DUT's perspective on the Circular Economy Act

The DUT Project and Partner representatives have provided input to the European Commission consultation process, open until the 6 November 2025. A written common position, collected through an internal workshop held on 22 October, was summarised, analysed and translated into 4 main messages: 

Cities must be recognised as key enablers and laboratories for the circular economy. They are where most consumption and waste generation occur, but also where crucial resource flows, skills, and innovation capacities converge. 

The Circular Economy Act should explicitly empower cities to act as resource managers, bridging urban-rural loops and localising circular practices where feasible. 

To enable this, cities need clearer mandates, regulatory flexibility in waste classification, and dedicated EU funding to scale successful pilots. Urban–business collaboration and inter-municipal coordination should be encouraged to drive systemic change.

The Act’s focus on recycling and secondary raw materials is too narrow. It must embed a hierarchy of circular actions - the 7 R’s - prioritising waste prevention, reuse, sharing, repairability, and design for longevity. 

In the built environment, the most circular building is the one not newly constructed. Rather, re-use existing structures, design for multipurpose use, and plan at neighbourhood level, integrating blue-green infrastructure, nature-based solutions and other natural systems which are circular by nature. Circular construction must evolve from material management to systemic urban design.

Circularity will not advance if linear options remain cheaper. The Act should promote internalisation of environmental costs by taxing non-durable, non-repairable products and exploring coordinated fiscal incentives. Tax systems should be aligned across jurisdictions to support circular value chains, for example, matching incentives for regions producing secondary materials with those using them, creating integrated fiscal frameworks that reinforce circularity. 

Secondary materials are not too expensive; primary materials are too cheap because their externalities are excluded. 

EU action should level economic conditions through coherent taxation and market incentives that favour circular business models and stimulate demand through requirements that make purchasing and public procurement more circular.

To be effective, the Act needs to be informed by a systemic understanding of circularity, where resource flows are embedded in a societal context. Circularity must be people-centred and a just transition requires investment in skills and capacity building. The Act should therefore be clearly aligned with the Clean Industrial Deal’s ambitions to create high-quality jobs. 

However, an efficient circular economy also requires the recognition of the value of local and community-based repair and recycling actors, such as grassroots waste collectors or food-saving initiatives. They contribute significantly and deserve recognition and integration into local strategies. Education at all levels and incentive systems are essential to address behavioural biases and build public support for circular lifestyles.

This perspective was written in collaboration between DUT Partner organisations Formas and RISE, DUT Project representatives, and Bax Innovation. All projects within DUT’s Circular Urban Economy Transition Pathway were invited to contribute, of which nine did.  Innovation. 

Authors Björn Wallsten, Formas ⎸ Camilla Sandberg, Bax Innovation ⎸ Josefina Sallén, RISE ⎸ Karolina Vikingsson, RISE ⎸ Zoë de Jonge, Bax

Contributors Alan Tkaczyk, University of Tartu Institute of Technology, CABE project ⎸ Chiara Pellegrini Eurac Research, ECLECTIC project ⎸ Cihan Kayaçetin, Bilkent University, Urban-CoLLaR project ⎸ Cristina Viano, Università degli Studi di Torino, CORPUS project ⎸ María José Zapata Campos, University of Gothenburg, Circular Grassroots project ⎸ Michael Martin, IVL Swedish Environmental Research Institute and KTH Royal Institute of Technology, FOCUSE project ⎸ Michael Søgaard Jørgensen, Aalborg University, TransScale project ⎸ Robert Boyer, RISE, CDCUL project ⎸ Vivek Voora, IVL Swedish Environmental Research Institute, NATURGO & FOCUSE projects.