Circular Economy Action Plan in EU Green Deal

21/12/2023    5

Circular economy action plan (CEAP) is an important part of the European Green Deal, adopted on Mar 2020, aims to build a green, clean, circular economy and make sustainable products the norm at the EU. This new plan replaces CEAP which has been already in place since 2015.

This is one of the measures packages for implementing the European Green Deal, which have the most direct and extensive impacts on production, use, disposal of goods in the EU, including goods imported from the outside to the EU.

For scope, CEAP comprises 35 specific actions relating to implementing measures of circular products in 07 value chains, including: Electronics and ICT, Batteries and vehicles, Packaging, Plastics, Textiles, Construction and building, Food, water and nutrients. These are resource-intensive and high circular potential sectors.

Brief of actions implementing circular economy in 07 product chains listed in CEAP

1. Electronics and ICT

- Management of electronics and ICT under Eco-design Directive so that devices are designed for energy efficiency, durability, reparability, upgradability, maintenance, reuse and recycling;

- Focus on implementing the ‘right to repair’ (including a right to update obsolete software) for electronics and ICT;

- Management of chargers for mobile phones and similar devices;

- Collection and treatment of waste from electrical and electronic equipment toward measures of EU-wide take back scheme;

- Review of EU rules on restrictions of hazardous substances in electrical and electronic equipment

2. Batteries and vehicles

  • Battery: setting up new framework for batteries with following elements:

- Rules on recycled content; measures to improve the collection and recycling rates of all batteries;

- Addressing non-rechargeable batteries with a view to progressively phasing out their use where alternatives exist;

- Information transparency of battery sustainability (the carbon footprint of battery manufacturing, source of raw materials, facilitating reuse, recycling of battery).

  • Vehicles

- Revising the rules on end-of-life vehicles;

- Considering the rules on mandatory recycled content for certain materials of components, and improving recycling efficiency.

3. Packaging

  • Reviewing Directive 94/62/EC towards:

- Reducing packaging and packaging waste;

- Driving design for re-use and recyclability of packaging, restrictions on the use of packaging for products without packaging;

- Reducing the complexity of packaging materials (reducing the number of materials and polymers used in a packaging to facilitate recycling).

  • Some other actions:

- Assessing the feasibility of EU-wide labelling that facilitates the correct separation of packaging waste at source

- Establishing rules for the safe recycling into food contact materials of plastic materials other than PET.


  • Mandatory requirements for recycled content and waste reduction measures for key products such as packaging, construction materials and vehicles;
  • Treatment of intentionally added microplastics in environment:

- Restricting intentionally added microplastics;

- Developing labelling, standardization, certification and regulatory measures on unintentional release of microplastics;

- Developing and harmonizing methods for measuring unintentionally released microplastics, especially from tires and textiles.

  • Developing a policy framework on sustainability:

- Labelling and use of bio-based plastic.

- Use of biodegradable or compostable plastics.

  • Boosting implementation of the new Directive on Single Use Plastic Products, especially: 

- Interpretation of the products covered by the Directive;

- Labelling of products such as tobacco, beverage cups and wet wipes and ensuring the introduction of tethered caps for bottles to prevent littering;

- Developing new rules on measuring recycled content in products.


Objectives of circular and sustainable textile strategy are implemented by following measures:

- Applying the new sustainable product framework to textiles (eco-design, treatment of hazardous chemicals, option rights of consumer actors);

- Providing incentives and support to circular materials and production processes;

- Providing guidance to Member States to achieve the target of collection of textile waste by 2025;

- Boosting the sorting, re-use and recycling of textiles.

6. Construction and buildings

Promoting circularity principles throughout the lifecycle of buildings by:

- Recycled content requirements for certain construction products;

- Promoting measures to improve durability and adaptability of buildings;

- Considering criteria for lifecycle assessment in public procurement and the EU sustainable finance framework;

- Revision of material recovery targets for construction waste.

7. Food, water and nutrients

- Initiative of reuse to substitute single-use packaging, tableware and cutlery by reusable products in food service;

- Integrated nutrient management plan;

- New rules to encourage circular approaches to water reuse in agriculture

Source: Extract of VCCI Research Group from CEAP documents

For implementation, most of the expected abovementioned actions have been implemented through revision of EU’s respective legislative rules in the direction of supplementing relevant standards, technical standards (TBT) for listed products (standards of products’ characteristics, packaging procedures, labelling methods, etc.) or requirements for waste treatment after consumption. 

Below are some measures implemented by EU within CEAP which have substantial impacts on goods imported to the EU:

  • EU Textile Strategy
  • Proposal for empowering the consumer for the green transition

- Progress: the Proposal was presented by European Commission in early 2022, and is currently in the consultation process by European Council and European Parliament for approval.

- Content: The proposal comprises expected revision of existing legislation to help the EU’s consumers to be more informed of the products, from which they can make green, environmentally-friendly choices. Specifically, manufacturers and businessmen shall have to (i) provide more details of products’ durability, repairability and sustainability; (ii) stop planned obsolescence[1] and (iii) ensure only use of certified sustainable labels.

  • Proposal for a new Eco-design for Sustainable Products Regulation

- Progress: The proposal was published in Mar 2022, and is now in the consultation process by European Council and European Parliament for approval. Once approved, it shall have immediate effect, however, specific requirements for eco-design of each product group shall be detailed in delegated acts – it is expected that the EU shall have about 30 new delegated acts for this Regulation which are being drafted from now to 2030.

- Content:

+ Scope: This Proposal aims to replace Eco-design Directive which is currently in place in the EU, and is expected to (i) cover all produced and processed products except for food, pharmaceutical products, animal feeds (instead of energy-related products in the existing Directive); and (ii) implement under EU-wide unified regulations (instead of Member State’s individual regulations in the existing Directive);

+ Regulations: The Proposal is expected to (i) set specific eco-design requirements for each product groups to align with their life cycles through minimum criteria to ensure product’s durability, accountability, reusability, energy efficiency, recycled content; (ii) provide guidance of product’s upgradability, recyclability, recoverability; rules of Digital product passport (accordingly, each product is supposed to have a digital “passport” which enables to check product-related information

  • Extended Producer responsibility (EPR)

- EPR Programme is a policy instrument to implement EU Waste Framework Directive and Packaging and Packaging Waste Directive, in which producers are supposed to be partially or fully financially responsible for waste treatment from product use process by paying respective fees to countries handling this waste treatment. EPR aims to force producers to think and find solutions (during design and manufacturing process) to minimize waste from the use of products.

EPR has been in place in EU, however, it is only restricted to some product groups (i.e.: batteries, transport vehicles, etc.).

- Within the framework of the European Green Deal implementation, EPR Programme could be extended in terms of scope (i.e. applicable to waste from packaging of all products) and progress (until the end of 2024, all EU’s Member States are expected to possess their EPR for packaging waste, applicable to their local or imported products which are consumed at that country market).

Notably, regulations in these Programmes apply mostly to relevant products (regardless of within the EU or imported from outside), and some are applicable for import products (i.e.: EUDR or CBAM). Therefore, CEAP and some materialization documents have been considerably affecting goods imported from outside to the EU, including goods from Vietnam.

Source: Report "EU Green Deal and Vietnam's Exports - The case of the agricultural, food and textile industries" – Center for WTO and International Trade

[1]For instance: for electronics products, manufacturers can design applications, new updates only compatible with new products models, from which encourage consumers to replace the old product model with the new ones.