Circularise
To radically shift the global economy to the circular model.
ID: 254586698080-86
Lobbying Activity
Response to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market
31 Aug 2025
Circularise is a technology company advancing the circular economy by enabling traceability and secure data exchange across global supply chains. Our Digital Product Passports (DPPs) support businesses and consumers alike in accessing trustworthy information on products carbon footprint, material composition, and origin, while safeguarding data privacy and ensuring interoperability across sectors. By providing reliable insights into product sustainability and safety, DPPs empower consumers to make informed decisions and build trust in the Single Market. The latest EU Consumer Conditions Survey highlights persistent challenges faced by citizens in exercising their rights and making confident purchasing decisions. Cross-border e-commerce, in particular, has led to the growing presence of unsafe or non-compliant products entering the EU market, often accompanied by incomplete or unclear information. Consumers environmental intentions also remain partially reflected in actual behaviour, as sustainable choices are not consistent, comparable, or affordable. These barriers create fragmentation, weaken consumer confidence, and limit the ability of citizens to drive the green and digital transitions through their purchasing power. To close these gaps, the new Consumer Agenda must place transparency, safety, and accountability at the heart of product lifecycles. DPPs provide a strategic, ready-to-deploy solution to achieve this. By embedding verifiable and up-to-date data into every product, they ensure that consumers are protected from unsafe or non-compliant goods while gaining the tools to assess environmental performance. This reduces the asymmetry between what consumers expect and what businesses disclose, helping create a level playing field. DPPs are also a fundamental instrument to substantiate green claims. By providing clear, product-specific data on sustainability parameters, they allow companies to back up their environmental marketing with verifiable evidence and enable consumers to distinguish between genuine and misleading claims. The EU would then be supported in combating greenwashing and making environmental communication transparent, reliable, and comparable across the Single Market. Beyond consumer protection, DPPs are designed to be accessible to all. They can be generated in multiple languages, allowing every consumers to understand product information without complexity, and enabling EU authorities and consumers alike to access reliable data for goods imported from third-countries. This multilingual and interoperable functionality ensures that transparency is not confined by geography or language, but becomes a consistent feature of the EU market. DPPs also serve consumers beyond the point of purchase by capturing and updating information throughout the entire life cycle of a product. This means consumers, repairers, and recyclers can easily access data that facilitates reparability, reuse, and recycling. By extending product lifetimes and enabling efficient recovery of materials, they reduce waste and associated costs, ensuring that consumers do not lose money on products that could otherwise be repaired or resold. This life-cycle approach not only empowers consumers but also contributes to Europes strategic objectives on circularity and resource efficiency. For these reasons, the Consumer Agenda should not limit DPP deployment to the product categories envisioned under the Ecodesign Regulation (ESPR). Extending DPPs to a broader range of goods will ensure that, in the future, all products circulating in the EU can move with a passport. Only then can consumers truly benefit from uniform levels of safety and transparency. The new Agenda is a unique opportunity to place consumers at the centre of the Single Market and make them active participants in the green and digital transitions. Extending the use of DPP, Europe can ensure that consumer rights, market integrity and environmental sustainability.
Read full responseResponse to Proposal amending the Batteries Regulation (EU) 2023/1542 as regards battery due diligence obligations
31 Jul 2025
Circularise is a technology company advancing the circular economy by enabling traceability and secure data exchange across complex global supply chains. Our Digital Product Passports (DPPs) support companies in tracking critical product information such as carbon footprint, material composition, and origin, ensuring interoperability, data privacy, and supply chain accountability in, among others, the battery sector. Circularise does not recommend postponing the mandated use, as it hinders a future-proof, digital, competitive, and sustainable European economy and delays further innovations safe-guarding the material supply for EU businesses and reducing geopolitical risks to European economic independence. Overall, the EU Commissions simplification efforts to reduce administrative burdens by at least 25% should not come at the expense of regulatory effectiveness. While on the one hand the proposed postponement may offer companies additional time to adapt, on the other it risks undermining the momentum toward building a transparent and responsible battery value chain in a time when the demand for batteries is rapidly accelerating. Experience shows that many companies delay concrete implementation of regulatory requirements, such as the same battery passport, until the final stages of enforcement. Therefore, while some actors have already taken significant steps to comply with the Battery Regulation, others are likely to continue deferring actions if obligations are postponed. As a result, the same implementation challenges will risk resurfacing at a later stage. Timely implementation of traceability and due diligence solutions is not merely a compliance issue, but the starting point to reach the Unions climate goals, digital transition, and industrial competitiveness. Furthermore, a delay in enforcing these obligations risks generating regulatory uncertainty, which weakens investment signals and disincentivizes early movers. Fragmented market conditions, disadvantaging companies that have already invested in traceability and compliance infrastructure would represent a missed opportunity to enhance supply chain resilience and promote ethical sourcing at scale. Battery Passports are mature, ready-to-deploy solutions that enable industry actors to meet due diligence and sustainability requirements. They facilitate secure, automated, and interoperable data exchange without compromising commercial confidentiality. Postponing their mandated use delays further innovations, emissions reduction, and responsible sourcing and the overall progress towards circularity. Europes sustainability ambitions require a stable, forward-looking regulatory framework to drive meaningful outcomes, not just within the battery sector, but across critical raw materials and the wider industrial landscape. Only through timely implementation of these provisions a future-proof, digital, competitive, and sustainable European economy can be ensured.
