Public Policy and EU Representative in Brussels for GRS Service. With 20+ years experience, he held senior roles at the United Nations, at the OECD, and at the International Chamber of Commerce, as well as in consulting and academia. He is a member of the World Economic Forum Expert Network. He holds a PhD and an MSc in Engineering and Environment from the University of Southampton.
EPR Schemes: Current State and Recommendations for Improvement - Read this report by the Economic Incentives Leadership Group to learn more about how EPR schemes can improve. These suggestions would not only improve these schemes but also lay the groundwork for further expansion.
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