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Association of Cities and Regions for sustainable Resource management

ACR+

ACR+ is an international network of local and regional public authorities sharing the aim of promoting a sustainable resource management and accelerating the transition towards a circular economy on their territories and beyond.

Lobbying Activity

Response to EU’s next long-term budget (MFF) – implementing EU funding with Member States and regions

29 Oct 2025

Together with its Local Alliance partners - a coalition of Europe's leading local and regional governments - ACR+ aims at ensuring that our constituencies have the competencies and resources to implement and reinforce Europes resilience, competitiveness and decarbonisation. Local and regional governments are Europes frontline for delivering change, but the Commissions proposal for the next MFF risks sidelining local and regional governments who are best placed to deliver. A centralised approach, which does not reflect the local realities and priorities, not only threatens delivery on the ground, but also Europes long-term societal, democratic and economic resilience and competitiveness. Our attached position paper offers 10 points to make the MFF work for cities and regions. We ask for stronger multilevel governance, a stronger partnership principle, mandatory regional and territorial chapters within NRPPs, earmarked funds for the just transition, a workable EU Facility for cities, safeguarding for cities and regions, meaningful performance indicators, recognition of cities and regions as innovators and investors, a continued Mission approach under Horizon Europe, and strong support for accession cities and regions. The success of Europe hinges upon the success of its cities and regions.
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Response to Circular Economy Act

27 Oct 2025

Advancing the circular economy is imperative for Europe. Beyond its core benefit of waste and resource-use reduction, it is also a strategic lever to boost competitiveness, rejuvenate industrial capacity, and minimise import dependency. This is why ACR+ ( https://acrplus.org ) welcomes the European Commissions commitment to introduce a Circular Economy Act by 2026. Drawing upon more than 30 years of experience and lessons learned during EU-funded projects as well as the expertise and practices of local and regional authorities across Europe ACR+ is sharing its recommendations to ensure that the Circular Economy Act is an opportunity to make circularity a central pillar of EU competitiveness, climate action, and social progress. Read ACR+ position on the EU Circular Economy Act This position paper outlines 26 recommendations to strengthen the EUs circular transition, focusing on: - Establishing a Circular Single Market with binding targets to increase circular material use and reduce residual waste; - Leveraging public procurement to drive demand for sustainable and circular products; - Reinforcing Extended Producer Responsibility (EPR) to support prevention, repair, and reuse; - Tackling Waste from Electrical and Electronic Equipment (WEEE) through stronger collection, treatment, and recovery of critical raw materials; - Creating a more circular built environment via sustainable (de)construction practices; - Advancing circularity in food and organic material systems, supporting the circular bioeconomy and tackling waste; - Ensuring that the circular economy benefits all citizens and regions, creating fair and high-quality jobs across Europe. Discover our recommendations in the attached file
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Response to Towards a Circular, Regenerative and Competitive Bioeconomy

