Hogeschool van Arnhem en Nijmegen (HAN University of Applied Sciences)
HAN
HAN is considered the top university of applied sciences in the region by companies, institutions and individuals alike.
ID: 07558879697-95
Lobbying Activity
Response to Circular Economy Act
23 Oct 2025
HAN University of Applied Sciences welcomes the European Commissions Circular Economy Act initiative. As an active member of the Dutch Association for Circular Economy (NVCE), the topic aligns with our mission and strategic priorities. The initiative supports national and regional goals, including the Regional Innovation Strategy for East Netherlands. Circularity is one of five core themes of our regional triple helix network, Think East Netherlands. Universities of applied sciences (UAS) like HAN play a key role in developing and testing circular solutions through practice-based research and education. We work with SMEs, municipalities, civil society, and end-users in projects and living labs focused on circular design, material reuse, and sustainable business models. --- Strategic Resource Autonomy: The Netherlands is highly dependent on (critical) raw materials. A circular economy is essential to reduce this vulnerability. By recovering critical materials, keeping them within the EU, using them efficiently, and finding sustainable alternatives, including reuse, we can strengthen strategic autonomy and resilience. --- Preconditions for Effective Circular Policy: To accelerate circularity, EU and national policies must be aligned and measurable. Harmonized definitions, targets, and monitoring frameworks are essential. A major barrier is outdated waste legislation, especially in the Netherlands, where materials labeled as "waste" are often restricted from reuse due to health classifications. Laws must distinguish between real health risks and safe reuse to unlock circular innovation. --- Fair and Effective Responsibility in the Value Chain: Extended Producer Responsibility (EPR) is fair for all actors and stimulates circularity as high up the R-ladder as possible. It should be expanded to more product groups and linked to design-for-reuse and recyclability. --- Incentives and Measurement Tools: The EU should adopt true pricing by internalizing environmental and social costs into product prices. Currently, these costs are externalized, making sustainable options less competitive. For example, recycled plastics often cost more than imported virgin plastics, despite their lower environmental impact, distorting the market and undermining recycling. To address this, the EU should introduce taxation or pricing mechanisms that discourage harmful products and reward sustainable ones. The Environmental Cost Indicator (ECI) can support this by providing transparent, comparable data on environmental impacts. Integrating ECI into procurement, labeling, and fiscal policy would help scale circular and biobased business models. --- Material Transparency and Innovation: Improved material labeling and traceability are essential, especially for complex or composite materials. Without this, recycling and reuse are hindered. This applies to both biological waste streams and virgin biobased materials (e.g., hemp, bamboo, wood), which are often overlooked in policy. These renewable alternatives to fossil-based resources should be supported through labeling, incentives, and market development. --- Empowering Regional Innovation for a Circular EU: The EU must strengthen regional innovation ecosystems, where universities of applied sciences act as key facilitators between education, research, and industry. These ecosystems are vital for translating circular ambitions into practical solutions. We recommend: -Improved access to and alignment between funding instruments (e.g., Horizon Europe, LIFE, Erasmus+) for practice-based research and education. -A stronger focus on talent development, embedding circular skills in curricula and lifelong learning, and fostering interdisciplinary learning and reskilling. By aligning funding, education, and regional innovation, the EU can build a resilient, inclusive, and future-proof circular economy. HAN UAS is open to further dialogue with the Commission on the Circular Economy Act and its implementation.
Read full responseResponse to European Research Area (ERA) Act
8 Sept 2025
As HAN University of Applied Sciences, we fully support the development of an ERA act, to contribute to the 3% investment commitment, alignment across borders, and strengthening the circulation of knowledge and researchers. Europes first research legislation must enshrine the 3% R&D investment target as binding for all member states. Voluntary agreements have failed to deliver sufficient progress; legal mechanisms and consequences are needed to ensure compliance by 2030. Investment targets should be harmonized at EU level, to keep member states accountable for the ambitions they already agreed on. To reduce fragmentation, the ERA Act must align investments and policies across the EU in close cooperation with stakeholders and member states. Existing platforms like ERAC and the ERA Forum must be preserved to ensure meaningful participation, including by universities of applied sciences (UAS). Framework conditions must be concrete and build on existing initiatives. The Act should remove barriers to researcher mobility and ensure free circulation of data and research results, embedding the fifth freedom. This includes integrating education, improving access and infrastructure, and aligning with open science and EOSC. Education must be part of the ERA Act. It is essential for academic freedom, recognition of qualifications, and international cooperation. Inclusive research assessment (e.g. CoARA) and integration of the knowledge triangle (research, education, innovation) are key to attracting and retaining talent. Integrating education in the ERA Act is also essential for legislative anchoring of academic freedom, as the European Parliament has called for. This step is also vital to strengthen international cooperation and to attract and retain talent. The Act must also advance open science and fair data policies at the EU level, and stay in in close synergy with the EOSC. Lastly, specific attention is needed for the recognition of practice oriented and applied research as an essential part of the R&D ecosystem. As such, Universities of Applied Sciences (UAS) play a pivotal role in connecting research, education and the field towards valorisation and impact. - We stress the importance of looking at research, development and innovation along all TRL-levels, and further expand the scope to include SRL-levels. Look beyond fundamental research and draw the full line towards market and societal uptake, to make sure investments have ample potential to provide a return to the EU and its member states. - To do this, it is important to give sufficient space for Universities of Applied Sciences in the European innovation ecosystem. Practice oriented research should be receive an adequate share of the 3% goal, to allow research to develop from fundamental research to market implementation. UAS are a crucial link the innovation chain. - Apart from being this crucial link in the R&D ecosystem, UAS can play a strong role in realising the fifth freedom of movement. Deeply rooted in regional ecosystems, UAS can benefit from and contribute to better access of researchers to means, mobility and knowledge in regions throughout the EU. - To support this, UAS need the ERA act to include measures towards an not only attractive but also diverse research landscape. Part of this landscape should be appropriate appreciation of multi-track careers and broad space for UAS in (new) European University Alliances. - Strengthening the alignment between national, private and European investment should be combined with the stimulation of further investments. Synergies should be supported by policy. Policy should also reduce the administrative burden and increase alignment, which ways particularly heavy on (relatively) smaller research bodies, including most UAS.
Read full responseResponse to A New European Innovation Agenda
20 Apr 2022
As HAN University of Applied Sciences (www.han.nl) we think that it is good to support medium and long-term investments at European, national and regional level and thus initiatives with resources that can be used as leverage. These initiatives are currently mainly aimed at making entrepreneurial talent attractive for innovative technologies that support the use of AI for cancer research, key technologies such as photonics, start-ups in the pharmaceutical industry, hydrogen, green chemistry, making the industry more sustainable and digitization in the logistics sector and such incentive. This means that attention will also have to be paid to the social, digital and climate challenges we face. This must be taken into account.
The resources should be conditional on contributing to economic growth, strengthening research and innovation ecosystems and Europe's international knowledge and competitiveness. This also means that entrepreneurial talent must have the access to realize scale-ups and that a reinforcement of education and research and attention to innovation from the entire higher education sector is necessary. A integral, chain approach must be used in collaboration with the business and industry community, including scouting and guidance.
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