• The Commission correctly recognizes the need for consumption and environmental footprint indicators to track progress towards the EU's circular economy objectives and leading global efforts to improve circularity in its supply chains. It is important to distinguish between territorial and embedded emissions from imports; and to target and track both. This is also in line with the much-welcomed initiative in the CEAP to explore the definition of a "Safe Operating Space" for natural resources as part of the EU's global efforts.
• Footprint calculation methods exist for top-down sector-level accounting and bottomup product supply chain tracking. Both must be deployed to capture data required to better understand the material resource requirements to supply European consumption, track progress over time and target responses to preserve the value of resources in the economy.
• At the sector-level, the EU's global footprint can be calculated using existing reporting by Member States (through the European System of National and Regional Accounts), paired with established accounting tools that track material transactions between countries across global supply chains (environmentally extended multi-regional inputoutput models)6 . Eurostat has initiated work on this through its project, Full International and Global Accounts for Research in Input-Output Analysis (FIGARO). In Sweden, SEI has helped develop such a method which has led to the global emissions footprint (consumption-based emissions) included as official statistics, meaning that Statistics Sweden now reporting annually. Using the same method, this would also be possible for Eurostat using existing statistics without any additional policy frameworks7 .
• At the product-level, reporting on supply chains by companies themselves is currently voluntary using Type 1 reporting under International Standards (ISO 14024). The EU could mandate such company-level reporting to provide the required data for both tracking and consumer information through the EU Ecolabel. We would welcome this to be explored in the development of concrete measures to implement the CEAP.

Potential issues:

• We welcome the Commission's commitment to refocus the European Semester process to integrate a stronger sustainability dimension. This could include using indicators to measure green innovation through the number of patents related to recycling and secondary raw materials; Member State progress on circular economy through domestic material consumption per capita and circular material use rates8 . Other examples include index turnover (or GVA) of second-hand versus turnover (or GVA) of new produce, rate of products-as-service contracts in the economy and the number or value of public procurement contracts which fulfil circular economy requirements9 .