23 Jun 2025

HOW CAN THE EU BIOEOCNOMY STRATEGY SUPPORT CITIES AND REGIONS IN THEIR TRANSITION TO CIRCULAR BIOECONOMY? Although bioeconomy relies on renewable resources, it is not necessarily circular by essence, and that circularity is not a given in biobased systems. To be circular, biobased systems must prioritize an optimised use of locally available materialsparticularly from waste and secondary sourcesbefore resorting to primary biomass extraction. These materials need to be kept in use for as long as possible and, at the end of their lifetime, be harmless when re-entering the biological cycle.Currently, several barriers hinder the shift to bio circular models in Europe: environmental trade-offs, socio-economic barriers (lack of knowledge and education) and financial (lack of support and business sustainability), a non-level playing field with linear value streams (competition with cheap fossil resources and optimized value chains), governance and policy barriers, as well as technological and logistic barriers (lack of knowledge on available feedstock and of adequate local infrastructure to valorize it, as well as lack of low development of technologies). The still weak investment on secondary raw material markets is also an obstacle to circularity. Local and regional authorities have a crucial role to play for enabling the transition to circular bioeconomy, through planning via CBE strategy, facilitating collaboration among local players, and through setting policy, legal, and economic instruments to foster CBE value chains/projects. To maximise impact and enable this shift, the revision of the EU bioeconomy strategy should foresee technical and financial support for European cities and regions. The recommendations below stem from concrete experiences of some ACR+ members (FADI (RO), Zero Waste Scotland (UK), Fryslan (NDL), Pays de la Loire (FR), Region Wallonie (BE), Lipor (PT)as well as EU funded project results. 1)COLLECTION AND ANALYSIS OF DATA ON SECONDARY MATERIALS -Introduce a postal code system at the NUTS3[1] level to enable precise tracking and mapping of resource flows. This would allow policymakers and entrepreneurs to understand where resources are generated, processed, utilized, and disposed of, facilitating better decision-making, innovation and planning. The above system will allow to monitor what is the percentage of materials that are generated within a specific regional zone, and what percentage comes from elsewhere. This system will also simplify the computation of environmental impact assessment through the use of LCA. -Encourage regions to develop resource maps (local biomass, industries, and workforce strengths) at the local level (i.e Scotland Bioresource Data Tool) 2)SUPPORT SKILLS DEVELOPMENT AND JOB CREATION -Funding for vocational training and curricula on bioeconomy and circular bioeconomy (i.e expansion of Erasmus +). The free online trainings by the SCALEUP and Hemp4circulairty projects provide a good example for the content and structure of these courses. -Establishing an EU-wide certification to standardise skills and improve mobility that covers key areas like biomass processing and circular design -Strengthen universities' capacity to integrate bioeconomy and circularity concepts across a wide range of academic programmes, from engineering and economics to the social sciences 3)STAKEHOLDER ENGAGEMENT -Support financially the establishment and maintenance of peer learning platforms, where regions can exchange best practices and success stories (i.e ECESP) -Promote technology and innovation clusters for stakeholder engagement (i.e Scottish Ocean Cluster, Fryske Hemp Fiber Deal) 4)BUSINESS SUSTAINABILITY -Strengthening public procurement for secondary bio-based products and services, through EU guidelines on GPP criteria for bio-based products -Providing guidance to EU regions on how to identify and support sustainable bioeconomy business model
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Response to Policy agenda for cities

23 May 2025

The Association of Cities and Regions for sustainable Resource management (ACR+) connects 48 local and regional authorities from 15 countries leading the transition to a collaborative circular economy. With expertise supporting cities and regional authorities to achieve sustainable resource management, ACR+ welcomes the call for evidence for an EU Agenda for Cities. Cities are central to delivering EU policies. Beyond implementation, they serve as investors, innovators, consumers and producers. At the same time, cities do not stand alone. Regions provide the material resources and energy that power cities' contributions to EU priorities. Recognising the shared importance of both cities and regions, a territorial approach is needed to deliver goals including decarbonisation, competitiveness, and social cohesion. By positioning local and regional governments at the heart of the transition, supported by flexible regulations that accommodate diverse local needs, a bottom-up planning approach can leverage local skills, expertise, and resources to best support industry, businesses, and SMEs. Furthermore, with respect to territorial hierarchies, local actors should be empowered to design and implement local solutions wherever such solutions are best positioned to secure lasting environmental, social, and economic sustainability. To achieve this, capacity building among local authorities and public servants is fundamental. Adopting a peer-to-peer approach toward capacity building like the EU Taiex (Technical Assistance and Information Exchange) could harness and multiply the expertise of local actors from all 27 Member States via workshops, expert missions, and study visits. No single city or municipality can tackle industrial or ecological challenges alone. Stronger cross-border cooperation between authorities can be strengthened by facilitating joint investment projects, reducing administrative barriers, and aligning regulatory frameworks. In turn, new interregional synergies can accelerate innovation, bridge skills gaps, and strengthen European cohesion all while bolstering resilience and competitiveness. Finally, cities must embrace the circular economy to achieve well-being for all with respect to planetary boundaries. The Covenant of Mayors for Climate & Energy has already enabled local authorities to become leaders in implementing ambitious European climate and energy objectives on their territory. The scope of this initiative should now be expanded to include circular economy, recognising its potential as a driver of European strategic resource autonomy, climate mitigation, competitiveness, and environmental protection.
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Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