Read full responseResponse to Industrial Decarbonisation Accelerator Act
8 Jul 2025
Circularise is a digital technology company advancing the circular economy by enabling traceability and secure data exchange across global supply chains. Through our Digital Product Passports (DPPs), we enable companies to monitor and manage information along their supply chain, such as material composition, provenance, risk, quality, sustainability,while guaranteeing data privacy across complex industrial ecosystems. The Industrial Decarbonization Accelerator Act offers a timely and necessary step toward transforming Europes energy-intensive industries. To be truly effective, this legislative framework must go beyond voluntary initiatives such as the carbon label. Indeed, to meet the EU climate neutrality goals while preserving strategic autonomy, the Union should create mechanisms not only to incentivize decarbonized production but also to discourage linear business models that generate avoidable waste, emissions, and inefficiency. Mandatory mechanisms are feasible whenever clearly scoped, started with time and consistently applied across all actors of the industry. Building on the Ecodesign for Sustainable Products Regulation (ESPR), the scope of DPPs should be incentivized and broadened to further products and extended across a wider range of sectors and circular practices. Labels should not be limited to consumer-facing communication tools but as an integral components of cross-sector data infrastructures, preventing unfair competitions and assuring a level playing field within the single market. Many business in Europe are already working at different quality and sustainability standards. Mandatory mechanisms to label such practices will only strengthen European businesses towards unfair external competition. Mandating labels for energy-intensive industries (EIIs) would not only ensure regulatory compliance but the actual acceleration towards decarbonization, reducing GHG emissions in a costly efficient way. Traceability systems such as DPP serve exactly this function. By enabling automated, standardised, and interoperable emissions tracking in every step of the supply chain, these tools reduce costs for businesses, minimize human error, and support better-informed procurement, production, and investment decisions. As such, they contribute directly to industrial competitiveness and resilience. Leveraging on digital infrastructure to support the efficient use of secondary raw materials and the reduction of waste, would give EIIs a concrete opportunity to treat data as an asset. Industry actors could in fact reduce dependency on primary materials, exchanging key information without compromising intellectual property or commercial confidentiality. Once consistently applied efforts to assess the sustainability of supply chains go much beyond decarbonization and end up revealing bottlenecks in supply chains. The resulting insights of increased transparency in business practices will strengthen European businesses, enable them to make their supply chains more resilient and opt for material supply that is not at risk to be impacted by geopolitical challenges. However, the ongoing simplification efforts risk undermining the very due diligence obligations that underpin emissions accountability. Simplification should not compromise regulatory effectiveness. Both investors and public authorities rely on credible and consistent emissions data to evaluate performance, assess compliance, and support informed decision-making. A robust Industrial Decarbonisation Act, as part of the Clean Industrial Deal, should reinforce, not dilute, support for clean innovation. It must help unlock private and public investment, by creating the right conditions for emerging technologies to scale and turn Europes decarbonisation goals into tangible, measurable outcomes that strengthen the European production and independence of supply chains.
Read full responseResponse to The EU Cybersecurity Act
20 Jun 2025
Circularise is a technology company at the forefront of digital transparency and traceability in global supply chains. Through our Digital Product Passports (DPPs), we enable secure and standardized data exchange across a wide range of industrial sectors. Our solution supports regulatory compliance while directly contributing to the development of sustainable, resilient, and transparent value chains. As a provider of digital infrastructure for data management, cybersecurity constitutes the essential enabler of trust, data integrity, and operational resilience. An integral navigator for complex, cross jurisdictional and multi-tiered supply networks. The secure handling of sensitive and business-critical data across product lifecycles is a foundational requirement to the reliability of digital systems, supporting both the EU green and digital transition. Robust cybersecurity safeguards are needed for data integrity, verifiability and confidentiality, without compromising interoperability or scalability. Traditional digital identity solutions, such as those relying on Source Authentication mechanisms like Self-Sovereign Identity (SSI), Decentralised Identifiers (DID), and Verifiable Credentials (VCs), base trust primarily on the reputation or identity of the issuer of a claim. For example, a supplier may assert that a material is sustainable, and trust is derived solely from the supplier's credibility. This identity-based approach limits the concept of trust to the entity making the claim, with no embedded capacity to independently verify the accuracy or integrity of the underlying data. Moreover, trust established within a single industrial system is often not transferable across sectors or jurisdictions. On the contrary, leveraging on blockchain technology and zero-knowledge proofs (ZKPs) allows to establish trust through cryptographic evidence rather than reputation. This approach ensures that claims are supported by immutable, independently verifiable data trails. It prevents silent post-hoc manipulation and reduces inconsistencies in data entry, all while preserving privacy and intellectual property through selective disclosure. Trust is then built on procedural integrity rather than on the issuers identity, making it possible to scale secure and credible data exchange across industries and jurisdictions. The revised cybersecurity framework should then remain technologically neutral and focused on verifiability rather than on specific implementations. Legislation should describe the desired outcomes - such as data integrity, provenance, and confidentiality - without mandating a specific architecture or technology. Equally, certification process should be accessible and tailored to the diverse profiles of ICT service providers. Finally, high cybersecurity standards should be maintained without imposing disproportionate barriers to market entry or innovation. As the EU continues to advance its strategic objectives, cybersecurity policy must evolve in parallel to support trustworthiness and resiliency of its digital infrastructures. While a harmonised European framework for cybersecurity and data governance is necessary to ensure consistency in data-sharing practices, security and privacy standards must remain high. Simplifying reporting obligations and cybersecurity compliance must not lead to deregulation or the erosion of data safeguards. Data communication systems that foster secure and sustainable supply chains are no longer optional - they are essential to industrial competitiveness and economic sovereignty.
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