In the movie Groundhog Day, Bill Murray’s character is forced to re-live the same day over and over again. Repeated promises by the EU to introduce what it has called “…a clear and ambitious political vision [for the circular economy] combined with effective policy tools…” are beginning to feel like the Commission is stuck in a similar temporal loop. After first announcing, and then withdrawing, proposals in 2014 it opened up a further consultation in 2015 which has just closed. It has promised a new proposal will be announced this year.

With just a few months to go before the year end – which is no time at all for the bureaucrats to assimilate the consultation responses – it would not be surprising if we went around the loop (no pun intended) one more time. In the course of writing this blog I contacted the EU Circular Economy Team and was told that publication of the consultation responses on the Europa website was being held up due to ‘technical difficulties’.

So whilst we eagerly await an official update from the EU, it is encouraging to note that a number of the consultees have chosen to make their responses public on their own websites which provides some indication of the appetite for stronger circular economy legislation.  It is difficult, of course, to predict how influential these self-selected responses will be, however they do give a useful insight into the direction of travel for those businesses keen to future proof their operations.  I have looked over several submissions to get a few different perspectives. There are many similarities (at least amongst those who have published their responses) and several themes stand out.

- Organisations as diverse as WRAP, CIWM and the NFU mention the gap in the current EU policy framework around food waste and argue that new legislation should be included in the revised CE package.

• CIWM argues the case for better metrics although no mention is made of the EU’s recently released Circularity Metric (CM) which may address some of their concerns around measurement and reporting.  Certainly, promotion of the new CM has not been as vigorous as it should have been.  And whilst on the subject of metrics, the European Green Group references the need for sustainable material flows and suggests that any targets must recognise ‘one planet’ limits (as promoted by organisations such as WWF).

• There are a number of calls to better enshrine the ‘polluter pays’ principles in any new legislation. The Local Government Association see this as avoiding the financial burden of implementing a circular economy falling directly on tax payers and they suggest that producers should cover half the cost of implementation.

• The Resource Association makes perhaps one of the most progressive suggestions – to entirely ban recyclables from landfill and incineration. They also mention the need to better enforce Waste Shipment Regulations in order to promote more effective recovery, reuse and recycling. The need to better address hazardous substances is also mentioned by a number of respondees including, not surprisingly, those in the chemicals sector.

So where does this leave us?

Stricter regulations around food waste, more comprehensive data collection methods and further recognition of producer responsibility all seem to be on the cards. And despite the delays to date, there is a sense that the end of Groundhog Day is just around the corner.   Please keep an eye on the Anthesis website for further updates as they occur.

Craig Simmons is Chief Technical Officer at Anthesis and is based in our Oxford office.  Craig can be contacted at: craig.simmons@anthesisgroup.com.

Update 8^th October 2015 - Sign up for our Circularity Package Briefing

EC’s Director of Green Economy, Kęsţutis Sadauskas made an informal announcement today that the EU's Circularity Package will be published on 2nd December this year! Speaking at the Scottish Resources Conference this morning, he confirmed that, as predicted, legislation on food waste would be included in the package but was silent on what else would be covered.

Anthesis will be monitoring the situation closely and be on-hand and ready to prepare a briefing for our clients if the Package does indeed materialise on 2^nd December.

If you would like to receive this briefing, please email elanor.swan@anthesisgroup.com with the subject 'EU Circularity Package'.