ACR+ views the Social Climate Fund as a critical tool for driving the just transition by addressing the social aspects of the Green Deal policies. In response to the Commission's request for information on the operationalisation of the DNSH (Do No Significant Harm) Principle, we emphasise that a decentralised approach to the fund is essential. This approach ensures that the unique needs and capacities of local and regional authorities (LRAs) are effectively addressed. This aligns with our 2030 strategy, which emphasises the importance of tackling social issues as part of the broader climate transition. The success of the fund hinges on its ability to integrate territorial aspects into its design and implementation. This means recognising the diverse challenges and opportunities faced by different regions and municipalities. A decentralised approach ensures that funding and initiatives are tailored to local contexts, leveraging local knowledge and capacities to maximise impact. Local and regional authorities play a vital role in implementing the Green Deal at the ground level. Their involvement is essential for the successful deployment of SCF initiatives. We advocate for a structured dialogue between the Commission and LRAs to ensure that their insights and experiences inform policy decisions. For example, integrating sustainable consumption and production practices, such as making "green" products and food affordable for all citizens, is crucial. Additionally, implementing the polluter pays principle at the closest level to the waste producer ensures that the biggest waste producers are more effectively taxed, rewarding eco-friendly behaviors. In response to the Commission's request for information on the necessary technical guidance for the SCF, we highlight the crucial need for robust capacity building and technical assistance for local authorities. Many municipalities, especially smaller and rural ones, face significant challenges in meeting new requirements under Green Deal legislation. Strengthening their capacities is essential for the effective implementation of SCF initiatives. Transparency and accountability are key to the successful operationalisation of the SCF. We stress the importance of clear certification processes to ensure that Member States consult with LRAs as intended. This includes establishing mechanisms to monitor and report on consultation processes, ensuring that local inputs are genuinely considered in decision-making. We support the establishment of a regular and direct dialogue between the political leadership of EU institutions and local and regional leaders. This would facilitate continuous multilevel political support, shared responsibility, and better implementation of necessary actions. The SCF presents a significant opportunity to advance a just and inclusive transition by adopting a decentralised approach. We advocate for the integration of local perspectives, enhanced coordination, and robust support mechanisms to ensure the SCF effectively addresses the social dimensions of climate policies. We look forward to continued dialogue and collaboration with the Commission to achieve these goals.
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Response to Promoting sustainability in consumer after-sales

4 Apr 2022

ACR+ welcomes this initiative of the European Commission to encourage consumers to use goods for a longer time and to promote repaired, second-hand and refurbished goods. We would like to highlight some key points that have to be kept into consideration. Please find more clarification in our full feedback attached. Legal and economic instruments are needed both on demand and supply side: - Product policy. We refer to the inclusion of repair and reuse not only in a waste policy but particularly in a product policy based on binding instruments supported by specific indexes (material passport, repairability and durability index). ACR+ supports the implementation of a high-level intervention to impose to the producers to facilitate repair (specific repair manuals, provision of spare parts, repair tools available). - EPR and fee modulation. These economic mechanisms can play a relevant role to improve the environmental performance of the products while also financing awareness raising and communication campaigns, and repair initiatives. - Instruments of public authorities. Public authorities can use their competence related to VAT and act on public procurement to support repair activities, but also sharing economy initiatives. - Targets on waste prevention. ACR+ supports the setting of targets to decrease the amount of residual waste and also prevention targets addressing the total waste production as well as specific product categories. - Extension of legal guarantee. While supporting the Option 3 listed on this consultation, we suggest a longer extension of the guarantee period for refurbished goods, as further support to repair activities. This additional measure aims also at building a sense of trust of consumers on refurbished products. The initiative should also tackle the challenge of social acceptance and right to information by supporting: - Public awareness campaigns. Second-hand, repair and reuse should become part of the European culture. For this, several and coordinated awareness raising and communication campaigns should be supported and the EPR schemes could be a helpful source of funding. - Instruments to share information with the consumers. Universal and specific standards such as a material passport, indexes on repairability and durability would support the consumers in taking aware choices but also to promote eco-design long-lasting products.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

