Value chain and sector-specific actions:

• Electronics and ICT
• Batteries and vehicles
• Packaging - Plastics
• Textiles
• Construction and buildings
• Food, water and nutrients

Promising:

• While a transition toward a more circular economy within the boundaries of the planet requires a horizontal approach, it needs to be combined with ambitious sector-specific initiatives. It is therefore encouraging to see that the Commission is planning to take action on high-impact sectors such as textiles and ICT. Turning attention first to impact hotspots seem a sensible approach when big change is required fast. It is meanwhile encouraging that the Commission is clear that these initiatives will contribute to and feed into other EU policy, including the upcoming biodiversity, Farm to Fork and forest strategies.
• In general, innovative business models based on circularity, servicing, etc. are still very much the exception in Europe and are often struggling to compete with linear solutionsxxiii. We therefore welcome the Commission's commitment to provide incentives and support to, for instance, product-as-service models in the textiles sector and as part of the forthcoming Comprehensive European Strategy on Sustainable and Smart Mobility, with the aim to reduce virgin material consumption.
• It is encouraging to see that the individual sector- and material-specific initiatives put forward under the CEAP will go beyond material substitution and incorporate also measures aiming to, for instance, promote longer lifetimes of electronics (as part of a Circular Electronics Initiative), reducing excessive use of packaging (as part of a reinforcement of existing mandatory essential requirements for packaging), and possibly introducing recycled content requirements for certain construction products (in the context of revising the existing Construction Product Regulation).

Potential issues:

• It will be important to bear in mind and to emphasise in sectoral proposals that business models branded as "circular" cannot be automatically assumed to benefit the environment. For instance, secondary (reused/ remanufactured/ recycled) products are still often sold in addition to primary (new) products, resulting in environmental impacts of both the primary and secondary productionxxiv. There is a need to ensure that circular business strategies result in actual displacement e.g. from new to secondary or from ownership to sharingxxv.
• In the initiatives proposed for Food, water and nutrient value chains, we are missing the focus on the role of demand for ensuring circularity of materials in these sectors and to bring them back within the planet's boundaries. Previous IEEP analysis has highlighted that the current EU food system is oversized with detrimental impacts to biodiversity and ecosystems xxvii, which is both wasteful, and in some cases, dangerous to human health. xxvi. Furthermore, current European consumption of animal protein, for instance, is on average 70% higher than advised in dietary guidelines which is both wasteful, and in some cases, dangerous to human health.