The new Circular Economy Action Plan (CEAP), presented by the Commission on 11th March 2020, is a promising continuation of existing efforts, initiated since 2015, to increase material circularity in the European economy. Although the focus on products and production remains, the Commission takes important and significant steps in terms of recognising key issues and remaining gaps. Notably, the Commission is right to acknowledge the need to keep the EU's resource consumption within planetary boundaries, transform consumption patterns and reduce consumption footprints.

Of course, the hard work lies ahead.The authors therefore call on the European Commission, the European Parliament and the Council of the EU to ensure a high level of ambition in the development of the initiatives put forward as part of implementing the new CEAP. In particular, there is a need to adopt concrete measures that address both supply and demand in order to deliver a more circular economy within the boundaries of the planet. More specifically, in relation to demand-side measures, the authors call on EU policymakers to:

1. Develop clear EU-level targets to reduce the Union's ecological footprint with respect to use of material in absolute terms.

The Commission has missed the opportunity to do so in the CEAP, and we therefore urge policy makers to explore such targets in the development of the sustainable product policy legislative initiative

2. Avoid a sole focus on citizens' role in changing consumption behaviour…

…based on information tools and labels, as this approach has had limited impact so far and there is little evidence to suggest that increased awareness will deliver the change required in the short time available. We urge EU policy makers to focus more on the responsibility of private and public sector to address unsustainable consumption, e.g. to help ensure - in a balanced and transparent manner - that the healthier, more sustainable and safer choice is the easier choice for citizens.

3. Provide incentives and support - and address remaining barriers - to genuinely circular and "disruptive" business models

A good start would be the key sectors identified in the CEAP, using the initiatives suggested for these sectors. There are promising examples of such strategies already on the EU market, such as productsas-service systems, but none of these are yet mainstream. Most businesses' growth is still based on more people buying more stuff - a model that is no longer compatible with a safe and sustainable future. Importantly, it is not always clear to what extent business models branded as "circular" actually replace use of virgin resources.

4. Complement the focus on job impacts of circular economy transition with a recognition of and measures to ensure a fairer balance of access to resources in Europe…

…pursuing a more circular economy that truly works for people, regions and cities. Parts of Europe have some of the highest ecological footprints in the world, whereas other parts have not yet reached a standard of living that is considered acceptable. The ongoing revisions of the reporting under the EU semester process (e.g. just transition plans) could be one avenue to take this forward.

5. Make better use of the potential of environmental tax reform…

…using EU levers such as fiscal and economic coordination instruments, to create the conditions for Member States to gradually shift tax burden from labour to the use of non-renewable energy and virgin raw materials. As long as primary raw materials are cheaper than reused goods or secondary raw materials, policy interventions to deliver a more circular economy will have little impact.

EU-level action is important, but far from enough

Lastly, we want to reiterate that EU-level action is important, but far from enough. Many relevant policy tools are not within EU competence and the authors urge national, regional and local authorities to develop innovative responses to the issues addressed in the CEAP and to show leadership in implementing its initiatives. We also call on market front-runners to show willingness to innovate and see the opportunities in being early movers in this irreversible and long overdue transition.