ACR+ welcomes the European Commission’s proposal to revise the EU Waste Framework Directive. Setting mandatory targets to reduce municipal waste generation is necessary to force national governments and local and regional authorities to take action on waste prevention and to have quantifiable results. ACR+ supports the target proposed by ZWE to reduce municipal waste generation by 20% to be achieved in 2030 and 30% by 2035. We call for waste reduction targets for specific streams like textiles, packaging, food waste, WEEE and CDW. Re-use targets for EEE, packaging, textiles, furniture, ELV and CDW components, distinct from recycling are equally important. These should include preparation for re-use instead of having it counted with recycling. Product specific binding prevention measures would contribute to reduce waste generation. For packaging: support to reusable, improved essential requirements, ban on small packaging, and standardized refillable bottles would favor effective DRS systems. Individualizing separate collection, with the identification of the citizen, gives good results. Separate collection can also be improved via pre-collection equipment for vertical housing, direct targeted communication, incentives or adaptation of collection modes for challenging areas. LRA should be free to choose the most suitable system based on local conditions. We support the introduction of minimum requirements for source segregation and separate collection. Sorting guidelines should be more consistent, at least at national level. Different systems bring confusion and lead to heterogeneous sorted materials. Know as You Throw, a tool for raising awareness, should be further explored. Knowing what is not sorted out gives an indication on the products to address. Promoting the use of regular and consistent composition analysis at the local level is recommended. To measure sorting efficiency and quality of sorted materials as well as trace the final recycling there must be a better traceability between collection and the "final recycling process’’. It would contribute to better assess recycling performances of individual municipalities that need to pay more attention on the quality of separately collected waste. Tax on landfilling and incineration is key to favour prevention and separate collection. Its revenue should be distributed as an incentive to local authorities based on e.g. their biowaste separate collection performance as in Catalonia. Reuse and preparation for reuse/repair centers should accompany the mentioned collection systems. To promote re-use activities, we call for more cooperation between waste authorities and re-use entities and financial coverage through EPR schemes. Performance-based contracting should be further explored (cf report). The contractually agreed payment mechanism in relation to defined performance indicators and targets incentivises the movement of waste management further up the waste hierarchy. We welcome the target for collection of waste oils and the study to assess the feasibility of setting a cap on food waste in mixed waste (in kg/inh). EPR principles should be expanded to other products such as textiles, furniture, nappies, and mattresses (with modulated fees based on environmental performance). Eco-modulated producer contributions considering reparability, durability and recyclability should be implemented and enforcement should be ensured. According to the results of the ACR+ study on DRS, countries reaching nearly full collection of PET bottles are operating DRS whereas countries without DRS reach 48% (cf study Eunomia). We suggest investigating an EU DRS in order to reach the 90% collection of PET bottles, this would also help avoiding market fragmentation. Moreover, DRS guidance for member states would facilitate its implementation.
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Response to A new Circular Economy Action Plan

20 Jan 2020

ACR+ --- the Association of Cities and Regions for sustainable Resource management --- welcomes the European Commission’s efforts to devise a new Circular Economy Action Plan (CEAP) Roadmap and the targets it sets out to achieve, as described in the reference document for this stakeholder consultation Ref.Ares(2019)790787-23/12/2019. Our network of over 100 cities and regions spans 25 countries in the EU and its neighbourhood. We have been promoting the sustainable management of material resources and the circular economy at the local level for over 25 years through technical exchanges of know-how among local administrations and between them and other actors. Drawing on our extensive experience, we would like to highlight and add a few points in addition to those already listed in the abovementioned document. 1. In their role as regulators and facilitators, public authorities are key to the successful transition to the circular economy. Not only do they oversee the implementation and enforcement of laws directly through relevant institutions and instruments, but they also act as examples for other societal actors in their jurisdiction(s) to follow. 2. Good governance is essential to a successful transition away from a throwaway economic model. However, governance needs to be informed by science. In this regard, ACR+ would like to draw your attention to two gaps that we recommend the upcoming plan addresses: A. There is insufficient research substantiating the impact of the circular economy on climate change mitigation at the moment. Establishing the link between the two areas is important in order to design effective policies. B. Effective governance requires good metrics to benchmark and measure impacts. ACR+ recommends that the upcoming CEAP highlight the importance of identifying and establishing pertinent circular economy metrics. Furthermore, governance is as good as the people behind it. Therefore, investing in training the employees working at different levels of governance and, more broadly, EU citizens in general in the circular economy is important to achieving a successful transition. 3. Two recommendations regarding the sustainable products policy mentioned in the reference document: A. Aside from effectiveness, equity should be taken into consideration when designing this policy. Many Europeans cannot currently afford to choose the more sustainable alternatives on the market because of their higher prices. Likewise, fiscal incentives and other instruments promoting sustainable behaviour should be progressive, so that the economic burden is lower for consumers with limited means. B. The policy should encourage repairability and lowering the overall impact of products throughout their lifecycles. Existing policies, such as the revised Ecodesign Directive, are a first step in this direction, but are insufficient. The new policy should target all applicable consumer products and expand the ambition concerning repairability, planned obsolescence, and end-of-life treatment. 4. In order for the CEAP to be effective, targets and measures need to be binding; our experience indicates that actors do not respond quickly and effectively to voluntary instruments. Concretely, ACR+ recommends that the upcoming CEAP include the following: a. a mandatory minimum recycled content requirement for applicable products; b. the targets and measures stipulated in it are urgent enough for stakeholders to take action straightaway; c. producers bear the cost of handling products at the end-of-life and that market prices reflect all their environmental and social externalities, including littering. Included in the attachment are three of our recent technical publications substantiating our recommendations. ACR+ thanks you for the opportunity to participate in this stakeholder consultation. We remain at your disposal if you have any questions and look forward to reading the CEAP Roadmap.
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