European Environment Initiative (EURENI)

Project background

Supply disruptions and geopolitical tensions have increased concerns about secure access to critical raw materials. As a result, Circular Economy (CE) has gained increased political and economic attention. It is widely seen as a key concept to address resource insecurity, biodiversity loss, climate change, and overuse of natural resources.

The EU and Germany have adopted or revised several policies — such as the German Circular Economy Strategy, the EU Critical Raw Materials Act, and the EU Ecodesign for Sustainable Products Regulation. A comprehensive Circular Economy Act is also being planned at EU level. It aims to increase demand for secondary raw materials and strengthen the internal market for waste. At the same time, more businesses are switching to circular models.

For CE to deliver on its promise, it must lead to an absolute reduction in resource consumption. However, implementation remains complex. Practical barriers persist, and some measures may cause unintended consequences — such as negative environmental displacement effects. These risks need to be better understood and addressed.

The ICT and Electronics/Electrical (EE) sectors are central to this challenge. They often rely on scarce materials and feature complex designs that hinder recycling or reuse. Strong dependencies between hardware and software can obstruct repair. In many cases, companies do not disclose information about materials or repair procedures, making it difficult to establish effective circular systems.

Electronic waste is among the fastest-growing waste streams in the EU. A significant share of used products is exported — sometimes under unclear conditions — to third countries, where reuse or recycling may be incomplete. These exports can undermine local reuse practices and increase demand for primary raw materials in importing countries, counteracting CE’s intended benefits. 
Awareness of these dynamics and of the need to reduce resource demand in digital and electronic products needs to be raised. To prevent negative displacement effects — such as increased demand for primary resources abroad due to increased demand for secondary resources in the EU — we need better knowledge and practical strategies to mitigate such impacts. 
 

Project goals and measures

Focusing on the ICT and EE sector, this project aims to support stakeholders in Germany and at the EU level in addressing key barriers to implementation and in mitigating negative sides of the CE. 

Digital Product Passports are one promising approach. They can help close information gaps along value chains, but their effectiveness depends on thoughtful design. For example, decisions around data access and usability are essential. In dialogue with small and medium enterprises, researchers, and civil society, the project will develop recommendations for effective Digital Product Passports and identify the support structures needed to implement them successfully. 

Intellectual Property Rights represent another significant obstacle. They often prevent companies from repairing, refurbishing, or remanufacturing products, limiting the scalability of circular business models. Despite some legal exceptions, major challenges persist. In dialogue with affected companies, research and civil society, the project will identify the main Intellectual Property Rights’ barriers and develop practical solutions.

CE policies can also produce unintended negative side effects. The project will explore ways to avoid these. One option under consideration is a globally extended producer responsibility system, which could hold companies accountable for the full lifecycle of their products across international markets.

The project will gather insights through research, stakeholder dialogues, interviews, and workshops. Based on these findings, recommendations will be developed. These will be shared with stakeholders at the national and European levels to help inform and drive the further development of circular economy strategies.

Special attention is given to small, medium and micro businesses. These businesses play an essential role in local repair, reuse, and sharing services but often lack the resources to scale up. By involving them — along with civil society — the project seeks to promote a more inclusive and practical CE, increasing the chances of successful implementation.