Response to the Commission’s Call for Evidence
Generation Climate Europe (GCE) welcomes the European Commissionʼs initiative on a Circular Economy Act, a very important step forward to enhance the circular economy in the EU. In response to the Call for Evidence of the EU Commission, GCE wants to highlight the necessity of rethinking the current economic system. Such a rethinking is a systemic change necessary to secure intergenerational justice and resource justice, the respect of planetary boundaries and ultimately the resilience and security of the EU, and must be integrated in the Act.
So far, the focus of EU legislation such as the Critical Raw Materials Act has been on continuing to carry out an extractive production model with regards to primary raw materials, which are often cheaper than secondary raw materials. We then welcome the observation of the Call for Evidence that in order for secondary raw materials to compete with primary, incentives have to be put in place. The cost of primary raw materials, which are extracted anew, has to reflect their true environmental and social impact. Both the EU and in third countries are impacted by European extractivism and consumerism, which will affect future generations. Incentivising secondary raw materials will have the effect of sending a positive signal to businesses that are willing to change their productive model, but are struggling to do so in economic terms.
However, incentivising the market for secondary materials will not be enough for meeting the circular material use rate that the EU has committed to in its Circular Economy Action Plan. Additional actions are needed, outlined in the points in our report.
